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June 12, 1996, letter to Mr. Alfred W. Lindsey, Deputy Director of the USEPA Office of Wastewater Management, thoroughly discusses three problems with Federal sludge policy and regulations.
Certain processes clearly represent "best demonstrated available technology."
1. Pathogens:
Class A processes are required to destroy pathogens to a level 2,000 times more stringent than Class B processes. In most cases, e.g. stored bio-solids, no-till bio-solids, and grazing land bio-solids, Class B bio-solids are not directly injected or incorporated, so that any statements that such incorporation or injection makes Class B comparable to Class A are simply not valid. Prior to incorporation, the public is exposed to these marginally disinfected residuals. Significant parasitic survival in the soil from Class B sludge application has been demonstrated. Class A clearly represents "best demonstrated technology." Who is preventing such designation and on what authority?
2. Metals:
EQS processes require lower levels of metals concentrations (Table 3) than do other land applied (Table 1) bio-solids. Moreover, certain EQS processes also immobilize metals far better than alternative processes. Chemical stabilization achieves BDAT status in the fixation of heavy metals in hazardous waste. In contrast, digestion, a Class B process, actually increases concentrations and availability of metals. Yet, the EQS processes that immobilize metals, such as N-Viro, lime stabilization and composting, are not designated as "best demonstrated available technology." Why? The completed Louisiana State University study, which we received on September 29, 1994, documents the metals immobilization superiority of certain technologies. (N-Viro was #1.) This report, funded by USEPA and USDA, has still not been published. Why? Who is holding it up? On whose authority is it being delayed? Doesn't this report clearly demonstrate that certain processes provide "best demonstrated available technology" to immobilize metals? Why has this information not been shared with POTWs and the public? The public has a right to know the truth.
3.Vector attraction:
Again, certain processes, such as composting and N-Viro (AASSAD), have demonstrated the ability to be stored outdoors in all climates for substantial periods, i.e. greater than one year, without attracting vectors. This is not true with Class B processes. Why is there no differentiation (i.e. BDAT) between levels of vector attraction reduction processes? This is a critical public acceptance and social responsibility issue and, to date, it has been shamefully ignored.
4. Non-point source water pollution:
Congress is aggressively seeking to shift regulatory emphasis to non-point source rather than point source pollution. WEF and AMSA are supporting this position. We agree! It has never made sense to us how EPA could spend so much money cleaning up POTW effluent and then encourage year around land application of non-stabilized, non-immobilized bio-solids, which run-off to surface waters or leach into ground waters. Certain processes are clearly superior to all other processes in their ability to stabilize and immobilize nutrients and organics in bio-solids. Again, why not BDAT classification of superior processes. How can EPA correctly argue for better non-point source management of agricultural organic wastes, which is desperately needed, when EPA makes no effort to require "best demonstrated available technology" for reducing run-off and leaching of bio-solids? Where is EPA's credibility?
We urge the reader to carefully review the issues raised in the N-Viro Treatice. The entire letter, including all ten of its enclosures, is available upon request.
The landfilling of raw sludge, as permitted by 40 CFR 257, but prohibited by some States, is a national disgrace. Let's examine our reasons.
We fully appreciate the strong political clout of the landfill industry, particularly its largest member and its subsidiaries. We understand how important their "soft money" contributions to each political party are, especially in this presidential election year. However, no amount of political clout should cause the United States of America to implement policies that harm our ecology, our environment, or our public and national interests. Unlike a skeptical media, we believe national leaders have the will and the courage to stand tall when they understand the truth.
Enclosures XI-2., 3. & 4. raise additional issues with EPA policy and regulations, particularly concerning enforcement, storage, and year-around land application. We urge your review and welcome your comments, suggestions, concerns and criticisms.
Enclosures