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The Metropolitan Sanitary District of Greater Chicago
CUMULATIVE FREQUENCY OF Cd IN SLUDGE SAMPLES FROM SEVEN STATES.
THE VALUE IN PARENTHESIS SHOWS THE NUMBER OF SAMPLES ANALYZED.
(UNPUBLISHED DATA COURTESY OF NC-llt)
100
90
80
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70
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FIGURE 6
WISCONSIN (34)
MINNESOTA (19)
ALL 7 STATES (115)
INDIANA (14)
25
Cd, /jg/g dry basis
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33
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CONTROL OF METALS IN RAW SEWAGE
It has been suggested by many that the levels of metals,
such as cadmium and zinc/ in sludge can be reduced through a
vigorous industrial waste enforcement program. More specifically,
it has been stated by the EPA and USDA that the large metro-
politan areas which have significant industrial waste contri-
butions can reduce their sludge cadmium levels to 10 ppm or less,
via an enforcement program.
Since 1969, the District has had an Industrial Waste Ordi-
ance which has limited the levels of heavy metals for discharge
to the sewer system. This ordinance was put in effect for the
purpose of protecting the biological processes utilized in
sewage treatment and is enforced with a staff of 69 personnel
and an operating budget of 1.0 million dollars.
In Table 9 are presented the maximum allowable sewage
concentrations contained in the 1969 District Ordinance.
Also presented are the metal levels present in sludge from the
District's Calumet plant for 1969, 1972 and 1974. This data
clearly shows significant reduction in the Cd, Cr, Cu, Fe, Hg,
Ni, Pb and Zn content of the Calumet sludge since 1969. Cadmium
reduction is approximately 72%.
Also, one can see that the Zn/Cd ratio has steadily in-
creased. As striking as the decreases in metal levels are,
it is clear that the Calumet sludge has not even approached
the suggested 10 ppm cadmium level or the Zn/Cd ratio of 100.
-34-
-------
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-35-
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In figure 7 are presented the raw sewage cadmium and zinc
levels in Lue Calumet plant's raw sewaqe since 1969. The re-
luction in cadmium to below detection levels in 1972 through
!f*74, from a 1970 cadmium level of 0.01 mq/1, is evident.
Simildrly, but less pronounced, is a reduction in the zinc levels
in Calumet raw sewage since 1969.
It is interesting to note that vigorous industrial waste
enforcement will reduce both zinc and cadmium levels and, there-
fore, may have no effect or a negative effect upon the Zn/Cd
radio. In the case of the Calumet plant, the Zn/Cd ratio did
actually rise;but this may not be the case in all situations.
In the enforcement of an Industrial Waste Ordinance, it would be
unrealistic not to enforce a zinc standard while vigorously
enforcing a cadmium standard.
An earlier edition of the Proposed Standards states that:
...up to 150 percent of the (metals) values
listed in Table 1* may be tolerated if an
abatement program is currently offered which
will have the potential to reduce the sludge
contents to those listed.
Thus, the following concentrations would apply:
Element Proposed ppm 150% of Proposed
Cd 10 15
Cu 1000 1500
Hg 10 15
Ni 200 300
Pb 700 1050
Zn 2000 3000
It is the contention of the MSDGC that this statement is
erroneous, misleading at best, and is included only to divert
attention from the principal issue; namely, that the proposed
* USEPA DOCUMENT "Policy Statement on Acceptable Methods for
the Utilization or Disposal of Sludges"; USEPA, Washington, D.C. 1974
-36-
-------
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limits are arbitrary, unreasonable and are not supported by
any scientific documentation known to the District.
The facts are that the proposed limits cannot be met by
enforcement in the urbanized areas such as Chicago, Milwaukee,
New York City, Philadelphia, Cleveland, and St. Louis, as
evidenced by the data just presented.
-38-
-------
CROP YIELDS AND HEAVY METALS LEVELS IN ROW CROPS DUE
TO SEWAGE SLUDGE APPLICATION
Crop Yields
Implicit in the EPA proposed heavy metal limitations for
sewage sludge is the assumption that the heavy metals in the
sludge will eventually accumulate in the fertilized crop. The
basic stated purpose of the regulations are to limit the amount
of metal (both in concentration and total amount) that is
applied to land and thereby limit the amount in the crop and
ultimately the amount in the human food chain.
It is rather easy for the lay public to understand the
apparent logic of such an assumption. Certainly the concept
of limiting metals applied and therefore the amount taken up
by the plant is a simple and easily understood concept. However,
to the scientist and engineer, the relationship is clearly
more complex and it is not axiomatic that metals applied to
the soil are readily available for plant uptake. The District is
not ayare of any direct scientific evidence available to the EPA to
support this assumption.
The metals present in sewage sludge are not all in ionic
form and many are tied up as metal salts or organic complexes.
Upon application to the soil, the conditions for metal uptake
are complex and depend upon soil type, soil pH, type of crop, etc.
Another assumption in the EPA proposals suggests that
as organic matter decomposes in the soil, metals will be released
in a form that is available to plants. Recent studies by
-39-
-------
Cunningham, et al (16) have shown that successive crops follow-
ing a single application of sludge show successively lower metals
concentrations, although the organic matter in the sludge is
being destroyed.
Since there is a lack of a specific theory or model available
concerning the uptake of metals in sludge by crops, one must
rely upon available scientific data regarding this phenomenon.
The most extensive and comprehensive study conducted in
the United States has been a cooperative project between the
University of Illinois and the Metropolitan Sanitary District
of Greater Chicago (District) which has been partially funded
by the EPA since 1968. Portions of this work has been reported
by Hinesly, et al (17).
The University of Illinois Department of Agronomy established
a field study in 1968 on a Blount silt loam soil occupying part
of the cultivated area on the Northwest Agronomy Research Cen-
ter near Joliet, Illinois. The main objective of the study
was1 to determine how the chemical changes occurring in sludge
fertilized plots would effect soybean and corn nutrition and
the extent of changes in metal levels in these crops.
For soybeans, three 12 x 12 meter plots were established
on Blount silt loam in the fall of 1968 for the following
treatments: (1) zero on conrol, (2) maximum, (3) one-half
maximum, (4) one-fourth maximum application rate of sludge
and (5) well water supplied at the same time and rate as
the maximum sludge application. The maximum rate of
sludge application was one inch per application. The
plots were split and super - phosphate was applied by
-40-
-------
broadcasting on one-half of each plot at a rate to provide
105 Ibs. per acre of elemental phosphorus each year. All
plots received a broadcast application of potassium chloride
to provide 200 Ibs. per acre (224 kg/ha) of elemental potassium.
Immediately after plowing, followed by the ridge and furrowing
operation, Beeson variety soybeans were planted on the ridges.
Digested sludge from the West-Southwest and Calumet
treatment plants of the Metropolitan Sanitary District of
Greater Chicago (District) was applied by furrow irrigation
as often as weather conditions permitted, including applica-
tion, following crop harvesting.
Total annual maximum application of "digested sludge are
presented in Table 10 as liquid amounts containing 1.9 to 4.31
percent solids. In 1972, only one sludge application was made
when soybean seedlings showed what appeared to be signs of
phosphorus toxicity.
Sludge application was begun again after harvesting was
completed in 1972.
Yield responses of soybeans to sludge, phosphorus and water
treatments are shown in Table 11. When the data in Table 10
was subjected to statistical analysis, it was shown that sludge
application significantly increased yield during each of the
five years. However, in 1972, the response to maximum sludge
treatment was negative. Again, this is believed to be due
to a phosphorus toxicity problem. In 1972, the year when sludge
application had a significant negative effect on soybean yields,
-41-
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-43-
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the plant toxicity symptoms observed may be attributable to
phosphorus toxicity, a plant-soil-salt interation, or both.
In another experiment on the Northeast Agronomy Research
Center of the University of Illinois near Joliet, Illinois,
digested sludge from wastewater treatment plants operated by
the District has been applied at various rates, each growing
season on 20 x 44 ft. (6.1 to 12.2 m) plots on a Blount silt
loam soil continuously planted to corn since 1968. The maximum
loading rate of sludge was 1 inch (2.54 cm) of liquid containing
2% to 4% solids applied by furrow irrigation as often as weather
conditions and labor permitted. Lesser amounts of sludge were
applied on the 1/2 and 1/4 maximum treated plots on the same
day sludge was applied to the maximum treated plots. Each
spring, before plowing, the control plots received 300 Ibs/acre
(336 kg/ha) of N and 100 Ibs/acre (112 kg/ha) of P as a broad-
cast application. All plots received an application of 100
Ibs/A (112 kg/ha) of K each spring before plowing until 1974,
when the K fertilizer application was doubled. The four sludge
treatments were replicated in a randomized block design.
The amounts of sludge applied each year on maximum treated
plots are shown in Table 12. It may be noted that sludge solids
content varied from slightly less than 2% to almost 4% by weight.
Such a variation in sludge solids contents contributes to a
variation in annual applications of solids which have varied
from a low of 11.4 tons/acre (25.6 mt/ha) in the growing season
of 1972 to a high of 57.2 tons/acre (128.4 mg/ha) in the relative-
ly dry growing season of 1971.
-44-
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-45-
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Corn grain yields in response to sludge applications are
shown in Table 13. Grain yields were significantly increased
(1% level) by sludge treatments over those obtained from heavily
fertilized corn plots in only 1970 and 1973, when total applied
sludge solids on maximum treated plots amounted to 118 and 139
tons/acre (264 and 312 mt/ha) in each of the respective years.
Although yield increases with increasing sludge application have
been highly significant in only two of the six years, it was
noteworthy that the sludge application at the high rates used
never resulted in yield decrease on the poorly drained Blount
silt loam soil where the pH conditions were not always optimum.
Crop responses to sewage sludge application has been
evaluated by the Metropolitan Sanitary District of Greater
Chicago for many years. To determine the environmental effects
of sludge on agricultural lands experimental corn plots were
developed from a 7-acre (2.8 ha) field at the Hanover Park
Wastewater Reclamation Plant in 1968. The original experimental
design was a randomized block with five replications and three
sludge loading rates of 0, 1/4, and 1/2 inch (0, 6 and 12 mm)
of sludge/week. Sludge from the District's Hanover Park treat-
ment plant has been applied to the plots at weekly intervals
in furrows between growing corn rows since 1968.
Corn yields from 1968 to 1973 are presented in Table 14.
Sludge applications consistently produced yield increases for
corn grown on the Dummer silty clay loam soil with poor natural
drainage.
-46-
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48
-------
It is evidently clear from the crop yield data from both
the Elwood and Hanover data that sludge application results
in a significant yield response from soybeans and corn. In
only one case was a phytotoxic situation evident; namely, in
1972 at the Elwood soybean experiment. However, one may state
that sludge application to soil produces significant yield
responses some of which are equal to or better than those of
inorganic fertilizer.
Heavy Metal Levels
The University of Illinois Department of Agronomy has
probably the most extensive long term field data concerning
the metal uptake of crops continuously fertilized with liquid
digested sewage sludges.
Table 15 shows the element concentration in the tissues
of soybeans receiving sludge at the rate described in Table 10,
An examination of the data contained in Table 15 shows that
zinc, nickel and cadmium contents of soybean tissues were much
increased by sludge application. In comparison to amounts
in plants from control plots, copper contents in above-ground
plant tissues were not increased by sludge application. The
greatest increases in content of zinc, nickel and cadmium in
soybean tissues occurred in plants grown on maximum sludge
treated plots in 1972, the year in which the major portions of
the plants succombed to phosphorus toxicity.
It can be seen that the levels of metals present remain
nearly the same each year and do not reflect the accumulative
yearly applications of sewage sludge.
-------
TABLE 15
Average contents ef several chemical elements in tissues
of soybeans fertilized with various loading rates of
digested sludge. Values are ppm dry weight of plant tissue
Year
Leaf and Petiole
H20
Ck
1/4 Max
'/2 Max
Max
Seed
H2Q
Ck
M Max
'/2 Max
Max
ZINC ppm
1970
1971
1972
1973
29
77
45
42
mm
49
50
41
80
107
146
82
--
162
222
122
180
203
444
191
59
57
50
49
58
58
51
53
68
72
72
69
73
81
82
77
83
85
94
85
COPPER ppm
1970
1971
1972
1973
4.9
6.6
8.9
7.5
»
5.9
8.4
6.6
5.7
6.6
8.6
7.5
6.7
8.0
7.8
4.1
5.9
9.0
6.3
13.1
10.8
13.0
14.0
14.0
11.4
13.0
14.0
14.9
10.7
12.0
13.0
12.5
9.6
13.0
11.0
12.2
9.5
14.0
14.0
NICKEL ppm
1970
1971
1972
1973
3.5
2.7
3.0
3.4
3.0
2.0
3.7
4.7
4.5
5.1
4.5
mm
5.2
6.3
6.3
4.3
5.5
10.9
5.4
6.1
7.4
4.2
5.3
10.1
11.7
6.5
8.6
9.4
13.4
9.9
8.4
10.5
15.7
10.2
9.9
10.5
17.8
16.5
10.6
CADMIUM ppm
1970
1971
1972
1973
0.42
0.26
0.38
0.50
0.30
0.54
0.47
1.70
0.90
2.14
1.10
3.16
4.46
2.00
10.3
7.0
13.9
4.2
0.12
0.35
0.19
0.20
0.12
0.33
0.35
0.25
0.38
0.47
0.55
0.36
0.60
0.96
1.00
0.59
1.08
1.61
3.06
0.79
THE METROPOLITAN SANITARY DISTRICT
OF GREATER CHICAGO
ENGINEERING DEPARTMENT
D.F.M.&W.B. MARCH 1975
-50-
-------
Table 16 presents the levels of metals in the tissues of
mature corn plants at the University of Illinois experimental
station at Elwood which were fertilized with sludge at the
rate described in Table 12. The Zn and Cd contents in corn
leaf, grain and mature plant residues were increased by greater
application of sludge. However, metal concentrations in corn
plant tissues were not elevated by increasing years of sludge
application at the rates used in this experiment. Concentra-
tion levels of Zn and Cd reached a fairly constant value in
corn plant tissue and these levels were not changed by increas-
ing accumulative amounts of sludge applied in subsequent years.
With respect to Cu and Ni concentration in the corn plant
tissues, there was in some years little apparent relationship
with the amount of sludge applied. For example in 1971, the
Cu levels in corn grain were significantly reduced by increas-
ingly greater application rates of digested sludge. There is
evidence that the Cd, Cu, Ni and Zn levels in tissue do not
reflect the accumulative amounts of digested sludge applied
during the experiment.
The effect of sludge application on metal levels in crops
has also been evaluated by the District at its Hanover Park
7-acre research plot.
Analysis of corn leaf is presented in Table 17 and of corn
grain in Table 18 for the sludge application rates presented
in Table 14. Metal uptake by corn was determined by analyzing
corn leaf and corn grain samples. Corn leaf samples were taken
each year from 1969 through 1973 while corn grain samples were
-51-
-------
TABLE 16
Average contents of several chemical elements in tissues of corn continuously
grown and annually fertilized with various loading rates of digested sludge.
Values are ppm dry weight of plant tissues
Year
Leaf
Ck
14 Max
'/2 Max
Max
Groin
Ck
% Max
'/2 Max
Max
Mature Plant Residues
Ck
'/4 Max
V4 Max
Max
ZINC ppm
1970
1971
1972
1973
58
28
56
60
85
95
139
113
138
158
253
223
212**
259**
381**
328**
32
24
22
29
40
36
29
37
50
36
40
51
65**
53**
50**
58**
43
39
133
94
237
193
340**
337**
COPPER ppm
1970
1971
1972
1973
8.9
10.4
12.4
7.4
9.0
9.2
13.6
7.8
10.2
9.5
14.3
6.6
8.7
5.6
15.4*
7.2
2.5
2.4
2.8
2.4
3.6
2.6
3.0
2.6
NICKE
1970
1971
1972
1973
1.5
1.5
3.5
1.1
1.9
1.5
2.9
2.6
2.3
1.9
1.7
4.3
2.6
2.4**
3.0
2.3
0.8
0.6
1.2
3.0
0.8
0.8
0.9
2.9
2.2
2.9
2.6
4.2 *
2.0*
3.1
2.0
10.0
2.3
8.2
2.3
8.5
2.7
7.8
3.0
Lppm
2.2
1.2
1.3
1.3
3.1
3.5**
2.2**
1.7
1.4
0.7
1.2
0.7
1.6
0.7
2.0
1.4*
CADMIUM ppm
1970
1971
1972
1973
0.9
0.2
1.1
0.4
3.0
3.4
9.0
2.3
5.3
7.5
18.8
6.9
11.6*
10.3**
22.2**
13.7"
0.30
0.14
0.14
0.08
0.60
0.70
0.45
0.15
0.79
0.65
0.83
0.35
1.00**
0.92**
1.10**
0.61**
0.4
0.3
4.8
0.8
8.9
4.2
13.2**
12.9**
IRON ppm
1970
1971
1972
1973
107
98
159
126
84
93
160
118
101
98
154
124
112
90
144
118
36
19
30
33
16
30
34
20
32
36
19
35
211
90
231
99
286
82
166
61
MANGANESE ppm
1970
1971
1972
1973
81
59
64
64
83
57
60
40
92
79
126
44
116*
151**
180**
54**
6.0
3.4
8.2
6.0
2.4
6.8
5.5
3.1
6.8
8.2**
4.6**
6.6**
35
29
38
31
47
38
72*
C6
Significant at 5% level.
Significant at 1% level.
THE METROPOLITAN SANITARY DISTRICT
OF GREATER CHICAGO
ENGINEERING DEPARTMENT
D.F.M. & W.B. MARCH 1975
52
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-55-
-------
THE METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
TABLE 18
Range of chemical content of corn grain collected in 1973 from
the Hanover Park experimental corn plots which have received
liquid sludge from 1968 through 1973.
Element
K
Co
Mg
Fe
Mn
Zn
Cu
No
Cr
Ni
Cd
Pb
wit
sludi
2,730 -
43 -
1,100 -
26 -
4.6 -
20 -
1.4 -
19 -
0.5 -
^
c
0.6 -
h
ge
lift /MM flrif
'^ig/gni ory
4,140
74
1,590
42
7.5
33
2.2
70
1.0
0.5
0.5
1.2
without
sludge
2,520 - 3,610
55 - 66
1,290 - 1,440
35 - 48
4.6 - 6.1
23 - 26
1.4 -2.2
20 - 42
0.5 - 1.0
<0.5
<0.5
0.7 - 1.2
accumulative
sludge, metric
tons dry solids
per hectare 107 - 203
56
-------
first taken in 1973.
Ranges of metal content are presented since there were wide
variations in metal content and no significant correlations
among samples from sludge fertilized plots. Significance of
metal uptake by corn leaf was also determined by analysis of
variance using the mean values of metal content for each treat-
ment for each year. There was no significant difference between
the two sludge treatments for any metal, but there was a signi-
ficant difference (0.01 level) between corn leaves from the
sludge-applied and unfertilized plots for Zn, Mn, and Cu.
The concentrations of these three metals were within the common
average composition range for foliage of selected agronomic crops
as reported by Melsted (18): Zn, 15-150 ppm; Mn, 15-150 ppm;
and Cu, 3-40 ppm. Analysis of variance of metal content of
corn grain showed there was no significant difference between
sludge-applied and unfertilized plots in 1973, the only year
grain samples were analyzed, except Ca in which there was
a significant increase (at the 0.01 level) for the 6mm/week
sludge treatment.
The data from both the Elwood and Hanover Park experiment
sites do not show an increasing level of metals with accumulated
yearly sludge application. Metal level in agronomic crops appears
to be related to yearly sludge application only and does not
increase in subsequent years.
The Elwood soybean data indicates that reducing a yearly
sludge application reduces metal levels in crops for that year.
The metal levels in these crops approached in other years have
no effect upon the metal levels in subsequent years.
-57-
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A COMPARISON OF THE UNIVERSITY OF ILLINOIS AND
DISTRICT RESEARCH STUDIES WITH THE PROPOSED
USEPA STATEMENT ON ACCEPTABLE METHODS FOR THE
UTILIZATION OR DISPOSAL OF SLUDGES
The EPA in its proposed policy statement lists the maximum
allowable metal content of sludges which are to be used for
land application. Table 19 presents the proposed USEPA maximum
metal levels and metal content of sludge used in the University
of Illinois and District experiments.
The Cd content of the sludges used at Elwood and Hanover
Park were respectively 24 and 6.6 times the USEPA proposed
values. The sludge used at Elwood exceeded the proposed values
for Zn by 2.2 times. The Ni content of Hanover Park sludge was
1.2 times the proposed maximum allowable content. The proposed
limits for metals given in Table 1 would prohibit the use of
either of these sludges as a source of fertilizer for crops.
The EPA has proposed an equation limiting the total quan-
tity of sludge which may be applied to a given soil according
to the Zn, Cu, and Ni content of the sludge. The application
of the USEPA equation to the Blount silt loam at Elwood, Illinois,
which has a cation exchange capacity of 12 meq/lOOg and for the
sludge properties listed in Table 19 for the Elwood site,
permits a total sludge application of 54.7 dry tons (122 mt/ha)
per acre. For the Elwood corn experiment site up to the end
of 1973, approximately 160 dry tons per acr% (360.0 mt/ha)
of sludge were applied, or 2.9 times the proposed EPA limit.
For the soybean experiment at Elwood, approximately 115 ton/acre
(255.4 mt/ha) have been applied in the six years from 1969 to
1974, or 2.1 times the proposed EPA limit.
-58-
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METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
November, 1974
TABLE 19
THE USEPA PROPOSED METAL CONTENTS AND THE METAL
CONTENTS OF THE DIGESTED SEWAGE SLUDGES USED AT
ELWOOD AND HANOVER PARK, ILLINOIS RESEARCH SITES
Element
Cd
Cu
Hg
Ni
Pb
Zn
Zn/Cd
Proposed
USEPA
mn/L
mg/"
10
1000
10
200
700
2000
= 100
Elwood *
Site
244
970
4.6
200
1250
4400
18
Hanover Park
Sludge
66
624
--
242
352
718
10.9
* Applied sludge came from West-Southwest and Calumet
Sewage Treatment Plants, Chicago.
59
-------
On the Drummer silty clay loam (CEC=31 meg/100 gms) at
Hanover Park, Illinois, the maximum sludge application permitted
by the proposed equation is 348 dry tons per acre (778 mt/ha).
In the six years from 1968-1973, 90 dry tons/acre (203 mt/ha)
have been applied to the Hanover site, or 27% of the maximum
amount proposed by EPA.
The EPA has also proposed limiting the cadmium content of
sludges to less than 1 percent of the zinc con-i-ent or a zinc-
to-cadmium ratio (Zn/Cd) of 100 to 1 or greater. Table 19
indicates that the sludge used in the Elwood and Hanover ex-
periments would not meet this criteria.
The proposed EPA maximum sludge application equation,
the limits on heavy metals levels in sludge, and the Zn/Cd
ratio limitation are claimed by their proponents to be useful
in protecting man and domesticated animals against excessive
accumulation of such metals as Zn, Cu, Ni, and Cd in the consumed
portions of agronomic plants. From the data presented regarding
metal levels in crops grown at the Elwood and Hanover Park
experiment stations, it can be seen that zinc and cadmium co%r
tents in corn grain and mature plant residues are increased
by increasingly greater annual application of sludge. However,
concentration levels in corn plant tissue are not increased by
increasing years of sludge application. Concentration levels
of these two elements reach a more or less constant value in
corn plant tissues that are not changed by accumulative amounts
of sludge applied. The same kinds of statements regarding en-
hanced concentration levels of Zn, Cu, Ni and Cd in soybeans
with sludge application as was made with regard to corn tissues
-60-
-------
can be made from the Elwood soybean data. None of the heavy
metal elements are increased in soybean tissue as a result
of accumulative sludge application.
It seems clear, based upon the Hanover Park and Elwood data,
that the heavy metal levels in sewage sludge are noi the limit-
ing factor in determining application rates. There is no evi-
dence to suggest based upon this research that metals such as
zinc and cadmium accumulate increasingly in crops. The evidence
to date indicates this not to be true and that levels of metals
in crops are to the greatest extent directly related to annual and
to only a minor extent to total accumulated sludge applications.
Other Available Data
Cities as large as Paris, Berlin and Melbourne have operated
"sewage farms" to dispose of sewage and sludge for several decades.
Rohde (19), however, has claimed that the soils at the sewage
farms operated by Paris and Berlin have become exhausted due to
high accumulated levels of Zn and Cu. Leeper (20) reviewed
Rohde1s work and that of Trocne, et al (21), who reported on
manganese deficiency in vegetables at the Paris farm, and re-
interpreted their data. According to Leeper, the problem at
the Paris farm was not Zn and Cu phytotoxicity but rather Zn
deficiency which Trocne, et al reported had occurred around
Paris before 1925.
Melbourne has operated a sewage farm since 1897 at Werribee,
Australia. Johnson, et al (22) analyzed tissue from selected
sites on the farm and concluded that in regard to food chain
-61-
-------
effects, forage contained neither excessive nor deficient amounts
of trace elements. These results are very significant for help-
ing to determine the long term effects of sludge application
or recycle to land.
Kirkham (23) studied the chemical characteristics of corn
plants which had been grown on sludge-fertilized so.Is at Dayton,
Ohio. She reported that the concentration of the metals, cad-
mium, copper, nickel and zinc in corn grain were within those
concentration ranges normally observed in commercially available
plants. The significance of Kirkham1s data lies in the fact
that these corn fields had been used for sludge disposal con-
tinuously for 35 years. Of equal significance also is the fact
that the cadmium content of the sludges used ranged between
800 and 830 mg/1 (dry weight basis) and the Zn/Cd ratio ranged
between 10.1 and 13.1. Chemical characteristics of the sludges
from Dayton, Ohio, are shown in Table 20.
It is clear from these data that the "metal catastrophe"
envisioned by the EPA proposals are more imagined than real.
Though it can be argued, for example, that the work at
Dayton may not qualify as a carefully controlled experiment,
the data presented does offer strong evidence that the EPA
proposals are unrealistic, and that sludge utilization is not
likely to create any additional risks at loadings of 10 to 25
times the ultraconservative limits being proposed.
It should be pointed out here that the USEJPA proposals with
respect to cadmium are similar to Chaney's recommendations first
made public in 1973 (24) and since attributed to the USDA. To
date, neither Chaney nor the USDA have presented any direct
-62-
-------
THE METROPOLITAN SANITARY DISTRICT OF GREATER CHICAGO
TABLE 20
CHARACTERISTICS OF SLUDGE FROM DAYTON, OHIO, SEWAGE
TREATMENT PLANT
(Kirkham, 23)
Measured
Parameter 1931a 197lb
or element
Wet Solids
produced, Kg
PH
Total Solids, %
Volatile Solids, %
N
P
K
Ca
Mg
Ag
Al
AS
Ba
Cd
Cr
Co
Cu
Fe
Hg
Mn
Na
Ni
Pb
V
Zn
PCB (poly-
chlorinated
biphenyls)
2,286,900 8,798,900C
6.7 ...
4.8 6.2
58
34,000 23,400
24,000
2,000
26,000
4,100
360
12,550
1,800
3,020
830
5,900
NDd
6,020
20,370
11.5
1,140
... 1,800
ND
6,940
ND
8,390
105
*
.
5.4
50
*
17,800
*
*
*
*
800
*
4,100
*
15.0
1,200
...
400
4,000
10,500
12.0
aTatlock, M.M., "The Economic Preparation and Sale of Digested
Sludge as Commercial Fertilizer," Sewage Works J., 4, 519-
525 (1932). bFrom B. V. Salotto, National Environmental Re-
search Center, EPA, Cincinnati, Ohio. cFrom the records of
the Dayton, Ohio, Sewage Treatment Plant, 1970 data. dNot
Detected.
-------
scientific evidence to substantiate these recommendations,
to the best knowledge of the District.
In addition to the lack of documented evidence to support
the assumptions made in the EPA proposals and the recommendations
offered by Chaney, there are a number of barriers that act to
protect the food chain from the alleged toxic effect 3 o^l metals
in sludge (25). These include:
a. The metals may be precipitated to spai.'ngly soluble
inorganic forms that are not availab. to plant growth.
Many attempts to measure available met. Is in soils
by the use of an extractant solution have been made.
An extractant that changes the pH must be suspect,
for it is well known that lime or high pH reduces
the availability of metals such as zinc. Chelating
agents, such as DTPA at pH 7.3, appear to correlate
well with plant uptake in some -species (26).
b. The metals are absorbed by organic matter reducing
their activity.
c. Metals are held back by the soil-root barrier. The
rejection of metals varies not only with species but
even with strains accounting for metal tolerant strains
of grasses that colonize mine dumps (27).
d. Metals taken up by roots accumulate preferentially
in the stems and leaves and are not translocated to
the fruits or grains. In this case, typified by the
cereals, total metal uptake by young plants is a poor
indication of the hazard to human food (28,29,23).
e. Metal toxicity usually inhibits growth before concen-
trations toxic to humans have been reached in the
parts used for food (17).
f. Not all metals present in foods are assimilated into
the body burden. Cadmium, for example, is rapidly
excreted in the feces; only 3 to 8% is slowly excreted
and contributes to the body burden (30).
-64-
-------
The EPA proposal is replete with apologies and statements
of conflict. Under the heading "Impact of the Policy Statement1,1
we find the following apologies:
1. The impact will be most significant for land appli-
cation. After examining data on sludges from 180
sources it has been determined that more than 50 per-
cent of the sources would not qualify, including
Milwaukee's milorganite and Chicago's Fult )n County.
For this reason, provision was made foe demonstration
projects under carefully defined and monitored con-
ditions where the sludge exceeds the limits given in
the policy statement.
2. Cost impact and energy impacts have not been included
in this analysis since the only criterion considered
was environmental acceptability.
Under "Application to Agricultural Lands" we find the following:
The criteria in this section are based on limited
information and admittedly EPA is conservative in
defining a sludge acceptable for land application.
Other sludges may also be acceptable as demonstration
projects, including some sludges which do not in
every respect fall within the above limits.
Similarly, we find the following statements of conflict,
page 7:
It is recommended that "Acceptable Methods, Based
Upon Current Knowledge, for the Utilization or
Disposal of Sludge from Publicly Owned Treatment
Plants" be approved....
On page 3, we find:
The Agency is aware that there are research and
demonstration efforts now underway to define op-
timum methods for utilization of municipal sludge.
The present policy statement is based on current
knowledge, and will be modified from time to time
as additional information becomes available.
In spite of the obvious Fallacy of the EPA proposals,
credit must be given to the Agency for admitting: (1) that
the proposals are based on "limited" information and ...conse-
quently have no basis in fact and (2) that the proposals com-
-65-
-------
pletely excluded considerations of cost impact and energy impacts.
However, their statements which indicate that the proposals
are based on current knowledge deserves more severe and direct
criticism. For example, much available information was ignored
from the Agency's own research centers in Cincinnati and Ada,
Oklahoma, and from the MSDGC, the University of Illinois, Ohio
State University, and other State Agricultural Experiment Stations,
It is therefore only reasonable to conclude that the USEPA
proposals relative to metals and loading rates are not supported
by relevarit research findings; and that contrary to the Agency's
statements, the proposals have not incorporated available rele-
vant data. In fact, the proposals present no relevant data
whatever.
-66-
-------
CONCLUSIONS
1. The USEPA proposals are not supported by current and
available relevant research and full-scale field data.
2. The proposals have seemingly ignored relevant data generated
by their own organization and by other organizations.
3. The proposals are based on the assumption that metals
will accumulate to harmful levels in the edible parts of
plants. This assumption is not supported by available
data.
4. Current data show that the proposals would eliminate from
land utilization greater than 90% of the sludges produced
in some areas including the States of Illinois, Wisconsin,
and Indiana.
5. Those states producing sludge which qualifies as "Accept-
able" would still be subjected to severely restricted
loading rates. In some areas with "Acceptable" sludges,
land application would be permitted for only 10 years at
a rate of 10 dry tons/acre/year.
-67-
-------
REFERENCES
1. Lynam, B. T., Report to the Metropolitan Sanitary District
of Greater Chicago on Visit to Rye Meads Works, 1974.
Unpublished.
2. Hinesly, T. D. and Sosewitz, B., 1969. "Digested Sludge
Disposal on Cropland." J.W.P.C.F.
3. Dallaire, G. and Godfrey, N., 1972. "Chicago Reclaiming
Strip Mines with Sewage Sludge." Civil Eng. Journal,
ASCE 98-102.
4. Seitz, W. D., 1972. "An Analysis of Strip-Mining and
Local Taxation Practices." Illinois Agricultural Economics.
5. Dalton, Frank E. and Murphy, R. R., "Land Reclamation
the Natural Cycle." Presented at the 45th Annual Conference
of the Water Pollution Control Federation, Atlanta, Georgia,
October, 1972.
6. Kudrna, Frank L. and Kelly, G. T., '"Implementing the
Chicago Prairie Plan." In Recycling Treated Municipal
Wastewater and Sludge through Forest and Cropland; Sopper
ed. Pennsylvania State University Press, 1973.
7. Peterson, J. R. and Gschwind, J., "Amelioration of Coal
Mine Spoils with Digested Sewage Sludge." Proceedings of
the Research and Applied Technology Symposium, National
Coal Association, Monroeville, Pennsylvania, 1973.
8. Hinesly, T. D., Jones, R. L. and Sosewitz, B., "Use of
Waste Treatment Plant Solids for Mined Land Reclamation."
Mining Congress Journal, September, 1972.
9. Conforth, Carol L., "Treated Waste Water Solids Fertilize
Strip-Mined Land." Coal Mining and Processing, March, 1972.
10. Troemper,A. P., (1974) "The Economics of Sludge Irrigation,"
In Municipal ManagementProceedings June 11-13, 1974,
Pittsburgh, Pennsylvania.
11. The Metropolitan Sanitary District of Greater Chicago,
Department of Research and Development, Unpublished Data,
1975.
12. A Survey of the Chemical Characteristics of Sludges Produced
by Publicly Owned Treatment Plants in Illinois, Unpublished
Data, Dept. of Research and Development, The Metropolitan
Sanitary District of Greater Chicago, 1974.
-68-
-------
13. Konrad, I. G. and Kleinert, S. J.. 1974. "Removal of Metals
from Waste Waters by Municipal Sewage Treatment Plants."
Technical Bulletin No. 74, Department of Natural Resources,
Madison, Wisconsin.
14. Sommers, L. E., Yahner, J. E., and Mannering, J. V., "Chem-
ical Composition of Sewage Sludge from Selected Indiana
Cities," Purdue Journal Paper No. 4957; A Contribution of
the Agricultural Experiment Station, Purdue University,
Ind. Aca. of Sci. Vol 82: 424-432 (1972).
15. North-Central Regional Agricultural Experiment Station
Committee (NC-118) on Utilization and Disposal of Agri-
cultural Processing Wastes on Land. Unpublished Data.
16. Cunningham, et al (Univ. of Wise. 1975) "Yield and Metal
Composition of Corn and Rye Grown on a Neutral (pH 6.8)
Soil Amended with Wastewater Sewage Sludge.: J. Env. Qual.
in press.
17. Hinesly, T. D., Braids, O. C., Dick, R. I., Jones, R. L.
and Molina, J. A. E., 1974. Agricultural Benefits and
Environmental Changes Resulting from.the Use of Digested
Sludge on Field Crops. Report from the University of 111.,
Urbana, to the Metro. San. District of Greater Chicago.
18. Melsted, S. W., 1973. Soil-plant RelationshipsSome
Practical Considerations in Waste Management. Proceedings
of the Joint Conference on Recycling Municipal Sludges and
Effluents on Land. University of Illinois, Urbana, 111.,
July 9-13, 1973.
19. Rohde, Gustav, 1962, "The Effects of Trace Elements on the
Exhaustion of Sewage-Irrigated LAND," Inst. Sew. Purific.,
London. Journal and Proceedings, pp. 581-585.
20. Leeper, G. W., 1974. Heavy Metal Issues: The Use of Sludge
as an Agricultural Resource. Manuscript Pending Publication.
21. Trocne1, S., Barbier, G. and Chabannes, J., 1950. Researches
Suer La Chlorose Par Carence De Maganese Des Cultures
Irriguees al'eau d'egout. Annales Agronomique, 1:663-685.
22. Johnson, R. D., Jones, R. L., Hinesly, T. D. and David, D. J.,
1974. Selected Chemical Characteristics of Soils, Forages
and Drainage Water from the Sewage Farm Serving Melbourne,
Australia Department of the Army, Corps of Engs.
23. Kirkham, M. B., "Trace Elements in Corn Grown on Long-
Term Sludge Disposal Site," Envir. Sci. and Tech., 9:765-768,
August, 1975.
-69-
-------
24. Chaney, R. L., 1973. Crop and Food Chain Effects of Toxic
Elements in Sludges and Effluents. In Proceedings of the
Joint Conference on Recycling Municipal Sludges and Effluents
on Land. National Assoc. of State Univ. and Land-Grant
Colleges, Washington, D. C.
25. Dean, R., B., "Hazards from Metals and Organic Pollutants
in Sludge from Municipal Treatment Plants" presented at the
- Conference in Connection with the Internat'l rater Con-
servancy Exhibition, Jonkoping, Sweden, September 1-5, 1975.
26. Lindsay, W. L. and Norwell, V. A. (1969) "Development of
a DTPA Micro-Nutrient Soil Test." Agronomy Abs. p. 84.
27. Smith, R. A. and Bradshaw, A. D., 1972, "Stabilization of
Toxic Mine Wastes by the Use of Tolerant Plant Populations."
Inst. Mining & Met. Trans. Sect. A., 81 (Oct.) A 230-37.
28. Kirkham, M.B. (1974), "Trace Elements in Sludge." Science
184, p. 1030
29. Kirkham, M. B. (1974), "Disposal of"Sludge on Land." Compost
Sci., 15(2) 6-10.
30. Fleischer, M., et al,(1974) "Environmental Impact of Cadmium,"
Environmental Health Perspectives. No. 7, pp 253-323.
-70-
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APPENDIX I
Additional Guideline Titles
-------
Additional Guideline Titles
Section 2. SLUDGE UTILIZATION METHODS
2-1. Stabilization
2-2. Additional Pathogen Reduction
2-3. Sludge Characteristics
2-4. Site Soils
2-5. Crops Suitable for Sludge Application
2-6. Public Areas
2-7. Ground Water Protection
2-8. Controlling Surface Water Runoff
2-9. Application to Agricultural Lands
a. Some projects of minimal concern
(1) Design flow of the publicly owned
treatment
(2) Where the sludge is applied to city-
owned or government controlled land
dedicated to receive sludge
(3) Where the sludge operation is a
commercial activity, such as bagged
soil conditioner
b. For larger projects, or those not other-
wise controlled
(1) Protection of food products
(2) Use of other sludges
(3) When the project includes sludge
application to agricultural lands
r-10. Sludge Application Methods
2-11. Application Rates
2-12. System Operation
2-13. Monitoring
2-14. Surveillance of Operation and Monitoring
-------
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Flow
Chicago, II 60604-3590
-------