Member Pipeline - Regulatory - Regulatory Alert (RA 01-09) - Attachment
| Date: | June 14, 2001 |
| Subject: | SIERRA CLUB’S DRAFT SEWAGE SLUDGE GUIDELINES |
| Reference: | RA 01-9 |
DRAFT - Sierra Club Sewage Sludge Guidelines
MAY 2001
BACKGROUND
The Sierra Club opposes the land application of municipal wastewater
(sewage) sludge as a fertilizer and/or soil amendment because current federal regulations
do not adequately protect public health and the environment from its hazards. The EPA
Office of Inspector General audited EPA's program for "Biosolids Management and
Enforcement" and concluded that EPA does not have an effective program for ensuring
compliance with the land application of sewage sludge and cannot assure the public that
current land application practices are protective of human health and the environment. A
1998 National Academy of Science study entitled, "Strengthening Science at the
EPA", singled out the federal land application regulations as not being firmly
grounded in good and recent science. These findings, along with the CDC/NIOSH
identification of Class B sewage sludge as a hazard to workers who handle this material,
reinforce the growing concern of many scientists and environmentalists that regulations
must be significantly strengthened.
Sierra Club Municipal Waste Management Policy states: "Wastewater pretreatment and
treatment should be sufficient to make sewage sludge safe as a soil conditioner or for
composting with food and plant wastes. Application of compost or sludge to the land should
follow guidelines that will protect the environment and public health." Because such
protection cannot be assured at this time, federal, state and local governments must
develop programs and regulations to eliminate the hazards posed by sewage sludge.
Although a complete overhaul of the current sewage handling infrastructure could take
generations to accomplish, efforts must be undertaken immediately by federal, state and
local governments to develop programs to separate industrial, commercial and household
chemical waste from the human waste stream and otherwise eliminate the hazards posed by
sewage sludge.
GUIDANCE
The Sierra Club opposes the land application of municipal wastewater
(sewage) sludge as a fertilizer and/or soil amendment, and other uses that result in its
distribution in the environment, unless and until it is treated adequately to remove
contaminants and the following conditions for controlled reuse or release are met:
1. Fully protective government regulations, programs and infrastructures must be put in
place to regulate the generation and management of sewage sludge such that workers, public
health, long-term agricultural productivity, and the environment are protected from
exposure to hazardous constituents.
2. Contamination of sewage sludge by persistent, bioaccumulative, toxic chemicals such as dioxins, furans, PCBs, surfactants, flame retardants, pharmaceuticals, heavy metals, and radioactive byproducts, should be prevented through source separation, product-use restrictions and pretreatment requirements. Governments should provide economic and educational incentives to stop the use of dangerous materials that may end up in sludge.
3. Contamination of sewage sludge by pathogens, including bacteria, viruses, fungi, single-celled and multicellular parasites, should be eliminated by appropriate treatment technologies. Passive solar and other energy efficient techniques to destroy pathogens should be used if feasible and appropriate.
4. The best available technology must be used to protect the health and safety of the public and all who work with sewage sludge. Federal, state and local governments and private wastewater management companies should invest in the development and deployment of better technologies where the best currently available are inadequate.
5. There should be ongoing monitoring of waste-treatment facilities, the transportation of products made from sludge, the landspreading of sludge, and its impact on soils, surface water, and groundwater. These records should be easily available to the public.
6. Transportation of sewage sludge should be minimized because it increases worker exposure and the risk of releases during transfer. All wastes, including wastewaters, should be managed at the point of generation or as nearby as possible to eliminate toxic contaminants.
7. Land applications of sludge should be regulated and monitored to prevent distribution and application of sludge that contains substances in concentrations or quantities that present unacceptable hazards to people and the environment. Permit fees should cover the costs of the regulatory program, including monitoring and inspections.
8. If sewage sludge products are used on food crops or pastures, the crops should not be consumed until those products have been fully tested and certified free of potential toxins and pathogens. Sludge containing dioxin should never be placed on grazing pastures. Wisconsin's soil standard for dioxins on grazing pastures is 0.5 ppt. This should be the national standard for grazing pastures.
9. Agricultural and animal products grown on fields receiving sewage sludge should be so labeled throughout the distribution chain on each food product for sale.
10. Sewage sludge should be spread only at seasonally adjusted agronomic rates for nitrogen, phosphorus and all nutrients, taking into consideration all naturally occurring nutrients and fertilizer.
11. To avoid pathogen regrowth, reduce vector attraction, and prevent contaminants from moving off site either through wind or water, sludge should be incorporated immediately upon delivery. It should not be stockpiled on site. Sludge and its constituents should not be allowed to leave property designated for spreading through flooding or other conditions. Sewage sludge should not be allowed to contaminate ground or surface water. Spreading of sewage sludge should take place only when wind is not strong enough to blow the sludge or its constituents. To decrease mobility of toxic metals in areas where there is acid soil and acid precipitation, sludge sites should be managed and monitored for pH.
12. Sewage sludge should not be disguised as compost or sanitized with misleading terms such as "biosolids". Bagged Class A sewage sludge should be clearly marked accordingly. It should be clearly labeled as to its hazards and application rates. Class A sewage sludge should never be used in home gardens.
13. Sewage sludge should not be used in areas of high public exposure, particularly in areas such as public parks and schools, where children may be exposed, or in areas of critical wildlife use.
14. Areas where sewage sludges are applied should be fenced and signed in the languages of all likely to visit or work in the area. When these areas change hands, the amounts and times of sewage sludge product application should be disclosed to the new owner.
15. Alternatives to land application of sludge should be considered, for example landfills, landfill cover, highway landscaping, and bioreactor landfills.
16. Incineration is not an acceptable process for sewage sludge management because it contaminates the air and creates toxic ash.