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Fwd: Part 7 -- It began in New York

  • Subject: [cg] Fwd: Part 7 -- It began in New York
  • From: TheBynums@aol.com
  • Date: Wed, 23 May 2001 20:45:21 EDT


  • Subject: Part 7 -- It began in New York
  • From: TheBynums@aol.com
  • Date: Tue, 22 May 2001 05:58:51 EDT
  • Full-name: TheBynums
    "Trust Us, We're Experts", said EPA's Robert Bastian, Alan Rubin, and 
John Walker.  Congress said OK, but made its intent concerning the 
environment very clear, "Under RCRA solid waste do not cease to be solid 
waste simply because they are being used, re-used, recycled or reclaimed.  
Rather, use, re-use, recycling, resource recovery and reclamation are ways of 
managing solid waste, which, if properly conducted, can avoid environmental 
hazards, protect scarce land supply, and reduce the nation's reliance on 
foreign energy and materials ---Congress' "Overriding concern" --elimination 
of "the last remaining loophole" in environmental regulation" (H.R.Rep.at 4) .

     Well, maybe everyone didn't get the word. According to a memo from EPA's 
Robert E. Lee to EPA's John Walker and Bob Bastian, dated Oct.  17, 1994, the 
public relations campaign funding for the WEF would come from the EPA 104 
grant program which was restricted to "...establish national programs for the 
reduction, and elimination of pollution..." However, "Areas that we had 
considered using these funds include: 1. Odor Control Manual, 2. Sludge 
Horror Stories, 3. Biosolids Technical Assessment, 4.  Management of Class B, 
5. Arid Lands, 6. PCB's in Biosolids...What about one with a water shed 
twist....Ways to utilize biosolids in water sheds to mitigate other 
environmental problems...Bob B. maybe we should put one or some $ in for the 
wetlands work in watersheds also." 

This memo appear to be the authority Walker and Bastian used to create their 
debunking program within the EPA/WEF partnership. By this time of course, EPA 
had hooked a group of scientists and the National Academy of Science (NAS) 
into the debunking program. From 1993 to 1996,  the NAS  Committee ate up a 
lot of public money trying to figure out how to explain to the public that 
the use of sewage sludge was safe when used for growing food crops.
     The NAS Committee was up front about its purpose as it explains: "It is 
hoped that this report will be particularly useful to food processors, 
states, and municipalities in assessing the use of treated municipal 
wastewater and sludge in producing crops for human consumption." (p. viii)

     The last paragraph in the NAS report was a red flag concerning the 
nature of the science behind EPA's sludge disposal policy: "The suite of 
existing federal regulations, available avenues for additional state and 
local regulatory actions, and private sector forces appear adequate to allow, 
 with time and education, the development of safe beneficial reuse of 
reclaimed wastewater and sludge." (p. 172)

     Everyone in the government didn't sign off on the sludge dumping policy 
because,  Number 14 on the EPA list to debunk is, "BLM (Federal Bureau of 
Land Management) policy opposing use of biosolids on Federal lands: equating 
its use to hazardous waste dumping and landfilling raising SUPERFUND 
liability concerns." 

Michael Baram, a professor of public health law at the Boston University 
School of Public Health, one of the 14 authors of the report, also disagrees 
with the reports conclusion, not for the misstatements of facts on the 
federal regulations or law,
but for the infectious disease aspects.

      Baram's statement of public dissent is quoted by Joel Bleifuss in the 
June 10, 1996 edition of IN THESE TIMES: "Having served on the NAS [the 
National Academy of Sciences, which in turn operates the National Research 
Council], which authored the report, I would not want EPA-approved sludge 
applied to land in my community nor to land within the watershed of my water 
supply system. Nor would I want to 
purchase or consume sludge-grown foods or foods containing sludge-grown 
ingredients. ... [Sludge] poses risks to the  health of persons who would be 
exposed to it. ...The EPA regulation which permits farmland application of 
treated sludge (Part 503) does not prevent these risks." 

      Baram also puts the NAS Report in perspective.  "You can just look to 
see who's paying for all this, and you get a pretty good idea of the vested 
interest involved."
  Furthermore, according to Baram, "It's a main weakness of the report that 
it did not probe sufficiently into the infectious disease aspects... We spent 
most of our time just determining if the EPA used risk-analysis that met 
professional standards."

     Not only that, "But the trouble is," according to Baram, "that there 
were many (different topics of concern) they didn't include in the 
risk-analysis.  They only picked a subset of things to study and they didn't 
do risk-analysis of infectious disease organisms," he says.  (Baram is quoted 
from a Boulder Weekly article, As the Topsoil  Turns, by Greg Campbell, May 
2, 1996.  Baram's statement of public dissent
was also quoted in the article)

     The NAS claims that based on its scientific study,  sludge use on crops 
is safe. Yet, the NAS Committee did not review the one human health study 
(Municipal Sewage Sludge Application on Ohio Farms: Health Effects) published 
 in, Environmental Research 38, pp. 332-359, 1985. It was funded by the EPA 
and used by the EPA as the ultimate proof of the safety of sludge.

The NAS Report quoted an abstract by a third party and the study is 
re-titled, Demonstration of Acceptable Systems for Land Disposal of Sewage 

     The NAS Report also failed to reveal the Ohio study's finding that, 
"There have been no previous reported studies of the human health effect of 
land application of treated municipal sewage sludge."

   Moreover, it would appear that the NAS writer failed to read beyond the 
sixth paragraph of Brown's abstract.  Brown stated, in the seventh paragraph 
of the abstract, 
"Significantly higher fecal Cd (cadmium) concentrations in cattle, and 
significantly higher Cd and Pb (lead) accumulations were observed in kidney 
tissues of calves
grazing on sludge-amended pastures."

     Not only that, but the Ohio Study documented a (WHO. 1981) study, 
"....of Salmonella in cattle grazing on sludge amended pastures in 
Switzerland (which) have indicated a positive association and a cycle of 
infection from humans to
sludge to animals to humans."

      In the past, the EPA's main concern with toxic metals has been Cadmium, 
a poison which can be taken up by leafy plants grown on sludge amended soils 
such as tobacco which can accumulate up to 10 times the soil level of Cadmium 
in the leaves. Inhaling cadmium dust and fumes is very hazardous and will 
produce pulmonary edema.  It can cause death or delayed death from acute 
renal (kidney) failure.  Cadmium also concentrates in the liver and kidney of 
animals.  This could be a major concern for people who eat liver.

     The authors of the "Ohio" study  made it very clear the study was not to 
be used in the manner the EPA and NAS are now using it. In the actual 
abstract of the study, the researchers state, "The absence of observed human 
or animal health effects resulting from sludge application in this study of 
Ohio farms was associated with low sludge application rates which were in 
accordance with Ohio and U.S. Environmental Protection Agency guidelines. 
(Not current part 503 guidelines) Caution should be exercised in using these 
data to predict health risks associated with sludges
containing higher levels of disease agents and with higher sludge application 
rates and larger acreages treated per farm than used in this study."

     The NAS Committee admitted that it had no scientific idea how to deal 
with pathogens in sludge when it found, "Many of the variables associated 
with the transmission of infectious disease from wastewater and sludge are 
either not well
understood or are unpredictable." (p. 93-94)

     The NAS Report notes that the parasites are "quite resistant to chemical 
and physical disinfection"  (p. 96).  Yet, Salmonella, according to the EPA, 
is subject to
growth within 14 hours after the sludge leaves the treatment plant, even if 
it is Class A sludge.
       Furthermore, the NAS Report acknowledges cyanobacteria (blue-green 
algae) is found on sludge amended soil and that it reduces nitrogen fixation 
(p. 77).  They do not acknowledge that cyanobacteria has been reclassified as 
the parasite, Cyclospora, and the first infectious disease outbreak from 
Cyclospora was reported in 1990.

     Yet,  the NAS "Study" assures the public that Coxsackie Viruses and 
Echoviruses in sludge only cause "flu-like" symptoms.  However, according to 
Tabor's Cylopedic Medical Dictionary, the (sixty species `EPA') of the two 
viruses can also cause inflammation of the heart, spinal cord and brain.

    The NAS Report also acknowledged a major problem behind the scientific  
assumptions, "There are instances in sludge processing, such as composting, 
in which  the coliform levels cannot be satisfactorily reduced even though 
there is reason to believe that the sanitary quality of the material is 
otherwise acceptable (EPA, 1992b; Skanavis and Yanko, 1994)....Many of the 
parasites of concern exist in
the encysted stage outside of the human or animal intestinal track, and are 
quite resistant to chemical and physical disinfection in this form." (p.  94)

     The EPA's own research has documented the danger to humans and animals 
from the pollutants in sludge.  Besides toxic heavy metal, by 1989 the EPA 
had established a primary list of  25 pathogens (family groups) in sewage 
sludge which can cause serious damage.  Five pathogens are bacteria, nine are 
viruses, five are helminths, Five are protozoans and one is a fungi.  Most of 
these pathogens can be very deadly to humans and animals, the others will 
only make you wish you were dead.

     The bacteria Campylobacter jejuni and Escherichia primarily cause a 
relative mild case of diarrhea, while Salmonella, shigetla and Vibrio 
cholerae can lead to death.
The nine listed viruses are a little misleading, 1) Entroviruses or 
Picornaviruses actually includes 152 species and includes three of the listed 
viruses, many will cause pneumonia,  2) Poliovirus (3 species) causes 
inflammation of the grey matter of the spinal cord, 3) Coxsackievirus A (23 
species), B (6 species) mostly mild but can cause inflammation of heart in 
newborns, 4) Echovirus (31 species) primarily causes inflammation of the 
heart, spinal cord & brain, 5) Hepatitis A virus, can cause death , 6) 
Norwalk viruses, 7) Norwalk like viruses, mostly diseases of the 
gastrointestinal tract, 8) Reovirus, unknown,  9) Rotavirus, acute 

      The five Helminths actually produce different worms such as hookworms, 
tapeworms and nematode worms.  In humans, the nematode worms may end up in 
the brain, retina vessels, liver, lung and heart. The larve cause hemorrhage,
inflammation, necrosis in these tissues.  This causes myocarditis, 
endophthalmitis, epilepsy or encephalitis. The five Protozoans; 1) Toxoplasma 
gondii, causes pneumonitis, hepatitis and encephalitis, 2) Balantidium, is 
mild, 3) Entamoeba histolyca, forms liver abscess, 4) Giardia lambia, is the 
cause of severe intestinal problems, 5) Cryptosporidium, causes explosive 
diarrhea and cramps, it was
first described in humans in 1976.

      The one fungi considered is Aspergillus, it causes inflamed tissues in 
bronchi, lungs, aural canal, skin and membranes of the eye, nose or urethra. 
It may also produce mycotic nodules in the lungs, liver, kidney and other 
(FR 54-P.5829 & Tabor's Cylopedic Medical Dictionary).

     It appears that in spite of EPA claims to the contrary not only is it 
not safe to harvest any food or feed crops 30 days after sludge has been 
used, it's not safe to grow crops on pollutant contaminated soil a year after 
sludge has been applied.
      According to  D. Strauch, who is with the Institute of Animal Medicine 
and Hygiene, University of Hohenhiem,  Salmonella has survived in forest 
stands between 424 and 820 days.  Although the EPA claims  that any one of 
the six alternatives for Class A pathogen reduction will prevent regrowth of 
Salmonella, an EPA- sponsored survey of distribution and marketed sludges in 
the U. S. (Yanko 1987) found that Salmonella was often present in 
PFRP-treated sludges and sludge products (13) (high- temperature composting, 
heat-drying, heat treatment, and thermophilic aerobic digestion). The 
conclusion of the author was that the occurrence of pathogenic bacteria in 
distributed and marketed sludge products represented a potential health 
hazard, but the extent of the health risk was unknown. 

     In 1994, Constantine Skanavis and William Yanko conducted a study of 
composted sewage sludge based soil amendments for potential risks of 
salmonellosis. They analyzed samples of composted sewage sludge, amendment 
materials added to the compost (bulking agents such as aged redwood, fir 
bark, redwood chips, rice hulls, and sawdust) and four bagged commercial 
sludge soil conditioner products representing different blends of materials 
for home garden use. These bagged products were designated Product A 
(recycled compost), Product B (made with rice hulls), Product C (made with 
wood chips) and Product D (made by modifying sludge with the addition of the 
company's proprietary formulation).

     All samples were tested for total and fecal coliforms and the presence 
of Salmonella. The average total and fecal coliform concentrations were 
significantly lower in the composted sludge compared to the four 
compost-based products.

Although there were no significant differences in total and fecal coliform 
concentrations among products A, B, and C, the average total and fecal 
concentrations in Product D were significantly higher than in A,B,C products 
and the bulking agents. Laboratory tests detected salmonella in the compost- 
based products but not in the compost material used to make the products. 
Thirty-six percent of Product D samples were positive for Salmonella. Product 
D also contained the highest average concentration of Salmonella. Product A 
was second with 27 percent and Products B and C were tied with 22 percents of 
the samples positive for Salmonella. Because Salmonella was detected in the 
sludge products but not in the compost, the authors retested (using another 
testing procedure) four samples that had been negative for Salmonella. 
Retesting resulted in detection of Salmonella in 2 of the 4 compost samples. 
The authors conclude that "compost-based products could, in specific 
represent a source of Salmonella infection. This study, therefore, points to 
the need for intensive study of the factors associated with Salmonella spp. 
regrowth." (p.  9)

      Some pathogens have even developed resistance to time- tested controls 
such as heat and refrigeration. Several of the alternatives to reduce 
pathogens in sludge products use heat at temperatures of 55 C and above to 
achieve Class A  status. However, according to the article "Pathogen 
Destruction and Biosolids Composting" in Biocycle of June of 1996, "There is 
some evidence that coliforms and Salmonella sp. can survive prolonged 
exposure to temperatures of 55 C." They cite a study done by Droffner and 
Brinton (1995) using DNA gene probes, where they detected E. coli and 
Salmonella sp. in samples collected from an in-vessel composting  facility 
after the first 15 days of active composting at a temperature above 55 C. In 
Table 5-4 Processes to Further Reduce Pathogens in A Plain English Guide to 
the EPA Part 503 Biosolids Rule, composting time and temperature requirements 
for within-vessel composting method was 55 C or higher for three days!  
Droffner and Brinton found that it took 56 days and 90 days for the densities 
of Salmonella sp. and E. Coli, respectively, to decline below the detection 
limit...These investigators also "cite evidence of mutant strains of E. coli 
and Salmonella sp. resistant to thermal environments in composting." (p. 68)

     According to microbiologists, some bacteria form an endospore, a cell 
type developed from the vegetative bacterial cell through a sequence of 
morphological changes. Although the vegetative cell of bacteria is usually 
killed by heat and disinfectant, the endospore is resistant to agents that 
kill the vegetative cell (heating, drying, freezing, chemicals, and 
radiation).  Nester, Roberts, Pearsall and
McCarthy (1978) in their text Microbiology point out the threat that 
endospores present.  They say: Endospores represent the most resistant form 
of life known; they tolerate extremes of heat and dryness, the presence of 
disinfectants, and radiation. Some members of Bacillus and Clostridium play a 
role in fixing atmospheric nitrogen and others cause serious infectious 
diseases. Thermophilic strains of Bacillus can grow at temperatures above 70 
C (158 F) (p. 260)

     Linne and Ringsrud (1979) in their text Basic Techniques for the Medical 
Laboratory also point out how spores, as highly resistant forms of bacteria, 
pose a great problem in sterilization. They state that certain spores have 
been known to survive 16 hours of boiling. (p. 452)

     It has been recognized in Germany, at least since D. Strauch published 
his paper in 1991, that" most pathogenic agents can survive the treatment 
process" and the sewage treatment process causes some of the pathogenic 
disease organisms to be absorbed or enclosed in faecal particles during the 
treatment process. "Therefore," according to Strauch, "sewage sludge is 
rightly described as a  concentration of pathogens."

     In a personal interview with scientist David Lewis of the EPA, who is a 
whistleblower, EPA's nondetection phenomenon for pathogens was explained a 
little better. He said,      "The problem of pathogen detection in sludge is 
that the sewage treatment process changes the outside crust of the aggregates 
in sludge and only the pathogens on the outside of the aggregates are 
measured by standard tests." He says that most of the microbes are trapped 
inside the aggregates.  When ultrasound was used to break open the aggregates 
of sludge the trapped microbes were revealed. In effect, it appears that the 
treatment processes hide most of the pathogens rather than destroying them.

When John Walker first reported the "regrowth problem in 1973, scientists at 
Institute for Environmental Science, Murdoch University Murdoch 6150 
Australia, were still duplicating the study in 1997. 

They say, "In a soil amendment trial biosolids were mixed with sandy soil and 
monitored for 37 weeks. In two storage trials biosolids were stored in piles 
1m high and monitored for <60 weeks. Included in the monitoring programme 
were tests to determine the concentrations of faecal coliforms, faecal 
streptococci and salmonellae. In both the soil amendment trials and biosolids 
storage trials, concentrations of indicator organisms and salmonellae 
decreased through an extended hot, dry summer period. Although these 
organisms were not detected in the majority of samples taken during the 
summer, repopulation of faecal coliforms and salmonellae occurred in the 
trials following rainfall at the beginning of the winter. In the case of one 
of the storage trials repopulation occurred following a period of 50 weeks 
when salmonellae and faecal coliforms were not detected. When repopulation 
occurred, faecal coliform concentrations increased to higher than those at 
the beginning of the trials. These results suggest that faecal coliforms and 
salmonellae were at undetectable concentrations through the summer period but 
were able to grow when provided with favourable conditions. From this limited 
trial it was concluded that soil amended with biosolids could not be 
considered free from pathogens for at least one year following amendment."  
(Water Science and Technology Vol 35 No 11-12 pp 269275  IWA Publishing 1997 

     Straub, Pepper and Gerba say that the list of pathogens are not constant 
but keep changing:      As advances in analytical techniques and changes in 
society have occurred, new pathogens are recognized and  the significance of 
well-known ones change. 
     Microorganisms are subject to mutation and evolution, allowing for 
adaptation to changes in the environment. In addition, many pathogens are 
viable but nonculturable
by current techniques (Rozak and Colwell 1987), and  actual concentrations in 
sludge are probably underestimated.(p. 58)
    They add further: Thus, no assessment of the risks associated with the
land application of sewage sludge can ever be considered complete when 
dealing with microorganisms. As new agents are discovered and a greater 
understanding of their ecology is developed, we must be willing to reevaluate 
previous assumptions. (p.  58)

The High Road
     By January 1998, in the draft Statement Summary requesting additional 
funding, Bastian, Rubin and Walker's boss, Perciasepe wrote Harman about how 
Al Rubin and John Walker Plan to take the high road on the USDA National 
Organics Rule:
     * With the Statement that the rule is a marketing rule
       and is not risk based;
     * That the rule should be science based--otherwise using
       raw manures and composts without regulation or
       guidance can and is causing diseases;
     * That the criteria used for choosing what is acceptable
       for use to produce organic grown food should be
       science based;
     * That the rule should be subject to Peer Review
     * And that biosolids are safe for use and are highly

    Persiacepe, Assistant Administrator for the EPA's Office of Water, wrote 
in two confidential January 1998 draft statements (original & final)  that 
there hasn't been any monitoring or compliance enforcement.  In these two 
drafts, Persiacepe revealed that
EPA has never adequately monitored or enforced the Part 503 regulation.  
Perciasepe admits in a statement to Steven Harman, Assistant Administrator 
for Enforcement and Compliance Assurance, that "Our limited biosolids 
staffing has crippled our ability to oversee the quality of biosolids being 
land applied and to assure that the regulations governing land application 
are properly enforced."

     In the draft statement, Perciasepe requested support from Harman in 
"implementing a strategy for biosolids compliance and enforcement; and 
providing training for persons involved with biosolids inspections; 
enforcement; compliance assistance; and technical assistance." 

     These statements acknowledged what many people in and out of government 
already knew, the EPA has not overseen the safety of sludge disposal. Since 
States with the exception of Utah have not accepted delegation of Part 503, 
the oversight
and compliance for land application of sewage sludge is an EPA problem to 
explain away.

     In Perciasepe's Statement to Harman, he requested financial assistance 
in excess of $3,780,000 above his budget for two years. The two year request 
for funding included: 1) Research and Technical Support ($1.6 Million), 2) 
Stakeholders Partnership with AMSA and WEF ($500 thousand), 3) Biosolids 
Quality Survey ($325 thousand), 4) Biosolids Data Management System ($350 
thousand), 5) Code of Good Practice and Third Party Verification ($200 
thousand), 6) Booklet Explaining Quality Control ($80 thousand), 7) Expand 
Training ($130 thousand), 8) Enhance Oversight and Compliance ($150 thousand) 
and 9) Technical Support for Pathogens & Vector Attraction Equivalency 
Committee ($50 thousand) and the Incidence Response Team
($120 thousand).

     According to the budget outlay request there still would not be adequate 
compliance and oversight. Compliance and oversight was only going to cost 
$100 thousand the first year and $50 thousand the second year.  The Incidence 
and Response Team (debunking group) was cheap at $60 thousand a year.  This 
budget request was just another way to fund the public relations program.

     A closer examination of Perciasepe's draft statements reveals the real 
reason for the additional outlay of money is to counteract the growing 
opposition of the public to
biosolids use. Perciasepe wrote:
     Because the public perceives that risks are high, we
     need to reinvest in biosolids to address the public's
     concerns. Specifically, the public believes that
     biosolids qualities are poor, that the science behind
     the rule is suspect, that emerging potential problems
     with the use of biosolids are equivalent to a new "Love
     canal," and finally that EPA does not know what is going

     He added further that, "the public's poor perception of environmentally 
sound land use practices is severely impacting EPA's ability to successfully 
implement the
beneficial use policy. The poor public perception may force  municipalities 
to spend unnecessary expenses to manage biosolids."

     Perciasepe uses the same tired old line used by most regulatory agencies 
who fail to fulfill their assigned functions-- we don't have enough money, or 
enough people, or enough power to do the job. So, they receive more taxpayer 
dollars to hire more people and get more power to cover up their misdeeds.  
It is evident from Perciasepe's Statement,  the real purpose of the request 
for over 2 million dollars annually was to cover up the brewing scandal CNN 
exposed.  He has a right to be concerned with public perception. As was 
pointed out by Powell Tate, this is a major problem for the EPA/WEF 

     However, the real problem is not public perception, it is the damage 
done to the public's health and the environment. 

Jim Bynum
PO Box 34475
N. Kansas City, Mo. 64116

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