[USCC] FW: Re: Fecal Coliform testing issues
frank@compostlab.com
frank at compostlab.com
Sat Nov 4 15:20:46 CST 2006
Dan,
I am very glad you are a part of this discussion on the USCC list serve. From
working with you in the past you seem to be very creative in your ideas and
approach to problem solving and, more than me, more ready to listen and work
with others. The USCC members has all the people with the needed expertise to
form a group to work on what you suggest. From my past experience the group
cannot be run with one paid leader that makes all the final decisions while
the rest of us just volunteer our time to make suggestions. The group must be
made of the right people and well organized for decision making. I suggest you
are an excellent person for that job.
I have one word of caution in your approach. We have talked about it before
and I have seen it happen in other groups. We are working in the 'noise level'
of the environment. And it does not pay to spend a lot of money and time
monitoring and evaluating results when working within this range. I have seen
others wanting to do it with End Use Guidelines and Global Warming etc.
Working in this range we can only 'work to improve' conditions. But if that
specific situation fails we cannot draw a conclusion of the condition we
improved because there are so many other parameters the effect the final
results. Most of them we have no control over - and that is the 'noise level'
I am talking about.
So my thinking is we 'work to improve' and have no expectations of success or
failures from the outcome. Because working in the 'noise level' we will have
failures (100 year rain, poor quality seed). We look at each 'small' change
we can make to reduce a 'failure peak' and correct that. With each small
change we make we improve the chance of success - but no guarantees.
And, as you point out, regulations placed on us that have no basis for
improving plant growth, public safety or environment protection (only for the
purpose of defining the word 'compost') only stifles progress in finding ways
to reduce the noise level one 'failed' peak at a time.
Again - Welcome to the USCC list serve!
Frank
On Sat, 4 Nov 2006 11:05:46 -0800, Dan Noble wrote
> Hey Frank,
>
> Thanks for your more precise discussion (than mine) of "rules" vs.
> "performance."
>
> I became sensitized to this issue when I was a "stakeholder" on the
> US EPA's "Advanced Monitoring Systems Pilot Project" a few years
> back. So now, I think you're challenging me to think more precisely
> about this distinction, and I believe it's VERY important (for all
> of us "environmentalists") to do so. Also, I feel VERY strongly
> about this subject, because I think it strikes at the heart of
> quickening science & technology innovation and progress (i.e.
> enhancing environmental/watershed sustainability) while AT THE SAME
> TIME protecting the environment to ever higher standards. I trust
> it's obvious to all of us that we want cleaner, healthier air, water
> and soil for ourselves AND future generations... while AT THE SAME
> TIME we live personally, socially and financially fulfilling lives.
> (Just to make explicit my social/environmental "performance" values
> and objectives).
>
> "Performance" as I'm using the term is not ONLY just growing healthy
> plants, but also the "performance" of the material inputs to the
> soil (e.g. pathogen levels is a "performance" standard... i.e. it
> "performs safely" from production, through transport to use)... also,
> salt, nutrients, etc., can be "material" performance standards,
> too. So performance CAN (not that it should) be tested at various
> levels/stages throughout the material production chain, from inputs
> (manure, biosolids, green residuals, food waste), during processing,
> all phases of composting, end product (before and after shipping) as
> you all have been discussing. And then tested in the soil as it's
> performing to either increase various parameters of soil
> "performance" (e.g. water infiltration, water holding capacity,
> saturation, nutrient availability and transport, plant growth, etc.,
> etc.).
>
> Clearly, measuring all these performances on all of the applications
> all of the time is (currently) considered either impossible or way
> overkill (i.e. too expensive, if not impossible). In fact, many of
> the compost providers I've talked to in So. Calif. (as recently as
> yesterday) don't see a NEED to even STA test their compost (now the
> new standard for Caltrans specs, as you know). So performance, the
> way I'm using it, must be thought of holonically, to use an emerging
> systems theory term (see
> http://en.wikipedia.org/wiki/Holon_(philosophy) for definition
> of "holon," an increasingly important concept for our times, I
> believe). That is, "performance" testing can be done throughout
> the resource acquisition, product production and use stages (at
> least theoretically, if not practically!).
>
> By "rules" I mean certain actions regulators require the regulated community
> to take that are attempting to function as surrogates for testing
> the actual parameter in question... i.e. instead of testing it in
> real time, and adjusting the management, in real time, to reach
> certain performance outcomes. For example, measuring time and
> temperature INSTEAD of actual pathogen reduction (of course, again,
> in this case because it's "cheaper and easier" to measure time and
> temperature than ACTUAL pathogen reduction). Other "rules" could be
> building a certain type of structure (building, aeration system,
> cement pad, filtering system, etc., etc.) to mitigate against an
> occasional offensive release of some material (e.g. silt), chemical
> (e.g. contaminant) or odor, or whatever. The "rule" (constructed
> system OR surrogate testing method) becomes the "standard" that it
> regulated, rather than use "whatever means you can" to achieve the desired
> performance outcome (performance standard).
>
> Of course, so far, it is generally VASTLY easier to regulate environmental
> "behavior" through "rules" than through "performance." Performance
> seems to require continuous monitoring and is influenced by many
> uncontrolled, or uncontrollable(!?), influences. As well as not
> having the technology to measure performance (again, at this time),
> through the entire production, distribution chain, through to its
> field use and performance. So we settle for a few key points in
> production (in the case of compost), combined with certain "rules."
>
> My point is that "rules" tend to stifle new methods for achieving specific
> "performance" levels. RULES tend to SLOW innovation. We've seen
> this in the entire environmental industry for the last two decades
> (I saw it personally as Director of Research and Consulting with my
> former company, Environmental Business International (www.ebjusa.com,
> publishers of the Environmental Business Journal, a strategic
> publication that pays attention to such issues for our readers,
> mostly environmental engineers and technology providers).
>
> So the journey to move from "rules-based' regulations to
> "performance-based" regulations is going to be a long one (why I
> call it a "journey" not a "step"). But as we move to ever-more nano-
> technologies and wireless data/info/communication technologies, our
> technical ability to "monitor" performance throughout the chain will
> continue to increase (I started seeing this with my field monitoring
> clients as well as in the Advanced Monitoring Systems Pilot Project)
> . I predict that in the next two decades, we can (and hopefully
> will) make great strides in moving in this direction (from rules to
> performance based regulations).
>
> One of the places we're seeing it currently in California is in the
> stormwater regulations. A "Blue Ribbon Panel" (in "Storm Water Panel
> Recommendations to the California State Water Resources Control
> Board: The Feasibility of Numeric Effluent Limits Applicable to
> Discharges of Storm Water Associated with Municipal, Industrial and
> Construction Activities, June 19, 2006"), concluded and recommended
> that in California we move toward setting "numeric limits" for
> stormwater runoff into TMDL sensitive water bodies (what I would
> call performance-based), and MOVE AWAY from simply accepting certain
> stormwater "BMPs" (best management practices) (what I would call
> rules-based), since "we don't know how they are actually performing
> in the field application," the panel concluded and recommended.
>
> So I hope this clarifies my distinction between rules and
> performance. This is going to be an ongoing conversation for years,
> likely decades, to come. Truly a journey for our industry... and all
> watershed impacting, and enhancing, industries!
>
> Thanks, again, Frank for your clarifications... it induced me to
> clarify my thinking (and expression) even further.
>
> Onward!
> Dan
>
> Noble Resources Group
> "Sustainable Market Development"
>
> Dan Noble, President/CEO
> Off: 619-303-3694
> Cell: 619-992-8389
> Fax: 619-589-9905
> dan at resourcetrends.com
>
> -----Original Message-----
> From: compost-bounces at composter.com [mailto:compost-bounces at composter.com]
> On Behalf Of frank
> Sent: Friday, November 03, 2006 11:17 AM
> Cc: 'US Composting Council Compost Discussion List'
> Subject: Re: [USCC] FW: Re: Fecal Coliform testing issues
>
> U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW
> Wyndham Orlando Resort | Orlando, FL | January 21-24, 2007
> The National forum for those involved in the development and
> expansion of the composting and organics recycling industry
> CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS, EXHIBITOR
> INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE AVAILABLE AT THE USCC
> WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931
>
> Hi Dan,
> Pathogen reduction is serious business especially when we consider
> biosolids. If we are to ever move biosolids into main stream
> composting, as I would like to see, we need solid data that known
> conditions (as shown in the lab using pure cultures) and procedure
> that will obtain the conditions in the compost that are required to
> kill all forms of the pathogens of interest. Then we need to take
> those conditions into the field and monitored (temperatures) and
> verify (fecal coliform at end of heat : ) ) that they have been met.
> More than performance based. These need be solid rules.
>
> I agree with the "performance based" approach and "advanced
> monitoring and reporting/information/communication systems" you
> suggest. But this will only work if the CaDOT User, and others, is
> given flexibility in the materials he/she is permitted to use - and
> this is not often the case. Also, to report a 'good performance'
> when using a certain product there must be included a
> characterization of the product used so it can be repeated. The
> testing required from CaDOT and most other agencies does not give
> the necessary info to properly match the material to the results
> IMO. And, as you mention we need weather and environment conditions
> along with soil and plant type. And someone dedicated to monitor and
> report how the site is doing.
>
> A great project, and with the right people, could make big advances
> in using compost, and compost related products.
>
> Frank
>
> Dan Noble wrote:
>
> >Frank and Eliot,
> >
> >Once again another argument for "performance based" rather than "rules
> >based" regulations. This has been a problem with the "rules based"
> approach
> >for decades... it literally "blocks" innovation that arises continuously
> out
> >of new science and new technology. If we ever plan to have ever enhanced
> >watershed environments, whose management is based on ever improving science
> >and technology, we need to get on the journey of crafting and implementing
> >evergreen, performance based approaches to management and regulation, it
> >seems to me.
> >
> >We see it operating here in California constantly with all the CalEPA
> boards
> >(air, water and waste). Seems that its time to start moving forward with
> >new, more evergreen approaches to environmental/watershed regulations. My
> >belief is that we now have the science and technology to head in this
> >direction (mainly advanced monitoring and
> >reporting/information/communication systems).
> >
> >Is there anyone (or group) within USCC that is addressing this, albeit much
> >bigger, regulatory issue?
> >
> >Sincerely,
> >Dan
> >
> >Association of Compost Producers
> >"We Build Healthy Soil"
> >
> >Dan Noble
> >Executive Director
> >Bus: (619) 303-3694
> >Cell: (619) 992-8389
> >Fax: (619) 589-9905
> >dan at resourcetrends.com
> >www.healthysoil.org
> >
> >-----Original Message-----
> >From: compost-bounces at composter.com [mailto:compost-bounces at composter.com]
> >On Behalf Of frank
> >Sent: Thursday, November 02, 2006 3:26 PM
> >Cc: US Composting Council Compost Discussion List
> >Subject: Re: [USCC] FW: Re: Fecal Coliform testing issues
> >
> >U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW
> >Wyndham Orlando Resort | Orlando, FL | January 21-24, 2007
> >The National forum for those involved in the development and expansion of
> >the composting and organics recycling industry
> >CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS,
> >EXHIBITOR INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE AVAILABLE AT THE
> >USCC WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931
> >
> >
> >Eliot,
> >Does that mean that at 55 deg c it has been shown in the lab that is
> >enough time to kill all the pathogens and their associated more
> >resistant stages? I am just wondering where 55 deg for three days comes
> >from and what it is based on.
> >
> >It seems it is very hard to make changes to about anything because once
> >a group has completed a task it is disbanded and there is not another
> >with the job of keeping the regs or procedures updated as new science
> >and experience may dictate.
> >
> >Thanks again
> >
> >Frank
> >
> >
> >
> >
> >epsteinee at comcast.net wrote:
> >
> >
> >
> >>Frank
> >>
> >>E. coli is a bactrerium in the genus Escherichia and Klebsiella sp. is
> >>in the genus Klebsiella . These are both Enterobacteriaceae.
> >>
> >>Facultative bacteria are able to live with or without oxygen.
> >>
> >>I appologize for not making the formula more clear. D is the time
> >>depending on t which is the temperature. So if you put in55C you will
> >>get three days.
> >>
> >>It is very difficult to get EPA to make a change if it is in the rule.
> >>You may wish to contact Jim Smith at EPA. His e-mail is:
> >>smith.james at epamail.epa.gov <mailto:smith.james at epamail.epa.gov>
> >>
> >>Eliot
> >>
> >>--
> >>Eliot Epstein
> >>19 Preston Place
> >>North Easton, MA 02356
> >>Tel: 508-238-1631
> >>Cell: 781-603-7151
> >>E-mail: epsteinee at comcast.net
> >>
> >>
> >> -------------- Original message --------------
> >> From: frank <frank at compostlab.com>
> >>
> >> > U.S. COMPOSTING COUNCIL 15th ANNUAL CONFERENCE AND TRADESHOW
> >> > Wyndham Orlando Resort | Orlando, FL | January 21-24, 2007
> >> > The National forum for those involved in the development and
> >> expansion of the
> >> > composting and organics recycling industry
> >> > CONFERENCE PROGRAM, REGISTRATION FORMS, WORKSHOP AGENDAS,
> >> > EXHIBITOR INFORMATION AND SPONSORSHIP OPPORTUNITIES ARE
> >> AVAILABLE AT THE USCC
> >> > WEBSITE: www.compostingcouncil.org OR CALL THE USCC AT 631-737-4931
> >> >
> >> >
> >> > Jennifer and composters,
> >> >
> >> > Jennifer Appel wrote:
> >> >
> >> > >Method A believes the following:
> >> > >
> >> > >Add a high nitrogen starter to the pile and heat it up to kill the
> >> > >pathogens.
> >> > >
> >> > >What this ac tually does is kill both the pathogens and the
> >> beneficial
> >> > >species. (But this method is not looking for beneficial
> >> organisms only the
> >> > >removal of pathogens.) When the pile cools the bad guys come
> >> back first.
> >> > >(About the time you send in the sample for testing.)
> >> > >
> >> > >Because there was a synthetic starter used - the aerobic
> >> bacteria that eats
> >> > >pathogenic organisms WILL NOT start their function because the
> >> synthetic
> >> > >process is a chemical one and the biological process CAN NOT
> >> START until the
> >> > >chemical reaction has finished its process.
> >> > >
> >> > >One way for Method A to achieve an aerobic pathogen free
> >> status, is to
> >> > >inoculate the pile with the beneficial organisms after the pile
> >> cools to a
> >> > >temperature and aerobic status that can support your new
> >> organisms.
> >> > >
> >> > >Once this has been achieved, the biology will perform the
> >> nutrient c ycling
> >> > >functions required to KEEP the pile aerobic and pathogen free.
> >> > >
> >> > >
> >> > >
> >> > You make a good point. With windrow composting, as I see it, the
> >> hot
> >> > part is killing all while at the same time the microbes in the
> >> cooler
> >> > band on the outside are getting established. Then we turn it all
> >> over
> >> > and it starts again. I don't think the pathogens (I'm not
> >> talking about
> >> > the indicator FC) will get established, as you suggest, because the
> >> > aerobic conditions common in the cooler parts of the pile are
> >> not to
> >> > their liking. So I think this is a process of killing the spores of
> >> > pathogens along with the vegetative phase and providing a place
> >> where
> >> > the benificials will take over. But your point is well taken
> >> when in
> >> > vessel or container composting. That kills off all and then
> >> readies the
> >> > material for whatever gets a foothold. Being aerobic I still see
> >> it as
> >> > unlikely a pathogen that normally lives in anaerobic conditions
> >> will
> >> > take over. FC will along with all the other common microbes
> >> surrounding
> >> > the pile, or on equipment that survived the process. All good
> >> reasons to
> >> > test after the heat phase.
> >> >
> >> > >Method B: (rarely used in large commercial composting operations)
> >> > >It is also possible to NOT USE a synthetic high nitrogen
> >> starter. This is a
> >> > >bit more advanced. This method requires microscope time to
> >> assess the
> >> > >organisms in the pile, then feed stocks that promote specific
> >> aerobic
> >> > >organism activity to mitigate pathogenic organisms are added in
> >> appropriate
> >> > >proportion to promote a fully functioning aerobic compost pile
> >> that can
> >> > >provide 2-3 tons of Nitrogen supply if all the biology is
> >> functioning
> >> > >correctly.
> >> > >
> >> > >The SECOND reason I see for why pathogens reestablish in a pile
> >> is becau se
> >> > >far too many compost operations OVER WATER the pile every 3rd
> >> day and thus
> >> > >de-oxygenate it! Three steps forward and two steps back is a
> >> hard way to
> >> > >make a good product. I understand the intent of the rules,
> >> however, most of
> >> > >the operations I have visited could make a better product in a
> >> shorter
> >> > >period of time if they just used LESS WATER in conjunction with
> >> negatively
> >> > >aerating the piles!!!
> >> > >
> >> > >Moisture content and optimum temperature will vary depending on
> >> the location
> >> > >where the pile is made, type of feed stock, type of pathogen or
> >> beneficial
> >> > >organisms and the type of aeration method used... Minnesota
> >> composting is
> >> > >very different from South Texas composting with respect to
> >> temperature, time
> >> > >and moisture content - and to add to that - the type of raw
> >> materials used
> >> > >will require a different amount of water depending on the
> >> biological species
> >> > >requirement in the pile. (MSW versus food residual vs. cotton
> >> burr,
> >> > >in-vessel, static, etc.)
> >> > >
> >> > >ALL soil has 3 properties: chemical, physical and BIOLOGICAL!
> >> The first two
> >> > >have enough science behind them to establish good composting
> >> practices and
> >> > >it would appear an opportune time to add the third element
> >> based on
> >> > >scientific data in order to achieve a smoother process.
> >> > >
> >> > >
> >> > As I see it all this should happen, and will, after the heat phase.
> >> > Because we can -not- count on it happening in the way we want
> >> due to so
> >> > many variables (you point out many) and based on no 'lab prove
> >> method'
> >> > we should not include this in the pathogen reduction program. As
> >> it is
> >> > now we do include this in the program and it is giving us
> >> misleading
> >> > results and preventing other stabilization processes from being
> >> used -
> >> > like vermistabilization.
> >> >
> >> > Frank.
> >> >
> >> >
> >> >
> >> > >
> >> > >
> >> > >
> >> >
> >> > --
> >> > Frank Shields
> >> > Soil Control Lab
> >> > 42 Hangar way
> >> > Watsonville, CA 95076
> >> > (831) 724-5422 tel
> >> > (831) 724-3188 fax
> >> > frank at compostlab.com
> >> > www.compostlab.com
> >> >
> >> >
> >> >
> >> > _______________________________________________
> >> > Compost maillist - Compost at composter.com
> >> > http://mailman.cloudnet.com/mailman/listinfo/compost
> >> >
> >> > This list is a service provided by the US Composting Council.
> >> >
> >> > _______________________________________________
> >> >
> >> >
> >> > Ongoing Sponsors of the USCC Discussion list are:
> >> >
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> >> policy e-mail alert
> >> > service for environmental, food and agricultural industry
> >> professionals.
> >> > Contact Jack Cooper 301/384-8 287 JLC at fien.com --- www.fien.com
> >> >
> >> > Renewable Carbon Management, LLC with the containerized,
> >> in-vessel NaturTech
> >> > Composting System www.composter.com rcm at composter.com
> >> >
> >> > (c) Copyright 2006 United States - All rights reserved
> >> >
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> >> have their
> >> > posting privelages suspended. No exceptions!
> >> >
> >> > Opinions expressed represent only the poster and are not
> >> necessarily the opinion
> >> > or policy of any organization.
> >> >
> >> > Non-members of USCC are encouraged to join the Council through
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> >
>
> --
> Frank Shields
> Soil Control Lab
> 42 Hangar way
> Watsonville, CA 95076
> (831) 724-5422 tel
> (831) 724-3188 fax
> frank at compostlab.com
> www.compostlab.com
>
> _______________________________________________
> Compost maillist - Compost at composter.com
> http://mailman.cloudnet.com/mailman/listinfo/compost
>
> This list is a service provided by the US Composting Council.
>
> _______________________________________________
>
> Ongoing Sponsors of the USCC Discussion list are:
>
> Food Industry Environmental Network (FIEN), a regulatory and policy
> e-mail alert service for environmental, food and agricultural
> industry professionals. Contact Jack Cooper 301/384-8287
> JLC at fien.com --- www.fien.com
>
> Renewable Carbon Management, LLC with the containerized, in-vessel NaturTech
> Composting System www.composter.com rcm at composter.com
>
> (c) Copyright 2006 United States - All rights reserved
>
> Members posting CC copies to the list and other addresses will have their
> posting privelages suspended. No exceptions!
>
> Opinions expressed represent only the poster and are not necessarily
> the opinion or policy of any organization.
>
> Non-members of USCC are encouraged to join the Council through our website
> at: http://www.compostingcouncil.org/membership.cfm For
> discussion list policies and information regarding subscribing,
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>
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