Thursday, August 13, 2009

More thoughts on biosolids

Why all the mystery?

Thanks to the persistence of concerned citizens, a public hearing about an application to apply biosolids to farmland in Goochland was held on August 3.

It was just that, a public hearing. Officials from the state water control board listened to comment on the application of filed by Nutriblend to land apply biosolids. A final decision on whether the application to apply biosolids on 1466 acres in Goochland will be made in October. The complete application is on the county website and there is a hard copy behind the circulation desk in the Goochland library.

It’s not too late to add your thoughts in writing. They can be sent before August 21 via email to anita.tuttle@deq.virginia.gov; by fax to 804.527.5106 or by snail mail to Anita Tuttle, DEQ-Piedmont Regional Office, 4949-A Cox Road, Glen Allen, VA 23060. Reference Nutriblend draft permit VPA 00806. Written comments must include the names, mailing addresses and telephone numbers of the person commenting and all other people represented by that communication and a brief informal statement about how the proposal affects the person commenting.


Before the hearing, a panel of representatives from several state agencies entertained questions.

Their answers tended to offer little comfort to those concerned about the practice of using the processed residue from municipal sewage plants as fertilizer for farms and forested land.

Most of the people in the room seemed to be from western Goochland. Their homes are served by private water supplies including bored or drilled wells and springs. Of obvious concern was the fouling of surface and ground water by sludge applications.

Notably absent were those who live in eastern Goochland served by public water provided by the Henrico county water treatment plant. All of their water comes from the James River. Whatever goes into the James upstream from the plant at the corner of Gaskins and Three Chopt Roads, winds up in the water at some point.

One of the agencies distributed copies of the December 2008 final report of “the panel of experts convened by the Secretary of Natural Resources and The Secretary of Health and Human Resources to study the impact of land application of biosolids on human health and the environment pursuant to HJR 604(2007) to the Governor and General Assembly of Virginia.”

It’s quite a document that includes a lot of technical detail. It also outlines the need for further studies. In addition to possible bacteria and viruses that may remain in biosolids after treatment, other substances like heavy metals; pharmaceuticals; residue of personal care products and a host of miscellaneous chemicals could be included in the mix.

The report uses a lot of weasel words because no one really knows what is in every bit o biosolids. They come from many places and not every bit of biosolids is subject to testing to determine its components.

Testing to determine the exact contents of specific loads of biosolids is not regulated. Origination facilities may analyze their output at certain intervals, but rarely test every bit of output.

It’s also hard to say where the biosolids that will be put on any given field originate. According to a report filed with the county’s sludge czar, Hugh Hardwicke and available on the county’s website, the sludge can come from a host of places on the east coast including the United States Naval Academy and Bergen County, New Jersey.

A November 2007 report on the “Health Effects of Biosolids to Land: Available Scientific Evidence” prepared by state epidemiologists was also distributed at the hearing. This report discusses the various pathogens and contaminant that might be incorporated into biosolids.

It concludes: “The body of epidemiologic literature on the adverse health effects of biosolids is small.”


Studies performed on people claiming to have suffered ill health as a result of exposure to biosolids were inconclusive, said the state epidemiologists:

“Human health allegations associated with biosolids usually lack evidence of biological absorption, medically determined health effects and/or do not meet the biological plausibility test. On the other hand, no concerted effort has been made to collect and analyze data on related health effects resulting from biosolids applied to land.”

The report urges that complaints of biosolids related health effects should be investigated and that federal and state standards for monitoring the land application of biosolids should be observed.

Both reports observed that more detailed information about the long term effects of biosolids application are needed, but, given the dire economics facing the state budget, they will be pipe dreams for the foreseeable future.


So where does this leave Goochland?

For one thing, the location and schedule of applications should be easily available. The report about locations says that it will be spread on numbered fields between October 2009 and October 2010. The field numbers may have meaning to the biosolids folk and landowners, but do not describe their location to those without the magic decoder ring.

There is no reason that the location of the application cannot be plotted used the county’s geographic information system (GIS) and be located with the nearest street address.

The GIS system could also be used to prepare a list of neighboring property owners, who should receive a rough schedule of applications.

One of the state agency representatives at the question and answer session stated flatly that there is no legal requirement for the neighboring property owners to be notified prior to land application of biosolids. Why not just do it because it’s the right thing to do?

Adding a notation to the deed of land that had been the recipient of biosolids application would ensure that future owners of that property know exactly what they are getting.

That might take action at the state level. Biosolids are undoubtedly big business with deep pockets able to afford the best lobbyists.

Biosolids are not going away any time soon.

Careful monitoring of applications is about as good as it’s going to get. If the current county ordinance regulating land application of biosolids is not being observed, that must change.

The county has a moral obligation to monitor biosolids applications regardless of whose land it’s spread on.

We all live downstream from someone.

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