FROM POLLUTANTS IN SEWAGE SLUDGE
Resource Conservation and Recovery Act (RCRA)
Congress found that most solid waste in the form of sludge
was dumped on land - our most valuable resource.

Congress found that improper and mismanaged disposal
could create a danger to human health and the environment.
Congress found that due to the danger to human health land
disposal of hazardous solid waste should be eliminated as
landfills and surface disposal polluted the land, air and water,
and should be the least favored method of disposal.

The Agency agreed that landfill and permitted surface
disposal was the most dangerous disposal option. Therefore,
EPA promoted the disposal of unlabelled hazardous solid
waste (sludge/biosolids) as a fertilizer on home lawns,
gardens, food crop production lands, parks, school yards,
golf courses and forest land.

Congress found that the infectious characteristics of the
pathogen pollutants in sludge makes it a hazardous waste.
Whereas, EPA chose to create hazardous waste levels for
certain pollutants which would contaminate groundwater
under a mismanaged permitted landfill.

While Congress enacted the CERCLA, it was intended to
give EPA another tool to use against the the polluters.

Congress was more specific in identifying the hazardous
substances, toxic pollutants, imminent hazardous chemicals
and pollutants or contaminates which could harm public
health, and the environment.

On the other hand, EPA chose to us the normal application
commercial fertilizer exclusion in the CERCLA as a mandate
to dump hazardous sludge/biosolids as an unlabelled
fertilizer on home lawns, gardens, food crop production land,
schools yards, golf courses, and forest land.

Instead of a clear warning about the dangers to public health
in its definition of a pollutant in part 503.9(t), EPA chose the
term "organism" which includes all forms of life.

Plus, the implication of part 503 is that there are only nine
metal pollutants that will kill us.
                   CLEAN WATER ACT (CWA)

The intent of Congress in the CWA was to restore the waters
of the United States. The CWA was enacted to prevent toxic
pollutants from entering the waters, surface water,
groundwater, as well as rivers, streams and the ocean, in
toxic amounts.

A major point, was to prevent toxic pollutants from entering
these waters from non-point sources of pollution.

Under the CWA, sludge/biosolids is a pollutant. The metals
listed in part 503 are "Toxic Pollutants" which "will" cause
death, disease, cancer, and other assorted physical and
mental problems to organisms-human and animal.

EPA chose not to identify the metals in part 503 as CWA toxic
pollutants, because no home owner, farmer, school district,
golf course owner, or forest owner, including the Federal
Bureau of Land Management would knowingly accept a
fertilizer product loaded with toxic pollutants.

The Water Environment Federation (WEF) doesn't list toxic
pollutants in its glossary. But it does know the toxic pollutants
in sludge has the potential to kill you. It also knows that the
infectious agents in sludge has the potential to create toxins
which will can kill you. Yet, this organization still promotes
sludge as a safe unlabelled fertilizer. WEF doesn't confine its
terms to only the 13 organics in the
part 503 risk assessment
which EPA says has been banned, no longer manufactured
or is restricted in use. Nor does WEF imply that the that the
metals listed as pollutants in part 503 are non cancer
causing agents as EPA did for the risk assessment.

It does list:
toxic: having the characteristic of causing death or damage
to humans, animals, or plants; poisonous.

toxic chemical: a chemical with the potential of causing
death or damage to humans, animals, or plants; poison.

toxin: any of various poisonous substances produced by
certain plant and animal cells, including bacterial toxins,
phytotoxins, and zootoxins.

pollutant: an impurity (contaminant) that causes an
undesirable change in the physical, chemical, or biological
characteristics of the air, water, or land that may be harmful
to or affect the health, survival, or activities of humans or
other living organisms.

pollution: contaminants in the air, water, or soil that cause
harm to human health or the environment.

Congress identified a point source of pollution and
specifically excluded stormwater runoff from agricultural sites
and return flows from irrigated agriculture.

The WEF says a non-point source of pollution can not be
nonpoint source pollution (NPS): pollution that cannot be
traced to a single point (Example: outlet or pipe) because it
comes from many individual places or a widespread area
(typically urban, rural, and agricultural runoff).

EPA deliberately chose to create a traceable non-point
sources of agricultural and urban pollution under the CWA by
promoting its part 503 sludge policy.  This is unregulated
open dumping under the provisions of the RCRA.

EPA and the WEF know they are wrong in promoting solid
waste (sludge/biosolids) dumping as a unlabelled fertilizer.
WEF identifies these large farmland dump sites as a:
landfill: a large, outdoor area for waste disposal; landfills
where waste is exposed to the atmosphere (open dumps) are
now illegal; in "sanitary" landfills, waste is layered and
covered with soil.

EPA with its partner,the Water Environment Federation,
created a multi-million dollar public relations campaign to
change public perception about the dangers to public health
from the toxic pollutants in sludge/biosolids. They even
created the term biosolids and worked very hard to get it put
in the dictionary.