A Letter to the Alliance for Chesapeake Bay
The Mid Atlantic Biosolids Association (MABA) has been working jointly with the PWEA Biosolids Committee to improve public perception of biosolids recycling and the work of wastewater professionals. MABA's Executive Director, Michael Wardell, often writes letters to the editor and various organizations to provide factual, scientifically based information about biosolids, especially in response to concerns about biosolids recycling. In January, 2010 just such an article, written by Paul Solomon, chairman of the Shrewsbury Township, PA, Board of Supervisors, appeared in the Forum section of The Bay Journal, a monthly publication by the Alliance for the Chesapeake Bay. The Alliance is a nonprofit organization whose mission is saving the Chesapeake Bay through collaboration, partnerships, and consensus and informing the public about issues and events that affect the Bay. In his article in the Journal, Mr. Solomon expressed concern about nutrient management in the Chesapeake Bay relative to the land application of biosolids. Mr. Wardell responded to this article with a letter, written to the Alliance, in which he addressed Mr. Solomon's concerns and provided data supporting the safe use of biosolids for agricultural application. The following are excerpts from that letter.
Excerpts from a letter by Michael Wardell to the Alliance for the Chesapeake Bay
"Nutrient management is a topic of concern to everyone interested in protecting the Chesapeake Bay. This includes engaged private citizens, farmers, regulators, environmental professionals and wastewater managers. There is a danger is trying to pin the blame on a particular nutrient source, whether that is inorganic fertilizers, animal manures, or in the case of a recent Forum, biosolids.
In order to protect the Bay, and address climate issues, the time has come to start looking at the complete wastewater treatment infrastructure. Over the decades, we have invested trillions of dollars to develop the world’s most advanced system. Outbreaks of diseases such as cholera have been virtually eliminated. One only has to read about the recent cholera outbreak in Zimbabwe or imagine the sanitary conditions created by an earthquake in Haiti to gain appreciation of this benefit, Technological advances have improved the collection, conveyance and treatment of sewage. Consider that individual septic systems now average $10, 000 to $20,000 per house to install. Consider that the City of Philadelphia’s wastewater treatment plant alone requires 2,980 miles of underground pipe to work. And imagine 50,000 fans showing up for a Ravens game with no sewage system. Yet all these benefits occur with almost no notice from the public. And everyone contributes to it.
Approximately 7 million dry tons of residuals are produced by the wastewater treatment plant infrastructure system in the United States each year. A portion of those are further treated to produce biosolids, and about 3.5 million dry tons of biosolids are beneficially used as a fertilizer or soil amendment each year. Residuals are also landfilled, incinerated or managed in some other manner not involving use on the soil. In Pennsylvania, the most recent survey by the DEP showed that 58% of the biosolids were land applied or composted, 27% were landfilled, and 15% were incinerated. Land application is often, but not always, the most cost effective method of managing biosolids, and decades of science tell us it is also a safe and environmentally sound management option.
When a farmer uses biosolids in place of commercial fertilizers, he is helping to protect the bay in many ways. The regulations which govern the use of biosolids limits the application rates to the nitrogen needs of the crop, meaning there is little excess nitrogen to leach to the groundwater. Buffer areas are imposed which provide setbacks from streams and swales, limiting the potential for runoff of nutrients. The organic matter in biosolids improves soil tilth, which serves to increase water holding capacity and the soils ability to retain nutrients. Recent research has shown that biosolids encourage the production of compounds in the soil that help reduce drought stress in crops, improving plant health and increasing yields. Farmers using biosolids are usually required to have nutrient management plans and soil conservation plans. Looking beyond the boundaries of our region, when a farmer uses biosolids instead of commercial fertilizers, he is reducing the greenhouse gas emissions associated with the production and transportation of those fertilizers.
Biosolids are extensively tested on a regular basis for a variety of compounds, including nutrients, metals and organic chemicals. A study by Penn State published in 1999 showed that median biosolids quality in Pennsylvania met the most stringent quality standards in the State and Federal regulations, and metal loadings are orders of magnitude lower than that allowed by regulation. In addition, this study showed that biosolids also met the more stringent requirements suggested by Cornell University and others in the 2007 'Guidelines for Application of Sewage Biosolids to Agricultural Lands in the Northeastern U.S'
Continued research over the 17 years since the Federal regulations were promulgated have added to our knowledge of the constituents of biosolids, and improved our understanding of how some of these chemicals move or are sequestered during treatment and after land application. This information continues to inform regulators and biosolids managers in their decision making process. This continuing research has not raised undue concern among those charged with protecting human health and the environment because this new information has helped to confirm the safety of current biosolids treatment and management options. The presence of synthetic organic chemicals does not mean they are a danger either to the environment or to human health. EPA has recognized the need to consider what compounds are in biosolids, their fate in the environment, and what research or regulation is appropriate to insure the continued safe utilization of biosolids as an agricultural amendment.
Enforcement of biosolids quality and management regulations in Pennsylvania falls to the regional offices of the Pennsylvania Department of Environmental Protection. At least one inspector in each region is assigned the task of overseeing the biosolids management programs of the wastewater treatment plants in that region. On-site inspections are routinely conducted of both the wastewater treatment plant and the land application facilities. Inspectors take random samples of biosolids to confirm their quality, and respond quickly to citizen complaints when they occur. Interviews conducted with the regional inspectors revealed that the biosolids management programs were well run with a minimum of complaints or violations. Enforcement and oversight in Pennsylvania is effective and protective of both human health and the environment.
The concern for human health is one of the major factors regulators and biosolids managers consider when developing regulations or determining how best to manage biosolids. While there is anecdotal evidence of health impacts associated with biosolids, there have been no epidemiological studies which confirm a causal link. Most recently, the Biosolids Expert Panel convened by the Virginia General Assembly made the following observation in their final report. 'In the past 18 months, the Panel uncovered no evidence or literature verifying a causal link between biosolids and illness, recognizing current gaps in the science and knowledge surrounding this issue. These gaps could be reduced through highly controlled epidemiological studies relating to health effects of land applied biosolids, and additional efforts to reduce the limitations in quantifying all the chemical and biological constituents in biosolids.' Additional support comes from a 2007 study by three epidemiologists of Virginia’s Department of Health who concluded the following: 'Although much still needs to be learned about the content, bioavailability and fate of chemicals and pathogens in biosolids and their health effects, there does not seem to be strong evidence of serious health risks when biosolids are managed and monitored appropriately. Human health allegations associated with biosolids usually lack evidence of biological absorption, medically determined human health effects, and/or do not meet the biological plausibility test.'
In 2008, approximately 0.4% of the farmland in Pennsylvania received biosolids. These materials, which decades of continuing research has shown to be a safe and effective soil amendment, do not pose a threat to either the health of citizens near the farms or that of the Chesapeake Bay. The discussion we need to be having is about how we protect and encourage agriculture, which is an important economic engine in our region, while at the same time protecting the bay from nutrient runoff from all sources, including urban runoff, rural septic systems and improperly managed agricultural operations. Those discussions, which will include biosolids and how best to manage them, will help to bring all the stakeholders together and make a lasting and significant impact on the health of the Chesapeake Bay."
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