Dear TXEB 9a,

Now that you have identified and openly attacked me on a public website, it is time that you identify yourself. I am surprised that as a " respected career research scientist"
you would resort to ad hominum attacks, rather than addressing the legitimate concerns that have been raised by me, by other commentators on this forum, and by many scientists, citizens, environmental, health, and farm groups across the nation.
Yes, and by the Cornell Waste Management Institute, whose soil scientists have , since 1985, published hundreds of accurate, and unbiased papers about the risks linked to using sludge as fertilizer:

http://cwmi.css.cornell.edu/case.pdf

Dr. Snyder - you identified yourself, and I never attacked you. In fact, I openly stated you have " raised a number of valid concerns, many of which I share".

I never identified myself as a " respected career research scientist" as you mistakenly quote, I simply stated I was a career research scientist, never claiming any degree of respect for myself. Apparently you have difficulty even getting the quotes correct.

I already identified the Cornell Waste Management Institute's work as a credible source of scientific information on the subject, so I really don't get your point in repeating that.

I will point out that you began the attack by asserting that I was "misleading gardeners" and later again stating I was "misleading readers".

In the first you stated I was "implying that all sludge composts are regulated and produced like Milorganite". If you re-read what I stated it had nothing to do with compost. As I hope you well know, but it is not apparent that you do, Milorganite is not a compost. It is simply a treated sewage slude, never subjected to composting. My statement on the matter began "Don't know about any other version, but Milorganite is...". The topic was sewage sludge as fertilizer, not compost. The compost topic came up later in the thread.

In the second attack you characterized my "misleading readers" as one of "by failing to point out". I failed to point out nothing. Rather than to cherry-pick only a quote I referenced the entire report and provided the means to access the entire report. I did quote the "Overreaching Findings" from the summary to correctly state what you appear to have mischaracterized in report stating "that the current rules are based on out-dated science and flawed risks assessment models ". The report made no such allegation. The summary speaks for itself, which is how I presented it rather than point to your errant characterization.

I made no attack. I did provide my own, personal assessment of how you have presented your arguments in any number of venues and though any number of media sources, as well as the scientific quality of those presentations. I will add that it seems you prefer to lead by alleging that anyone who suggests anything that is inconsistent with your agenda is "misleading" the broader audience. You have done it with your long-time opponent Ned Beecher, you've done it with Dr. Michael Klag, and you did it twice here with me in just this thread.

Dr. Snyder, you were the attacker, and you identified yourself. It is that simple. If you don't like the heat, then kindly stay out of the kitchen.

Just watching this one with interest. A brief visit to the sludgefacts website was enough to confirm the lack of rigorous science and evidence observed by TXEB and nc-cm.

For example, there is a list posted of "Contaminated Branded Products" that claims to list products with 'toxic ingredients and industrial waste.' Yet there is nothing to back up this claim or how those categorizations are made. "Industrial waste" could be shredded pine bark from a sawmill, unless you're going to define it otherwise. That's the problem here, a lot of scary terms without clear definitions and verifiable information.

BTW I work with some 'superfund sites'. There is a great variety in toxicity and concentration of contaminants, and there are strict limits on what may be discharged to sewers.

I could go on and on challenging these vague claims. I have no wish to ridicule or dismiss. If you want to gain acceptance, learn from the comments made here and improve your case.

seems to be drifting well into paranoia and personal attacks now, with no hard facts to back up outrageous claims of this and that, i talk from around 15 years experience and many chats online but now these chats are bogged down by followers of false sciences and they write long answers, which many may not even read more than the first couple sentences.

it comes to this we need to look after the planet we simply cannot continue to pollute it, we all know what industrial waste is it is waste from hospitals and all sorts of industry even the local garage, acids included.

i've seen pictures of liquid waste being mixed into the product we talk of, it does make up the basis of nearly all potting mixes etc.,.

yep call me mr potato head i know how to grow potato's easily, but at least i am not paranoid.

instead of theories lets see facts are there any traceable records of cases, i mean cases not s single we think of anyone getting ill or worse, unless they pick their nose after gardening before washing.

len

len

-edit- Nevermind...I've said all I want to say about the issue...I'm just repeating myself at this point.

This post was edited by nc-crn on Fri, Apr 19, 13 at 15:58

len: I certainly agree with taking care of the planet. I do it all day at work and at home.

But I don't see how these are a problem:

"...we all know what industrial waste is it is waste from hospitals and all sorts of industry even the local garage, acids included. "

Hospital sewage? How is that different from other sewage, in a way that persists into the product?

Acids? The sewage treatment process - in fact, even the mixing with other sewage prior to arrival at the plant - tends to neutralize small volumes. Don't see how this is a toxic threat.

"i've seen pictures of liquid waste being mixed into the product we talk of, it does make up the basis of nearly all potting mixes etc.,. "

"Liquid waste" is pretty vague.

Yes, there are potential issues with pathogens and toxins. That's why we're all talking about it. But vague terms like this don't help focus the discussion on specific problems.

nothing vague about liquid industrial waste, in your mind maybe but not mine, it sticks it is full of greases fats and acids et.,. you really need to become aware if you are going to be a credible advisor. you cannot base your observation on organic or gov' or world gov EPA regulators, they move the bar up and ever upward to suit needs, they have no impartial umpire to keep them honest.

the vagaries are in the minds of the holder.

the gov's had a lot of dangerous liquid wastes to get rid of so like flouride they give it back to the people.

ok? what happens here happens in the world leader US, and what happens in the US happens here, i'm not so naive as many to think otherwise.

have a nice one though run with wisdom less paranoia.

len

Dear TEXEB 9a, nc-crn 7b, and toxcrusade 5

Why do you refuse to identify yourselves? You know a lot about me. I know nothing about you. Not even your names. Are you afraid of an open and honest debate?

I never ID'd you...let's stick to the subject at hand...which isn't you. We don't need to make it about you.

I'm a plant breeder, geneticist, and soil scientist (degree holder in 2 fields (horticulture/soil) and professional proxy experience in the other (genetics)). Because of my field of work, I choose to not expose myself on the internet. You, however, do choose to expose yourself on the internet...and push your website and testimony and your own works.

What I do doesn't matter, though. This entire field and subject moves and exists independent of me no matter how much experience I have with it (which is a whole lot more than your common home gardener).

This post was edited by nc-crn on Fri, Apr 19, 13 at 18:21

I'm with nc-crn. I could care less about you or your agenda, and I am sure you feel the same way about me. Based on what I've seen thus far, as I said in my very first reply, I haven't seen anything that merits any "debate".

My issue with sludge is disclosure. I would like to know if and when I am using it and then selectively choose how I use it. Sludge is now called biosolids and sometimes just compost. Go to the organic forum and everyone recommends *compost* . Go to your local home improvement center and read the labels. You won't find sludge or biosolids, you will find compost. There is a good chance the compost is sludge.

I can go to my water utility and find out what is in my water. I can find a test report. Why can't I find out what is in my compost? It most likely comes from a public treatment plant. Why is it so hard to find out if I am using sludge in my garden?

How does it sneak into the white house organic garden? How does it sneak into Calif school organic gardens? Shouldn't there be more disclosure?

I am thankful for the Dr's efforts even if some of her tactics might be considered *fear tactics* or perhaps not fully scientific. She is most likely working against millions of dollars in a campaign which has been able to recharacterize sludge to biosolids and now compost which is conflated with organic gardening. When someone's heart is in the right place I think a little more latitude is in order.

Just saying

Zeuspaul

This post was edited by zeuspaul on Fri, Apr 19, 13 at 22:34

After a number of diversions, trying to drag this back on topic -- the question was about the safety of using processed biosolids (sewage sludge) as a fertilizer in residential applications.

To my knowledge, the only product that is legally available for home use is that which meets EPA Class A EQ (exceptional quality) requirements. IMHO, it is as safe to use in lawn, turf and ornamental landscape applications as any conventional fertilizer. Personally I choose to not to use it in food production although it is approved for such. My choice is based upon my own biased views of about how food should be grown and how that extends to soil and how I manage my garden soil.

Beyond the class A EQ stuff, I have many concerns, but they do not directly affect what I do on my corner of the earth, nor are they part of the consideration of what the home owner/gardener may be using. As such, I will choose to avoid them in discussion on these forums - I don't see this as the place to get into broad political policy, other than as it affects our practices and decisions as home gardeners.

To zeuspaul's concerns about labeling - I totally agree. This is a case of caveat emptor. Sludge is being used as a nitrogen component to produce composts commercially. Those that meet EPA'a class A requirements may be bagged and sold to the public as "compost" with no indication of what was being composted, be it municipal solid waste, cow manure, cardboard, etc. In general, commercially prepared and bagged compost doesn't come with an ingredients label, whether it contains biosolids or not. If you want to buy compost and avoid that containing biosolids, then about your only options are to buy from a local producer whom you trust and will tell you what they are using, or to buy bagged stuff that is OMRI listed (and there isn't much of that around).

As far as a decision making, everyone needs to decide for themselves. I have no agenda. But as a scientist I urge anyone who has concerns to get the facts from credible and reliable sources, including the unanswered questions, then conclude for themselves if the risks and uncertainties are acceptable to them based upon sound information. The web is loaded with good information and bad information. The challenge will always be separating the two. My experience leads me to first considering the source, and to see if a particular viewpoint or bias is being advanced, and if so on what basis.

With that I have to run - here's comes my date - she's a French model I met on the internet.

This post was edited by TXEB on Sat, Apr 20, 13 at 13:10

In one of his earlier comments TXEB kindly posted the link to the 2002 National Academy of Sciences NRC report: Biosolids Applied to Land. This report summarizes the pollutant concentrations permitted in Exceptional Quality (EQ) sludges given away in bulk or sold in bags:

mg/kg:

Arsenic 41
Cadmium 39
Mercury 17
Lead 300
Copper 1,500
Zinc 2,800
Nickel 420
Selenium 100
Molybdenum --
ceiling concentration 75

In addition, EQ products generated in industrialized urban centers contain countless other unregulated chemical compounds as well as pathogens that can proliferate in cool and moist climates.

A final note: Most experts now agree with scientists at the Cornell Waste Management Institute, that the current US regulations that govern the land application of sewage sludge do not protect human health, agriculture, or the environment.

Good info from Cgsnyder.

For those who may be trying to understand the muddy mess of regulations covering the use of biosolids, a potentially useful summary presentation from the EPA 's Enforcement Training Institute is available as a PDF via the link below. For unrestricted residential use, the appropriate consideration is Class A, Unrestricted Use (EQ Quality).

Here is a link that might be useful: EPA Regulations for Biosolids

This my not pertain to the debate at hand, just a quick question..

From my understanding milorgsnite is not exactly sludge, it Is dried micro organisms,correct? Does anyone use it on their lawn? Does it work good? I am thinking about putting in some fruit trees in the lawn in a few years, would it be safe to use milorganite several times a year, without worrying about future food crops? I'm not familsr with Watse products, I try to stay away from them, but it's a cheap organic fertilizer to green up the lawn..

Appreciate it,,
Joe

Science evolves. That is why we like to use the most recent scientific information and are constantly updating our webpage. For example, the EPA link TXEB posted earlier (Fertilizer Made from Domestic Septage and Sewage Sludge) is 17 years old. For more recent EPA sludge information which includes the 2009 Targeted National Sewage Sludge Survey, go to
http://water.epa.gov/scitech/wastetech/biosolids/

The survey tested sludge samples from 74 treatment plants for a limited number of chemicals. The chemicals were found in every sample. Yet even this survey is already outdated. Since 2009 thousands of new chemical compounds have been added to the waste stream, many of them ending up in sludge. For most there exist not even basic toxicity data.

Same with the 2006 power point,( EPA Regulations for Biosolids) which ignores the findings of the 2002 NRC report. In 2009 the Cornell Waste Management Institute warned that the current sludge regulations are based on outdated and inadequate science. Which is what we have been saying all along.
http://www.sludgefacts.org/Ref105.pdf

Cgsnyder - if you actually go back up an look, you will see I previously referenced posted the URL for the EPA Survey. You're replowing the same ground. Keep up Doc.

The purpose of my previous post was to provide an easy to follow intro to complex regs. Few live in the regulatory law world; I have and am comfortable with them, but most are not..

Raw - Milorganite is Class A EQ sludge that has been very well heat dried. If the plant is being operated correctly, the majority of the sludge solids that are collected are actually the cellular biomass of the microbes that were doing the digesting. I keep my food stuff separate from my lawn stuff. That's a personal bias. On my lawn I have no problem with Class A EQ product. When I lived in MI I used it without reservation for turf/lawn. In my current environment in SE TX I found it to be nowhere near as effective, so I don't use it anymore, but that is solely because of its efficacy. I won't use it for food. You need to make your own assessment and decide for yourself.

This post was edited by TXEB on Sun, Apr 21, 13 at 4:04

Sewage sludge is basically the same thing as 'dried microrganisms'. At least, I would guess the vast majority of the mass is exactly that.

As to who we are...I'm a Ph.D environmental chemist with an emphasis on environmental toxins. Worked for a couple years in a contract lab doing env. fate studies on pesticides and pharmaceuticals for manufacturers to support their FIFRA and FDA registrations. Wasn't really thrilled about helping put chemicals INTO the environment. Now I oversee hazardous waste site cleanups, so I get to help remove toxins from the environment. I do composting and waste reduction education and advocacy in my spare time. I remain anonymous so as not to be perceived as speaking on behalf of my employer.

and those toxins you remove from the environment, what happens to them eg.,. how are they disposed of?

len

gardenlen is asking an important question. Where do all those removed environmental toxins go?

My credentials follow:
Harvard Ph.D.
Professor Emeritus
Rochester Institute of Technology
where I designed,administered and taught environmental science courses for 22 years. Before retiring, I chaired the Department of Science, Technology, and Society.
Since then I have researched the land application of sewage sludge full-time and am an unpaid consultant to several groups, including the national Sierra Club, on issues dealing with the land application of sewage sludge.
I helped write the Sierra Club's sludge policy ( which has been revised twice). The latest version went through several drafts, and was vetted by top-experts in the field-- including soil scientists at the Cornell Waste Management Institute-- and two attorneys.

http://www.sierraclub.org/policy/conservation/LandApplicationSewageSludge.pdf

Isn't the PH.D. in Germanic languages? I'm Just curious. You don't have to answer if you don't want to because I won't tell you anything about myself. I likes me anonymity. But....since your user name is your real name and you brought up the degree and all....

"gardenlen is asking an important question. Where do all those removed environmental toxins go? "

Indeed. I, however, don't believe that the gardenweb forums are the appropriate place to debate or discuss that issue. So, I'll pass.

For the airing of credentials, for the Doc's sake - BS degrees in Chemistry and Physics; PhD Chemistry, 30 years research experience, including 20 years R&D management for one of the world's five largest chemical companies (won't be any more specific than that), that included several years of corporate management of all health, environment and safety policies and practices for R&D, and the relationships we maintained with a myriad of federal and state regulatory agencies, including EPA, OSHA, NRC, etc.

Doc - I maintain my online anonymity for professional reasons.

Well, if we are posting credentials....

Grade twelve drop-out;
45 minutes of University education (sat in on a Basic French class at Mount Allison when DD was touring the school).

I know diddly about the subject and find this whole thread extremely entertaining.

I would use humanure but would not use treated sludge. Probably irrational but that's the way it is.

Lloyd

Lloyd - to me it's actually pretty rational given what you do with the stuff (but it's not for me). As far as credentials, I'll take your experience and wisdom over most academic knowledge cases most days.

I think that question was directed at me, and it is beyond the scope of the forum. To be honest, some of them are moved around rather than destroyed, due to cheap landfill fees. I'm not thrilled about it but they are at least managed and controlled. Some are destroyed. Some are deemed not to be a threat due to low levels. Some are managed in place. The key is that human and env. exposure is reduced to an acceptable level.

I am not sure if this was mentioned...this thread got kind of long....but are the presence of heavy metals in sewage a result of bioaccumulation or is it due to fortification of foods like cereals or is it because people throw all kinds of stuff down the drains and in their toilet?

The metals come from the source. Over time the levels of heavy metals in untreated wastewater streams have been decreasing for several reasons, most notably better pretreatment at industrial sources, and changes in piping / plumbing. The metals coming in concentrate in the residual solids that become biosolids for a couple or reasons - binding to suspended solids, and outright precipitation of insoluble salts from the water being treated.

As untreated wastewater levels have dropped, so have the heavy metal levels in treated biosolids. Using Milorganite from Milwaukee only as an example, the lead level average dropped from about 120 ppm to about 70 ppm over ~ 10 years.

Hope that answers your question.

I think it is a pretty safe assumption that the heavy metals come mostly from what is dumped down the drain. From home disposal to the shops, malls, repair shops, dental offices, small factories, gasoline stations, and retail places where things are cleaned up from spills. Probably these days most larger manufacturing places, smelters, refineries, labs, pharmaciticals, and such have at least some water treatment facilities, but spills do happen.

Wayne: its not just spills or metals. Every entity connected to a sewer is legally permitted, every month, to discharge 33 pounds of hazardous waste into sewage treatment plants. Hospitals, factories, chemical labs, metal plating shops, dry cleaning establishments, pharmaceutical companies, nuclear laundries, nuclear power plants, semi-conductor facilities, etc etc. Add to this leachates from landfills, fracking fluids, and storm water run off.

No wonder that pretreating industrial wastewater before it enters sewers is, according to EPA data, not working very well. Many users are in Significant Non Compliance with the requirements. Only a fraction of pollutants require pretreatment. And many industries do not have to pretreat their liquid waste at all. This is one reason why so many sludges-- according to experts at Cornell-- contain toxic pollutants at levels exceeding EPA's Superfund Screening Limits.
Worse, in 2005 EPA proposed to weaken the already inadequate pretreatment requirements even further.

Okay, I'm done here. This thread has turned well away from gardening and pertinent gardening questions, and now morphed into an activists agenda platform. Enjoy!

vieja - I hope you got your questions answered.

This post was edited by TXEB on Tue, Apr 23, 13 at 6:03

Wise decision, TXEB. As you said earlier, those who can't stand the heat, should get out of the kitchen..

I'd be very interested to know where this regulation is that allows 33 lb of 'hazardous waste' to be dumped down every drain. I'm not aware of it.

Response to toxcrusadr:

40 CFR
403.12 (p) 2:

"Dischargers are exempt from the requirements of paragraph (p)(1) of this section during a calendar month in which they discharge no more than fifteen kilograms of hazardous wastes, unless the wastes are acute wastes as specified in 40CFR 261.30(d) and 261.33(e). Discharge of more than fifteen kilograms of non-acute hazardous wastes in a calendar month, or of any quantity of acute hazardous wastes requires a one-time notification. Subsequent months during which the industrial user discharges more than such quantities of any hazardous waste do not require additional notification."

So folks can dump 15 kilos as long as it is not an "acute waste" as defined by 40 CFR 261.30(d) and 261.33(e).

That means stuff described in, well I'm short on time so let's just say 261.3(d), can't be dumped at that rate. Let's see what 261.3(d) is, shall we?

"The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (T)
F002 The following spent halogenated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (T)
F003 The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (I)*
F004 The following spent non-halogenated solvents: Cresols and cresylic acid, and nitrobenzene; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (T)
F005 The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures (I,T)
F006 Wastewater treatment sludges from electroplating operations except from the following processes: (1) Sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel; (3) zinc plating (segregated basis) on carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel; (5) cleaning/stripping associated with tin, zinc and aluminum plating on carbon steel; and (6) chemical etching and milling of aluminum (T)
F007 Spent cyanide plating bath solutions from electroplating operations (R, T)
F008 Plating bath residues from the bottom of plating baths from electroplating operations where cyanides are used in the process (R, T)
F009 Spent stripping and cleaning bath solutions from electroplating operations where cyanides are used in the process (R, T)
F010 Quenching bath residues from oil baths from metal heat treating operations where cyanides are used in the process (R, T)
F011 Spent cyanide solutions from salt bath pot cleaning from metal heat treating operations (R, T)
F012 Quenching waste water treatment sludges from metal heat treating operations where cyanides are used in the process (T)
F019 Wastewater treatment sludges from the chemical conversion coating of aluminum except from zirconium phosphating in aluminum can washing when such phosphating is an exclusive conversion coating process. Wastewater treatment sludges from the manufacturing of motor vehicles using a zinc phosphating process will not be subject to this listing at the point of generation if the wastes are not placed outside on the land prior to shipment to a landfill for disposal and are either: disposed in a Subtitle D municipal or industrial landfill unit that is equipped with a single clay liner and is permitted, licensed or otherwise authorized by the state; or disposed in a landfill unit subject to, or otherwise meeting, the landfill requirements in § 258.40 , § 264.301 or § 265.301 . For the purposes of this listing, motor vehicle manufacturing is defined in paragraph (b)(4)(i) of this section and (b)(4)(ii) of this section describes the recordkeeping requirements for motor vehicle manufacturing facilities (T)
F020 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production or manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tri- or tetrachlorophenol, or of intermediates used to produce their pesticide derivatives. (This listing does not include wastes from the production of Hexachlorophene from highly purified 2,4,5-trichlorophenol.) (H)
F021 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production or manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of pentachlorophenol, or of intermediates used to produce its derivatives (H)
F022 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tetra-, penta-, or hexachlorobenzenes under alkaline conditions (H)
F023 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production of materials on equipment previously used for the production or manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tri- and tetrachlorophenols. (This listing does not include wastes from equipment used only for the production or use of Hexachlorophene from highly purified 2,4,5-trichlorophenol.) (H)
F024 Process wastes, including but not limited to, distillation residues, heavy ends, tars, and reactor clean-out wastes, from the production of certain chlorinated aliphatic hydrocarbons by free radical catalyzed processes. These chlorinated aliphatic hydrocarbons are those having carbon chain lengths ranging from one to and including five, with varying amounts and positions of chlorine substitution. (This listing does not include wastewaters, wastewater treatment sludges, spent catalysts, and wastes listed in § 261.31 or § 261.32 .) (T)
F025 Condensed light ends, spent filters and filter aids, and spent desiccant wastes from the production of certain chlorinated aliphatic hydrocarbons, by free radical catalyzed processes. These chlorinated aliphatic hydrocarbons are those having carbon chain lengths ranging from one to and including five, with varying amounts and positions of chlorine substitution (T)
F026 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production of materials on equipment previously used for the manufacturing use (as a reactant, chemical intermediate, or component in a formulating process) of tetra-, penta-, or hexachlorobenzene under alkaline conditions (H)
F027 Discarded unused formulations containing tri-, tetra-, or pentachlorophenol or discarded unused formulations containing compounds derived from these chlorophenols. (This listing does not include formulations containing Hexachlorophene sythesized from prepurified 2,4,5-trichlorophenol as the sole component.) (H)
F028 Residues resulting from the incineration or thermal treatment of soil contaminated with EPA Hazardous Waste Nos. F020, F021, F022, F023, F026, and F027 (T)
F032 Wastewaters (except those that have not come into contact with process contaminants), process residuals, preservative drippage, and spent formulations from wood preserving processes generated at plants that currently use or have previously used chlorophenolic formulations (except potentially cross-contaminated wastes that have had the F032 waste code deleted in accordance with § 261.35 of this chapter or potentially cross-contaminated wastes that are otherwise currently regulated as hazardous wastes (i.e., F034 or F035), and where the generator does not resume or initiate use of chlorophenolic formulations). This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol (T)
F034 Wastewaters (except those that have not come into contact with process contaminants), process residuals, preservative drippage, and spent formulations from wood preserving processes generated at plants that use creosote formulations. This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol (T)
F035 Wastewaters (except those that have not come into contact with process contaminants), process residuals, preservative drippage, and spent formulations from wood preserving processes generated at plants that use inorganic preservatives containing arsenic or chromium. This listing does not include K001 bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote and/or pentachlorophenol (T)
F037 Petroleum refinery primary oil/water/solids separation sludge�"Any sludge generated from the gravitational separation of oil/water/solids during the storage or treatment of process wastewaters and oily cooling wastewaters from petroleum refineries. Such sludges include, but are not limited to, those generated in oil/water/solids separators; tanks and impoundments; ditches and other conveyances; sumps; and stormwater units receiving dry weather flow. Sludge generated in stormwater units that do not receive dry weather flow, sludges generated from non-contact once-through cooling waters segregated for treatment from other process or oily cooling waters, sludges generated in aggressive biological treatment units as defined in § 261.31(b)(2) (including sludges generated in one or more additional units after wastewaters have been treated in aggressive biological treatment units) and K051 wastes are not included in this listing. This listing does include residuals generated from processing or recycling oil-bearing hazardous secondary materials excluded under § 261.4(a)(12)(i) , if those residuals are to be disposed of (T)
F038 Petroleum refinery secondary (emulsified) oil/water/solids separation sludge�"Any sludge and/or float generated from the physical and/or chemical separation of oil/water/solids in process wastewaters and oily cooling wastewaters from petroleum refineries. Such wastes include, but are not limited to, all sludges and floats generated in: induced air flotation (IAF) units, tanks and impoundments, and all sludges generated in DAF units. Sludges generated in stormwater units that do not receive dry weather flow, sludges generated from non-contact once-through cooling waters segregated for treatment from other process or oily cooling waters, sludges and floats generated in aggressive biological treatment units as defined in § 261.31(b)(2) (including sludges and floats generated in one or more additional units after wastewaters have been treated in aggressive biological treatment units) and F037, K048, and K051 wastes are not included in this listing (T)
F039 Leachate (liquids that have percolated through land disposed wastes) resulting from the disposal of more than one restricted waste classified as hazardous under subpart D of this part. (Leachate resulting from the disposal of one or more of the following EPA Hazardous Wastes and no other Hazardous Wastes retains its EPA Hazardous Waste Number(s): F020, F021, F022, F026, F027, and/or F028.)"

Boy, that's a lot of stuff that does not get a free pass and can't be dumped under the 15 kilo rule you mention. I bet that a lot of the waste from the places you described would fall in there somewhere.

In fact, just for kicks I picked one of the businesses out of the list that you specifically mentioned as those that can dump materials at the given rate with impunity. That business was dry cleaning.

It took me 15 seconds on Google to find that the most common solvent in dry cleaning is tetrachloroethylene. And, by golly, wouldn't you know it that tetrachloroethylene is one of the very fisrt things mentioned that you are not allowed to dump at a rate of 15 kilos per month. I honestly don't have the time to comb through the rest but feel free to see how many matches you can find. It's fun!....kind of like "Where's Waldo" but with lies.

I'm not saying there is no reason to be concerned about biosolids. I'm just saying that you are implying that any of those industries can jettison 15 kilos of whatever they want every month. This is an example of the way you tend to make your points. You like to blur facts to scare people into agreeing with you. It's reprehensible, damages your credibility, and you should stop.

gargwarb:

Thank you for providing our readers with the long list of acute hazardous wastes that can legally be dumped into sewage treatment plants, in any amount, as long as dischargers comply with the one-time notification requirement.

It appears that you misread 40 CFR 403.12 (p) 2.
Perhaps you should read regulations more carefully before accusing people of blurring facts.

And no, I have no intention of stopping, as long as you and others on this website continue to post false and misleading information about the contents of municipal sewage and ignore the risks linked to using this material as fertilizer.

You're right. After going over it again, I misread that. I apologize for the personal attack.

"And no, I have no intention of stopping, as long as you and others on this website continue to post false and misleading information..."

Your initial post was full of misleading, scare, and non-plant-useful information.

I'm not sure you understand how plants use this soil vs. a toddler making mud pies and eating them.

I would just like to point out that 403.12 addresses *notification requirements*, not actual discharge limits or how those are determined. Water pollution is not my main area so it would require more research to determine exactly where in the regs that is addressed, but on the face of it, this section does not seem to allow discharge of any particular pollutants.

In the meantime, can you cite an actual example of an industrial or commercial facility that has or is discharging such an amount of RCRA hazardous waste to a POTW? Let's look at cases.

This post was edited by toxcrusadr on Fri, Apr 26, 13 at 11:55

gargwarb:

No problem. Apologies accepted. I am used to unwarranted attacks. See, for example, nc-cm's latest.

nc-cm:
Please list any statement in my original comment that is inaccurate and I will be glad to correct it.

Oh now, I wouldn't say nc-crn's latest post was an unwarranted attack. He makes valid points and I agree with him (or her?)

I did, however, interpret the regulatory gobbledeeguck incorrectly and went overboard. Tox has a much better handle on such things than I do.

"In fact, instead of killing pathogens, many driers actually PRODUCE antibiotic resistant germs, as the more vulnerable indicator pathogens are destroyed, letting superbugs survive and multiply."

Scare tactic...and totally off base given the amount of sludge used in parks and the sod industry. I heard about some listeria cantaloupe...i wouldn't advise not eating cantaloupe ever again because they've been shown to carry listeria.

"NO amount of lead is safe in your garden."

Unrealistic scare tactic...where on this planet are you going to find a lead-less soil? An undisturbed, unamended, urban soil will contain 30-50ppm lead rather easily. It's hard to find a soil without at least 5-10ppm even in some of the most rural areas.

"Current federal sludge rules do NOT regulate PCBs or related persistent toxic chemicals."

Plants don't care about PCBs, nor do they translocate them.

"There is no credible science that supports using sludge as fertilizer. Instead tax dollars are used to wage a massive public acceptance campaign to persuade gardeners, farmers, the media , and the public that this practice is safe."

YOUR OPINION on credible science isn't the end-all on the discussion, especially since there is science out there supporting it's use...you just choose to invalidate it.

I'm not expecting to change your mind about any of this...this is your "activist thing" you've tied your horse to. It's getting a bit old to hear you call others out for attacking you when it's your information that's being attacked. You're so close to this issue that you're defining yourself and personalizing with the issue. That doesn't lead to a discussion...it leads to a person lecturing and any counter-point to the lecture as a personal attack.

That said, I still don't think you understand how plants use these soils vs. a toddler eating a mud pie.

This post was edited by nc-crn on Wed, Apr 24, 13 at 19:23

I have inserted some peer reviewed research articles in response to nc-crn's statements. We have many more in our files and will be glad to forward them to anyone interested. Just email us at info@sludgefacts.org.
_______________________________________________
"In fact, instead of killing pathogens, many driers actually PRODUCE antibiotic resistant germs, as the more vulnerable indicator pathogens are destroyed, letting superbugs survive and multiply."

Chen, Yen-Chih et al. 2011. The effect of digestion and dewatering on sudden
increases and regrowth of indicator bacteria after dewatering. Water and Environ.
Research 83: 773

Droffner, M. L. 1995. Survival of E. coli and Salmonella populations in composts as measured with DNA gene probes. Zentralbl. Hyg.
Umweltmed 197(5): 387-397.

Selvaratnam, et al. 2004. Increased frequency of drug-resistant bacteria and fecal
coliforms in an Indiana Creek adjacent to farmland amended with treated sludge.
Can. J. Microbio. 50(8): 653-656.

Torrice, M. 2011. Spreading resistance during wastewater treatment. Chemical Engineering News. March 28. doi: 10.1021/CEN031011143933

Pathogen regrowth after dewatering and digestion
http://ascelibrary.org/doi/abs/10.1061/41036(342)530
_______________________________________________

"NO amount of lead is safe in your garden."

Very small amounts of lead can cause irreversible neurological damage to small children. Lead accumulates in soil. Is it wise to permit unregulated Class A EQ sludges to contain 300 ppm of lead to add to the lead that is already present in urban soils?
_________________________________________________
"Current federal sludge rules do NOT regulate PCBs or related persistent toxic chemicals."

PCBs in Milwaukee’s Class A sludge:
http://www.jsonline.com/news/milwaukee/29463034.html

Plants don't care about PCBs, nor do they translocate them.
Not quite true. Although exposure from PCBs and dioxin- like chemicals comes mostly from meat and dairy products, there is new data that these extremely toxic compounds can also adhere to or be absorbed by crops:
EPA PCB Fact Sheet:
Some plants in the squash family appear to be able to accumulate PCBs from soil via their roots. Studies of tomatoes grown downwind from a PCB-contaminated sediment site demonstrated that lighter, more volatile, congeners released into the atmosphere can be taken up by the leaves and transported into edible portions of the plant.

Generally, however, most of the PCBs remain on the surface of fruits and vegetables, often as part of the soil deposited by wind or rainwater splash clinging to the plant.

http://www.sciencedirect.com/science/article/pii/004565359390324X:

Field studies were conducted on PCDD/PCDF transfer from contaminated soils to lettuce, potato plants and hay. Contamination of crops by soil particles proved to be an important source of PCDD/PCDF in plants.
_____________________________________________
"There is no credible science that supports using sludge as fertilizer. Instead tax dollars are used to wage a massive public acceptance campaign to persuade gardeners, farmers, the media , and the public that this practice is safe."

Please forward specific credible science you claim is “out there”, published in the peer reviewed literature that indicates that the regulations governing the use of sludge are protective of human health, agriculture, or the environment.
_______________________________________________
I'm not expecting to change your mind about any of this

Of course I will change my mind if I see credible data that proves me wrong. I mean solid peer reviewed published research, not vague unsubstantiated claims. Show me your data. Two or three recent peer reviewed articles will do.

toxcrusadr:

I guess you are still confused about the pretreatment regulations. All the toxic chemicals that were listed by gargwarb earlier can legally be dumped into sewage treatment plants. All that is required from the industrial user is a one-time notification during the first month. During the subsequent eleven months the user is free to continue discharging any or all of these extremely toxic chemicals into sewage treatment plants without reporting.
Once entering the treatment plant, the pollutants mix with other contaminants discharged by other users and the resulting sewage is treated by removing pollutants from the waste water and transferring most of them into the resulting sludge.
It's really not that complicated once you understand the process.

You don't know what "scare tactic" means, huh? The cantaloupe analogy was lost on you?

I'm starting a new non-profit to get people away from eating apples. Did you realize people are actually uptaking deadly cyanide? Our food system is so irresponsible. When I see a child eating an apple I just wanna slap that kid's parents. Wake up people!

>>I guess you are still confused about the pretreatment regulations.

Anything is possible.

>>All the toxic chemicals that were listed by gargwarb earlier can legally be dumped into sewage treatment plants.

That is an oversimplification at best. First of all, 'chemicals' implies specific compounds, whereas F-listed wastes may contain numerous compounds. Granted, those chemicals - from other sources than F-listed wastes- can get into sewage. But I seriously doubt that F-listed RCRA Hazardous Wastes can be discharged to a POTW in the first place as you imply. However, one of RCRA's complexities is that a chemical compound - benzene, for example - can be part of a listed waste, and thus regulated in a certain way, but benzene from another source is not. Furthermore, listed wastes are listed wastes *regardless of the concentration*. This means everything when talking about the ultimate fate of chemicals with respect to sludge. In fact, a gram of listed waste diluted in 33 lb of drinking water gives you 33 lb + 1 g of listed waste. But the amount of toxic chemicals involved is obviously different compared to 33 lb of the original waste.

>>All that is required from the industrial user is a one-time notification during the first month. During the subsequent eleven months the user is free to continue discharging any or all of these extremely toxic chemicals into sewage treatment plants without reporting.

No, that is not all that is required. You gloss over many facts here which results in an implication that the process is completely uncontrolled. It is not. Anyone treating (or pre-treating) hazardous waste needs a RCRA HW Treatment Permit, for one thing. These are not simple to obtain and have stringent requirements. There are also Local Discharge Limits, which POTWs apply to ANY discharge, limiting the concentration of various pollutants allowed in. For example, I know of a large city whose local discharge limit for benzene is 3 ppm, which means incoming sewage has to be 25 times lower in benzene than the level allowed by the state in surface waters used for swimming and fishing.

>>Once entering the treatment plant, the pollutants mix with other contaminants discharged by other users and the resulting sewage is treated by removing pollutants from the waste water and transferring most of them into the resulting sludge.

This ignores biodegradation and volatilization in the plant. It varies by chemical, but 'most of them ending up in the sludge' is way overstated.

>>It's really not that complicated once you understand the process.

I believe I have shown that it is that complicated. We may not be satisfied with the end result, but there is a very sophisticated regulatory machine controlling discharges.

None of this has much to do with the fact that detectable levels of toxic chemicals can be found in sewage sludge, a fact everyone here has already accepted.

Toxicrusadr:

Before accusing others of glossing over many facts, get your own facts straight.

RCRA Section 1004(27) (DSE) provides that hazardous waste when mixed with domestic sewage is no longer considered hazardous after it reaches the treatment plant. So treatment plants are not subject to RCRA treatment, storage, and disposal facility requirements.

We have a local product called Tuscarora Landscapers choice and it is from the sewer system in Leesburg, VA where there is no industry. We use it on everything including veggies and have had no problems whatsoever. The source of the sewage can dictate how you use it.

"You may have heard news stories about public outcry against the land application of biosolids on farmland. That type of biosolids is called Class B. Although this level of treatment is generally safe, Tacoma chose a different and more strenuous process for its biosolids to ensure that our products would be completely pathogen free. "

"Our biosolids are so safe the U.S. Environmental Protection Agency calls them “Class A-Exceptional Quality,” the agency’s highest rating. But we had to wait to earn this rating. As one of the pioneers of Class A biosolids treatment and product innovation, Tacoma’s treatment program preceded the EPA’s very definition for the process."

Source: City of Tacoma

If the product is not promoted as a Class A biosolid, then it should be considered NOT safe for food production. Even then, Class A might not be appropriate and use would be up to the individual.

As I explained in my April 20, 2013 2:12 pm comment, "Class A
EQ." sewage sludge is a deceptive term. Some experts believe that
spreading Class A EQ on the land where we grow crops and graze animals
is actually more harmful than using Class B. Here is why:

1. Current methods to further treat sewage to produce a Class A
product may deactivate the more vulnerable indicator pathogens. But the
processing actually causes more robust superbugs to evolve which can
pass their anti-biotic resistance to healthy soil organisms.

2.Some of the designated methods to produce Class A pathogen reduction are not working, so what is being spread is often Class B.

3. During moist and cool climates and storage Class A destabilizes and turns into Class B

4. Class A sludge from our industrialized urban centers ( 83%
land-applied sludge originates in those center) contains most of the
thousands of chemicals in commerce today that I listed in my previous
blog.

5. Worse, Class A is virtually unregulated. It can be spread anywhere,
anytime, during any weather conditions, and in any amounts, without
tracking toxic pollutants. Even though it contains hundreds of
priority pollutants, it contains very little nitrogen. So farmers and
gardeners need to use 3-5 times more per acre to get any yield
increases. This of course means, 3-5 times more pollutants per acre
which does not bode well for preserving clean soil for growing healthy
produce.

For those want to know why sludge and sludge products are still being
promoted by those who profit from this risky practice, see http://www.sludgefacts.org/testimony_to_pa.pdf