ALAN RUBIN
told county officials Tuesday that they have the power to control the spread of sewage sludge on local
farmland.

"It's time we looked at direct exposure," Ruben said. "We have in the past concentrated on contaminates in the food
chain."
CALIFORNIA   SOLANO COUNTY – JANUARY 2003 – NEWS:  THE GREAT SLUDGE DEBATE – AN ENVIRONMENTAL
PROTECTION AGENCY REGULATOR TOLD COUNTY OFFICIALS TUESDAY THAT THEY HAVE THE POWER TO
CONTROL THE SPREAD ON SEWAGE SLUDGE ON LOCAL FARMLAND.
The great sludge debate TheReporter.com  Jan.22, 2003 (Excerpts)
By Jason Massad/Reporter Staff
An Environmental Protection Agency regulator told county officials Tuesday that they have the power to
control the spread of sewage sludge on local farmland.

That statement from Allen Ruben came at the beginning of a series of public hearings called by the Solano County
Board of Supervisors who will determine, at least locally, the fate of the sludge.
The semi-treated sewage, also known as biosolids, has come under fire in Solano County from a growing collection of
residents who live in or near Rio Vista. The residents have cited health concerns with the spreading of biosolids on
nearby rangeland in their request that the board impose a ban on the practice.

The local controversy is also fueled by a 2002 National Research Council review of EPA regulations regarding biosolids,
which called for further national restrictions and more study.
And while EPA officials call current regulations adequate, they acknowledge there are some serious holes in them. For
example, Ruben said Tuesday that there are no studies in regard to people's direct contact with biosolids. Residents
near Rio Vista, where there are commonly 25-mph winds, fear that spreading biosolids near their home sends
particulates through the air into their yard and homes prior to decomposition.

"It's time we looked at direct exposure," Ruben said. "We have in the past concentrated on contaminates in the food
chain."
“The overall complexity of the biosolid issue led the board of supervisors last fall to call a series of public forums to
receive scientific testimony on biosolids, and establish an "administrative record" for a decision that could alter the local
ordinance that regulates their use.

Watching closely for the outcome is the Rio Vista City Council - which has endorsed a suspension of biosolids - the Bay
Area utility districts, and Synagro - a nationwide hauler of biosolids with contracts in Solano.

"It seems somewhat clear you will not (at the end of the hearings) have all the information you'd like to have," said Rio
Vista Mayor Marci Coglianese. "As you're contemplating your decision, you need to think about how much risk we will
take."




----- Original Message -----
From: <Rubin.Alan@epamail.epa.gov>
To: "US Composting Council Compost Discussion List" <compost@compostingcouncil.org>
Sent: Thursday, September 30, 2004 3:43 PM
Subject: RE: [USCC] Suggestion on Modifying Part 503 Standards toAccomodateComposts

Frank:
Composters and State/Local regulatory authorities are free to impose
more stringent requirements on biosolids, biosolids processing/treatment
such as composting, and finished biosolids composts.  Less stringent
measures are considered not to be in compliance with the part 503
Standards and is not allowed.

As I said before, any amendments to the part 503 Standards must be done
by EPA in Notice and comment rulemaking.

Cheers

Alan B. Rubin, Ph.D., Senior Scientist
Biosolids Team
Office of Science and Technology
U.S. Environmental Protection Agency
Washington, DC 20460
Ph: 202-566-1125
Fax: 202-566-1139
http://epa.gov/waterscience/

DR. ALAN RUBIN, SELF-DESCRIBED AUTHOR OF THE US EPA 40 CFR PART 503 SLUDGE REGULATIONS SAYS
LOCAL AUTHORITIES ARE FREE TO IMPOSE MORE STRINGENT REQUIREMENTS ON SLUDGE BIOSOLIDS