From: Charlotte Hartman, 180 Boston Corners Road, Millerton, NY 12546
To: Susan Martel, Project Manager
Cc: Dr. Thomas Burke, Committee Chair
Re: Risks from Toxicants and Pathogens in Biosolids Fertilizers project BEST-K-00-02-A
There are two important areas of concern. In addition to the unbalanced membership of the proposed committee will there be a real opportunity for public participation? Will the lack of EPA's adoption of the recommendations from the first NAS/NRC study be revisited?
The experience of testifying at the so called "public" session at Rutgers 1994 was not as advertised and can only be characterized as a disappointing "sham." The format should not be repeated. The "public" session began with EPA, USDA, and the industry supporting the 503's. The public and independent scientists including scientists from Cornell and Steve Lester from CHEJ and the public spoke about their concerns with the regulations which the proponents had an opportunity to refute to end the "public" session. The NAS/NRC needs to hear from the public about the risks and real life experiences of harm. In order to provide meaningful public participation in the committee's deliberations the forum can not be controlled by the proponents.
This must be an independent study by committee members with no ties to either the regulators or the industry to retain any kind of public credibility. Must include toxicologists, medical professionals (human and animal). Honestly investigate public health and safety and the environment from all the constituents in sludge with an emphasis on children, the elderly and the immune compromised. Investigate the impacts of the proposed 300ppt dioxin in sludge and additives such as cement kiln dust and ash. Impacts from allowing radioactive wastes to be discharged to sewage treatment plants and used on food crops, problems from drugs, chemicals endocrine disrupters, pathogens and the increase of food borne and waterborne diseases some that have been traced to a human rather than animal source.
Background of National Research Council Report 1996 Use of Reclaimed Water and Sludge in Food Crop Production:
Some Recommendations from Executive Summary: (Not quite the glowing endorsement EPA and industry spin) Why have they been ignored and will they be revisited?
Until a more sensitive method for the detection of salmonella in sludge is developed, the present test should be used for support documentation, but not be substituted for the fecal coliform test in evaluating sludge as Class A.
EPA should continue to develop and evaluate effective ways to monitor specific pathogens in sewage sludge.
EPA should re-evaluate the adequacy of the 30-day waiting period following the application of Class B to pastures used for grazing animals.
A more comprehensive and consistent survey of municipal wastewater treatment plants is needed to show whether or not toxic organic compounds are present in sludges at concentrations too low to pose a risk to human and animal heath and to the environment. In conducting a second NSSS, EPA should strive to improve the integrity of the data by using more consistent sampling and data-reporting methods.
The EPA should not exclude chemicals from regulatory consideration based solely on whether or not these chemicals have been banned from manufacture in the US (PCBs) since they are still found in sludges from many wastewater treatment plants.
Those who irrigate crops with treated municipal wastewater should be aware of the concentrations of nutrients (nitrogen and phosphorous) in the reclaimed water and should adjust fertilizer practices accordingly in order to avoid undesirable vegetative growth or potential contamination of ground water.
When determining sludge and fertilizer application rates, an analysis of the rates of organic nitrogen mineralization should be performed in order to avoid buildup of excess nitrate-nitrogen. Nitrate-nitrogen that is not taken up by plants may contribute to excess fertilization and leaching. Where excess phosphorus is of concern, soil phosphorous levels should be monitored and sludge application rates should be adjusted to correspond to crop phosphorus rater than nitrogen needs
As more croplands are treated with municipal sludges and reach their regulatory limit of chemical pollutant loading from sludge applications, additional information will be needed to assess potential, long-term impacts of sludge on ground water quality and on the sustainability of soils for crop production. Comment: This is especially true in the northeast with acidic soils, abundant rainfall, shallow depth to groundwater, and diverse crops. More attention has to center on the sustainability of farmland in the northeast.
Please advise how these concerns will be addressed by NAS/NRC. Thank
you in advance.