!doctype html public "-//w3c//dtd html 3.2//en"> Ben Oostdam at PDER Hearing re A & M Composting Permit Renewal Application, July 18, 2001
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Statement of Bernard L. Oostdam

PDER Hearing re extension of A & M Composting Permit

Manheim, Wednesday , July 18, 2001
Good Evening, Ladies and Gentlemen, my name is Ben Oostdam, and I am a retired Professor of Earth Sciences who did teaching and research at Millersville University for more than 30 years. During that time, I had the opportunity to conduct several research and monitoring projects dealing with the offshore dumping of treated sewage sludge generated by the City of Philadelphia – second only in size to the sludge disposal at sea of the City of New York.

In the 1970's – almost 30 years ago – I testified on several occasions before the US EPA and the US Congress, and in 1983 published a summary article entitled "Sewage Sludge Dumping in the Mid_Atlantic Bight in the 1970's". The gist of my testimonies was that the option of ocean dumping of sewage sludge should be kept open until is was conclusively proven that the two alternatives, i.e. incineration or land disposal – were less damaging to the environment. Specifically, land disposal would be more likely to harm our citizens than disposal at sea.

But for purely political reasons and without a solid scientific basis, Congress went ahead and outlawed ocean dumping of sewage sludge in 1981, giving such reasons as " Fish Do Not Vote" and "the USA should set an example to other Nations".
In effect, we painted ourselves in a corner and now have to live with the consequences: vis. using the other two options. Thus, by serendipitous coincidence, I find that (one of) the largest sewage sludge disposal facilities in the entire world, that of the City of New York, is now located in My Own Back Yard, Manheim, PA !!

EPA, which had gone scientifically overboard (e.g. commenting that a single Phila sludge dump had killed thousands of oysters off Ocean City, MD) to prove how bad sewage sludge was for marine life, now had to change its tune, and even engaged an expensive PR firm to tell us about the beneficial uses of QUOTE"Biosolids"UNQUOTE - which contributed to the publication in 1995 of a very revealing book entitled "Toxic Sludge is good for you", by John Stauber and Sheldon Rampton. I recommend you get a copy and read it.

The very term "Biosolids" is a betrayal, since it excludes the considerable contributions to the waste stream of industrial effluents – a remnant of a previous giant mistake we made when we allowed industries to hook up to sewage treatment plants.

The US Environmental Protection Agency and its allies, including the Water Environment Federation, continue to push the use of "biosolids" , in several ways:
(1) by hiding their deleterious effects,
(2) by slackening their regulations and limits and enforcement , a n d
(3) by ridiculing and/or disregarding responsible scientists.
For examples, I refer you to the Website I have maintained since 1997, entitled:
"Pennsylvania Sewage Sludge Issues". One of such examples is Cornell University's excellent study on the topic of sewage sludge, entitled: "The Case for Caution" from which you can learn , for example, that land application concentration limits for the toxic trace element Cadmium as set by the EPA are as much as 30 times higher than those used by the Dutch Government – whose figures are based on extensive and responsible research in contrast to EPA's very questionable "risk-based" interpretations.
As to the use of "biosolids" as fertilizer, I found the following recent quote from Duff Wilson of the Seattle Times: QUOTE …there are no standards, no required testing, and no limits of the amount of toxic material that can be legally tucked away in fertilizer products in this country, except in Washington State. Fertilizer has even less control than sewage sludge. The EPA is supposed to act (or not) on the fertilizer issue by April 15, 2002, as part of settling a suit with the Sierra Club and Washington Toxics Coalition UNQUOTE

In summary, I continue to be strongly opposed to land application of sewage sludge or biosolids without serious safeguards. Neither the EPA nor PDER presently provide us with such safeguards. On the contrary, their attitude is callous and irresponsible and disregards the public safety, interest and right to know. They are guilty of PROPAGANDA and misleading the public by diverting its attention and tax dollars.
Case in point: if "biosolids" are really good for you, why does not New York keep them for the benefit of their own citizens?
Another case in point is our Federal and State Government's use (or abuse?) of the World Wide Web, potentially a very effective tool. Looking at their websites, one is impressed by the profusion of well-done and colorful pages and reports. But wait a minute and do what I did: try to look up one single specific item, for example, details about Mascaro and its operations. Try to find a single page dealing with the composition of the sludge they receive from NYC– some seven truckloads a day, each of which should have its own manifest of compositional details.
Since 1999, I have urged PDER to arrange that such details be posted on the Web, for easy public access. I failed to get any action on this, neither did I get a reply to the E-mail I sent to PDER asking for specifics when I landed (surfed) onto one of their user-friendly webpages including prompts for information requests..
More immediate yet: Is there anywhere on the World Wide Web a single page "Executive Summary" concerning the Permit Renewal Application which is the subject of the present Hearing? A Hearing dealing with what is probably the World's biggest sewage sludge disposal operation? Millions of dollars were spent to prevent NYC sludge to be dumped in the ocean, but it is alleged that there is not enough money to prepare some simple webpages dealing with such substantial and relevant public information topics as the composition of Mascaro's imports and exports. If we want to find out details, we are forced to come to Harrisburg to get them. That's like when you want to look up a telephone number - the telephone company tells you to come to their Headquarters in Washington to do so...
I want to point out how relatively easy it would be with present technology to have all analyses dealing with the NYC sludge published on the Web since most of them are put on computers, anyhow. Of course, someone needs to summarize them and calculate such details as monthly averages, minima and maxima.
just to save us from being swamped by an excess of information

I will end my statement by listing some of the specific safeguards I would recommend for consideration:
(1) that PDER realizes that its responsibilities to PA environment and safety of its citizens may well go beyond Federal Rules , Regulations and guidelines. Therefore, it can, if necessary, set rules and limits for more parameters, more frequent analyses and stronger safety factors, as is exemplified by actions of Washington State
(2) to have PDER apply a reasonable safety factor of upto 10 to any and all allowable concentration limits set by the USEPA, (meaning that if the EPA allows element X to have a maximum concentration of 20 ppm, PDER's would be set at 2 ppm.)
This would be more in line with limits set in European countries and with sound engineering practice.
(3) to decrease the A & M permit time from an excessive 10 year period to a maximum of three years.
(4) alternatively, to allow some compromise or "trade-off" between items (2) and (3):
the longer the permit duration granted, the higher the safety factor to be imposed
(5) to set up a Citizen Oversight Committee with sufficient authority and funding to perform and/or obtain a reasonable number or amount of independent audits, sample analyses and expert advice and to make recommendations as to suitable safeguards and to oversee a more constructive use of webpages on the PDER website for public information and management tools
(6) to secure that any healthproblems which may be attributable to A & M's operations or products be promptly investigated and mitigated
(7) to regulate the allowable toxics concentrations, labeling, sale and distribution, as well as application sites and procedures of A & M's products, specifically those derived from the so-called "Exceptional Quality" sewage sludge

If the question be asked: Who is to pay for that? the answer would have to be:
A & M Composting itself, as an integral part for being given the right to operate and make profit in our State to the potential detriment of our citizens!
BLO fecit 20010719