- Subject: Part 7 -- It began in New York
- From: T*@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
prevention,
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
Sludge.
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
gastroenteritis.
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
organs
(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
situations,
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
the
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
regulated.
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
on.
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
partnership.
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
