LETTER: Sewage sludge fertilizer undergoes limited testing

To the Editor:

Ellis County Farmers and Citizens,

On October 2, 2014, additional Texas Administration Code (TAC) 30 rules were adopted, creating a third class of sewage sludge "AB" and some amendments to the TAC 30 application process. Here is a link to those rules so you will understand just how complex it is to know, regulate, and follow the rules. (http://texreg.sos.state.tx.us/public/readtac$ext.ViewTAC?tac_view=2&ti=30)

The average Texas farmer/citizen would need a lawyer to decipher the language, thus making it very difficult for Texas Citizens to know if regulations are being followed or broken.

These rules are based on the EPA's CFR-40-part 503, which makes TAC 30 rules look easy. Part 503 was developed in the '70s and '80s and was published in 1993. It has remained unchanged to this day. Sewage has not.

Ellis County farmers and ranchers are on the very bottom of the receiving end of this plan. The plan states that treated sewage sludge is "beneficial and safe." It goes on to state how Waste Water Treatment Plants (WWTP) test for heavy metals and pathogens. The truth is they test for arsenic, cadmium, copper, lead, mercury, molybdenum, nickel, selenium, and zinc. They are required to reduce not destroy. They test for one of two pathogens, usually fecal coliform which is a single indicator organism and in no way reflects all the pathogens in sewage. The other is salmonella. Vector or bug reduction attraction is just funny. I know you are not chemists, as I am not either — but aren't there more chemicals? Of course there are. You can find the EPA list (EPA TNSSS) and an Independent Study List on this web site: http://www.stopsewagedumpsellis.com/.

Farmers and ranchers should not trust municipalities and companies like Renda for information that is correct, complete, and without bias. The EPA, TCEQ, and the sewage syndicate are not in the farming or ranching business. They are in business to get rid of the toxic concentrated waste they produce by cleaning sewage water. Their methods to make it attractive reflect their business. Free, Safe, Beneficial, Nutrients, We Test, We follow strict EPA regulations, Industrial Waste is highly regulated with a pre-treatment program and more. You have all heard it.

Then you look at the EPA's Targeted National Survey of Sewage Sludge (TNSSS) and the EPA's auditor, the Office of Inspector General (OIG), (See Inspector General Report Brief same on web) and you just have to wonder what the truth is. Did any of the "bio-solids" solicitors happen to mention the chemicals in bio-solids? Industrial, hospital, storm, and household chemicals — many of which are hazardous.

We have made repeated attempt to get the EPA, TCEQ and just in the last few day the Trinity River Authority to answer this question:

Are you allowing, though CFR 40-part 503, chemicals of unknown amounts, concentrations and degree of hazard onto Ellis farms, ranches and forests without the consent or knowledge of those farmers, ranchers and landowners labeled as Class A, Class AB(Texas), and Class B bio-solids?

They all refuse to answer it.

The EPA does not require them to fully disclose and the TCEQ will not, either. Why? They will tell you we monitor for hazardous chemicals with the Toxicity Concentrations for Characteristic Wastes (TCLP), which is 40 chemicals of nearly 80,000. You also will hear there are only trace amounts. Now how would anyone know, when WWTP's do not TEST for them and most are unregulated?

During the 2013 Midlothian Stake Holders meeting, you may have heard a farmer exclaim "no one has died from bio-solids." Death from "bio-solids" comes in the form of chronic diseases, such as cancer. Chemicals are a major contributor to those diseases in food and water.

Ellis County farmers and ranchers may step up for another round of sewage when the Trinity River Authority gets its new Cambi THP built, but be warned: The digesters will not affect in-organic persistent chemicals nor have they ever, and do not forget they are mixing all those chemicals together and heating them up.

There is always a price to FREE.

- Craig Monk