scoops

Tuesday, July 12, 2016

Another citizen speaks

At Monday’s Commissioner’s Court session, Chris Denison read this comment that was submitted to the TCEQ regarding the Denali Permit Application.

The area of Bastrop County being considered for sewage dumping is underlain by a rock unit called the Calvert Bluff Formation. This unit consists of layers of sands, shales and lignites, sometimes cut by sand-filled channels. All of the aquifer sands are connected to some extent, vertically and laterally. Water wells can produce from the layered sands at fairly low rates, but if you are fortunate enough to have a well that produces from a channel sand, copious amounts of water can be produced.

The Calvert Bluff dips (is inclined) to the southeast at about 100 feet to 200 feet per mile. For example, I have property on Lone Star Road, to the southeast of the intended dumping area, and I am producing water from a sand at 300 feet. That sand comes to the surface somewhere between 3 and 6 miles away, which is where the sludge will be dumped. That is where my aquifer sand is recharged.

Surface water soaks into the ground and slowly moves through the aquifer, spreading vertically and laterally, reaching my well possibly years to decades later. Any pollutants on the surface of the recharge area will be transferred into the aquifer and will eventually reach my well. Hundreds of household wells down-dip from the proposed dumping area are potentially at risk.

As an illustration of what will happen, during WWII what is now Livermore Labs in California was an airbase. On grassed areas of the airbase, oil-coated aircraft engines were washed with carbon tetrachloride (dry-cleaning fluid), which “disappeared”. Decades later, a plume of contaminated groundwater is moving towards Livermore City water wells.

Sewage sludge is notorious for containing pharmaceuticals flushed down toilets and heavy metals, including lead, mercury, arsenic and cadmium, from various household cleaning products. Complex molecules from the pharmaceuticals will break down, but the surviving molecular fragments and the heavy metals will be washed into the aquifer. I will have to pay for tests to determine when the pollutants reach my well. When this toxic chemical soup eventually appears, I will not be able to use the water in my house, for my animals, or for irrigation. What do I do then - move?

Monday, July 11, 2016

A citizen speaks

This comment was read at today’s Commissioner’s Court session by the author of this website.

Let’s start at the beginning. The guidelines for the sludging of America are contained in the EPA’s 503 sludge rule which was implemented in 1993. The TCEQ is just being a good foot-soldier reinforcing the EPA’s big lie that sludge is nothing but ordinary fertilizer and perfectly safe.

In case you’ve bought into the EPA’s greenwashing and think this is an OK idea, please look at the handout listing contaminants that have been found in sludge. Out of all those, only nine heavy metals and one pathogen – fecal coliform - are monitored for Class B biosolids. All the rest of those contaminants may legally be present.

Yes, the TCEQ knows exactly how unsafe Class B biosolids are. Just take a look at the excerpt from the Texas Administrative Code TAC 30 regulations. That section specifies how many days, weeks, months, years must pass before sludged land can be used for certain purposes. And that caution relates to only one pathogen - E. Coli.

So what does this mean for Bastrop county and its residents? The most pressing concern with this permit proposal is water resources. Please look at the two graphic handouts. The Wallace Farm, which has signed up for the free sludge, lies almost entirely over the Wilcox outcrop where rainwater replenishes the aquifer. Toxic components in that sludge would inevitably leach into the aquifer and also Cedar Creek when it rains heavily. That contaminated water would then radiate from the Wallace Farm by the aquifers’ underground streams. The creeks would move those pollutants into the Colorado river. And surface runoff would flow downhill to pollute neighbors’ land and water sources.

But, neither the TCEQ nor Denali Water Solutions would bear any responsibility for testing of neighboring wells that may become contaminated OR for maintaining county roads OR or compensating neighbors for loss of property value. There are Commercial Liability and Environmental Impairment policies in place for ten million dollars per occurrence. But how exactly does one unimpair toxic pollution? Interestingly, this policy is issued to the Wallace Farm in a mythical BAXTER county, Texas.

When Denali Water Solutions withdrew their application for a similar permit in Fayette county a few weeks ago, they emphasized that the residents had an “emotional attachment to the Colorado river”. Well, my attachment is to water that isn’t polluted by heavy metals and pathogens and chemicals and pharmaceuticals and and and . . . Those nasties have no business being dumped over an aquifer outcrop or in the Cedar Creek floodplain or on a site that has higher elevation than neighboring properties. Period.

The Resolution before you today would be an important step in the process of putting an end to this before it starts. It’s unthinkable that our precious water resources could be jeopardized by one landowner’s misinformed and naive idea that sludge is just harmless, “free-fertilizer”.

Video: Cedar Creek flood

This video was taken from the north side of Cedar Creek looking across the creek toward the northwestern corner of the Wallace Ranch. The flood meets the treeline about 25-30 feet above the creek-bed. If you could see under the treeline, the ranch pasture used to grow oats would be visible. This is by no means the highest the creek gets during floods.

Sludge exposes a stink

The saga of David Lewis and the EPA’s failure to protect the public is summarized in this 2008 article published in Nature:

Online: Raking through sludge exposes a stink

Download PDF

The accompanying editorial chastises the EPA for its non-action:

Online: Stuck in the mud

Download PDF

Tuesday, July 5, 2016

10 Myths about biosolids

Ten Government-Industry Myths about Biosolids (download PDF)

Caroline Snyder Ph.D.*

MYTH NO. 1: For more than 2000 years industrial waste and sewage sludge have been land-applied as soil amendments. (Source: EPA i )

FACT: The myriad hazardous industrial chemical wastes found concentrated in modern treated sewage sludges (biosolids), including pesticides, pharmaceuticals, plasticizers, flame retardants and growth hormones to mention a few, did not even exist until recent decades.

MYTH NO. 2: Biosolids are nutrient-rich organic fertilizers. (Source: EPA ii )

FACT: It’s highly deceptive to call mixtures of many thousands of industrial chemical pollutants “nutrient-rich” simply because several of the pollutants are nitrogen and phosphorus compounds found in commercial fertilizers. Biosolids produced from sewage sludges generated in industrial urban centers are undoubtedly the most pollutant-rich materials on Earth. When applied to land, industrial pollutants in biosolids reenter aquatic systems and are magnified up the food chain. iii

MYTH NO. 3: Over 99% of biosolids is composed of water, organic matter, sand, silt, and common natural elements. (Source: NEBRA iv )

FACT: It’s also deceptive to call mixtures of many thousands of industrial chemical pollutants “natural,” especially when EPA and the biosolids industry are targeting consumers who use the words “natural” and “organic” to mean free of synthetic chemical contaminants.

MYTH NO. 4: Biosolids are essentially pathogen free. (Source: State of California v )

FACT: Many if not most pathogenic (disease-causing) bacteria and viruses can survive treatment processes used to produce biosolids (Class A and Class B); and many dangerous pathogens, such as Salmonella and Staphylococcus, can re-grow to high levels in biosolids, which is mostly comprised of human feces. vi New research indicates that sewage sludge treatment facilities are actually breeding grounds for antibiotic-resistant pathogens. vii

MYTH NO. 5: Infectious prions will not survive wastewater treatment and therefore are not present in land-applied biosolids. (Source: U. Arizona viii )

FACT: The latest research shows that prions survive wasterwater treatment processes. ix

MYTH NO. 6: Biosolids are not sources of pathogens or toxicants. Sludge syndrome is a somatic disease triggered by biosolids odors and by fears raised in the community and through the media. (Source: Mid-Atlantic Biosolids Association x )

FACT: Odors from biosolids are a warning that the material is emitting disease-causing pathogens and biological toxins, e.g., endotoxins. Peer-reviewed scientific studies have demonstrated that resulting health effects are not imagined but real. xi

MYTH NO. 7: Allegations of health problems linked to biosolids exposure are urban myths. (Source: NEBRA xii)

FACT: Many hundreds of sludge-exposed rural neighbors have reported chronic respiratory, skin and gastrointestinal conditions consistent with exposures to the types of chemical and biological contaminants found in biosolids. The relationship between land application of biosolids and such adverse health effects has been documented in valid scientific studies, including the peer-reviewed scientific literature. xiii

MYTH NO. 8: Treatment breaks down most organic chemical pollutants. (Source: NEBRA xiv )

FACT: EPA’s 2009 Targeted National Sewage Sludge Survey of 74 sewage treatment plants in 38 states, which sampled 145 industrial chemical pollutants, found them in every sample. xv Their concentration ranges often topped ppm-levels and higher, exceeding concentrations considered safe in drinking water by orders of magnitude. Moreover, the breakdown products from organic chemical pollutants are often more harmful than the parent compounds. xvi

MYTH NO. 9: Biosolids contaminants are tightly bound to soil and do not become bioavailable. According to Rufus Chaney, “You can put enough heavy metals in the soil to kill the crop but that crop is still safe for human consumption.” (Source: USDA xvii )

FACT: EPA and the USDA buried studies demonstrating heavy metals in biosolids exceeding current levels permitted by EPA caused liver and kidney damage in farm animals grazing on fields treated with biosolids. xviii After EPA promulgated the current sludge rule in 1992, it worked with the Water Environment Federation to establish the “National Biosolids Public Acceptance Campaign.” EPA’s Office of Inspector General investigated EPA’s efforts to silence Dr. David Lewis, one of its top scientists who documented adverse health effects, and concluded that EPA could not assure the public that land application of biosolids is safe. xix

MYTH NO. 10: US sludge regulations that govern the land application of biosolids (40 CFR Part 503) are completely protective, based on science and valid risk assessment models. (Source: NEBRA xx )

FACT: A 1999 Cornell Waste Management Institute paper concluded that the 503s do not protect human health, agriculture, or the environment. xxi The 503s regulate only nine metals plus inorganic nutrients (N, P). Even though industry can legally discharge any amount of hazardous waste into sewage treatment plants, the rules are based on chemical-by-chemical risk assessment which ignores the effects of mixtures and interactions. The 2002 NRC biosolids panel recognized this andconcluded that u201cis not possible to conduct a risk assessment for biosolids at this time (or perhaps ever) that will lead to risk-management strategies that will provide adequate health protection without some form of ongoing monitoring and surveillance . . . the degree of uncertainty requires some form of active health and environmental tracking. xxii

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