A confidential legal analysis prepared in 1996 for the City of Denver illuminates another aspect of the arrangement
that's beneficial to polluters: As long as the contaminated groundwater remains on-site, it is categorized as
hazardous waste and subject to the plethora of federal laws governing the disposal and storage of such wastes. But
once the liquids are pumped through the sewers, the site waters  need only meet the standards of the sewage-
treatment facility accepting the wastes.

Reactivation -- regrowth of pathogens

Reclaimed water  benign name for infectious sewage effluent forced on consumers for irrigation of food crops,
school grounds and home lawns

Congress wrote RCRA to achieve three primary goals: (1) protection of human health and the environment; (2)
reduction of waste and conservation of energy and natural resources; and (3) reduction or elimination of the
generation of hazardous waste as expeditiously as possible.

However, according to the EPA Routing and Transmittal Slip from EPA's Wastewater Management Branch, Region
10, dated August 3, 1993, there is no protection under the regulations. Please note that,when final, such documents
(part 503) are only guidance and that individual EPA offices and permit writers are free to either use or not use the
Agency guidance as they consider appropriate and technical sound, ;guidance is only guidance. ;Furthermore,
States are not required to use or conform to EPA guidance.

Between 1989 and 1999 Kansas City, Missouri assured the neighbors and farmers of its sludge disposal site that it
was a very safe place. In 1999, Kansas City went to court to shut down public access to farms near its 1,200 acre
sludge disposal site. City attorneys told the court that federal and state law required the site be restricted to public
access. The court agreed that a gate could be placed a public street some 500 feet from the city's fenced disposal

Resistant --
Antibiotic Resistants -- Genetic transfer of toxin producing genes between bacteria.

Risk Assessment for sludge/biosolids
We expect that EPA is required to tell the truth. What we find is that EPA will lie about what it actually does. EPA wrote
a convincing book on the science behind the part 503 risk assessment. Yet, on page 110, EPA stated it didn't use
any science or consider all of the chemicals. EPA's John Walker and USDA's Rufus Chaney appear to be the main
source of this non-science.

Risk Assessment for sludge disposed of in a Part 257 sludge only landfill
Gerba, 1986, Development of a Qualitative Pathogen Risk Assessment Methodology for Municipal Sludge

;But when the fluid biosolids are spray applied on standing forages,the biosolids particles can get stuck
to the forages . . . when such contaminated forages are grazed, livestock can get high exposure to
xenobiotics in biosolids;

Late Friday afternoon, just in time for the Fourth of July holiday weekend, a bipartisan contingent
gathered at the county elections office to drop off paperwork and a $200 check. The move officially
launched the Keep Kern Clean campaign.If Kern County voters pass it in June 2006, the initiative will
place an immediate ban on land application of treated sewage in the unincorporated county.

Dairy farm destroyed 3. The sludge contained;substances and compounds, toxic to humans and animals, i.
e., fluoride, cadmium, lead, mercury, iron, arsenic, aluminum, selenium and molybdenum ; Said
substances and compounds migrated from Bradens' land to Rollers' farm, causing damage including
diminished milk production, death of cows and loss of breeding opportunity.

Dairy farm cattle dead.In the same WEF/EPA Fact Sheet debunking the Zander dairy cattle deaths, the;
blame the victim; strategy was again used to explain the cause of deaths and diseases of the dairy cows
of another dairy farmer, Robert Ruane, of Rutland, Vermont, According to the Fact Sheet,;Ruane
possessed few herd records, silage quality was poor, the recommended feeding program was largely
ignored, and  feeding practice did not meet National Research Council ;recommendations for lactating
dairy animals, the Vermont Department of Agriculture found

Much of the original science showing sludge could very dangerous was done at Cornell University in the
early 1980s. Rubin received his advanced degree from Cornell so he should have known about the
science. However, he has chosen to promote sludge dumping as a fertilizer knowing that pathogens can
not be detected after the stress of certain treatment processes.

EPA Sludge Salesman Alan Rubin on Marketing and Distribution of sludge/biosolids in Sludge

EPA has told the Centers for Disease Control it developed a list of safety recommendations for people
when dealing with sludge/biosolids. However, it has refused to pass those recommendations to the
farmers who handle Class B sludge or the public who handles unlabelled Class A sludge/biosolids
contaminated by pathogen regrowth.

Some links

Sewage effluent   Effluent is the chemical and infectious streams of sludge biological solids and water
from a sewage treatment plant.

40 CFR 503.9 (t) Pollutant is an organic substance, an inorganic substance, a combination of organic and
inorganic substances, or a pathogenic organism that, after discharge and upon exposure, ingestion,
inhalation, or assimilation into an organism either directly from the environment or indirectly by ingestion
through the food chain, could, on the basis of information available to the Administrator of EPA, cause
death, disease, behavioral abnormalities, cancer, genetic mutations, physiological malfunctions
(including malfunction in reproduction), or physical deformations in either organisms or offspring of the


According to scientists working for the Environmental Protection Agency's Office of Research;
Development, the Sludge Rule on land application of municipal wastes (40 CFR Part 503) promulgated in
1993 may be the most scientifically unsound action ever taken by the agency. Rather than being
protective, the rule actually threatens public health and the environment.

Science Safety Sludge - bioslids Research

In a1973 conference on sludge use, USDA's John Walker reported to EPA that USDA Research at the
Beltsville facility showed that mixing lime in sludge or earth as a pathogen control was only effective for
about 30 days. Salmonella bacteria would reappear in tests after 30 days.
EPA's John Walker  (former USDA employee) and USDA's Rufus Chaney have been key players in
promoting toxic and hazardous sewage sludge as a safe fertilizer. EPA's Alan Rubin has claimed to be the
Sheik of sludge (look that word up). Rubin was the key contact for the Water Environment Federation
(WEF). He even served two years of his EPA tenure with WEF promoting sludge disposal as a fertilizer to
wastewater treatment plants and state regulators.

EPA has trotted out its infamous Ohio sludge Study  as positive proof that sludge is safe to use on
farmland. It was suppose to be a 3 year study. Except the study was never completed, but it was written
up. EPA followed up with the infamous National Research Council (NRC) Study The Use of Reclaimed
Water and Sludge in Food Crop Production. .The most alarming part of the NRC scientific study was the
reference to the one limited epidemic study on human exposure to sludge which was attributed to:
Brown, R.E, and titled, Demonstration of acceptable systems for land disposal of sewage sludge. Water
Engineering Research Lab. EPA 600/Z- 85- 062. Cincinnati, Ohio: U.S. Environmental Protection Agency.

;Sludge disposed of in a sanitary landfill will not harm anyone, nor will it contaminate the food or water
supply . (Federal Register (FR.) 58, 32, p. 9375).Under laboratory conditions the biological agents in
sludge requires Biosafety level Two practices.

Staph Bug pneumonia

If Staphylococcus aureus are found dead, does that mean that the problem is solved?" The
corollary: Are they dead, or merely in the viable but nonculturable state, in a starvation arrested state, or
killed from a starvation but otherwise in a recoverable state by sudden nutrient excess in the culture?
Additionally, there are issues of the reuptake of naked DNA. Recently, in discussing mobile genetic
elements (MGEs), Nielsen and others (2000) demonstrated that DNA was well protected in dead cells and
that transforming activity remained. The survival of such material was found to be up to two years.

When EPA came out with its part 503 open sludge dumping sludge policy which was based on perceived
exclusions in the environmental laws, was self-permitting and only included management practices -- a
county could have easily have banned sludge use. However, once state solid waste statutes were
revised to comply with part 503, EPA's open dumping policy became state law. Virginia shows us how this

Subj: David Donnini, Synagro Director sells $98 million in stock Date: 6/28/2005 5:27:25 PM Central
Daylight Time  It would seem Synagro Director Donnini is very nervous about the future prospects of the
company due to the sludge war brewing in Kern County, California.

Strep A necrotizing pneumonia

streptococcus   the medical community was shaken by the arrival in the late 1980s of several severe
forms of streptococcal infection and by the emergence of several drug-resistant strains (see
resistance. drug resistance,

Substance - hazardous

The NRC Committee claims the wastewater treatment technologies and procedures are adequate to
control: bacteria, viruses and parasites. ;Yet, According to the study,  There are three kinds of
microorganisms in sewage sludge which are of concernfor their effects on human health: bacteria,
viruses,and parasites. All have been found in treated secondary effluent and sludges ;Using traditional
methods ofvirus sampling and assay of water from soil lysimetersat sites irrigated with undisinfected
secondary watereffluent, Moore et al. (1981), have found coliphage virus particles at a depth of 1.37
meters. Using more sensitive detection methods, several ground water samples were taken 27.5 meters
below wastewater soil application sites and were found to be positive for animal viruses.

TOTAL COLIFORM  = ENTEROBACTERIACEAE - In sewage sludge and sewage wastewater effluent
                       (Biosolids and Reclaimed water)

Most pollution of America's waters is unregulated and unmonitored -- allowing polluters to pollute with
little fear of regulation or disclosure. A 1994 study by the General Accounting Office, a research and
auditing arm of the Congress, found that the majority of toxic pollutants discharged from 200 of 236
pesticide, pharmaceutical, and paper plants it examined, were so-called uncontrolled ; pollutants that are
exempt from regulation under the pollution permitting process of the Clean Water Act (GAO 1994). The
Environmental Working Group estimates that the total load of toxic pollution in most rivers, streams,
lakes, and bays over the past five years may be 20 times greater than the amounts reported in
Dishonorable Discharge.

Kern County is about to get tough with agencies that truck treated sewage sludge here, and local voters
are part of the strategy. A new web-site that would encourage a local initiative to ban importation of
sludge is already partially up and running.State Senator Dean Florez (D-Shafter) has a bill now working its
way through the Legislature. If sludge importers don't drop opposition to the bill, Florez vows to work on
a sludge-ban initiative that could go to Kern County voters in June 2006.

Valley fever epidemic
CDC-Morbidity and Mortality Weekly Report
Coccidioidomycosis — United States, 1991-1992
Valley fever epidemic Kern County

Viable, but nonculturable disease organisms in sewage sludge and effluent.


Viruses in sludge biosolids and reclaimed water into food and drinking water

Walkerton is the Ontario Canada  town where thousands were made sick andseven people died of  Ecoli
0157 and Campylobacter jejuni fromcontaminated drinking water

A usually quiet retreat in southwestern Ontario -- a place few Canadians had ever heard of before the
deaths of seven locals and the contaminating of more than 2,300 others -- the name of Walkerton is now,
and forever, synonymous with poison.

In Southern California, as in other states -- the sludge bullies in the waste industry and state and federal
regulatory  agencies are forcing toxic/pathogenic sewage sludge biosolids  from urban and industrial
sources on unwilling rural communities

In the first systematic attempt to assess how common the infections have become, researchers did a
comprehensive analysis of these methicillin-resistant Staphylococcus aureus (MRSA) infections in
Baltimore, Atlanta and Minnesota in 2001 and 2002. They found 2,107 cases in people who had no contact
with hospitals, the primary locales where such infections turned up in the past. The non-hospital cases
accounted for 8 percent to 20 percent of all such infections identified in the study. Children ages 2 and
younger appeared to be especially vulnerable

WEF/U.S. EPA Biosolids DEBUNKING Fact Sheet Project;  Biosolids in Northern Washington State:
Biosolids Fact SheetExecutive SummaryLegal biosolids land applications on a farm in Whatcom County,
Washington,prompted the owners of an adjacent farm to sue their neighbors, a district, andseveral
municipalities involved in the operation. The lawsuits claimed biosolids tainted a well and killed dairy
cattle in the area. Experts disputed the chargeson nearly every point, and the Washington Supreme
Court ruled against the couple who alleged the damages, Ray and Linda Zander. The Zanders gained
attention from two articles in Farm Journal and Dairy Today

The Water Environment Federation (WEF) received a lot of money from EPA for head up a public relations
campaign to defame the names of victims who were harmed by sludge. EPA is God to these people who
operate the treatment plants having to dispose of sludge.EPA gave them the list of victims and told them
who to hire to debunk the victims stories. Then gave WEF a letter from EPA stating EPA didn't know about
the victims.

[Sludge/Biosolids meets the definition of a biological weapon] Biological weapons may expose people to
bacteria, viruses, or toxins as fine airborne particles. Biological agents are infectious through one or
more of the following mechanisms of exposure, depending upon the particular type of agent: inhalation,
with infection through respiratory mucosa or lung tissues; ingestion; contact with the mucous
membranes of the eyes, or nasal tissues; or penetration of the skin through open cuts (even very small
cuts and abrasions of which employees might be unaware). Organic airborne particles share the same
physical characteristics in air or on surfaces as inorganic particles from hazardous dusts. This has been
demonstrated in military research on biological weapons and in civilian research to control the spread of
infection in hospitals.

EPA does not like to have its dirty secrets exposed to the light of public opinion: "A major thrust
involves using federal and private funds to pressure employers to fire scientists who raise concerns
about government policies or industry products and practices. The most common approach used against
scientists at government laboratories and universities is to file allegations of scientific misconduct,
ethics violations, and even criminal violations".Of course, EPA does asked its employees to commit
criminal violations when it is hiding the truth from us.

Dairy farm destroyed. Number 2 on the list to debunk was the Linda Zander story. Linda and Raymond
Zander became the victims of land application of sewage sludge. As a result of their exposure, through
both air and water, to the various toxic contaminants in the sewage sludge, the odds of this middle-aged
couple living to a ripe old age are slim to none.