Biosolids were spread on several fields near my land in 2005.  The smell was nauseating and lasted for days.  I also worry about my well becoming contaminated.

 

Our property adjoins a farmer who has unwisely chosen to spread human waste on his fields. The first time it happened after we moved in last year, I was appalled when my husband told me what had been spread.  The smell is overpowering, causing windows to be kept closed, and heaven forbid that we would try to sit outside to enjoy the stunning view of the Peaks. And again this fall, the spreading continues.  Yes, it does affect my quality of life, and I wonder about my dogs who very occasionally maneuver through the fence and run on this stuff.  I also wonder what breathing in these horrendous odors will do to my respiratory system.  If it makes me cough to breathe the air, wouldn't you just wonder what other damage is being done?  Shame on you, Virginia.

After reading Virginia House Document 89, it is clear that biosolids can be a health risk. The document makes it every clear that VDH does NOT monitor the application on Virginia farm lands and does not collect all the fees. The author of the document Joint Legislative Audit and Review Commission found a number of violations.

 

I can not find articles that there have been long term studies on the affect on the land, ground water or animals eating the grass and grains. Since they are not making any more dirt and water, let’s not waste what we have. The tobacco companies said for decades smoking was ok now we are finding that was wrong. Let’s not forget about lead paint.

 

Granted it is cheaper then purchasing fertilizer and lime. I just have to ask when was the last time you got something for free that was good for you. I understand the smell of money is going to be stronger then the smell of biosolids.

 

I do have some questions. Why are other states shipping it here, I am sure they have farms?  If people can make money selling pet rocks, why are companies not selling biosolids? Why is the state not allowing the counties decide, if they want it?

 

We need to stop its just until studies clearly show it is not harmful and that timely monitoring can be down.  

I know someone who lives in Bedford county next to a property where sewer sludge was applied last spring. Their dog got loose one day and became ill after running through the field of sludge. Over the next few months the dog got progressively worse, experiencing a number of issues – and finally died. Recently I have heard of a number of people who live next to properties that have either ‘storage sites’ or fields where sludge has been applied. Their stories are frightening. I feel sad for them, and for all those who are innocent bystanders – whose lives are being quite negatively affected by the decisions of a neighbor. I feel scared about how many more there will be. I feel angry that we, as a civilization, in this day and time – are making decisions that could potentially harm our friends, neighbors, strangers, animals, our food supply, our ground water… haven’t we learned anything from history? WE NEED TO INFORM OURSELVES. One great source of information is House Document 89, entitled ‘Review of Land Application of Biosolids in Virginia’, a report of the Joint Legislative Audit and Review Commission, published in November 2005. This is an excellent document, a fair and thorough analysis of the issues – from all perspectives. A copy can be obtained from your representative, or viewed online. The bottom line for me is, we do NOT have clear and convincing evidence that application of this sludge is safe. It must not be applied unless there is EXTREME caution exercised and EXHAUSTIVE procedures in place to monitor all related processes and evaluate any consequences. I feel lucky that I am not personally faced with looking at a neighbor’s field full of sludge. Not yet, anyway... How would you feel if it were happening on your neighbor’s land?

Recognizing sludge storage as an "alternative" land use for farmers facing dwindling options, I hold grave reservations about the safety and efficacy of current use and policy.  At the front of my concerns are that the DEQ now forbids the substance to be dumped in the ocean--if it's not safe for the water, why is it safe for the land (and, yes, it's inevitable seepage into the water  table)?  Why do the states of origin, such as New York, ban it, yet the Commonwealth of Va sees fit to not only store it but risk the health and well-being of its citizens and tax-payers by spreading it onto food crops and pasture for food stock?  Why does the Commonwealth allow properties bordering storage sites plummet in value because of the stench, the vehicular activity, and biological threats?  This seems as much a violation of our right to life, liberty and the pursuit of happiness as any.

Until these questions are answered, thoroughly and scientifically, it is ithe only moral choice to offer localities the opportunity regulate sites affecting their citizens, their tax payers, their land values.  I am appalled that our elected bodies and its departments--i.e. the Dept. of Health--have so easily served up our health and well-being and the safety of our food supply. 

Nan Carmack, Forest, Virginia

 

 

The first "Temporary Biosolids Storage Facility" in Bedford County is operating for a second year 1/3 of a mile from our home. Synagro was granted a variance (See ltr to Mr. Steve McMahon, Synagro from Robert B. Stroube, April 19, 2005) that allowed Synagro to varying from many of the code regulatins for these facilities. We were subjected to a huge volume of truck traffic on our right of way, the only access to our property, for over 4 and a half months, industrial volume of noise for this period, beginning at daybreak and continuing until dark, and months of inhaling the odor (ammonia!) that made us have constant headaches and feelings of nausea. The burden of this commercial/industrial operation was such that we consulted a real estate agent about selling and were told that our farm is worthless and that no one would want to live next to this operation because the odor, noise, and traffic. We are trapped here. The right to the "peaceful and quiet enjoyment of our home" has been denied us and we are being forced to "live in a privy" and next to an industrial-scale operation. Shame on the VDH! Many other families in our neighbor are negatively impacted, including a neighbor with a lung problem. The pit was unlined, uncovered, on a slope, and about 500 feet from a stream. Virginia nuisance law's questions are "Is it offensive to the senses?" Is it a threat to public health and does it violate the law of decency?" The answer to these questions is "YES." I have written Robert Hicks for information about what we can do to protect ourselves from inhaling ammonia over many months, but have received no response.

I just attend a gathering of nearly 100 Bedford County residents who were all concerned about "biosolids" being spread and stored on County land. Almost all of them including myself have come to the conclusion that northern sewage sludge does not need to be spread or stored on our land. I realize that private landowners (farmers) stand to gain financially from the savings on fertilizer or in getting direct payment for storing the stuff and the state gets paid for allowing this distribution. The gain though in my opinion is not worth it! This practice is degrading the soil, an asset that can't be replaced, and creating gross smells, incredible truck traffic, road degradation, water polution and a lot of unhappy people. I would encourage lawmakers to stop this program entirely. This stuff should be landfilled not some how pawned off as fertilizer. Counties should also have direct say as to whether they want this stuff. We are being victimized by our own state!

As a rural citizen and owner of a farm, I am concerned about the safety issues involved in applying sewer sludge to land. Monitoring is an impossibility since each load would have to be thoroughly tested by a certified third party to guarantee that no heavy metals, no carcinogens, no pathogens, no toxic wastes were present.

Common sense should prevail. Something as simple as dumping old medications down a toilet would have possible health and environmental consequences. One can only imagine what besides human waste has entered the sewer systems of any metropolis. Any short term gain on a ledger sheet must be outweighed by the possible consequences of poisoning our citizens, our environment, our future.

The spreading, storing and transporting of human sludge is dangerous and has been verified by many to be a health problem.  Synagro has in fact, paid out on at least one wrongful death lawsuit in the case of a man who died after being exposed to biosolids.  There are thousand of accounts of health issues to humans, death to pets and livestock after the exposure to Biosolids.

Counties must have the ability to deny outside companies from transporting, storing and spreading of this sludge within the boudaries of their county. 

A Taxpayer,

Greg Fenning

I am speaking for my family and others on Cobbs Mtn.Rd. on Aug 18-23-06 this stuff called sludge was applied on property east of my home 220 ft.from front door the average temp.was 87 degrees the stench was so bad we basically lived away from home for 28 days no meals at home no A.C no windows opened and not only did we put up with the spreading of ----we had to drive home through 1 mile  of this stench .I have been associated with farming most of my life but never have I had to endure anything like this ,and never will again,also the stock pile was only 500ft.from the home .I am by no means against farming I am against spreading something on land that no one can tell me what the long term effect will be,

Tell me how this make sense.  Virginia is trying to clean up the waterways and yet we are putting human crap on our fields, which then are washed in to our streams and creeks.  Please stop this for the sakes of our children and grandchildren.

One of the most disturbing things about the spread of sludge is the astonishing lack of respect and concern that VA legislators and the VA Health Department has for the citizenry they are sworn to protect.  Horrendous odors sicken property owners adjacent to sludge spread fields for weeks.  State regulations also allow sludge storage and distribution facilities in residential zones that operate four to six months in duration.  The one on the Wilkerson farm, on Otterville Road, brought heavy industry, noise and truck traffic along with the stench.  We personally witnessed sludge trucks leaking liquid and solids on Otterville Road.  We also saw numerous other violations including runoff from the storage site into a nearby creek.  VDH officials in Richmond and elected state representatives who are bowing at the altar of the large sludge corporations, perhaps should be required to live next to one of the storage facilities for it's duration.  I believe that that might bring about a drastic change in attitude.  I understand the lure to the farmer, I am also one.  However, I believe future events will create a very negative picture of Virginia beef production.  The growing anger of the VA population and the fear of being sickened from sludge raised beef is going to torpedo the price of beef.  "There is no free lunch." 

I thought it quite interesting that the ONLY adverse economic impacts consideredbwere the profits of the sludge haulers.  What about individual property values, home businesses, churches, daycare centers and all other small businesses located adjacent to a sludged field or stockpile?

Khalil Hassan
Madison County

I cannot believe that I came upon this site purely by accident.  and it supposedly started in October 2006. I will have to hurry to tell my friends......

I live in Bedford County, about 1/4 a mile from the Otterville Road storage site, that was put there last year.  I noticed the big hole and excavating...and I was told the Mr. Wilkerson was building a pond.  there had been no public announcement or meeting for a "biosolid storage facility".  which means what. dig a hole HUGEEE, put some rock in the bottom and fill it up with raw black dripping "S---". 

I couldn't get by on Otterville Road last winter, three hughe trucks were blocking the way, and waiting down by North Otter Creek to get into the Wilkerson property.  I got out and asked the guys if they were lost, no, "they said", we are waiting to dump this waste from NJ.  I go "what".....  I saw this stuff dripping on the road.....and smell, oh yeah!  It was dripping from the wall of the truck and the gate on the truck.  anyway I started asking questions.......

I was told many different thinks...that the permit for Wilkerson was for only 3 years (by Mr. Scofield) The health director would not even return calls.  I was concerned about the water, being so close to North Otter Creek.  Scofield said it was well in limits, and the drainage was fine also.   I am here to beg to differ....I always slow down or sometimes get out at the creek, and pick up cans or whatever, and look at the water.  well the water level was down and I saw a line on those rocks and gasped.  That color was unmistakable.  sludge in the water......I had asked about a water test,  oh the water's fine I am told. ......

I have stayed in my house since January 2006, and have not been too many places....I have came outside for some things, and sometimes the smell is enough to make you puke.  so much for a nice BB-Q.  we live in the mountains, there is always a low cloud of moisture, holding all smells down, even burning wood in fireplaces, it is obvious that an impact study was not done at the Otterville site. I am not sure if any study was done.  this area is zoned "rural PRESERVE".  that means to me, and why we moved here is because it was a reserve, farms, horses, cattle,   NO INDUSTRY...no smell....

Since January of 2006 I have had one medical problem after another.  More headaches than normal.  my blood has gotten really thin, won't clot, anemia, needing potassium, to name just a few.  and sore throat since that time, ans sinus problems, and coughing.  and I was supposed to have both tonsils out because of all the infections and the doctor can't figure out how in the world I got a "bacteria" infection in my throat.  

This action of permiting this "biosolid waste" to be put in this section of the county, has already caused more harm than good. And I can promise you that if I can prove all my suffering, and blood issues are related to that mess just sitting there on open ground, I will get the best lawyer I can, and sue for my life.  what is a life worth? mine is priceless......

My husband works for Homeland Security and is working very hard to help secure this country from violence.  He is a dedicated individual and has been working in this arena for 40 years.  And he comes home, and what does he smell?  and his wife of 33 years is sick constantly.  so where is the logic?   "Is it all about money"....

Sincerely,
Rebekah M. Crum
12/04/06

I am writing you to support the Public Comments, dated December 5, 2006 prepared by the Citizen's Members to the Virginia Biosolids Use Regulations Advisory Committee and urge VDH to adopt the recommendations contained in these documents.

Whereas I support these recommendations, there is scientific support for more than the 1.5 miles minimum as stated in the recommendations. Also there should be more than one person with authority to oversee the health issues concerning biosolid land application sites. These persons should be doctors of medicine and they should be empowered to modify or lift sites due to health issues of citizens in the Commonwealth.

 

When reading all of the articles that have been written on the subject of bio solids, it is clear to me that the term bio solids is a grandiose misnomer, if I ever saw one. My big question is why would the Commonwealth of Virginia want to be the septic system for the BIG CITIES sewage sludge? I hope the answer is not: MONEY. 

Apart from the potential health hazards, why would the Commonwealth and its lawmakers be tempted to reduce the the beauty of the State and Bedford County to be the depository of this sludge. 

Both the spreading and in particular the "temporary" but long term storing of the sludge should be outlawed. Our septic system discharges in Bedford County soil, which may be bad enough already, and I suggest wherever this sludge comes from it stays where it is produced.  

   

NOTICE TO AGENT IS NOTICE TO PRINCIPAL

NOTICE TO PRINCIPAL IS NOTICE TO AGENT:

YOU ARE HEREBY NOTICED THAT THOSE WHO HAVE BEEN AND WILL BE HURT BY RAW SEWAGE WILL BE WRITING AFFIDAVITS OF TRUTH ABOUT THEIR SYMPTOMS AND SICKNESSES AND SIGNING THEM UNDER PENALTY OF PERJURY. YOU, PUBLIC SERVANTS, WILL BE REQUIRED TO REBUT EACH AFFIDAVIT OF TRUTH POINT FOR POINT AND SIGN YOUR REBUTTAL UNDER PENALTY OF PERJURY...OR THE AFFIDAVIT WILL STAND AS TRUE. IF DERELICTION OF DUTY IS A CRIME, AND YOU DO NOTHING TO STOP THIS, YOU WILL PROBABLY BE FOUND GUILTY.  I SHALL BE CONTACTING MANY OF THE PEOPLE WHO ARE LISTED ON DEADLYDECEIT.COM TO GET AFFIDAVITS OF TRUTH FROM THEM. 

WE WILL NOT INHALE DUST FROM THE ROADS THAT MAY BE INFECTED WITH PARASITES, GERMS, BACTERIA, OR POISONOUS, TOXIC CHEMICALS THAT CAN HARM BORN AND UNBORN BABIES AND CHILDREN.  WE WILL INSIST THAT A HAZ MAT TEAM COME TO CLEAN UP EVERY LITTLE DROP OF SEWAGE THAT LEAKS FROM YOUR LOVELY PORTAPOTTY TRUCKS. AND YOU,SYNAGRO, CAN PAY FOR IT. WE DO NOT AGREE THAT IT IS SANITARY TO WALK OR RIDE OVER THE ROADS THAT YOUR ECOLI AND PARASITE AND LEAD AND DIOXIN INFESTED SEWAGE CRAP HAS FALLEN ON FROM YOUR AGENTS' TRUCKS.  THERE ARE OVER 6 MILLION CRIMINAL LAWS ON THE BOOKS.  WE WILL FIND, WITH GOD'S HELP, THE LAWS YOU ARE VIOLATING AND WILL INSIST ON YOUR CRIMINAL PROSECUTION.   WE ARE NOT STUPID. WE WILL DEAL WITH YOU AS THE DOMESTIC TERRORISTS THAT YOU APPEAR TO BE.THERE ARE PROBABLY LAWS IN THE ANTITERRORIST LEGISLATION THAT WILL APPLY TO WHAT SYNAGRO IS DOING. PEOPLE ARE AFRAID OF THIS SEWAGE, BUT KNOWLEDGE IS POWER, AND WE ARE GETTING EDUCATED AND POWERFUL! HOW DARE YOU CONTAMINATE OUR WATERS AND OUR CROPS?  ARE YOU SO BLIND THAT YOU DO NOT SEE WHERE ALL THE FOOD POISONING AND ECOLI IS COMING FROM?  IT SURE ISN'T BECAUSE TACO BELL IS AN UNSANITARY PLACE OR BECAUSE THEY DONT WASH THE PRODUCE...DON'T YOU REALIZE THAT THE ECOLI IS TAKEN UP INTO THE PLANTS AND BECOMES A PART OF THE FOOD WE AND OUR CHILDREN PUT INTO OUR MOUTHS?  WE WILL NOT BE INTIMIDATED BY ANY PUBLIC SERVANT WHO THINKS THEY ARE EXPERTS.  ANY IDIOT KNOWS THAT YOU WASH YOUR HANDS AFTER YOU GO TO THE BATHROOM TO PROTECT THE HEALTH OF OTHER PEOPLE. DO YOU REALLY THINK THAT YOU CAN TAKE RAW SEWAGE AND SPREAD IT ALL OVER THIS COUNTY AND NOBODY WILL GET SICK?  WE ARE NOT THAT STUPID!!! ARE YOU? WE THE PEOPLE WILL BE SENDING MANY CERTIFIED LETTER/AFFIDAVITS OF TRUTH TO YOU.  ALSO, EXPECT SOME FOIA LETTERS AND KNOW THAT THEY MUST BE ANSWERED WITHIN 30 DAYS...  (TO THE BEST OF MY KNOWLEDGE, A FOIA VIOLATION CAN BE HANDLED CIVILLY OR CRIMINALLY.  PERSONALLY, I WOULD LIKE TO SEE DOMESTIC TERRORISTS WHO DESTROY OUR LAND SPENDING TIME IN JAIL. OR IN GUANTANAMO.)

ANY PROPERTY THAT LOSES VALUE WILL BE A BIG PROBLEM FOR THE PUBLIC SERVANT WHO DID NOT FULFILL THEIR RESPONSIBILITY TO WE THE PEOPLE.  THERE MUST BE A WAY TO COME AGAINST PEOPLE WHO WORK FOR AGENCIES AS INDIVIDUALS, AND THE SAME FOR PEOPLE WHO "ARE JUST DOING THEIR JOB" BY ENDANGERING THE HEALTH OF THEIR FELLOW MAN.  "I WAS JUST FOLLOWING ORDERS" DIDN'T CUT IT AT THE NUREMBURG TRIALS. AND IT WON'T CUT IT IF A HUMAN OR ANIMAL DIES 

THERE WILL BE NO MORE CONTINUATION OF THE CONSPIRACY TO DEFRAUD 'WE THE PEOPLE' OF INFORMATION THAT COULD PROTECT THE CHILDREN, BORN AND UNBORN. YOU WILL NOT WITHHOLD OR LIE ABOUT HEALTH RISK INFORMATION AS HAS BEEN DONE IN OTHER COUNTIES. BECAUSE OF THE MANY LIES THAT HAVE BEEN TOLD BY GOVERNMENT REGULATORS AND BIOSOLID (aka SEWAGE) PUSHERS, WE WILL, IF I HAVE ANY INPUT, INSIST THAT ALL DOCUMENTS ARE SIGNED UNDER PENALTY OF PERJURY.  

THIS IS OUR LINE IN THE SAND,

WE WILL UNLEASH LEGAL HELL IF YOU CROSS IT! 

 

I support the recommended changes to the Biosolids regulations.  However, I believe the buffer from any residential property line should be a minimum of  5 miles.  Application should be firmly denied near any resident who has an weakened immune system, respiratory health problems or for the elderly and very young populations.  All applications should be stopped until such time that:

1)The EPA conducts the needed epidemiological studies on effected populations.

2) The VDH and EPA have the proper staff to oversee wastewater treatment plants and enforce all regulations.

Further concerns are:

1)The EPA has inadequate & outdated scientific research on effects on humans, wildlife, and the environment.

2) Hundreds of Virginian are reporting chronic and life threatening health effects from exposure to dusts, aerosols and direct or indirect contamination from these fields.  These reports are minimized by VDH, not required to be maintained on website after two years, and those affected can obtain no relief or help from the government agencies responsible.

3)The EPA Inspector General Report of 2000 states that the agency has failed to protect the public health and cannot say that the current practices are safe.

I believe the lack of concern by VDH and EPA is a travesty imposed on Americans. 

I highly support the only two citizen representatives allowed on the Biosolids Use Regulations Committee.  The other members are from the Sludge contracting industry and others who have conflicted interest.  I want to know why these comments are not posted on the Town Hall comment list for the public to view. 

I strongly support the recommendations for changes made by these two members and urge you to adopt the recommendations verbatim listed in the documents submitted by them.  I fail to understand why the Board of Health does not realize the wisdom of stated information submitted therein.  To the average citizen, it is a "no brainer" and a continuation of the status quo to do as little as possible to regulate the application of biosolids.

The reason citizens don't register on you website is because it states it is being submitted to an unsecure site.  This should be changed.

I just read Frances Coristin and her words mirror my own thoughts. The people of this state are comming together in their determination to stop the biological warfare being waged against the rural citizens of this Commonwealth. As Ms. Coristin stated, we are becomming educated and powerful. Our outrage is growing daily at the arrogant disregard of human health and welfare by the people in an agency whose sworn duty is to protect our health and welfare.

We are no longer going to tolerate the poisioning of our environment or ourselves. Let this serve notice that the people of this State of Virginia have reached the saturation point with the  arrogance toward and disregard of the wishes of the people.

Helen Cooke Eggleston

Surry County, Virginia

 

We the residents of Surry County were subjected to what the residents of our large cities and towns would define as biological terrorism.  A group of citizens from other counties formed an LLC and colluded with the VDH(this word is an oxymoron)to spread processed human waste and industrial chemicals on approximately 3900 acres in Surry County.  The citizens in this group and their registered agent are so proud of their handiwork that they won't even answer their phones.  We will keep looking until we can find the legal precident or  Virginia Code to prosecute these people and others like them that think it is okay to defile and pollute our soil and waterways with impunity for the sake of the almighty dollar.  Furthermore any politician who recieves money from the waste management industry and furthers their cause in polluting our invironment will be added to our list of politicians that needs to be replaced in the General Assembly.  We will expose you and the ways that you vote on biosolids legislation that damage the environment and poison Virginia residents.

Furthermore We intend to lobby the Federal Government  for changes long overdue on the EPA definition of biosolids and the hazards they contain.  Inspections of this nightmare in Claremont Virginia were virtually non-existent and the only reason the DEQ is monitoring Sunken Meadow Pond now is to cover their ass because a group of citizens has had enough and decided to sue the perpetrators of the rape of our environment.  We would strongly encourage the indian tribes across from Claremont Virginia on the James River to sue Synagro and Sussex Surry LLC ,also because of  what the pollution coming from this site will do to your fishing grounds longterm.

We intend to hold the perpetrators accountable for their actions.  Virtually the only people doing samples of this human waste are the producers of the same which smacks of the fox guarding the hen coop.  We wish the people sueing Synagro and Sussex Surry LLC the best of luck and success in their endeavor and hope they extend their suit to cover the VDH and the Government of Surry County for their inactivity.

I support the language changes to 12VAC 585BUR dated December 5, 2006 prepared by the Citizens' Representatives of the Virginia Biosolids Use Regulations Advisory Committee and urge VDH to adopt the recommendations contained in those comments.

I will first comment on the four major areas affected by the proposed regulations as identified in the Brief Summary section at the beginning of the Agency Statement, which reads “The Biosolids Use Regulations (12 VAC 5-585) are to be amended to provide regulations and standards for enforcement related to local oversight of land application operations and provide requirements for land application site management practices to protect odor sensitive receptors, ensure permit compliance and address nutrient management concerns.”

 

1. Regulations and standards for enforcement related to local oversight of land application operations

The phrase “local oversight”, which appears only in the Brief Summary, is misleading. A complete reading of both the Agency Statement and the Proposed Text reveals no additional authority granted to localities to oversee land application of biosolids. In fact, the primary purpose appears to be to force local government compliance with the state standards with the purpose of relieving biosolids companies of the burden of challenging local ordinances in court.

The proposed process for resolving enforcement disputes between permitees and localities with an ordinance for testing/monitoring land application of sewage sludge appears to ensure that the local ordinances cannot be enforced in court.  Placing all of the power for resolution in the hands of a VDH commissioner completely dis-empowers the locality to enforce its own ordinances.       

2. Requirements for land application site management practices to protect odor sensitive receptors

The proposed regulation for an extended buffer leaves too much discretion in determining if an extended buffer is required as a condition of the permit. The extended buffer distance of 400 ft. is too small to make a difference when dealing with a pungent odor.   

3. Ensure permit compliance

There is no section/subsection in the Proposed Text on “permit compliance”, so it is somewhat difficult to determine what the VDH means in the Brief Summary when it lists “ensure permit compliance” as a substantive change. However, in the Agency Statement, it appears that this is actually again referring to the proposed changes that negate court enforcement of local ordinances.

4. Address nutrient management concerns

The VDH decision not to require a DCR-approved nutrient management plan as part of the permit process is a very troubling omission. If the purpose of spreading sludge is for soil amendment, then nutrient management is at the heart of the entire process. Failure to include such a fundamental part of the whole process leaves one to ponder if soil improvement is really why VDH wants to enable the land application of biosolids or not. It certainly “smells” of special interest influence.    

I will now comment on the more general area of biosolids as regulated by VDH. In my opinion, VDH has failed to “step up”.

In the Agency Statement, VDH acknowledges that one of the options available was to revise the entire set of biosolids use regulations. However, it chose the easier path, stating “Although additional requests for revisions to the Biosolids Use Regulations have been submitted by local governments and private individuals, the process of revising the entire set of the Biosolids Use Regulations will likely become a long drawn out process, as the land application of biosolids is a highly controversial subject. Thus, the Virginia Department of Health is electing to recommend that only the previously listed sections of the Biosolids Use Regulations be revised at this time.”

Yes, it’s a very tough subject, but that doesn’t mean any stakeholder should play “ostrich”, and particularly not the state agency whose stated mission is “to achieve and maintain optimum personal and community health by emphasizing health promotion, disease prevention and environmental protection”.

Why did VDH duck its responsibilities? Apparently because the agency is more concerned about the financial health of biosolids corporations than the physical health and well-being of Virginia citizens. The Agency Statement actually says doing anything other than what they chose to do “…will likely result in local adoption of ordinances with varying non-uniform requirements, that could have significant financial impacts on the regulated entities.”

The biosolids issue is an extremely important long-term health issue. The results of dumping sewage sludge into the ocean took time to rear their ugly heads. Now, we all accept as “good science” that dumping sludge in the ocean is a very environmentally unsound practice. Applying deductive logic to good science tells us that the same material is likely to eventually cause equivalent problems when dumped on land. Sludge is not like manure from your own barn that you throw in the manure spreader. It has pathogens and heavy metals and is entering our food chain right where it all begins. 

As citizens, we expect our state health department to protect us, not protect the companies doing the dumping.  

Rural Madison, Inc. is a 501(c)3 organization dedicated to careful and responsible growth that conserves our natural, cultural, and historical resources, protects the rural character of our county and improves the general welfare of all of the county's citizens.

We full recognize the dilemma that many in the agricultural community face in these times of globalization.  While empathize with their quandary, we also recognize that land application of sludge is a short-term solution that will, in time, destroy the very thing that we are all trying to preserve, that is a safe and secure food source.

Having reviewed the recommendations set forth by Henry J. Staudinger and C.W. Williams and having agreed in totality with those recommendations we urge you to adopt them verbatim.

We urge even stronger that the term should be deleted and replaced with shall as pointed out in their recommendations.

We hope that in the interest of public health, safety and general welfare you will adopt these recommendations.

Sincerely
Khalil Hassan
President

I am writing you to support the Public
Comments prepared by the Citizen's Members to the Virginia Biosolids
Use Regulations Advisory Committee and urge VDH to adopt the
recommendations contained in these documents.
Eric Kvarnes
Sperryville, Va

 I am writing you to support the Public Comments prepared by the Citizen's Members to the Virginia Biosolids Use Regulations Advisory Committee and urge VDH to adopt the recommendations contained in these documents.

Thank you,

Nancy H. Halgren

I am writing you to support the Public Comments prepared by the Citizen's Members to the Virginia Biosolids Use Regulations Advisory Committee and urge VDH to adopt the recommendations contained in these documents. Joy Lorien Shenandoah River Watershed Luray, Virginia

I wish to go on record in support of the comments of the citizen representatives to the Virginia Biosolids Use Regulations Advisory Committee.  I further urge the Virginia Department of Health to adopt the recommendations as specifically proposed by Mssrs. Staudinger and Williams in toto, with specific emphasis on their stated request (which I echo) that the department actually enforce the laws (and the health of the general public) with which they have been entrusted by substituting "shall" for "should".

After moving to rural Virginia three years ago, I have spent much of that time researching the sludge issue.  I find the casual disregard of human health and welfare, evidenced in the lack of enforcement of statutory guidance, to be appalling.  Without going into the chapter and verse of my research (all of which is scientifically based), I draw your attention to the well-deserved criticisms found in the Joint Legislative Audit and Review Commission Draft report dated October 11, 2005 -- Review of Land Application of Biosolids in Virginia.  That staff has consistently underserved Virginia's citizens is demonstrated throughout the report.   The adoption of the amended language as proposed by Mssrs. Staudinger and Williams will begin to rectify an egregious situation.

 As a taxpayer in the Commonwealth, I would also appreciate being notified as to what specific action is taken.

I am writing you to support the Public Comments prepared by the Citizen's Members to the Virginia Biosolids Use Regulations Advisory Committee and to urge VDH to adopt the recommendations set forth in those documents.

Without liiting the generality of the foregoing, I also favor inclusion of stricter standards for buffers, including the following language:

"Extended buffer setback distances.  For all biosolids applications,
the department shall require extended buffer zone setback distances
when necessary to protect the health and quality of life of those
exposed to biosolids as well as odor sensitive receptors.  Buffer zone
setback distances from those who may be exposed to biosolids aerosols
may be extended to 400 feet or more, but shall not be less than 1.5
miles where the severe immune and other health compromised individuals
may be exposed unless VDH demonstrates that there is nothing in the
biosolids that may cause them serious harm, and no biosolids shall be
applied within such extended buffer zones…."

I also favor inclusion of stricter standards and for larger buffers from rivers and other natural watercourses. 

I favor inclusion of stricter standards and mandatory testing for chemicals including, inter alia, pharmeceutical compounds, polybrominated diphenyl ethers (PBDEs), carcinogenic pesticides, and heavy metals.

Finally, I favor more local authority in communities to place their own restrictions on sluge application.

Thanks for taking my views into account.

 

David L. Konick, PO Box 57, Washington, VA 22747

I am writing you to support the Public Comments prepared by the Citizen's Members to the Virginia Biosolids Use Regulations Advisory Committee and urge VDH to adopt the recommendations contained in these documents.

It is obvious from reading the associated proposals, background documents, impact analysis, etcetera that these regulations are not written with the health and well-being of Virginia (people, land, waterways) as their core consideration.  They are clearly written to facilitate the monetary gain of the companies involved in the transport, storage, distribution, and application of biosolids; and to allow metropolitan localities to eliminate their waste disposal quandary without consideration for the long term costs they are imposing on the localities where their waste is dumped.  It is obvious that the proposed regulations are intended to preclude Virginia's more rural localities and citizens from protecting themselves against the potentially harmful effects resulting from the storage and application of Class B sewage sludge.  For example, section E.1. of the proposal states "The decision of the commissioner shall be final and binding...." And that the commissioner "may seek an injunction compelling the halting of activity."  In other words, the commissioner makes all of the decisions, the locality suffering the consequences has no right to challenge the decision, and the commissioner may or may not do anything about the violation.

The Agency Background Document (Form TH-02, dated 10/27/2005) states that "revising the entire set of Biosolids Use Regulations will likely become a long drawn out process...."  And it should be for the very reason stated, that "application of biosolids is a highly controversial subject."  The fact that VDH is recommending a limited review is clear evidence of their wish to duck their responsibility to protect the public welfare.  Otherwise they would take the initiative to research and understand all of the implications of applying/storing Class B biosolids and re-write the regulation in such a way as to properly protect Virginia.

The Economic Impact Analysis states that "applying biosolids...have become a common practice...provides an effective and environmentally friendly way to dispose of wastes while simultaneously improving soil quality."  This is a statement of opinion; there is no scientific evidence presented to support it.  The analysis goes on to state that there is "no documented scientific evidence of adverse human health effects...."  There was also initially no scientific evidence showing the adverse effects of asbestos, lead based paint, dioxin, DDT, radiation, etcetera.  But longer term analysis has shown that all of these are deadly to humans, even in small amounts, and render land where they exist to be worthless.  The EPA Superfund exists for a reason.  And there are regulations precluding the dumping of sewage into our waterways for the same reasons.  Additionally, there is no reasonable way to control what is incorporated into the sewage waste stream.  A homeowner in New Jersey can dump anything they want into the toilet (e.g., mercury, lead, persistent poisons, medical waste) which will become part of the Class B sludge spread on the land and likely ending up in our water.  Hard science has shown that as toxins pass up the food chain they are continually concentrated, with humans at the top of that food chain.

The Economic Impact Analysis goes on to state that the proposed amendments to the regulations "may have a positive impact on the value of residential properties...."  If they "may" have a positive impact, then logic says that they also "may" have a negative impact.  Where is the science that determines which will occur?

Looking at specifics of the proposed regulation changes show things like

• Section 3.c.(1).(a), which states "Biosolids are surface applied...beneath a living crop..., or timely planted small grain cover."  So what is "timely planting" to a farmer whose time is already stretched thin?  Maybe a day, maybe a week, maybe a month, maybe spring comes and it doesn't really matter any more because the sludge has already washed into the creek.
• Section 3.(d).2, discussing buffer zones, states the "commissioner may impose standards that are more stringent...prevent nuisance conditions from developing...."  Most people would agree that an odor that precludes them from enjoying their yard, and which dramatically reduces the sale-ability of their home would, at a minimum, qualify as a nuisance.  But the commissioner may (or may not) choose to do anything to mitigate this impact on residents surrounding the application/storage site.
• Section 3.e. states that "Groundwater and surface water and soils monitoring and testing may be required...for any frequent application sites...."  The statement makes it clear that sites reaching agronomic rates more than once in three years have an increased potential for environment or public health concerns. But monitoring and testing to ensure that the public health is not being harmed "may" be required.

The list could go on and on.  But one thing is completely clear, these regulations are aimed at facilitating the disposal of Class B waste, not protecting the welfare of Virginia's people and natural resources.

 

Loudoun Neighbors Against Toxic Sludge (NATS)

1496 Teague Drive

McLean, VA 22101

December 8, 2006

 

Kerri Nicholas

109 Governor St

Hearing and Legal Services Officer

Richmond, VA 23219

Dear Ms. Nicholas:

I would like to add my name to the list of Commonwealth citizens who support Henry Staudinger’s Amendments to the existing inadequate sewage sludge regulations. However, I would go much further and demand an immediate moratorium on this heinous program.

EPA nor the Virginia Department of Healthhave produced one single credible scientific study to support their erroneous contention the program is "safe" for public health. Yet there are peer-reviewed scientific studies linking illnesses to sewage sludge exposure. The National Institute for Occupational Safety and Health (NIOSH) confirms that sewage sludge exposure is linked to worker illnesses that are similar to neighbor health complaints. Two EPA Inspector General Reports and two National Academies of Science Reports all found the science behind the sludge rule weak and out of date. Hundreds perhaps thousands of Virginia citizens have complained about putrid smells interfering with the enjoyment of their homes and property. Still others have complained about illnesses they developed after their exposure to sewage sludge and which they and their physicians believe is linked to their sludge exposure. Yet all this documentation has fallen on deaf ears of the various health agencies and the Virginia Assembly

Just recently a lawsuit was filed in Surry County Virginia alleging negligence, private nuisance and trespass. Specifically the suit alleges sewage sludge usage denied plaintiff’s the enjoyment of their homes, in one case forcing a plaintiff to leave the comfort of her home. The suit also alleges plaintiff’s emerging physical and emotional problems are linked to sludge exposure.

EPA and Virginia authorities admit they do not know what specifically is in sewage sludge. They have refused countless requests to specify contents. This puts them in the indefensible position of claiming that a complex product, for which they have no idea of its contents, is "safe" for public health. It is even more ridiculous for them to further claim the material they admit contains pathogens, endotoxins, and chemical toxins, did not cause our illnesses.

I, many other Virginians, as well as our doctors, believe our mushrooming health problems are linked to exposure to this toxic soup. This conclusion comes after careful consideration and elimination of other possible causes. This belief is supported and reinforced by the repeated occurrence of the exact same kinds of illnesses occurring with neighbor exposure to sewage sludge in other states and counties which also have land application programs.

It is about time Virginia’s arrogant public officials and legislators stop responding to pressure from this greedy industry at the expense of the public’s health. The primary obligation of these officials, whether elected or appointed, is to protect the health and welfare of the citizens. They can easily do this by declaring an immediate moratorium on this program.

Loudoun Neighbors Against Toxic Sludge

www.LoudounNATS.org

I am writing you to support the Public
Comments prepared by the Citizen's Members to the Virginia Biosolids
Use Regulations Advisory Committee and urge VDH to adopt the
recommendations contained in these documents.

Sludge is just some nasty, nasty stuff. Please stop spreading it and polluting our beautiful state of Virginia with heavy metals and hormones.

I am writing you to support the Public Comments prepared by the Citizen's Members to the Virginia Biosolids Use Reguulations Advisory Committee and urge VDH to adopt the recommendations contained in these documents. Let's have the most restrictive regulations possible against biosolids.

I sincerely urge Virginia Department of Health to adopt the recommendations of our two Citizen members of BURAC regarding the Enforcement and Site Management of Biosolids (Sludge) regulation which is open for public comment.  I have read, agree and support their comments.

However, based on my research, it appears that a minimum buffer distance of 1.5 miles for the severe immune compromised may not be sufficient.  I urge VDH to consider a larger minimum distance when those people are present.  Now is the time to do this.

I am writing you to support the Public Comments prepared by the Citizen's Members to the Virginia Biosolids Use Regulations Advisory Committee and urge VDH to adopt the recommendations contained in these documents.

I really want to know how, as educated, scientific-minded people, you all sleep at night.  It seems so clear that there is a pay-off somewhere in this system which is allowing our environment to be poisoned.  The tide is turning and people are becoming aware of what sludge really contains and it will be your legacy if you do not begin to work against it now.

I am writing you to support the public comments prepared by the Citizen's Members to the Virginia Biosolids use Regulations Advisory Committee and urge VDH to adopt the recommendations contained in these documents.

Please add my name to those who are in support of Mr. Staudinger's proposed amendments.  I would like to further ask for an immediate moratorium on the spreading of sewage sludge in the name of free fertilizer.  How can it be that it is safe to spread sludge on the land, when it is no longer acceptable to dump this sludge in our oceans?   I have heard of how more stringent policies wil be intitiated to remove higher levels of wastes from the water discharged at sewage treatment plants in hopes of cleaning up and saving our beloved Cheasapeake bay.  Meanwhile, the sewage sludge will then be dumped back on the ground to leach into our waterways, and eventually pollute the bay anyhow!!  There is absolute ignorance in such a policy.

I am always apalled at how VDH sidesteps the issue of public safety when it comes to citizen exposure to biosolids.  It is a lie to say that the illlnesses that Virginia citizens have had to endure have not been linked to the exposure to the airborne pathogens and toxic materials found in land applied sewage sludge.  Where are the epidemiological studies that confirm, without a doubt, that human exposure to sludge is safe?  To my knowledge, no federal or state studies have been done.  We only have VDH and EPA saying they think it is safe to apply if regulations are followed.   As a private citizen, I could not revove the wastes from my septic tank and apply it to a field to use as fertilizer, so why should biosolid companies be able to do the same?  It is obvious that the larger muncipalities and biosolid companies have the desire to continue to operate in the same manner they have in the past, with no regard for the health, safety or quality of life of the rural citizens who have to endure this scam called biosolids.  In the light of our needs for energy independence, why are we not using sewage sludge to produce methane gas that can be burned to produce electricity as is happening in Los Angeles? 

In short, the continued land application of untreated sewage sludge is assault on the health of innocent Virginia citizens and our environment!

Anthony Pasciuta Jr.

Commonwealth Coalition

I have read the articles on the fish kill in the Shenandoah River and have seen creeks in my own county go on the impaired list because of pollution. We must for the sake of the watersheds all over this nation understand the disastorous effects of sludge applied to the land. A quote from Dr. Lynton S. Land is emeritus professor of geological sciences at the University of Texas in Austin, and now lives in Virginia. "A Virginia Joint Legislative Audit and Review Commission recently released Report No. 89, "Review of Land Application of Biosolids in Virginia" which was rightly critical of the management of the land application of municipal sewage sludge—biosolids—by the Virginia Department of Health. An Inspector General's Report (2002-S-000004) and a report from the National Academy of Sciences (7-2-02) were similarly critical of the EPA's out-of-date and inadequate management and enforcement policies regarding sewage sludge. The reports concentrate on human health issues and ignore the environmental consequences of nitrogen and phosphorus pollution caused by the land application of sewage sludge. Nobody questions the potential benefits of land-applying animal waste (poultry litter, manure and sewage sludge) to supply nitrogen, phosphorus and other nutrients, to increase soil quality and to reduce the use, and thereby cost, of chemical fertilizer. But the cost to society of the pollution resulting from using such a very inefficient form of fertilizer must also be clearly understood." Recently those on the Potomac River have made steps in the right direction on this issue. WASHINGTON - The U.S. Army Corps of Engineers will spend $96 million to build a new processing facility in Northwest that should put an end to the periodic, massive discharge of sludge into the Potomac River. The 68,559-square-foot residuals-processing facility, slated for 7.4 acres off Little Falls Road near the Dalecarlia Reservoir, immediately north of Sibley Memorial Hospital, should allow the Washington Aqueduct to meet a Clean Water Act permit restricting the expulsion of sediment and aluminum sulfate into the river. The project is being undertaken by the Corps of Engineers, the group that manages the aqueduct. "Should we be using our rivers as sewers?" asked Ed Merrifield, executive director of Potomac Riverkeeper. "The answer is no. >From my perspective, it's a good thing that the stuff isn't going back into the river." We need to seriously address the issue of sludge or be held responsible if we do not.

1) Health problems are well documented, especially for individuals with compromised immune systems, certain kinds of allergies, etc. Just as peanuts don't affect most people, peanuts can kill a select few. The same is true of sludge. Several people are alleged to have been killed. 2) The pharmaceuticals now known to be present in sludge (see research by the United States Geoloical Survey) have unknown effects. Common sense dictates that it is unwise to spread substances on the land when small quantities of them are known to have powerful biologic consequences. Similarly, the antibiotics being spread on the land increase the liklihood that antibiotic-resistent bacteria will evolve. 3) Land application in the name of "free fertilizer" causes massive pollution of Chesapeake Bay. See my article in the December isssue of the"Bay Journal" or the web site www.VaBayBlues.org. The cost to society of the increased pollution far outweighs the cost-savings for a few farmers. No politician can support the land-appliction of sewage sludge and at the same time claim to be in favor of reducing nutrification of Chesapeake Bay. 4) The cost of landfilling the sludge is less than $1.00 per year for each citizen served by a wastewater treatment facility. If done properly, the landfill could generate methane. Burning the organic material in the sludge would not impact global warming because the carbon is not "fossil" carbon, and phosphorus could be recovered from the ash.

That sludge application continues in the face of near destruction of the Chesapeake Bay is incredible. Regulations, standards for enforcement, site practices are trivial questions in the face of complete devastaton of fisheries, oyster reefs and general health of the Bay. The Bay's multi-billion value to the 16 million people living in it's watershead is declining rapidly as the bay edges toward being a gigantic cesspool. Both nutrients and toxics in sludge contribute significantly to bay decline. Sludge caused dead zones when barged out to sea, so politics forced it into land application where it is now making people sick and destroying the local environment. Yeah, we need better regulations, standards for enforcement, and site practices, but the real answer is in finding new uses for sludge that don't pollute the environment. Conversion to fuel comes to mind. The "stuff" needs to be banned now for use in land application.

As a result of sewage sludge being applied to pastureland adjacent to my home in Greene County in August 2005, I lost five weeks of work (organic grower) due to violent nausea due to the odor.  I contracted a respiratory infection which took me five months to get rid of and I am left with allergies for the first time in 71 years.  Despite calls to national, state and local officials, from EPA to health departments, I was told the same thing, "It's safe".  I know better through living experience.

This material is not fertilizer, it is a pollutant.  It needs better monitoring and testing of the sludge itself, before and after it is mixed with all of the imported material and before the product is put on the land.  Heavy metals do not go away. I support any legislation that will put into motion processes that will ascertain the total contents of this material and its affect on human and animal health.

The most distressing part of the spreading of this material near my home was the transfer of the particulate matter being carried by the prevailing wind onto my property.  I grow my food and work my land with no synthetic or organic chemicals of any sort.  I could now be dealing with contaminated soil in which I grow my food.    Would you eat food grown in sludge as it exists currently?

 

 

 

<a href="http://horoskop.smscentar.com/">Dnevni Horoskop</a>

 

http://horoskop.smscentar.com/

As part of the health profession I see to many unknowns about health hazzards. Arsenic ,mercury,carbon tetrachloride,tobacco smoke,asbestos just to name a few all  very safe at one time.Now they are health risk issues. Sometimes in the future exposure to biosolids will be added to the list.We must think long term. 

Too bad for citizens that VDH is political and more concerned about keeping sewer rates low in large cities rather than the health and safety of rural Virginians.  If you have half a brain, you will look specifically at the front page article of the 12/13/06  "News & Advance," where Bedford county neighbors of a  sludge field storage "facility" share their experiences--or should I say horror stories.  It is longer than 750 words so perhaps you won't look at it--but, maybe you will actually let facts and citizen testimonials be your guide in this no brainer of a decision.  I will be happy to send you the link or mail you all the hard copies of the news article--but don't read it before lunch.  VDH has much too cozy a relationship with the sludge industry.  VDH now hires new staff from the sludge industry (Scott Hailey).  They say the more times you tell a lie, the easier it gets.  We'll have to ask Mr. Hailey  if this is true.  Importing sludge is like a cancer for the state--why on earth would we want to sicken citizens so out of state sludge haulers can make  few more bucks.?

The Cornell Waste Management Institute reports that hundreds of sludge-exposed rural people have suffered serious respiratory and gastrointestinal illnesses. Peer reviewed research published in the scientific literature has linked illnesses and deaths to land application. Drinking water sources in New Hampshire, Maine, and other states have been polluted.  Virginia, not the sludge hauler paid for a massive fish kill in a Loudoun County pond due to sludge runoff. EPA, and industry trade groups, such as NEBRA, are ignoring and covering up these reported and documented incidents. Enough is enough.  Why should greed and profits outweigh the health concerns of those rural citizens who are FORCED to live near these dumping grounds.