Sludge Watch ==> Imperial Valley California - Ballot Initiative Delay

[Maureen Reilly]

Sludgewatch Admin:

There is a group in Imperial Valley California looking to prevent the 
importation of sludge into Imperial Valley.  The initiative is aimed against 
a proposed power plant.   The initiative sponsors have posted expensive 
billboards that read 'Enjoy your veggies without toxins'...as though it is a 
sludge land application proposal that is being proposed.  There is no land 
application of sludge in Imperial County due to a strongly worded county 
ordinance.

The proposed ballot initiative does not oppose the land application of 
Imperial Valley sewage sludge two hours away on farmland in Yuma 
Arizona....where the sludge – some of which is neither digested nor even 
screened - is applied to farmland - tampax, syringes, heart monitors, 
plastics, condoms and all.  The farmer who spreads Imperial Valley’s sludges 
says that the personal hygiene items often end up in the harvested crop - to 
the disgust of their customers.

The proposed ballot initiative would do nothing to stop the high traffic in 
sludge trucks from all parts of California that now travel through Imperial 
County to farmfields in Arizona.

Due to Arizona's more lax regulatory environment it is now the destination 
of choice of much of California's sludge.  Indeed, most of the sludge 
applied to farmland in Arizona comes from California.  This is an increasing 
concern especially in the spinach / lettuce growing areas in Yuma where 
organic tender greens grow next to fly-infested sewage sludged fields.

The Imperial Valley sewage treatment plants are routinely fined for 
pollution of the New River - but since some Imperial Valley sewage ‘plants’ 
don't really have any equipment they pay their fines and continue to 
pollute.  The Brawley sewage treatment plant, for example,  has been hit 
with 30 violation notices in the past 10 years.

See: 
http://ciwqs.waterboards.ca.gov/ciwqs/readOnly/ciwqsReportEnforcement.jsp?reportID=5&place=7&facility=Brawley+City+WWTP&pageSize=25&pageCur=1&sortOrder=VIOLATION_TYPE&sortDir=ASC

Below the following news story is a report on Imperial Valley sludge 
prepared by the Imperial County staff.
..........................................................

June 20, 2007

Supes delay vote on sludge measure
  PETITION: Board grapples with legality.

By BRIANNA LUSK
Staff Writer

  A crucial deadline looms for a ballot measure aimed at banning the 
importation of sludge into Imperial County as officials grapple with whether 
proper procedures were followed.

  At issue is the certification of a petition submitted by the citizens 
group, Imperial Valley Residents for Health and Safety First, which would 
put the ordinance on the November ballot.

The deadline
  for the County Board of Supervisors to place the ordinance on the ballot 
is July 5.
  The petition was up for certification by the Imperial County Board of 
Supervisors on Tuesday but was pulled off the agenda by county Registrar of 
Voters Dolores Provencio.
  “I have some concerns about the publication process and petition format,” 
Provencio told the board.  It will brought back to the board July 3.

  Provencio later said she  is conferring with county counsel on whether 
proper procedures were followed but would not elaborate on those procedures.
  “Until I meet with counsel I’m not prepared to discuss it any further,” 
Provencio said.
  Supervisor Victor Carrillo asked whether the delay on the board’s vote 
could “jeopardize its placement on the November ballot.”


  “It’s not a question I feel I can answer at this time,” Provencio said.
  The ordinance is aimed to block the importation and disposal of sewage 
sludge .
  It also would prevent governmental bodies from authorizing the disposal of 
imported sludge .  The petition is the group’s latest effort to stop a 
proposed sludge
  -to-energy plant from being built in Imperial County.
  An environmental impact review is under way for the Liberty Energy XX 
plant, headed by Bakersfieldbased Liberty Energy.

  The environmental impact report could be released as early as November.
  Supervisor Larry Grogan has already raised questions of whether the 
ordinance is constitutional.
  County Counsel Ralph Cordova will not comment on the record, other than to 
say that he has some concerns about the way the ballot measure is worded.
  According to California Elections Code, the board can adopt the ordinance 
without alteration or submit the ordinance to the voters.

  After months of gathering signatures, Monique Lopez, a member of Residents 
for Health and Safety First, said the county seems to be searching for cause 
to prevent the measure from going to a vote.

  Lopez said the group was not informed that there were concerns about the 
processes they followed in gathering petition signatures.
  “It’s a concern of mine because it does not show transparent government,” 
Lopez said.


..................................
Biosolids Generation and Management
In Imperial County (August 2006)

Imperial County has fifteen wastewater treatment facilities, which are 
operated by municipalities, the Naval Air Facility, the County (Gateway to 
the Americas facility), and several community service districts.  While 
there is currently no estimate of the total volume of sewage sludge 
generated in Imperial County, these fifteen plants generate an estimated 
4,000 dry tons of biosolids per year, which is, by far, the majority of 
sludge material generated within Imperial County.  Several small wastewater 
treatment systems and package treatment plants also exist within the County 
to serve mobile home parks and schools, but the amount of sludge being 
accumulated from these systems is minimal and therefore is not specifically 
discussed in this report.

Additional sewage sludge generated by on-site sewage (septic) systems within 
the County is taken by licensed haulers to the Calexico, Holtville, or 
Westmorland wastewater treatment plants.  The California Regional Water 
Quality Control Board, Colorado River Basin, regulates the operation all of 
the wastewater treatment facilities.  (Imperial County Environmental Health 
regulates the installation of small on-site septic systems, but these 
systems are not subject to the same operational regulations as the larger 
facilities.)

In general, while there are minor variations in the specific treatment 
processes applied, the treatment plants receive wastewater for separation 
into solids and liquids through gravity and/or mechanical devices, break 
down solids through bacterial action, and reduce potential disease-causing 
microorganisms through sunlight, aeration, digestion, disinfection, and/or 
desiccation.  The sludge is retained in drying beds or lagoons for periods 
ranging from several months to several years, depending on the rate of 
accumulation, storage capacity, and budgetary considerations.

Sewage sludge from wastewater treatment plants that undergoes treatment to 
meet the land-application standards of the federal Clean Water Act, Part 503 
is typically referred to as “Biosolids.”  Biosolids may be beneficially 
recycled and are classified into either Class A Biosolids and Class B 
Biosolids depending on the treatment processes that have been conducted on 
the primary sewage sludge to reduce pathogens, and the results of required 
analytical testing.

Prior to transport of biosolids from wastewater treatment plants, samples 
are collected and tested in accordance with Section 503.8 of Title 40, Code 
of Federal Regulations.  Required analytical data includes testing for 9 
specific inorganic pollutants (trace elements, including metals) and 
pathogens (bacteria and viruses).  Class A biosolids are essentially free of 
pathogens; whereas Class B biosolids have low levels of pathogens and must 
be managed to prevent public exposure.  “Exceptional Quality” Class A 
biosolids have lower trace element concentrations than either Class A or 
Class B biosolids and can be produced when there is enhanced regulation of 
wastewater generators to improve discharge quality into the sewer.  The 
biosolids produced by the 15 wastewater treatment plants within Imperial 
County listed in Attachment A are essentially all Class B, based on the 
analytical testing.

In general, Class A biosolids can be considered for a wider range of uses 
with less regulatory intervention than Class B because of the almost total 
elimination of pathogens.  Sensitive uses such as direct land application to 
human food crops (but not “organic” foods, which is prohibited by USDA) and 
soil amendments marketed for home landscaping can be allowed.  Class B 
biosolids have a pathogen concern and must be managed to prevent human 
exposure (direct or indirect) to those pathogens.  Therefore Class B 
biosolids are much more restrictive in terms of available uses.  A very 
typical use of Class B is agricultural land application for animal forage 
crops, but not for human food crops.

The biosolids generated from wastewater treatment plants in Imperial County 
are being managed by one of the following three methods: agricultural land 
application in Arizona, landfill disposal at municipal solid waste landfills 
in Imperial County and Arizona, or deposited in lagoons for long term 
storage.

Currently, a number of wastewater plants in the Valley have contracted with 
Levitt Farms to haul and apply biosolids as a fertilizer or beneficial soil 
amendment at Arizona registered land application sites, either at the Levitt 
Farm in Dateland (Yuma County) or at the Skousen-Hyder Farm in Maricopa 
County, Arizona.  The cost to Imperial County wastewater plants for trucking 
and land application of biosolids in Arizona is currently $30 per ton, for a 
total cost in 2005 of about $109,665.

Loren Fondahl, Biosolids Coordinator for the US EPA Region 9, indicated that 
the wastewater treatment plants submit annual reports to US EPA in addition 
to submitting sampling reports to the entities receiving biosolids for land 
application.  Annual reports are also submitted to the Arizona Dept of 
Environmental Quality (ADEQ), which has the sewage sludge program and 
enforcement authority in Arizona.  Ms. Fondahl indicated that she is unaware 
of any citations being issued for mismanagement of Imperial County generated 
biosolids in connection with land applications in Arizona.

Landfilling sewage sludge at the Allied Imperial Landfill (Imperial County) 
or at the La Paz County Landfill near Parker, AZ is another biosolids 
handling method employed by Imperial County sewer entities.  Allied Imperial 
Landfill is currently the only landfill permitted to accept biosolids in 
Imperial County.  The negotiated cost of landfill disposal of biosolids has 
ranged from $33 to $170 per ton.

Lagoon storage is another common management technique used in Imperial 
County, in which the sludge is stored for long periods in lagoons.  The 
frequency in which the accumulated sludge is dried and removed is dependent 
upon accumulation rates and the storage capacity of existing and proposed 
ponds or lagoons at the facility.  Based on current data, when the biosolids 
are ultimately removed from these lagoons, they would most likely be 
land-applied or disposed of in a landfill.

Of the approximately 4,000 dry tons of biosolids generated each year in 
Imperial County, nearly 92 percent of this is being land-applied in Arizona 
and about 5 percent is being landfilled either locally or in Arizona.  The 
remaining 3 percent goes into lagoons at various facilities within the 
County, a similar percentage to the statewide estimate for placement in 
lagoons.  Current biosolids management across the State of California 
follows a much more varied pattern than what we observe locally.  Of the 
750,000 dry tons of biosolids generated within California each year, 
slightly more than half is land-applied (54%).  Composting (16%) and 
alternative daily cover at landfills (12%) constitute relatively large 
percentages, and landfill disposal accounts for 6 percent of all biosolids 
disposal in the State.  A small percent is also incinerated (5%), surface 
disposed (4%), and placed in lagoon storage (3%).  (See chart for a 
percentage breakdown graphically displayed.)

As a method to enrich nutrient-depleted soils, land application has been the 
most widespread beneficial use of biosolids.  However, public concern and 
perception have limited the acceptance of this practice, particularly for 
direct market human food crops.  These concerns are often related to 
potential soil and water contamination by metals and the ingestion of trace 
organic pollutants (e.g. dioxins, PCBs) by grazing livestock or through 
human consumption of edible root crops, etc.  As an example of public 
concern, in June of this year, a ballot initiative (Measure E) was passed in 
Kern County that directed the county to adopt a local ordinance to ban the 
land application of all biosolids in the unincorporated areas of the County 
effective January 1, 2007.  Although the City of Los Angeles has received 
special recognition by the EPA for its Biosolids Management Program and has 
been shipping only Class A biosolids to Kern county since 2003, public 
objections to the importation of biosolids from Los Angeles and Orange 
County have remained high.

The USDA currently prohibits the use of biosolids in the production of 
“organic foods.”

Biosolids management options that have received the most interest in the 
State of California for potential beneficial use have generally involved 
composting to produce Class A biosolids, which are more marketable due to 
their low risk from pathogens, for various types of land applications, 
including agricultural, commercial, public and private applications.  
Composting is a stabilization process in which organic material undergoes 
biological degradation to achieve an end product that is a sanitary, 
nutrient-rich soil amendment.  The resulting Class A biosolids are often 
marketed as soil amendments or fertilizers for landscaping and similar uses 
like public gardens, parks, golf courses, land reclamation projects, and/or 
other agricultural crop or horticultural applications.  Market demand for 
composted biosolids, however, has been lower than anticipated.

More limited uses, such as for land reclamation projects, crops grown for 
ethanol fuel production, carbon sequestration projects (e.g. projects that 
provide “offsets” against climate altering CO2 and other carbon containing 
emissions), landscaping, or non-food agricultural operations may become much 
more widely accepted as better assessments of land application risks are 
developed.  Upstream biogas generation from the anaerobic digestion of 
sewage sludge may also reduce the volume of biosolids in the future at 
larger wastewater treatment facilities as energy costs increase.

Finally, another beneficial use that may become more widely used is the use 
of biosolids as an alternative daily cover (ADC) at municipal solid waste 
landfills.  For example, biosolids might be blended with soil to augment 
daily cover of landfill wastes rather than using soil alone as the cover 
material to control vectors, fires, odors, blowing litter, and scavenging.  
Approximately 12 percent of biosolids disposed of each year in California is 
routinely used to augment daily cover at 3 of 161 active landfills in 
California.  Landfills must first obtain written approval by the local 
enforcement agency prior to use, and specific limits on the relative amount 
and placement of biosolids as an alternative daily cover are contained in 
California regulations.  Presently, biosolids are not used for this purpose 
in Imperial County.

Several of the wastewater treatment facilities in Imperial County expressed 
interest in further exploring beneficial use options for biosolids that they 
generate.  In California, regional planning to include biosolids management 
options for out-of-county generated biosolids appears to remain a pressing 
issue as seen in the case of Kern County mentioned earlier.

While the scale of biosolids generation within Imperial County is 
substantially smaller than in more urbanized areas of California, planning 
to develop contingencies for local handling of biosolids and initiating 
discussions regarding regional biosolids management may be worthwhile 
endeavors.