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Statement of Layne Baroldi, Synagro’s director of regulatory affairs and
technical services, in response to questions on the company’s operations in north-west Alabama:
Thank you for the opportunity to respond to questions about our business. As you may know, Synagro is a nationwide recycling and residuals management company providing services for managing organic residuals that are the byproduct of municipal wastewater treatment facilities. Biosolids are the treated organic residuals that are rich in plant nutrients and can be safely recycled and land applied to benefit agriculture and horticulture. Biosolids provide primary and secondary nutrients for plants and bulk organic matter that improves soil tilth and quality, properties that cannot be duplicated by commercial fertilizers. Thousands of American cities and towns have recycled biosolids to farmland for many decades, providing a valuable fertilizer and soil conditioner that have particularly benefited small farms and pastures throughout the country, including in Franklin County, Alabama. Over half of America’s sewage sludge is recycled to the land as biosolids. Without land application, cities and towns would have to turn to landfilling and incinerating biosolids, expensive alternatives with no environmental benefits. The EPA, state environmental agencies, and researchers at major universities have long endorsed and encouraged the land application of biosolids as a safe alternative in residuals management.1 EPA first regulated land application of biosolids in 1979. In 1987 the U.S. Congress amended the Clean Water Act to direct EPA to update the regulations with comprehensive national standards to reduce any risks and maximize the benefits of land application of biosolids. After years of risk assessment studies, peer review, and notice and comment rule making, in 1993, EPA issued its Biosolids Use and Disposal Regulation, 40 CFR Part 503, commonly referred to as “Part 503.” The Part 503 regulations are comprehensive, risk-based rules that protect human health and the environment. Part 503 sets strict standards for treatment plants, land appliers, and farmers that are enforced by EPA. Among many requirements, the Part 503 regulations limit trace elements in biosolids and in farm fields, mandate technologies that reduce bacteria or viruses to negligible levels, limit the total amount of biosolids that can be applied to a field, require setbacks from waterways, and require extensive record keeping by wastewater plants and land appliers like Synagro.
See, e.g., EPA, Biosolids Recycling: Beneficial Technology for a Better Environment (1994); California State Water Resources Board, Statewide Program Environmental Impact Report for Biosolids Land Application (2004); Ian Pepper et al., Environmental and Pollution Science (2d ed. 2006); Gary Pierzynski et al., Soils and Environmental Quality (3d ed. 2005).
Part 503 mandates a continuing review and improvement of biosolids science and regulations. Every two years, EPA assesses whether additional chemicals potentially found in biosolids should be regulated. In addition, EPA, in cooperation with state governments and wastewater authorities, has made important progress in managing and reducing the levels of industrial pollutants in treated water and biosolids through industrial pre-treatment requirements. In fact, the amount of trace elements and other pollutants in biosolids has declined significantly in recent decades, a fact confirmed again by EPA’s latest National Sewage Sludge Survey, released in January 2009. There is an overwhelming scientific consensus that land application of biosolids poses little if any risk to public health and the environment. The National Research Council (NRC) of the National Academy of Sciences studied extensively the use of biosolids in land application and issued two major reports in 1996 and 2002. The NRC concluded in both reports that the application of biosolids to land, when practiced in accordance with existing federal guidelines and regulations, is beneficial and protects human health and the environment. The Academy’s 2002 Report, Biosolids Applied to Land: Advancing Standards and Practices concluded that “There is no documented scientific evidence that the Part 503 Rule has failed to protect public health.” Peer-reviewed scientific studies around the world continue to endorse the benefits and safety of recycling biosolids.2 As for your five specific concerns related to the use of Ney York City biosolids in Alabama, please refer to the following responses: • As with many organic materials used in agriculture, such as chicken litter, cow manure or vegetable composts, biosolids may have odors caused when proteins in biosolids break down. While the odors are not harmful, Synagro’s biosolids processing facility was selected specifically because the nearest residence was located more than one mile away from the processing facility. Frequent monitoring of the area confirmed that the odor dissipated into the atmosphere readily to the point where it could not be detected within 100 yards of the facility. It is our understanding that reports of odors traveling as far as five miles away from the facility were investigated by the State of Alabama Agriculture and Industry agency and were found to be without merit. Indeed, most of the complaints were determined to be as a result of poultry litter odors. This is a general statement, and we are not aware of any such occurrences. If you would like to provide us with an alleged specific occurrence, we would be glad to investigate further. In general, however, Synagro’s biosolids land application program utilizes a systematic approach to insure environmental compliance. Biosolids are applied at agronomic rates, land use is restricted to sites which meet requirements for biosolids land application, buffer zones are incorporated into land application sites to prevent runoff, land application does not occur during precipitation events and land application on saturated soils is prohibited. Synagro did not receive any notices of violation (NOV) from any regulatory agency for this project. Further, Region IV EPA inspection of the
See, e.g., Steven Smith, Imperial College, The Implications for Human Health and the Environment of Recycling Biosolids on Agricultural Land (2007); Rao Surampalli et al., Long-Term Land Application of Biosolids -- A Case Study, 57 Water Sci & Tech. 345 (2008).
NYC project always reflected that the operation was performed in compliance with the regulations. • The process Synagro used to achieve vector attraction reduction (VAR) complied with EPA’s requirements. Both the records of treatment and EPA Region IV inspection results establish that VAR was achieved. In addition, this allegation was investigated by the State of Alabama Agriculture and Industry agency and was not found to be well-founded. We do not agree with this characterization. To the contrary, Synagro held meetings with County Commissioners to inform them of the project and its benefit to agriculture in the area. Synagro also worked closely with federal, state and local agencies on the project. A public meeting was noticed and held at the Franklin County courthouse. Synagro sent notification letters to residences within 1/4 mile of a land application site prior to land application project commencing. Efforts were in fact made to educate the public about biosolids, and Synagro was available at all times to answer any questions about the project. As mentioned above, long-term scientific studies have consistently demonstrated that biosolids recycling is safe and beneficial when performed in accordance with federal regulations and guidance. To date, there have been no documented cases of negative impacts to human health and the environment when a biosolids program has met regulatory requirements and follows best management practices. In fact, the National Academy of Science reviewed the current biosolids management practices and regulatory standards and concluded that “the use of these materials [biosolids] in the production of crops for human consumption when practiced in accordance with existing federal guidelines and regulations, present negligible risks to the consumer, to crop production and to the environment.” As with all good science, research continues. The Clean Water Act requires EPA to the biosolids regulations every two years to ensure the continued safety of the practice. Synagro supports such continued research.
I have included a web link to provide additional information on the facts about biosolids recycling: http://biosolids.org/docs/frequently%20asked%20biosolids%20questions.pdf