Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Biosolids Use Regulations See Virginia Pollution Abatement (VPA) Permit Regulation at 9 VAC 25 - 32 [12 VAC 5 ‑ 585]
Action Enforcement and Site Management
Stage Proposed
Comment Period Ended on 12/15/2006
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12/8/06  12:00 am
Commenter: Barbara L. Rubin

Enforcement and Site Management
 
 

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General Reports and two National Academies of Science Reports all found the science behind the sludge rule weak and out of date.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

CommentID: 347