Chehalis River Council
October 10, 2002
Ethelwyn Hoffman
Southwest Region, Biosolids Coordinator
PO Box 47775
Olympia, WA
Dear Ms. Hoffman
Following is the official comment letter of the Chehalis River Council on the Fire Mountain Farms biosolids permit.
Thanks for the opportunity to comment. I am looking forward to sharing information with you on this subject in the future, as well.
Introduction
The Chehalis River Council is a grass-roots, all-volunteer environmental organization dedicated to the preservation and conservation of natural resources in the greater Chehalis River Basin. We have a particular interest in the potential effects of biosolids applications on water quality and the health of watersheds, but also will comment on more general public health issues.
Existing Watershed Challenges
The Chehalis Basin and the various watersheds composing it are subject to summer droughts and winter floods that happen almost every year. During low flow periods in summer and early fall, streams are susceptible to high temperatures and low dissolved oxygen to a degree that can kill fish and impair the integrity of the web of life in the river. In late fall, winter, and extending into spring, heavy rainfall causes the ground to become saturated, and runoff of the surplus waters causes flooding. This flooding carries any contaminants that may be lying on the surface into streams, polluting them.
Potential Impact of Biosolids Application on Water Quality
There are potentially favorable impacts on the watershed of biosolids applications. One beneficial effect may be to increase water retention of soils, thereby attenuating the annual cycle of flood and drought and mitigating the low stream flow crisis that tends to occur each summer. Another favorable impact may be to encourage growth of vegetation in riparian areas, shading waterways and the soil near streams and helping to keep water temperatures lower than they otherwise might be.
Unfortunately, several types of negative impact may occur from biosolids applications, particularly if the amount applied exceeds the "agronomic rate," which is the rate at which the nutrients in the biosolids can be used by the plants it is supposed to feed. As with any fertilizer, applications beyond the agronomic rate will leave excess nutrients in the soil. These nutrients may be carried into streams or percolate into the ground water whenever heavy rain or irrigation takes place. In streams, these nutrients feed algae and bacteria that contribute to the low dissolved oxygen situation that is common in the basin. This may happen with the first heavy rains in the fall. It may also occur in the spring, when heavy rainfall occurs while it still is too cool for plants to be making good use of the nutrients.
When added to other non-point sources of pollution, such as different types of agricultural fertilizer applications and failing septic systems, over-use of biosolids may cause an already bad situation to be even worse. Even a small marginal increase in nutrients may precipitate a crisis.
Farmers do not ordinarily apply fertilizer beyond the agronomic rate. That would be a simple waste, economically speaking. In the case of biosolids, however, the economics of the situation may provide an incentive to apply more of the material to the land than is beneficial. How can we be sure this is not happening?
We doubt that a ten-meter buffer is adequate to protect streams, ditches and wetlands from undesirable contamination. A committee of the National Research Council (NRC) has recommended that the Environmental Protection Agency (EPA) review its Part 503 rule on this subject. At least 21 states have increased their minimum setback requirements to 50 to 300 feet. What basis exists for the ten-meter buffer rule?
Public Health Considerations
The class B biosolids do contain a great variety of pathogenic organisms, including coliform bacteria. These bacteria present a risk of illness to persons with occupational exposures. Environmental Protection Agency regulations (40 CFR Part 503) prescribe a restricted period of up to one year to limit public access to lands where Class B biosolids have been applied. If these pathogens are washed into streams, they may present a health hazard to downstream residents and wildlife and contribute to high coliform counts in the lower Chehalis basin and a resulting negative impact on shellfish culture and harvesting.
The conditions of this permit require that the waste be of exceptional quality, which means that the generators of the waste must certify that it not contain more that a certain level of several heavy metals. That is an excellent provision. There is a possibility, however, that the biosolids may contain any of a number of chemicals and biologically active substances that may present health challenges to persons with chemical sensitivities, allergies, or compromised immune systems. According to the NRC, "...it is fairly clear that chemical contamination of sewage with industrial chemicals can result in product contamination leading to exposure of workers and community residents. It is unclear whether the system for preventing chemical contamination of sewage and monitoring sewage is sufficient to ensureprotection for chemical exposures."
Are the regulatory agencies and the applicator aware of this fact, and taking appropriate measures?
Worker Safety
In a recent publication, the Centers for Disease Control and Prevention has issued rather strong recommendations about protecting safety of workers who apply class B biosolids, These include providing goggles, splash-proof face shields, respirators, liquid-repellent coveralls, and gloves. Do DOE and the Lewis County Health Department plan to require such worker safety provisions as part of the permit? Will people who are harvesting hay in fields where sludge is not tilled in be warned about the risks, if less than a year has elapsed since application?
Specific Concerns with Fire Mountain Farms Biosolids Applications
Application Methods
There seems to be broad consensus that risks from pathogens are less if biosolids are either injected or tilled into the soil. The application does indicate some movement in this direction by Fire Mountain Farms. We request that DOE require Fire Mountain to inject or till in the sludge or provide a reasonable explanation why this is not done in each specific case. This would diminish the smell problem so burdensome to neighbors, the amount of windborne dry biosolids and potential runoff. We also suggest that lime be applied with the biosolids, to maintain a soil pH closer to 7 or greater, which would help stop heavy metals from migrating, as well as helping whatever crop is grown get the best use out of the nutrients.
Enforcement
In the public meeting held Sept 19, 2002 and in private conversations we have heard many allegations that Fire Mountain Farms has not adhered to the permit under which it has been operating for the past several years. It has been said that biosolids have been spilled into roads and ditches, have migrated onto adjoining property, and have been allowed to be carried as wind-borne dust onto neighboring land and public roads. We have been told that applications far beyond the agronomic rate have been applied to specific properties. How can we be assured that Fire Mountain Farms will rigorously adhere to the conditions of this permit, and that vigorous enforcement action will be taken by the Department of Ecology (DOE) and the Lewis County Health Department (with their slender resources) if these conditions are violated?
Monitoring
The permit requires monitoring in the form of sampling of water and soil. We have some doubt as to whether the number, location, and timing of samples is adequate, but are not in a position to assess details of the plan. What is missing, however, is analysis and reporting of this monitoring to the general public in a form that a generally educated reader can understand and interpret. How can the public obtain timely information about potential hazards from biosolids applications and ongoing assurance that, when biosolids are applied, it is done in the safest possible manner?
Summary
We recognize the problems posed by need to dispose of products generated by sewage treatment under today's technology, and that "beneficial use" of biosolids as fertilizer may be preferable to other available options, such as ocean dumping, incineration or disposal in landfills. We hope that biosolids may be applied in Lewis County in such a manner as to enhance, rather than degrade, the environment and present no hazard to public health. We would prefer that this always take place far from human habitation and completely away from watercourses, but realize that this would not be practicable.
We insist, however, that conditions of the permit be rigorously adhered to, and that prompt enforcement action be taken whenever the conditions are violated. We want biosolids to be injected or tilled into the soil whenever possible. We also would like to have results of environmental monitoring be analyzed and reported to the general public on an ongoing basis.
Again, the Chehalis River Council thanks you for the opportunity to comment.
Sincerely,
Paul T. Holm, Board Member
for the Chehalis River Council
Copies:
Lewis County Health Department
CRC Board
Brian Mittge, The Chronicle
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