Inside Washington
Water Policy Report
August 21, 2006
SECTION: Vol. 15 No. 17
HEADLINE: MUNICIPALITIES FILE LANDMARK SUIT AGAINST COUNTY OVER BIOSOLIDS BAN
To Editors of Inside Washington Publishers
Your article------ MUNICIPALITIES FILE LANDMARK SUIT AGAINST COUNTY OVER BIOSOLIDS BAN, seems to be a bit
lopsided. There are some very valid reasons that the communities within Kern County decided to ban sewage sludge.
None of these appear within your article.
The main thesis below is that when the standards established for land application of sewage sludge were driven by
economics impacting the needs of the industry and not necessarily for protection the health of the citizens.
Some of the main complaints against continued land application of sewage sludge are related to pathogens and
illnesses. In addition odor is a major factor. Dr. Al Rubin who was one of the EPA authors of the standards controlling
land application of sewage sludge noted ------- I believe that the reports we are getting are real, in that people feel sick
out there. I read 4-5 reports everyday, and I have a stack that is almost 2 feet tall. The EPA is taking the NRC
recommendations very seriously particularly in going back and looking and tracking incidents.
To determine the level of attained disinfection in their waste product, sewer districts use indicator organisms. These
indicators were originally thought to reflect the associated levels of the more serious pathogens found in sewage waste
from municipal and industrial sources. Unfortunately, as reported in numerous peer-reviewed scientific and medical
journals, these indicators do not accurately reflect actual pathogens present in waste and worse, are less reflective of
risks to health from the newly emerging infectious diseases. Nonetheless, they are the official and current standards. A
recently released paper by Higgins and Murthy put out of the Water Environment Research Foundation noted that over
half of the sewage plants tested saw resuscitation of pathogens in sewage sludge and the numbers were several
magnitudes over what should have been there per the standards. There are substantial industry-driven economic
incentives that detract from attempts to modernize these standards.
Current standards for this municipal/industrial waste product, or as it is called by the industry creating and applying it---
biosolids----, also allow for survival of high numbers of indicator organisms. Some of these have been shown, through
more recent transfer of genes from pathogens, to be themselves serious pathogens. For example, the allowed level of
indicators within a gram of Class B sewage sludge is 2-million per gram. A solid gram is about the size of a sugar cube
and there are hardly 2-million granules in a crushed sugar cube, yet the pile of sugar granules is not insignificant. There
are 454 grams to a pound and 2,000 pounds in a ton. The application rates for sewage sludge are often in the tens-of-
tons per acre---sometimes month after month.
If these easily killed indicators are surviving, one then wonders about the more robust and thus more serious
pathogens. Might they not thus survive in greater numbers? They do in fact survive in greater numbers as amply
demonstrated in the peer-reviewed literature, but then, under current standards, there is no particular interest in
ascertaining their numbers by industry. Thus although these current indicators do not reflect actual risk, they are used
to meet the current industry standards.
These standards allowing for the survival of indicator organisms may be driven by certain economic considerations for
both the producing industry that is ridding itself of this waste product and the industry receiving it. Such survival,
however, does not bode well for human or environmental health.
Allowing pathogen survival in the finished product allows for reduced production cost at the sewer plant; any problems
that develop later are outside the budgetary concerns of the producing industry. Thus there is little incentive to correct
this by sewer districts. Next, the receiving enterprise, those that use sewage sludge as a soil amendment and fertilizer---
often receiving it free, want to replace purchased commercial fertilizers with something that they may gain at no cost.
Sewer sludge is often delivered to farms at no cost or farmers are even paid to accept it. In either case this activity
reduces capital outflow for otherwise purchased fertilizer.
Thus, when considering the main drivers for fertilizers in the first place and the soil’s needs for nutrient replacement,
poorly treated sewage sludge may be best, especially if you are paid to take it and also earn a subsidy on your crop.
Let’s for a moment, look at the differences between well and poorly treated sewage sludge from an agronomic, but not a
public health, perspective. When speaking of fertilizers, one is usually concerned with the abundance and ratios of NPK,
or nitrogen (N), phosphorus (P), and potassium (K). The symbol for potassium is K is from the Latin kalium. For soils,
there is a desire to retain the nitrogen as this is what makes plants grow. Plants require N in relatively large quantities
and also in forms that are readily available. Nitrogen is a key component in plant proteins and chlorophyll, the green
pigment of the plant that is responsible for photosynthesis. Nitrogen helps plants with rapid growth. Nitrogen also
leaches easily and is lost as gas to the atmosphere; it thus requires constant replenishment, especially in high
production crops.
Loss of nitrogen through the soil and into the ground water is seen in increased health care costs. A classic example of
contamination is found in the drinking water from wells in agricultural areas within the Central Valley of California. Excess
nitrogen is converted to nitrite. Once in the blood, nitrite oxidizes iron in the hemoglobin of red blood cells to form
methemoglobin, which lacks hemoglobin's oxygen-carrying ability. This is known as the blue baby syndrome. In addition,
aluminum may be released as the soil pH is driven down. Excess aluminum in drinking water has been implicated in the
development of early dementia. These are just a few examples or the tip of the iceberg.
If sewage sludge had truly been disinfected and stabilized much if not all of the nitrogen would be removed by that
process. As it is now, many of the better-treated sewage sludges are very low in nitrogen content. Thus to meet
agronomic levels for nitrogen, more municipal/industrial waste, i.e., sludge (biosolid) needs to be applied. Since one may
be paid for receiving this waste, there may be an incentive to disregard the other detractors that are also involved in this
practice. To attain necessary levels of nitrogen, from this nitrogen poor source, there is often an excess of phosphorus
applied to land. This phosphorus may become soluble and consequently wash off the land with storm water or in
irrigation return-flow. The limiting nutrient of alga blooms in lakes and other water bodies that kill fish is often
phosphorus. We know that large amounts of these nutrients leave their application sites via transport in water and air.
Also moving within these transport mechanism into surface water and ground water are the heavy metals and other toxic
materials found in industrial and municipal waste. Thus the upshot is that to reach agronomic levels, much more of this
municipal and industrial waste or sludge (biosolid) needs to be applied to farmlands. Dr. Rufus Chaney, one of the
authors of the EPA sludge standards has recently commented on this. He notes "Undigested biosolids don't loose as
much N as digested." [Wed, 23 Aug 2006 10:12:40 -0400 From: "Rufus Chaney" <chaneyr@ba.ars.usda.gov> Subject:
Re: [USCC] Addition of Water Treatment Plant (Lime) Sludge to Biosolids for Composting].
From a public health perspective, the ability of pathogens to regrow depends on the nutrient value of the sludge. The
fact that poorly treated sewage sludge smells when land applied is an indication of the re-growth by bacteria and other
microorganisms, some of which are serious pathogens that have attained antibiotic resistance.
Further, and from a public health perspective, the other constituents involved with municipal/industrial waste, e.g., heavy
metals, carcinogens, organic toxins and pharmaceuticals are not destroyed but concentrated within the sludge. The
action of microbes may take solids and render them into soluble forms. Thus these can move with percolating water into
ground water resources. This is amply demonstrated as discussed above with the Central Valley nitrogen problem.
These are just a few reasons why the citizens of Kern County are objecting to continued land-spreading of sewage
sludge. If you would like more information, I would be pleased to discuss this with you in detail. I think, however, that the
above contains enough information to allow you to provide a more balanced follow-up article. I assume that you wish to
be even-handed in this.
With all due respect,
Dr. Edo McGowan
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Inside Washington
Water Policy Report
August 21, 2006
SECTION: Vol. 15 No. 17
HEADLINE: MUNICIPALITIES FILE LANDMARK SUIT AGAINST COUNTY OVER BIOSOLIDS BAN
Edo's Letter to Inside Washington editor on Sludge Ban