Sacrificial Lambs
WEF/U.S. EPA Biosolids Fact Sheet Project
Biosolids in Northern Washington State: Biosolids Fact Sheet

Executive Summary
Legal biosolids land applications on a farm in Whatcom County, Washington,
prompted the owners of an adjacent farm to sue their neighbors, a district, and
several municipalities involved in the operation. The lawsuits claimed biosolids
tainted a well and killed dairy cattle in the area. Experts disputed the charges
on 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.

Linda and Raymond Zander own a dairy farm at 2003 Pangbom Road. Their land
is uphill and across a stream immediately north of the John and Bernice Van Dalen farm at
1905 Pangbom Road and 1.5 miles south of the Canadian border. The Van Dalen farm is a
160-acre parcel with a main crop of feed grasses. The district of Birch Bay and the towns of
Lynden, Everson, Nooksack, and Sumas contracted with Western Services Inc. (WSI) to
apply biosolids to the Van Dalen farm between 1983 and 1984 and between 1988 and 1989.
The material was applied under fully permitted and supervised protocols, in accordance with
all state and federal regulations. All the cities’ publicly owned wastewater treatment works
were secondary treatment facilities using aerobic digestion processes None of the facilities
accepted wastewater flows from heavily industrial areas. The Whatcom County health
department determined application rates. No one challenged WSI’s 1988 land application
permit request.

Linda Zander first complained about biosolids in May 1989, alleging that runoff from biosolids
land applications caused a fishkill in Squaw Creek, which separates the Zander and Van Dalen
farms. Zander notified the Nooksack Tribe, the Washington Department of Fisheries, and the
government of British Columbia of her suspicions. On May 22, 1989, Zander filed her first
formal complaintagainst the Van Dalen land application site, claiming that WSI ignored
setback rules. Inspections found no violations or harm to fish. Due to the setbacks, WSI
applied biosolids no closer than 950 feet to a community well located on the Zander farm
north of the Van Dalen property.

When WSI sought a new application permit in February 1990, the Zanders challenged the
permit. The Zanders said their dairy herd was experiencing bone development problems, calf
mortality, and decreased reproduction due to heavy metals traveling in groundwater beneath
the Van Dalen farm to the Pangbom Community Well. WSI withdrew the biosolids land
application permit andstopped operations at the Van Dalen farm. The Zanders continued
filing complaints. The Zanders filed suit against WSI, Van Dalen, the district, each city, and
Biosolids Fact Sheets

Whatcom County in 1991. Their case sought to prove that groundwater to the community
well ran north, from beneath the biosolids applications on the Van Dalen farm to the well.
According to all experts familiar with theproperties, the opposite is true. Groundwater
feeding the well flows south and southwest from the top of the Zander farm down to the Van
Dalen farm.

Table 1. Zander Complaints Against Biosolids Use on Van Dalen Farm Are Consistently
Without Basis
Date                         Complaint                                          Authority Findings
5/89                 Fishkill in Squaw CreekNooksack No violation
5/89 Fishkill in Squaw CreekDept. of FisheriesNo violation
5/89 Fishkill in Squaw Creek British Columbia No violation
5/22/89 WSI ignoring setbacksWCDOH No violation
5/30/89 Fishkill in Squaw CreekWDOE No violation
3/29/90 Fishkill, eye irritation WDF No violation
4/4/90 Illegal biosolids appl. WCDOH No violation
4/12/90 Illegal biosolids appl. WCDOH No violation
5/10/90 Illegal biosolids appl. WCDOH No violation
5/14/90 Illegal biosolids appl. WCDOH No violation
5/15/90 Illegal biosolids appl. WCDOH No violation
5/23/90 Illegal biosolids appl. WCDOH No violation
6/5/90 Illegal biosolids appl. WCDOH* No violation
6/12/90 Illegal biosolids appl. WCDOH* No violation
7/2/90 Illegal biosolids appl. WCDOH No violation
7/9/90 Illegal biosolids appl. WCDOH* No violation
8/2/90 Illegal biosolids appl. WCDOH No violation
8/7/90 Illegal biosolids appl. WCDOH No violation
10/3/90 Illegal biosolids appl. WCDOH No violation
6/8/92 Illegal biosolids appl. WCDOH No violation
6/10/92 Illegal biosolids storageWDOE No violation
7/29/92 Illegal biosolids storageWDOE No violation
8/5/92 Illegal biosolids storageWDOE No violation
WCDOH - Whatcom County Department of Health
WDOE - State of Washington Department of Environment & Ecology
WDF - State of Washington Department of Fisheries
*Inspections made by Whatcom County officials and representatives of Soil
Conservation Services and County Sheriffs Office

WSI now is out of business, partly because of the Zanders’ complaints. Whatcom County and
the cities were dismissed by summary judgment of the Whatcom County Superior Court on
October 8, 1993. The dismissals were based largely on legal and procedural issues with the
result that many biosolids issues never were addressed. The Washington Court of Appeals
affirmed the trialcourt on July 31, 1995. The Washington Supreme Court declined

discretionary appeal on February 13, 1996, ending the legal battle,
Neighbors in the area said they experienced no ill health or other side effects. “We see no
harm done in the application of sludge upon this property... We feel the protest is unjustified,”
wrote 15 neighbors, many of whom live adjacent to the land application site.

Land Application of Biosolids

Municipal contractor WSI applied biosolids to the Van Dalen farm according to all
good management practices and standards mandated by the State of Washington and
the United States Environmental Protection Agency (U.S. EPA).

Prior to the mid-1980s, Whatcom County Department of Public Health regulated biosolids
land application by following “Sewage Sludge Guidelines for Washington,” developed in 1982
by Washington State University and the State of Washington Department of Ecology as the
state’s U.S. EPA-approved enforcement program. The public health department began issuing
biosolids utilization permits in 1985, as mandated by the state in its Minimum Functional
Standards for Sludge Utilization, in conformance with the state’s But Management Practices
for Sludge Utilization. In 1987, the Whatcom County Board of Health enacted local
regulations governing the use of biosolids in response to public concern over a request to
import biosolids into the county from Everett, Washington. The new regulations prohibited
biosolids land application from November through February and at times when groundwater
rises within two feet of the soil surface. Additionally, the regulations specified setback
distances from wells, surface water, property lines, and residences.

WSI received county biosolids permits in 1988 and 1989. The company applied biosolids to a
portion of the permitted area on the Van Dalen farm at a rate of 2.2 dry tons per acre in 1988
and 3.54 dry tons per acre in 1989. The Van Dalen application rates were determined by
nitrogen requirements of crop grasses to be grown. WSI applied biosolids at a nitrogen rate of
90 pounds per acre, about half the maximum allowable loading rate of 200 pounds per acre.
Metals levels in the biosolids were below current U.S. EPA standards not in effect at the time
of application at the Van Dalen farm. The biosolids at the Van Dalen site met all statutory and
regulatory requirements of the Washington Department of Ecology and U.S. EPA.

U.S. EPA has since issued standards and regulations for biosolids land application under Title
40 of the Code of Federal Regulations, Part 503. The district and cities which applied at the
Van Dalen farm produce and recycle biosolids that meet the federal government’s highest
standards for such material. The district and cities, along with Blaine, Washington, now are
joined under a singleagency called BBBLENS. The wastewater district has continued
biosolids land application atanother site without incident.

Federal Table 3 PCL
EQ BiosolidsBay Birch Lynden Everson Sumas
Arsenic 41 8.4 0.8 5.2 3.1
Cadmium 39 2.0 1.2 3.0 2.0
Chromium --- 8.5 4.0 16.0 17.0
Copper 1,500 170.0 140.0 545.0 215.0
Lead 300 24.0 43.0 40.0 23.0
Mercury 17 1.2 1.7 --- ---
Nickel 420 11.0 9.0 30.0 20.0
Selenium 36 --- --- --- ---
Zinc 2,800 490.0 390.0 585.0 310.0
PCL - Pollutant Concentration Limit
Samples taken September 1991, January 1992, and May 1992.

Physical & Environmental Impacts of Biosolids
Effects on the Pangborn Water Association Well The Zanders claimed their cattle and
they themselves were poisoned by the travel of heavy metals in the Van Dalen biosolids
to groundwater feeding the Pangborn Community Well. This claim was based on
invalid and unsupportable scientific theories.

According to Almer D. Zander, brother of Ray Zander and a former U.S. Forest Service soil
scientist and forest hydrologist, groundwater ran uphill for 900 feet from beneath a ditch at
the edge of the Van Dalen farm to the community well on the Zander property. The well
provided drinking water for the Zanders, their cows, and most of the surrounding community.
Almer Zander contended that a 900-foot-radius cone of depression existed beneath the soil
surface of the two farms and caused groundwater to run in a northerly direction to the well. A
cone of depression is an inverted cone shape in the surface of a groundwater table that forms
around a well as the well is pumped.

Zander never explained the rationale behind his method of identifying a cone of depression,
which was to compare the surface water in the ditch between the two farms with the level of
water in the community well. He took his measurements in the ditch and the well a full year
apart. This method is not recognized by U.S. EPA, the U.S. Geological Survey (USGS), the
Washington State Department of Ecology, or other members of the scientific community.
Scientists generally use twomethods for determining a cone ofdepression. The first method
calls for installation of test wells. The second method uses mathematics to evaluate soil and
subsurface data. Prior to his investigationinto the Pangborn community well, Almer Zander
never conducted a well pump test, a well study, or any work to determine groundwater
movement. He admitted in court that he had no idea how to track the path of water in the
ditch to other points in the cone of depression. Zander's lack of experience and failure to use
accepted scientific methods invalidate his claims. Moreover, the findings of all other scientists
to testify in the Zander case stand in direct opposition to Almer Zander’s allegations.
The Zander's own hydrologist, Dr. Hanspeter Schreier, testified in deposition that the natural
groundwater flow in the Pangborn Road area is south and southwest. Schreier’s conclusion is

Table 2. Biosolids Produced at BBBLENS Facilities Satisfy Levels for Exceptional
Quality Biosolids
(milligrams per kilogram)
supported by USGS findings in 1960 and 1992, as well as by a 1988 research report by
Western Washington University. At least five other studies of the area find that groundwater
runs south, not north. Local geologist Willard Purnell concluded that no well in Whatcom
County was fed by even a 500-foot, down gradient cone of depression. Dave Garland, a
hydrogeologist for the Washington State Department of Ecology, used U.S. EPA procedures
to determine that the Pangborn well could not have drawn water from more than 500 feet
down gradient.

Poor operating conditions, faulty equipment and corroded piping at the Pangborn well may
explainhigh levels of zinc and other metals found in some samples of the well water. The
Zanders’ cattle clearly grazed around the well, which suggests the cows left manure around
the well. Corn was grown with fertilizer in the field surrounding the well, as close as 30 feet to
the wellhead. The Zanders applied dairy waste and manure to the field next to and uphill from
the well. Investigators from the Whatcom County Health Department found the well in
disrepair as early as 1990. Whilesampling for contaminants, state hydrologist Dave Garland
observed that the wellhead and well-house were unsanitary and unsecured. The 250-gallon,
galvanized-steel well tank potentiallycould have leached zinc into water drawn from the
Zander taps. The well’s pump was 11 years old at the time of the Van Dalen biosolids
applications. By 1991, cement tiles which cased the well had cracked and sand had backfilled
the well. The members of the Pangborn Water Association removed the Zander well from
their system in April 1991, claiming water from the well was corrosive and that the well was
running dry.

Groundwater Quality
Analysis of groundwater on the Van Dalen and Zander properties closest to the time of
biosolids land application was conducted by the Whatcom County Health Department
on June 7, 1990. The tests demonstrated no problems with groundwater.
The groundwater at the Zander and Van Dalen farms proved normal in every respect with the
exception of iron. High iron levels, which were not previously detected, were attributed to the
steel well equipment from which samples were collected. Nitrates in groundwater in northern
Whatcom County have increased steadily since 1973, largely as a result of increased
agricultural activity in the region. High nitrates affect a large part of The North County
Aquifer, including parts of British Columbia, but pose very low risk to human health or the
environment. The health departmentconcluded that biosolids use had no impact on the
Pangborn well.

The Zanders claimed that soil at the Van Dalen farm was inappropriate for biosolids
land application and allowed metals to leach to groundwater, thereby contaminating
the Pangborn Water Association Well. Tests showed no signs of contaminated soil.
The June 7, 1990, Whatcom County Health Department found no elevated levels of metals in
the soils at the Zander and Van Dalen farms. Despite slightly elevated lead levels in some
specifictypes of soils, metals concentrations in the soil at the Van Dalen farm were well below
federal and state limits for maximum accumulation in soil during the land application of
biosolids. Concentrations of all metals tested compared favorably to average concentrations in

14 soil samples from other parts of Whatcom County. Hanspeter Schreier also testified that
overall metals levels in soil on the Zander farm were acceptable.

Table 3. Biosolids Land Applied at the Van Dalen Farm Did Not Cause Soil
(milligrams per kilogram)
Soil type 32B
Before Application1 1/88 12/89 6/90
Arsenic 9.6 20.0 13.0 13.7
Cadmium <2.0 0.97 n/d 0.8
Copper 142.0 31.0 38.0 20.5
Lead 27.0 31.0 26.0 27.1
Nickel 78.0 22.0 18.0 13.0
Zinc 277.0 67.0 58.0 40.6
Soil type 32D
Arsenic 11.3 12.0 14.0 17.4
Cadmium <2.0 <0.8 n/d 0.36
Copper 82.0 28.0 40.0 30.8
Lead 5.0 12.0 27.0 18.6
Nickel 64.0 20.0 21.0 18.0
Zinc 105.0 36.0 43.0 45.8

December 1989 results based on 20 core composite samples taken from 14 separate sites at a
depth of six inches. Analysis conducted by Columbia Analytical Services.

The Zanders contend that the air on their farm was contaminated by nickel and
fluoride. Virtually no scientific evidence backed up this assertion, and the Zanders’ own
expert witnesses contradicted the theory that air contamination occurred as a result of
biosolids land application.

Dr. Susan Cook, a forest zoologist and consultant for a company called Freshwater
Assessments, claimed that results of air-filter analysis showed high levels of fluoride and nickel
in the air on the Zander farm. Air filters were installed on the Zander property and in two
control locations. Fluoride in the Zander air filter accumulated to 150 parts per million during
a 30-hour period. These levels were alleged to be higher than control filters in other areas.
This claim is considered to be based on faulty and non-representative data since Cook
performed the analyses three years after the final biosolids application at the Van Dalen farm.

Cattle Illness
The Zanders’ lawsuit claimed that several of their 150 dairy cows were sick and
experiencing abortions and sluggish reproductive habits due to biosolids applications.
Washington State University veterinarians concluded that the cattle received
poor-quality feed and that some cattle deaths were misreported by the Zanders.

The Zanders informed the WSU team that the dairy herd experienced two deaths in 1986,
three in 1987, seven in 1988, five in 1989, and four in the first half of 1990. The Zanders’
reports of dead cows are suspect, based on the observations of the WSU team. One cow
reported dead actually was butchered, and another was alive and a recent mother. Diagnoses
of death for most of the cows were undocumented or unavailable, making determination of a
cause of death impossible. WSU veterinarians blamed poor management of Zanders’ herd for
excess deaths.

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,
determining that 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.

Veterinarians at Washington State University found no indication of heavy metal toxicity in
the cattle from the Zander farm and doubted that water from the community well on the
Zanders’ property hurt the cattle. Health problems in the Zanders’ dairy herd could readily be
explained byfactors other than contaminated water, the WSU report stated.

The Farm Journal Articles
A pair of March 1992 magazine articles by author Ed Haag related the Zanders’ story
and accused regulatory agencies of nonenforcement of biosolids standards. The articles,
published in Farm Journal and Dairy Today, made little attempt to cover both sides of
the issue or to inform readers of the volume of evidence casting doubt on the Zanders’

The Farm Journal articles contained no comments from regulatory officials or others
involved in oversight and research at the Zander farm. These articles warned against
biosolids use on agricultural land despite a substantial and growing body of knowledge
about the safety and benefits of biosolids and wastewater recycling. Haag cited
outdated and questionable hypotheses without mentioning the more reliable and
extensive scientific data supporting biosolids land application. Haag criticized the
regulatory framework then in place for biosolids land application for laxity on
contaminant control and questioned the credentials of biosolids regulatory officers.
Haag implied that lack of enforcement led to misdeeds at the Van Dalen application site
and harm to the Zanders. At the time of the Van Dalen land applications, WDOE
produced biosolids regulations and guidelines and assisted in monitoring and
enforcement. The Whatcom County Health Department issued biosolids land
application permits, with review by local planning organizations, a cooperative
extension service, state agencies and the public. Comment on permit issuance from such
sources was required under the Washington Environmental Protection Act.
Haag supports his statements by reference to the results of a 1983 survey co-authored
by Cornell University researcher Don Lisk, of 30 separate biosolids samples, which

claimed that only seven materials met land application standards. All the tested
biosolids could have been land applied, however, by determining the application rates
of the biosolids with reference to allowable cumulative loadings limits for heavy metals.
U.S. EPA’s 1993 national sludge survey, which is not discussed in the Farm Journal
articles, analyzed 200 biosolids samples from across the country. The agency found that
general biosolids quality is much better than determined by the earlier, smaller study.
Haag quoted his sources out of context. Many comments in the articles later were
disavowed and modified by the people quoted by Haag. Darrell O. Turner, a retired soil
scientist from Washington State University and witness for the plaintiffs in the Zander
case, stated in Haag’s article that farmers should not land apply biosolids to their crops.
In a later, private correspondence, Turner stated that contemporary wastewater
treatment technology can produce safe, clean biosolids if properly implemented by
responsible operators. “This is not a problem resulting from lack of technology; it is a
people problem. ...When and if we succeed in bringing our agencies into line...I will
support land application,” Turner wrote. Likewise L.W. Whitlow, a dairy husbandry
specialist at North Carolina State University, wrote that his comments to Haag were
directed at drinking water issues, not biosolids. Whitlow raised concerns of metals and
nitrates from biosolids traveling through water supplies. These issues should pose no
problem on sites where biosolids are applied in conformance with federal and state
regulations. Biosolids generators and appliers should be “informed of regulations and
safeguards, why they exist and how they are enforced,” Whitlow wrote. “I am
concerned that [Haag’s] articles simply set off alarms without providing enough
information for a producer to get a balanced picture of the practice of sludge

Questions and Answers about the Zander Farm
Were the Zanders denied federal loans due to contamination on their property?
Linda Zander claims her 1991 application for a new Farmers Home Administration
loan was rejected because the soil on her farm is contaminated. According to Linda
Zander’s own testimony, her dairy farm turned a profit only twice between 1985 and
1991. Net losses totaled $18,430 in 1989, $93,266 in 1990, and $59,909 in 1991.
Operating income dwindled to $5,496 in 1991. Tanya I. Reeck, county supervisor for
U.S. Department of Agriculture’s Farmers Home Administration, stated that the loan
request was rejected based solely on the Zanders’ financial status. No appraisal of the
Zander farm was conducted as part of the loan review process, as the process did not
progress past financial review.

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

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.
What about reports of cattle illness and death due to biosolids in otherparts 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 during North Carolina’s 25-year-old biosolids land application

Articles, Publications l Bisogno, Tom. 1996. “The Sludging of America.” E/The
Environmental Magazine, May/June:19-22.
l Bratt, Calvin. 1990. "Rates Could Climb With Sludge Ruling.” Lynden Tribune,
May 23:1A.
l Haag, Ed. 1992. “Sludge Under Suspicion.” Farm Journal 116, no. 6:16-19.
l Haag, Ed. 1992. “Just Say No.” Dairy Today, March, 1992:82-83.
l Kinsley, Carol. 1992. “Controversy Surrounds Washington State Sludge Case.”
Delmarva Farmer, November 24: 1A.
l Klimpel, Terry, Kenneth MacKenzie, and Richard T. Tyree. 1992. “BBBLENS
Wastewater Biosolids Utilization.” Review paper dated October 15.
l Merriman, Ed. 1991. “Dairy Ruined by Sludge: Zanders.” The Capital Press,
July 19:1.
l Merriman, Ed. 1991. “Farmers, Public Warned of Sludge Danger.” The Capital
Press, July 19:3.
l Merriman, Ed. 1991. “Sludge Not at Fault: Officials.” The Capital Press, July
l Merriman, Ed. 1991. “Varying Test Results Add Fuel to Sludge Controversy.”
The Capital Press, July 26:3.
l Mullen, Leo. 1992. “Sludge Slugfest.” The Bellingham Herald, November 12.
Biosolids Fact Sheets
Copyright (c) 2000 Water Environment Federation. All Rights Reserved.
l Mullen, Leo. 1992. “Farmers Sue Over Sludge.” The Bellingham Herald,
November 19.
l Mullen, Leo. 1992. “Suit Over Impact of Sludge to Get Jury Trial, Judge Says.”
The Capital Press, December 12.
l Mullen, Leo. 1993. “Wash. Cities Escape Sewage Sludge Lawsuit.” The Capital
Press, September 24:A1.
l Mullen, Leo. 1993. “County Out of Sludge Lawsuit” The Bellingham Herald,
October 9.
Correspondence l June 15, 1990. Dave Garland, State of Washington Department of
Ecology, to Ray and Linda Zander, Lynden, Washington.
August 20, 1990. Alvin L. Forar, Dale Hancock, and Sue Waller, Washington
State University, to Dr. Greg Iversen, Sumas Veterinary Clinic, Sumas,
September 18, 1990. Dave Garland, State of Washington Department of Ecology,
to Ray and Linda Zander, Lynden, Washington.
October 24, 1990. Dave Garland, State of Washington Department of Ecology, to
David Bader, Whatcom County Health Department’ Bellingham, Washington.
June 27, 1991. Dan Scruton, Vermont Department of Agriculture’ Food and
Market Division, to George Dunsmore, Commissioner of Agriculture, Vermont
Department of Agriculture.
August 2, 1991. Daniel J. Moran, Seattle-King County Department of Health, to
Valerie Cunningham, Enumclaw, Washington.
March 17, 1992. Darrell O. Turner, Darrington, Washington, to Frank Post,
AMSCO Inc., Clemmons, NC.
March 23, 1992. Michael Stricker, Maryland Department of the Environment, to
Simin Tirgari, Maryland Department of the Environment.
March 24, 1992. James Pendowski, Washington Department of Ecology, to Karen
Freiberg, Farm Journal Inc.
March 27, 1992. Mark E. Lang, Dufresne Henry Inc., to New England Water
Pollution Control Association Residuals Management Committee’
April 2, 1992. L.W. Whitlow, North Carolina State University, to Frank Post,
AMSCO Inc., Clemmons, NC.
May 21, 1992. Nancy Blatt, WEF, Alexandria, Virginia, to Patti Psaris, WEF
Biosolids Task Force.
December 4, 1992. Willard D. Purnell, Timothy H. Roberts, and Banks Upshaw
HI, W.D. Purnell and Associates Inc., Bellingham, Washington, to Mark Lee,
Langabeer, Tull, and Cullier, Bellingham, Washington.
January 19, 1993. Peter S. Machno, Municipality of Metropolitan Seattle’ to Dale
Arnold, et al.
January 26, 1993. Terry M. Klimpel, BBBLENS, Lynden, Washington, to Dr.
Charles Sorber, WEF, Alexandria, VA.
February 2, 1993. Dr. Charles Sorber, WEF, Alexandria, VA, to Terry M.
Klimpel, BBBLENS, Lynden, Washington.
February 10, 1993. Richard D. Kuchenrither, Black & Veatch, Kansas City, MO,


to Dr. Charles Sorber, WEF, Alexandria, VA.
l February 5, 1996. Dick Heatherington, U.S. EPA Region 10, to Linda Zander,
Lynden, Washington.
l May 15, 1996. Albert C. Gray, WEF, Alexandria, Virginia, to the Editor, E/The
Environmental Magazine.
Legal Documents l August 9, 1990. Whatcom County Hearing Examiner, decision
in the matter of the appeal of Linda and Raymond Zander, file no. HD 2-90.
l December 13, 1991. Ray and Linda Zander, et al., amended complaint to the
Superior Court for the State of Washington in and for Whatcom County, no.
l January 27, 1992. State of Washington Secretary of State, certificate of
incorporation to Help for Sewage Victims. UDI no. 601365843.
l November 13, 1992. Ray and Linda Zander, et al., declaration of Linda Zander in
response to motion for summary judgment, to to the Superior Court for the State
of Washington in and for Whatcom County, no. 91-2-01253-5.
l March 9, 1993. Ray and Linda Zander, et al., second amended complaint to the
Superior Court for the State of Washington in and for Whatcom County, no.
l October 6, 1995. Ray and Linda Zander, et al., petition for review to the Supreme
Court of the State of Washington, no. 34765-9.
l February 13, 1996. Supreme Court of the State of Washington, Order No.
l March 4, 1996. Court of Appeals of the State of Washington, Division 1. Order
No. 34765-9-I.

The information in this document has been funded wholly or in part by the U.S.
Environmental Protection Agency under assistance agreement #CX820725-01-2. It may
not necessarily reflect the views of the Agency and no official endorsement should be
inferred This fact sheet was reviewed by several people, including some concerned about
the beneficial use of biosolids. Unverified issues were omitted

This fad sheet was produced by the Water Environment Federation (WEF) under a cooperative agreement with
the U.S. Environmental protection Agency. WEF is a not-for-profit technical and educational organization.
Founded in 1928, WEF’s mission is to preserve and enhance the global water environment. Federation members
are 41,000 water quality specialists from around the world, including environmental, civil and chemical
engineers, biologists, government officials, treatment plant managers and operators, laboratory technicians,
college professors, students, and equipment manufacturers and distributors.

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