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Many POTWs are still disposing of their wastewater residuals in landfills and incinerators. While many opponents of such practices are properly concerned with critical health issues, particularly with incineration or the landfilling of unstabilized sludges, we are more upset that such practices deliberately destroy natural resources, so vital to the Earth's ecology, and unnecessarily create undesirable CO2 emissions. We, as a world society, know the value of recycling. How can we tolerate public officials who, in the name of short-term expediency, destroy organic resources whose proper use can help feed the world now, and more importantly, in future years. When we landfill such resources today, we ensure that tomorrow's land disposal costs will be much more expensive. When do we stop passing the deficit to our children?.
Can private enterprise save the municipality money? Not necessarily! The issue is professional management and the innovative capabilities of professional staff. New technologies, like N-Viro, are revolutionizing the capital needs of wastewater treatment, operating costs, and the safe and socially acceptable management and use of residuals. We see POTW staffs that are fully competitive in the market. We also see the alternative. N-Viro has revolutionized the management of wastewater residuals by pioneering the use of alkaline technology to dramatically lower costs, reduce capital requirements, to create real, salable EQS products In 1995, more N-Viro Soil was sold to American farmers than all other bio-solids products combined), and to allow for significant up-stream cost reduction and asset conversion.
Change is inevitable. POTWs are facing constant upgrading of regulatory standards to meet public health concerns. New technology is critical to meeting these standards without burdening communities with new and unnecessary capital debt and operating costs. The opportunity for the innovative manager or consultant is unlimited. The ability to find new uses for sunken costs opens wide possibilities. N-Viro's professional staff, consultants and representatives are available to help identify and quantify these solutions. N-Viro technology represents the "best demonstrated available technology" to disinfect pathogens, to fixate metals, and to immobilize nutrients. Each technology is critical. By using BDAT today, the probability of future regulatory changes is drastically reduced. Why is N-Viro Soil "best demonstrated available technology?"
- Pathogens:N-Viro achieves pathogen standards 2,000 times more stringent than Class B. After eight years of operation in four countries, there is no evidence of pathogen regrowth. N-Viro is Class A.
- Metals: N-Viro Soil products all meet 503 Table 3 metals concentration requirements. Moreover, chemical stabilization has been identified by the USEPA Office of Solid Waste as "best demonstrated available technology" for fixating heavy metals. The Ohio Edison Study (submitted with N-Viro's 1988 PFRP proposal) demonstrated that in testing significantly more rigid than TCLP (Chaney protocol) N-Viro met "drinking water standards." The Louisiana State University study, funded by USDA and USEPA, showed N-Viro Soil superior to all other bio-solids tested in the immobilization of heavy metals.
- Vector attraction: N-Viro products have been stored in the open in all climates, for as long as two years, without vector attraction. Can any other bio-solids product make such a claim?
- Nutrient non-point source pollution: N-Viro Soil has demonstrated the ability to immobilize nutrients and organics to provide for a slow release through mineralization, thus reducing non-point source run-off and leaching.
The critical issue facing POTW managers is liability. The 503 regulations are self-regulatory, so total responsibility and liability lies with the POTW manager. Today, enforcement of Federal regulations (40 CFR 503) is non-existent. No one is protecting the POTW against liability risks from CWA, RCRA, CERCLA (Superfund) or natural resource legislation. With EQS, the process is permitted at a point source facility. Compliance is easily monitored. No off-site "site restrictions and management practices" compliance is mandated to meet permit requirements to achieve a "federally permitted release." If the permit is violated by non-compliance, total liability rests with the POTW and its managers, even if the contractor is totally at fault. Moreover, if POTW residuals are used as "feed stock" in the production of a "commercial product," as they are with N-Viro or compost or pellets, then POTWs have great liability protection. Wastes used as "feed stock" in the production of a "commercial product" are no longer to be categorized as wastes. With traditional land application of Class B bio-solids there is no such protection
With new technologies like N-Viro, or compost, there is no excuse for burdening suburban or rural neighbors with either odors or public health concerns. The critical issue in beneficial utilization is long-term odor control. Bio-solids that are directly injected or incorporated into the soil do not cause substantial odor issues. However, bio-solids that are stored or placed on no-till or grazing land can be major causes of odor, unless sufficiently stabilized. N-Viro and compost provide such stability.
Does it make sense to use local dollars to rebuild capital intense facilities that are no longer viable or not state-of-the-art technologies? Can these facilities be used in a more cost-effective manner? Innovative public managers and/or their consultants will carefully analyze optional strategies, particularly strategies that convert from disposal to utilization; from Class B to Class A; from sludge (or bio-solids) to real products; and from residues that negatively impact non-point source water pollution to products that, through immobilization and stabilization, reduce non-point source water pollution.
Why spend more capital dollars? Old sludge treatment facilities can be converted to provide increased capacity.
First, bio-solids should not be land-applied on a year around basis. With such practices, run-off to surface waters and leaching to ground water cause significant and unnecessary non-point source discharge water pollution. Did we spend all that money at the POTW to pollute our streams elsewhere?
Second, if bio-solids are only applied seasonally, as they should be, then storage is a critical issue. Most EQS process technologies provide long-term storage capabilities (at least 4-6 months). Today, storage is unregulated. It soon will be regulated, but unless enforced, it will be another major liability concern.
Third, we believe that the recommendations of the National Research Council will soon result in more local control, i.e. county public health officials involved in bio-solids management. We support such involvement, and suggest it will have major impact on future policy and practices.
As mentioned earlier, the N-Viro technology, which is best used with raw sludge to achieve the highest value product, requires no digestion. Most compost and pellet operations do require digestion. The innovative manager will carefully review the discussion in enclosure III-5 of the N-Viro Treatice., by Dr. Douglas Borgatti and David Sloan, which identifies up-stream process cost reduction opportunities available with selection of the N-Viro process.