Sludge Watch ==> Sewage plants not designed to stop pathogens - no staff training on pathogens

[Maureen Reilly]

Re: pathogens in sewage effluent - cat feces into the toilet and 
toxoplasmosis in otters
Note to Steve Weigand
by Edo McGowan

There is technology out there that might go a long way toward solving the 
problems listed in your article. For example Gerald Marantz might be able to 
continue seeing his product flushed while at the same time Pat Conrad may be 
able to cease worrying about sea otters. Thus there are a lot of other 
things that most may not even aware of. The problem is that sewer plant 
operators are not trained in these areas (see response from state licensing 
agency below) and sewer plants are running on very---very old technology.

First, let’s look at current designs and standards for sewer plants (POTWs). 
These POTWs are built and run under EPA standards or in California, by a 
joint effort between EPA and the state’s regional water quality boards. 
Sewer plants do not conform to Public Law 92-500, the Clean Water Act (CWA), 
and its requirements but rather by some misinterpretation of the CWA. The 
reason for that is that as designed and operated, few if any POTWs could 
attain CWA standards so the EPA regs were tweaked to not look at certain 
things and viola, we have success.

EPA has never done a pathogen driven health risk hazards assessment on this. 
EPA is basically a chemical regulatory agency. It is very thin in the area 
of sickness and disease---that was to be CDC’s area but CDC has not entered 
the area of sewage for very carefully constructed political issues (see 
below). So who covers the waterfront?

Sewer plants can not deal with materials that are in solution, the lower 
size limit of materials captured excludes pathogens and virus as well as 
materials in solution. These limits allow a lot of stuff to be discharged 
into America’s rivers and coastlines.

What Pat Conrad is finding is just the tip of the iceberg. Amy Pruden just 
published on this---see Science daily at the following:

http://www.sciencedaily.com/releases/2006/10/061025185930.htm

The January issue of Scientific American also discusses this issue. The 
issue is that a lot is getting through these POTWs and the press has yet to 
really appreciate the extent. We in medicine have been dealing with the 
aftermath of this for a long time. The level of antibiotic resistant 
pathogens is no longer confined to the hospital. It is out in the community.

Sara Firl also is published in this area again showing what is actually 
coming out the back end of the currently designed POTW.

http://www.cura.umn.edu/reporter/06-Fall/LaPara_et_al.pdf.

Actually, the number of papers showing failure of standards to protect 
health is extensive. The age of these papers it is considerably older that 
either Firl or Pruden themselves (both are young women). But who has taken 
these papers into consideration---certainly not EPA.

Case in point, EPA has not studied antibiotic resistance in discharged 
sewage yet it allows both the fluids and solids to be used in agriculture. 
My group through a Freedom of Information Act request, sought to see just 
what EPA knew about antibiotic resistance. Their own head of science at the 
time, Dr. Al Rubin, admitted that they were not looking at this (see FOIA 
results below). Rubin also admitted that people were getting sick but few 
were actually looking at this---including his agency and the State of 
California.

>From the Agendas & Minutes For January 21, 2003 - Special Meeting – on       
                         Biosolids before the Solano County Board of 
Supervisors-------

------------“Dr. Rubin  suggested getting some activity going as soon as 
possible for somebody, either EPA, CDC, state health agencies, or local 
health agencies getting out there and seriously beginning to document what  
is happening in communities. I believe that the reports we are getting are 
real, in that people feel sick out there. I read 4-5 reports everyday, and I 
have a stack that is almost 2 feet tall. -------------------“

You will note that was January 2003 and it is now January 2007. The EPA has 
still not moved on this, nor CDC, nor the state, nor the 
locals-----------WHY??????????

The simple answer is that the agency once set up to regulate the sewage 
industry for the protection of humans and the environment has been captured 
by the very industry it was established to regulate. The lesser 
jurisdictions just fallow the federal lead.

This becomes critical when considering where sewage actually goes and what 
it is capable of doing. Take for example the spinach issue in the Salinas 
Valley.

The plant that supplies the irrigation water for the approximately 12,000 
acres, including acreage upon which certified organic crops are grown, is a 
POTW. While there is much ado about wild pigs and cattle, there has been 
little review of the POTW. As noted from Pruden’s work above as well as that 
by Firl, there are other papers out there that conclusively demonstrate the 
inability of currently designed POTWs to effectively cleanse the discharged 
water. Further, the lab tests designed to “assure” that health is not 
impacted, Title 22, can not even see some of the newly emerging infectious 
disease pathogens or those in what is called the viable but non-culturable 
(VBNC) state. Thus water being so tested while passing the standards still 
sees people going to the hospital. Foods offered in commerce inspected under 
these standards see people going to the hospital. There is absolutely 
nothing new here. This has been going on for decades.

Back to the POTW in Monterey. The plant has failed several times. By the 
time these failures are noted, the water has already been put on the crop. 
The lab analyses, in addition to being blind to many pathogens, are 
retrospective. It takes about 24 to 36 hours to get these lab test results 
back. There may be a need for confirmatory tests as no POTW director wants 
to admit the plant burped. So now we are out 36 to 48 hours. Do you think 
they just stop? Is all that water diverted until the system gets the all 
clear? Is all that water, which is now in 45 miles of pipe, just sucked back 
into the plant? No, none of this.

But wait a moment, we have contaminated 45 miles of pipe with loads of 
pathogens. Now we see the development of biofilms, slime protected and 
virtually impossible to disinfect. These biofilms continuously shed 
pathogens. Thus once started, they spread down the pipe, multiply and 
continue to shed. I am informed that no end-of-pipe analyses are 
done---tests are only at the plant. Ask Pat Conrad about biofilms.  In a 
classic case, a hospital’s distilled water system became somehow 
contaminated. This water was used for IV solution preparation. They tried 
any number of ways to destroy the biofilm (remember this is distilled water 
and not sewer water) and they could not. They had to rip-out the entire 
system and start from scratch.

There are myriad other issues with the 45 miles of pipe in this irrigation 
system. I don’t have time here to go into this.

Now, the alternative technologies. If the solids that contain much of the 
material of concern, are removed before they actually enter the plant, 
several advantages can be achieved. First, many of the pathogens are bound 
up in the solids. By removing these solids, compressing them and then 
shunting that to a fluid bed incinerator we capture 85% of the contained 
energy as a useable gas, somewhat more energy efficient than natural gas. If 
we scrub the non-combustibles from this we double the energy BTU out put, 
compared to natural gas. In the incineration, the pathogens, their genetic 
material, the endocrine disrupters, pharmaceuticals, personal care products, 
flame retardants, heavy metals, etc are destroyed. The available technology 
already exists and is produced by a number of different firms. This 
technology has been around for some time.  We are in an energy deficit time 
now, but this is largely ignored. The sewer plant in St Paul, I flew back 
there to see this plant and discuss it with the staff, uses a fluid bed 
incinerator to generate energy that runs the plant. The system had 6 older 
incinerators and these were replaced by 3 Von Roll fluid bed incinerators. 
The old incinerators met EPA air standards, the new Von Rolls have reduced 
the air emissions, compared to the 6 older units, by 98%. Thus the systems 
are very efficient and clean.

Thus by burning the sludge, one need not pay to have it hauled away to 
contaminate farmlands and burning captures the energy. Otherwise by putting 
this on farmlands a number of problems are created, greenhouse gas is one 
with about 3,000 cubic feet of methane being evolved for each ton. Sick 
people in the surroundings is another issue. There are about 3 tons of 
sewage sludge for each million gallons of sewage. There are now papers 
coming out that on the problems associated with land application of sewage 
sludge. Land applied sewage sludge is washing into our streams and rivers to 
bring to the down-stream areas some serious health issues. The Canadians 
have published on this---see------- Shivi Selvaratnam and J. David 
Kunberger-- "Increased frequency of drug-resistant bacteria and fecal 
coliforms in an Indiana Creek adjacent to farmland amended with treated 
sludge".

Once the solids have been separated, this material is no longer available 
for bacterial digestion, which is how POTWs work---bacterial digestion. Thus 
the heavy metals and other solids, although in small particulate form, are 
converted by bacterial action into solution states. Sewer plants are 
incapable of dealing with solutions. Thus this in-solution-material is 
discharged. Chad Kinney of the USGS has recently published several papers on 
the pharmaceuticals that get through, although this in not necessarily a new 
topic. But Kinney’s papers are critical reads here-------see for example

http://www.thenewstribune.com/news/local/story/6102777p-5348116c.html

Thus, there are also technologies that deal with this, again missed on those 
that operate sewer plants. Deep-shaft technologies and electro coagulation 
have been around for some time, yet are eschewed by most of the designers of 
POTWs--------------again why?

Most wastewater engineers and those that run POTWs are not cross-trained in 
now developing critical areas. There are crossed logics here and the 
discipline-oriented academic narrowness of the current academic curricula is 
thus failing to appreciate the need for cross training. Interestingly, when 
I was in clinical practice, I worked with several former Soviet MDs and all 
were cross-trained in several areas, as were their nurses. We rarely see 
cross-trained professionals here. Thus the narrowed perspective precludes a 
more synoptic analysis in problem solving. I happen to be cross-trained, 
having a degree in medicine and a PhD in water quality.

Cheers--------------------Edo
++++++++++++++++++++++++++++++++++
From: "Strutzel, Jon (DHS-DDWEM)" <JStrutze at dhs.ca.gov>
To: "Edo McGowan" <edo_mcgowan at hotmail.com>
Subject: RE: exams??
Date: Thu, 3 Nov 2005 08:33:08 –0800

-----Original Message-----
From: Edo McGowan [mailto:edo_mcgowan at hotmail.com]
Sent: Thursday, November 03, 2005 6:54 AM
To: abc at abccert.org
Cc: Strutzel, Jon (DHS-DDWEM); scfong at waterboards.ca.gov
Subject: exams??

I'm looking for certification exams guides and study material in wastewater 
or drinking water that would include discussions in the area of transferred 
genetic information conferring antibiotic resistance, virulence, or transfer 
genetic materials between organisms. I am also looking for information on 
pharmaceuticals in raw water or finished water or wastewater.
Please indicate which of your study guides might contain such information or 
whether your organization or agency deals with or tests for these subjects.
I look forward to your rapid response via return email.
Dr Edo McGowan, member, Citizens Planning Association of Santa Barbara


Dr McGowan
We do not provide study material for our exams. WE have a list of suggested 
reading material but it does not cover the subjects you are researching.
++++++++++++++++++++++++++++++++++++++++++
From: "NCID Internet Address" <ncid at cdc.gov>
To: <edo_mcgowan at hotmail.com>
Subject: Inquiry on biosolids
Date: Thu, 27 Oct 2005 15:09:51 -0400
    Dear Dr. McGowan,
I am not certain I understand what your question is. Can you clarify?

Thank you for your inquiry.

Internet Response Team
National Center for Infectious Diseases
Centers for Disease Control and Prevention


+++++++++++++++++++++++++++++++++++++++++++++++++

    Dr. Couvalin wrote an excellent paper (EID, Vol 11, #10). I commented, 
however, that there were exceptions to the paper's premise. Chance is 
greatly enlarged by putting these pathogens together in a sewer plant. Thus 
this augments the generation of new genetic mixes. Therefore risk is vastly 
expanded over what would be found in nature.

We have here a good start for arguing that sewer plants, their standards, 
and the land application of sludge are part of a high risk series of 
practices encouraging emergence of new diseases and their dispersal into the 
environment.

Unfortunately, the regulatory community is reluctant to look at this.

CDC writes---"At this time we do not have anyone working on this broad issue 
as it relates to biosolids."

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My group had requested, via Freedom of Information Act, (Feb 2005) certain 
data from the U.S. EPA on their progress dealing with biosolids and 
resistance. In providing us answers to this request, EPA delayed its 
response for about 6 months and then merely directed us to a section of the 
NERL’s website, which contained no usable information. The agency has not 
responded further on this topic as of the close of 2006. The site was 
(www.epa.gov/nerlesd1/chemistry/pharma/fq.htm#disposal), as evidenced by the 
following key-words and search results. Similar results were found for other 
EPA web addresses.
Results of Searching the "Environmental Sciences" Area of EPA's Web Site
No matches found for transposon; 1402 files searched
No matches found for antibiotic resistance + biosolids; 1402 files searched.
No matches found for antimicrobial resistance + biosolids; 1402 files 
searched
No matches found for virulent pathogens + biosolids; 1402 files searched.
No matches found for plasmids + biosolids; 1402 files searched.
No matches found for mobile genetic elements; 1402 files searched.
No matches found for high level disinfection + biosolids; 1402 files 
searched.
Results of Searching EPA's Entire Web Site
We have searched the entire EPA site and found the following results. You 
may also return to searching for the same terms within Environmental 
Sciences.
No matches found for high level disinfection + biosolids; 494732 files 
searched.
No matches found for plasmids + biosolids; 494732 files searched.
No matches found for transposons + biosolids; 494732 files searched.
No matches found for mobile genetic elements + biosolids; 494732 files 
searched.
No matches found for virulent pathogens + biosolids; 494732 files searched.
No matches found for antibiotic resistance + biosolids; 494732 files 
searched.
No matches found for antimicrobial resistance + biosolids; 494732 files 
searched.
Results of Searching the "Exposure Research" Area of EPA's Web Site
We have searched the area of EPA's site related to Exposure Research and 
found the following results. You may also search for the same terms across 
EPA's entire site.
No matches found for prions + biosolids; 3352 files searched.
Results of Searching EPA's Entire Web Site
We have searched the entire EPA site and found the following results. You 
may also return to searching for the same terms within Exposure Research.
No matches found for prions + biosolids; 530969 files searched.
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