BIOSOLIDS PARTNERSHIP

                                      DEBUNKING THE DEBUNKERS
In 1994 EPA put together a list of problem areas for sludge. EPA notified its partner,   the
Water Environment Federation (WEF), of a writer it needed to hire and the stories he was to
write about. EPA funded and ran the
public relations campaign.to debunk the factual

These are excerpts from the stories. The writer did not do any research according to the PR
campaign documents. What is worse, they sent out the documents to some people for
comment, then refused to include any comments which corrected the document. Still, the writer
included some interesting case material.

Full debunking articles @

Table of Contents
lntroductory Material
• Foreword
• Introduction
• Reviewing the WEF/USEPA Biosolids Fact Sheet Project
• Biosolids: A Short Explanation and Discussion
Fact Sheets
• Biosolids Recycling in West Texas
In September 1993, a series of human errors in New York City and in Texas led to the
application of nine rail containers of biosolids that had failed to meet the detention
requirement for PSRP. MERCO reported the incident to TNRCC and was fined for violating
its state registration.

MERCO and TNRCC tested the applied biosolids for pathogen indicators and determined the
biosolids did not threaten human health or the environment. Although they received
insufficient PSRP treatment, the pathogen concentrations in the measured biosolids were less
than 2 million parts per gram - a level that proper PSRP is designed to achieve.

Nonetheless, to avoid future problems, the frequency of PSRP certification was increased
from a monthly to weekly basis, and MERCO initiated the previously mentioned additional
testing prior to biosolids departure from New York City.

In Texas, the regular testing for the presence of pathogen indicators has occasionally revealed
varying levels above the federal and state regulatory limits, causing concern about pathogen
regrowth during transport. However, an independent analysis by Alternative Resources, Inc.,
of Stroudsberg, Pa., determined that the variations were most likely caused by inconsistencies
in the sampling and analytical methods at the five separate labs conducting the analysis.

• Biosolids Reuse in Southern California
On the other hand, residents complained of
thick dust, clouds of flies, allergic reactions, and concern about perceived groundwater
pollution from the stockpiled biosolids and the separate composting operations. Others
complained of headaches and nausea. Many residents said odors abated when composting

llegal Activity in Imperial County
When Mount San Diego began to attract widespread attention, CCF compounded its
imminent legal problems by land applying hundreds of truckloads of biosolids to
farmland in Seeley, a town in Imperial County, California. The discovery of this
activity, which clearly violated CCF’s contract with San Diego, led to the arrest of
company officials.

CCF’s scheme was uncovered when KGTV-10, a local television news team, followed several
Biosolids Fact Sheets
Copyright (c) 2000 Water Environment Federation. All Rights Reserved.
trucks from the Fiesta Island drying facility to a farm in Seeley. A San Diego employee also
pursued and videotaped the trucks. Under cover of night, the trucks dumped and spread full
loads of biosolids on to the farm. The U.S. Attorney’s Office for the Southern District of
Californiaalleges that CCF sent hundreds of truckloads of biosolids to Seeley.

A long paper trail followed CCF’s actions in Seeley. The company allegedly paid out more
than $36,000 in bribes and fees to haul and apply the biosolids to the farmland. In April 1993,
CCF issued a check for $14,300 to Triple M Trucking as payment for delivery of 44 loads of
Fiesta Island biosolids to Seeley. Later that month, CCF issued a check for $15,500 in the
name of the wife of the individual who allowed Fiesta Island biosolids to be dumped on his
land in Seeley. In March and May 1993, Cordon Cooper received forged weighmaster
certificates and invoicesfrom Manuel Mier. The items indicated that Fiesta Island biosolids
were shipped to Mexicali, Mexico. Also in

• Biosolids in Northern Washington State
Does Linda Zander run an anti-biosolids group?
On January 27, 1992, Linda Zander registered Help for Sewage Victims as a non-profit
corporation in Washington. The purposes and mission of the group were explained as
“networking, support of sewage victims, and help with 'investigation,’ 'legal
responses,’ and 'prevention’.”

Who else joined the Zanders' suit against WSI, the towns, and the Van Dalens?
Aside from farm owners Ray and Linda Zander, nine other people, mostly relatives of
the Zanders, participated in the lawsuit against the biosolids generators and land
appliers. All lived on the Zander farm. Co-plaintiffs included Linda Zander’s parents
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Carl and Glennis Vevag; Christopher Zander, the son of Ray and Linda, who grew
shiitake mushrooms for profit on the farm; Ervin A. Hicks, a deceased employee of the
Zander farm who allegedly received treatment for heavy metal poisoning; Deborah
Condon, the Zanders’ widowed daughter; Robert Zander, Ray and Linda’s son; Della
Zander, Robert’s wife; and Ashley and Diana Zander, the children of Robert and Della.

At times, the herd also experienced abortions, diarrhea, deformed leg tendons, and swollen
joints, according to the Zanders. The veterinarians reviewed that data and examined the herd,
determiningthat low reproduction rates and diarrhea were associated with poor quality grass
silage. Grass silage was fed as the cows’ only forage for at least four weeks in 1990, and
problems with the herd stopped when silage rations were discontinued. Some cattle illness and
deaths also may have been the result of noncompliance with vaccination strategies, foot rot,
poor bedding of cows and milking hygiene, or force in assisted calvings.

What about reports of cattle illness and death due to biosolids in other parts of the United

At least two other reports of biosolids contributing to cattle maladies have circulated
among farmers and biosolids managers. In Vermont’ dairy farmer Robert Ruane
allowed the City of Rutland to land apply 5.5 tons of biosolids per acre per year to his
99-acre farm for two years beginning in 1986. Ruane’s herd showed increased
mortality, arthritis, abortions, and muscular problems. Ruane possessed few herd
records, silage quality was poor, the recommended feeding program was largely
ignored, and feeding practices did not meet National Research Council
recommendations for lactating dairy animals, the Vermont Department of Agriculture
found. Ruane kept his cattle off fields to which biosolids were recently applied.

In North Carolina, several cattle died after eating Bermuda grass from a land
application site run by the City of Raleigh. The Bermuda grass was high in nitrates, as
is common in grasses grown with any type of fertilizer. All farmers were told to mix the
grass with hay or other material. The farmer who suffered the loss failed to mix the
Bermuda grass with other feed. This management problem is the only recorded animal
or human injury

• Biosolids and Miniature Horses in Oklahoma
In one worst-case study conducted by the U.S. Department of Agriculture and the University
of Maryland in Beltsville, Maryland, there was some damage to joints of cattle from high iron
contained in biosolids applied directly onto forages and immediately grazed. In these studies,
cattle were forced to graze forages that were treated each week with the high iron-containing

A review of the autopsies of the dead miniature horses was conducted by Oklahoma City’s
expert witness, John C. Haliburton of Veterinary Toxicology Consultants in Amarillo, Texas.
He concluded that iron contained in Oklahoma City biosolids did not injure the horses.
Instead, lesions he found on the livers and brains of the deceased horses suggested that the
cause of death was two forms of equine leucoencephalomalacia (ELEM),
a disease syndrome
caused by fungus

Both forms of ELEM are caused by a group of compound called fumonisins, which are
classified as mycotoxins. Mycotoxins are compounds produced by mold, or fungi. The fungus
which produces the toxic fumonisins is called Fusarium moniliforme, a common soil fungus.
Fumonisins are found commonly in horse feed ingredients such as corn, oats, and wheat, as
well as in many other environments conducive to mold. ELEM, however, is known only to
occur in association with the consumption of corn.

• Can AIDS Be Transmitted by Biosolids?
The dangers of HIV make experiments using the virus outside laboratory settings
Federal law protects workers who may come in direct contact with wastewater residuals. The
U.S. Department of Labor Occupational Safety and Health Administration’s Bloodborne
Pathogen Regulation, promulgated December 6, 1991, prevents potential infection of workers
Biosolids Fact Sheets
Copyright (c) 2000 Water Environment Federation. All Rights Reserved.
by many pathogens, including HIV. The law requires all employers to minimize worker
exposure to potentially infectious body fluids and to inform employees of their risks of coming
in contact with such materials in the workplace. The Bloodborne Pathogen Regulation can
reduce the HIV risk at wastewater treatment facilities to zero. Johnson et al. concluded that
wastewater treatment plant workers can eliminate the opportunity for all types of pathogen
infection by wearing protective clothing and practicing workplace hygiene. Likewise, the
Centers for Disease Control recommends protective clothing as a barrier to various infections.

• Biosolids and Bahamian Papaya Crops
A farmer obtained funding from the U.S. government and a British investor to
start a papaya plantation in Freeport, Grand Bahama. The farmer’s fertilization
protocol called for application of the heat-dried biosolids fertilizer Milorganite.
Instead, in 1986 and 1987, he obtained and land-applied biosolids from
Metropolitan Dade County, Florida. A year after planting, many of the papaya
plants yellowed and died. Although there was no scientific substantiation of the
claim the Dade County biosolids were responsible for the death of the papaya
crop, the farmer sued the county and won a $6.75-million judgment in May
1993. The case was settled out of court in June 1996.

• Biosolids Use in the Pacific Northwest
King County paid $428,000, the estimated value and replanting costs of
the affected trees, to Weyerhaeuser for reparations.
In many of the impacted areas, scientists found Armillaria root disease and root weevils
associated with more than 70 percent of the trees killed. Also contributing to the kill in those
areas was the Douglas Fir beetle. In other affected areas, diseases and insects apparently
accounted for only 30 percent of tree kill. In areas without insects and disease, the reduced
soil aeration alone (due to the surface sealing of the biosolids) may have killed the trees.
Douglas fir trees have many fine roots as well as larger roots. Fine roots are grow actively and
require relatively greater quantities of oxygen to survive. They are the primary means by
which the fir trees absorb water and nutrients. Fine root health was poor in all affected areas.
Not only are weakened trees more susceptible to disease and damage from insects, they are
also less able to recover from large animal damage. Contributory causes of death to the
weakened trees probably included bear damage.

• Biosolids and Lou Gehrig’s Disease
A series of 1987 newspaper articles alleged that application of the heat-dried
biosolids fertilizer Milorganite may have caused athletes to contract
amyotrophic lateral sclerosis (ALS), commonly referred to as Lou Gehrig‘s
disease. A neurologist alleged that high rates of ALS were observed around
Milwaukee, Milorganite's largest market. Review of the data by a large group
of federal, state, and local specialists dispelled all links between the fertilizer
and the disease.
Did Milorganite ever contain materials with the potential to harm humans or the
Milorganite contained relatively high levels of cadmium until the mid 1980s. As much as 80
percent of the cadmium in Milwaukee’s sewer system was traced to a single source, a Master
Lock cadmium plating facility. The city’s 1981 wastewater pretreatment program, reduced
cadmium levels in Milorganite from 140 mg/kg in 1980 to 3.08 mg/kg today. The
pretreatment program limited sewer system users to daily cadmium discharges of 1.5 mg/l.
From 1979 to 1992, Milorganite carried an approved, specific warning label alerting
consumers to cadmium’s possible links to kidney disfunction and other disorders. The material
was neither recommended for nor marketed toward residential gardens during this period, as
ingestion from food crops is a primary pathway of cadmium intake by humans. Milorganite
never was banned from designated uses before implementation of the pretreatment program.
Relevant research asserts no link between ALS and cadmium.

• Biosolids Application to Federal Land
In regard to biosolids land application, BLM’s greatest concern was federal liability for
environmental contamination under the Comprehensive Environmental Response,
Compensation, and Liability Act, the Resource Conservation and Recovery Act, or
other environmental statutes. In 1990, as now, landowners accepting properly managed
biosolids for land application are free of federal liability. No CERCLA sites have
received Superfund designation due to biosolids land application.

A few Superfund sites do involve biosolids. A Wisconsin biosolids lagoon system built in the
1940s contained some biosolids with polychlorinated biphenyl concentrations above the 50
mg/kg federal regulatory limit. This material is currently managed under Super-fund, and
biosolids exceeding the 50 mg/kg limit have not beenrecycled to agricultural land. Federal
authorities never have alleged Superfund or other liability due to biosolids land application.

BLM made a conservative decision by attempting to forbid land application of biosolids. The
Biosolids Fact Sheets
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Bureau expressed concern over possible poor management of biosolids by municipal
authorities leading to environmental contamination and federal liability. A U.S. General
Accounting Office report released around the time of BLM’s policy memorandum called into
question quality control and other issues in state biosolids programs, fueling fears of “local
incompetency.” BLM officials also contended that their staff could not possibly monitor the
operations and impacts of biosolids land application projects strung out over 270 million acres
of Bureau-managed land. In the face of strict enforcement of environmental regulations by
U.S. EPA and state agencies at numerous locally operated waste-disposal sites on public
lands, and harboring doubts about biosolids safety and management, BLM elected to opt out
of biosolids use.

The Bureau responded in two parts to the Colorado proposals. First, Bernie Hyde, a BLM
environmental policy expert at Bureau headquarters in Washington, D.C., rejected the
proposals by speculating that biosolids constituted hazardous waste and jeopardized elk
populations whichgrazed in the areas designated for land application. Second, Hyde
requested a definitive policy on whether BLM should allow application of treated municipal
biosolids on federally owned publiclands. Based on perceived risks associated with biosolids,
U.S. DO1 prohibited use of biosolids on its public lands. The Bureau permitted sale of federal
lands to municipalities for the purpose of biosolids application to commercial crops of
non-food agricultural products if no other option of biosolids management was available.