Class A Compost Sludge

To: Brunswick ME Town Council

From: Caroline Snyder, Ph.D.

Re: Final Report of the Brunswick Biosolids Peer Review Committee

February 23, 2006

Preliminary Draft Comments

At the request of the Katahdin Center for Education and Research, we are providing comments about the Final Report of a Brunswick Biosolids Peer Review Committee. The committee was charged with comparing the risks of Class A biosolids compost with those of organic composts when these materials are used to maintain vegetation on an athletic field located in Brunswick’s Aquifer Protection Zone.

We have not seen all the materials that the committee examined for their comparative risk assessment. However we have reviewed the documents and charts referenced in the Final Report. Therefore our comments are in the form of a preliminary draft. We will present a final draft, after we have reviewed the additional materials.

1. Committee Members

Town Council, cognizant of the increasing controversy in the scientific community about the safety and benefits of sludge use, sought to get unbiased, scientific, and objective data about this controversial practice. This is commendable. Accordingly, the Council stipulated that only those researchers could serve on the committee who had no preconceived notions about sludge use, or previous involvement with companies that land apply.

Sharon Marion D’Orsie, a member of the committee, has a 33-year old association with the Water Environment Federation (WEF). WEF is the nation’s most powerful lobbying group for land application of sewage sludge. Ms. D’Orsie served as President of the Texas WEF and contributed for thirteen years to their newsletter. She has received three awards from WEF. WEF has a long history of aggressively promoting sludge spreading and controlling the science that informs this practice. Members of the WEF and the companies they represent, have discredited and tried to silence scientists whose research indicates problems with land application. In no way can Ms. D’Orsie be considered a “neutral” member of the committee. She should have explained her WEF connection and excused herself from serving on the committee.

The Town Council also stipulated that committee members had to reside in Maine, presumably because they would be familiar with the many variables (soils, climate, precipitation, temperature, growing season, etc) that are unique to Maine that would need to be considered when using sludge in Maine; they would have done sludge-related research on Maine sites and thus would be best qualified to assess the risks of the proposed Brunswick project.

Neither Ms. D’Orsie, nor Dr. Langley-Turnbaugh fit that description. Ms.D’Dorsie has lived in the state for only three years and has never done any field studies, much less sludge research. Dr. Langley-Turnbaugh earned her soil science degrees from the University of New Hampshire and the University of Wisconsin, and none of her published articles focus on Maine sites.

It is unfortunate that the Council did not appoint Maine sludge experts with a proven track record who have done research on Maine sites, that includes assessing and measuring groundwater impact from land application of sludges. (e.g. Dick Behr, C.E. Catricala, and others).
2. Literature Cited

During the last eight years a considerable body of significant published research has emerged that deals with newly identified problems linked to land application of sewage sludges. The most important of these are the published version of Case for Caution (Harrison et al 1999), the 2002 National Academy of Sciences report, Biosolids Applied to Land, which warned that the scientific foundation of the current policies is either lacking or outdated, Robert Hale’s research on toxic organics that concentrate in sludge compost, and David Lewis et al’s investigations, suggesting that interactions between irritant chemicals and pathogens are the most likely cause of the hundreds of serious adverse health effects (including deaths) reported by sludge-exposed neighbors.

There is also some research that specifically deals with groundwater impacts related to sludge use [e.g. an unpublished study done at the Lisbon ME Little Turf Farm, the C.E Catricala et al field study indicating rapid movement of sludge contaminants after a heavy rain event in Maine, the E. Jacobsen et al study how sludge compost contaminants impacted groundwater in New Jersey, the UNH research by McDowell on groundwater impact from sludges at a number of NH sites, as well as research by Welch (2000), Behr, Kolpin (2002) and others]. It appears as though the committee did not review any of this research. Instead, the report references a handful of peer reviewed published papers, two of which were authored and co-authored by long-time advocates and defenders of the current land application policies and none of which address groundwater impact, or health risks associated with land application. In addition, the committee cites a flawed paper, funded mostly by the sewerage industry, newspaper articles, dictionaries, and encyclopedias.

The committee reviewed information provided by New England Organics, the company that makes and markets sludge compost. However, it apparently did not seek or review any information about organic composts, even though its stated purpose was to compare the risks of these two materials

3.The Final Report

General comments:

The final report ignores important information and makes unsubstantiated statements.
For example the committee did not substantiate its claim that inhalation risks from sludge ‘were not unique” and thus no different than those from organic composts. We know of no documented or anecdotal incident in New England where odors or air borne pollutants from land applied organic compost or manure have ever adversely affected the health of exposed neighbors. On the other hand, there are a great many anecdotal reports and some published research that link asthma and other serious respiratory problems to land applied sludges, including sludge compost. In 2000, a pile of New England Organic’s sludge compost, stored in rain, adjacent to an elementary school, destabilized and caused children in the school playground to become nauseous and vomit.

The committee states that risks from inhalation are reduced “as long as biosolids is incorporated into the soil before the fields are used”. We agree. But placing biosolids on fields “in the late fall and waiting for four months is not equivalent to “incorporation,” as the report states. Also, a good grass cover cannot be maintained if you incorporate the sludge into the soil. And if the point of using sludge compost is to establish a good vegetation cover, why is it not applied in the spring, at the beginning of the growing season? By applying it in the late fall, most of the available nitrogen will have volatilized before plants can use it.

The Risks from Organics

Toxic organics, as well as non-regulated inorganic chemicals, are a growing concern of independent scientists who are researching the impacts of sludge use. There are about 100,000 man-made chemical compounds in circulation today, with 1000 new ones added every year. Hale estimates that most of them eventually end up in our waste stream and sludge, especially in sludges generated in industrialized urban centers. Only a dozen have standards. Most of these compounds are not monitored, regulated, or tested. Every month, every industry and business in the country can legally discharge 33 pounds of hazardous waste into sewers. Wastewater treatment plants are designed to remove these hazardous materials from the wastewater. By necessity they concentrate in the resultant sewage sludge. The committee did not find this problematic.

According to one committee member, the rules are protective because “environmental professionals review each industrial effluent in a case-by-case basis.” However, an increasing number of scientific experts, environmental and health organizations, public officials, and impacted stakeholders, do not share the committee’s faith in the efficacy and adequacy of the current federal and state regulations that govern the land application of sewage sludges. This includes the National Academy of Sciences, the prestigious Cornell Waste Management Institute, the nation’s largest and oldest environmental organization, the National Farmers Union, and a growing number of public officials in New England and across the nation.

The Risks from Pathogens

The committee’s assessment of pathogen risks appears to be equally inaccurate and superficial. The use of indicator pathogens to determine pathogen risks has been widely questioned because they are the most easily destroyed in the treatment process. The more resistant bacteria can survive and re-grow, especially when Class A sludge is stockpiled. This is why the NSA panel recommended re-testing Class A sludge if it is not land applied within three weeks. The NAS report doubts whether some of the approved methods used to reduce pathogens in sludge work. Samples provided by New England Organics about their product may not accurately reflect the product’s content. Random samples, tested by independent laboratories, might give more accurate data. To claim that “ pathogen concentration of Class A compost is equivalent to that in natural soils,” is misleading.

Conclusion

A credible comparative risk assessment of two materials that are land applied would, at the minimum, include accurate information about the materials being compared. The committee failed to do this. The cited Hawkridge sludge quality data are misleading and inaccurate for many reasons: for example, the chart gives figures averaged over a two- year period. But when assessing sludge quality, averages can be misleading, because sludge quality is unpredictable and can vary from day to day. No land- applied sludge is ever “average”. The amount of regulated toxic metals permitted in Maine’s Class A sludge (300 ppm of lead, 10 ppm of cadmium, 1000 ppm of copper, 1000 ppm of chromium) should be a matter of great concern.

The chart does not give any data about the constituents of industrial paper mill sludge, one of the materials that New England Organics mixes with sewage sludge to produce sludge compost. Nor does the chart show what new chemicals can be generated when sewage sludge or paper mill sludges are stockpiled. The chart does not take into account synergistic interactions between chemicals, or the toxicity of break-down products, some of which can be more persistent and toxic than the unregulated parent compound. In summary: the data about sludge compost that the committee used in its deliberations were much too limited to adequately assess the risks of this material when land applied.

Since the committee apparently did not review information about organic composts, and had limited information about sludge compost, how could it compare the risks of these two materials when land applied?

The committee rightly points out that the sandy soil of the Edwards Field would cause metals and other contaminants to leach into the underlying groundwater. It also pointed out that organic matter, would delay the leaching because of the sorption capacity of the sludge’s organic matter. Once the organic matter decays, the risks of metal mobility increases. So, in order to prevent sludge contaminants from impacting groundwater, it is essential to repeatedly add organic matter, in the form of sludge. Since metals do not break down, but will accumulate with each new sludge application, Edwards Field will slowly turn into a superfund site. To suggest, as the committee does, that the way to protect the aquifers is to first apply sludge, and then keep adding more sludge, to prevent the accumulating contaminants from mobilizing, is irresponsible.
Hundreds of sludge-exposed neighbors have reported respiratory and gastrointestinal symptoms. Illnesses and deaths have been linked to the practice and documented in the peer reviewed scientific literature. In contrast, no deaths or illnesses have ever been documented or reported by neighbors who live or work near fields where seasoned manure or organic composts have been applied.

There is increasing uncertainty about the safety and sustainability of sludge use. The NAS panel warned that agent-specific testing of a limited number of pollutants, without considering break-down products cannot assure that land application is safe. The NAS panel also warned that sewage sludge is such a complex mix of chemical and biological contaminants that its risks, when land applied cannot be reliably assessed. Yet the Peer Review Committee thought otherwise. Ignoring most of the relevant research, the committee felt confident not only to reliably assess the risks of sludge use, but also to conduct a valid comparative risk assessment.

The final report contains some useful hydrologic data. But beyond that, the report is superficial, biased, and lacks scientific credibility. According to Murray McBride, soils, such as those of Edward Field, “with little capacity to buffer pH and adsorb metals are poor candidates for metal-contaminated waste application.”

Safer options for athletic field maintenance exist, options that will not permanently contaminate these sites, can be used long-term, and will not impact groundwater or public health. It would be prudent for the Brunswick Town Council to consider these other options to safeguard the integrity of its aquifer protection zone, rather than to choose sewage sludge, a material that the Federal Clean Water Act defines as a pollutant.