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Re: E-M:/ Re: Wetlands and Sludge



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Enviro-Mich message from fred cowles <fecowles@yahoo.com>
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Erik,

The 38 months is based on protection from pathogenic
organisms.  It is based on scientifically measured
die-off rates of pathogens multiplied by
unscientifically chosen safety factors.  Metals do not
degrade and have separate criteria that determine
application rates.  Metals in municipal sludges are
not nearly the problem that they were in the 1970s.  

As Jim stated, unregulated manure applications are a
much greater public health concern than well regulated
biosolids applications.  No one claims that improperly
applied biosolids are safe, and should not be confused
with well managed programs.  

======== Fred
Fred Cowles 


--- Erik Janus <Janus@nwf.org> wrote:
> Is there a scientific basis to this 38 months?
> 
> It seems reasonable, but for certain metals, they
> will
> reside in the sludge longer than 3 years (36 months)
> I bet. (Assuming that weathering studies from metals
> in soils
> can be applied to sludge...)
> 
> - Erik
> 
> Erik R. Janus
> Great Lakes Natural Resource Center
> National Wildlife Federation
> 213 West Liberty, Suite 200
> Ann Arbor, MI  48104-1322
> phone (734) 769-3351, ext. 44
> fax (734) 769 1449
> janus@nwf.org
> 
> >>> fred cowles <fecowles@yahoo.com> 11/26/02
> 11:12AM >>>
>
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> Enviro-Mich message from fred cowles
> <fecowles@yahoo.com>
>
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> 
> This response is from the DEQ employee responsible
> for
> the Biosolids Program (Municipal Wastewater Sludge
> Disposal Program):
> 
> There is a one year isolation time from the time of
> last biosolids application until land can be used
> for
> high public contact uses such as parks.  However,
> the
> law requires a 38 month waiting period from the last
> application of biosolids until the land can be used
> to
> grow root crops such as carrots and potatoes for
> human
> consumption.  Because new homeowners can grow root
> crops in gardens on their land that is subdivided
> and
> developed from former farm fields, it is my opinion
> that the same 38 month isolation time should apply. 
>  
> Although the risk associated with pathogens from
> biosolids is significantly less than land where raw
> animal manure is applied. There are no legal
> restrictions on development of land where animal
> manure has been applied.
>   
> 


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