[USCC] Compost Digest, Vol 29, #9--energy conversion

[Edo McGowan]

Al and Rufus, to continue with our conversation. Al, you state, quite incorrectly in at least two critical areas that “Elliot hit the nail on the head by emphasizing the enormous amounts of biosolids-based composts that have been produced and uccessfully [sic] marketed and used with superb results without ONE DOCUMENTED human health impact reported.” 

First, as you may well know, this information by Elliott attributed to me had nothing at all to do with me or my writing—I did not send it out; funny, however, that you would have caught it so rapidly. Second, if one were to actually reexamine the peer-reviewed literature there ARE reported health impacts accruing to both sludge and composted sludge. The problem is that there are poor tracking systems and the question arises---does industry have any requisite tracking? My guess is that the answer is no, but I doubt that this is a subject that you will expand upon. Further, the tracking by EPA is probably nonexistent. Thus if you don’t check and don’t follow up you have just what exists, no reporting. You noted something rather cute about the term ABSENCE. That also applies in reverse. But rather that use precautionary principles such as in Europe, the industry continues, with EPA, to put people and the environment at risk. 

Sludge industry dogma has its invocation and its spin practitioners their mantra. Dogma, in a time of confusion, offers only apparent clarity. In times of complexity it appears to offer simplicity but actually the simplistic. In dynamic times, it appears to provide certainty. What dogma can not offer are solutions. Again, you have not offered ONE DOCUMENTED item on antibiotic resistance, while at the same time, the World Health Organization indicates that antibiotic resistance is a world-wide crisis.

As to EPA handing over the promotion of sludge and handing to locals, that was mainly driven by economics and not because of other presumed causes. You were there during these times and I’m sure have some appreciation. During mid-1990, et seq, EPA faced a series of camouflaged budget decreases that critically undermined enforcement. This is reflected in a statement by David Ullrich---which in essence stated as much. Those working in enforcement were highly sensitive about their functions. Enforcement has and always will be controversial and contentious. A lack of clear direction causes rapid failure of enforcement. Signals coming from the top (OECA) have major impacts on enforcement. We want you to “enforce” but please check with us first. Staff soon found out that EPA was anything but its own boss on important and contentious issues related to environmental policy. Thus whatever policy existed, it could hardly be called policy. 

The Office of Water (OW) seems to have been the handmaiden for industry. As an example at the urging of industry representatives, OW is presumed to have prepared a draft guidance document permitting POTWs to blend partially treated or raw sewage during periods of heavy rains. The OECA objected to this on several bases, including chlorine levels and their impacts on pathogens. Suarez indicated that OW viewed the issue only in terms of “did we win or not”, which he indicated was no way to run the shop and thus reflecting the loss on independence and objectivity of enforcement. When you put on top of this the Congressional “trick” of COLA, the environmental enforcement budgets were heavily strapped. Staff was cut others in disgust left. Thus to contend that there is even the ghost of a chance that EPA could stay on top of enforcement is disingenuous; that is why the locals were ultimately given enforcement. All this provides a deterrent to enforcement. The agency will refrain from new national enforcement actions against regulated industries, especially against those with well-oiled political machinery. Thus the apparent anxiety and low morale amongst the Agency enforcement staff is self-fulfilling. No tracking, no info---it is as simple as that.

As to the conversion of sludge and manure to fuel rather than land apply, again the economics are shifting as new technology is adopted. As long as these issues that I and others raise about sewer sludge and its impacts on the environment, reflecting what I think was part of Frank’s post, there are clouds hanging over the compost industry. Their feedstock is threatened. By a steadfast refusal to seriously address these issues, industry is shooting itself in the foot and those refusing to seriously look at the charges are, in the long run, partly responsible for this demise. I think that it would be better to do the science for real and then see what you have left to work with. As it is now, all that is presented is the post-hoc rationalization for missed opportunities with a growing sense that the explanations remain excuses rather than valid reasons. In the interim, those supplying sewer sludge will be looking ever harder for alternatives. Further, as the knowledge of externalities from land application begins to be more widely shared, more groups such as mine will join the choir.   

It was recently reported that Pacific Gas & Electric Co, which is neither a small or stupid player in all this, plans to begin shipping gas made from dairy manure in the Central Valley. This accrues to a reached agreement between PG&E and Environmental Power Corp. The latter plans to install manure digesters on dairies and share the energy income with the farm owners.  As Rufus could tell you, a cow will produce about 25,000 Kg of manure annually year, a significant resource and a significant amount of methane. It has been estimated that this production would provide up to 5 percent of PG&E's "core" supply in 10 years and up to 10 percent eventually.

The sewer treatment plants that are getting increased flow from expanding development and yet are hemmed in by expensive real estate, such as Montecito now have options through new technology. This technology will both reduce the plant’s foot print by replacing old high-square-foot-print equipment with new technology. The answer is converting sludge into energy. This will impact the sludge hauling and disposal industry for which there are spin-masters. These spin-masters will eventually find themselves needing to quit their day jobs.