Attorney Hallman speaks of EPA and its partners and the law in Sludgewatch-1 Digest, vol 12, Issue
18:
The end result is that those who purvey the snake oil of biosolids, including those who
make it and apply it, and definitely including the government, will be no where to be
found when more and more human, animal and environmental damages occur. The only
echo in the wind will be a very weak "Sorry." Therefore, Mr. Beecher and all those like
him can continue to fool themselves until the day of reckoning occurs, which will
probably apply, unfortunately, to some future persons who had nothing to with this
atrocity.
Message: 5
Date: Sun, 23 Oct 2005 14:10:15 -0400
From: "F. Edwin Hallman, Jr." <[email protected]>
Subject: RE: Sludge Watch ==> Re: Sludgewatch-l Digest, Vol 12, Issue
15
To: <[email protected]>, "Ned Beecher"
<[email protected]>
Cc: MAUREEN REILLY <[email protected]>,
[email protected]
Message-ID: <[email protected]>
Content-Type: text/plain; charset="iso-8859-1"
Thanks to David Carter for your reply. I specialize in environmental matters in my law practice and
mostly represent businesses. If my business clients applied the same materials to lands which are
being applied to lands under the guise of sewage sludge, my clients would be guilty of criminal
conduct. If an industry and a sewage plant produced identical truck loads of materials which I have
seen called "sewage sludge", the industry would by law be required to dispose of its truck load in a
hazardous waste facility while the sewage plant could send the "sewage sludge" to a farm for
spreading and the growth of vegetables. T
To state that any materials made from any sewage sludge are safe from any source for any purpose
requires confidence in the systems of laws which theoretically regulate the material known as sewage
sludge which is now purveyed as "biosolids." I have been representing dairy farmers in Augusta,
Georgia since 1998 and we have successfully proven, factually and as a matter of law, that the City
of Augusta put hazardous wastes on the farms, that the hazardous constituents in the sewage
sludge contaminated forage fed to cows, that the dairy herds and lands have been substantially
damaged, that there was not ONE document generated by the City of Augusta documenting what
went on these lands in the form of sewage sludge that was accurate, that the City's calculations of
what went on the lands was, at a minimum, four orders of magnitude too low, that the City had
multiple sets of records, that the city hid records in its possession from the farmers and government
that proved that extremely high levels of a large numbers of hazardous materials went on the lands,
including mercury, cadmium and Chlordane to name a few and that the City created records years
later after the applications of sewage sludge that were false in an attempt to lie about the levels of
materials that went on the lands. One example of the egregious nature of Augusta's conduct was
Chlordane was banned from land application to dairy farms and other uses in 1978 while it was put
on the farmers lands long after that time. It is amazing the this evidence which we have produced
has not been challenged by the City or the EPA. As a result of this information being made public,
the Georgia Environmental Protection Division (EPD) and the EPA conducted an investigation in
December of 1998. In that investigation, the EPD investigators concluded that the Augusta sewage
treatment plant was completely out of compliance, that the management of the plant was "clueless"
and a "joke" and that the plant should have been "shut down".
As of today, the EPD report has been ignored, the plant has continued to operate in violation of
federal and state laws, agricultural applications of sewage sludge have continued and not one
agency, federal or state, has taken appropriate actions dealing with the fraudulent conduct of
Augusta and individuals involved.
The Augusta situation has proven to me unequivocally that the government does not care and will
not adequately enforce environmental laws regarding sewage and the magic labeling of hazardous
waste as "biosolids", as if this magic label somehow converts hazardous waste into a useful product.
The approach is simply not to require industry or the sewage handling industries to test for he
hundreds of hazardous materials which are known to be put in the sludge. Such an Alice in
Wonderland approach is shown by the exchange between Alice and the Cheshire cat. The Cheshire
cat said, "A word means what I say it means, no more and no less." Alice replied, "The question is:
Can a word have so many meanings?"
It is incredible to the undersigned who is trained to understand facts and apply the law to those facts,
that so many otherwise intelligent persons can buy into this snake oil syndrome which is created by
a few corrupt employees of the EPA in concert with the multi-billon dollar sludge application industry,
that the term sewage sludge "means what I day it means, no more and no less!!" There are more
and more persons and companies, such as the Heinz companies, which have reached the
conclusion based upon sound science and the law that "sewage sludge" and/or "biosolids" are both
smoke screen terms for hazardous waste.
The end result is that those who purvey the snake oil of biosolids, including those who make it and
apply it, and definitely including the government, will be no where to be found when more and more
human, animal and environmental damages occur. The only echo in the wind will be a very weak
"Sorry." Therefore, Mr. Beecher and all those like him can continue to fool themselves until the day
of reckoning occurs, which will probably apply, unfortunately, to some future persons who had
nothing to with this atrocity.
I speak from experience, not from vague pronouncements, smoke and mirrors approaches, and look
here and not there, syndromes. Had the EPA taken to heart the Augusta situation to show the world
how not to create and apply sewage sludge, I might have thought many years ago that there was
some credibility in the sewage sludge land application program. However, today it is clear the EPA
does not look at any production of sewage sludge any more closely that it did in the Augusta
situation and that industries are pumping hazardous wastes in sewage at staggering rates, which
becomes sewage sludge to be put on lands to produce materials that we are supposed to eat and
drink. All of those who like this idea, please enjoy my place in line. I, for one, am on the lookout for
the label "Not grown on lands receiving sewage sludge or Biosolids."
I wish you all the best in your endeavors.
Ed Hallman
-----Original Message-----
From: [email protected]
[mailto:[email protected]]On Behalf Of David F. Carter
Sent: Saturday, October 22, 2005 11:18 PM
To: Ned Beecher
Cc: MAUREEN REILLY; [email protected]
Subject: Re: Sludge Watch ==> Re: Sludgewatch-l Digest, Vol 12, Issue 15
Mr. Beecher,
I, for one, understand what you are saying, but find it hard to believe what you are saying.
Spreading unknown toxins on your garden is fool-hardy at best. At the least, unscientific. You have
no idea what is in the product, or the harm it may cause you and your neighbours. Which brings up
another point. It's not about
personal choice. This is a public issue. Do you really think that what you put on your garden stays
there? Do you think that nature in your yard, is somehow controlled by your property boundary?
Half of sewage sludge is not organic. The half that might be organic, is loaded with organic toxins.
With 60, 000 potential chemicals, any number of pharmaceuticals, street drugs, untested animal
renderings, and 100s of other ingredients, your brand name "biosolid" pills pack quite an
environmental punch. And, let us not forget the
hundreds of new chemicals that are introduced every year that enter your pill assembly line. Many of
these you may never identify, protected for years by trade secret laws.
What happens when you mix various chemicals together? In water? Mix chemicals with other
unknown toxins? Gulp. We haven't even discussed the half that isn't organic.
"Biosolids" make chemical-laiden cigarettes look like a child's candy.
And, if your pills are mixed with cement kiln dust, then you're adding a dozen heavy metals, and
possibly other nasty residues from any cement plant that burns hazardous waste.
Unfortunately, the package your sewage pills come in does not list these ingredients. Equally
unfortunate, every batch of pills, like every batch of sewage sludge, is different. What a choice!
Are "biosolids" good medicine? Truly beneficial? Not on your life, or mine.
Respectfully,
David Carter,
One Nova Scotian who will not swallow the "biosolids" pill.
Ned Beecher wrote:
> Hi.
>
> Just wanted to note a correction to an article that was included in a recent
> Sludgewatch Digest.
>
> In a story about the Marlborough, MA co-compost, the Boston Globe West
> reporter misunderstood me. I use biosolids compost or biosolids pellets on
> my home garden every year. They are beneficial soil amendments. I did not
> recommend against using biosolids compost on home gardens, and I see no
> reason for such a recommendation. Understanding, however, that each
> consumer will choose for themselves what works best for their situation.
>
> --
> Ned Beecher
> New England Biosolids and Residuals Association (NEBRA)
> P. O. Box 422 / 85 Main Street
> Tamworth, NH 03886
> phone 603-323-7654
> fax 603-323-7666
> www.nebiosolids.org
>
> --------------
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> > 1. Co-Composted muncipal trash and sewage sludge -- (M Reilly)
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End of Sludgewatch-l Digest, Vol 12, Issue 18
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