MICHIGAN REQUEST FOR APPROVAL FOR ITS PROGRAM OF DISCHARGES OF POLLUTANTS (sludge) FROM A
POINT SOURCE -- TO A NON-POINT SOURCE (agricultural land) -- INTO THE WATERS OF THE UNITED STATES.
In effect, a license for the "open dumping" of sludge -- an act prohibited by the Resource Conservation and
Recovery Act (RCRA)
Goal: Announce proposed changes to Michigan's biosolids management program. Background: The State of Michigan
has submitted a program modification application to the EPA to administer and enforce a sewage sludge management
program. Specifically, the state is seeking approval of a biosolids management program that addresses the land
application of biosolids, the EPA said.
Michigan Environmental Quality employees think people opposed to sewage sludge use are a mob and truth is stones being thrown at
them. These gentlemen are highly intelligent, but at best, semi-illiterate concerning sewage sludge, the RCRA and the CWA People do
not need to make an assumption that there is some large conspiracy to jeopardize the public health. It all comes back to a few people
at EPA who have encouraged municipalities to violate the law by taking sewage sludge from a point source of pollution at the
treatment plant and disposing of it as a non-point source of pollution on farmland, etc., The DEQ employees don't appear to realize
that sewage sludge is a solid waste by law and that the state is responsible for stopping the creation of open sludge dumps which are
prohibited by federal law.