Subject: RE: Revised PRECAUTIONARY ACTION SHOULD BE
MANDATORY
Date: 1/14/2008 6:09:22 P.M. Pacific Standard Time
From: PDavis@owasa.org
Reply To:
To: BynJam@aol.com
CC: ploar@arlingtonva.us
Dear Mr. Bynum,
Thank you very much for your email and inquiry, and for
providing the link to the website. Please note that as your web
information states, it was Walter Gottschalk – not me – that
actually provided your group the tour of the OWASA’s Mason
Farm Wastewater Treatment Plant. I happened to be at the
plant at the end of your tour and simply answered a few
questions that you, Ms. Holt, and Ms. Reilly asked, primarily
about OWASA’s plans for the use of reclaimed water.
I have quickly reviewed the website information, and certainly
have extensive initial comments. I have forwarded the link to
others here, and am sure that they would have comments, as
well. I am not sure if, when, and in what form, our reply may take.
As an example of one of the many issues I have with the
information you posted, it implies that the health problems Ms.
Holt and others claim have occurred from OWASA’s biosolids
application; however, it is my understanding that is not the case.
Another example is that you failed to mention that since there
are no other facilities in our county that accept septage for
treatment, we accept more than 1 million gallons of septage a
year that is pumped out of the septic tanks from people like Ms.
Holt. Should we stop that practice, thereby increasing the risk of
septic tank failures, illegal septage dumping, groundwater
contamination, and other problems?
Another example is that you made no reference to the
microbiological study of the planned reclaimed water system that
Dr. Mark Sobsey – a leading environmental microbiologist –
completed for the project. If we have a leading scientist that
does research into the project and concludes that the health risk
is extremely low, what do you suggest we do?
I could go on with more.
Although my first read of your information leads me to believe
you think otherwise, we here at OWASA are not “the enemy.”
We are trying to help protect human health and the
environment, and constantly face the real-world constraints of
technology, funding, etc. Unfortunately, based on my very quick
initial read of your website, I saw a lot of negative comments but
did not see any constructive suggestions and potential solutions
for how to practically deal with the issues you have raised. I do
not think many utilities will be able to ban society’s production,
use, and personal disposal methods of endocrine disrupting
compounds, pharmaceuticals, household cleaners, hazardous
materials, etc.
I apologize if on my first pass-through I missed your constructive
suggestions for addressing these challenges.
Thanks again for sharing this with me.
- Pat
Patrick Davis
Utility Manager Generalist
Orange Water and Sewer Authority
P.O. Box 366
Carrboro, NC 27510-0366
Telephone: 919-537-4210
Facsimile: 919-968-4464
www.owasa.org
Feed back from Phil Loar -- Arlington, Va.
Subject: Re: Revised PRECAUTIONARY ACTION SHOULD BE
MANDATORY
Date: 1/15/2008 2:51:09 P.M. Pacific Standard Time
From: BynJam
Reply To:
To: PDavis@owasa.org
Dear Mr. Davis.
I appreciate the feed back. As the manager of the OWASA's Mason
Farm Wastewater Treatment Plant I assumed you approved tours
and acted accordingly. I was impressed by your operation and the
people I met.
I appreciate the fact that you passed the website links to others for
their comments. I do want to be as accurate as possible since we
are dealing with such a complex issue.
Since I was discussing sludge/biosolids in general, I try not to imply
anything concerning health effects from sewage sludge or reclaimed
water as they pertain to Ms. Holt are anyone else. I like to work from
published documents. In fact I noted that the OWASA sewage sludge
was sent out for composting,
Mr. Davis, I understand that EPA, WEF and the state have placed
wastewater treatment managers (and scientists) between a rock
and a hard place -- then given you an easy way out to dispose of
sludge and polluted sewage effluent with little oversight and a
screwed up test. Generally I don't like talking about individuals in a
negative way. I am aware of Dr. Sobsey's work. He has averaged 21
published studies a year for the past five years. Indirectly, I did refer
to the microbiological study by Dr. Mark Sobsey when I wrote, "In
spite of the first hand knowledge as well as the studies showing
deadly bacteria survive the treatment process," Since 1988,
scientific studies concerning sewage effluents have focused on
reuse, not protection of public health and the environment, with
enough limitations included in the studies to cover the scientist's
ass. This puts your's on the line.
At EPA, on November 6, 2001, "Dr. Sobsey detailed water uses
including domestic and industrial wastewater reuse, cooling tower
waters, ballast/boat discharges, and biosolids. He also described
special water use in hospitals, home water treatment units, potable
water treatment units, hot tubs and swimming pools. Current
problems with these uses include no uniform EPA standards, no
risk-based microbial standards, standard variability among states,
little or no guidance provided to local governments for standard
setting, and little or inconsistent monitoring and enforcement
policies. Other special considerations discussed with respect to the
traditional fecal indicators were fecal coliforms that will regrow in
sewage discharges, pulp mill wastes, gray water, sediments,
biosolids, and compost."
As you noted in your own documents, "With proper treatment and
safeguards, the use of reclaimed water in accord with applicable
standards not a threat to public health. The U.S. Environmental
Protection Agency has concluded that “properly implemented non-
potable reuse does not entail significant health risks…” (EPA; 1992)"
Sixteen years later, there is still no EPA standards, no risk based
microbial standards, little or no guidance to local government and
little or no monitoring and enforcement policies. We still have the
fecal coliform regrowth problem in sewage discharges, pulp mill
waste, gray water, sediments, sludge/biosolids and compost..
It was not my intent to given the impression employees of OWASA
were the enemy. You have to work within the parameters set up by
people at the federal and state level who have no idea what a fecal
coliform is or the damage thermotolerant bacteria can do to public
health. Unfortunately, there are people at EPA and WEF who do
know testing for thermotolerant bacteria offer no protection for public
health and the environment without regard for your intent, yet EPA
and WEF have spent several fortunes on public relations programs
to convince people like you and this old country boy that the closer
you can get pollutants to the public the safer we are.
You are the expert, yet you wonder why I didn't offer any constructive
suggestions and potential solutions for how to practically deal with
the issues I raised. Actually, I did offer a suggestion and solution to
the sludge issue, "By federal law (RCRA), biosolids is simply
sewage sludge which must be disposed of in a sanitary landfill."
But, you need a permit for disposal in a Part 258 co-disposal landfill
and the state is required to do a risk assessment for the landfill. An
impossible task for individual states and probably for EPA, especially
since EPA admitted in 1995 it did not attempt to do a risk
assessment for heavy metals and chemicals in sludge or for
pathogens. Then of course the leachate from the landfill would be
sent back to your wastewater treatment plant where it could cause
serious problems as noted by Dr. Sobsey in 1979, "It is possible
that the leachate actually contained higher coiform levels but
leachate toxicity either prevented their growth or caused them to die
off. Both toxicity and die-off of coliforms due to leachates have been
reported previously.'-3 If the coliform die-off rate was faster than that
for enteric viruses, then the initial concentration differential between
them could be reduced. Such conditions have been reported for both
natural waters and treated sewage effluents." And that was just the
tip of the iceberg.
I agree that utilities will not be able to ban societies production, use,
and personal disposal methods of endocrine disrupting
compounds, pharmaceuticals, household cleaners, hazardous
materials, etc., However, spreading this compounds and pathogens
on our food crops, grazing lands, parks, school grounds and home
lawns as well as letting them get into the drinking water based on a
policy that EPA's Office of Compliance and Enforcement refuses to
get involved in, is a dereliction of public duty.
I do empathize with your position. I think we both realize that this is a
developing political issue because of the pandemics that have been
getting worse over the past 18 years.
http://thewatchers.us/1_index-pandemics.html
Thanks for the feed back. I hope I have addressed your concerns.
Jim Bynum