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San Francisco is Testing Its Sludge For Safety

by: Jill Richardson

Tue Jun 29, 2010 at 22:46:03 PM PDT


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Here's the response I received from the San Francisco Public Utilities Commission about their safety testing of their sludge compost that was given away free to San Francisco gardeners:

Thanks for your inquiry about the San Francisco Public Utilities Commission (SFPUC)'s Biosolids Compost Program. As you have mentioned on your email, the test results for the biosolids compost given away in fall 2009 posted online are the same reports that are printed and made available at each of our giveaway events. Repeated test results have shown the metal concentrations in the biosolids compost given away by the SFPUC were comparable to the compost found in a gardening store.  The testing standards and test results must meet compliance standards set through the EPA's Part 503 Rule.

The nine pollutants regulated by EPA's Part 503 Rule were selected after a 1984 Risk Assessment that included more than 200 inorganic and organic pollutants.  In order to responsibly regulate a pollutant certain information must be available in order to conduct a risk assessment. Such information includes toxicity, fate and transport (from within the biosolids matrix preferably), reasonable routes of exposure, and the dose to which the subject would be exposed. For those 200 pollutants, a hazard quotient (HQ) was calculated which is a measure for potential adverse effects to public health or the environment. Some 25 pollutants had a HQ of greater than one, which called for a full effect characterization through a comprehensive risk assessment. Fourteen pathways of exposure were evaluated with numerous conservative assumptions built in through which it was ensured that all reasonably anticipated adverse effects were captured. Ten pollutants were determined to be necessary to regulate (later reduced to nine in 2001).

The SFPUC is currently undertaking a comprehensive test of our biosolids compost, including heavy metals and pollutants of concern. In an effort to be completely transparent, these tests go above and beyond any current regulatory requirements for either biosolids compost or what is readily available as soil amendment from commercial gardening stores.

Our test results will be available to the public as soon as they are completed.  I hope this information helps you in the meantime.  Please feel free to contact me if you have any questions or need additional information.

I'd like to call out a gaping flaw that appears in the EPA's method of determining what to regulate in sludge as it is described here. There are literally tens of thousands of chemicals that can show up in sludge. Testing a mere 200 of them can hardly guarantee the safety of sludge. And the proof for that is in the pudding - when Andy McElmurray applied sewage sludge from Augusta, GA on his fields where he grew crops to feed his cows, the cows died. McElmurray went out of business. And milk was sold in the supermarket with high levels of thallium - a rat poison - in them. Thallium is NOT one of the chemicals that the EPA deemed hazardous enough to regulate. And it's not even a common chemical found in sludge, to the best of my knowledge. But that doesn't mean that it's never found in sludge or that the regulations keep us safe from it.

On another note, I'm encouraged that SFPUC promises to make its results fully available to the public once they are complete. However, it's been MONTHS since they supposedly initiated this testing. How long does it take? And what are they doing that requires so long? Shopping around for a lab that gives them the results they want? Sending back positive results for re-testing until they come back negative? Or, on the other hand, are they really doing the world's most complete testing of their sludge compost to ensure that it's 100% safe for applications in gardens where food is produced? I hope it's the latter.

Jill Richardson :: San Francisco is Testing Its Sludge For Safety
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sewage sludge hearing (4.00 / 1)
The link in the essay goes to a previous diary that does not contain any links, but refers to a 2008 hearing about sewage sludge held by the House Committee on Environment and Public Works. There is no such committee now, and there was no such committee in 2008. I can't find a hearing about sewage sludge by any House committee in 2008 or any recent year.

There is a Senate Committee on Environment and Public Works. Did that committee have a 2008 hearing about sewage sludge? I checked a couple of 2008 hearings, but didn't find one with McElmurray testimony. Searching the committee site for sewage sludge does not return any appropriate responses, ditto for McElmurray. The committee calendar for 2008 doesn't show that any such hearing was scheduled or held.

I did find an online document that purports to be a submission to the Senate Committee on Environment and Public Works, and which appears to be the source of quotes in the previous diary.

TESTIMONY OF ROBERT A. (ANDY) MCELMURRAY, III

Briefing on
"Oversight on the State of Science and Potential Issues Associated with EPA's Sewage Sludge Program"
September 11, 2008

Chairman Boxer, Ranking Member Inhofe and Honorable Members of the Committee, thank you for the privilege of testifying today about the destruction of our dairy farm business by hazardous wastes in sewage sludge, which was landapplied by the City of Augusta, Georgia.

Cattle Deaths, Milk Contamination

The document claims to represent testimony to a "briefing", whatever that is, not a hearing. I wonder if the Senate Committee on Environment and Public Works knows anything about it. The document does not seem to exist on the Committee's website.

This comment would have appeared in the previous diary if I had done the research at that time. The previous diary probably should be updated to include a link to the above document, if it is the quoted source, and edited to read "Senate Committee" instead of "House Committee".


gaping flaw (4.00 / 1)
I don't know any of the details about Reagan's 1984 Risk Assessment whing-ding, but any risk assessment that decides not to regulate anything but metals and fecal coliform seems more than a little strange. Perhaps the panel noticed that PCBs, brominated flame retardants, and many other toxic chemicals are so ubiquitous that few sewage sludges could pass. Remember, the goal was to develop regulations that sewage sludge could pass, not to guarantee that the sludge was safe.

The use of sewage compost in home gardens is a legitimate concern, as is contamination of the food chain, but only about one percent of SF PUC sewage sludge is composted. That other 99% is applied to ag land without the dilution of composting, and it not only contaminates the food chain, it contributes to air pollution and water pollution. Air and water pollution are problems that would bedevil us even if the sludge were only applied to non-food lands.


An interesting twist on Regans famous quote about the 9 scariest words in the english language (4.00 / 1)
I'm from the government and I'm here to help. A lot of people think the government is here to help, but in truth, the government is no different than any other large group of people. It can be, and often is, just as corrupt as the biggest transnational corporation. I have an idea that all of the slight of hand as far as testing of sludge is so that cities won't have to deal with the toxic products of their residents, both business residents and private citizen residents. They're no different than a big feed lot or pig CAFO in dealing with their wastes, and they'll pull just as many strings to get out of compliance with environmental laws, skate on fines, etc.

I only have to look at my own home town of Portland, Oregon. Beautiful 'green' gem on the Willamette and Columbia rivers, champion of the environment and sustainability. Which, by the way, just happened to spill so much raw sewage in the river due to our little rain event the other day, that boaters and others are advised to stay out of the river for a couple of days untill the shit litterally clears out of that part of the river. All because Portland grew and grew and grew over the past 100 years, and didn't bother to install sufficient rainwater handling infrastructure so that when it rains, the sewers would not over flow directly into the river. Portland city has been dumping raw sewage and what ever other contaminants there are in that sewage into the Willamette river for as long as I've been alive and I'm just about 48 years old. And it's not just industry that contaminates the sewage, the private citizens dump all sorts of chemicals, drugs, etc. down the drain as well.

Portland's building the 'big pipe' project to deal with this, finally, except the mayor of that great city has seen fit to steal $2 million from it to encourage bycicle riding. Hell of a set of priorities.

One of the biggest environmental problems with cities is the waste from them. From what I see, they're no better than any CAFO or industrial manufacturer at dealing with the problem. Whether they turn the sludge into 'biosolids compost' for the garden, sell huge quantities for farms to apply to their fields, or ship it to the current landfill, all they're doing is shoving their toxic problems onto someone else so that they can either hide the contaminants or it'll be someone else's problem. This is one reason why I'm not a real big fan of cities. They have always had this probems and they probably always will.

Normal people scare me.... But not as much as I scare them.


[ Parent ]
EPA Risk Assessment (4.00 / 3)
We expect that EPA is required to tell the truth. What we find is that EPA will lie about what it actually does. In 1995, EPA wrote a convincing book on the science behind
the part 503 risk assessment. Yet, on page 110, EPA stated it didn't use any science or consider all of the chemicals. EPA's John Walker and USDA's Rufus Chaney
appear to be the main source of this non-science.

According to EPA,the sludge health risk assessment was only based on looking at 13 organic chemicals which were either already banned, no longer manufactured or
restricted for use. These were dropped from consideration in the rule.

However, EPA ignored a large list of chemicals known to cause death, cancer and other bodily harm through the air, water and food chain.

EPA has admitted (1989) there are at least twenty-one carcinogens (cancer causing agents) in sludge which were removed  from the final 503. (FR 54,p. 5777). http://deadlydeceit.com/1989_5...

In spite of its own research, EPA said it did not consider any of the cancer causing hazardous metals in sludge to be cancer causing agents for the risk assessment.

Chapter 6
(PDF file, 1143K) Questions and Answers on the Part 503 Risk Assessments
http://www.epa.gov/owm/mtb/bio...


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