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#560 - A New U.S. Waste Strategy Emerges, Part 1, 20-Aug-1997

A new strategy for disposal of hazardous materials is emerging in the
U.S. After years of unsuccessful efforts to gain public acceptance of
waste disposal in the oceans, in landfills, and in incinerators,
frustrated environmental officials at the federal and state levels now
advocate spreading hazardous materials onto and into the land,
essentially dispersing dangerous toxins into the environment, leaving
no fingerprints.

Typical projects include these:

** For several years, New Jersey Department of Environmental Protection
(DEP) has been using monies earmarked for "recycling" to run
experiments placing toxic incinerator ash in road beds. In June of
1996, the research entered the real world when toxic ash from the
Warren County, N.J., municipal trash incinerator was mixed with asphalt
and spread onto the streets of Elizabeth, N.J., a major city. The "ash
recycling" operation took place in the dead of night, but local
activists managed to videotape it.[1] New Jersey DEP officials defended
the operation, saying it was completely safe and exempt from all state
and federal waste management laws because it was termed "recycling."[2]

** The phosphate fertilizer industry is lobbying U.S. Environmental
Protection Agency (EPA) for permission to spread radioactively-
contaminated phosphogypsum onto roadbeds, or to use it as a fertilizer.
Phosphogypsum is a waste product of phosphate mining, principally in
Florida. By the year 2000, some 870 million cubic meters (30.7 billion
cubic feet) of radioactive phosphogypsum waste will be piled up,
awaiting disposition. Phosphogypsum contains 30 picoCuries of radium
per gram. Radium has a half-life of 1600 years. The phosphate
fertilizer industry proposes to hide this radioactive material beneath
roadways. The amount of phosphogypsum available in the year 2000 would
require 1.3 million kilometers (807,000 miles) of highway --about one-
fifth of all the roadways under state and federal control in the U.S.
Radioactive waste consultant Marvin Resnikoff says such a program would
be a "major public health disaster" because it could cause thousands of
cancers among unsuspecting citizens.[3]

** U.S. EPA is actively promoting the "beneficial use" of sewage sludge
contaminated with industrial toxins. "Beneficial use" includes
ploughing contaminated sludge into soil as fertilizer for crops
intended for animal feed and for human food. Many such projects are
under way across the country, to the dismay of local citizens concerned
about the accumulation of toxic materials in the nation's agricultural

In 1990, EPA wrote, "The Agency will continue to enthusiastically
promote and encourage the recovery and reuse of sludge wherever its
safe environmental use is possible."[4,pgs.47254-47255] To assure the
public that almost any sewage sludge poured on crops is "safe," EPA has
made exceptionally creative use of risk assessment.

Sewage sludge is the mud-like material that remains after bacteria have
digested the human wastes that flow from your toilet into your local
sewage treatment plant. If human wastes were the only thing entering
the sewage treatment plant, then sewage sludge would contain only
nutrients and should undoubtedly be returned to the land.

Unfortunately, most sewage treatment plants receive industrial toxic
wastes, which are then mixed with the human wastes, creating a
pernicious mixture of nutrients and industrial poisons. Furthermore,
many American cities have sewage systems that mix storm water runoff
with the regular sewage; every time a rain storm scours these cities'
streets, additional toxins are added to the sewage sludge.

U.S. industry currently uses roughly 70,000 different chemicals. Any of
these may be found in sewage sludge, depending upon what chemicals
local industries and households are using. In 1988, EPA sampled sludge
from 180 sewage treatment plants, but they only looked for 409
chemicals, without sampling for the roughly 69,600 others that they
might have looked for. The "detection limits" for many organic
chemicals were set so high that few were detected even though many were
doubtless present.[5] Of the original 409, EPA narrowed the list to
only 28, which were labeled "of concern," ignoring the other 381. From
that list of 28, EPA then picked 10 metals that they would regulate:
arsenic, cadmium, chromium, copper, lead, mercury, molybdenum, nickel,
selenium, and zinc.

Sewage sludge regulations --known as the Clean Water Act Part 503
regulations --were published in the FEDERAL REGISTER February 19, 1993.
[6] The regulations were based on a "comprehensive"[4,pg.47252] risk
assessment of a "highly exposed individual."[4,pg.47249] In other
words, EPA asked how much of each of the 10 pollutants a highly-exposed
individual would be exposed to in various scenarios. If their risk
assessment showed that this individual would not be harmed by a
particular level of pollutants, EPA declared that level safe.

There are several serious flaws in such a procedure. First, no risk
assessment is ever "comprehensive" (especially not one based on only 10
out of 70,000 possible chemicals) and to label it such is misleading.
Tomorrow's science will very likely prove today's science wrong, so no
risk assessment is ever "comprehensive." Secondly, EPA assumed that the
"highly exposed individual" did not have any other exposures to toxins
besides the exposures created by the sewage sludge. Clearly, this is a
false assumption because each of us is exposed to tobacco smoke,
automobile exhaust, pharmaceutical preparations, pesticides, and a host
of other pollutants in our daily air, water, and food.

Third, and most importantly, concern for the "highly exposed
individual" omits the major category of dangers inherent in "beneficial
use" of sewage sludge: the slow but steady buildup of toxins in soils
and in food-chains that begin in the soils (such as earthworms or
insects to birds).[7] As Robert Goodland of the World Bank and waste
consultant Abby Rockefeller have recently written, "Land application
[of sludge] was implemented in Sweden in the early 1980s with
disastrous results, which to date the U.S. EPA seems to be ignoring.
Such a practice must lead to accumulation in living tissues of heavy
metals and persistent organic chemicals: first they accumulate in the
soil, then in decomposer microbes and soil-conditioning invertebrates.
Other life forms are damaged as thousands of non-biocompatible
substances move up the food chain. The toxic effect on crops, as well
as on the consumers of such crops, is buying risks for the future."[8]
It has been shown, for example, that sewage sludge applied to soils can
increase the dioxin intake of humans eating beef (or cow's milk)
produced from those soils.[9]

The fundamental problem with sewage sludge is that its four main
categories of potential pollutants --nutrients, pathogens, toxic
organics, and heavy metals --behave differently and cannot all be
managed by any single kind of treatment.[8] The goal of "safe
management" of such a complex toxic mixture simply cannot be met at any
reasonable cost. Ploughing it into cropland doesn't change that fact.

** In Pennsylvania, state environmental officials are promoting the
"beneficial use" of coal ash and incinerator ash as a soil amendment,
to rehabilitate coal mines and strip-mined lands.[10] A private firm,
Beneficial Ash Management, in Morrisdale, Pa., reportedly supplies the
ash, which it gets from "power plants, mid-sized industries, and paper
manufacturers." Professor Barry Sheetz of Pennsylvania State
University, funded by U.S. EPA, is providing the engineering know-how
to harden the toxic ash into a cement-like material, which is then
placed in mines and onto strip-mined land. The cement-like material is
then covered with "synthetic soil" and left. Professor Sheetz says he
hopes this provides a permanent solution to the problem of acid mine
drainage. More likely, it promises to provide a cheap, permanent
solution for toxic wastes generated by coal-burning power plants and
incinerators as far flung as the American Ref-Fuel incinerator in Essex
County, N.J.; International Paper Company's plants in Erie, and Lock
Haven, Pa.; and the Tobyhanna (Pa.) Army Depot, saving each of these
facilities large sums of money that would otherwise be spent on toxic
waste disposal, and absolving them of liability because their wastes
will never again be identifiable or traceable.

** In Washington state, the SEATTLE TIMES recently published a series
titled "Fear in the Fields," which documented the disposal, nationwide,
of industrial wastes on farmers' fields as "fertilizer." The TIMES
reported, "Manufacturing industries are disposing of hazardous wastes
by turning them into fertilizer to spread around farms. And they're
doing it legally...."

The TIMES gave this typical example:

"A dark powder from two Oregon steel mills is poured from rail cars
into the top of silos attached to Bay Zinc Co. under a federal permit
to store hazardous waste. "The powder, a toxic by-product of the steel
making process is taken out of the bottom of the silos as a raw
material for fertilizer.

"'When it goes into our silo, it's a hazardous waste,' said Bay Zinc
President Dick Camp. 'When it comes out of the silo, it's no longer
regulated. The exact same material. Don't ask me why. That's the wisdom
of the EPA.'"[11]

--Peter Montague (National Writers Union, UAW Local 1981/AFL-CIO)


[1] Sandy Lovell, "Environmentalists fume as incinerator ash pavers
strike in the dead of night," NEWARK STAR-LEDGER June 21, 1996, pg. 39.

[2] Maryann Spoto, "Judge delays ruling on paving Elizabeth roads with
incinerator ash," NEWARK STAR-LEDGER June 15, 1996, pg. 13.

[3] Garry Lenton, "Runoff from old coal mines pollutes state's streams;
2 PSU [Pennsylvania State University] Professors create remedy to help
separate rainwater, shafts," HARRISBURG PATRIOT April 21, 1997, pg. A3.
[4] Environmental Protection Agency, "40 CFR Part 503; National Sewage
Sludge Survey; Availability of Information and Data, and Anticipated
Impacts on Proposed Regulations; Proposed Rule," FEDERAL REGISTER
November 9, 1990, pgs. 47210-47283.

[5] R.D. Kuchenrither and S.I. McMillan, "Preview Analysis of National
Sludge Survey," BIOCYCLE (July 1990), pgs. 60-62.

[6] The "Part 503" sewage sludge regulations are available on diskette
from the National Technical Information Service [NTIS]; telephone 1-
800-553-6847; purchase item No. PB93-500478INC; price: $60.00.

[7] See, for example, J.G. Babish and others, ORGANIC TOXICANTS AND
Report No. 42] (Ithaca, N.Y.: Cornell University, 1981). And see Thomas
S. Davis and others, "Uptake of Polychlorobiphenyls Present in Trace
Amounts from Dried Municipal Sewage Sludge Through an Old Field
27 (1981), pgs. 689-694.

[8] Robert Goodland and Abby Rockefeller, "What is Environmental
Sustainability in Sanitation?" IETC'S INSIGHT [newsletter of the United
Nations Environment Programme, International Environmental Technology
Centre] Summer, 1996), pgs. 5-8. The International Environmental
Technology Centre can be reached at: UNEP-IETC, 2-1110 Ryokuchikoen,
Tsurumi-ku, Osaka 538, Japan. Telephone: (81-6) 915-4580; fax: (81-6)
915-0304; E-mail: cstrohma@unep.or.jp; URL: http://www.unep.or.jp/.

[9] Simon R. Wild and others, "The Influence of Sewage Sludge
Applications to Agricultural Land on Human Exposure to Polychlorinated
Dibenzo-P-dioxins (PCDDs) and -Furans (PCDFs)," ENVIRONMENTAL POLLUTION
Vol. 83 (1994), pgs. 357-369. And see: Michael S. McLachlan and others,
"A Study of the Influence of Sewage Sludge Fertilization on the
Concentrations of PCDD/F and PCB in Soil and Milk," ENVIRONMENTAL
POLLUTION Vol. 85 (1994), pgs. 337-343.

[10] Personal communication with Marvin Resnikoff, Radioactive Waste
Management Associates, New York, New York; phone: (212) 620-0526.

[11] Duff Wilson, "Fear in the fields; how hazardous waste becomes
fertilizer," SEATTLE TIMES July 3, 1997, pgs. A1, A10.

Descriptor terms: hazardous waste disposal; land farming; agriculture;
dioxin; epa; regulation; sewage sludge; phosphate; phosphogypsum; strip
mine reclamation; acid mine drainage; pa; nj; or; wa; msw;
incineration; incinerator ash; part 503 regulations; clean water act;
beneficial use; beneficial ash management, inc.; barry sheetz;
fertilizer; biosolids;