WASTEWATER REUSE -- A THIRD WORLD SOLUTION TO A MODERN DISPOSAL PROBLEM

                                     SEWAGE WASTEWATER REUSE
                                    A THIRD WORLD SOLUTION TO A MODERN DISPOSAL PROBLEM
By Jim Bynum                                         Also see comments Australian drinking water augmentation guidelines                                                        6/30/2007

The following information is adapted from EPA's Guidelines for Water Reuse, 2004 and other referenced material. All are direct quotes
except for a few comments in bold type. As you will note, EPA Guidelines for Water Reuse is based on the reuse of treated
domestic sewage effluent from residential sewers which does not include any industrial waste. The reality is that virtually all
wastewater reuse (reclaimed water projects) is from large municipal wastewater treatment plants which accept large amounts
of industrial waste through the sewers. The information is also relevant to sewage sludge (biosolids projects)

Given the unknowns, limitations, and uncertainty with the current state of science and technology, it is not possible to establish the threshold
at which no observed effect would occur, just as it is not reasonable to expect current scientific techniques to demonstrate the absence of
an impact on human health.

During the 70s some 70 billion dollars was spent building sewage treatment plants to clean up our water and get harmful
disease organisms and chemicals out of the public environment. Now the waste regulators and industry are resorting to a
third world solution to dispose of sewage effluent and sludge by recycling them where we and our children can not avoid
exposure. The solution includes public relations campaigns and high profile gatekeepers. The question we need to ask is,
how many of the 76 + million food poisoning cases annually are actually caused by exposure from the following very
dangerous wastewater reuse programs.

Urban
„ Industrial
„ Agricultural
„ Environmental and recreational
„ Groundwater recharge
„ Augmentation of potable supplies

There are 2 basic types of cooling water systems that use reclaimed water: (1) once-through and (2) recirculating
evaporative. There are 2 common types of evaporative cooling systems that use reclaimed water: (1) cooling towers and (2) spray ponds.

Since 1995, the Salinas Valley has been connected to nine of the 20 outbreaks of E. coli O157:H7 associated with lettuce and spinach.
The episode left the Salinas Valley with a tarnished reputation, a $77 million loss to its spinach crop and a marked drop in bagged salad
sales, which were down $10.5 million, according to the 2006 Monterey County Crop Report released last week.(Dawn Withers, 2007)

California's Title 22 effluent standard states No sample shall exceed a total colform value of 240 MPN/100 ml (MPN- most
probable number) for the reclaimed sewage effluent used to irrigate the Salinas Valley crops. That works out to 2,400 of the
pathogenic gram-negative Enterobacteriaceae family for ever liter of water released from the treatment plant during the 24
hours it takes to complete the tests. There is no space to cover each program use, but: there has been an ongoing outbreak
of Necrotizing fasciitis in Tucson, AZ.   In 2002, 83 people became ill and one 15 year old died after becoming infected with a
Norwalk virus at a Phoenix, AZ golf course. How many cases of sick building syndrome can be attributed to bacterial and viral
aerosol exposure from sewage use in the building cooling system? Could this explain the first outbreak of Legionnaires
disease? Interestingly, no investigation can ever pin point the cause of outbreaks associated with sludge or recycled water!

Traditionally, regulators, dischargers, and even water suppliers believed that wastewater discharge meeting the levels of 200 cfu/100 mL of
fecal coliforms in wastewater effluent was sufficient to protect against downstream microbial effects. However, these beliefs are now being
challenged by emerging pathogens that are resistant to standard water and wastewater treatment processes, exhibit extended survival
periods in the environment, can adversely affect sensitive subpopulations, and require extremely low doses for human infection. Based on
this new information, it is estimated that discharges of emerging pathogens from conventional wastewater treatment plants as far as 160 km
upstream and cumulative amounts of wastewater discharge ranging from 2 to 20 ML/d [million liter/day] have the potential to reach a water
supply intake in a viable state at significant concentrations that could exceed regulatory limits for drinking water supplies, increase endemic
risk from drinking water, and/or require additional drinking water treatment. (WEF, Volume 79, Number 3, March 2007 , pp. 221-232(12)

As an example, not only are gut bacteria becoming drug resistant, they have adapted to living outside the gut:

The presence of Escherichia coli in water is used as an indicator of fecal contamination, but recent reports indicate that soil populations can
also be detected in tropical, subtropical, and some temperate environments. In this study, we report that viable E. coli populations were
repeatedly isolated from northern temperate soils in three Lake Superior watersheds from October 2003 to October 2004. Seasonal
variation in the population density of soilborne E. coli was observed; the greatest cell densities, up to 3 x 103 CFU/g soil, were found in the
summer to fall (June to October), and the lowest numbers, 1 CFU/g soil, occurred during the winter to spring months (February to May).
Horizontal, fluorophore-enhanced repetitive extragenic palindromic PCR (HFERP) DNA fingerprint analyses indicated that identical soilborne
E. coli genotypes, those with 92% similarity values, overwintered in frozen soil and were present over time. Soilborne E. coli strains had
HFERP DNA fingerprints that were unique to specific soils and locations, suggesting that these E. coli strains became naturalized,
autochthonous members of the soil microbial community. In laboratory studies, naturalized E. coli strains had the ability to grow and replicate
to high cell densities, up to 4.2 x 105 CFU/g soil, in nonsterile soils when incubated at 30 or 37°C and survived longer than 1 month when
soil temperatures were 25°C. To our knowledge, this is the first report of the growth of naturalized E. coli in nonsterile, nonamended soils.
The presence of significant populations of naturalized populations of E. coli in temperate soils may confound the use of this bacterium as an
indicator of fecal contamination. (Satoshi Ishii, et.al, 2006)

The use of the coliform test (which includes E. coli) is a money saving public relations ploy to fool the public. Why in the world
would a fecal indicator test be used to test known fecal material? Furthermore, gene transfer between organisms in the
treatment plants and disposal of sewage sludge and effluent on land may be a factor in developing the new superbugs
(including E. coli) that cause necrotizing pneumonia which can kill you within 72 hours, and the environmental distribution
through the community.

To avoid wastewater discharge to sensitive receiving waters, the city of Tallahassee, Florida has been using treated effluent for agricultural
irrigation on city-owned farmland since 1966. About 68,000 m3/day (18 million gal/day) of secondary effluent are pumped approximately
13.7 km (8.5 miles) and irrigate about 700 ha (1,729 acres) (National Research Council, 1996)

There is an added advantage to the Cities using farmland for disposal. Wastewater discharging from the farm into sensitive
receiving waters is not regulated as agricultural runoff is excluded from environmental laws. Despite the known drug
resistant bacteria in the effluent, very little research has been done on bacteria biofilms that build up in irrigation pipes. As
Frank Pecarich pointed out, much of the Salinas Valley in California is irrigated with tertiary treated sewage effluent, yet, there
have been multiple disease outbreaks from spinach and lettuce grown there. In the beginning sewage treatment was
accomplished using large land farms. Then the U.S built treatment plants to separate solids (sludge) in sewage from the liquid
effluent. Now we have not only reverted to large municipal land farms to dispose sludge and/or liquid effluent, but they are
being promoted for use on food crops and direct public contact, even when they can not be put in a landfill or released to
local waters.

[Napa Sanitation District] NSD's National Pollutant Discharge Elimination System Permit issued by the San Francisco Bay Regional Water
Quality Control Board provides for the discharge of treated wastewater into the adjacent Napa River during the wet season
(November through April), but during the dry season (May through October) river discharge is prohibited. Recycling of wastewater has
environmental benefits because it limits the discharge of treated wastewater into natural waterways,   Additionally, expanded use of recycled
water reduces the amount of discharge to the Napa River and protects existing sources of water for other uses. (UC Davis)

The use of poorly treated sewage waste release to rivers as well as state permitted sewage sludge and effluent (biosolids
and reclaimed water)disposed of on farmland is destroying the qualiity of our water. Virginia is a perfect example:
State Department of Environmental Quality staff members, who advise the board, have said it makes sense to relax the bacteria limit
because it's almost impossible to meet the standard in many waterways.   In Virginia, about 72-hundred miles of river are polluted by fecal
bacteria or other substances.   The DEQ estimates that 720 miles that don't meet the current bacteria limit would comply with the relaxed
standard. http://www.wdbj7.com/Global/story.asp?S=6723596

In this context, sewage sludge—traditionally regarded by many groups as an urban waste requiring careful disposal—is now viewed by the
wastewater treatment industry, the regulatory agencies, and participating farmers as a beneficial soil amendment. EPA believed that both
water reclamation and sludge beneficial use programs could benefit from an independent assessment of the public health and
environmental concerns that have been raised by the food processors concerning land application of treated municipal wastewater and
sludge. (National Research Council, 1996)

That independent assessment of public health and environmental concerns has not been done. The reality is that if farmers
were informed of the potential danger by the waste industry, they would never look at this practice, nor would the public
accept the exposure to sludge and wastewater effluent reuse. According to Corpus Christi Wastewater Superintendent
Wayne Cockcroft, as reported in the Corpus Christi Caller Times, "It's very clean water that's suitable for outdoor use,"... "But
even when a lawn has been watered with effluent, we encourage people not to let their children play on the lawn until the
water has soaked into the ground. There is always a chance that a child could get his hands wet, put it in his mouth and get
an upset stomach" (gastroenteritis).

The answer to whether wastewater and sludge can be safely applied to crops that people eat depends on several factors. These include the
nature and amounts of potentially toxic or pathogenic constituents in treated effluents and sludges, the fate of these constituents once the
materials are applied to an agricultural site, the potential of harmful constituents to migrate into plant tissue, the potential for other
environmental impacts on water resources from runoff or infiltration, and whether long-term effects on the environment or future crop
production are likely.(National Research Council, 1996)

Municipal wastewater treatment processes used in the United States were designed to receive raw municipal wastewaters from both
domestic and industrial sources and produce a liquid effluent of suitable quality that can be returned to natural surface waters with a minimal
impact to the environment or to public health. (National Research Council, 1996)

Sources of Reclaimed Water

Under the broad definition of water reclamation and reuse, sources of reclaimed water may range from industrial process waters to the tail
waters of agricultural irrigation systems. For the purposes of these (EPA) guidelines, however, the sources of reclaimed water are limited to
the effluent generated by domestic wastewater treatment facilities (WWTFs).

503.9(g) Domestic sewage is waste and wastewater from humans or household operations that is discharged to or otherwise
enters a treatment works.

Industrial waste streams differ from domestic wastewater in that they may contain relatively high levels of elements
and compounds, which may be toxic to plants and animals or may adversely impact treatment plant performance. Where industrial
wastewater flow contributions to the WWTF are significant, reclaimed water quality may be affected.

Given that tertiary treatment may not adequately safeguard against eutrophication, even when plants are performing to specifications, plant
failure can be expected to have severe negative effects. Some industrial wastes, such as some POPs, may actually interfere with domestic
waste treatment, for example by poisoning biological digestion. (UN Atlas)

A year-long study by the General Accounting Office of 242 wastewater treatment plants in 10 states concluded that discharge permit
violations are “the norm, not the exception.” The failures, GAO wrote, may represent “the potential waste of tens of millions of dollars in
Federal, state, and local moneys.” The agency identified five basic reasons for such widespread noncompliance: design deficiencies,
operation and maintenance deficiencies, industrial waste overloads, infiltration/inflow problems, and equipment problems. These causes of
plant malfunction and GAO’s recommendations on how to improve compliance are reviewed. ASCE, Vol. 51, No. 4, April 1981, pp. 74-76

With the exception of the possible inhalation of volatile organic compounds (VOCs) from indoor exposure, chemical concerns are less
important where reclaimed water is not to be consumed. Chemical constituents are a consideration when reclaimed water percolates into
groundwater as a result of irrigation, groundwater recharge, or other uses.

Many people have reported the symptoms of VOC exposure near known sludge disposal sites.

Eye, nose, and throat irritation; headaches, loss of coordination, nausea; damage to liver, kidney, and central nervous system. Some
organics can cause cancer in animals; some are suspected or known to cause cancer in humans. Key signs or symptoms associated with
exposure to VOCs include conjunctival irritation, nose and throat discomfort, headache, allergic skin reaction, dyspnea, declines in serum
cholinesterase levels, nausea, emesis, epistaxis, fatigue, dizziness..(EPA)

Protection of public health is achieved by: (1) reducing or eliminating concentrations of pathogenic bacteria, parasites, and enteric viruses in
the reclaimed water, (2) controlling chemical constituents in reclaimed water, and/ or (3) limiting public exposure (contact, inhalation,
ingestion) to reclaimed water. Reclaimed water projects may vary significantly in the level of human exposure incurred, with a corresponding
variation in the potential for health risks.
http://www.epa.gov/ORD/NRMRL/pubs/625r04108/625r04108chap3.pdf

Before we get into the real problems with wastewater reuse, lets look at the third world view of wastewater reuse.

The International Water Management Institute is a non-profit scientific research organization specializing in water use in agriculture and
integrated management of water and land resources in third world countries.

The positive side of wastewater reuse:

conserves water
low-cost method for sanitary disposal of municipal wastewater
reduces pollution of rivers, canals and other surface water resources
conserves nutrients, reducing the need for artificial fertilizer
increases crop yields
provides a reliable water supply to farmer

Wastewater irrigation provides income for small farmers

The negative side of wastewater reuse:

health risks for irrigators and communities with prolonged contact with untreated wastewater and consumers of vegetables irrigated
with wastewater
contamination of groundwater (nitrates)
buildup of chemical pollutants in the soil (heavy metals)
creation of habitats for disease vectors
excessive growth of algae and vegetation in canals carrying wastewater (eutrophication)

In the eutrophication process water becomes enriched in dissolved nutrients, such as nitrates and phosphates, that stimulate the growth of
aquatic plants. This usually results in the depletion of dissolved oxygen needed by fish and other organisms. Eutrophication is an emerging
problem in many lagoons and lakes due to the inflow of nutrients from water draining from agricultural areas or industrial or municipal
wastewater.

IWMI’s research in Mexico examined the advantages and disadvantages of using urban wastewater for crop production in Mexico's water-
scarce Guanajuato river basin. Here, wastewater irrigation is a critical component of intensive water recycling practices. This study shows
that the 140-hectare site downstream of Guanajuato – that is irrigated with raw sewage – serves as a defacto water treatment facility with
significant retention of contaminants. The study found that the economic value of wastewater used for irrigation represents a significant
monetary benefit to both society and the water users.

The findings of this study suggest that the continued application of wastewater to agricultural land in this area would be a more economical
form of wastewater treatment than building a wastewater treatment plant. If a treatment plant were built, local farmers' net incomes would be
reduced, as they would have to buy crop nutrients to replace those previously provided by wastewater. The caveat is that the potential for
serious negative impacts on health and the environment must be researched and monitored on an ongoing basis.
http://www.iwmi.cgiar.org/health/wastew/index.htm

Health Assessment of Water Reuse

As previously explained, there in no general agreement on the numerical values used in setting microbiological standards. They vary from
region to region, both domestically and internationally. The standards are based on expected performance of wastewater treatment
processes and on past experience with land application rather than on predictive science. (National Research Council, 1996)

The types and concentrations of pathogenic organisms found in raw wastewater are a reflection of the enteric organisms present in the
customer base of the collection system. Chemical pollutants of concern may also be present in untreated wastewater. These chemicals may
originate from any customer with access to the collection system, but are typically associated with industrial customers. Recent studies have
shown that over-the-counter and prescription drugs are often found in wastewater.

The ability for waterborne organisms to cause disease is well established. Our knowledge of the hazards of chemical pollutants varies. In
most cases, these concerns are based on the potential that adverse health effects may occur due to long-term exposure to relatively low
concentrations. In addition, chemicals capable of mimicking hormones have been shown to disrupt the endocrine systems of aquatic animals.

Diseases associated with microorganisms can be transmitted by water to humans either directly by ingestion, inhalation, or skin contact of
infectious agents, or indirectly by contact with objects or individuals previously contaminated. The following circumstances must occur for an
individual to become infected through exposure to reclaimed water: (a) the infectious agent must be present in the community and, hence, in
the wastewater from that community; (b) the agents must survive, to a significant degree, all of the wastewater treatment processes to which
they are exposed; (c) the individual must either directly or indirectly come into contact with the reclaimed water; and (d) the agents must be
present in sufficient numbers to cause infection at the time of contact.

The second of the above criteria—that the infectious agent be present in sufficient concentration—is fraught with uncertainty because
available data on human dose response are very limited, particularly at the population level. Usually it takes more than a single organism to
produce a detectable disease response in an individual in the exposed population. In many instances a lower dose of pathogens will
produce infection but not disease. The limited human dose-response data that have been reported indicate much variation in the severity of
sickness among those exposed to known dosages of pathogens. (National Research Council, 1996)

The large variety of pathogenic microorganisms that may be present in raw domestic wastewater is derived principally from the feces of
infected humans and primarily transmitted by consumption. Thus, the main transmission route is referred to as the “fecal-oral” route.
Contaminated water is an important conduit for fecal-oral transmission to humans and occurs either by direct consumption or by the use of
contaminated water in agriculture and food processing. There are occasions when host infections cause passage of pathogens in urine.
The 3 principal infections leading to significant appearance of pathogens in urine are: urinary schistosomiasis, typhoid fever, and
leptospirosis. Coliform and other bacteria may be numerous in urine during urinary tract infections. Since the incidence of these diseases in
the U.S. is very low, they constitute little public health risk in water reuse. Microbial agents resulting from venereal infections can also be
present in urine, but they are so vulnerable to conditions outside the body that wastewater is not a predominant vehicle of transmission
(Feachem et al., 1983 and Riggs, 1989).

Table 3-6. Typical Pathogen Survival Times at 20-30 oC

c Fecal coliform is not a pathogen but is often used as an indicator organism

Source: Adapted from Feacham et. al., 1983

A coliform includes 12 common human disease causing pathogenic enteric bacteria that pass through the gut: ESCHERICHIA
COLI, SHIGELLA, EDWARDSIELLA, SALMONELLA, CITROBACTER, KLEBSIELLA, ENTEROBACTER, SERRATIA, PROTEUS,
MORGANELLA, PROVIDENCIA and YERSINIA.
Why do you think EPA and the waste industry would lie to us about the nature of a coliform and the biohazard laboratory safety
requirements for handling these disease organisms?

Coliform is not a taxonomic classification but rather a working definition used to describe a group of Gram-negative, facultative anaerobic
rod-shaped bacteria that ferments lactose to produce acid and gas within 48 h at 35°C. In 1914, the U.S. Public Health Service adopted the
enumeration of coliforms as a more convenient standard of sanitary significance.

The Introduction To Clinical Microbiology, University of Texas - Houston Medical School, describes coliform as:
"Enterobacteriaceae family have earned a reputation placing them among the most pathogenic and most
often encountered organisms in clinical microbiology. They are the causative agents of such diseases as
meningitis, bacillary dysentery, typhoid, and food poisoning."

Furthermore, according to Kenneth Todar, University of Wisconsin-Madison Department of Bacteriology,
"The enterobacteriaceae include agents of food poisoning and gastroenteritis, hospital-acquired infections,
enteric fevers (e.g. typhoid fever) and plague. They also cause infections in domestic, farm and zoo
animals and include an important group of plant pathogens. Their host range includes animals ranging
from insects to humans, as well as fruits, vegetables, grains, flowering plants, and trees."

Why would EPA and the waste industry mislead us about the survival time of pathogens?

EPA TABLE 2-4 Survival times of Pathogens in soils and on plant surfaces

a. For survival times see Sorber & Moore, 1986
b. Absolute survival times are possible under unusual conditions such as consistently low
temperatures or highly sheltered conditions (e.g. helminth ova under the soil in fallow fields),
(Kowal, 1985)
c. Solisey and Shields, 1987
d. Little, if any, data are available on survival times of Giardia cysts and Cryptosporidian oocysts
Source: Kowal, 1985

Pathogenic Microorganisms and Health Risks

The potential transmission of infectious disease by pathogenic agents is the most common concern associated with reuse of treated
municipal wastewater. Fortunately, sanitary engineering and preventive medical practices have combined to reach a point where waterborne
disease outbreaks of epidemic proportions have, to a great extent, been controlled. However, the potential for disease transmission through
water has not been eliminated. With few exceptions, the disease organisms of epidemic history are still present in today’s sewage. The level
of treatment today is more related to severing the transmission chain than to fully eradicating the disease agents.

Many infectious disease microbes affecting individuals in a community can find their way into municipal sewage. Most of the organisms found
in untreated wastewater are known as enteric organisms; they inhabit the intestinal tract where they can cause disease, such as diarrhea.

Bacteria are microscopic organisms ranging from approximately 0.2 to 10 μm in length. They are distributed ubiquitously
in nature and have a wide variety of nutritional requirements. Many types of harmless bacteria colonize in the human intestinal tract and are
routinely shed in the feces. Pathogenic bacteria are also present in the feces of infected individuals. Therefore, municipal wastewater can
contain a wide variety and concentration range of bacteria, including those pathogenic to humans. The numbers and types of these agents
are a function of their prevalence in the animal and human community from which the wastewater is derived. Three of the more common
bacterial pathogens found in raw wastewater are Salmonella sp, Shigella sp. and enteropathogenic Escherichia coli which have caused
drinking water outbreaks with significant numbers of cases of hemolytic uremic syndrome (HUS) and multiple deaths (e.g. Walkerton,
Ontario; Washington County, NY; Cabool, MO; Alpine, WY).

All three bacteria are part of the biohazardous coliform group.

Bacterial levels in wastewater can be significantly lowered through either a “removal” or an “inactivation” process.

Inactivation does not mean the bacteria is dead or removed and the waste industry has known that since at least 1979.

Injury induced in Escherichia coli cells by chlorination was studied from a physiological standpoint. Predictable and reproducible injury was
found to occur rapidly in 0.5 mg of chlorine per liter and was reversible under nonselective conditions [VBNC]. There was an extended lag
period in the growth of chlorinated cells not seen in control suspensions followed by the resumption of logarithmic growth at a rate equaling
that of control cells. The aldolase activity of cells chlorinated in vivo was equivalent to that obtained for control cells. Oxygen uptake
experiments showed that chlorinated cells underwent a decrease in respiration that was not immediatedly repaired in the presence of
reducing agents. This effect was more pronouned in rich media containing reducing agents. Uptake of metabolities was inhibited by
chlorine injury as shown with experiments using 14C-labeled glucose and algal protein hydrolysate.
Appl Environ Microbiol. 1979 March; 37(3): 633-641

The wastewater regulators and industry has not even been keeping up with the new science that is only 20 years old..

Enteropathogenic and indicator bacteria become injured in drinking water with exposure to sublethal levels of various biological, chemical
and physical factors. One manifestation of this injury is the inability to grow and form colonies on selective media containing surfactants. The
resulting underestimation of indicator bacteria can lead to a false estimation of water potability. m-T7 medium was developed specifically for
the recovery of injured coliforms (both "total" and fecal) in drinking water. The m-T7 method was used to survey operating drinking water
treatment and distribution systems for the presence of injured coliforms that were undetected with currently used media. The mean recovery
with m-Endo LES medium was less than 1/100 ml while it ranged between 6 and 68/100ml with m-T7 agar. The majority of samples giving
positive results with m-T7 medium yielded no detectable coliforms with m-Endo LES agar. Over 95% of the coliform bacteria in these
samples were injured. Laboratory experiments were also done to ascribe the virulence of injured waterborne pathogens. Enteropathogens
including Salmonella typhimurium, Yersinia enterocolitica and Shigella spp. required up to 20 times the chlorine levels to produce the same
injury in enterotoxigenic Escherichia coli (ETEC) and nonpathogenic coliforms. Similar results were seen with Y. enterocolitica exposed to
copper. The recovery of ETEC was followed by delayed enterotoxin production, both in vitro and in the gut of experimental animals. This
indicates that injured waterborne enteropathogenic bacteria can be virulent. (Water Sci Technol. 1986;18(10):227-31)

Recent scientific research, as noted, has caused the wastewater industry to further rethink the removal and inactivation
process when dewatering sewage sludge. Sewage sludge is the second stream of effluent with 1/2 to 4 percent solids in it.

The search for salmonella is the only bacteriological index included in Italian guidelines (in accordance with EU regulations) for the use of
sewage sludge in agriculture. As a result, information regarding the presence of Listeria monocytogenes is rather limited. We therefore
decided to carry out an investigation of Listeria in the sludge produced by the Bologna (Italy) treatment plant during the various phases of
treatment. Five different types of sludge were analysed (primary raw, activated, thickened, digested and dewatered) in a total of 66 samples.
The highest frequency and concentrations of Listeria species (100% and 2,743 MPN/g dry matter) and the lowest (63% and 6 MPN/g dry
matter) were found in the activated and digested sludge respectively. These bacteria were mostly present in spring and autumn and
positively correlated only with fecal streptococci. Four species were isolated: Listeria monocytogenes, Listeria innocua, Listeria welshimeri
and Listeria grayi. Listeria monocytogenes (prevalent serotype 4b) was seen to be resistent to the biological oxidation but sensitive to
anaerobic conditions during thickening and digestion. The dewatering process led to an increase in contamination. Since the sludge is used
to fertilize land destined for vegetable farming our results show that it may represent a potential health risk. An understatement by the
Department of Medicine and Public Health, University of Bologna, Italy

Dr. Edo McGowan is concerned about the damage to health by reuse of sewage effluent in California. He states, "To initiate
septic abortion, just a single Listeria bacterium will do it. Once within the placenta, these bacteria are not responsive to the mother's immune
system, which is changed during pregnancy. The bacteria then multiply undetected and both the developing babe and mother fall to the
infection.What is being discussed here in is the failure of standards to appreciate these issues. Yet, produce is in the market and that
produce is also uses reclaimed or recycled wastewater used for irrigation. We have a similar issue right here in Santa Barbara with the use
of reclaimed water for our parks. The city fails to appreciate the risk and stands on the claim that the water meets all standards. The
standards are antiquated, the city understands this, the city could initiate higher standards but fails to do so, and the city has no internal
public health arm to guide it. A citizens advisory committee on public health is needed by this city."

The standards Dr. McGowan refers to is the use of a coliform test at the treatment plant to assure the public that treated fecal
material is safe for public contact. The Water Environment Federation (WEF) (waste industry representatives) has finally
published a study showing that the high levels of treatment measured by the coliform test doesn't work.

“Basically, what happens is when you come out of digestion and go into a dewatering device, you have one density of fecal coliform and
then, immediately after dewatering, that level increases by one, two, three, or four orders of magnitude,” said Matthew Higgins, associate
professor in the Department of Civil and Environmental Engineering at Bucknell University (Lewisburg, Pa.), and a principal investigator for
the WERF study.

Since the reactivated coliform group of bacteria are known human pathogens, the dewatered sludge would be classified as a
hazardous waste under the RCRA.

We are told that the Metropolitan Wastewater Treatment Facility in St. Paul, MN., regularly wins state and national awards for
operational excellence. However, the facility still releases treated effluent (clean water) carrying 300,000 tetracycline-
resistant bacteria per liter in winter (November to April) and 30,000 tetracycline-resistant bacteria per liter in the summer.
Anyway you look at it, that is some very hazardous toxic pollutants under the CWA. LaPara said, "about 99.6% and 99.97% of the
resistant bacteria in the aeration tanks are removed in the winter and summer." Using the summer figure of 99.7%, according to
LaPara, there are still "10 trillion tetracycline-resistant bacteria released each day from this treatment facility into our waterways" (Study
in UMN cura reporter, fall 2006)

Drug resistant bacteria coming out of sewage treatment plants and gene transfer has been a growing problem since it was
first reported in the 1950s. Furthermore, there could be any of the 1,407 disease causing organisms in sewage effluent.

In recognition of the many constraints associated with analyzing wastewater for all of the potential pathogens that may be present, it has
been common practice to use a microbial indicator or surrogate to indicate fecal contamination of water. Some bacteria of the coliform group
have long been considered the prime indicators of fecal contamination and are the most frequently applied indicators used by state
regulatory agencies to monitor water quality. The coliform group is composed of a number of bacteria that have common metabolic
attributes. The total coliform groups are all gram-nega-tive aspogenous rods, and most are found in feces of warm-blooded animals and in
soil. Fecal coliforms are, for the most part, bacteria restricted to the intestinal tract of warm-blooded animals and comprise a portion of the
total coliform group. Coliform organisms are used as indicators because they occur naturally in the feces of warm-blooded animals in higher
concentrations than pathogens, are easily detectable, exhibit a positive correlation with fecal contamination, and generally respond similarly
to environmental conditions and treatment processes as many bacterial pathogens. Where low levels of coliform organisms are used to
indicate the absence of pathogenic bacteria, there is consensus among microbiologists that the total coliform analysis is not superior to the
fecal coliform analysis. Specific methods have been developed to detect and enumerate Escherichia coli for use as a potential indicator
organism.

Can you imagine -- using indicator organisms to test for potential fecal contamination in sewage sludge or effluent?
The fact is that when sewage sludge and effluent is involved, the waste regulators and industry don't want any microbiologists
involved in their magical game. This is an example of the wastewater regulators smoke and mirror scam, as noted early, all 12
of the enteric coliform bacteria, including Escherichia coli are now pathogens, but they have been used as indicator organisms
by U.S. Public Health Service since 1914. Yet, the El Dorado County, CA. Environmental Health said:

Coliforms are a group of bacteria which are readily found in soil, decaying vegetation, animal feces, and raw surface water. They are
not normally present in deep groundwater and treated surface water. These indicator organisms may be accompanied by pathogens (i.e.,
disease-causing organisms), but do not normally cause disease in healthy individuals. However, individuals with compromised immune
systems should be considered at risk. Coliforms, rather than the actual pathogens, are used to assess water quality because their detection
is more reliable. Pathogens appear in smaller numbers than coliforms, so are less likely to be isolated. Drinking water found to contain
coliforms is considered biologically contaminated.

The saving grace is that most healthy people, most of the time, may come in contact with the coliform pathogens (and others)
and not get sick. Even the Black Plague and Spanish flu didn't infect everyone. However, some disease organisms and
chemicals take weeks, months or years to show up.

The most common parasites in domestic untreated wastewater include several genera in the microspora, protozoa, trematode, and
nematode families. Since the parasites cannot multiply in the environment, they require a host to reproduce and are excreted in the feces as
spores, cysts, oocysts, or eggs, which are robust and resistant to environmental stresses such as dessication, heat, and sunlight. Most
parasite spores, cysts, oocysts, and eggs are larger than bacteria and range in size from 1 μm to over 60 μm. While these parasites can be
present in the feces of infected individuals who exhibit disease symptoms, carriers with unapparent infections can also excrete them, as may
be the case with bacteria and viral infections as well. Furthermore, some protozoa such as Toxoplasma and Cryptosporidium are among the
most common opportunistic infections in patients with acquired immunodeficiency syndrome (AIDS) (Slifko et al., 2000).

There are several helminthic parasites that occur in wastewater. Examples include the roundworm Ascaris as well as other nematodes such
as the hookworms and pinworm. Many of the helminths have complex life cycles, including a required stage in intermediate hosts. The
infective stage of some helminths is either the adult organism or larvae, while the eggs or ova of other helminths constitute the infective
stage of the organisms. The eggs and larvae, which range in size from about 10 μm to more than 100 μm, are resistant to environmental
stresses and may survive usual wastewater disinfection procedures.

In recent years, the protozoan parasites have emerged as a significant human health threat in regards to chlorinated drinking water. In
particular, the protozoa such as Giardia lamblia, Cryptosporidium pavum, and Cyclospora cayetanensis have caused numerous waterborne
and/or foodborne outbreaks. Microsporidia spp. have also been implicated as a waterborne pathogen (Cotte et al., 1999).

As an example, the 1993 Milwaukee Cryptosporidium outbreak which infected 400,000 people, put 4,000 in the hospital and
killed about 400 people was, according to CDC's DNA comparison test, a human type Cryptosporidium which did not infect
animals. Sewage contaminated the drinking water system, but the problem was blamed on animal manure.

Viruses are obligate intracellular parasites able to multiply only within a host cell and are host-specific. Viruses occur in various shapes and
range in size from 0.01 to 0.3 μm in cross-section and are composed of a nucleicacid core surrounded by an outer coat of protein.
Bacteriophage are viruses that infect bacteria as the host; they have not been implicated in human infections and are often used as
indicators in seeded virus studies. Coliphages are host specific viruses that infect the coliform bacteria.

Enteric viruses multiply in the intestinal tract and are released in the fecal matter of infected persons. Not all types of enteric viruses have
been determined to cause waterborne disease, but over 100 different enteric viruses are capable of producing infections or disease. In
general, viruses are more resistant to environmental stresses than many of the bacteria, although some viruses persist for only a short time
in wastewater. The Enteroviruses, Rotavirus, and the Enteric Adenoviruses, which are known to cause respiratory illness, gastroenteritis,
and eye infections, have been isolated from wastewater. Of the viruses that cause diarrheal disease, only the Noroviruss and Rotavirus
have been shown to be major waterborne pathogens (Rose, 1986) capable of causing large outbreaks of disease.

Bacteria, viruses, and parasites can all be detected in wastewater. Studies of pathogens have reported average levels of 6.2, 5.8, and 5.3
log cfu/100ml of Yersinia, Shigella, and Salmonella detected in primary-clarified sewage influent over a 2-year period in a U.S. facility (Hench
et al., 2003). Salmonella may be present in concentrations up to 10,000/l. The excretion of Salmonella typhi by asymptomatic carriers may
vary from 5 x 103 to 45 x 106 bacteria/g of feces. But there are few studies in recent years, which have directly investigated the presence of
bacterial pathogens and have focused more often on the indicator bacteria. Concentrations excreted by infected individuals range from 106
cysts, 107 oocysts and as high as 1012 virus particle per gram of feces for Giardia, Cryptosporidium, and Rotavirus, respectively (Gerba,
2000). Pathogen levels in wastewater can vary depending on infection in the community.

The methods currently used to detect Cryptosporidium oocysts and Giardia cysts are limited since they cannot assess viability or potential
infectivity. Therefore, the health risks associated with finding oocysts and cysts in the environment cannot be accurately ascertained from
occurrence data and the risks remain unknown.

Dowd et al. (1998) described a polymerase chain reaction (PCR) method to detect and identify the microsporidia (amplifying the small
subunit ribosomal DNA of microsporidia). They found isolates in sewage, surface waters, and ground waters. The strain that was most often
detected was Enterocytozoon bieneusi, which is a cause of diarrhea and excreted from infected individuals into wastewater. Microsporidia
spores have been shown to be stable in the environment and remain infective for days to weeks outside their hosts (Shadduck, 1989;
Waller, 1980; Shadduck and Polley, 1978). Because of their small size (1 to 5 μm), they may be difficult to remove using conventional
filtration techniques. However, initial studies using cell culture suggest that the spores may be more susceptible to disinfection (Wolk et al.,
2000).

Under experimental conditions, absorption of viruses and E. coli through plant roots, and subsequent acropetal translocation has been
reported (Murphy and Syverton, 1958). For example, one study inoculated soil with Polio virus, and found that the viruses were detected in
the leaves of plants --.

Enteroviruses have been recovered from sewage treatment plant discharges (1, 3, 4-7, 9, 22, 23). The quantity and types of viruses in
sewage vary with the contributing population and the virus removal efficiency of the sewage treatment plant. Studies on virus removal from
sewage, effluents, and other waters emphasized the deficiencies of the various treatment methods and indicated that viruses could survive
even after secondary and tertiary sewage treatment. Survival of poliovirus 1 in soil irrigated with inoculated sewage sludge and effluent was
determined during two summer growing seasons and one winter period. The longest period of survival was during the winter, when virus was
detected after 96 days. During the summer, the longest survival period was 11 days. Poliovirus 1 was recovered from the mature vegetables
23 days after flooding of the plots had ceased. (TIERNEY, et.al., 1977)

Despite the scientific facts, Los Angeles County Sanitation Districts' gatekeeper, Earle Hartling, has a different view. Earle is
the sewage Water Recycling Coordinator for the southern California districts. In discussing a San Diego tertiary water
recycling plant that didn't get built, he states.
Virus removal was not deemed “problematical,” rather, the level of removal had been recalculated by the project designers and lowered from
a 26 log removal to a 24 log removal. If you have any scientific background, you’ll know this means removal by a factor of 1 with 24 zeros
behind it, instead of 1 with 26 zeros behind it. This removal efficiency is staggeringly high, and the practical difference between the two
removals is statistically insignificant.
Earle seems to have a problem with his scientific math calculations? If one log is a 90% removal and a 5 log is a 99.999%
removal, then what exactly does 24 zeros behind the decimal point mean, or 24 nines for that matter?

Application of E. coli O157:H7-contaminated manure to the production field or irrigation with E. coli O157:H7-contaminated water may result
in contamination of the crop in the field. Studies have indicated that E. coli can survive for extended periods in manure and water (7, 11).
We have demonstrated that lettuce grown in soil containing contaminated manure or irrigated with contaminated water results in
contamination of the edible portion of the lettuce plant. Moreover, the results suggest that edible portions of a plant can become
contaminated without direct exposure to a pathogen but rather through transport of the pathogen into the plant by the root system. We
recognize that the levels of E. coli O157:H7 used in this study are far greater than what may be found on an agricultural field; however,
numbers of bacteria were used that could be readily detected by the assays used in the present study. Under natural conditions, even a low
level of contamination could present a significant human health risk, since the infective dose of E. coli O157:H7 is less than 1,000 cells (1).
Research suggests that surface sanitizing of lettuce is not an effect method to eliminate all E. coli O157:H7 cells (3, 14). The inaccessibility
of a large number of organisms, as a consequence of their subsurface location, is perhaps the reason for the lack of effectiveness of
surface-sanitizing treatments. The impacts of on-farm practices which may result in E. coli O157:H7 becoming associated with lettuce, or for
that matter other crops, have not been sufficiently explored. Applied and Environmental Microbiology, January 2002, p. 397-400, Vol. 68,
No. 1

Survival profiles of Salmonella on vegetables and soil samples contaminated by irrigation water were similar to those observed when
contamination occurred through compost. Analysis of carrots grown in amended soils began on day 42 and that of radishes began on day
21, when the vegetables were large enough for sampling. Serovar Typhimurium was detected for 203 days on carrots and for 84 days on
radishes after seeds were sown (Fig. 3 and 4). Initial serovar Typhimurium cell numbers ranged from 1.8 to 3.83 log10 CFU g of carrots−1
(Fig. 3) and from 1.53 to 2.36 log10 CFU g of radishes−1 (Fig. 4) at the initial day of sampling (42 and 21 days, respectively). Serovar
Typhimurium cell numbers on carrots declined progressively with time but remained in approximately the same range through 84 days on
radishes. At approximate dates when radishes (day 57) and carrots (day 149) were harvestable, serovar Typhimurium counts were 1.0 to
2.5 and 1.0 to 1.2 log10 CFU g−1 on the vegetables, respectively. The radishes (91 days) and carrots (231 days) were grown well beyond
normal growing cycles to enable determination of the length of time salmonellae could survive in soil under field conditions. Appl Environ
Microbiol. 2004 April; 70(4): 2497–2502.

Most pathogens do not increase in numbers outside of their host, although in some instances the ova of helminths do not mature to the
larval stage until they are in the soil. In all cases, the numbers decrease at various rates, depending on a number of factors including the
inherent biologic nature of the agent, temperature, pH, sunlight, relative humidity, and competing flora and fauna.

As noted above, not always true, and there appears to be a seasonal ebb and flow of the numbers.

Pathogens and Indicator Organisms in Reclaimed Water

There have been a number of studies regarding the presence of pathogens and indicator organisms in reclaimed water and such studies
continue as experience in this field expands. Koivunen et al. (2003) compared the reduction of fecal coliforms to the reduction of Salmonella
by conventional biological treatment, filtration, and disinfection. Fecal coliform bacteria were present at 1000 fold greater concentration, and
the Salmonella bacteria were reduced to non-detectable levels by advanced treatment (greater than 99.9 percent). Fecal coliform bacteria
were a good, conservative indicator of such reductions. However, given the numbers of Salmonellae in secondary effluents and the fact that
18 carried multiple antibiotic resistance, the authors concluded that without proper additional advanced treatment, there may be a significant
public health risk.

A year-long study investigated a conventional reuse treatment facility in St. Petersburg, Florida (Rose et al., 1996). In this facility, deep-bed
sand filtration and disinfection, with total chlorine residual (4 to 5 mg/L) were the barriers assessed through both monitoring of naturally
occurring bacteria, protozoa, and viruses, as well as through seeded challenge studies. Removals were 5 log for human viruses and
coliphage indicators, with anywhere from 1.5 to 3 log reductions by disinfection. A 3 log reduction for protozoa was achieved and greater
than 1 log reduction was achieved for bacteria and indicators. Protozoan viability was not evaluated. In this study, Enterococci and
Clostridium were not included as alternative indicators. Only the phage was used as a virus indicator. Seeded trials using bacteriophage
demonstrated a 1.5 and 1.6 log reduction by filtration and disinfection, respectively.

A second study was done at the Upper Occoquan Sewage Authority (UOSA) in Fairfax County, Virginia. Samples were collected once per
month for 1 year from 8 sites from the advanced wastewater reclamation plant (Rose et al., 2000). The 8 sites were monitored for indicator
bacteria, total and fecal coliforms, enterococci, Clostridium, coliphage (viruses which infect E.coli), human enteric viruses, and enteric
protozoa. Multimedia filtration reduced the bacteria by approximately 90 percent, but did not effectively reduce the coliphage or
enteroviruses. The enteric protozoa were reduced by 85 to 95.7 percent. Chemical lime treatment was the most efficient barrier to the
passage of microorganisms (reducing these microorganisms by approximately 99.99 percent for bacteria, 99.9 percent for Clostridium and
enteroviruses, and 99 percent for protozoa). Disinfection was achieved through chlorination (free chlorine residuals of 0.2 to 0.5 mg/l), and
effectively achieved another 90 to 99 percent reduction. Overall, the plant was able to achieve a 5 to 7 log reduction of bacteria, 5 log
reduction of enteroviruses, 4 log reduction of Clostridium, and 3.5 log reduction of protozoa. Total coliforms, enterococci, Clostridium,
coliphage, Cryptosporidium, and Giardia were detected in 4 or fewer samples of the final effluent. No enteroviruses or fecal coliforms were
detected. Protozoa appeared to remain the most resistant microorganisms found in wastewater. However, as with the St. Petersburg study,
protozoan viability in these studies was not addressed.

Lime raises the pH factor which causes bacteria injury and the bacteria become non-detectable (i.e. viable, but nonculturable
by standard lab methods). EPA's John Walker first reported on this phenomenon in 1973 when he was with USDA, where it was
found bacteria returned to original levels after 30 days.

Visual inspection studies in Florida and elsewhere routinely found Giardia cysts and Cryptosporidium oocysts in reclaimed water that
received filtration and high-level disinfection and was deemed suitable for public access uses. A number of more detailed studies which
considered the viability and infectivity of the cysts and oocysts suggested that Giardia was likely inactivated by chlorine but 15 to 40 percent
of detected Cryptosporidium oocysts may survive (Keller, 2002; Sheikh, 1999; Garcia, 2002; Genacarro, 2003; Quintero, 2003).

Aerosols

Aerosols are defined as particles less than 50 μm in diameter that are suspended in air. Viruses and most pathogenic bacteria are in the
respirable size range; hence, the inhalation of aerosols is a possible direct mean of human infection. Aerosols are most often a concern
where reclaimed water is applied to urban or agricultural sites with sprinkler irrigation

The concentration of pathogens in aerosols is a function of their concentration in the applied water and the aerosolization efficiency of the
spray process. During spray irrigation, the amount of water that is aerosolized can vary from less than 0.1 percent to almost 2 percent, with
a mean aerosolization efficiency of 1 percent or less. Infection or disease may be contracted indirectly by deposited aerosols on surfaces
such as food, vegetation, and clothes. The infective dose of some pathogens is lower for respiratory tract infections than for infections via
the gastrointestinal tract. Therefore, for some pathogens, inhalation may be a more likely route for disease transmission than either contact
or ingestion.

The infectivity of an inhaled aerosol depends on the depth of the respiratory penetration and the presence of pathogenic
organisms capable of infecting the respiratory system. Aerosols in the 2 to 5 μm size range are generally excluded from the respiratory tract,
with some that are subsequently swallowed. Thus, if gastrointestinal pathogens are present, infection could result. A considerably greater
potential for infection occurs when respiratory pathogens are inhaled in aerosols smaller than 2 μm in size, which pass directly to the alveoli
of the lungs (Sorber and Guter, 1975).

One of the most comprehensive aerosol studies, the Lubbock Infection Surveillance Study (Camann et al., 1986), monitored viral and
bacterial infections in a mostly rural community surrounding a spray injection site near Wilson, Texas. The source of the irrigation water was
undisinfected trickling filter effluent from the Lubbock Southeast water reclamation plant. Spray irrigation of the wastewater significantly
elevated air densities of fecal coliforms, fecal streptococci, mycobacteria, and coliphage above the ambient background levels for at least
650 feet (200 meters) downwind. The geometric mean concentration of enteroviruses recovered 150 to 200 feet (44 to 60 meters) downwind
was 0.05 pfu/m3, a level higher than that observed at other wastewater aerosol sites in the U.S. and in Israel (Camann et al., 1988). While
disease surveillance found no obvious connection between the self-reporting of acute illness and the degree of aerosol exposure,
serological testing of blood samples indicated that the rate of viral infections was slightly higher among members of the study population who
had a high degree of aerosol exposure (Camann et al., 1986).

For intermittent spraying of disinfected reclaimed water, occasional inadvertent contact should pose little health hazard from inhalation.
Cooling towers issue aerosols continuously, and may present a greater concern if the water is not properly disinfected. Although a great
deal of effort has been expended to quantify the numbers of fecal coliforms and enteric pathogens in cooling tower waters, there is no
evidence that they occur in large numbers, although the numbers of other bacteria may be quite large (Adams and Lewis, n.d.).

Epidemiological investigations have focused on waste-water-contaminated drinking water supplies, the use of raw or minimally-treated
wastewater for food crop irrigation, health effects to farm workers who routinely contact poorly treated wastewater used for irrigation, and the
health effects of aerosols or windblown spray emanating from spray irrigation sites using undisinfected wastewater. These investigations
have all provided evidence of infectious disease transmission from such practices (Lund, 1980; Feachem et al., 1983; Shuval et al., 1986).

Review of the scientific literature, excluding the use of raw sewage or primary effluent on sewage farms in the late 19th century, does not
indicate that there have been no confirmed cases of infectious disease resulting from reclaimed water use in the U.S. where such use has
been in compliance with all appropriate regulatory controls. However, in developing countries, the irrigation of market crops with poorly
treated wastewater is a major source of enteric disease (Shuval et al., 1986).

compliance with all appropriate regulatory controls has little or nothing to do with science, public health, the environment, or
the environmental laws.

Occurrences of low level or endemic waterborne diseases associated with exposure to reclaimed water have been difficult to ascertain for
several reasons:

Current detection methods have not been sufficiently sensitive or specific enough to accurately detect low concentrations of
pathogens, such as viruses and protozoa, even in large volumes of water.

Many infections are often not apparent, or go unreported, thus making it difficult to establish the endemicity

of such infections.

The apparently mild nature of many infections preclude reporting by the patient or the physician.

Current epidemiological techniques are not sufficiently sensitive to detect low-level transmission of these diseases through water.

Illness due to enteroviral or parasite infections may not become obvious for several months or years.

Once introduced into a population, person-to-person contact can become a secondary mode of transmission

of many pathogens, thereby obscuring the role of water in its transmission.

Because of the insensitivity of epidemiological studies to provide a direct empirical assessment of microbial health risk due to low-level
exposure to pathogens, methodologies have increasingly relied on indirect measures of risk by using analytical models for estimation of the
intensity of human exposure and the probability of human response from the exposure. Microbial risk assessment involves evaluating the
likelihood that an adverse health effect may occur from human exposure to one or more potential pathogens. Most microbial risk
assessments in the past have used a framework originally developed for chemicals that is defined by 4 major steps: (1) hazard identification,
(2) dose-response identification, (3) exposure assessment, and (4) risk characterization. However, this framework does not explicitly
acknowledge the differences between health effects due to chemical exposure versus those due to microbial exposure. Those differences
include acute versus chronic health effects, potential for person-to-person transmission of disease, and the potential need to account for
the epidemiological status of the population (Olivieri, 2002).

At the present time, no wastewater disinfection or reclaimed water standards or guidelines in the U.S. are based on risk assessment using
microorganism infectivity models. Florida is investigating such an approach and has suggested levels of viruses between 0.04 to 14/ 100 l,
depending on the virus (ranging from Rotavirus infectivity to a less infectious virus), viable oocysts at 22/ 100 l, and viable cysts at 5/100 l
(York and Walker-Coleman, 1999). Microbial risk assessment methodology is a useful tool in assessing relative health risks associated with
water reuse. Risk assessment will undoubtedly play a role in future criteria development as epidemiological-based models are improved and
refined.

Risk assessment has been used as a public relations ploy by EPA where sewage is concerned. As an example, EPA wrote a
144 page book, A Guide to the Biosolids Risk Assessment for the EPA Part 503 Rule. On page 110, EPA admitted it did not
include cancer causing organics, inorganics-metals or disease organisms as a part of the risk assessment. Yet, EPA
acknowledges in 503.9(t) that these substances could cause death, disease and cancer, etc., to organisms--a CWA term for all
living things in water. Only under the RCRA do these same substances cause death, disease, cancer, etc., to humans.

Chemical Constituents

The chemical constituents potentially present in municipal wastewater are a major concern when reclaimed water is used for potable reuse.
These constituents may also affect the acceptability of reclaimed water for other uses, such as food crop irrigation or aquaculture. Potential
mechanisms of food crop contamination include:

Physical contamination, where evaporation and repeated applications may result in a buildup of contaminants

on crops

Uptake through the roots from the applied water or the soil, although available data indicate that potentially toxic organic pollutants
do not enter edible portions of plants that are irrigated with treated municipal wastewater (National Research Council, 1996)

Foliar uptake

"The uptake and movement of a chemical into a wheat leaf has been simulated in a 5-compartment model. The compound is considered to
be applied to the leaf as discrete droplets of solution, from which water evaporates at a uniform rate. Solute diffuses from the droplets
through the plant cuticle into the epidermal cell wall, and from there either into and out of the cytoplasm and vacuole of the mesophyll cells
or along cell walls to the xylem. Once in the xylem it is carried in the transpiration stream towards the tip of the leaf." (Bridges, 1974)

Inorganics

In general, the health hazards associated with the ingestion of inorganic constituents, either directly or through food, are well established (U.
S. EPA, 1976). EPA has set maximum contaminant levels (MCLs) for drinking water. The concentrations of inorganic constituents in
reclaimed water depend mainly on the source of wastewater and the degree of treatment. Residential use of water typically adds about 300
mg/l of dissolved inorganic solids, although the amount added can range from approximately 150 mg/l to more than 500 mg/l (Metcalf &
Eddy, 2002). As indicated in Table 3-11 the presence of total dissolved solids, nitrogen, phosphorus, heavy metals, and other inorganic
constituents may affect the acceptability of reclaimed water for different reuse applications. Wastewater treatment using existing technology
can generally reduce many trace elements to below recommended maximum levels for irrigation and drinking water. Uses in wetlands and
recreational surface waters must also consider aquatic life protection and wetland habitat.

Actually, United States Department of Agriculture studies (1974) indicated there could be very serious problems with tobacco grown on land
[including leafy vegetables such as spinach] where toxic sewage sludge was used because of the high uptake of Cadmium. "Chaney et
al. (84)--- observed Cd (Cadmium) content in tobacco to be 15 to 20 ppm at 1 ppm in the soil, and 45 ppm with 2 ppm Cd in the soil." (1)
http://www.penweb.org/issues/sludge/112.htm

It is interesting that the government can state there are some 4,000 chemicals in secondhand smoke which will cause death,
disease, cancer, etc., but if the chemicals are put on your food crops and in your water, in a state sponsored program they are
perfectly safe and there is no need to test for them?

Organics

The organic make-up of raw wastewater includes naturally occurring humic substances, fecal matter, kitchen wastes, liquid detergents, oils,
grease, and other substances that, in one way or another, become part of the sewage stream. Industrial and residential wastes may
contribute significant quantities of synthetic organic compounds. The need to remove organic constituents is related to the end use of
reclaimed water. Some of the adverse effects associated with organic substances include:

Aesthetic effects – organics may be malodorous and impart color to the water

Clogging – particulate matter may clog sprinkler heads or accumulate in soil and affect permeability

Proliferation of microorganisms – organics provide food for microorganisms

Oxygen consumption – upon decomposition, organic substances deplete the dissolved oxygen content in streams and lakes. This
negatively impacts the aquatic life that depends on the oxygen supply for survival

Use limitation – many industrial applications cannot tolerate water that is high in organic content

Disinfection effects – organic matter can interfere with chlorine, ozone, and ultraviolet disinfection, thereby making them less
available for disinfection purposes. Further, chlorination may result in formation of potentially harmful disinfection byproducts

Health effects – ingestion of water containing certain organic compounds may result in acute or chronic health effects.

The wide range of anthropogenic organic contaminants in streams influenced by urbanization (including wastewater contamination)
includes pharmaceuticals, hormones, antioxidants, plasticizers, solvents, polynuclear aromatic hydrocarbons (PAHs), detergents,
pesticides, and their metabolites (Kolpin et al., 2002). The stability and persistence of these compounds are extremely variable in the
stream/sediment environment. A recent comprehensive study of the persistence of anthropogenic and natural organic molecules
during groundwater recharge suggests that carbamezepine may survive long enough to serve as a useful tracer compound of
wastewater origin (Clara et al., 2004).

The health effects resulting from organic constituents are of primary concern for indirect or direct potable reuse. In addition, these
constituents may be of concern where reclaimed water is utilized for food crop irrigation, where reclaimed water from irrigation or other
beneficial uses reaches potable groundwater supplies, or where the organics may bioaccumulate in the food chain (e.g., in fish-rearing
ponds).

Waster regulators and industry have an organic secret. It's not just about plant uptake.
PLANT UPTAKE STUDIES OF TOXICS -- toxic organic may kill without leaving a trace.

Traditional measures of organic matter such as BOD, chemical oxygen demand (COD), and total organic carbon (TOC), are widely used as
indicators of treatment efficiency and water quality for many nonpotable uses of reclaimed water. However, these measures have only
indirect relevance related to evaluating toxicity and health effects. Sophisticated analytical instrumentation makes it possible to identify and
quantify extremely low levels of organic constituents in water. Examples include gas chromatography/tandem mass spectrometry (GC/MS/
MS) or high performance liquid chromatography/mass spectrometry (HPLC/MS). These analyses are costly and may require extensive and
difficult sample preparation, particularly for nonvolatile organics.

Organic compounds in wastewater can be transformed into chlorinated organic species where chlorine is used for disinfection purposes. In
the past, most attention was focused on the trihalomethane (THM) compounds; a family of organic compounds typically occurring as chlorine
or bromine-substituted forms of methane. Chloroform, a commonly found THM compound, has been implicated in the development of cancer
of the liver and kidney. Improved analytical capabilities to detect extremely low levels of chemical constituents in water have resulted in
identification of several health-significant chemicals and disinfection byproducts in recent years. For example, the extremely potent
carcinogen, N-nitrosodimethylamine (NDMA) is present in sewage and is produced when municipal wastewater effluent is disinfected with
chlorine or chloramines (Mitch et al, 2003). In some situations, the concentration of NDMA present in reclaimed water exceeds action levels
set for the protection of human health, even after reverse osmosis treatment. To address concerns associated with NDMA and other trace
organics in reclaimed water, several utilities in California have installed UV/H2O2 treatment systems for treatment of reverse osmosis
permeate.

-unanswered questions remain about organic constituents, due mainly to their potentially large numbers and unresolved health risk
potentials related to long-term, low-level exposure. Assessment of health risks associated with potable reuse is not definitive due to limited
chemical and toxicological data and inherent limitations in available epidemiological and toxicological methods. The results of
epidemiological studies directed at drinking water have generally been inconclusive, and extrapolation methodologies used in toxicological
assessments provide uncertainties in overall risk characterization (National Research Council, 1998).

Table 3-11. Inorganic and Organic Constituents of Concern in Water Reclamation and Reuse

Source: Adapted from Pettygrove and Asano, 1985

Table 2-7. Recommended Limits for Constituents in Reclaimed Water for Irrigation

They left out Mercury
They also left out Thallium
Source: Adapted from Rowe and Abdel-Magid, 1995.

Endocrine Disrupters
In addition to the potential adverse effects of chemicals described in Section 3.4.1.6, certain chemical constituents
present in wastewater also can disrupt hormonal systems. This phenomenon, which is referred to as endocrine
disruption, can occur through a variety of mechanisms associated with hormone synthesis, hormone receptor binding, and hormone
transformation. As a result of the many mechanisms through which chemicals can impact hormone function, a large number of chemicals are
classified as endocrine disrupters. However, the exact types of chemicals that are classified as endocrine disrupters vary among
researchers.

For example, the oxyanion, perchlorate, is an endocrine disrupter because it affects the thyroid system (U.S. EPA, 2002). The herbicide,
atrazine, is an endocrine disrupter because it affects an enzyme responsible for hormone regulation (Hayes et al. 2002). A USGS project
recently sampled 139 streams in 30 states for any 1 of 95 endocrine disrupters. The results indicated that 80 percent of the streams had at
least 1 of these compounds (McGovern and McDonald, 2003). The topic of endocrine disruption has significant implications for a wide
variety of chemicals used by industry, agriculture, and consumers. As a result, the EPA, the European Union (EU), and other government
organizations are currently evaluating approaches for regulating endocrine-disrupting chemicals.

With respect to water reuse, the greatest concerns associated with endocrine disruption are related to a series of field and laboratory
studies demonstrating that chemicals in wastewater effluent caused male fish to exhibit female characteristics (Purdom et al., 1994; Harries
et al., 1996; Harries et al., 1997). This process, which is referred to as feminization, has been attributed mostly to the presence of steroid
hormones excreted by humans (Desbrow et al., 1998 and Snyder et al., 2001). The hormones involved in fish feminization include the
endogenous (i.e., produced within the body) hormone 17b-es-tradiol as well as hormones present in pharmaceuticals (e.g., ethinyl estradiol
in birth control pills). Other chemicals capable of feminizing fish are also present in wastewater. These include nonylphenol and alkylphenol
polyethoxylates, both of which are metabolites of nonionic detergents formed during secondary wastewater treatment (Ahel et al., 1994).

The specific endocrine-disrupting chemicals in reclaimed water can be quantified using modern analytical methods. As indicated previously,
the compounds most likely to be responsible for feminization of fish include steroid hormones (e.g., 17b-estradiol and ethinyl estradiol) and
detergents metabolites (e.g., nonylphenol and alkylphenol polyethoxylates). Although these compounds cannot be quantified at the levels
expected in reclaimed water with the gas chromatography/mass spectrometry (GC/MS) techniques routinely used to quantify priority
pollutants, they can be measured with equipment available in many modern laboratories. For the hormones, analytical methods
such as gas chromatography/tandem mass spectrometry (GC/MS/MS) (Ternes et al., 1999, Huang and Sedlak, 2001), high performance
liquid chromatography/ mass spectrometry (HPLC/MS) (Ferguson et al., 2001), or immunoassays (Huang and Sedlak, 2001 and Snyder et
al., 2001) are needed to detect the low concentrations present in wastewater effluent (e.g., ethinyl estradiol concentrations are typically less
than 2 υg/l in wastewater effluent). Although the endocrine-disrupting detergent metabolites are present at much higher concentrations than
the hormones, their analysis also requires specialized analytical methods (Ahel et al., 1994) not available from many commercial
laboratories.

The current focus of research on disruption of the estrogen system may be attributable to the relative ease of detecting this form of
endocrine disruption. As additional research is performed, other chemicals in wastewater effluent may be found to disrupt hormonal systems
through mechanisms yet to be documented. For example, although results from in vitro bioassays suggest that the steroid hormones are
most likely responsible for feminization of fish, it is possible that other endocrine disrupters contribute to the effect through mechanisms that
cannot be detected by the bioassays.

The ecological implications associated with the feminization of fish are unknown. The potential of reclaimed water to cause endocrine
disruption in humans is also unknown. It is anticipated that problems associated with endocrine disruption could occur, given prolonged
consumption of substantial volumes of polluted water. The compounds in wastewater effluent that are believed to be responsible for
feminization of fish may not pose a serious risk for humans because of differences between human and fish physiology. For example, the
hormone 17b-estradiol is not used in the oral form in clinical applications because it would be metabolized before it could reach its target.
Nevertheless, the evidence of endocrine disruption in wildlife and the absence of data about the effects of low-level exposure to endocrine
disrupting compounds in humans has led to new scrutiny regarding endocrine-disrupting chemicals in reclaimed water.

Table 3-12. Examples of the Types and Sources of Substances that have been Reported as Potential Endocrine-Disrupting Chemicals

Source: Adapted from McGovern and McDonald, 2003 and Berkett and Lester, 2003

http://www.epa.gov/ORD/NRMRL/pubs/625r04108/625r04108chap3.pdf

The reclaimed sewage effluent irrigation program has been a very low profile program for the waste regulators and industry.
Today, it is claimed while virtually all other fields had an interest in the phenomenon of viable bacteria that was
nondetectable by standard methods, they knew nothing about the problem.

WEF waste disposal scientists now admit, "The issue of viable but non-culturable (VBNC) bacteria was advanced in the 1980s, and gained
significant interest in medicine, the food industry, and many other fields." For the past twenty-five years public health, our lives, as well as
the quality of our air, water and food has been firmly in the hands of waste disposal people within EPA and WEF. After 25 years of putting
the public health, air, water and food chain at risk by promoting sewage sludge as a safe fertilizer and garden soil amendment free of
disease causing organisms -- Twelve years of running a government funded public relations program to discredit people who have been
exposed to the disease causing organisms and suffered sickness, and even death --Ten years of funding scientific studies to assure the
public disease causing organisms in sludge are eliminated or killed -- these waste disposal scientists now want us to give them time to study
the problem and how to fix it. But, WEF only plans to do more research on one non-disease causing organism as an indicator for the 1,407
human pathogen species that may be in sludge and there is no fix to kill a spore forming bacteria or fungi.
http://deadlydeceit.com/wef-study-vbnc.html
http://deadlydeceit.com

States with Wastewater Reuse programs
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Iowa
Illinois
Indiana
Kansas

Pathogen	Fresh Water & Sewage	Crops	Soil
Viruses
Enteroviruses b	<120 but usually <50	<60 but usually <15	<100 but usually <20
Bacteria
Fecal coliforms a,c	<60 but usually <30	<30 but usually <15	<70 but usually <20
Salmonella spp. a	<60 but usually <30	<30 but usually <15	<70 but usually <20
Shigella spp. a	<30 but usually <10	<10 but usually <5	----
Vibrio cholerae d	<30 but usually <10	<5 but usually <2	<20 but usually <10
Protozoa
Entamoeba histolytica cysts	<30 but usually <15	<10 but usually <2	<20 but usually <10
Helminths
Ascaris lumbricoides eggs	Many months	<60 but usually <30	Many months

Pathogen	Absolute maximum a	Common Maximum	Absolute maximum b	Common maximum
Bacteria	1 year	2 months	6 months	1 month
Viruses	1 year c	3 months	2 months	1 month
Protozoan cysts d	10 days	2 days	5 days	2 days
Helminths ova	7 years	2 years	5 months	1 month

Soil

Plants

Survival Time (days) ( < ) means less than the number indicated

Constituent	Measured Parameters	Reasons for Concern
Suspended Solids	Suspended solids (SS), including volatile and absorbed on particulates.	Organic contaminants, heavy metals, etc. are absorbed on particulates. Suspended matter can shield microorganisms from disinfectants. Excessive amounts of suspended solids cause plugging in irrigation systems.
Biodegradable Organics	Biochemical oxygen demand, chemical oxygen demand, total organic carbon	Aesthetic and nuisance problems. Organics provide food for microorganisms, adversely affect disinfection processes, make water unsuitable for some industrial or other uses, consume oxygen, and may result in acute or chronic effects if reclaimed water is u (end is missing from EPA document)
Nutrients	Nitrogen, Phosphorus, Potassium	Nitrogen, phosphorus, and potassium are essential nutrients for plant growth and their presence normally enhances the value of the water for irrigation. When discharged to the aquatic environment, nitrogen and phosphorus can lead to the growth of undesir (end is missing from EPA document)
Stable Organics	Specific compounds (e.g., pesticides, chlorinated hydrocarbons)	Some of these organics tend to resist conventional methods of wastewater treatment. Some organic compounds are toxic in the environment, and their presence may limit the suitability of reclaimed water for irrigation or other uses. Chlorine reacts with man (end is missing on EPA document)
Hydrogen Ion Concentration	pH	The pH of wastewater affects disinfection, coagulation, metal solubility, as well as alkalinity of soils. Normal range in municipal wastewater is pH = 6.5 - 8.5, but industrial waste can alter pH significantly.
Heavy Metals	Specific elements (e.g., Cd, Zn, Ni, and Hg)	Some heavy metals accumulate in the environment and are toxic to plants and animals. Their presence may limit the suitability of the reclaimed water for irrigation or other uses.
Dissolved Inorganics	Total dissolved solids, electrical Conductivity, specific elements (e.g., Na, Ca, Mg, Cl, and B)	Excessive salinity may damage some crops. Specific inorganics electrical conductivity ions such as chloride, sodium, and boron are toxic to specific elements (e.g., in some crops, sodium may pose soil permeability Na, Ca, Mg, Cl, and B problems).
Residual Chlorine	Free and combined chlorine	Excessive amounts of free available chlorine (>0.05 Chlorine chlorine mg/l) may cause leaf-tip burn and damage some sensitive crops. However, most chlorine in reclaimed water is in a combined form, which does not cause crop damage. Some concerns are expre (end missing on EPA document)

Category	Examples of Substances	Examples of Uses	Examples of Sources
Polychlorinated Compounds	polychlorinated dioxins and polychlorinated biphenyls	industrial production of byproducts (mostly banned)	incineration and landfill runoff
Organochlorine Pesticides	DDT, dieldrin, and lindane	insecticides (many phased out)	agricultural runoff
Current Use Pesticides	atrazine, trifluralin, and permethrin	pesticides	agricultural runoff
Organotins	tributyltin	antifoulants on ships	harbors
Alkylphenolics	nonylphenol and octylphenol	surfactants (and their metabolites)	industrial and municipal effluents
Phthalates	dibutyl phthalate and butylbenzyl phthalate	plasticisers	industrial effluent
Sex Hormones	17-beta estradiol and estrone	produced naturally by animals (humans)	municipal effluents
Synthetic Steroids	ethinylestradiol	contraceptives	municipal effluents
Phytoestrogens	isoflavones, lignans, coumestans	present in plant material	pulp mill effluents

Constituent	Long-Term Use (mg/	Short-Term Use (mg/l)	Remarks
Aluminum	5.0	20.0	Can cause nonproductiveness in acid soils, but soils at pH 5.5 to 8.0 will precipitate the ion and eliminate toxicity.
Arsenic	0.10	2.0	Toxicity to plants varies widely, ranging from 12 mg/L for Sudan grass to less than 0.05 mg/L for rice.
Beryllium	0.10	0.5	Toxicity to plants varies widely, ranging from 5 mg/L for kale to 0.5 mg/L for bush beans.
Boron	0.75	2.0	Essential to plant growth, with optimum yields for many obtained at a few-tenths mg/L in nutrient solutions. Toxic to many sensitive plants (e.g., citrus) at 1 mg/L. Usually sufficient quantities in reclaimed water to correct soil deficiencies. Most grasses are relatively tolerant at 2.0 to 10 mg/L.
Cadmium	0.01	0.5	Toxic to beans, beets, and turnips at concentrations as low as 0.1 mg/L in nutrient solution. Conservative limits recommended.
Chromium	0.1	1.0	Not generally recognized as an essential growth element. Conservative limits recommended due to lack of knowledge on toxicity to plants.
Cobalt	0.05	5.0	Toxic to tomato plants at 0.1 mg/L in nutrient solution. Tends to be inactivated by neutral and alkaline soils.
Copper	0.2	5.0	Toxic to a number of plants at 0.1 to 1.0 mg/L in nutrient solution.
Fluoride	1.0	15.0	Inactivated by neutral and alkaline soils.
Iron	5.0	20.0	Not toxic to plants in aerated soils, but can contribute to soil acidification and loss of essential phosphorus and molybdenum.
Lead	5.0	10.0	Can inhibit plant cell growth at very high concentrations.
Lithium	2.5	2.5	Tolerated by most crops at concentrations up to 5 mg/L; mobile in soil. Toxic to citrus at low doses - recommended limit is 0.075 mg/L.
Manganese	0.2	10.0	Toxic to a number of crops at a few-tenths to a few mg/L in acidic soils.
Molybdenum	0.01	0.05	Nontoxic to plants at normal concentrations in soil and water. Can be toxic to livestock if forage is grown in soils with high levels of available molybdenum.
Nickel	0.2	2.0	Toxic to a number of plants at 0.5 to 1.0 mg/L; reduced toxicity at neutral or alkaline pH.
Selenium	0.02	0.02	Toxic to plants at low concentrations and to livestock if forage is grown in soils with low levels of selenium.
Tin, Tungsten, & Titanium	---	---	Effectively excluded by plants; specific tolerance levels unknown
Vanadium	0.1	1.0	Toxic to many plants at relatively low concentrations.
Zinc	2.0	10.0	Toxic to many plants at widely varying concentrations; reduced toxicity at increased pH (6 or above) and in fine-textured or organic soils.
Constituent	Recommended Limit		Remarks
pH	6.0		Most effects of pH on plant growth are indirect (e.g., pH effects on heavy metals’ toxicity described above).
TDS	500 - 2,000 mg/l		1,000 mg/L, TDS in irrigation water can affect sensitive plants. At 1,000 to 2,000 mg/L, TDS levels can affect many crops and careful management practices should be followed. Above 2,000 mg/L, water can be used regularly only for tolerant plants on permeable soils.
Free Chlorine Residual	<1 mg/l		Concentrations greater than 5 mg/l causes severe damage to most plants. Some sensitive plants may be damaged at levels as low as 0.05 mg/l.

„ Irrigation of public parks and recreation centers,
    athletic fields, school yards and playing fields,   highway
    medians and shoulders, and landscaped areas
surrounding public buildings and facilities
„ Irrigation of landscaped areas surrounding
single-family and multi-family residences, general
wash down, and other maintenance activities
„ Irrigation of landscaped areas surrounding
commercial, office, and industrial developments
„ Irrigation of golf courses

„ Commercial uses such as vehicle washing facilities,
laundry facilities, window washing, and mixing water
for pesticides, herbicides, and liquid fertilizers
„ Ornamental landscape uses and decorative water
features, such as fountains, reflecting pools, and
waterfalls
„ Dust control and concrete production for construction
projects
„ Fire protection through reclaimed water fire hydrants
„ Toilet and urinal flushing in commercial and industrial
buildings

Indiana
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey

New Mexico
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Virginia
Washington
West Virginia
Wyoming