RECLAIMED WATER -- SLUDGE -- BIOSOLIDS -- COMPOST?

By Jim Bynum

Two health and environmental disasters in recent months highlight the increased probability of danger from disease
contaminated sewage effluent (reclaimed water) and sewage sludge (Biosolids) that “sound science‘ proclaimed safe in
the 90s. Both started in September 2006. In both instances, reclaimed water (sewage effluent) is used: First,
irrigation of  food crops; and Second, for recharging drinking water aquifers. The first is being investigated by
FDA, and the second by CDC,
both of whom signed off on EPA’s policy of using reclaimed water and
sludge/biosolids for use on food crops even though there is no testing for specific disease organisms. In both cases
the use of manure/sludge/biosolids compost could be involved in the mix. In 2005 and 2006 the “sound science” of the
90’s was revealed to be simple political expedience.

To understand the risk of disease organism contamination in reclaimed water and pipelines, we need to review what  
EPA said is:
    "known about the health risks associated with several [drinking water] distribution system issues, and
    where relevant, identify areas in which additional research may be warranted. The issues were selected
    based on the input of distribution system experts. The distribution system issues of concern are:
    Growth/Biofilms, Cross-Connections, Intrusion, Aging Infrastructure, Decay of Water Quality over
    Distribution System Residence Time, Contamination During Infrastructure Repair and Replacement,
    Nitrification, Covered Storage, and Corrosion, Permeation and Leaching."

    Some opportunistic pathogens such as L. pneumophila, M. avium, and primary pathogens such as
    V. cholerae, and E. coli O157:H7 survive and even grow within certain common amoeba (Barker and
    Brown, 1994; Barker et al., 1999; Wadowsky et al., 1991; Cirillo et al., 1997; Thom et al., 1992), and
    may be protected from disinfection. Some of the biofilm organisms may even supply an essential
    nutrient to facilitate the growth of an opportunistic pathogen. In one study, Legionella only grew near
    colonies of the bacterium Flavobacterium breve on an L-cysteine-deficient medium (Wadowsky and Yee,

    Many studies have identified microbes in accumulated sediments, including both pathogens
    and non-pathogens. These include bacteria, viruses, protozoa, algae, fungi and invertebrates.
    Opportunistic pathogens that have been detected, and can multiply in sediments, include Legionella and
    mycobacteria (van der Kooij, 2000). Some primary pathogens can also survive for some time in
    sediments. Hepatitis A virus survived more than four months in sediments at both 5/C and 25/C
    (Sobsey et al., 1986). Other opportunistic pathogens found in sediments include Pseudomonas
    fluorescens and Flavobacterium spp. (Berger et al., 1993). Sediments can also release nutrients into the
    water which stimulate biofilm growth downstream (LeChevallier, 1999b).

The first health and environmental disaster was  E. coli 0157:H7 contaminated produce from Salinas Valley, California
which sickened 200 people in 26 states, hospitalized 104 and killed 4 people. Estimates for infection rates vary
between 9 to 1 and 20 to 1 for ever documented case. There could have been 4,000 people infected or even more. It
has been estimated that the economic impact on the Salinas Valley farmers will exceed $100 million dollars. There
have been 22 outbreaks attributed to this E. coli strain since 1997.  It would appear the other
1,407 disease organisms
that could be on food or in water and harm human health are not being tracked.

The second health and environmental disaster is in Sierra Vista, Arizona. Sierra Vista uses a reclaimation wetland as
final treatment before the water goes to the recharge aquifer. It appears unusual that the City would allow the direct
disposal of septage into the wetlands without treatment, but that appears to be happening according to the November
2006 issue of PUMPER Magazine. Since September, 2006, 46 people have been document to be infected with
Salmonella Oranienburg. This strain was first isolated from a prisoner in 1930. The first known animal case was five
years later from a baby quail documented in 1935. Cochise County and Arizona health officials have been unable to
document a source of infection and called on the federal CDC for help. Also, Sierra Vista appears to have the first
documented genetic transfer of DNA to create a new Salmonella species only seen once in this county -- Salmonella

This brings up another disturbing fact at Sierra Vista. 12 children in Sierra Vista have developed cancer of the blood
and bone system since 1997.
Carla McClain, ARIZONA DAILY STAR, reported in December of 2006 that  was
triple the expected rate for a town of its size and "the CDC did find a variation in a gene that controls how the body
converts an unsafe chemical to a safe one in all of the leukemia-stricken children and almost half of the healthy
children in the study." Two children died.

In the media, Federal and State Agencies have a habit of underplaying the danger to public health from exposure to
the toxic chemicals, volatile  organic compounds and disease organisms in reclaimed water and sludge disposed of on
food crops, parks, school grounds, home lawns, etc..  Public health reactions to these pollutants have generally been
attributed to mass psychogenic illness.

EPA and its partners (USDA, FDA and CDC) have been in the habit of overestimating the ability of the treatment
processes to protect you. However, that is not the case when spokespersons address government agencies. As an
example, in the 1986, EPA Risk assessment for landfills, it was estimated that there were about
two (2) million cases of
foodborne illnesses. In 1998, Dr. Patricia Griffin, Chief of the Foodbourne Diseases Epidemiology Section of CDC’s
Foodborne and Diarrheal Branch reported, “A 1987 estimate of foodborne related deaths, based on educated
estimates but not hard data, totaled 9,100.” However, “A recent annual estimate of acute diarrhea from FoodNet data,
she noted, indicates a reported 360 million cases. In most of these cases, the cause (food, water, other) is unknown.
Old estimates of foodborne-related cases range from 6½ to 81 million per year. She noted that people who become
sick may or may not see a physician. The physician may or may not obtain a stool culture; and if the physician does
obtain a culture and confirm the cause of disease, that result may or may not be reported to health departments. As a
result, Dr. Griffin characterized the number of reported cases as "the tip of the iceberg."

Public attention was divert from the 350 million cases of diarrhea in 1999 when  Paul Mead,  former Chief of the
Foodbourne Diseases Epidemiology Section of CDC’s Foodborne and Diarrheal Branch wrote, “We estimate that
foodborne diseases cause approximately 76 million illnesses, 325,000 hospitalizations, and 5,000 deaths in the United
States each year.”  When Mead wrote the paper he was chief of epidemiology, microbiology, and diagnostic activity in
the bacterial zoonosis (a disease that can be transmitted from animals to humans or from humans to animals) branch in
the division of vector-borne infectious diseases at the Centers for Disease Control and Prevention's National Center for
Infectious Diseases in Fort Collins, CO. focusing on Lyme disease, plague, tularemia, bartonellosis, and tick-borne
relapsing fever.

Mead apparently based his paper on the estimated number of foodborne illnesses and ignored the 280 million cases of
diarrhea caused by other sources. Mead said, “More than 200 known diseases are transmitted through food (1). The
causes of foodborne illness include viruses, bacteria, parasites, toxins, metals, and prions, and the symptoms of
foodborne illness range from mild gastroenteritis to life-threatening neurologic (brain), hepatic (liver), and renal
(kidney) syndromes “ (Pathological [diseased] conditions of a part of an organism resulting from causes such as
infection, genetic defect, or environmental stress, and characterized by an identifiable group of signs or symptoms.)

This is a case of downplaying the seriousness of the current situation concerning public exposure to infectious disease
organisms in food, water and even on your lawn. This type of article focusing on food by CDC would ignore outbreaks
such as the 1993 drinking waterborne
Cryptosporidium outbreak in Milwaukee that infected 400,000, hospitalized over
4,000 and killed over 400. Four years after that outbreak,  CDC final acknowledged the outbreak was caused by a
human form of  Cryptosporidium rather than those carried by animals.

What is even more disturbing is that Mead used 1982 data in discussing the 200 known diseases transmitted through
food. It now appears that there may be over 200 strains of E. coli and CDC even lists over 900 strains of Salmonella.
The numbers are constantly changing and the disease organisms becoming more deadly due to there factors: 1)
natural environmental genetic mutation; 2) accelerated  genetic mutation in wastewater treatment plants; and 3)
genetic engineering in the laboratory.

The first E. coli 0157:H7 case (a Naval Officer)  documented with samples at CDC was in Oakland, California in 1975.  
E. coli  picked up an extremely virulent toxin gene from Shigella from Central America and is now known as Shiga toxin
producing Escherichia coli(STEC). . This Shiga like toxin gene (a known neurotoxin that produces delayed limb
paralysis and death) was sequenced in 1986. It has been noted that Escherichia coli of various serotypes, Salmonella
typhimurium, and Vibrio choterae also produce the toxin. Researchers at Walter Reed Hospital had cloned the toxin
producing gene by 1987.

This appeared to be an environmental genetic transfer of Shiga toxin DNA to E. coli, until you consider that in 1980, a
patent was assigned to Stanford University for a process to insert genes into E. coli so as to create a bacteria never
before seen in nature. The first case of foodborne E. coli 0157:H7 documented  by CDC was recorded in 1982.  Fifteen
cases were documented between 1982 and 1992.  For those who would blame animal manure for E. coli 0157:H7
outbreaks, a USDA investigation in 1982 did not find 0157:H7 in any cattle in the United States.

This becomes much more disturbing when you consider scientists can now construct viruses at will with material from
commercial laboratory suppliers. As an example, Terrence M. Tumpey, a virologist at the Centers for Disease Control
and Prevention, was part of a team that recently constructed a Spanish flu (H1N1) virus from scratch. This was a virus
that kill some 50 million people between 1918 and 1920.  Can you imagine the havoc that would do if it was accidentally
released in sewage reclaimed water or sludge/biosolids?

When you have sick people, or sloppy laboratory practices, the disease organisms end up in sewage wastewater
treatment plants. Part of the medicine and disinfectants used to cure or inactivate these disease organisms also end
up in the treatment plant. This mixture appears to accelerate the transfer of DNA from one organism to another.

In a
1982 EPA study, M. C. Meckes' noted, "In 1959, Wantanabe  discovered that some Escherichia coli strains could
transfer antibiotic-senstive strains of shigella spp. Subsequent research has demonstrated that bacteria carrying
transmissible R-factors [genetic transfer] are responsible for the spread of multiple antibiotic resistence among
members of the Entero-bacteriaceae (such as E. coli, Samonella typi, and Shigella dysenteriae) Aeromonas and
Yersinis species, Pseudomonas, and Vibro cholerae,"

May 2006, University of Minnesota researchers published data showing that extremely high numbers of multi-drug
resistant bacteria (173 types) in effluent (treated water) at high levels are being released into the environment from
highly efficient, award winning, sewage wastewater treatment plants. Researchers were
very concerned when they found extremely fast transfer of the drug resistant gene between bacteria in the treatment

June 2006, the Water Environment Federation released a study which showed that disease organisms in
sludge/biosolids were not destroyed during the treatment process.  According to the authors, “At four of the seven
facilities studied, higher levels of fecal coliforms were detected after dewatering in high solids centrifuges than before
this dewatering treatment.” The study stated, “The standard culturing method (SCM), sometimes used to measure
regulatory compliance, showed decreased coliform levels after digestion, followed by increases after dewatering at four
facilities” Their conclusion, “Reactivation is suspected here since the solids residence time in the centrifuge, typically
20-30 minutes, is too short for regrowth to account for the several orders of magnitude increase in fecal coliforms
observed at the four facilities.”

The authors explained their conclusion, “indicator organisms may "hibernate" and become "non-culturable." This
phenomenon is referred to as "viable but non-culturable". The issue of viable but non-culturable (VBNC) bacteria was
advanced in the 1980s, and gained significant interest in medicine, the food industry, and many other fields.”

This really wasn’t new information. In the article  "Pathogen Destruction and Biosolids Composting" in Biocycle of June
of 1996, "There is some evidence that coliforms and Salmonella sp. can survive prolonged exposure to temperatures
of 55 C." They cite a study done by Droffner and Brinton (1995) using DNA gene probes, where they detected E. coli
and Salmonella sp. in samples collected from an in-vessel composting facility after the first 15 days of active
composting at a temperature above 55 C.”

In Table 5-4 Processes to Further Reduce Pathogens in A Plain English Guide to the EPA Part 503 Biosolids Rule,
composting time and temperature requirements for within-vessel composting method is 55 C or higher for three days!
Yet, Droffner and Brinton found that it took 56 days and 90 days for the densities of Salmonella sp. and E. Coli,
respectively, to decline below the detection limit...These investigators also "cite evidence of mutant strains of E. coli
and Salmonella sp. resistant to thermal environments in composting." (p. 68)"

This would tend to explain the remarks in the 1
996, NRC Report  "Use of Reclaimed Water and Sludge in Food Crop
Production", where it was stated, "Many of the variables associated with the transmission of infectious disease from
wastewater and sludge are either not well understood or are unpredictable." (p. 93-94)"

This was put bluntly in the study, " The Importance of Pathogenic Organisms in Sewage and Sewage Sludge" Stefano
Dumontet et al., 2001, reported in the J. Air & Waste Manage. Assoc., where it was stated that "Bacterial pathogens in
sewage sludge contribute significantly to health problems, locally and globally."

James D. Oliver,Department of Biology, University of North Carolina at Charlotte, 2005, expands on WEF’s theory that
“indicator organisms may "hibernate" and become "non-culturable." Oliver states,  "Since the original 1982 paper from
the laboratory of Rita Colwell (Xu et al., 1982), over 400 papers have appeared which describe various aspects of the
phenomenon most commonly referred to as the " but nonculturable (VBNC) state" A great many pathogens, as well as
nonpathogens, are now known to enter this dormancy state.”  

Furthermore, Oliver said, "The number of species described to enter the VBNC state constantly increases, with
approximately 60 now reported to demonstrate this physiological response. Included are a large number of human
pathogens, including Campylobacter spp., E. coli (including EHEC strains), Francisella tularensis, Helicobacter pylori,
Legionella pneumophila, Listeria monocytogenes, Mycobacterium tuberculosis, Pseudomonas aeruginosa, several
Salmonella and Shigella spp. and Vibrio cholerae, V. Parahaemolyticus, and V. Vulnificus."

Human health complaints associated with sludge disposal sites as well as composting operations have been dismissed
by environmental and health authorities as mass psychogenic illness or in simple terms, imagined illnesses. However,
by 2006, EPA
was more forthcoming about the potential deadly health effects in its Biosolids Technology Fact Sheet ,
 Use of
Composting for Biosolids Management

The potential problems according to EPA:

  • Survival and presence of primary pathogens in the product.

  • Composting is not a sterilization process and a properly composted product maintains an active population of
    beneficial microorganisms that compete against the pathogenic members. Under some conditions ,explosive
    regrowth of pathogenic microorganisms is possible.

  • Dispersion of secondary pathogens such as Aspergillus fumigatus, particulate matter, other airborne allergens

  • While healthy individuals may not be affected, immunocompromised individuals may be at risk.

  • The spores of A. fumigatus counts at composting facilities are high, and-- persons handling composted biosolids
    being exposed to these spores is also high (Epstein, 1998).

  • These organisms can potentially invade a normal, healthy human being and produce illness or debilitation

EPA warns these are
pollutants which could cause death, disease, cancer, etc., by direct or indirect exposure.

This information meets the Resource Conservation and Recovery Act’s
(RCRA) definition of a hazardous waste. Yet,
under the current “sound science” policy this sludge/biosolids compost is safe for direct public contact on parks, school
grounds, gardens and home lawns as an unlabelled soil amendment. Could this also account for part of the 280 million
cases of diarrhea not caused by foodborne disease organisms?

It is apparent, federal agencies dominated by political appointees care little about real science, health or the
environment. The hierarchy of the federal system placed the Environmental Protection Agency (EPA) at the top when it
was formed in 1970.  While the EPA was charged with enforcing Congressional Policy (environmental laws) to clean up
the environment, in the 80s it transformed itself by policy into a hazardous waste disposal agency. The primary focus of
the interagency policy was to promote the disposal of hazardous waste on agricultural land.

In the beginning EPA oversaw a 70 billion dollar wastewater treatment plant construction program. The wastewater
treatment plant removed the solids from sewage and many of the chemicals and disease organisms and concentrated
them into a sludge. The remaining water (sewage effluent) from the wastewater treatment plant still contained  some
disease organisms and chemicals which is discharged to local waters. The safety of the system depended on adequate
dilution in the moving local waters. In trying to make it safer, secondary wastewater treatment plants were developed
which removed more of the solids, chemicals and disease organisms, but they still depended on moving water for
dilution of the remaining chemicals and disease organisms. Unfortunately, treatment plants are subject to malfunction
which releases chemicals and disease organisms into the environment.

The result of this program was mountains of solids waste generated by the treatment plants as sewage sludge. In spite
of the fact that sewage sludge contained unknown levels of infectious disease organisms which caused sludge to
classified as hazardous waste on land or a toxic pollutant in water, in 1981 EPA developed a policy to divert sludge
from landfills and use the sludge as a fertilizer on food crops. By 1989, EPA (who had initiated the ocean dumping ban)
had the political backing create a sludge use and disposal regulation. The original regulation as proposed was not
acceptable to industry as it listed
25 primary (families) disease organisms and 21 known carcinogens -- five were
carcinogenic when inhaled.

It was EPA’s position that the disease organisms only caused mild gastritis.  Yet, the environmental law and the
regulation suggests exposure to the disease organisms,
may or will, cause death, disease, behavioral abnormalities,
cancer, genetic mutations, physiological malfunctions (including malfunctions in reproduction) or physical
deformations.  By 1993 EPA had turned the proposed regulation into a infectious waste sludge dumping regulation that
depended on exclusions in the environmental laws. EPA created a
public relations campaign to convince the public
and lawmakers this infectious waste sludge dumping regulation was based on sound science. The PR campaign
included a
risk assessment that did not include disease organisms or cancer causing agents. But they also changed
the name of sewage sludge to biosolids to overcome the public perception that sludge use could be dangerous.. Many
states revised the solid waste laws and force the public to accept this infectious waste dumped on agricultural land next
to them without any recourse. Not only that, but the states not only allow, but promote the use of this composted
hazardous infectious waste as an unlabelled soil amendment on parks, school grounds and you lawn.

The population growth of the nation has created a water shortage in some areas of the country. Based on EPA’s
misleading “sound science” policy this has led to uninformed promoters for the use of sewage effluent (renamed
reclaimed water) to irrigate food crops and to recharge drinking water aquifers where the water may be thousands of
years old.  This reclaimed water is also used for irrigation of city parks, school grounds, industrial lawns, golf courses
and cooling water for building cooling towers as well as snow making for ski resorts.

A wastewater treatment plant and a little over 45 miles of irrigation pipeline was built in the Salinas Valley of California
to irrigate food crops such as the lettuce and spinach involved in the latest outbreaks. Even if it was possible to
disinfect the reclaimed water at the treatment plant, it would not assure safe irrigation water because bacterial biofilms
grow in all water pipes, even with distilled water, and they are occasional broken loose.

While the trend is to blame farmers for food contamination outbreak, the farmers have been assured this irrigation
system is furnishing safe water and manure/sludge/biosolids compost is safe for food crops.  The latest outbreak is
estimated to have cost Salinas Valley farmers over $100 million dollars. Based on the health and environmental
disasters caused by reclaimed water and sludge/biosolids across the country by EPA’s current “sound science” policy,
this is just the tip of the iceberg.