2005 – OFFICE OF INSPECTOR GENERAL – EPAs PRETREATMENT PROGRAMS AT RISK – TOXIC INDUSTRIAL POLLUTANTS STILL BEING DISCHARGED TO POTWS http://www.epa.gov/oig/reports/2004/20040928-2004-P-00030.pdf September 28, 2004

[before you read what EPA is not doing about the toxic chemicals pouring into America’s POTWs, ask yourself HOW MANY CHEMICALS ARE IN PLAY IN THE USA RIGHT NOW? HOW ABOUT 93,564 ?? “The Substance Registry System (SRS) is the Environmental Protection Agency's (EPA) central system for information about regulated and monitored substances. The system provides a common basis for identification of chemicals, biological organisms, and other substances listed in EPA regulations and data systems, as well as substances of interest from other sources, such as publications. The SRS supports and conforms to EPA's Chemical Identification Data Standard and the EPA's Biological Identification Data Standard. The SRS is a part of the centralized Systems of Registries (SoR), which provides access to the Agency's core registry systems. “ http://oaspub.epa.gov/srs/intro$.startup

“What does the SRS contain?

Number of substances currently in the SRS: 93,564 Number of submitting organizations represented in the SRS: 38 Number of information resources included in the SRS: 716 The SRS contains substance identification information and listings of substances in regulations and Agency programs. Using the SRS Search, you can search for substances by common identifiers such as Chemical Abstracts Service Registry Number (CASRN) and name (systematic or scientific). Each substance is linked to regulations in which it is referenced and program systems where it has been reported. Searches can also be done by specific regulation or program system. “ or try this web page which says there are millions of chemicals out there !! http://www.cas.org/cgi-bin/regreport.pl

CAS is the leading provider of organic, inorganic, and biosequence substance information.

1 Date Fri Feb 4 21:10:22 EST 2005 Count 25,273,887 organic and inorganic substances 54,419,609 sequences CAS RN 825595-30-0 is the most recent CAS Registry Number

CAS also provides specialized databases of chemical reactions, regulated chemicals, commercially available chemicals and Markush substance information.

CASREACT® 8,840,971 Single- and multi-step reactions CHEMLIST® 235,162 Inventoried/regulated substances 8,354,696 Commercially available chemicals

CHEMCATS (Chemical Catalogs Online), produced by CAS, is a catalog database containing information about commercial available chemicals and their worldwide CHEMCATS® suppliers. CHEMCATS contains:

 A list of over 8 million commercially available chemicals - 1/05

MARPAT® 568,896 Searchable Markush structures

The excerpts below from EPA’S OIG Report demonstrate why Caroline was so right when she said it is absolutely impossible to even attempt to know the toxic constituents in a load of sewage sludge biosolids:

“Those of us who are experts, or have worked with experts for a long time have concluded that it is IMPOSSIBLE to control sludge quality from industrialized urban centers. Hale and others estimate urban sludges contain tens of thousands chemical compounds. Such a mixture can NEVER be tested for even 1/100th of the compounds. Sometimes the parent material is not nearly as toxic or persistent as the break down product (nonylphenols). Because different industries dump their waste at different times and in varying quantities into sewers, testing would have to be done EVERY DAY for every load of sludge for all contaminants which simply is impossible. And as the NAS

2 report says, even if this were possible, you still would not know the total hazard of sludge because you are dealing with a complex mixture and are ignoring interactions.”

EPA OIG REPORT SEPTEMBER 2004 ON PRETREATMENT http://www.epa.gov/oig/reports/2004/20040928-2004-P-00030.pdf

EPA Needs to Reinforce Its National Pretreatment Program - Report No. 2004-P-00030 - September 28, 2004 http://www.epa.gov/oig/reports/2004/20040928-2004-P-00030.pdf

Summary: OFFICE OF INSPECTOR GENERALCatalyst for Improving the Environment Evaluation Report EPA Needs to Reinforce Its National Pretreatment Program Report No. UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D. C. 20460OFFICE OFINSPECTOR GENERAL

5 of 57 "Preventing industrial pollutants from interfering with wastewater treatment facility operations or passing through facilities untreated into water bodies are functions of EPA's pretreatment program. It is a core part of the Clean Water Act's National Pollutant Discharge Elimination System (NPDES) program.

The Agency considers the pretreatment program successful in reducing discharges of harmful pollutants, and this has resulted in less resources and attention being directed toward this program in recent years. However, Toxic pollutants are still being transferred to sewage treatment plants, and the impact to human health and the environment of some of these pollutants may still not be known."

"The reductions in industrial waste discharges to the nation's sewer systems that characterized the early years of the pretreatment program have not endured, according to EPA published data compiled from information provided by industrial facilities. Since the middle of the 1990s, there has been little change in the volume of a broad list of toxic pollutants transferred to POTWs or in the index of risk associated with these pollutants.

As a result, the performance of EPA's pretreatment program, which is responsible for controlling these discharges, is threatened and progress toward achieving the Congress' Clean Water Act goal of eliminating toxic discharges that can harm water quality has stalled.

The curtailing of the early gains may be explained in part by two factors: (1) dischargers that developed systems in response to EPA's initial program requirements have not enhanced their pretreatment systems in recent years, and (2) the rate at which EPA has been issuing effluent guidelines dramatically declined since 1990."

6 of 57 "THE DIFFERENCE BETWEEN THE PROPORTION OF POTWs with approved programs that discharged to an impaired water (25 percent) was even smaller compared to the proportion of POTWs without approved programs that discharged to an impaired water (60 percent). One possible explanation is that EPA Regions and State agencies that are supposed to act as control authorities for POTWs without approved programs do not have standards for overseeing industrial users discharging to these POTWs. Although EPA was working

3 on necessary guidance for these Regions and States , the project was put on hold due to other priorities ."

"Without more visible leadership from Headquarters, improved programmatic information, and the adoption of results-based performance measures, EPA's pretreatment program is at risk of losing the gains it made in its early years. The leveling off of those early gains, coinciding with EPA's diminishing program emphasis, paints a picture of a program at risk.

"Headquarters has delayed finalizing guides and regulations intended to update the pretreatment program by not allocating sufficient resources or requesting budget increases for additional pretreatment resources. Additionally, results-based performance measures on pretreatment program activities have not been developed partially due to the lack of adequate, accessible data. As a result, POTWs' pretreatment programs may not be as effective in protecting environmental quality or worker health and safety as they could be, and EPA cannot assess the effectiveness of its pretreatment program." pg 11 of 57 "The focus of the Environmental Protection Agency (EPA) clean water program is reducing pollutant loadings. There are hundreds of thousands of industrial users in the United States, and many may discharge toxic pollutants to wastewater facilities."

"The Agency considers the pretreatment program successful in reducing discharges of harmful pollutants to wastewater facilities and their receiving waters. This success has resulted in less resources and attention directed toward this program in recent years, even though toxic pollutants are still being transferred to sewage treatment plants." pg 15 of 57 "The reductions in industrial waste discharges to the nation's sewer systems that characterized the early years of the pretreatment program have not endured according to EPA published data compiled from information provided by industrial facilities. Changes in the amount of pollution that industrial users discharge into sewers is a good indication of how successful this program has been. Measured by volume as well as an index of risk associated with a broad list of toxic pollutants, there has been little change since the middle of the 1990s.

"As a result, the performance of EPA's pretreatment program, which is responsible for controlling these discharges, is threatened and progress toward achieving the Congress' Clean Water Act goal of eliminating toxic discharges that can harm water quality has stalled."

PG 16 OF 57 - Regarding EPA's Toxics Release Inventory - "Transfer of Pollutants: The transfer of pollutants to POTWs decreased by approximately 50 percent from 1987 to 1995, then climbed up again by approximately 100 percent from 1995 to 2001. Figure 2((A) shows that the increase was the result of requirements for the reporting of additional pollutants starting in 1995. Pollutants reported consistently from 1987 to 2001 show a leveling off in transfers since 1995." (but no decline !!)

"Nitrate compounds - a pollutant that POTWs incidentally treat - were responsible for the significant increase in transfers since 1995."

4 [Helane’s note: see chart which shows increase of toxic chemicals to POTWs from about 160 million pounds in 1995 to over 320 million pounds in 2001 -- and still, hundreds if not thousands of toxic industrial chemicals in use today are not included in the EPAs very limited TRI list of under 700 chemicals.

[TRI Chemicals - requires reporting on less than 700 toxic industrial pollutants in common use in USA . . . . . http://www.epa.gov/tri/chemical/

The current TRI toxic chemical list contains 582 individually listed chemicals and 30 chemical categories (including 3 delimited categories containing 58 chemicals). If the members of the three delimited categories are counted as separate chemicals then the total number of chemicals and chemical categories is 667 (i.e., 582 + 27 + 58). This page contains links to information on TRI chemical lists, tri pbt chemicals, list changes, toxicity, regulatory program information, fact sheets, and chemical specific guidance documents.

Note: Three chemicals on the current list (methyl mercaptan, hydrogen sulfide, and 2,2-dibromo-3-nitrilopropionamide) are under administrative stays and are not currently reportable. ]

pg 17 of 57: "After a significant decrease from 1987 to 1988, the risk associated with pollutants tracked in TRI since 1987 shows no apparent trend, while the risk associated with pollutants added since 1995 has been increasing. We used EPA's Risk-Screening Environmental Indicators to assess the potential impact related to oral ingestion toxicity of the industrial releases to POTWs. Our analysis considered the following information: The amount of chemical released, the toxicity of the chemical, its fate, and transport through the environment."

"Figure 2(C) shows that the risk associated with the 1987 chemicals was reduced by 60 percent from 1987 to 1988. Risk showed a further decrease in 1995, with some increases in 1998, 1999, and 2001. This figure does not include individual discharges that could material affect the results of our review (such as a single plant in Tennessee discharging thorium dioxide, which significantly increased the risk during 1995 and 1996; thorium dioxide is a radioactive substance that has the highest toxicity weight amount the TRI pollutants."

"Our analysis of the 1995 pollutants showed the risk of these pollutants increasing even when we eliminated single facilities discharging highly toxic pollutants that caused significant increases in 2000 and 2001." pg 18 of 57 "Figure 2(D) Risk associated with 1995 pollutants increased." [see chart "Trends in Risk" increased from Factor in millions –from about 58 million in 1995 to almost 80 million in 2001."

5 "Enforcement of Regulations as Motivating Factor - "Prior to 1991, when there was the first drop in transfers, EPA had issued 49 effluent guidelines; since that time to 1999, only 7 new and revised effluent guidelines were issued. This may explain the initially significant drop in pollutant transfers and then a leveling off period." pg 19 of 57 "The official (of the Minnesota firm) noted the company still uses tin/lead solder because it is requested by their customers and will continue to use it unless it becomes illegal."

"A representative for an Indiana firm stated that when finally motivated the company to eliminate the use of chromium was to address a Safe Drinking Water Act violation caused by its discharge of fluoride to its local POTW. This company and others were allowed to discharge fluoride to the POTW in accordance with the local pretreatment program. However, the fluoride was discovered downstream to be in excess of drinking water standards." pg 19 of 57 “ The reduction in transfers of toxic pollutants to POTWs has not been reduced since the mid 1990s . The reduction of risk for oral ingestion for some of these pollutants shows no apparent trend indicative of progress. Significant reductions in transfers were seen in prior years when EPA was active in establishing its pretreatment program and issuing numerous effluent guidelines.:

"EPA needs to take stock of its pretreatment program to determine how it will eventually fully meet Congress' goal of the elimination of toxic discharges to the nation's waters. Otherwise, wastewater treatment facilities remain vulnerable to industrial waste discharges that can disrupt plant operations or pass through to receiving waters, resulting in poor water quality and potential harm to human health and the environment." pg 32 of 57 "EPA began projects to further develop and modify its pretreatment program, but in recent years has not devoted sufficient resources to complete the projects, as shown by the following examples. For the period 1995 to 2000, EPA did not request additional funding for its pretreatment program."

"In 1995, the Office of Water developed options and a basic plan in response to the Association of Metropolitan Sewerage Agencies' (AMSA's) concern of excessive administrative burdens. EPA issued its proposed streamlining rule in 1999 but had still not finalized it by 2004."

"EPA issued guidance in 1987 to assist POTWs to develop local limits. In 1997, the Agency started work to revise this guidance because the 1987 inhibition and removal efficiency data did not reflect the current diversity of POTW wastewater treatment utilized. The guide was finalized in July 2004"

"EPA formed a workgroup in 2000 to address industrial user discharging to POTWs without approved pretreatment programs. The group started to develop guidance 2001, but that work has been put on hold."

pg 33 of 57 " EPA does not have the information systems necessary to effectively measure, analyze, demonstrate, and improve program performance. EPA collects influent, effluent,

6 and biosolids, data, but it is not uniformly entered into EPA's Permit Compliance System (PCS). Also, because EPA has not established results-based measures for its pretreatment program (as noted in the next section), data collection and systems are not geared toward providing EPA with an analysis of program progress. Without sufficient data to show the gains made by its pretreatment program, EPA leaves this program vulnerable to future budget cuts." (probably exactly what they want !!)

"Our efforts to utilize PCS (Permit Compliance System) and annual pretreatment reports prepared by POTWs to determine trends in discharges of metals to and from 10 POTWs were largely unsuccessful (see Appendix F). We found that PCS was not a good source of data for evaluating trends for industrial pollutants because: (1) only 3 of the 10 Regions input influent data into PCS; (2) NPDES permits did not always require the monitoring of industrial pollutant in effluent; and (3) Sludge data in PCS is limited because EPA did not consider its entry as a high priority. (Some Regions indicated that sludge data is entered into EPA's biosolids database but even this was not consistent."

pg 36 of 57 "The Water Permits Division Director said that the pretreatment program's impact on the environment would be evaluated as part of EPA's watershed program. However, EPA will still have a challenge in showing results on a watershed basis because of a lack of quality and consistent data. Regardless, we believe that EPA also needs to evaluate the pretreatment program on its own as well as part of a watershed, since the watershed approach will not assist the Agency in identifying specific industrial problems and trends." pg. 36 of 57 "Conclusion: The pretreatment program is at risk of losing the gains it has made if EPA does not become more vigorous in setting national policy and developing program measures that can adequately document the program's progress."

" Considering the fact that the pretreatment program has not made significant progress in the past 10 years , now is the time for EPA to take stock of its pretreatment program. It needs to develop goals on how to further reduce toxic transfers to POTWs and the risk associated with those pollutants so that it can fully realize Congress' goal -- the elimination of toxic pollutants to the nation's waters."

pg. 37 of 57 "While Headquarters may not directly determine Regional resources levels, it does have powerful, indirect influence. Regional staff told us that their offices usually take the lead from Headquarters when determining the resources to allocate to a program . If Headquarters places less emphasis on a program, the Regions will follow." pgs 43 - 44 of 57 - "All the POTWs with approved programs said they sampled and inspected at least annually. All the POTWs without approved programs said they inspected their industrial users but only 70 percent described formal, annual inspection programs. Only 50 percent said they sampled on an annual schedule. Regional offices and State Agencies will act as control authorities for POTWs without approved pretreatment programs, but not all the Regions and States were able to carry out inspection and sampling responsibilities due to the large universe of significant industrial users spread out over a State and limited staffing."

7 [Helane’s notes: pg. 49 of 57 – CHART indicates an appalling lack of oversight and control over significant industrial dischargers of toxic pollutants into sewage treatment plants. pg. 51 of 57 – CHART indicates an appalling lack of information on the pollutants being discharged into POTWs and no PCS (Permit Compliance System) information ...... ]

EPA COPPING OUT ON ANY RESPONSIBILITY: pg 45 of 57 :In accordance with NPDES and Pretreatment regulations (40 CFR 122 and 123, and 403 respectively), decisions on individual POTW NPDES permitting requirements are the responsibility of the permitting authority, determined on a case-by-case basis. The pretreatment regulations do not require EPA to inspect or sample SIUs (significant industrial users who discharge large amounts of toxic chemicals to POTWs.)"

" . . . decisions on individual POTW NPDES permitting requirements, particularly any increase in reporting beyond what is already imposed by the regulations, are the responsibility of the permitting authority, determined on a case-by-case basis. Finally, POTWs without approved programs would have regulatory authority to take enforcement action ONLY if authorization is provided by the State Codes."

FROM RECENT HEADLINES – WHAT’S BEING DUMPED INTO POTWS AND ENDING UP IN THE SLUDGE BEING DUMPED ON AGRICULTURAL LAND IN RURAL AMERICA ??

ALABAMA – TEFLON - http://www.decaturdaily.com/decaturdaily/news/050204/teflon.shtml

TEFLON PERFLUOROOCTANOIC ACID PFOA IN THE SLUDGE - AND FROM LANDFILL LEACHATE SENT TO POTW NOT ON EPA’S TRI LIST OF REPORTABLE CHEMICALS ......

DU considers water sampling for Teflon

By Martin Burkey DAILY Staff Writer [email protected] · 340-2441

Decatur Utilities managers are considering whether they need to test their tap water for Teflon-related chemicals after an environmental group Wednesday asked the state to test the water.

After seeing the letter from the Washington-based Environmental Working Group on Wednesday, DU officials are evaluating whether they may need to do their own testing, said Gary Borden, gas, water and

8 waste-water manager for the utility. Four-year-old studies by one Decatur company showed no evidence of the chemicals in tap water, although it found higher amounts in sewage sludge and landfill runoff.

Water treatment sludges are commonly discharged into local POTWs:

TRI tests for chlorine in wastewater – but not trihalomethanes which are a carcinogenic combination of 4 chemicals: chloroform, bromodichloromethane, dibromochloromethane, and bromoform.

NEW HAMPSHIRE JANUARY 2005

Feds say Exeter violated water standards

By TERRY DATE

Democrat Staff Writer

EXETER — The town manager announced on Monday that in June Exeter violated the federal drinking water standard for the disinfection byproducts known as trihalomethanes.

Meanwhile, a nearby town, Newmarket, has also experienced problems with the byproducts.

Some people who drink water with excessive levels of trihalomethanes over many years may experience problems with their liver, kidneys and central nervous system, and may have an increased risk for cancer, said Town Manager George Olson.

Trihalomethanes in Drinking Water

SPECIAL REPORT March 2002

Trihalomethane is a by-product that comes from chlorination.

It is one of the toxic carcinogens created when Chlorine reacts with organic matter in water. When this matter decays - somewhat like compost materials (leaves, bark, sediments) Trihalomethanes are formed. This includes chemicals called chloroform, bromoform and dichlorobromethane. Even in small amounts they are all very carcinogenic. (DRINKING WATER SLUDGE IS DISCHARGED INTO SEWAGE TREATMENT PLANTS)

VERMONT –(DRY CLEANING WASTES DISCHARGED TO SEWERS END UP IN GROUNDWATER)

9 http://www.timesargus.com/apps/pbcs.dll/article?AID=/20040918/NEWS/409180382/1002

Williamstown water called undrinkable

September 18, 2004

By David Gram Associated Press

MONTPELIER — Twenty-one years after Vermont Health Department tests first found pollution around a Williamstown dry-cleaning plant, the state is moving to declare groundwater in the area undrinkable.

The state Department of Environmental Conservation is accepting public comments until next Friday on its proposal to reclassify the groundwater under 85 acres around the UniFirst Corp. facility on Hebert Road in Williamstown.

The state Department of Health first tested groundwater around UniFirst in 1983 and found it contained three forms of a class of chemicals called chloroethylenes, which are used as solvents in dry cleaning.

One of the chemicals, PCE, turned up in groundwater tests at 88,000 micrograms per liter. Another, TCE, registered at 6,290. The state safety standard for both is 5 micrograms per liter. Tests last October found PCE at 38 mg/liter and TCE at 26 mg/liter.

POLYBROMINATED DIPHENYL ETHERS – BROMINATED FLAME RETARDANTS – TURNING UP IN SIGNIFICANT CONCENTRATIONS IN SEWAGE SLUDGE AND SURFACE WATERS – NOT INCLUDED IN EPA’S TRI LIST OF CHEMICALS TO REPORT

RC Hale, MJ La Guardia, EP Harvey, MO Gaylor, T Matteson Mainor and WH Duff. 2001. Flame retardants: Persistent pollutants in land-applied sludges. Nature 412: 140 - 141

quick background on PBDEs Press coverage

Hale et al. report high concentrations of brominated diphenyl ethers (BDEs) in sewage sludge being applied as fertilizer to US farmland. They also report high levels of BDEs in fish in Virginia.

This family of compounds is widely used as a flame retardant in various industrial and consumer products. According to Hale et al., the most toxic BDEs are molecules containing 4-6 bromine atoms. Those with more than one bromine are "polybrominated," or PBDEs. These forms of BDEs are found increasingly in people and wildlife around the world. In general, they are highly persistent and bioaccumulative. Recent toxicological studies demonstrate that some of them are powerful hormone disruptors, particularly capable of disrupting thyroid hormone.

10 surely this is yet another reason why PBDE contaminated sewage sludge should not be topdressed on hay fields, dairy pastures and grazing lands.

http://www.ars.usda.gov/research/publications/Publications.htm?seq_no_115=164265

Research Project: DIOXINS AND OTHER ENVIRONMENTAL CONTAMINANTS IN FOOD

Location: Animal Metabolism-Agricultural Chemicals Research

Title: POLYBROMINATED DIPHENYL ETHERS IN MEAT SAMPLES COLLECTED FROM SUPERMARKETS ACROSS THE US

Author Huwe, Janice Submitted to: International Workshop On Brominated Flame Retardants Publication Acceptance Date: May 5, 2004 Publication Date: June 7, 2004 Citation: Huwe, J.K. 2004. Polybrominated Diphenyl Ethers In Meat Samples Collected From Supermarkets Across The Us. [abstract] Abstracts Of The 3rd International Workshop On Brominated Flame Retardants, June 6-9, 2004, Toronto, On, Canada. Pp. 41-44. Interpretive Summary: Polybrominated diphenyl ethers (PBDEs) are flame retardants which are increasing in the environment and in humans. Because these compounds show chemical similarities to other persistant pollutants, it is hypothesized that human exposure may also occur by a similar route, namely through the food supply.

Concentration of the emerging issue contaminant, polybrominated diphenyl ethers (PBDEs), was also traced from its apparent entry into this ecosystem from about 1980 until 1999. Time trends for the PBDEs were increasing exponentially at all of the sites, with concentration doubling times varying from 1.58 to 2.94 years.

Sent: Wednesday, January 26, 2005 5:46 PM Subject: Water and Wastewater Newsletter No. 220 – ANOTHER TOXIC CHEMICAL NOT INCLUDED IN TRI - TRICLOCARBAN

Read online at: http://www.waterandwastewater.com/www_services/newsletter/january_24_2005.htm

Toxic : Anti-Bacterial Additive Widespread In U.S. Waterways

Baltimore, MD -- Many rivers and streams in the United States are believed to contain a toxic antimicrobial chemical whose environmental fate was never thoroughly scrutinized

11 despite large-scale production and usage for almost half a century, according to an analysis conducted by researchers at the Johns Hopkins Bloomberg School of Public Health.

The chemical, triclocarban, has been widely used for decades in hand soaps and other cleaning products, but rarely was monitored for or detected in the environment. The new findings suggest that triclocarban contamination is greatly underreported. The study is published in the current online edition of Environmental Science & Technology, a peer-reviewed journal of the American Chemical Society.

The nationwide assessment of triclocarban contamination is based in part on an analysis of water samples collected from rivers in and around Baltimore, Md., as well as from local water filtration and wastewater treatment plants.

CALIFORNIA - http://www.latimes.com/news/printedition/california/la-me- water27dec27,1,254426.story?coll=la-headlines-pe-california Toxins Harm Orange County Water, Suit Alleges District says companies didn't clean sites in Anaheim and Fullerton where the drinking supply for 2 million could be contaminated.

By Sara Lin Times Staff Writer

December 27, 2004

The Orange County Water District has sued a group of mostly large industrial manufacturers that it contends has failed to clean up toxic chemicals that have seeped into the ground and threaten the water supply for more than 2 million residents.

Though none of the chemicals was detected in county drinking water, routine monitoring near former industrial sites in Fullerton and Anaheim turned up traces of the solvent perchloroethylene, or PCE, a suspected carcinogen.

------

CALIFORNIA – perchloroethylene DUMPED INTO THE SEWERS

Sent: Saturday, January 22, 2005 6:39 PM Subject: Lodi Newspaper to Pay City $2 Million in Toxics Suit

http://www.latimes.com/news/local/la-me-sbriefs22.6jan22,1,5495848.story?coll=la-headlines- california IN BRIEF / LODI

12 Newspaper to Pay City $2 Million in Toxics Suit

From Times Staff and Wire Reports

January 22, 2005

A local newspaper has agreed to pay the city $2 million to settle a claim that it added to the toxic chemicals that have fouled the city's soil and groundwater.

The owners of the Lodi News-Sentinel said that although it would be hard to write the check, they hoped the decision would help the city.

Lodi sued the newspaper and 14 other businesses in federal court in 2000, charging them with polluting the ground with the suspected carcinogen perchloroethylene by either dumping it onto the ground or down sewer drains.

MICHIGAN – FALSIFYING THE SEWAGE TEST RESULTS http://www.mlive.com/news/bctimes/index.ssf?/base/news-4/110632591227740.xml Sentence upheld for former wastewater super

Friday, January 21, 2005 By Crystal Harmon TIMES WRITER A judge has upheld the sentence, already served, of the former superintendent of the Bay City Wastewater Treatment Plant for alleged pollution of the Saginaw River. U.S. District Judge David M. Lawson resentenced Michael J. Kuhn to six months in a halfway house, six months of home confinement and $6,000 in fines. Federal prosecutors were seeking a higher sentence, but Lawson's ruling means Kuhn will serve no additional time. Kuhn was convicted by a jury in 2001 of causing sewage sludge to flow into the Saginaw River in 1996 and of falsifying test results of wastewater samples in 1997.

CALIFORNIA AND OTHER STATES – PERCHLORATES FROM ROCKET FUEL SHOWING UP IN WATER SUPPLIES - PERCHLORATES ARE NOT A TRI REPORTABLE CHEMICAL – IF IT IS IN THE WATER, IT’S IN THE SLUDGE . . . . .

JAN. 14, 2005

ALERT: STOP THE MILITARY INDUSTRIAL COMPLEX FROM > POLLUTING OUR FOOD & WATER This week the National Academy of

13 > Sciences (NAS) released its long awaited report on perchlorates, a > byproduct of rocket fuel that has contaminated water, vegetables, > and dairy products across the United States. Perchlorates, > recklessly discharged into streams and rivers near military bases > and weapons manufacturing facilities, have contaminated drinking > water in 35 states, and have been detected in measurable amounts in > 93% of lettuce and milk samples as well, including organic products. > The government funded NAS study has found that perchlorates are > roughly ten times more toxic to humans than the Department of > Defense has been claiming. Perchlorates can inhibit thyroid > function, cause birth defects, and lower IQs. Perchlorates are > considered particularly dangerous to children. In monitoring wells > across the U.S., scientists have found perchlorate levels as high as > 30,000 times what the NAS report indicates would be "safe" exposure. > Due to pressure exerted on Congress by military officials and > defense contractors, there are currently no federal restrictions or > tolerance levels regulating perchlorates. To date, only one Senator, > Diane Feinstein from California, has had the backbone to propose > legislation that would clean up perchlorate pollution and make the > military (and other perchlorate polluters) pay for this clean-up. > Please send a quick letter urging Congress to support Senator > Feinstein's (CA) bill to create federal perchlorate safety > regulations, and to allocate funding for its clean-up. Take action > here: [5]http://www.organicconsumers.org/perchlorate.htm

Since the issuance of DWP’s EIR on the treatment of reclaimed water for potable purposes in 1991, there have been a number of findings of contaminants and pollutants with potentially devastating impacts on water quality. These include MTBE, Perchlorates, Arsenic, and Hexavalent Chromium or Chrome 6 (Cr VI) among others.

“The recent discovery” of Cr VI in drinking water sources is more correctly understood as the recent acknowledgement of the presence of Cr VI for over forty years as a poison in various sources of water. Some of these sources were and continue to be destined for drinking and cooking usage. The Chromium problem provides a good model for the kinds of problems that must be dealt with for each contaminant and each pollutant involved in the “toilet to tap water” project.

***********************************************************

Subject: CANADA RADIOACTIVE SLUDGE LEAKY NUKE CHALK RIVER - RADIONUCLIDES MAGNIFY IN FOOD CHAIN - CONCENTRATE IN FISH AND MUSSELS

http://www.canada.com/ottawa/ottawacitizen/soundoff/story.html?id=e830a84f-4f9f-4a30-a441- ae1f4528aa3e Stop 'outrageous' nuclear waste dump Come clean on Chalk River, firm told

Neco Cockburn

The Ottawa Citizen

Sunday, January 16, 2005

14 Environmentalists yesterday called on Atomic Energy of Canada Ltd. to come clean about its waste management practices after it was revealed the company broke a promise to stop dumping radioactive and chemical waste at Chalk River.

"Unfortunately, it isn't a surprise. These types of infractions on the public trust seem to be standard practice for AECL," said Shawn-Patrick Stensil, director of atmosphere and energy for the Sierra Club of Canada.

Regulators from the Canadian Nuclear Safety Commission were outraged at a meeting last week after they discovered that AECL continued to dump tainted sludge -- containing what are believed to be small amounts of radioactive and chemical material -- into sandy trenches at Chalk River, in Renfrew County. The company had promised in 1997 to stop dumping the untreated sludge.

AECL has since denied its dumping had continued in secret, saying it believed the practice was out in the open. But Mr. Stensil and others called for an independent public audit into waste materials found at Chalk River, and the cost of cleaning up the site, which is about two hours west of Ottawa.

NEW HAMPSHIRE – SOME SLUDGES CONTAIN CHEMICAL CONCENTRATIONS SO HIGH THEY VIOLATE STATE BROWNFIELD SOIL CLEAN UP STANDARDS – INCLUDING NASHUA – AND INCLUDING ACETONE WHICH IS ANOTHER CHEMICAL IN SLUDGE IN HIGH CONCENTRATIONS WHICH IS NOT REPORTABLE UNDER EPA’S TRI

and some of the exceedances are quite large, such as the toxic pollutants in Nashua, NH sludge:

TESTS results in DES files indicate NASHUA sludge exceeds the S-1, S-2, S-3 soil standards, as follows:

Carbon Disulfide - 1.7 ppm S-1, 2 and 3 soil standard - 0.4 ppm

Acetone - 270 ppm S-1, 2 and 3 soil standard - 9 ppm

2-Butanone (MEK) - 77 ppm S-1, 2 and 3 soil standard - 2.0 ppm

4-Methylphenol - 270 ppm S-1, 2 and 3 soil standard - 5.0 ppm

COLORADO – GARBAGE SOUP FROM LANDFILLS TO POTWS

http://www.dailycamera.com/bdc/county_news/article/0,1713,BDC_2423_3457077,00.html Modern landfill a 'dry tomb' for organic materials

Mix of bacteria, trash, water makes 'garbage soup'

15 By Todd Neff, Camera Staff Writer January 9, 2005

Two-thirds of what ends up in landfills is organic: paper, yard waste, food, wood and textiles.

In supermarkets, "organic" is good. In landfills, it's a problem.

Organic materials are the great villain of the waste stream. When moisture, trash and bacteria combine, they create leachate, or "garbage soup," capable of dissolving toxic metals such as those found in discarded batteries and electronics. They also produce methane-rich landfill gases that, in addition to stinking regally, may contain volatile organic compounds known to cause cancer in heavy doses.

Twenty years ago, there were some 10,000 landfills in the United States — then best known as local dumps. Water rained in and, for between 30 and 50 years, leachates brewed and seeped from thousands of dumps across the country.

Many, like the 80-acre Marshall Landfill northwest of Superior in Boulder County, threatened water supplies.

That changed in 1991, when the Environmental Protection Agency instituted what's known in the trash business as "Subtitle D," a section of the Resource Conservation and Recovery Act regulating municipal solid waste. It established national standards for landfills, requiring waste companies to install pollution control measures before receiving a license.

So modern "dry-tomb" landfills are a relatively recent invention. Today's landfills must have clay basins fully protected by plastic liners, pipes to collect leachate for pumping to a sewage-treatment facility, monitoring wells outside the basin to make sure there's no leakage, and, once the landfill is full, a plastic liner, fill and soil on top.

WASHINGTON

. . thus indicating that there are chlorinated solvents in sewage sludge ! . . . .

http://www.iol.co.za/index.php?set_id=14&click_id=143&art_id=qw1105073464966B252

Pollution-eating bugs found in sewage sludge

January 07 2005 at 10:51AM

Washington - A pollution-eating bacteria first found in sewage sludge may have evolved its talents in response to human contamination of the environment, researchers said on Thursday.

16 They published the genetic sequence of the bug, called Dehalococcoides ethenogenes Strain 195, and said it showed some surprising flexibility.

"The genome sequence contributes greatly to the understanding of what makes this microbe tick and why its metabolic diet is so unusual," said Rekha Seshadri of The Institute for Genomic Research in Maryland, who helped lead the study.

D. ethenogenes, discovered by a team at Cornell University in New York, is being used at 17 polluted sites in 10 states.

'There is a Different strains break down perchloroethylene or PCE, a chlorinated pressing need for solvent used for dry cleaning; trichloroethylene, used to clean metal parts; chlorobenzenes, used to produce the now-banned pesticide DDT; and new techniques to polychlorinated biphenyls or PCBs, compounds that were once used as clean up such coolants and lubricants in transformers. pollutants' "Because chlorinated solvents have polluted so many water sources, there is a pressing need for new techniques to clean up such pollutants," said John Heidelberg of The Institute for Genomic Research, who has helped decode the genomes of other pollution-eating bacteria including the radiation-loving Deinococcus radiodurans.

The researchers, including teams at Cornell, Johns Hopkins University and Technical University in Berlin, found genes for 19 different reductive dehalogenases, enzymes that help D. ethenogenes microbe "breathe" chlorinated solvents.

It has clusters of genes called mobile genetic elements, said Cornell professor of microbiology Stephen Zinder, who named the bacteria after it was found in a sewage treatment plant.

"Just by picking up these mobile genetic elements from other bacteria, Dehalococcoides strains seem able to adapt and to take advantage of opportunities as they present themselves," Zinder said in a statement.

The researchers said their findings suggest the bacteria may have developed the ability to munch chlorinated solvents fairly recently, the researchers said.

NEBRASKA - INDUSTRY ILLEGALLY DUMPING TOXIC SOLVENTS POLLUTANTS INTO THE GROUND - [These are the same solvents dumped into sewage treatment plants under NPDES permits)

Web-Posted Dec 18, 2004 Federal lawsuit filed against CNH Suit seeks damages over contamination from industrial solvents

By Tracy Overstreet

17 [email protected]

"Relief."

That's what Grand Island homeowner Joan Schwan felt Friday knowing that a federal lawsuit was filed on behalf of 176 people whom plaintiffs believe have been hurt or killed by contamination from industrial solvents.

"This might be a beginning of getting this all resolved," Schwan said.

The suit was filed Friday in Lincoln against local combine manufacturer CNH America and its predecessors.

The 34-page lawsuit seeks a jury trial before U.S. District Judge Richard Kopf and wants past and future damages for everything from mental and medical problems, lost wages, loss in property value and the costs to property owners for procuring alternative water sources.

It alleges that CNH, and the predecessor companies that operated the plant at 3445 W. Stolley Park Road in Grand Island since 1965, contaminated the soil, air and groundwater with chemicals it used in industrial metal cleaning, finishing and degreasing equipment, painting and the manufacturing of agricultural equipment.

Those chemical contaminants include trichloroethylene (TCE); tetracholorethylene (PCE or perchloroethylene); 1,1,1-trichloroethane (TCA or methyl chloroform); 1,1 dichloroethane; 1,2 dichloropropane; zinc; chlorothane; copper; napthalene; toluene; xylenes; 1,1 dichloroethene; acetone; antimony; arsenic; barium; beryllium; cadium; chromium; nickel; and other synthetic and petroleum-derived products.

The suit alleges that the company buried drums filled with the contaminants, which then seeped from the drums; and that contaminants were and are being discharged into an unlined pond and unlined pits on CNH property.

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Water Quality Research Journal of Canada, 37(4): 681-696 (2002)

18 http://www.cciw.ca/wqrjc/37-4/37-4-681.htm

Organic Contaminants in Canadian Municipal Sewage Sludge. Part I. Toxic or Endocrine-Disrupting Phenolic Compounds

Hing-Biu Lee* and Thomas E. Peart

Aquatic Ecosystem Protection Research Branch, National Water Research Institute, Environment Canada, 867 Lakeshore Road, Burlington, Ontario L7R 4A6

Abstract

The occurrence of toxic or endocrine-disrupting chemicals such as nonylphenol ethoxylates (NPEO), 4-nonylphenol (NP), 4-tert-octylphenol (OP), bisphenol A (BPA), triclosan (TCS), pentachlorophenol (PCP), hexachlorophene (HCP), and tetrabromobisphenol A (TBBPA) in 35 sewage sludge samples collected from cities across Canada is documented.

19