[Durham INC] FW: TOXICS in US sludge - the North Carolina debate

Sun Jul 5 18:02:58 EDT 2009

It's a bit long, but definitely worth a skim. Please see below regarding the public health risk of using sewer sludge as fertilizer--

Melissa (Rooney)

Date: Wednesday, July 1, 2009, 6:55 PM

From Helane
Shields.... 

From: Helane Shields
[mailto:hshields at worldpath.net] 

Sent: Wednesday, July 01, 2009
3:55 PM

To: NORTH CAROLINA - SUE DAYTON,
ENVIR. DEF. LEAGUE

Subject: TOXICS in US sludge - the
 North Carolina 
debate 

Hi, Sue - would you be kind enough to post these comments in
response to the ongoing debate on your sludge list.    Thank
you, Helane Shields, Alton ,
 NH 

The
dirty little secret most people don't know is that it is official government
policy is to mix and dispose of BOTH industrial and domestic wastes  in
public sewers. 

On
November 19, 1998, Dr. Alan Rubin, US EPA retired, author of the federal sludge
rules 40 CFR Part 503, testified before the NH Environment & Agriculture
Committee: 

"Congress
passed a series of construction grant programs ... taxpayer funds ... paying
for

construction or upgrading sewage treatment so discharges into ambient
environment would not be degraded .... we had fish kills, rivers on fire

....people couldn't go into Lake 
 Ontario .... Congress
granted 70 billion dollars into the program ..... it was the largest public
works

project ever. 

In that program, Congress made it clear that we were going to
treat both domestic and industrial/commercial wastewater in the sewage
treatment plans.

We should not segregate our
industrial and commercial wastes from domestic. It was Congress who laid it
down, not

the EPA ... Congress said you are going to treat these wastes together." 

The
premise was that industrial pretreatment programs were supposed to limit the
pollutants and keep the sludge from being too toxic to spread as
"fertilizer".. The problem is those programs apply primaruily to
heavy metals which have been decreasing for years anyway, as dirty polluting
industries close down or move to Third World 
countries with weak labor and environmental laws. Also, pretreatment programs
apply to only a few toxic chemicals and only reduce - not eliminate, the
quantity of those chemicals poured into the sewers. 

There are
thousands of new chemicals in industry and commerce today discharged to public
sewer which are untested, unmonitored, unregulated. A good example is Perfluorooctanoic acid (PFOA) , which was found in
 Alabama sludge this
spring, which contaminated soil, surface and groundwater, and meat and milk of
livestock put out to graze on sludged fields. . . . untested, unmonitored,
unregulated . . .  

Politics,
NAFTA, the weak economy, etc. have made sludge even MORE toxic. Requiring
businesses and industries to treat or recycle their hazardous wastes would
impose high costs upon them. With NAFTA sucking industries and employment from
the US ,
many city sewage agencies seek to protect local industries and jobs by looking
the other way when toxic chemicals are dumped into public sewers. 

EPA Office of Inspector General -
report dated September 2004, on the failure of pretreatment programs to keep
toxic pollutants out of sludge 　
http://www.epa.gov/oig/reports/2004/20040928-2004-P-00030.pdf 

　". . . the
performance of EPA's pretreatment program, which is responsible for controlling
these discharges, is threatened and progress toward achieving the Congress'
Clean Water Act goal of eliminating toxic discharges that can harm water
quality has stalled." 

　". . . , Toxic pollutants are still being
transferred to sewage treatment plants, and the impact to human health and the
environment of some of these pollutants may still not be known." 

　" One possible explanation is that
EPA Regions and State agencies that are supposed to act as control authorities
for POTWs without approved programs do not
have standards for overseeing industrial users discharging to these POTWs. Although
EPA was working on necessary guidance for these Regions and States, the project was put on hold due to other priorities." 

　The leveling off of those early
gains, coinciding with EPA's diminishing program emphasis, paints a picture of
a program at risk. 

　"There are hundreds of thousands of industrial users in the
 United States ,
and many may discharge toxic pollutants to wastewater facilities." 

The US EPA has a "Toxics Release Inventory"
program" (TRI) which is supposed to inform the public each year about the
toxic chemicals industries discharge to air, land, water and sewage treatment
plants (POTWs). But the TRI only applies to a limited number of industries and
high volume industrial discharges and there are numerous loopholes and
exceptions. However, we can get a hint of the magnitude of toxic industrial
wastes discharged to POTWs - over 5 billion pounds in 2005 - from the
Environmental Working Group: 

ENVIRONMENTAL WORKING GROUP – quoting EPA and US
General Accounting Office: 

"http://www.ewg.org/reports/dishonorable/ddweb.html 

Dishonorable Discharge

Toxic Pollution of
 America 's
Waters 

Under existing federal pollution control laws, the American
people are kept in the dark about the vast majority of toxic pollution spewed
into the environment by U.S. 
industry. Even the most comprehensive toxic pollution reporting system in the
nation, the Toxics Release Inventory(TRI), accounts for only about 5 percent
of all toxic pollution of the environment each year (GAO 1991, EPA 1996c).　　" 

Thus, if 262 million pounds = 5% - then 100% of hazardous
chemicals discharged to POTWs in 2005 would be over 5 BILLION POUNDS . . . . .  

　If 1.7
million pounds = 5% of toxic metals -- then 100% of toxic metals discharged to
POTWs in 2005 would be over 34.7 million pounds . . . . 

Furthermore, to make matters worse, federal law permits
every business and industry in the United States to dump 33 pounds of hazardous
wastes into public sewers every month with no reporting requirements [ 40CFR
403.12)P)(2) ] And this same law provides for only a one time reporting if acutely
hazardous wastes, or more than 33 pounds of hazardous
wastes, are dumped into the public sewers. 

And who
is standing there weighing or measuring the toxics as they are being dumped in
the sewers ? 

****************************************************************************** 

The
bottom line is that public sewers will NEVER be discontinued as the end point
for toxic wastes. Industry and the government NEED the "domestic
wastes" from us to DILUTE the toxic industrial chemicals. Beating each
other up over washing our hair, taking our meds, doing the laundry, flushing
the toilet, is naive and absurd. 

What CAN
be discontinued is spreading this noxious witches' brew on agricultural land.
Around the world for many years,( and even now in the
 US in a few
locations), cities are converting sewage to clean, renewable power and energy.
Jumping up and down and proclaiming "no incineration- no exceptions"
is childish and misleading.--  And the suggestion composting toilets
can somehow solve the sludge problem produced by 300 million Americans who
flush the toilet is unrealistic and impractical.   

Just as
the clean hybrid cars of today bear no relation to the 10 cylinder, gas
guzzling, pollution spewing, Lincolns 
of the 1950s. so the clean biogas, pyrolysis, gasification, plasma arc
technologies of today bear no resemblance to filthy old-style incinerators.
European cities are running fleets of buses and heating their homes with clean
renewable biogas from sewage. Conversion of manure to biogas is starting to
grow around the US .     
Converting sewage sludge to clean fuel could help solve a multitude of problems
such as reducing our reliance on imported oil and gas, reducing greenhouse
gases, and getting both human and animal wastes, and toxic industrial discharges,
out of water and off our land.    

Helane
Shields, Alton ,
 NH    Sludge 
researcher since 1996 - http://www.sludgevictims.com  

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