March 22, 2000
House Committee on Science Hearing on EPA and Sludge Rules
Desired Outcomes of Hearing
The following describes the outcomes
which might flow from this hearing which would address many of
the concerns raised in my testimony and the written materials
I have submitted.
1. Survey sludges in the U.S.
As recommended by National Research
Council 1988 survey was flawed
For additional contaminants such as
surfactants like nonylphenols, brominated dioxins
2. Expand monitoring of land applied
sludges
Routine periodic testing of land applied
sludges for additional parameters beyond the current short list
of regulated contaminants
Increase frequency of testing for smaller
facilities given the variability of sludge quality over time
3. Rework the risk assessment for
land application
Use current probabilistic techniques
such as a Monte Carlo analysis. Use a realistic distribution
for many parameters key to the risk assessment such as:
Diet
Body weight
Groundwater movement
Uptake coefficients
Percent of watershed receiving sludge
Include analysis of impact to farm
family using sludge
Assess impacts from several pathways
simultaneously (eg. Eating sludged vegetables, meat and milk,
breathing and drinking well water in vicinity of application
site, ingesting sludged soil)
Consider revised soil ingestion estimate
(400 vs 200mg/day) and also acute impacts of pica episodes
4. Revise the currently proposed
dioxin standards for land applied sludges
Use probabilistic risk assessment methods
Evaluate non-cancer end points, especially
for developing fetuses and infants
5. Leave states free to adopt more
stringent rules
Cease pressuring states to conform
to the 503 rules
Given the history, this may require
an independent entity to conduct investigations
7. Require labeling of all sludges
and sludge products
Consumers should know what the ingredients
of products they buy are
Consumers should know about the quality
of the product
Consumers should know how to use the
product
8. Prohibit the distribution of
non-"EQ" sludge products to individuals
It is unrealistic to expect home users
to abide by application restrictions which are specified for
"APLR" sludge products. Use of sludges containing the
higher pollutant levels at high rates could be dangerous.
9. Within EPA, separate science/risk
assessment function; regulatory function and; funding of WWTP
function
The present arrangement allows:
Inconsistent risk assessment approaches
in different agency programs
Conflicting interests since the same
section both funds and regulates WWTP
10. Sponsor independent research
on critical issues
See suggested list of research needs
submitted separately
Movement of viruses to groundwater
is key research issue for Class B application
Separate research funding from WEF
11. Keep track of where sludge is
applied
Until we know more about potential
impacts, locations where sludge is applied in bulk should be
tracked. This is needed for possible investigation of problems.
12. Create incentives and programs
to encourage improved sludge quality
Pretreatment programs, which apply to a limited set of dischargers,
have been successful in improving sludge quality in the past.
There are additional contaminants and dischargers which should
be addressed to continue improvements in sludge quality.