Sludge Watch ==> Nursury Products Sludge Compost EIR Hinkley Calif - ready in late Aug?

[Maureen Reilly]

Sludgewatch Admin:

Word has it that the Nursery Products EIR will be available for public review in about 3 weeks.  
This is astonishing!  How could they investigate the impact of the sludge on the Desert Tortoise
the other endangered species, the air impacts, the water impacts, the bioaerosols, the transport
safety issues  in the scant
few weeks since the Scoping Meeting in June?

Here it what the Sierra Club Mohave Group put forward as to the required scope of the Nursery
Products open air sludge compost proposal.  In addition, it was recommended that a full 
site characterization report down to first water be undertaken.

And there is still no word on what is happening with the illegal treated wood chips that were dropped
off in piles in the desert at the site location.

.................................................................................................

 

ISSUES THAT NEED TO BE ADDRESSED IN THE EIR

URS Corp EIR Proposal for Nursery Products Compost Site 

 

 

Understanding the Project

 

1. Accurate description of the project.compostables?

 

To do an EIR that has meaning, there needs to be a clear and unambiguous description of the project.  It is not clear in the Initial Study whether the project refers to wet weight or dry weight tons, whether the 522 truck trips are 522 trucks and over a thousand return trips or whether it means 261 return trips (ie there and back). 

 

Based on Ms Hyke's memo of this past week, I understand that the proposal intends that there is to be a maximum of 2,000 tons per day of compostable material measured in wet weight - as delivered- tons.   Also it needs to be understood that sewage sludge weighs about 2 tons per cubic yard, and greenwaste is about half a ton per cubic yard, and that finished compost is about one ton per cubic yard. The last draft permit written by the LEA proposed equivalencies that a cubic yard of any of these materials weigh the same amount.one ton.   This would serve to underestimate the true tonnage at a site.  

 

>From a phone call with Ms Hyke, I understand that there are to be a maximum of 522 truck trips meaning 261 trucks driving to the site and away from the site.  This needs to be clarified in the proposal description.

 

 

2. Biosolids and greenwaste and illegally dumped wastes

 

 WHAT kind of greenwaste is being considered?  Bark?  

Grass clippings?  Woodwaste?  Treated or painted wood? 

 

 What kind of Biosolids?  What criteria must be met regarding heavy metals, what quality regarding pathogens, what quality regarding dewatering?   Again, there isn't enough information in the initial study proposal to provide effective input into the scoping of the EIR.

 

Already it seems that illegal chipped treated board has been dumped on or near the site.  Is the proponent intending to incorporate this illegal material into the construction of the site, or the compostable material?  Is illegal dumping going to be factored into the risk assessment?

 

These materials contain formaldehyde and other toxic compounds, and will need to be addressed in the EIR.

 

What about the berms? What are they to be made of, and what is their environmental impact?  Is it, like Adelanto, to consist of materials from the TPS Technology tailings from the contaminated soil processing facility?  In that case we need to know what is the chemical composition of that soil residual, and whether it is likely to leach, or become windborne.

 

 

3.Grass Clippings?  

 

Will the company be taking grass clippings and urban greenwaste? Jeff Meberg claimed that the plague of flies in Adelanto was from grass clippings and he would not allow them.  Is this the case?  

Are there to be no grass clippings?  If grass clippings and greenwaste are to be accepted the EIR needs to examine the mitigations for flies and other vector, and for plastic and trash that can blow off the site.

 

Apparently vector issues .particularly fly problems that may torment neighbors, will vary based on what materials are to be brought to the site. 

 

 

 

4. The biosolids and greenwaste would be dumped on a compost pad.  

 

Is this a mixing pad or is the whole windrow on a pad?  What kind of pad? Constructed 

of what material?  How permeable?  Will the windrowed compost piles and storage 

piles be on a pad? Is it porous?  Where is runoff directed and contained?  What will be the impact of stormwater and leachate?  Where will it go? This needs to be examined.

 

The public is at a disadvantage since the description of the project is so vague.  Since it isn't clear what is arriving at the site, how can we suggest what needs to be in the EIR?

                                                                                                

5. The windrow is about 12 ft high, 15 ft wide but how long? 

  

Again.is it on a pad its whole length? How is the pad to be engineered? What will protect

groundwater?   Will there be an impermeable pad all along the length of the windrows? Or will the compost take place simply on the desert floor?  Will leachate and contaminated stormwater move down into groundwater?

 

6. Will this project be required to meet the composting pathogen reduction requirements set out in the 503 legislation ? We need an accurate and complete project description.

 

Windrow turning.the EPA requires 5 turnings.this proposal has 2 turnings.  

Does not meet EPA minimum requirements for Class A biosolids.  Will the project

be required to meet the composting requirements for windrow composting as 

Set forth in Part 503 32(a) Process to Further Reduce Pathogens page 51

http://www.epa.gov/ORD/NRMRL/pubs/625r92013/625R92013chap7.pdf

 

Nursery Products has had dreadful problems with flies, odor, and dust offsite.  Small 

wonder since they didn't meet the minimum requirements of the EPA 503 requirements

for composting sludge in windrows.  There is no aeration. ..according to Jeff Meberg. 

Los Angeles County staff claims sludge composts have to be turned as often as 12 -15 times

 

7.  Turning the windrows - particulate pollution, gases, bioaerosols

 

It is my understanding from Lauren Fondahl, EPA, (Fondahl.Lauren at epamail.epa.gov) that the proponent will conduct a minimum of 5 windrow turnings.  This means that the pile will be delivered, then mixed on the compost pad, then turned 5 times, then screened, then stored, then loaded.

 

Arrival, windrow turnings, screening, and loading are all likely to cause offsite dust, odor, and blowing plastics.  Given high desert wind conditions, and people living as close as a mile and half away, how can an open unenclosed site protect the environment and the neighboring communities?

 

The EIR will need to model dust, fly and particulate, and blowing trash from the site. and examine the impact on the desert ecology as well as human receptors.

 

Also bioaerosols, viruses and bacteria and endotoxins, mold and fungus spores need to be be modeled.since they will impact endangered species like the desert tortoise as well as people.

 

 

8. Screening and air pollution

 

 

Screening causes a lot of air pollution.  In California, projects are supposed to use best available technology.  Best available technology for particulate, ammonia, and gasses escaping compost sites, would be a fully enclosed facility with air emissions controls and biofilters.   This facility should be indoors.  

 

Screen sludge compost - is it finished when it is screened?  How long can it 

stay on the property before it is removed?  There needs to be modeling for offsite impacts of new material, composting material, additives, composting agents, sludge turning equipment, trammel screen function and emissions, stored material, and loading and unloading.

 

9. Water contamination at the site - Truck Cleaning

 

Trucks arrive with sludge ...how are the sludge trucks cleaned?  To put finished compost in a sludge truck would contaminate the finished compost with pathogens and flies.

Trucks hauling sludge drop it off at the site, and then they need to clean off the truck tires, wheel wells and undercarriage.  Even if the truck leaves empty, it needs to be cleaned first.   A truck washing station for 261 trucks per day will need thousands of gallons of water. 

How would the sludge truck wash water be managed? EIR needs to address this.

 

Water and Road Access for Fire Fighting

 

Where will the water come from for fire fighting if this site catches fire? How will the fire be contained?  Where will fire trucks get access to all parts of the site?  There would need to be roads built all around the site and through the sites so that fire trucks or other emergency vehicles could attend fires or accidents at all times. 

 

What would be the impact of fire on the desert and surrounding homes and communities? What mitigations{possible think of having a bit of a glossary page?} are required to address a fire at this site? 

 

 

Total water use at the site

 

There will need to be water for sanitation - hand washing, showers for the staff and some handwashing etc for  up to several  hundred truckers.

- 100 gallons of water per employee per day

 

Water for fire fighting

- supply of at least 250,000 gallons of water on site at all times in an empoundment to provide for firefighting

 

Water for truck washing 

- 200 gallons per truck per day

 

Water for dust control /composting to moisture content in the compost

- 2 acre feet per year would be need per acre of the site 

 

In addition there will need to be storm water management.

- there would need to be retention ponds that are lined.or some other containment method.

 

Where will the water come from? Without electricity at the site, how will it be pumped up from the ground? Is this much water available to be taken from the ground?  Where will the stormwater, washwater, truck wash water go?  

 

8. Initial study and Notice of Preparation

 

The website for San Bernardino County misdirected the public who went to the Notices of Preparation page and clicked on Nursery Products Notice of Preparation.  They were sent to a 2005 EIR that was utterly unrelated to Nursery Products. Those people would not have known to go the public meeting on the scoping for the EIR.  Due to this failure to provide accurate notice of the meeting, the comment period needs to be extended another month.

 

Project No. 500644CU1 is the Project Number for this EIR. 

 

9. Air Quality Truck Emissions

 

Truck Emissions .up to 522 trips will emit toxins, particulate and gases.  These emissions need to be evaluated within the airshed of the proposed site and outside this airshed.   Most of these trucks will be traveling, and emitting greenhouse gases, carbon monoxide, volatile organic compounds, smog initiating compounds,  and other emissions all the way from Los Angeles to the site.  These emissions need to be quantified and considered in the proposal.

 

Will the roads into the compost site be paved ? Will the roads inside the site, and around the site be paved to mitigate dust? Are there unpaved sections of Highway 58?  If so, they should be paved to mitigate dust and provide driving safety.

 

10. Air Quality Emissions from the sludge and composting operations 

 

Outdoor compost operations release greenhouse gases, particulate, ammonia, 

and other smog forming and dangerous emissions.  These will need to be 

evaluated for environmental impact, climate change, habitat, and human 

health.

 

Also the sludge contains pathogenic bioaerosols..endotoxins, and other 

bacterial fragments that can impact human and animal health.  The use of 

actinomycetes as a compost agent needs to be examined as this material 

becomes airborne in the surrounding lands.impacting desert tortoise habitat as well as  the Harper Lake Bird Sanctuary, and may impact humans, crops, soil quality etc.

 

Greenhouse gases are emitted by sludge composting sites.  Studies by the South Coast Air Quality Monitoring District show that each ton of composting sludge gives off 35 pounds of methane.a serious greenhouse gas.  In addition there are the Volatile Organic Compounds and smog inducing ammonia and tailpipe emissions from trucks and also equipment on the site that need to modeled in the EIR.

 

Work Study Needed to Look at Equipment

 

In addition, they need a work study to see if the equipment that they propose at the site is adequate to do the work.  Don't they need water trucks? Several windrow turners etc? They need to show that the on site equipment emissions includes adequate equipment to compost 400,000 tons of incoming materials. 

 

PM10

This site is in a PM10 non attainment zone.  What will the implications be for asthmatics or asthmatic children?

 

How can an open air facility protect against further erosion of public health from small particulate in 

the air?  California law requires that 'all feasible measures' be used to protect air quality. 

 An open air compost site cannot be said to implement 'all feasible measures'.  

 

An enclosed facility would be required to meet 'all feasible measures'.

 

Air emissions will also depend in part on how many times the windrows are turned, since each turning will release particulate, PM10, pathogens, viruses, gases and bioaerosols.  Los Angeles Wastewater staff claim that sludge compost may need as many as 15 turnings of the windrow.

 

Is one windrow turner enough equipment to manage a site with 250,000 tons of active compost?

How long are the windrows, and how many?  Where is the site plan layout?  Will the process include the use of actinomycetes? Will these desiccated biofragments become airborne? How will they be stored?  What is in them? How much will there be in storage on site? Stored how?

How will it be applied to the compostable material?

 

Again, an accurate description of the project needs to include a description of the composting technology that is to be used, and the EIR cannot proceed until there is a comprehensive, unambiguous articulation of the project and the technology.  Once there is a full description there needs to be air modeling of these emissions to show their impact on endangered species, humans, and the desert environment.

 

 

11.  Public Services/ Transportation Traffic

 

The project description calls for up to 522 sludge trucks trips on Highway 58.  Plus some staff trucks, and visitors and inspectors.  That is a huge amount of extra traffic on this highway.  This means up to 522 stinky trucks stopped at stoplights in Kramer Junction.   What mitigations are in place for highway safety and for odor?

 

Accidents on Highway 58 and Highway 115

 

If there is an overturned sludge truck on Highway 58, it is quite possible that fire trucks, police or other service vehicles could not continue to navigate the highway.  This would pose a risk, since the high number of traveled truck miles, means that truck overturns will be a routine event.

 

Also a truck overturn on Highway 15 could mean seriously delayed traffic on this busy commuter route.  

 

The fatality rates for large truck occupants was about .37 per 100 million vehicle miles.  How many truck crashes can be anticipated from all these trucked miles? How many deaths and injuries? How many truck sludge spills can be anticipated in a month?  In a year? 

 

There have been highway deaths recently near Hinkley.  The roadway is unpaved through some of the stretch.  What will protect people from additional carnage from these millions of extra truck trips?  

 

12. Berm

 

What will the berm around the site be made of?  Local native soil?  Imported soil?  Soil 

from TPS Technology in Adelanto? Compost from Adelanto Nursery Products site?

 

What soil standard will be used for this material?  How will it be audited for contaminants?

Any contamination in the berm or any other soil amendments (topsoil, sand, etc) will need to be modeled in the EIR from air, soil water pollution perspectives, as well as from a stormwater runoff perspective.

 

13.  Occupational Health and Safety

 

There will be as many as 261 truck drivers arriving at the site.  Their shoes and boots are likely to get covered in sludge.  They may need to shower or use the toilet and wash their hands.  Where will the water come from?  Where will the dirty water go?

                                    

 

14. Desert Tortoise and Burrowing Owl and Mojave Ground Squirrel

 

This EIR proposal suggests that there is burrowing owl habitat on the site, 

but goes on to suggest that desert tortoise habitat is only on property 

adjacent to this site, but that some tortoises might wander over and forage.

 

This means that the proposed site IS desert tortoise habitat. This is a Desert Wildlife Management Area and a waste facility would need a permit.  It will need a federal as well as a state permit.  

 

There would need to be mitigations - fencing to keep the tortoises out of the road.  With as many as 1044 {is that right?}truck trips per day, there could be significant danger to these three species.  

 

Desert tortoises known to be subject to respiratory tract infections and exposure the viruses, pathogens and bioaerosols from sludge could be damaging to this endangered population over a very very large area.  The bioaerosol impact should be modeled in the EIR.

 

There should be a Section 10 consultation for wildlife.

 

15,  Hydrogeology

 

 

Further study of the water at the site is needed, since it seems that far more water is required than is indicated in the Initial Study.  The groundwater is scarce, and is still under adjudication stemming from a lawsuit between Barstow and Victor Valley.  The water under the site is threatened with contamination from a variety of toxic compounds, surfactants, sanitizers, pathogens, nutrients.  There will be compost leachate, runoff from truck cleaning, staff washing facilities, rainwater and storm water inundation and contamination from seismic activity that need to be considered.  

 

The water beneath the proposed site provides drinking water for the community and the risk of contamination from this kind of project is high.

 

16.  Seismic Risk

 

Earthquakes move both soil and water.  This is an area of high seismic 

activity and the disruption of the soil and cracks in containment facilities 

need to be considered.  The County of San Bernardino, the Title 17, and the 

Part 503 sludge regulations all have requirements regarding sludge use and 

sludge composting on seismically active sites.

 

17.  Storm water

 

Storm events and flooding are likely to create a disaster at 

this site. It isn't clear that this will be adequately addressed.

 

18.  Site Characterization Report

 

Because this is an area that can be sensitive environmentally, there needs to 

be a full site characterization report.right down to first water.

 

19. Existing contamination

 

The neighbors health has already been impacted from exposure to toxic concentrations of Chromium 6, first in the well water and then in the surface soil and dust (after PG&E were allowed to get rid of contaminated water through evaporation).  These citizens and the surrounding wildlife, both fauna and flora, will be further impacted by sludge insults that may compound their existing health issues.  Heavy metal levels will only increase through windborne sludge residuals and the implications of the further sludge contamination with viruses, pathogens, trichlocarban, endocrine disruptors, dioxins and furans, hydrocarbons, and nutrients needs to be examined along with the synergistic effects.

 

Bioaerosols from sludge spreading have traveled as much as 10 miles away.  The health and environmental impact of bioaerosols from the proposed site need to be part of the EIR.

 

20.  Sludge and Weeds

 

Sludge has high levels of phosphorus and nitrogen. This promotes the growth of wee{d}ks and non{-}native species into the desert. The weeds die off and lead to fire hazards.that can ruin desert habitat and take away people's homes.  The impact of the sludge nutrients and the weed seeds needs to be modeled and mitigated.

 

21. Problematic Compounds in Sludge

 

There are a number of compounds that are found in municipal sewage sludges that have not been evaluated for human health or environmental impacts by either the EPA or the California State government Biosolids EIR.

Some of these compounds  (to name just a few) are:

 

Triclocarban - sterilizing agents that may cause the development of antimicrobial resistant pathogens, and may inhibit normal desert microbiota.

 

Pharmaceuticals - these may also be giving rise to antibiotic resistant bacteria and viruses that may be moving off site, through wind or on truck tires, or into groundwater or surface water runoff.

 

 

Viruses and Bacteria - Bioaerosols - may be moving off site, through wind or on truck tires, or into groundwater or surface water runoff. These may impact people over 10 miles away, according to recent research.

 

 

Antibiotic resistant organisms - through the digestion process at the sewage treatment plant, pathogens acquire antibiotic resistance. These disease organisms would arrive in the desert in the sludge, and could impact endangered species, wildlife, and humans.

 

The Nursery Products composting site in Adelanto sparked hundred of complaints, and even an investigation by Tracy Barreau ( tbarreau at dhs.ca.gov 510 622 4489 ext 620)  Senior Environmental Scientist, Environmental Health Investigations Branch Agency for Toxic Substances and Disease Control

 

Given all the health complaints about the previous site, it does not make sense to suggest that human health impacts are not a serious issue for research under the proposed scope of the EIR.  There must be no repetition of the health complaints, and the fly outbreak as there was at the previous operation,,,,an operation considerably smaller than this proposed project.

 

 

22. Dairy Barns - Agriculture

 

Dairy barns are fairly close to this site.  The bioaerosols, viruses, bacteria, endotoxins and particulate, dust and odor and flies from the site could impact the dairy cattle.  Mastitis, respiratory problems, and flies could pose health or veterinary risks.

 

23. Cultural Resources

 

This site is near Harper Dry Lake.  The edges of the dry lakes waxed and waned with the years, and the shorelines, which are generally rich sites for artifacts from native habitation or early man, may be found in this area.

 

24. Recreation

 

Many tourists will be coming to the Barstow area for casinos and other recreation.  Also the tourist traffic between Los Angeles area and Las Vegas means that the sludge trucks will be hauling on the tourist traffic routes.  Odor, traffic accidents,and traffic congestion could mean that tourists will abandon this avenue of recreation in the face of competing sludge impacts ..odor, trucks, blowing particulate, flies.

 

In Adelanto, people could smell the site for at least 5 miles away if the weather conditions were right.  

 

25. Biological Resources

                        

The extra nutrient in the sludge can promote a richer soil than is normal in the Mojave Desert.

This non typical enrichment can allow non native species to grow and may impact native species of plants and animals.  Also the non native plants may grow in the wetter season and then die.leaving the desert vulnerable to fires which can destroy precious habitat. 

 

The viruses and bacteria windborne away from the site might lie in a dormant state in the desert soil, but a rain event could remoisten and reactive these pathogens.  When desert animals drink from the small ponds after a rain storm they may find these precious puddles contaminated with urban chemicals, drugs, and pathogens.  These contaminated water sources could further destroy already endangered species.  

 

26. Manditory Findings of Significance

                                                

With the closest residence only 1.5 miles away and a school only 8  miles away, this site could certainly have mandatory  findings of significance for human health.

 

27. Aesthetics

 

Lights at night could certainly impact the view of the night sky in this part of the desert.  Aesthetics need to include more than just visual.  They need to consider the odor aesthetic of this community.

If there is odor, especially evening, morning and night odors like the Adelanto site, then this could have a profound effect on the community.  

 

It may have an effect on the fauna who may leave the area in search of better aesthetics.

 

There are the aesthetics of sludge grit in the eyes and the teeth when winds over 11 miles an hour blow sludge particles off site into neighboring homes and communities.  Sludge on the cars in the morning. Sludged phlegm in the throat in the morning, and windborne sludge  particles in the swimming pool or animal  water trough.

 

These aesthetic issues may also pose health risks, but their impact as 'aesthetics' can cause depression, anxiety, anger.and the exacerbation of diseases or conditions like high blood pressure and depression.  

 

Many people moved to the desert to be far from the anthropogenic wastes of the city.and to have those urban waste aesthetics impact their environment can be traumatic.  These impacts need to be considered in the EIR.

 

 

 

 

Comments on the Initial Study

 

I am aware of the comments on the Newberry Springs proposed Nursery Products project that gave rise to the EIR.  Now that the proposed site has moved to the Hinkley area, what comments went into this proposed Initial Study?  How was the project described to the URS consultants and to the responsible agencies?  

 

If they only got this description, how could they have commented meaningful on the scoping of the EIR, since there is so much confusion about so many issues?

 

 

 

 

 

 

 

 

 

Conclusion:

 

California requires facilities to adopt Best Available Technology.  In the case of a composting facility, that means a fully enclosed facility with air emissions controls.  This would stop greenhouse gases, would stop materials from blowing offsite, keep down disease, limit some of the damage to habitat.  South Coast Air Quality Monitoring District requires an enclosed facility.  This proposal needs to be an enclosed facility.

 

Illegal wastes in the form of chipped treated wood has already been dumped at the compost site. See the photos at the Locations link below.

This bodes very poorly for environmental compliance.  It has to be assumed that this operator will not respect the requirements of the permits, and will need close supervision.






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