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EPA one up on Congress


Senate Hearings on Sludge

Fifty thousand + dollars in the last year, in hospital costs, just to diagnose a health problem indicate we have a serious problem with our health care system. Nineteen years of research indicates that the medical community has been blind sided by the wastewater industry regulators who have promoted the use of sludge on food crops, grazing land, parks, school grounds and home lawns.

The waste industry regulators claim the safety of sludge use is guaranteed by a scientific risk assessment and a test for thermotolerant E. coli (fecal coliform). http://thewatchers.us/Fecal_coliform.html In 1995, EPA admitted the risk assessment did not include any chemicals or pathogens and claimed the few heavy metals did not cause cancer. http://deadlydeceit.com/503-Riskassessment.html http://deadlydeceit.com/1989_503_cancer_list.html

As a member of the Kansas City, Missouri Mayor's Committee to evaluate solid waste disposal options in the early 70's, it appeared that the U.S. was on track to protect public health and the environment. In the mid-70s the City forced the sale of part of my wife's family's farm in the Floodway of the Missouri River for the Birmingham wastewater Treatment Plant (it was flooded out in 1993 for several weeks).

In 1989, based on the proposed conservative Part 503 sludge rule, Kansas City began using the treatment plant land as a sludge disposal site. Since the City claimed to have landlocked the farm under an EPA contract, which EPA claimed it could not enforce, but it would keep the contract open until the City decided to comply with federal law, it was decided this would be a good research project. Based on the conservative Part 503, I opined in a paper given at the New Mexico Governor's Conference on the Environment in 1992 that these sludge disposal farms were Open Dumps under RCRA and 40 CFR 257 and potential Superfund sites which contaminate our food and water. http://thewatchers.us/New-Mexico-paper.html

By 1998, we discovered that not only was calcium washing of the sludge disposal site unto the family farm, but high levels of bacteria was accumulating on the farm. Both E. coli and Salmonella were found at over 800,000 cfu per 100 mg/l of soil on the farm. Records show that groundwater was contaminated by fecal coliform and metals. Records also indicated that when the land loading limit was reached, the City started over. The state claimed the site was self-permitting and pollution runoff was allowed under the CWA exemption for agriculture. http://deadlydeceit.com/DD4.html

In the final analysis is that the only metals EPA included in Part 503 where the metals for which removal credits for land disposal where allowed under part 403. http://deadlydeceit.com/403-503-removal_credit_Table.html Chromium was removed from the Part 503 subpart for sludge applied to land in a court action by EPA and its partners because the levels in sludge/biosolids were five times higher than that allowed in the Part 503.23 subpart for sludge/biosolids placed on the land. Under the rules if sludge is applied to the land it is a self-permitting application of fertilizer, If it is placed on the land it is being disposed of and requires a permit. http://deadlydeceit.com/503-23.html

For the past 19 years it would appear waste industry regulators have been playing a game of one upmanship with legislators. Legislators have enacted the laws to protect public health and the environment, but you have given agencies the money and means to counteract legislative intent. The result, pathogens are disposed of in the toilets, go through the water treatment plants, end up on farms, parks, school grounds and home lawns, run off into the waters of the United States, are pick up by drinking water treatment plants, and we have contaminated food and water at home and in the hospital.

Since this affect the elderly more often than not, the government picks up most of the tab. http://thewatchers.us/disease-machine.html

Jim Bynum, VP Help for Sewage Victims A Washington Nonprofit PO Box 682 Smithville, Mo 64089