TRANSCRIPT
PUBLIC HEARING
OIM THE
PROPOSED CLASSIFICATION
CRITERIA FOR SOLID WASTE
DISPOSAL FACILITIES
MARCH 1, 1978
SAN DIEGO, CALIFORNIA

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TRANSCRIPT
Public Hearing
on Proposed Classification Criteria
for Solid Waste Disposal Facilities
March 1, 1978, San Diego, California
This hearing was sponsored by EPA, Office of Solid Waste,
and the proceedings (SW-34p) are reproduced entirely as transcribed
by the official reporter, with handwritten corrections.
U.S. ENVIRONMENTAL PROTECTION AGENCY
1978

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PANEL MEMBERS:
DR. JOHN SKINNER, CHAIRMAN
DIRECTOR, SYSTEMS MANAGEMENT DIVISION
OFFICE OF SOLID WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
MR. TRUETT DE GEARE
CHIEF, LAND PROTECTION BRANCH
SYSTEMS MANAGEMENT DIVISION
OFFICE OF SOLID WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
MR. KENNETH SHUSTER
PROGRAM MANAGER, LAND PROTECTION BRANCH
SYSTEMS MANAGEMENT DIVISION
OFFICE OF SOLID WASTE
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C.
MR. JAMES K. CHANNELL
CHIEF, HAZARDOUS MATERIALS BRANCH
AIR AND HAZARDOUS MATERIALS DIVISION
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IX
SAN FRANCISCO, CALIFORNIA
MR. ANTHONY GARVIN
OFFICE OF REGIONAL COUNSEL
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IX
SAN FRANCISCO, CALIFORNIA
SPEAKERS:
MICHAEL L. KIADO
MICHAEL SELNA
ROBERT E. VAN HEUIT
HENRY HYDE
BILL DAVIS
CLARENCE KAUFMAN
ARLO KEITH AMUNDSON
CLAY KELLOGG
PAUL MNOIAN

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SAN DIEGO. CALIFORNIA - WEDNESDAY, MARCH 1, 1978. 7:30 P.M.
DR. SKINNER: GOOD EVENING. I WOULD LIKE TO
WELCOME ALL OF YOU TO A PUBLIC HEARING THAT IS BEING
CONDUCTED BY THE UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY ON A PROPOSED REGULATION ENTITLED "CRITERIA FOR
CLASSIFICATION OF SOLID WASTE DISPOSAL FACILITIES."
THIS REGULATION IS BEING PROPOSED UNDER THE AUTHORITY
OF SECTION 4004 OF THE SOLID WASTE DISPOSAL ACT AS
AMENDED BY THE RESOURCE CONSERVATION AND RECOVERY ACT
OF 1976. THIS IS PUBLIC LAW 94-580.
THE REGULATION IS ALSO BEING PROPOSED UNDER
SECTION 405(D) OF THE FEDERAL WATER POLLUTION CONTROL
ACT AS AMENDED BY THE CLEAN WATER ACT OF 1977. THAT
IS PUBLIC LAW 95-217.
THE PROPOSED REGULATION WAS PUBLISHED IN THE
FEDERAL REGISTER ON FEBRUARY 6, 1978, AND THERE WILL BE
A 90-DAY PUBLIC COMMENT PERIOD ENDING ON MAY 8, 1978.
COPIES OF THE PROPOSED REGULATION, AND COPIES OF
THE RESOURCE CONVERSATION AND RECOVERY ACT ARE
AVAILABLE AT THE TABLE TO THE SIDE THERE.
THERE ARE ALSO COpIES AVAILABLE OF OTHER
REGULATIONS AND OTHER REPORTS ISSUED BY EPA.
THIS IS THE FIRST OF FOUR PUBLIC HEARINGS THAT
WE WILL BE HAVING ON THIS REGULATION.

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WE WILL ALSO BE HAVING A NUMBER OF PUBLIC
MEETINGS WHICH WILL BE MORE INFORMAL THAN THESE
HEARINGS.
ANNOUNCEMENT OF ALL OF THE PUBLIC HEARINGS AND
ALL OF THE PUBLIC MEETINGS ON THIS PROPOSED REGULATION
WAS PUBLISHED IN THE FEDERAL REGISTER ON FEBRUARY 27TH.
THAT IS MONDAY OF THIS WEEK.
THE ADDITIONAL HEARINGS WILL BE HELD IN
WASHINGTON, D.C. ON APRIL 21ST; KANSAS CITY, MISSOURI
ON APRIL 24TH; AND PORTLAND, OREGON ON APRIL 26TH.
AN ENVIRONMENTAL IMPACT STATEMENT IS BEING
PREPARED ON THIS REGULATION, AND A DRAFT OF THAT
STATEMENT SHOULD BE AVAILABLE FOR PUBLIC REVIEW TOWARDS
THE END OF THIS MONTH.
AND NOTIFICATION OF THE AVAILABILITY OF THE
DRAFT OF THE ENVIRONMENTAL IMPACT STATEMENT WILL ALSO
BE PUBLISHED IN THE FEDERAL REGISTER AND WE WILL HAVE
AT LEAST A 45-DAY PUBLIC COMMENT PERIOD ON THE DRAFT
OF THE ENVIRONMENTAL IMPACT STATEMENT.
FOR FURTHER INFORMATION ON THE PUBLIC HEARINGS
AND THE PUBLIC MEETINGS I AM GOING TO READ AN ADDRESS
THAT YOU SHOULD CONTACT -- THIS ADDRESS IS ALSO
AVAILABLE AT THE REGISTRATION DESK -- BUT FOR FURTHER
INFORMATION ON THE PUBLIC HEARINGS AND THE PUBLIC
MEETINGS YOU SHOULD CONTACT MRS. GERRI WYER, W-Y-E-R,

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THE PUBLIC PARTICIPATION OFFICER OF THE OFFICE OF
SOLID WASTE, UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY, *+01 M STREET, S.W., WASHINGTON, D.C., THAT'S
20460. AND MAIL CODE ON THAT IS "WH562."
A VOICE: WILL YOU REPEAT THAT, PLEASE?
MR. SKINNER: YOU CAN FIND THE INFORMATION AT
THE REGISTRATION DESK RATHER THAN REPEATING IT, IF
YOU'RE INTERESTED.
WE ARE MAINTAINING AN OFFICIAL RECORD OF ALL
COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND
THIS RECORD IS REFERRED TO AS "DOCKET 4004," AND ALL
COMMENTS SHOULD BE ADDRESSED TO THAT DOCKET AT THE SAME
ADDRESS AND THAT ADDRESS IS ALSO AT THE REGISTRATION
DESK .
ALL MAJOR SUBSTANTIVE COMMENTS MADE WILL BE
ADDRESSED IN THE FINAL PROMULGATION OF THIS REGULATION.
THIS HEARING IS BEING RECORDED AND A VERBATIM
TRANSCRIPT WILL BE PLACED IN THE DOCKET AND THE
DOCKET IS AVAILABLE FOR PUBLIC REVIEW DURING NORMAL
WORKING HOURS AT EPA HEADQUARTERS, WASHINGTON.
THE PURPOSE OF THIS HEARING IS FOR THE PUBLIC TO
PRESENT THEIR VIEWS ON THE PROPOSED REGULATION, AND WE
WILL START THE HEARING WITH STATEMENTS FROM A NUMBER
OF PARTIES WHO HAVE REQUESTED PERMISSION TO MAKE A
FORMAL STATEMENT, AND I BELIEVE WE HAVE TEN SUCH FORMAL

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STATEMENTS TO 8E MADE, AND I WOULD ASK THAT THESE
STATEMENTS BE SUMMARIZED IN A PERIOD OF APPROXIMATELY
TEN MINUTES EACH. IF YOU HAVE A LONGER WRITTEN
STATEMENT THAT YOU WOULD LIKE TO MAKE YOU CAN SUBMIT
THIS TO THE RECORDER AND IT WILL BE PUBLISHED IN THE
TRANSCRIPT IN ITS ENTIRETY.
BUT I WOULD APPRECIATE IT, FOR THE SAKE OF TIME,
IF YOU COULD SUMMARIZE YOUR REMARKS IN A PERIOD OF
APPROXIMATELY TEN MINUTES.
FOLLOWING EACH STATEMENT THE PANEL MAY ASK
QUESTIONS OF THE PEOPLE PRESENTING THE STATEMENTS.
THIS IS NOT A FORMAL ADJUDICATORY HEARING AND
THERE IS NO CROSS-EXAMINATION OF THF PARTIES MAKING
STATEMENTS, SO ANY SUCH RESPONSE TO THE QUESTIONS
ASKED BY THE PANEL IS VOLUNTARY.
FOLLOWING THE PROPOSED STATEMENTS WE WILL ACCEPT
QUESTIONS FROM THE REST OF THE PEOPLE ATTENDING.
QUESTIONS MAY BE DIRECTED TO ANY MEMBER OF THE
PANEL OR THEY MAY BE DIRECTED TO A PREVIOUS SPEAKER.
ALL QUESTIONS SHOULD BE SUBMITTED IN WRITING ON
CARDS THAT WILL BE PASSED OUT TO YOU IN A COUPLE OF
SECONDS AND THEN PASSED TO THE PERSON WHO IS
DISTRIBUTING THEM AND THEY WILL BRING THEM UP AND WE
WILL ASK THE QUESTIONS THAT ARE WRITTEN DOWN.
LET ME INTRODUCE THE PANEL.

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MY NAME IS JOHN SKINNER AND I AM THE DIRECTOR
OF THE SYSTEMS MANAGEMENT DIVISION OF THE OFFICE OF
SOLID WASTE, UNITED STATES ENVIRONMENTAL PROTECTION
AGENCY IN WASHINGTON, D.C.
ON MY IMMEDIATE RIGHT IS MR. KENNETH SHUSTER.
HE IS THE PROGRAM MANAGER OF THE LAND PROTECTION
BRANCH IN THE OFFICE OF SOLID WASTE IN WASHINGTON AND
HE IS THE PRIMARY AUTHOR OF THE PROPOSED REGULATION.
NEXT TO HIM IS MR. TRUETT DE GEARE WHO IS CHIEF
OF THE LAND PROTECTION BRANCH, OFFICE OF SOLID WASTE,
EPA IN WASHINGTON.
NEXT TO HIM IS MR. ANTHONY GARVIN WHO IS FROM THE
OFFICE OF REGIONAL COUNSEL IN THE EPA REGIONAL OFFICE,
REGION NO. IX IN SAN FRANCISCO.
NEXT TO HIM IS MR, JAMES CHANNELL WHO IS THE
CHIEF OF THE HAZARDOUS MATERIALS BRANCH, EPA REGIONAL
OFFICE NO. IX IN SAN FRANCISCO, CALIFORNIA.
I WOULD LIKE TO TURN TO THE PREPARED REMARKS.
WE WILL START WITH THOSE PEOPLE WHO PRE-REGISTERED
AND REQUESTED PERMISSION TO MAKE A STATEMENT, AND THEN
WE WILL MOVE ON TO THE PEOPLE WHO REGISTERED TONIGHT
AND ASKED TO MAKE A STATEMENT.
THE FIRST PERSON IS MR. MICHAEL KIADO.
IF YOU COULD SPELL YOUR NAME AND GIVE YOUR
AFFILIATION AND THEN MAKE YOUR STATEMENT.

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MR. KI ADO: MY NAME IS MICHAEL L. KIADO,
K-I-A-D-O. I AM WITH THE CALIFORNIA DEPARTMENT OF
HEALTH AND I AM REPRESENTING THEM TONIGHT.
I AM A REGISTERED CIVIL ENGINEER WHOSE
RESPONSIBILITY IS TO DEVELOP THE DEPARTMENT OF HEALTH
PROPOSED POLICY AND/OR GUIDELINES PERTAINING TO THE
USE OF SEWAGE SLUDGE.
MY COMMENTS TONIGHT ARE ON THE TOPIC OF CADMIUM
IN SEWAGE SLUDGE THAT MAY BE ADDED TO PRIVATELY-OWNED
AGRICULTURAL LAND OR TO SOIL WHICH MAY BECOME A HOME
VEGETABLE GARDEN.
AS WE SEE IT, THE CRITICAL ISSUE REGARDING THE
ADDITION OF SEWAGE SLUDGE TO PRIVATELY-OWNED
AGRICULTURAL LAND IS THAT REPRESENTATIVES OF THE
FEDERAL FOOD AND DRUG ADMINISTRATION APPEAR TO BE
SERIOUSLY CONCERNED ABOUT POSSIBLE INCREASES IN THE
AMOUNT OF CADMIUM IN THE DIET.
FDA REPRESENTATIVES HAVE DISPLAYED THEIR CONCERN
BY INDICATING THAT FDA MAY ESTABLISH MAXIMUM PERMISSIBLE
CADMIUM CONCENTRATIONS IN FOODS. IF FDA TAKES ACTIONS
ADVERSE TO THE SALE OF FOODS WHICH VIOLATE AN FDA
STANDARD ON CADMIUM, A FARMER WHOSE SOIL IS RICH IN
CADMIUM THAT IS AVAILABLE FOR UPTAKE BY PLANTS MIGHT
HAVE TO RESTRICT HIS PLANTINGS TO: Cl) SPECIES WHICH
TRANSFER RELATIVELY LITTLE CADMIUM TO THE EDIBLE

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PORTION; (2) PLANTS THAT DO NOT PRODUCE FOOD EATEN BY
HUMANS; OR (3) PLANTS NOT EATEN BY AN ANIMAL THAT
PRODUCES A PRODUCT EATEN BY HUMANS. TO OUR KNOWLEDGE,
FDA HAS NOT INDICATED THAT IT WOULD EXEMPT HIGH
CADMIUM PRODUCE FROM A STANDARD TO FACILITATE THE USE
OF CADMIUM-RICH WASTE IN AGRICULTURE.
EPA'S PROPOSED CRITERIA, PUBLISHED IN THE
FEDERAL REGISTER ON FEBRUARY 6, 1978, WOULD ALLOW
AGRICULTURAL SOILS TO BE MADE EXTRAORDINARILY RICH IN
CADMIUM THROUGH THE ADDITION OF CADMIUM-RICH SEWAGE
SLUDGE. IT APPEARS ESSENTIAL THAT STATE AND LOCAL
AGENCIES WHO REGULATE THE USE AND DISPOSAL OF WASTES,
AND WHO ADVISE FARMERS, KNOW WHETHER COMPLIANCE WITH
THE NUMERICAL CRITERIA PROPOSED BY EPA IN THE FEBRUARY 6,
1978 FEDERAL REGISTER WILL GUARANTEE A FARMER THAT HIS
CROPS WILL NOT VIOLATE AN FDA STANDARD.
IT HAS BEEN OBSERVED THAT SOLID ORGANIC MATTER
IN SOIL ADSORBS CADMIUM AND THEREBY HELPS RESTRICT THE
TRANSFER OF CADMIUM TO THE SOIL SOLUTION WHERE IT MIGHT
BE TAKEN UP BY PLANTS. THE ADDITION OF A SUBSTANTIAL
AMOUNT OF SEWAGE SLUDGE TO A SOIL THAT HAS LITTLE
ORGANIC MATTER TO START WITH (LIKE MANY OF THE SOILS
IN THE ARID SOUTHWESTERN STATES) WILL CAUSE A
SUBSTANTIAL PERCENTAGE INCREASE IN THE AMOUNT OF SOLID
ORGANIC MATTER IN SUCH SOIL. A SUBSTANTIAL PERCENTAGE

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INCREASE IN THE AMOUNT OF SOLID ORGANIC MATTER IN THE
SOIL MAY PROVIDE A SUBSTANTIAL PERCENTAGE INCREASE IN
THE AMOUNT OF CADMIUM WHICH CAN BE HELD IN THE SOIL
WITHOUT RELEASE TO THE SOIL SOLUTION.
AFTER SLUDGE APPLICATIONS ARE PERMANENTLY CEASED
MUCH OF THE SOLID ORGANIC MATTER THAT WAS ADDED TO THE
SOIL BY SLUDGE APPLICATIONS WILL BE LOST DUE TO
DECOMPOSITION. COMPLETION OF DECOMPOSITION COULD TAKE
MORE THAN 15 YEARS IN UPLAND SOILS.
AN UPLAND SOIL IN AN ARID SOUTHWESTERN STATE THAT
HAD LITTLE ORGANIC MATTER BEFORE RECEIVING SLUDGE, MAY
AGAIN HAVE LITTLE ORGANIC MATTER AT THE END OF THE
PERIOD OF DECOMPOSITION.
IT APPEARS REASONABLE TO QUESTION WHETHER THE
AMOUNT OF CADMIUM TAKEN UP BY PLANTS FROM A SLUDGE-
TREATED, CADMIUM-RICH SOIL THAT HAS LITTLE ORGANIC
MATTER AT THE END OF THE PERIOD OF DECOMPOSITION MIGHT
DIFFER SUBSTANTIALLY FROM THE AMOUNT OF CADMIUM TAKEN
UP BY PLANTS IN THE FIRST FEW YEARS AFTER SLUDGE IS
APPLIED -- THAT IS, WHEN THE SOIL IS A NEWLY-CREATED,
CADMIUM-RICH SOIL CONTAINING A SUBSTANTIAL AMOUNT OF
ORGANIC MATTER.
WE ARE NOT AWARE OF ANY FINDINGS THAT ASSURE THAT
THE ADSORPTION CAPACITY OR OTHER FUNCTION OF MATTER THAT
WILL REMAIN IN SOILS OF ARID SOUTHWESTERN STATES AT THE

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END OF THE PERIOD OF DECOMPOSITION WILL BE GREAT
ENOUGH TO PREVENT AN INCREASE IN THE AVAILABILITY OF
CADMIUM FOR UPTAKE BY PLANTS.
THUS WE QUESTION WHETHER "WORST CASE" SITUATIONS
HAVE ACTUALLY BEEN REVEALED IN PAST EXPERIMENTS IN
WHICH THE CROPS THAT WERE ANALYZED WERE GROWN SOON
(I.E., WITHIN A FEW YEARS) AFTER SLUDGE WAS APPLIED TO
SOIL .
EPA COULD GREATLY AID STATE AND LOCAL AGENCIES
WHO CONTEMPLATE THE USE OF THE PROPOSED CRITERIA BY
PUBLISHING THE FOLLOWING INFORMATION:
1.	CADMIUM CONCENTRATIONS IN NON-LEAFY CROPS
AND LEAFY CROPS THAT WILL BE AVOIDED BY COMPLIANCE WITH
THE PROPOSED CRITERIA — DURING A MULTI-YEAR PERIOD
PRECEDING THE PERMANENT CEASING OF APPLICATIONS OF
SLUDGE;
2.	CADMIUM CONCENTRATIONS IN NON-LEAFY CROPS
AND LEAFY CROPS THAT WILL BE AVOIDED BY COMPLIANCE
WITH THE PROPOSED CRITERIA -- AFTER APPLICATIONS OF
SLUDGE HAVE BEEN PERMANENTLY CEASED AND ADDED SLUDGE-
BORNE ORGANIC MATTER HAS BEEN DECOMPOSED TO THE EXTENT
POSSIBLE IN THE ARID SOUTHWESTERN STATES;
3.	STATEMENTS ON WHETHER THOSE CADMIUM
CONCENTRATIONS IN NON-LEAFY CROPS AND LEAFY CROPS HAVE
BEEN DEMONSTRATED TO BE AVOIDABLE BY COMPLIANCE WITH

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THE PROPOSED CRITERIA IN LONG-TERM EXPERIMENTS THAT
REPRESENT THE FULL RANGE OF NON-LEAFY CROPS AND LEAFY
CROPS FOR WHICH A CALIFORNIA FARMER MAY DESIRE HIS
SOIL TO REMAIN USABLE, AND THAT REPRESENT THE RANGE OF
CONDITIONS THAT WILL OCCUR IN THE ROOT ZONE OF A
CALIFORNIA FARMER'S SOIL WHEN THE FARMER USES SLUDGE
AND OTHERWISE MANAGES HIS SOIL IN A CONVENTIONAL MANNER;
4.	A DESCRIPTION OF THE RELATIONSHIPS BETWEEN
ANNUAL AND CUMULATIVE AMOUNTS OF CADMIUM APPLIED, AND
CADMIUM CONCENTRATIONS IN CROPS, THAT HAVE BEEN
DEMONSTRATED TO SUPPORT THE PROPOSED CRITERIA;
5.	A DESCRIPTION OF THE COMBINATIONS OF CROPS
AND SOIL CONDITIONS INVOLVED IN EXPERIMENTS THAT
DEMONSTRATED THOSE RELATIONSHIPS; AND
6.	STATEMENTS ON WHETHER COMPLIANCE WITH THE
PROPOSED CRITERIA WILL SUFFICE TO AVOID VIOLATION OF
STANDARDS FDA MAY BE EXPECTED TO SET ON CADMIUM
CONCENTRATIONS IN NON-LEAFY FOODS, AND IN LEAFY FOODS.
IN THE ABSENCE OF ASSURANCES THAT COMPLIANCE WITH
THE PROPOSED CRITERIA WILL AVOID THE OCCURRENCE OF
SPECIFIED CADMIUM CONTENTS IN FOODS, IT WOULD APPEAR
APPROPRIATE THAT A SEWjifrAGE AGENCY THAT WISHES ITS
SLUDGE TO BE USED IN AGRICULTURE HAS THREE REASONABLE
ALTERNATIVE COURSES OF ACTION. THE FIRST ALTERNATIVE
IS TO UNDERTAKE APPROPRIATE FIELD EXPERIMENTS WHICH

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REPRESENT CONDITIONS THAT WOULD OCCUR IN A FARMER'S
SOIL AFTER SLUDGE IS ADDED, AND WHICH INDICATE
CADMIUM CONCENTRATIONS IN THE GREATEST CADMIUM-
ACCUMULATING CROPS EATEN BY HUMANS FOR WHICH THE
FARMER DESIRES HIS SOIL TO REMAIN USABLE. THE SECOND
ALTERNATIVE IS TRY TO FIND A FARMER WHO DOES NOT WISH
HIS LAND TO REMAIN USABLE FOR PRODUCTION OF FOOD FOR
WHICH AN FDA STANDARD IS APT TO BE SET CE.G., FOOD
EATEN BY HUMANS). AND A THIRD ALTERNATIVE IS TO
PURCHASE AGRICULTURAL LAND TO AVOID MOTIVATIONS TO
PRODUCE FOOD FOR WHICH FDA STANDARDS ARE APT TO BE
SET.
IT APPEARS THAT EXPERIMENTS UNDERTAKEN OR CITED
TO SUPPORT THE ADDITION OF SLUDGE TO LAND NOT OWNED BY
A SEWgftAGE AGENCY SHOULD BE DESIGNED TO REPRESENT THE
RANGE OF CONDITIONS THAT WOULD OCCUR IN THE ROOT ZONE:
CD WHEN THE FARMER USES SLUDGE AND OTHERWISE MANAGES
HIS SOIL IN A CONVENTIONAL MANNER; AND C2) AFTER THE
FARMER STOPS APPLYING SLUDGE AND DOES NOT REPLENISH THE
SOLID ORGANIC MATTER WHICH THE SLUDGE PROVIDED OVER AND
ABOVE THAT PROVIDED BY CROP RESIDUES AND OTHER SOURCES.
METHODS BY WHICH THE LATTER SITUATION CAN BE
REPRESENTED, OR ASSUMED TO BE REPRESENTED, HAVE
SHORTCOMINGS, EITHER WTTH RESPECT TO PRACTICALITY, OR
LACK OP VERIFICATION. HOWEVER, THEY APPEAR BETTER THAN

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PROCEEDING WITHOUT RELEVANT DATA. THOSE METHODS
INCLUDE ANALYZING CROPS GROWN IN SLUDGE-TREATED SOIL
15 TO 25 YEARS AFTER SLUDGE APPLICATIONS HAVE BEEN
STOPPED. ANOTHER METHOD MIGHT BE TO SIMULATE FUTURE
CHEMICAL CONDITIONS BY NOT ADDING SLUDGE BUT ADDING
READILY DEGRADABLE ORGANIC COMPOUNDS OF CADMIUM AND
OTHER CHEMICAL SUBSTANCES AS ARE IN SLUDGE.
STATE AND LOCAL AGENCIES WOULD BE AIDED BY
INFORMATION PERTAINING TO CONVERSION OF SLUDGE-TREATED
AGRICULTURAL SOIL TO RESIDENTIAL LOTS WHERE HOME
VEGETABLE GARDENS MIGHT BE ESTABLISHED. WE RECOMMEND
THAT EPA PUBLISH ESTIMATES OF THE AMOUNT OF CADMIUM
THAT WOULD BE IN THE DIET OF VEGETARIAN AND
NON-VEGETARIAN HOME GARDENERS WHO PRODUCE AS MUCH OF
THEIR OWN FOOD AS IS PRACTICAL IN SOIL WHICH WAS,
UNTIL A TIME AT LEAST 15 YEARS BEFORE THE ESTABLISHMENT
OF THE HO,ME GARDEN, TREATED WITH SLUDGE BY A FARMER
WHO ADDED AS MUCH CADMIUM AS ALLOWED BY THE PROPOSED
EPA CRITERIA, WHEN THE CURRENT PH LEVEL OF THE SOIL
IS: Cl) AS HIGH AS MIGHT OCCUR IN A CALCAREOUS SOIL
AFTER TREATMENT WITH SLUDGE; (2) 6.5, THE LEVEL CITED
IN THE PROPOSED EPA CRITERIA; AND (3) A LOWER PH WHICH
MIGHT OCCUR IN A FORMERLY ACIDIC SOIL WHERE PH WAS
RAISED TO 6.5 DURING THE PERIOD OF SLUDGE UTILIZATION.
WE WISH TO NOTE THAT WE HAVE REVIEWED A PAPER BY

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EPA STAFF IN CINCINNATI ENTITLED "AN APPRAISAL OF THE
RELATIVE HEALTH RISKS ASSOCIATED WITH LAND APPLICATION
OF MUNICIPAL SLUDGE", AND FIND NO ADEQUATE SUPPORT
THEREIN FOR THE NUMERICAL CRITERIA PROPOSED IN THE
FEDERAL REGISTER. WE WILL SHORTLY SUBMIT TO EPA AND
THE PUBLIC OUR APPRAISAL OF THAT PAPER WHICH IS
CONTAINED IN OUR TECHNICAL BULLETIN ENTITLED
"CONSIDERATION OF CHEMICAL SUBSTANCES IN SEWAGE SLUDGE
ADDED TO SOIL THAT WILL PRODUCE AN EDIBLE CROP: A
PUBLIC HEALTH PERSPECTIVE.11
WE HAVE SCHEDULED THREE FULL-DAY SEMINAR-PUBLIC
FORUMS IN MARCH TO DISCUSS THE TOPICS COVERED BY OUR
BULLETIN AND TO HEAR THE CONCERNS OF PEOPLE WHO HAVE
REVIEWED IT, AND OF OTHER MEMBERS OF THE PUBLIC.
THESE MEETINGS WILL BE: IN SACRAMENTO ON
WEDNESDAY, MARCH 22ND; IN BERKELEY ON TUESDAY,
MARCH 23RD; AND IN LOS ANGELES ON FRIDAY, MARCH 2IfTH.
THE PURPOSE OF THESE MEETINGS IS: CD TO INVOLVE
THE PUBLIC AS MUCH AS POSSIBLE IN DECISIONS THAT WILL
BE MADE BY THE DEPARTMENT OF HEALTH WHICH PERTAIN TO
THE USE OF SEWAGE SLUDGE; AND (2) TO PROVIDE THE PUBLIC
WITH TECHNICAL INFORMATION WHICH THEY DESIRE. WE HOPE
TO OBTAIN PARTICIPATION BY EPA PERSONNEL IN THESE
MEETINGS TO DISCUSS TECHNICAL ISSUES, SUCH AS THOSE I
HAVE MENTIONED TODAY.

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lh
THANK YOU.
DR. SKINNER: THANK YOU.
ARE THERE ANY QUESTIONS FROM THE PANEL?
I WOULD LIKE TO ASK ONE QUESTION TO SEE IF I
UNDERSTAND THE POINT THAT YOU WERE MAKING.
IS YOUR POINT THAT IT IS NOT CLEAR THAT OVER
TIME THAT THE CADMIUM UPTAKE OF CROPS WOULD DECREASE
AND MAY INCREASE?
MR. KIADO: I BELIEVE WE DON'T KNOW WHAT WILL
HAPPEN OVER TIME AT THE END OF THE PERIOD OF
DECOMPOSITION. I COULD NOT SAY THAT. I WOULD EXPECT
THERE TO BE AN INCREASE.
I WOULD SAY THAT WE JUST DON'T KNOW.
DR. SKINNER: AND YOUR CONCERN, THEN, IS THAT
IF THERE IS NOT A DECREASE, THAT THE PROPOSED CRITERIA
WOULD NOT PROVIDE SUFFICIENT PROTECTION?
MR. KI ADO: WELL, I WOULD LIKE TO BE TOLD WHAT
THE CRITERIA DO GUARANTEE.
DR. SKINNER: FINE. THANK YOU.
MR. GARVIN: I HAVE ONE QUESTION.
DR. SKINNER: YES.
MR. GARVIN: DO YOU KNOW WHETHER THE FDA HAS
ESTABLISHED MAXIMUM LEVELS OF CONCENTRATION FOR
CADMIUM IN FOOD PRODUCTS AT THIS TIME OR WHEN IT IS
ABOUT TO OCCUR OR --

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MR. KI ADO: THEY CANNOT AND COULD NOT, SHOULD
NOT BE BASED UPON THE AVAILABILITY DATA AT HAND FOR
SUCH AN UNDERTAKING. I THINK THEY HAVE SEEN ENOUGH
DATA TO SEE JUSTIFICATION FOR EXPANDING THE SAMPLING
PROGRAM, AND AT THE END OF A LARGE SAMPLING PROGRAM
THEY COULD DO THIS.
MR.	• SIR, YOU SEEM TO BE SAYING THAT
THE RESEARCH ISN'T YET COMPLETE AND THEREFORE I AM
UNCLEAR AS TO WHAT YOU ARE RECOMMENDING. ARE YOU
SAYING THAT WE SHOULD NOT BE SETTING ANY LIMITS AT
THIS TIME?
MR. KI ADO: NO. I AM SAYING THAT YOU HAVE
PROPOSED MIRACLE CRITERIA AND YOU COULD HELP THESE --
THE STATE AND LOCAL AGENCIES -- BY TELLING US WHAT
CADMIUM CONCENTRATIONS IN CROPS -- THOSE NUMERICAL
CRITERIA WILL AVOID. THIS IS WHAT I PRESUME YOU KNOW
AND WE DON'T.
DR. SKINNER: THANK YOU. I THINK WE WILL DO
THAT .
THE NEXT PERSON IS DR. LUE-HING.
DR. LUE-HING: DR. SKINNER, I DON'T HAVE A
PREPARED STATEMENT. IF I DO LATER FEEL I WILL MAKE
A STATEMENT I WILL LET YOU KNOW. I AM SORRY I DIDN'T
BRING A PREPARED STATEMENT.
DR. SKINNER: FINE, YOU CAN SUBMIT A STATEMENT

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TO THE RECORD ANY TIME DURING THE PUBLIC COMMENT
PERIOD, OR IF YOU CHOOSE TO ATTEND ONE OF THE OTHER
PUBLIC HEARINGS AND WISH TO MAKE A STATEMENT AT THAT
TIME THAT WILL BE FINE AS WELL.
DR. LUE-HING: THANK YOU.
DR. SKINNER: MR. MICHAEL SELNA?
MR. SELNA: MY NAME IS MICHAEL SELNA. I AM WITH
THE LOS ANGELES COUNTY SANITATION DISTRICTS.
THE SANITATION DISTRICTS RECOVER ABOUT 350 DRY
TONJOF SLUDGE PER DAY AND WITH COMPLETION OF OUR FIRST
TWO STAGES OF SECONDARY TREATMENT AT OUR MAIN TREATMENT
PLANT WE WILL HAVE AN ADDITIONAL 200 TONS A DAY, GIVING
US ON THE ORDER OF 550 TONS A DAY.
PRESENTLY, MUCH OF OUR SLUDGE MATERIAL -- WHICH
IS COMPOSED OF DIGESTED SLUDGE, BY THE WAY -- IS
DISPOSED OF THROUGH A COMMERCIAL MARKETING ENTERPRISE,
KELLOG6-SUPPLY COMPANY, CARSON, CALIFORNIA.
THE MARKET FOR COMPOSTED SLUDGE IN LOS ANGELES
AREA IS APPROXIMATELY THREE TO FOUR HUNDRED TONS PER
DAY.
IN ADDITION, THE DISTRICTS ARE PRESENTLY INVOLVED
IN REGIONAL STUDY OF SLUDGE DISPOSAL WITH THE OTHER
LARGE MUNICIPAL AGENCIES IN SOUTHERN CALIFORNIA, ORANGE
COUNTY, AND LOS ANGELES CITY. THIS IS THE LA/OMA
STUDY WHICH STUDIES SLUDGE MANAGEMENT ALTERNATIVES

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INCLUDING APPLICATION OF SLUDGE TO AGRICULTURAL LANDS.
AND BECAUSE THAT IS ONE OF THE OPTIONS BEING
STUDIED IN OUR AREA I WOULD LIKE TO ADDRESS PORTIONS OF
THE REGULATIONS THAT REFER TO AGRICULTURAL LAND
DISPOSAL OF SLUDGE, IN PARTICULAR CADMIUM, THE MOST
CONTROVERSIAL PART OF THE REGULATIONS, IN OUR OPINION.
I'D LIKE TO ADDRESS THE FDA'S ASSESSMENT THAT HAS
BEEN MADE OF THE HEALTH RISKS ASSOCIATED WITH CADMIUM
SLUDGE.
IT WAS ASSUMED BY FDA THAT A THRESHOLD OF
APPROXIMATELY 70 MICROGRAMS PER DAY IN THE HUMAN DIET
WOULD BE A SAFE VALUE THAT WOULD NOT CAUSE ACCUMULATION
OF ENOUGH CADMIUM IN THE KIDNEY TO CAUSE RENAL FAILURE
AT LATER AGES.
THE WORLD HEALTH ORGANIZATION STATED ALSO THAT
70 WAS A SAFE VALUE, AND IN AN INITIAL MARKET BASKET
SURVEY IN THE UNITED STATES IT WAS FOUND BY FDA THAT
TEENAGE MALES IN THE UNITED STATES CONSUME ABOUT
72 MICROGRAMS PER DAY AND, THEREFORE, YOU SEE THAT THE
INITIAL ASSESSMENT REVEALS THAT WE ARE ALREADY AT THE,
PERHAPS, THE THRESHOLD OR IMPORTANT LEVEL IN TERMS OF
CADMIUM.
SUBSEQUENT ASSESSMENTS BY EPA, AS I UNDERSTAND
IT, INDICATED THAT THE AVERAGE DAILY INTAKE WAS ON THE
ORDER OF 35 MICROGRAMS PER DAY IN TEENAGE MALES. THIS

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18
USING AN AVERAGE OVER SEVERAL YEARS RATHER THAN A
SINGLE YEAR'S DIET.
IN ADJUSTING FOR DIETARY INTAKE A REALISTIC
ESTIMATE FOR THE INTAKE OF CADMIUM BY HUMANS IN THE
UNITED STATES IS 30 MICROGRAMS PER DAY.
WELL, THE WORLD HEALTH ORGANIZATION'S
RECOMMENDATION OF 70 HAS ALSO BEEN TEMPERED TO SOME
EXTENT. THE AVERAGE DAILY INTAKE TO CAUSE ADVERSE
KIDNEY EFFECTS IS NOW ESTIMATED TO BE 440 MICROGRAMS
PER DAY BY DELSTRUM IN HIS WORK.
USING THE WORLD HEALTH ORGANIZATION RECOMMENDATION
THAT THE KIDNEY LEVEL BE RESTRICTED TO 50 MICROGRAMS
PER GRAM KIDNEY WEIGHT, THE DAILY SAFE INTAKE MAXIMUM
COULD BE ESTIMATED TO BE 110 MICROGRAMS PER DAY WHICH
IS, IF YOU COMPARED IT TO 30, IS AS MUCH DIFFERENT THAN
A COMPARISON BETWEEN 70 AND 72 -- THESE DATA ARE MERELY
PRESENTED TO YOU TO SUPPORT THE STANCE THAT WE MIGHT
NOT TODAY HAVE A CADMIUM CRISIS AS INITIALLY REGARDED
BY THE FDA.
AND I'D LIKE TO POINT OUT, AT THE SAME TIME, THAT
THIS ANALYSIS BASICALLY FOLLOWS THE LINES BY A PERSON
IN EPA, A MR. HERBERT OF THE HEALTH RESEARCH IN
CINCINNATI, WHO POINTS OUT THE FACT THAT THERE IS A
DISCREPANCY WITHIN THE EPA ABOUT THE HEALTH RISKS
INVOLVED IN CADMIUM APPLICATION OR SLUDGE APPLICATION

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19
TO LAND.
I'D LIKE TO TALK BRIEFLY ABOUT THE ANNUAL
APPLICATION RATES THAT ARE SPECIFIED IN THE fiCRA
REQUIREMENTS. THEY VARY FROM 50 KILOGRAMS PER HECTARE
TO 20 KILOGRAMS PER HECTARE. THESE ARE THE CUMULATIVE
CADMIUM APPLICATIONS.
QUESTIONS EXIST AS TO WHETHER CADMIUM REMAINS
TOTALLY AVAILABLE IN SOIL WITH TIME.
REACTIONS SUCH AS PRECIPITATION AND IRON EXCHANGE
CAN TEND TO TIE UP CADMIUM TO THE EXTENT THAT PERHAPS
THE CURRENT YEAR'S APPLICATION IS A MORE IMPORTANT
CONTROLLING FACTOR THAN THE TOTAL CADMIUM APPLICATION.
I WOULD LIKE TO SUBMIT THAT A MORE RATIONAL
REGULATION MIGHT INVOLVE A CADMIUM AVAILABILITY TEST
AS A SUBSTITUTE FOR COMPLIANCE WITH CUMULATIVE
APPLICATION; SOMETHING THAT MIGHT INVOLVE A DPTA
EXTRACT ANALYSIS; SOMETHING THAT WOULD BE DESIGNED BY
EPA AND PERHAPS WITH HELP FROM FDA THAT WOULD GIVE US
A CHANCE TO ANALYZE SOIL IN VIABILITY WITH THE CADMIUM
PLANTS. ANOTHER PART OF THE REGULATION RESTRICTS USE
OF LAND TO BE USED TO GROW LEAFY VEGETABLES, TOBACCO,
OR CROPS. IT'S NOT CLEAR WHY THERE SHOULD BE A
CONCENTRATION RESTRICTION WHEN THE LOADING RATE FOR
CADMIUM IS ALREADY RESTRICTED. AND, IN FACT, THE
ANALYSIS BY PAHREN INDICATES THAT 60 MILLIGRAMS OF

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20
CADMIUM IN SLUDGE MIGHT BE SAFE WHEN THE SLUDGE IS
APPLIED AT MAXIMUM AGRONOM RATE. THAT IS THE RATE THAT
SUPPLIES SUFFICIENT NUTRIENT.
THERE IS A RECOMMENDATION IN THE REQUIREMENTS --
AND THIS IS NOT PART OF THE REGULATION BUT IT APPEARS
IN THE PREAMBLE -- THAT THE CADMIUM PER ZINC RATIO
BE LIFTED TO LESS THAN 0.015. THIS DOES NOT APPEAR TO
BE PRUDENT IN LIGHT OF THE STRICT CADMIUM CONTROL.
LET ME GIVE YOU AN EXAMPLE.
IF YOU HAVE A SLUDGE WITH LOW ZINC CONTENT THAT
HAS ALSO LOW CADMIUM CONTENT, WHY SHOULD THAT SLUDGE
BE DISQUALIFIED BECAUSE OF THE RATIO?
AND I THINK THAT IT MERELY CONFUSES THE ISSUE TO
HAVE IT APPEAR IN THE RECOMMENDATION.
YOU ASKED FOR COMMENTS ON THE ABILITY OF SOURCE
CONTROL TO LIMIT THE CADMIUM IN SLUDGE TO PRESCRIBED
LEVELS.
IT IS OUR ESTIMATE THAT WITH COMPLETE SOURCE
CONTROL -- THAT IS NO INDUSTRIAL IMPUT -- WE WOULD HAVE
ON THE ORDER OF 20 TO 25 MILLIGRAMS PER KILOGRAM OF
CADMIUM IN OUR SLUDGE.
AT A NITROGEN LOADING RATE -- OR THE AMOUNT OF
SLUDGE NECESSARY TO SUPPLY NUTRIENTS FOR CROP GROWTH --
THE CADMIUM APPLICATION RATE WOULD EXCEED THE 1986 RATE
OF .5 KILOGRAM PER HECTARE, EVEN WHEN WE HAD VERY

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21
COMPLETE SOURCE CONTROL.
THE PORTION OF THE REGULATION THAT I HAVE BEEN
TALKING MOST ABOUT REFERS TO LOADING RATES AND
NUMERICAL RATES FOR CADMIUM. THERE IS A COMPARABILITY
SECTION THAT ALLOWS BYPASSING ALL THAT INFORMATION AND
MERELY ASSESSING THE CADMIUM CONTENT OF CROPS OR ANIMALS
SITUATED WITH THE SLUDGE.
I THINK THIS SECTION NEEDS CLEARER DEFINITION
AS TO WHAT "COMPARABILITY" MEANS.
WHAT IS A COMPARABLE CADMIUM CONCENTRATION?
IN OTHER WORDS, HOW MUCH DIFFERENCE CAN IT BE
ALLOWED TO BE?
AND, SECONDLY, AND MORE IMPORTANTLY, THAT LOCAL
COMPARISONS -- THAT IS BETWEEN CROPS GROWN ON
SLUDGE-MANAGED LAND AND LOCAL MARKETPLACE CROPS --
MIGHT NOT BE FAIR. MAINLY BECAUSE CERTAIN AREAS MAY
HAVE NATURAL IMPUT OF CADMIUM THROUGH SOIL.
THERE IS AN EXAMPLE — A FAMOUS EXAMPLE -- IN
CALIFORNIA, SALINAS VALLEY, WHERE ONE WOULD BE ABLE
TO APPLY A LOT OF SLUDGE AND STILL NOT EXCEED THE
MARKET VALUE OF CADMIUM. THE CONVERSE IS ALSO TRUE,
IT MIGHT BE MORE FAIR TO COMPARE IT TO THE NATIONAL
MARKET BASKET ANALYSIS FOR CADMIUM.
LET ME STRAY AWAY FROM CADMIUM NOW AND TALK ABOUT
PATHOGENS.

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22
A ONE-YEAR WAITING PERIOD IS REQUIRED FOR USE
OF SLUDGE TO SOIL FOR EDIBLE CROP PRODUCTION.
I THINK THAT A CLAUSE LIKE THAT NEEDS TO BE
ADDED TO THE END OF THE STATEMENT IN REGARD TO
ADDITIONAL PATHOGEN CONTROL MEASURES SUCH AS ADEQUATE
COMPOSTING OR HEAT TREATMENT THAT COULD BE EMPLOYED TO
ALLEVIATE THE ONE-YEAR WAITING PERIOD.
IN THE PREAMBLE OF THE RCRA REQUIREMENTS THERE IS
A SET OF FIVE CRITERIA FOR SLUDGE UTILIZATION ON LAND
THAT OPERATING AGENCIES MUST ADHERE TO.
THESE FIVE CRITERIA ARE: ANALYSIS OF SLUDGE FOR
CADMIUM; THAT THE OPERATING AGENCY IS SURE THAT THE
SLUDGE IS STABILIZED; THAT THE OPERATING AGENCY
DETERMINE APPROPRIATE RATES, AND ASSURE COMPLIANCE WITH
THOSE RATES; THAT THE AGENCY DESIGN MONITORING SYSTEMS,
AND ASSURE THAT THESE ARE CARRIED OUT AND THAT
CONTINGENCY PLANS BE ESTABLISHED.
AT LEAST TWO OF THOSE CRITERIA WOULD BE DIFFICULT
FOR MANY MUNICIPAL AGENCIES TO COMPLY WITH SIMPLY
BECAUSE IF THE SLUDGE IS GIVEN OR SOLD TO AGRICULTURAL
INTERESTS, MOST MUNICIPAL AGENCIES ARE NOT GOING TO BE
ABLE TO ENFORCE OR REGULATE THE ACTIVITIES OF THOSE
PEOPLE.
IN CALIFORNIA, I KNOW THIS IS TRUE, BECAUSE THE
ENABLING LEGISLATION FOR SANITATION IN DISTRICTS IN

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23
CALIFORNIA WOULD NOT ALLOW US TO REGULATE THE PRODUCTS.
WE CAN REGULATE OUR FACILITIES FOR INDUSTRIAL CONTROL
BUT NOT AT THE OTHER END. WE CAN DO THAT THROUGH
AGREEMENT BUT THERE WOULD BE NOTHING IN OUR ENABLING
LEGISLATION THAT WOULD ALLOW US TO REQUIRE A FARMER
TO AGREE THAT WE CAN REGULATE HIS ACTIVITIES.
LET ME MAKE ONE FINAL PHILOSOPHICAL COMMENT.
I THINK WE CAN ALL AGREE THAT THE NITROGEN
IN THE SLUDGE SHOULD BE REGARDED AS A RECOVERABLE
AND A USEFUL RESOURCE.
WE CAN ALSO AGREE THAT THE HEALTH EFFECTS OF
CADMIUM ARE POORLY UNDERSTOOD, AND THERE IS DIVERGENT
SCIENTIFIC OPINION EVEN WITHIN THE EPA.
MY PLEA IS THAT REASONABLE AND CAREFUL HEALTH
ASSESSMENT BE CARRIED OUT, AND THAT OVERLY RESTRICTIVE
REGULATIONS SHOULD NOT BE ESTABLISHED AT THIS TIME.
ONCE SUCH REGULATIONS BECOME LAW A DECISION WILL BE
MADE; IRREVERSIBLE EXPENDITURES OF MONEYS WILL BE
MADE, AND THAT WE CANNOT EXPECT TO BACKTRACK FROM
THESE DECISIONS WHEN ADDITIONAL INFORMATION ON
HEALTH RISKS BECOMES AVAILABLE.
THANK YOU.
DR. SKINNER: THANK YOU.
ANY QUESTIONS FROM THE PANEL?
I HAVE A FEW QUESTIONS.

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WILL YOU ELABORATE ON YOUR COMMENT WITH RESPECT
TO CADMIUM EXTRACT TESTS? AMD HOW THAT WOULD WORK, AND
PERHAPS COMPARE THAT TO THE PROVISION IN THE CRITERIA
WHERE THE CROP CAN BE COMPARED TO OTHER CROPS LOCALLY
GROWN, PLEASE?
MR. SELNA: YES.
I AM NOT A SOIL SCIENTIST AND SO I WOULDN'T BE
PREPARED TO STATE THAT ANY EXTRACT METHOD WOULD BE THE
PERFECT METHOD.
I UNDERSTAND THAT THERE ARE METHODS THAT FAIRLY
WELL REPRESENT THE AVAILABILITY OF MATERIALS IN SOIL TO
PLANTS. ONE OF THEM IS, AS I UNDERSTAND IT, A DPTA
EXTRACT.
IN COMPARISON WITH THE COMPARABILITY CRITERIA, T
THINK THAT IT PROVIDES AN AGENCY WITH AN ADVANCED
WARNING -- OR AN ADVANCED ABILITY TO DETECT A CADMIUM
UPTAKE PROBLEM RATHER THAN AN AFTER-THE-FACT PROBLEM
WHERE A FARMER'S CROP MIGHT BE DISQUALIFIED.
SO I THINK IT IS A MORE WORKABLE CRITERIA.
DR. SKINNER: r SEEM TO BE FACED WITH THE SAME
PROBLEM THAT YOU RAISED WITH RESPECT TO THE
COMPARABILITY CRITERIA IN THE FINDING AND ACCEPTABLE
LEVEL OF UPTAKE OR DEFINING WHAT COMPARABILITY IS.
IS THAT CORRECT?
MR. SELNA: I THINK SO.

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25
DR. SKINNER: ANOTHER QUESTION WITH RESPECT TO
YOUR COMMENT ON THE FACT THAT IF YOU COMPLETELY
ELIMINATED INDUSTRIAL IMPUTS INTO YOUR SEWERAGE IMPUT
AT NITROGEN LOADING RATES THAT YOU WOULD REDUCE THE
CADMIUM CONCENTRATION OF THE SLUDGE DOWN TO 25 PARTS
PER MIL, I BELIEVE YOU SAID. AND THAT YOU SAID THAT AT
THE NITROGEN LOADING RATE FOR CROPS THAT WOULD NOT
ALLOW YOU TO COMPLY WITH THE 1985 REQUIREMENT WHICH IS
.5 KILOGRAMS PER HECTARE.
THAT WOULD HAVE TO BE BASED UPON A CERTAIN
NITROGEN AVAILABILITY IN THE SLUDGE, AND A CERTAIN
APPLICATION RATE OF THE SLUDGE TO THE CROP.
WOULD YOU TELL ME THE BASIS FOR THAT CALCULATION
AND WHAT LOADING RATE IN KILOGRAMS PER HECTARE YOU
WOULD BE ABLE TO COMPLY WITH A 25 EPM SLUDGE?
MR. SELNA: YES. MY CALCULATION IS ONE THAT
PERTAINS TO COMPOSTED SLUDGE.
YOU MAY BE AWARE THAT IN COMPOSTING SLUDGE HIGH
NITROGEN LOSS OCCURS, SO TO SUPPLY THE NECESSARY
NUTRIENTS FOR PLANT GROWTH YOU HAVE TO APPLY MORE
SLUDGE.
I ASSUMED FULL AVAILABILITY OF THE NITROGEN.
WE DON'T HAVE ANY AMMONIA LEFT IN COMPOSTED
SLUDGE, AND, THEREFORE, WE DON'T HAVE ANY AMMONIA LOSS.
THAT'S A CONSERVATIVE ASSUMPTION, BUT I MEAN THAT

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26
I BELIEVE THAT THE CADMIUM LOADING RATE CALCULATED TO
BE .6 OR .7 KILOGRAMS PER HECTARE.
DR. SKINNER: BUT THAT WAS FOR COMPOSTED SLUDGE?
MR. SELNA: YES, THAT'S CORRECT.
DR. SKINNER: ONE OTHER COMMENT, OR QUESTION.
WITH RESPECT TO YOUR COMMENT ON THE ONE-YEAR
WAITING PERIOD, YOU INDICATED THAT THE CRITERIA SHOULD
PROVIDE FOR REDUCING THAT WAITING PERIOD IN COMPOST
OTHER STABILIZATION METHODS WERE USED.
DO YOU HAVE INFORMATION AVAILABLE THAT INDICATES
THAT COMPOSTING AND STABILIZATION IS EFFECTIVE IN
REDUCING VARIOUS PATHOGENS IN SLUDGE SO THAT A SHORTER
WAITING PERIOD WOULD BE PERMISSIBLE?
MR. SELNA: YES, WE DO. WE HAVE DATA FROM
PERIODS WHEN WE WERE ABLE TO CONTROL THE COMPOST
PROCESS VERY WELL. TURNS OUT THAT WE DON'T PRESENTLY
DO THAT, BECAUSE WE HAVE A CHANGE IN OUR DE-WATERING
PRACTICE.
THE DATA THAT WE HAVE INDICATE THAT WHEN
60 DEGREES CENTIGRADE IS REACHED FOR A PERIOD OF A FEW
DAYS, CONSECUTIVE DAYS, THAT WE HAVE EXCELLENT KILLS
OF ASPERGILLUS, SALMONELLA AND VIRUSES.
WE HAVE DONE TWO YEARS WORTH OF MONITORING OF OUR
COMPOST OPERATION TO DETECT THAT.
AS I SAID, WE HAVE HAD A MINOR CHANGE -- NOT A

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MINOR CHANGE -- WE HAVE HAD A DRASTIC CHANGE IN OUR
DE-WATERING PROGRAM AND WE ARE NOW STUDYING UNDER AN
EPA GRANT DIFFERENT METHODS FOR COMPOSTING THAT HAVE
BEEN METHODS SIMILAR TO THOSE USED IN BELLVILLE.
DR. SKINNER: THANK YOU, VERY MUCH.
ANY OTHER QUESTIONS FROM THE PANEL?
MR. VAN HEUIT.
MR. VAN HEUIT: I'M ROBERT VAN HEUIT, AND I AM
ALSO FROM THE COUNTY SANITATION DISTRICT, AND MY
COMMENTS ON THE CRITERIA WILL BE ON THAT PORTION OF THE
CRITERIA EXCLUSIVE OF THE SEWAGE DISPOSAL SINCE
MIKE SELNA HAS VERY APTLY COVERED THE SUBJECT ON THAT.
WE OF THE SANITATION DISTRICTS ARE PARTICULARLY
CONCERNED WITH PORTIONS OF THE CRITERIA, BECAUSE WE
RECOGNIZE -- AND WE THINK THAT THE EPA RECOGNIZES --
THAT THE CURRENT TECHNOLOGY FOR DISPOSAL FOR THAT
MAJORITY OF THE SOLID WASTE PRODUCED IN THE UNITED
STATES IS TO THE LAND, AND THAT THE MOST IMPORTANT
OBJECTIVE IN THE CRITERIA IS TO OPERATE ALL OF THE
DUMPS TO SANITARY LAND FILLS. YET THE LANGUAGE IN
SOME AREAS APPEARS TO BE SOMEWHAT NEGATIVE ABOUT
LAND DISPOSAL, EMPHASIZING PROBLEMS THAT MAY ONLY
APPLY TO A MINORITY OF LAND DISPOSAL FACILITIES RATHER
THAN TO THE MAJORITY, AT LEAST THE WELL RUN FACILITIES.
WE HOPE THAT THIS LANGUAGE CAN BE MODIFIED AND

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BE MORE SUPPORTIVE OF PROPERLY RUN LAND DISPOSAL
FACILITIES SO THAT THEY WILL BE AVAILABLE IN THE FUTURE
AS ACTIVE PARTNERS TO RESOURCE RECOVERY FACILITIES AS
THEY ARE DEVELOPED.
AS AN ACTIVE PARTNER I'M REFERRING TO THESE
FACILITIES AS BEING THE REPOSITORY FOR THOSE WASTES
THAT EVEN RESOURCE RECOVERY FACILITIES DO PRODUCE.
WE THINK, IN ADDITION, THAT THE CRITERIA NEEDS
TO HAVE SOME ADDED FLEXIBILITY WHICH WILL ALLOW
ENFORCEMENT AGENCIES -- I'M TALKING ABOUT LOCAL AND
STATE ENFORCEMENT AGENCIES -- TO HAVE A PRACTICAL
OUTLOOK ON THE OPERATION OF THE FACILITIES.
THERE ARE SOME AREAS THAT ARE BOUND TO DEVELOP
IN ANY FACILITY WHERE MINOR MALFUNCTIONS, BOTH
MECHANICAL OR HUMAN ERROR, DO OCCUR THAT MAY PUT A
FACILITY INOPERATIVE.
LOCAL ENFORCEMENT AGENCIES SHOULD HAVE THE
ABILITY TO SET PRACTICAL OPERATING RULES THAT WILL
ALLOW CONTINUATION OF THESE NECESSARY DISPOSAL
FACILITIES AT TIMES OF MINOR VIOLATIONS AND ALLOW THE
USERS OF THE FACILITIES NOT TO ENDURE UNUSUAL
HARDSHIPS DURING THESE PERIODS OF TIME.
SOME OF THE LIMITS — AND A NUMBER OF THEM HAVE
ALREADY BEEN REFERRED TO BY MIKE -- APPEAR TO BE
PARTICULARLY CONSERVATIVE. WE WOULD HOPE THAT THESE

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29
LIMITS WOULD BE INVESTIGATED VERY CLOSELY SO THAT THEY
WILL BE PRACTICAL INITIALLY, AND, CERTAINLY, WITH THE
IDEA THAT THEY CAN BE RAISED OR LOWERED AS APPEARS TO
BE WARRANTED IN THE FUTURE, BASED ON FUTURE RESEARCH
THAT NEEDS TO BE DONE IN MANY AREAS.
THE SANITATION DISTRICT PLANS TO PREPARE A VERY
DETAILED RESPONSE TO THE CRITERIA PRIOR TO THE
COMPLETION OF THE PUBLIC COMMENT PERIOD, AND IN THAT
RESPONSE WE WILL PROPOSE CHANGES IN THE LANGUAGE IN THE
CRITERIA THAT HOPEFULLY WILL IMPROVE IT AND MAKE THE
CRITERIA A PRACTICAL AND USEFUL DOCUMENT.
THANK YOU.
DR. SKINNER: THANK YOU.
ARE THERE ANY QUESTIONS FROM THE PANEL?
MR. GARVIN: YES, I HAVE ONE.
YOU SUGGESTED THAT THE CRITERIA OUGHT TO BE
CHANGED IN SOME MANNER SO THEY ALLOW FLEXIBILITY FOR
PRACTICAL OPERATING MEANS.
CAN YOU GIVE ANY SPECIFIC INSTANCES OF WHICH
PROVISIONS IN THE PROPOSED CRITERIA YOU FEEL ARE TOO
STRICT AS WRITTEN?
MR. VAN HEUIT: WELL, I THINK THAT THERE ARE A
NUMBER OF PROVISIONS THAT -- MINOR VIOLATIONS OF WHICH
COULD TECHNICALLY — OR THE CRITERIA CAUSE A SANITARY
LANDFILL -- BECAUSE IN VIOLATION IT WOULD BE KIND OF

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30
OPENED UP.
IF, FOR INSTANCE, IN A GAS MIGRATION PREVENTION
SYSTEM -- A MECHANICAL SYSTEM -- YOU HAD A BELT BREAK
AND HAD A MINOR MIGRATION OF GAS FOR A VERY SHORT
PERIOD OF TIME WHILE IT TAKES A PERIOD OF TIME THAT IT
TAKES TO REPLACE THE BELT, THIS WOULD TECHNICALLY MAKE
THE SANITARY LANDFILL INTO AN OPEN BELT, WHICH WOULD
MEAN THEN THAT IT WAS NOT LEGALLY OPERATIVE.
IT IS A VERY TECHNICAL POINT, I ADMIT, BUT THERE
NEEDS TO BE, I THINK, SOME FLEXIBILITY SO THAT THOSE OF
US WHO ARE OPERATORS OF LARGE LANDFILL FACILITIES --
OPERATORS OF SMALL ONES HAVE THE SAME PROBLEM -- CAN
CONTINUE TO SERVE THE PUBLIC AS WELL AS CORRECT THOSE
SITUATIONS.
LOCAL ENFORCEMENT AGENCIES IN THE PAST HAVE DONE
A GOOD JOB OF INSURING THAT THE PUBLIC HEALTH AND
SAFETY IS PROTECTED.
BUT FROM A PRACTICAL ASPECT THAT -- IF YOU TAKE A
MINOR SITUATION AND SHUT DOWN A FACILITY THERE MAY BE
A MINOR HEALTH PROBLEM DEVELOPED AS A RESULT OF THAT.
MR. GARVIN: SO YOU WOULD BE RECOMMENDING THAT
THERE BE SOME KIND OF PROVISION FOR AN OFFSET BREAKDOWN
OR MALFUNCTIONS OF EQUIPMENT?
MR. VAN HEUIT: I THINK THAT THERE NEEDS TO BE A
PROVISION THAT ALLOWS LOCAL ENFORCEMENT AGENCIES TO BE

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31
ABLE TO TAKE PRACTICAL ACTIONS IN CASE OF THOSE KINDS
OF MINOR — I LIKE TO STRESS THE WORD MINOR -- PROBLEMS
THAT WOULD, FROM A TECHNICAL STANDPOINT, PLACE A
SANITARY LANDFILL IN THE CATEGORY SUBJECT TO BECOMING
AN OPEN DUMP BY THE DEFINITIONS IN THE CRITERIA.
MR. GARVIN: THANK YOU.
DR. SKINNER: THANK YOU.
MR. HENRY HYDE?
MR. HYDE: YES. I AM HENRY HYDE, H-Y-D-E. AND
I REPRESENT THE SAN FRANCISCO BAY REGION WASTE WATER
SOLID STUDY.
THIS IS A JOINT POWERS GROUP WHICH WAS ESTABLISHED
IN MAY OF 1976 TO STUDY THE SLUDGE MANAGEMENT PROBLEM
IN THE BAY REGION AND TO COME UP WITH A REGIONAL PLAN
AND FACILITIES PLANT FOR THE FOUR LARGEST AGENCIES IN
THE REGION.
THERE ARE 55 OR SO WASTE WATER AGENCIES IN THE
BAY REGION, TOTALLY. THEY REPRESENT ABOUT 25 PERCENT
OF THE SLUDGE PRODUCED IN THE STATE OF CALIFORNIA.
COMBINED WITH THE LOS ANGELES BASIN WE HANDLE TOGETHER
ABOUT 75 PERCENT OF THE SLUDGE IN THE STATE.
LOS ANGELES HANDLES ABOUT 50 PERCENT OF;ALL THE SLUDGE
IN CALIFORNIA.
I WOULD LIKE TONIGHT TO JUST GIVE SOME BRIEF
UNOFFICIAL COMMENTS. WE DIDN'T HAVE MUCH TIME TO

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32
REVIEW THE REGULATION IN DETAIL OR PREPARE A WRITTEN
STATEMENT. WE ARE IN THE PROCESS OF PREPARING WRITTEN
STATEMENTS AND HAVING OUR STATEMENT REVIEWED BY OUR
WASTE WATER AGENCY. WE WILL SUBMIT WRITTEN COMMENTS,
AND PROBABLY SEE THE IMPORTANCE OF THIS.
VERY BRIEFLY, BASED ON WORK WE HAVE DONE ON OUR
FIELD EXPERIMENTS OVER FIVE YEARS, BASED ON GREENHOUSE
EXPERIMENTS AT THE UNIVERSITY OF CALIFORNIA AT RIVERSIDE
AND BASED ON REVIEW OF THE LITERATURE, AND ACTUALLY
EXPERIENCED IN USING SLUDGE IN AGRICULTURE OVER SEVERAL
HUNDREDS OF YEARS, IT IS NOT A NEW IDEA, OBVIOUSLY, WE
QUESTION THE NEED FOR NUMERICAL CRITERIA SUCH AS
PROPOSED IN THIS REGULATION.
AS A MATTER OF FACT, WE QUESTION THE NEED FOR
ANY CRITERIA SUCH AS THIS PROPOSED AT ALL.
THE BASIC REASON FOR THAT IS THAT, FIRST OF ALL,
WE QUESTION THE BASIS FOR THE CRITERIA AS IT RELATES
TO THE IMPACT ON HUMAN HEALTH.
I THINK WE WOULD AGREE WITH MR. SELNA THAT FOR A
START THAT AT BEST THE BASIS FOR THESE CRITERIA, AS WE
UNDERSTAND IT, THE WORLD HEALTH ORGANIZATION WORK IS
VERY QUESTIONABLE.
THERE IS SOME LATER INFORMATION THAT IS BEING
DEVELOPED THAT WOULD INDICATE THAT WE PROBABLY AREN'T
ON THE THRESHOLD OF CADMIUM POISONING AS WAS ORIGINALLY

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33
THOUGHT.
WITHOUT A SOUND BASIS FOR THE REGULATION TO
START WITH WE, THEREFORE, WOULD QUESTION THE REGULATION
ITSELF.
WE THINK THAT IF YOU'RE GOING TO REGULATE SEWAGE
SLUDGE FOR BENEFICIAL USE IN AGRICULTURE AS WELL AS
EVENTUALLY THE SALE OF COMPOST PRODUCTS AND SO FORTH
WHICH WILL HAPPEN, THAT YOU SHOULD HAVE VERY SOUND
BASIS FOR DOING SO, ESPECIALLY IN LIGHT OF EPA'S
POLICY WITH ENCOURAGEMENT OF BENEFICIAL USE RECOVERY
OF NUTRIENTS AND SO FORTH IN SLUDGE SLUICES.
SOME FAIRLY OTHER OBVIOUS FACTS.
FIRST OF ALL, THE AMOUNT OF SEWAGE SLUDGE
AVAILABLE AS USED IN AGRICULTURE WOULD NOT SIGNIFICANTLY
IMPACT ON PRODUCTS GROWN IN COMMERCIAL AGRICULTURE
TODAY.
WE ESTIMATE YOU MIGHT IMPACT PERHAPS ONE PERCENT
OF ALL THE AGRICULTURE PRODUCTS GROWN IN THE
UNITED STATES.
IN OUR WORK IN SOLANO COUNTY WITH OUR FIELD CORN
WE WOULD IMPACT APPROXIMATELY ONE PERCENT OF THE FUEL
CORN CROP GROWN IN SOLANO COUNTY. WHEN YOU MIX THAT IN
WITH OTHER CROPS AND IF YOU IMPLEMENT PRACTICES WHICH
ARE FAIRLY -- WELL, GOOD, SOUND MANAGEMENT PRACTICES,
WHICH IS THE KEY, WE WOULD FIND IT HARD TO BELIEVE IN

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HAVING ANYBODY PROVE TO US THAT YOU'RE GOING TO CREATE
A SIGNIFICANT HEALTH PRODUCT FROM USING SEWERAGE SLUDGE
IN AGRICULTURE. GENERALLY IN COMMERCIAL AGRICULTURE.
IF THE WORLD HEALTH ORGANIZATION AND FDA IS
REALLY CONCERNED ABOUT CADMIUM IN THE DIET, AND THEIR
CONCERN IS VALID, WE WOULD BE -- WASTE WATER AGENCIES
ARE A VERY RESPONSIBLE TYPE OF AGENCY -- WELL, WE'D BE
THE FIRST ONES TO NOT USE SLUDGE IN AGRICULTURE.
IF THE FACT THE WORLD HEALTH ORGANIZATION AND
FDA ARE CONCERNED ABOUT CADMIUM IN THE DIET IS VALID,
AND SINCE _\£ERY LITTLE SLUDGE IS USED IN AGRICULTURE
TODAY, IT WOULD SEEM TO US THAT IF YOU REALLY WANT A
CONTROLLED PROBLEM YOU WOULD CONTROL, YOU KNOW, THE
SOURCE OF THE PROBLEM, OR CONTROL THE PROBLEM THROUGH --
BASED ON EXISTING AGRICULTURAL PRACTICES RATHER THAN TO
TRY TO CONTROL IT THROUGH SLUDGE BECAUSE OUR OPINION IS
THAT THROUGH CONTROL OF SLUDGE YOU'RE NOT GOING TO MAKE
ANY IMPACT WHATSOEVER ON ANY POTENTIAL CADMIUM PROBLEM
IN AGRICULTURE.
IT'S JUST AS SIMPLE AS THAT.
YOU ARE NOT GOING TO GROW ENOUGH CROPS WITH
SLUDGE TO MAKE ANY IMPACT, NO MATTER WHAT.
THEN, YOU KNOW, THERE COULD BE LOCAL EXCEPTIONS.
IF A FARMER GREW ONLY .HIS CROPS ON SLUDGE AND ONLY FED
THIS TO HIS CATTLE, AND THAT SORT OF THING.

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35
BUT WHAT I'M TALKING ABOUT IN GENERAL, IF YOU
REALLY WANT TO SPEND YOUR ENERGY IN THE AREAS WHERE IT
WOULD REALLY DO THE MOST GOOD, WE SUGGEST THAT YOU GO
AFTER THE PROBLEM INSTEAD OF REGULATING SEWER SLUDGE.
FOR US IN THE BAY AREA WE FOUND THAT COMPOST
MARKETING AND AGRICULTURAL USE ARE THE PRIMARY USED
PROJECTS. OR LAND RECLAMATION IS ALSO POSSIBLE.
BUT REMEMBER THAT IN LAND RECLAMATION WE RECLAIM
LAND FOR A PURPOSE. USUALLY THAT PURPOSE IS TO RECLAIM
IT SO WE CAN USE IT.
WE WORK WITH FARMERS WHO ARE TRYING TO RECLAIM
AGRICULTURAL LAND, SO IT IS ECONOMICALLY ADVANTAGEOUS
FOR THEM TO FARM THAT LAND, AND IF WE RECLAIM IT WITH
SEWER SLUDGE AND THEN TURN AROUND AND SAY YOU CAN'T
GROW ANYTHING ON IT BECAUSE OF THIS CADMIUM REGULATION,
IT PROBABLY WOULDN'T BE RECLAIMED IN THE FIRST PLACE
WITH SEWER SLUDGE.
LET ME MENTION THAT OUR ANALYSIS SHOWED THAT
AGRICULTURE USE AND COMPONENT MARKETING IS COMPETITIVE
ON A COST AND ENERGY BASIS AND IS COMPETITIVE IN ALMOST
ALL OTHER RESPECTS IN TERMS OF THE SOCIAL IMPACT
ANALYSIS AND ENVIRONMENTAL IMPACT ANALYSIS.
AND WE ALSO LOOKED AT THE RISK ANALYSIS AND
IMPLICATION CONSTRAINT ON ANALYSIS, AND THE PRIMARY
REASON WHY THE LARGE URBAN AGENCIES IN THE BAY REGION

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36
WILL NOT IMPLEMENT -- AND I'M SAYING PROBABLY BECAUSE
IT DOESN'T LOOK LIKE THEY WILL AT THIS TIME -- WILL NOT
IMPLEMENT A FAIRLY LARGE-SCALE AGRICULTURE USE PROJECT
IS BECAUSE OF THESE TYPES OF REGULATIONS WHERE THE
AGENCIES FEEL THAT ALTHOUGH OUR STUDIES HAVE SHOWN
THAT UNDER CONTROLLED CONDITIONS YOU CAN MANAGE A
PROJECT, AND ALTHOUGH OUR ANALYSIS SHOWS THIS IS A
VERY COMPETITIVE METHOD, THEY ARE NOT WILLING TO
INVEST FIFTEEN OR TWENTY MILLION DOLLARS INTO CAPITAL
FACILITIES EVEN AT 87 1/2 PERCENT GRANT FUNDING AND
RISK THE ASSOCIATED IMPLEMENTATION OPERATION WITH THAT
KIND OF PROJECT WITHOUT ANY KIND OF ASSURANCE THAT WE
CAN OPERATE THAT PROJECT OVER A LONG TERM.
WE FEEL THAT OUR BACKGROUND WORK IN BOTH OUR
FIELD TESTS AND OUR GREENHOUSE TESTS, AND THROUGH
IMPLEMENTATION OF PROPER MANAGEMENT METHODS -- AND WE
SEE THREE ITEMS THERE "SOURCE CONTROL" "ADEQUATE SLUDGE
PROCESSING" AND "ADEQUATE MONITORING OF THE SLUDGE,"
AND THE SITE -- THAT WE COULD OPERATE A SYSTEM IN THAT
AREA -- IN OUR AREA -- AND I'M TOLD ON CERTAIN SITES
THEY HAVE ALREADY BEEN IDENTIFIED OVER A LONG TERM
WITHOUT ANY PROBLEM.
NOW, I AM NOT SAYING THAT WE KNOW ALL THE ANSWERS.
WE AGREE THERE ARE UNKNOWNS. BUT IN GENERAL WE FEEL
THAT BASICALLY WHAT MIKE SELNA SAID IS THAT WE WOULD

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37
CAUTION THE IMPLEMENTATION OF THESE KINDS OF REGULATIONS
AT THIS TIME THAT WOULD IN EFFECT -- AND I CAN TELL YOU
FROM OUR PRESENT WORKING IN THE BAY AREA THAT
PRE-AMENDMENT BENEFICIAL USE PROJECTS -- FORCE LARGE
AGENCIES WITHOUT AN ADEQUATE BASIS, IN FACT, FOR YOUR
ASSESSMENT OF THE HEALTH IMPACTS.
AND I WOULD RECOMMEND THAT YOU WORK -- AND I HAD
A SOUND BASIS FOR THESE SO-CALLED HEALTH RISKS PRIOR TO
DEVELOPMENT AND IMPLEMENTATION OF SUCH A REGULATION
BASED ON STRICT CRITERION STANDARDS.
THAT IS ALL I HAD TO SAY. I APPRECIATE THE
CHANCE TO COMMENT.
WE ARE PREPARING A FORMAL COMMENT AND WE WILL
SUBMIT THAT TO YOU IN THE NEAR FUTURE.
MR. SKINNER: THANK YOU.
ARE THERE ANY QUESTIONS BY THE PANEL?
MR. CHANNELL: YES.
IN YOUR STUDIES IN THE BAY AREA HAVE YOU
EXAMINED THE AVAILABILITY OF NON-FOOD CHAIN USE FOR
SLUDGE?
MR. HYDE: YES, WE HAVE LOOKED AT THAT AND IT'S
SOMEWHAT HARD TO FIND, FOR EXAMPLE, CIVIL CULTURE. WE
HAVE LOOKED AT AREAS IN THE BAY AREA WE MIGHT USE IN
CIVIL CULTURE. IT JUST SO HAPPENS THAT WE HAVEN'T
IDENTIFIED ANY VERY SIGNIFICANT AREAS IN WHICH THIS

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38
COULD BE DONE. FOR EXAMPLE, IN SOLANO COUNTY AREA
fktf.
WHERE WE ARE WORKING NOW THERE HARDLY ANY FORESTS
IN THAT PARTICULAR AREA.
WE HAVE LOOKED AT PROPOSALS FOR EVEN STARTING A
FOREST AND USING CERTAIN WOOD PRODUCTS DOWN THE RIVER
IN ANTIOCH AT A PULP MILL, AND WE HAVE LOOKED AT THAT
KIND OF THING.
THERE ARE FORESTED AREAS ALONG THE COAST BUT THE
TERRAIN AND ACCESSIBILITY TO THOSE AREAS, PLUS A LOT IS
IN THE NATIONAL PARK AREA NOW, OUR INDICATIONS, IN
DISCUSSING THIS WITH SOME OF THE FEDERAL AGENCIES THAT
CONTROL THAT LAND, PLUS THE FACT IT WOULD BE VERY
DIFFICULT TO EVEN GET IN THERE AND OPERATE A SYSTEM,
PRECLUDES MOST OF THOSE COASTAL AREAS.
THERE ARE OTHER VALLEYS LIKE THE LIVERMORE, AMADOR
VALLEYS; YOU GET OUT OVER THE HILLS FROM THE BAY, THAT
HAVE AGRICULTURAL AREAS. BUT NOT MUCH IN TERMS OF
FOREST AREAS IN THE REGION.
THERE ARE SOME AREAS IN THE SOUTH COUNTY
SOUTH SANTA CLARA AREA WHICH WE INVESTIGATED THAT HAD
SOME FORESTS, BUT WE WERE PRETTY WELL TOLD THAT THEY
DIDN'T WANT A SLUDGE OPERATION DOWN IN THAT PARTICULAR
AREA.
I THINK SOME OF THE MOST COMMON NON-FOOD AREAS IN
TERMS OF RECLAMATION IS NUMEROUS GRAVEL PITS AND

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39
QUARRIES IN THE AREA, BUT THEY ARE FAIRLY WELL SPREAD
OUT AND THEY WOULD PROBABLY BE MOST ADVANTAGEOUS IN
TERMS OF RECLAMATION OF THOSE LANDS BY AGENCIES LOCATED
NEAR THOSE PARTICULAR SITES.
BUT THERE ARE PROBLEMS ASSOCIATED WITH THOSE
KINDS OF SITES IN TERMS OF GROUNDWATER AND SO FORTH.
MR. DE GEARE: I THINK YOU MENTIONED THREE
CONTROLS THAT YOU WOULD RECOMMEND. WOULD YOU RESTATE
THOSE, PLEASE?
MR. HYDE: YES. THE THREE BASIC CONTROLS -- THIS
IS NOTHING NEW -- IS SOURCE CONTROL, AND WE THINK THAT
HAS LIMITATIONS. WE ARE IN THE PROCESS OF TRYING TO
PUT TOGETHER SOURCE CONTROL PRODUCT IMPLEMENTATION IN
THE BAY REGION. I JUST RECENTLY REVIEWED -- IN FACT ON
THE WAY DOWN ON THE AIRPLANE -- FEDERAL PRE-TREATMENT
I r
PROPOSALS FOR CADMIUM, AND I READ,\ IS AN INSTANTANEOUS
ONE MILLIGRAM PER LITER AND A 30-DAY AVERAGE OF .5.
WE ALREADY MEET THAT IN THE BAY REGION WITH OUR
SOURCE CONTROL PROGRAMS. WE WERE ABLE TO OBTAIN AROUND
50 PARTS MILLIGRAMS PER CADMIUM SLUDGE IN THE REGION.
WE APPLY THAT -- ABOUT TEN TONS PER ACRE PER YEAR,
WHICH WORKS OUT TO ABOUT A POUND OF CADMIUM PER ACRE OR
A KILOGRAM PER HECTARE AT THE PRESENT TIME.
UNDER YOUR 1986 LOW OF A HALF A POUND, WE'D
EITHER HAVE TO HAVE THE CONCENTRATION IN OUR SLUDGES

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40
OR DOUBLE THE LAND AREA BY HAVING APPLICATION RATES.
AND, FRANKLY, WE'D BE TALKING FOR A SINGLE LARGE AGENCY
AROUND 10,000 ACRES. WOULD BE A LITTLE DIFFICULT TO
OBTAIN, AND WE ARE CONCERNED THAT WE MIGHT NOT BE
ABLE TO HAVE THE CONCENTRATION IN THE SLUDGE THROUGH
SOURCE CONTROL. I THINK MIKE KIND OF TOUCHED ON THAT,
MIKE SELNA, A LITTLE BIT.
WE ARE WORKING TO IDENTIFY THE POSSIBILITY FOR
SOURCE CONTROL, DEMONSTRATION PROGRAM WITH REGION IX
TO SEE IF WE COULD DEMONSTRATE IN FACT THAT THROUGH
SOURCE CONTROL WE MIGHT BE ABLE TO MEET AT LEAST, YOU
KNOW, YOUR MINIMUM REQUIREMENT.
SOURCE CONTROL IS ONE ITEM.
THE SECOND ONE WAS ADEQUATE SLUDGE PROCESSING.
WE BELIEVE THAT SLUDGE SHOULD BE ADEQUATELY
STABILIZED WHICH IS NOT VERY WELL DEFINED IN YOUR
RCRA, BUT HANDLE THE DIGESTION AND TYPE OF SYSTEM. IT
SHOULD BE DE-WATERED, WHICH PROVIDES THE FLEXIBILITY
TO MOVE IN DIFFERENT DIRECTIONS.
IF IT'S BEING USED FOR PUBLIC CONTACT, PUBLIC
USE, PUBLIC SALE, WE THINK IT SHOULD BE COMPOSTED OR
ITS EQUIVALENT TO PROVIDE A PATHOGEN-SAFE TYPE 1
PRODUCT.
IN TERMS OF AGRICULTURAL USE WE WOULD AGREE WITH
SOME FORM OF STORING OF LIQUID SLUDGE PERHAPS SIX

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MONTHS TO A YEAR WHICH WOULD AFFECT ADDITIONAL PATHOGEN
REDUCTION.
BEYOND THAT WE DON'T BELIEVE THAT IT WOULD BE
NECESSARY TO COMPOST THE SLUDGE PRIOR TO THE USAGE IN
COMMERCIAL AGRICULTURE, BUT ADEQUATE SLUDGE PROCESSING
IS A CONTROL FOR PRODUCTS IN THE ADMINISTRATIVE
TREATMENT OF SLUDGE ITSELF, YOUR SLUDGE PROCESS AND
YOUR SITE, AND WE AGREED THAT IN OUR REGION A LOT OF --
WELL, NOT A LOT BUT THERE ARE CERTAIN OPERATIONS THAT
INVOLVE USE OF SLUDGE IN AGRICULTURE OR MARKETING TO
THE PUBLIC WITHOUT ADEQUATE CONTROL.
IN FACT, MOST OF THOSE TYPES OF PROJECTS
CURRENTLY IN OPERATION HAVE NO CONTROL, AND I THINK IN
ORDER TO ASSESS THE IMPACT OF THIS PROJECT YOU WOULD
NEED TO — YOU WOULD NEED MONITORING OF THE PROJECT.
BUT WE FEEL A TECHNICAL BULLETIN THAT WAS ISSUED
BY EPA A FEW MONTHS AGO THAT WOULD EVALUATE PROJECTS
ON A CASE-BY-CASE BASIS THROUGH THE ENVIRONMENTAL
PROTECTION AGENCY WOULD ALSO HAVE ADEQUATE MANAGEMENT
CONTROLS. WE BELIEVE THAT IS WHAT IS NEEDED AND WHAT
IS NECESSARY TO IMPLEMENT AGRICULTURAL USE PROJECTS
THAT WOULD BE SAFE OVER THE LONG TERM.
I AM SURE THERE ARE THOSE WHO WOULD DISAGREE
WITH US BUT THAT'S OUR BASIC APPROACH.
DR. SKINNER: WERE THOSE THREE MANAGEMENT CONTROLS

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42
SOURCE CONTROL AND MANAGEMENT OF THE OPERATION AND THEN
MORE MONITORING OF THE SLUDGE AND MONITORING OF THE
CROP?
THERE IS IMPLICIT OR EXPLICIT DETERMINATION AS TO
WHAT AN ACCEPTABLE LEVEL OF UPTAKE OR ACCEPTABLE LEVEL
OF LOADING THAT THE SOIL WOULD BE.
WOULD YOU INDICATE WHAT YOU FEEL IT WOULD BE?
MR. HYDE: WELL, OUR APPROACH IS THAT AS PART OF
OUR OVERALL SITE MANAGEMENT OR MONITORING METHODS --
THE APPLICATION RATE WOULD BE CONSISTENT WITH THE
NITROGEN REQUIREMENTS OF THE CROP. AND CERTAINLY WE
NEED TO LOOK AT OTHER THINGS LIKE CADMIUM. BUT WITH
ADEQUATE SOURCE CONTROL AND PROCESSING OF THE SLUDGE,
I JUST DON'T BELIEVE, BASED ON THE WORK WE HAVE DONE
THAT, AGAIN, IF YOU HAVE THE RIGHT SOILS, PH 6-5 AND
A COUPLE OF THESE THINGS, THAT YOU WOULD BE IN PRETTY
GOOD SHAPE.
DR. SKINNER; I GUESS MY QUESTION IS WHAT IS
ACCEPTABLE UPTAKE. WHAT WOULD YOU KEY YOUR SOURCE
CONTROL APPLICATION RATE AND MONITORING TO? WHAT WOULD
YOU LOOK FOR IN TERMS OF UPTAKE OR CADMIUM LEVEL IN
THE SLUDGE THAT WOULD AID YOU 1^ A DECISION THAT
PERHAPS A DIFFERENT APPROACH WOULD BE NECESSARY?"
MR. HYDE: WELL --
DR. SKINNER: I GUESS MY QUESTION IS THAT

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MANAGEMENT WITHOUT A GOAL OF MANAGEMENT —
MR. HYDE: RIGHT. AN APPROACH WE HAVE TAKEN IS:
GIVEN OUR SLUDGE AT THE PRESENT TIME WITH OUR PRE-LEVEL
OF SOURCE CONTROL, OUR APPLICATION RATE, AND SO FORTH,
WE MONITOR THE CROP THAT WE GROW, BOTH THE TOTAL PLANT
AND THE PLANT WHICH IS ACTUALLY FED TO THE ANIMAL, AND
WE HAVE SHOWN, FOR EXAMPLE, OVER FIVE YEARS NO INCREASE
WHATSOEVER COMPARED TO CROPS GROWN WITH NO SLUDGE AT
ALL, JUST THROUGH SOME SIMPLE STATISTICAL SAMPLING OF
OUR CROP.
AND I WOULD SAY THAT WE ARE NOT CONCERNED ABOUT
THAT.
NOW, AT WHAT POINT ARE WE CONCERNED? WE ARE NOT
AGRICULTURAL EXPERTS AND WE EMPLOY CERTAIN AGRICULTURAL
EXPERTS TO ADVISE US ON THIS, AND WE WOULD EVALUATE THAT
ONE THING FOR SURE, WHEN YOU MONITOR YOU KNOW WHERE YOU
ARE AT, GIVEN TIME.
BUT 1 DON'T KNOW IF ANYBODY COULD TELL US WHETHER
WE COULD GO AT THE PRESENT TIME IN OUR CROP .01, .02
MILLIGRAM PER CADMIUM, WHICH IS ALMOST A DETECTABLE
LIMIT. IF WE INCREASED THAT TEN TIMES SO WHAT?
THERE IS SOME LITERATURE THAT SAYS THE AVERAGE
VALUE IN CORN CROPS IS MAYBE TWO OR THEREABOUTS. I AM
NOT SURE WHAT PERCENT THAT WOULD BE. BUT THIS
MONITORING YOU COULD HAVE A HANDLE ON THIS.

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FOR EXAMPLE, WE SAW SOME OF THE CROPS WHERE
CADMIUM WAS INCREASING VERY RAPIDLY AND WE TOOK A LOOK
AT THIS AND TRIED TO FIGURE OUT WHAT WAS GOING ON
BECAUSE WE WERE CONCERNED THAT WE MIGHT BE REACHING A
HIGHER TOXICANT IN GRASS, FOR EXAMPLE.
WHAT I'M SAYING IS THAT YOU HAVE TO KEEP A HANDLE
ON IT AND EVALUATE THE THING AS YOU GO ALONG, AND I
THINK IF YOU GET OFF WITH A REASONABLY DESIGNED
PROJECT THROUGH GOOD MANAGEMENT CONTROL YOU WILL
PROBABLY STAY OUT OF TROUBLE FOR A WHILE.
DR. SKINNER: DID I UNDERSTAND YOU CORRECTLY TO
INDICATE THAT YOUR MONITORING SHOWS NO UPTAKE —
MR. HYDE: THAT'S CORRECT.
DR. SKINNER: — AS COMPARED TO SIMILAR CROPS
GROWN ON SIMILAR SOILS —
MR. HYDE: THAT'S CORRECT.
DR. SKINNER: -- IN THE SAME AREA?
MR. HYDE: THAT'S CORRECT.
DR. SKINNER: SO, THEREFORE, YOU WOULD BE ABLE
TO --
MR. HYDE: IN THE GRAIN.
DR. SKINNER: IN THE GRAIN.
SO, THEREFORE, YOU WOULD BE ABLE TO COMPLY WITH
THE SECOND PROVISION OF THE CRITERIA.
MR. HYDE: YEAH, BUT WE WOULDN'T WANT TO DO THAT

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45
BECAUSE --
DR. SKINNER: WHY?
MR. HYDE: WELL/ YOU TALK ABOUT, YOU KNOW, THE
LEVELS OF CADMIUM AND CROPS IN THE LOCAL MARKETPLACE,
AND IN MEATS.
AND THE WASTEWATER AGENCY IS NOT IN THE BUSINESS
OF GOING OUT AND SURVEYING MARKET BASKETS.
THE DEPARTMENT OF HEALTH AND US -- WE KICKED THAT
ONE AROUND HERE IN CALIFORNIA A WHILE BACK — AND WHEN
YOU REALLY GET INTO THAT THING, YOU KNOW, THE
DEPARTMENT OF HEALTH REALLY IS NOT IN THE BUSINESS OF
SURVEYING MARKET BASKETS AND THE STATE DEPARTMENT OF
AGRICULTURE HAD NO INTEREST IN DOING THAT, EITHER, AND
WHO IS GOING TO DO IT? WHEN YOU START TALKING LOCAL
MARKETS ALL OF A SUDDEN, YOU KNOW, IT EXPANDS, AND
WHO DESIGNS THE LOCAL MARKET? WHO IS GOING TO PROVIDE
THE MONEY FOR THESE SURVEYS? WHO IS GOING TO DO THE
ANALYSIS? YOU KNOW, IT CAN'T BE VERIFIED. THIS IS
GOING TO BE A BASIS. BUT THIS GETS VERY, VERY
COMPLICATED AND WHEN WE GOT FINISHED WE CAME BACK TO
THE TEST PLOT APPROACH AND THAT IS SOME TESTS ON THE
SITE AND WE USE THAT AS A CONTROL.
DR. SKINNER: WOULD YOU FEEL THAT A STANDARD
BASED UPON A TEST PLOT WHICH REQUIRED A TEST PLOT
DEMONSTRATION TO SHOW NO INCREASE AS -COMPARED TO
RCRA WOULD BE ACCEPTABLE?

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i+6
MR. HYDE: WE THINK THAT IS MORE REASONABLE. I
AM NOT SURE IT IS ACCEPTABLE BUT IT IS MORE
REASONABLE.
WE, IN FACT, DEVELOP, YOU KNOW, INFORMALLY, AN
APPROACH WHERE YOU MIGHT ALLOW TWO TIMES IN SLUDGE
CROP AND THE NON-SLUDGE CROP.
THE PROBLEM IS, LIKE I SAY, IN OUR CROPS .01 OR
.02. SO TWO TIMES -- OR SAY TWO TIMES OF THAT IS .0^.
SO WHAT? YOU KNOW, IT'S NOT SIGNIFICANT ANYWAY, SO
TWO TIMES SOMETHING, THAT IS NOT SIGNIFICANT, YOU KNOW.
THAT IS THE PROBLEM.
I UNDERSTAND WHAT YOU ARE COMING FROM --
MR. SKINNER: YES.
MR. HYDE: — THE DIFFICULTY,.
BUT THIS IS A KIND OF APPROACH WE TRY TO USE.
I THINK PERHAPS SOME TYPE OF PROGRAM LIKE THAT,
BASED ON SOME FACTUAL BASIS OF WHAT LEVELS IN CERTAIN
CROPS ARE — IF YOU EXCEED THAT -- MIGHT GET INTO A
PROBLEM. CERTAINLY WOULD HELP US IN TERMS OF MONITORING
OUR SITE. BUT AS FAR AS I KNOW THERE IS NOT VERY MUCH
DATA AROUND LIKE THAT. DATA THAT IS VALID OR USEFUL.
IF WE KNEW, FOR EXAMPLE, THAT TWO PARTS PER
MILLION IN CORN GRAIN FED TO CATTLE OVER A PERIOD OF
TIME WOULD CREATE A CADMIUM PROBLEM IN CATTLE AND WE'RE
OPERATING DOWN IN .01 OR .02, AND, SAY, OVER A TIME,

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b7
YOU KNOW, WE STARTED COMING UP, WE COULD AT LEAST HAVE
AN INDICATION OF AT WHAT POINT ARE WE GOING TO BE
STARTING TO GET INTO TROUBLE.
OF COURSE WHAT HAPPENS A HUNDRED YEARS FROM NOW
OR 200 YEARS, AS MICHAEL SELNA SAID, WHAT IF ALL THE
ORGANIC MATTER IN THE SOIL WAS DEPLETED? WHAT IF ALL
YOUR CADMIUM COMES OUT IN SOLUBLE FORM?
THERE ARE A LOT OF "WHAT IFS".
IF THE ORGANIC CONTENT OF SOIL IS DEPLETED,
PROBABLY NOT GOING TO GROW ANYTHING ON IT ANYWAY.
IF YOU TRY TO COVER ALL YOUR CONTINGENCIES OR
ALL CONDITIONS, THEN WHAT YOU END UP WITH IS WITH A
NO RISK DEGRADATION POLICY, AND UNDER THAT SITUATION
WE WON'T COMPLETE THE SLUDGE IN AGRICULTURE PERIOD.
AND IF THIS IS WHAT WE REALLY WANT TO DO AND BASE
THIS, IN FACT, THAT IS WHAT WE SHOULD DO, YOU KNOW, THE
HEALTH IMPACT BASIS, THEN, FINE. GREAT. TELL US THAT.
BUT DON'T PROMOTE A LAND APPLICATION POLICY AND THEN
GIVE US A REGULATION THAT IN EFFECT DISCOURAGES THAT
POLICY.
Dfe. SKINKlER: FINE, THANK YOU.
WE WOULD APPRECIATE ANY FURTHER COMMENTS THAT YOU
WOULD HAVE ON WHAT THAT COMPARABILITY WOULD BE.
MR. HYDE: YES. WE THII^K THAT IS CONTROVERSIAL,
OBVIOUSLY.

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48
DR. SKINNER: AND WHAT ACTIONS COULD BE
PRESCRIBED AND COULD BE TAKEN, BASED UPON A FINDING
OF AN INCREASE OF APPROACHING COMPARABILITY LEVEL OR
SOME THRESHOLD LEVEL, SOMETHING THAT YOU WOULD FIND
REASONABLE; WE'D BE VERY, VERY INTERESTED IN HEARING
FROM YOU.
MR. HYDE: OKAY.
DR. SKINNER: FINE. THANK YOU.
MR. HYDE: THANK YOU.
DR. SKINNER: MR. BILL DAVIS.
MR. DAVIS: THANK YOU. MY NAME IS BILL DAVIS,
D-A-V-I-S. I'M THE GUY WITH HALF THE SLUDGE IN THE
STATE OF CALIFORNIA.
I AM GOING TO TRY TO AVOID COVERING MANY OF THE
THINGS THAT HENRY HAS TALKED ABOUT ALREADY. I THINK IT
WOULD BE HELPFUL, THOUGH, FOR YOU AND THE SOLID WASTE
PROGRAM TO HAVE A HANDLE ON SLUDGE PROBLEMS IN L.A.
WE ARE TALKING ABOUT A BASIN THAT IS RINGED WITH
MOUNTAINS, ABOUT THREE OR FOUR THOUSAND FEET IN
ELEVATION.
WE ARE TALKING ABOUT A CRITICAL AIR BASIN WHICH
COUNSEL HAS JUST IDENTIFIED AS THE WORST BASIN IN THE
COUNTRY.
WE ARE TALKING ABOUT A SITUATION WHERE EPA AND
CONGRESS HAS PROHIBITED THE DISCHARGE OF SLUDGE TO THE

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49
OCEAN IN CURRENT PRACTICE.
SO I THINK YOU CAN SEE THE LEVEL OF CONCERN AND
THE REASON FOR THE LEVEL OF CONCERN OVER THESE
REGULATIONS THAT ARE GOING TO BE DEALING WITH LAND
APPLICATION OF SLUDGE.
THERE ARE A COUPLE OF PHILOSOPHICAL POINTS I'D
LIKE TO COVER.
I THINK THE EIS IN THESE REGULATIONS IS GOING
TO HAVE TO DEAL VERY DIRECTLY WITH THE BASIS AND KEY
POINT, THAT IS THE HEALTH HAZARD ASSOCIATION FOR
CADMIUM.
I HAVE SAT HERE AND HEARD AT LEAST TWO CONTRARY
POINTS; APPARENTLY ONE FROM EPA'S OWN HEALTH EXPERT
RESEARCH LAB, AND ONE FROM THE FDA.
I THINK THE QUESTION OF MINIMIZING ADDITIONAL
CADMIUM TO CROP LANDS ALSO MERITS SOME DISCUSSION ON
THE EIS. WHERE IS IT COMING FROM? HOW MUCH IS GOING
TO COME FROM SLUDGE? THERE ARE OTHER SOURCES. IF
YOU"RE REALLY CONCERNED ABOUT CADMIUM PERHAPS THOSE
OUGHT TO BE ADDRESSED.
I THINK THE MONITORING REQUIREMENTS FOR THIS
KIND OF ACTIVITY OUGHT TO SPELL OUT VERY CLEARLY —
PRAGMATICALLY, WE'RE TALKING ABOUT IN THE L.A. AREA,
CAPITAL EXPENDITURES OF $500 MILLION; ANNUAL
EXPENDITURES OF SOME $60 MILLION PLUS TO CARRY OUT A

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50
LAND APPLICATION PROGRAM.
YOU ARE NOT GOING TO GET AGENCIES, EVEN YOUR OWN,
TO COMMIT SPENDING MONEY OF THAT KIND UNLESS THE
REQUIREMENTS ARE CLEARLY SPELLED OUT. THIS IS THE FACT
OF LIFE.
I THINK THE COMBINATION OF YOUR SNOWSTORM AND OUR
RAINFALLS HAS DELAYED OUR SET OF THE PUBLISHED
REGULATIONS. WE JUST RECEIVED THEM ABOUT MID FEBRUARY.
WE WILL BE GIVING YOU DETAILED COMMENTS ON MANY OF THE
POINTS COVERED, AND WE WILL GIVE THEM TO YOU IN WRITING,
AND, LIKE HENRY, WE MAY MAKE IT TO PORTLAND ALSO.
SO THANK YOU.
DR. SKINNER: THANK YOU.
ARE THERE ANY QUESTIONS?
MR. CLARENCE KAUFMAN.
MR. KAUFMAN: THE COUNTY'S SOLID WASTE STAFF HAS
CAREFULLY REVIEWED THE PROPOSED CLASSIFICATION CRITERIA
FOR SOLID WASTE DISPOSAL FACILITIES IN CONJUNCTION WITH
OUR COUNTY HEALTH DEPARTMENT, REGIONAL WATER QUALITY
CONTROL BOARD, AND OTHER INTERESTED PARTIES .
OUR NORMAL PRACTICE IN REVIEWING PROPOSED
REGULATIONS IS TO BE AS CRITICAL AS POSSIBLE, AND ON
THIS OCCASION, I THINK IT IS FAIR TO SAY OUR INTENT
WAS TO BE MORE CRITICAL THAN EVER. CERTAINLY, THESE
REGULATIONS ARE VITALLY IMPORTANT TO THE COUNTY, AND

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51
ANY OTHER AGENCY WHICH HAS RESPONSIBILITY FOR OPERATING
OR REGULATING LAND DISPOSAL OF SOLID WASTES.
TO OUR SURPRISE, WE FOUND VERY LITTLE TO
CRITICIZE. I CAN ONLY CONGRATULATE THE EPA STAFF FOR
DEVELOPING SOLID WASTE FACILITY CRITERIA WHICH WILL
EFFECTIVELY PROTECT THE ENVIRONMENT FROM DEGRADATION
BY SOLID WASTE DISPOSAL FACILITIES, AND YET ALLOW
RESPONSIBLE AGENCIES TO CONTINUE TO PROVIDE DISPOSAL
SERVICE WITH A REASONABLE AMOUNT OF REGULATION.
YOUR PROPOSED CRITERIA HAVE BEEN WISELY DIRECTED
TOWARD A STANDARD OF PERFORMANCE TO BE ATTAINED,
RATHER THAN ARBITRARY RESTRICTIONS TO BE IMPOSED ON
DISPOSAL FACILITY LOCATION, DESIGN, OPERATION, AND
MAINTENANCE. IT APPEARS THAT THE INTENT IS TO PLACE
RESPONSIBILITY FOR THE ESTABLISHMENT AND ENFORCEMENT
OF DETAILED REGULATIONS AT THE STATE AND LOCAL LEVEL
WHICH WILL CERTAINLY ENHANCE THEIR EFFECTIVENESS.
THESE CRITERIA WILL IMPACT SOLID WASTE DISPOSAL
IN SAN DIEGO COUNTY IN SEVERAL WAYS. FIRST, THE
PROHIBITION OF OPEN BURNING OF RESIDENTIAL WASTES WILL
INCREASE THE AMOUNT OF SOLID WASTE TO BE DISPOSED IN
THE MOUNTAIN AND DESERT REGIONS OF THE COUNTY. LAST
YEAR, 956 BURNING PERMITS WERE ISSUED TO RESIDENTS OF
THESE AREAS AND AN UNKNOWN NUMBER OF ADDITIONAL
RESIDENTS BURNED THEIR WASTES WITHOUT HAVING OBTAINED

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52
A PERMIT. SINCE THE COUNTY PROVIDES A NUMBER OF BIN
SITES AND LANDFILLS IN THESE AREAS WITHOUT COST TO THE
AREA RESIDENTS, THE INCREASE IN WASTE VOLUME WILL
INCREASE THE COUNTY'S COST IN PROVIDING THIS SERVICE.
THE AMOUNT OF THIS INCREASE CANNOT BE ESTIMATED AT THIS
TIME.
ALTHOUGH SAN DIEGO COUNTY HAS FOR MANY YEARS
OPERATED ITS SANITARY LANDFILLS IN COMPLIANCE WITH
ALL LAWS AND REGULATIONS, IT APPEARS THAT SOME
ADDITIONAL EFFORT WILL HAVE TO BE EXPENDED ON OUR
PART IN PROVIDING SUFFICIENT MONITORING FOR LEACHATE
AND GAS MIGRATION TO PROVIDE ASSURANCE THAT THE
STANDARDS SET FORTH IN THE PROPOSED CRITERIA ARE MET.
WE DO NOT EXPECT THIS EFFORT TO SIGNIFICANTLY IMPACT
OUR DISPOSAL OPERATIONS.
SOME SEWAGE SLUDGE IS PRESENTLY BEING DISPOSED
OF IN THE COUNTY'S LANDFILLS, AND THERE IS A STRONG
LIKELIHOOD THAT THESE QUANTITIES WILL GREATLY INCREASE
WITHIN THE NEXT FEW YEARS, PARTICULARLY IF SECONDARY
TREATMENT OF SEWAGE IS APPLIED.
ALTHOUGH THE COUNTY BELIEVES ITS EXISTING
INDUSTRIAL WASTE CONTROL PROGRAM PROVIDES EFFECTIVE
CONTROL OVER QUANTITIES OF HEAVY METALS ENTERING THE
SEWERAGE SYSTEM, THE PROPOSED PROGRAM WILL PROVIDE
ADDED ASSURANCE THAT THE FOOD CHAIN IS PROTECTED FROM

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53
HEAVY METAL INTRUSION. WE DO NOT HAVE ANY ESTIMATE
OF THE ADDITIONAL COSTS OF THIS PROGRAM AS YET.
IN SUMMARY, I WOULD LIKE TO EMPHASIZE THAT WE
BELIEVE THE PROPOSED CRITERIA ARE WORKABLE AND
REASONABLE, AND WTLL LEAD TO SUCCESSFUL IMPLEMENTATION
OF THE MANDATE OF PUBLIC LAW 9^-580.
THANK YOU.
DR. SKINNER: THANK YOU.
ANY QUESTIONS? JIM?
MR. CHANNELL: IN YOUR REFERENCE TO THE BURNING
IN THE MOUNTAIN AND THE DESERT PORTION OF THE COUNTY,
WERE YOU REFERRING TO BURNING OF REFUSE FOR PRIVATE
INDIVIDUALS OR —
MR. KAUFMAN: BY PRIVATE RESIDENCES IN THE
INTERIOR REGIONS OF THE COUNTY AND IS AUTHORIZED BY
PERMIT FROM THE -- THEY ARE ISSUED BY VARIOUS FIRE
AGENCIES -- BUT THE PERMITS ARE ISSUED CENTRALLY FROM
THE AIR POLLUTION CONTROL DISTRICT.
MR. CHANNELL: THANK YOU.
DR. SKINNER: ANY OTHER QUESTIONS?
THANK YOU.
KEITH AMUNDSON.
MR. AMUNDSON: DR. SKINNER, WE HAVE NO COMMENT
AT THIS TIME OTHER THAN THE FACT THAT W6 HAVE ONLY
RECENTLY RECEIVED THE CRITERIA AND HAVE NOT HAD THE

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54
OPPORTUNITY TO REVIEW THEM IN DEPTH.
HOWEVER, I MIGHT JUST SAY AS A MATTER OF RECORD,
THAT WE DO ANTICIPATE PROVIDING A DETAILED COMMENTARY
ON THE CRITERIA AT A LATER DATE, PERHAPS AT THE
SEATTLE MEETING.
DR. SKINNER: THANK YOU. THAT IS IN PORTLAND.
THE PORTLAND MEETING.
MR. AMUNDSON: PORTLAND.
MR. GARVIN: WHO DO YOU REPRESENT?
MR. AMUNDSON: STATE SOLID WASTE MANAGEMENT
BOARD, STATE OF CALIFORNIA.
DR. SKINNER: MR. KELLOGG.
MR. KELLOGG: MY NAME IS CLAY KELLOGG,
K-E-L-L-O-G-G. I REPRESENT THE MARKETING BRAf^ttOF
THE L.A. COUNTY SANITATION DISTRICT.
OUR COMPANY HAS BEEN IN BUSINESS 52 YEARS. THE
FIRST 25 YEARS WERE STRICTLY AGRICULTURE, AND WE HAVE
SEEN THE TREMENDOUS RESULTS FROM THE USE OF SEWERAGE
SLUDGE WHICH HAVE BEEN VERY FAVORABLE.
THE LAST 2 7 YEARS HAVE BEEN PRIMARILY THROUGH THE
ORNAMENTAL AND THE HORTICULTURAL FIELD BECAUSE THE
MARKET WAS IN THE L.A. AREA WHERE THE FARM MARKET HAS
DISAPPEARED AND TURNED INTO HOMES.
SO WE HAD TO CHANGE WITH IT. AND WHENEVER YOU HAUL
SEWAGE SLUDGE OR ANY ORGANIC MATERIAL ANY GREAT DISTANCE

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55
YOU RUN OUT OF THE -- THE FREIGHT ITSELF BECOMES SO
HIGH THAT NO LONGER IS IT ECONOMICAL TO USE IT WHEN
YOU GET TO CERTAIN DISTANCES, PLUS NOW WE RECOVER MORE
AND MORE SLUDGE ACROSS THE UNITED STATES; THERE IS
GOING TO BE SLUDGE IN OTHER PEOPLE'S BACK YARDS THAT
THEY ARE GOING TO NEED TO STABILIZE AND COMPOST AND
MAKE AVAILABLE.
NOW, I DON'T THINK IT IS PARTICULARLY WRONG IN
REPEATING SOMETHING THAT SOMEBODY ELSE HAS SAID. I
THINK IT SORT OF EMPHASIZES HOW THE SAME PROBLEM
EXISTS, NOT ONLY AT THE MARKETING END BUT THE
PROCESSING END, AND I — I HAD NEVER MET MIKE SELNA
IN PERSON — I HAVE TALKED TO HIM ON THE PHONE -- BUT
I HAD NEVER MET HIM BEFORE, BUT IT IS AMAZING HOW WE
HAVE AGREED HERE.
NOW, IF YOU REMEMBER A FEW YEARS AGO HOW A
NUMBER OF PEOPLE ACROSS THE UNITED STATES — OR IF YOU
MENTIONED THE WORD "SEWAGE SLUDGE" IT WAS SOMETHING
THEY ARE REALLY AFRAID OF. THEY NEVER REALLY RECOGNIZED
IT AS A NATURAL RESOURCE, WHICH IT IS.
AND NOW, THROUGH GREAT RESEARCH AND STUDY THAT
HAS TAKEN PLACE, THEY FOUND OUT IT ISN'T SUCH A BAD
THING AFTER ALL; THAT THEY ARE HAVING DIFFICULTY
FINDING WHAT IS WRONG WITH SEWAGE SLUDGE WHEN IT IS
WELL STABILIZED AND COMPOSTED. THE CADMIUM — YOU CAN

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TAKE CARE OF THE PATHOGENS AND THE ODORS AND THE
ESTHETIC VALUES BUT THE CADMIUM IS STILL A QUESTION
MARK, AND YET IT STILL HAS NEVER BEEN PROVEN TO BE
HARMFUL TO MAN FROM THE USE OF SEWAGE SLUDGE ON CROPS
WHERE THEY NEED THEM.
ALL OTHER HEAVY METALS AGREED UPON BY THE
EXPERTS THAT BEFORE YOU WILL EAT ENOUGH OF THE --
BEFORE YOU CAN APPLY ENOUGH SLUDGE TO THE LAND TO
CREATE A TOXICITY IN THE PLANT TO WHERE IT WOULD BE
TOXIC TO THE HUMAN, THE PLANT WOULD DIE. SO WE DON'T
NEED TO WORRY ABOUT THAT OTHER THAN CADMIUM.
WHEN I SAY "WORRY ABOUT IT" I MEAN LOOK AT IT.
THE MORE RESEARCH WE DO THE MORE I BELIEVE WE ARE GOING
TO FIND OUT IT IS NOT NEAR AS GREAT A CONCERN AS SOME
PEOPLE THINK IT IS.
SOME PEOPLE ARE STILL FEELING "I HAVE NO PROOF
IT'S NOT HARMFUL."
SO HOW DO YOU FEEL WITH THAT?
I LIKE TO USE THE EXPRESSION "I FEEL MORE NOW
THAN I DID WHEN I GOT HERE." SO, ANYWAY.
SOME TREAT SLUDGE AS ALL THE SAME, WHICH I THINK
IS TOTALLY INCORRECT. WE SHOULD CAREFULLY RECOGNIZE
I
THE DIFFERENCE BETWEEN COMPOST AND WELL STABILIZED
SLUDGE AND JUST ANY OLD THING THAT IS ON THE MARKET.
LAST WEEK OR TWO WEEKS AGO IN ORLANDO, FLORIDA,

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A FELLOW GAVE A -- A DR. WEBER FROM NORTH CAROLINA
GAVE A TALK ON SLUDGE AND SHOWED HOW THIS CORN CROP
WAS GROWING OVER HERE, AND HERE WHERE SLUDGE WAS
APPLIED IT WAS STERILE, AND HOW -- I THINK IT WAS
$100,000 TO BE GIVEN BACK TO THE FARMER FOR RECOVERY
OF HIS LAND, AND IN THE END HE HAD A PICTURE"OF A
HONEY WAGON. THEN THE QUESTION CAME UP FROM THE FLOOR
"BY THE WAY, WHAT IS THAT, SEWAGE SLUDGE?" AND HE SAYS,
"WELL, NO, IT WAS A RESIDUE FROM AN URBAN SITE." BUT
HE WAS REFERRING TO IT AS "SLUDGE."
NOW, A LOT OF PEOPLE WILL PICK UP AN ARTICLE
LIKE THAT AND RUN SCARED.
SO WE HAVE TO LOOK AT IT VERY CLOSELY, WHAT THESE
CONDEMNATIONS OF SLUDGE ARE.
NOW, EPA HAS ASKED FOR COMMENTS ON PROPOSED
CRITERIA. NUMBER ONE, AND TWO, THE ADEQUACIES OF
CRITERIA IN PROVIDING FOR THE PROTECTION OF PUBLIC
HEALTH AND THE ENVIRONMENT.
NUMBER TWO IS: THE PRACTICALITY OF IMPLEMENTATION
OF THE CRITERIA SUCH AS MONITORING, ADMINISTRATIVE AND
ENFORCEMENT PROGRAMS TO ESTABLISH A MINIMUM LEVEL OF
PERFORMANCE BASED ON A COMPARISON WITH THE CADMIUM
LEVELS OF THE SAME APPROPRIATE SPECIES OR METES
PRODUCED ELECTRICALLY FOR SOLID WASTE HAS NOT BEEN
APPLIED. THAT IS TOTALLY IMPRACTICAL. IT WOULD

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CREATE AN ENORMOUS BURDEN ON EVERYONE INVOLVED.
AUTHORITIES WOULD USE ONE AREA AS THEIR CRITERIA FOR
THE ENTIRE STATE OF CALIFORNIA, WHICH IS A HUGE STATE.
SUCH STRANGULATION BY GOVERNMENT AUTHORITIES WOULD
DISCOURAGE THE USE OF STABILIZED AND COMPOSTED AND
SEWAGE SLUDGE.
NOW, MY FEELINGS ARE THAT SEWAGE SLUDGE ARE
VERY, VERY, VERY PRONE. I HAVE NEVER SEEN ANYTHING
ADVERSE OTHER THAN A FEW AREAS WHERE WE HAD USED RAW
SLUDGE TO SEE THE DIFFERENCE. THERE IS A DIFFERENCE IN
THE GROWTH OF PLANTS.
I THINK MAYBE THERE IS GOING TO HAVE TO BE A
COMPROMISE AND IF THERE WAS, FROM THE MARKETING
STANDPOINT, OF HOW I THINK POSSIBLY IT WOULD BE DONE ON
OUTER LIMITS -- IT WOULD BE -- I'D RATHER SEE
RECOMMENDED AMOUNTS OF SLUDGE TO BE USED PER HECTARE
BASED ON CADMIUM CONTENT OF THE SLUDGE- YOU COULD USE
MORE OF THE LOW CADMIUM SLUDGES THAN THE SLUDGES WITH
HIGH CONCENTRATIONS OF CADMIUM.
THE SANITATION DISTRICT WOULD KNOW THEIR
CONCENTRATIONS OF CADMIUM AND A BILL OF SALE TO THE'
FARMER FROM THE BROKER, OR CONTRACTOR, COULD BE SENT
TO THE DISTRICT. THE LEACHATE OF THE SOIL SHOULD BE
TESTED TO MAKE SURE IT WAS AT LEAST 6.5. IT WOULD TAKE
AN EFFORT TO DO IT, BUT I DON'T SEE WHERE IT WOULD BE

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ANY PROBLEM. IT WOULD CERTAINLY MAKE THE FARMER THINK
"WELL, WHY DO I HAVE TO DO THIS," LIKE THIS IS SOMETHING
NEGATIVE AS AN OUTSIDE EDGE.
I THINK WE COULD LIVE WITH THAT IF WE HAD TO.
ANYTHING MORE THAN THAT YOU CAN JUST FORGET THE WHOLE
THING. YOU AREN'T GOING TO GET A FARMER TO APPLY
SEWAGE SLUDGE TO HIS LAND, PARTICULARLY IN CALIFORNIA,
SAY, A GUY WHO OWNS A GOLF COURSE, AND EVEN THOUGH
YOUR REGULATIONS DON'T HAVE THIS AS MIKE KIADO DOES
RIGHT NOW — AT LEAST THE FIRST PART OF IT -- YOU HAVE
TO PLOW TWO FOOT DEEPER OR BRING IN TWO FOOT LANDFILL.
NO FARMER IS EVER GOING TO DO IT. ABSOLUTELY, TOTALLY
IMPRACTICAL. IT'S JUST UNNECESSARY AS FAR AS I'M
CONCERNED.
THERE IS NO NEED TO WAIT — I PUT DOWN "THERE IS
NO NEED TO WAIT ONE YEAR BEFORE PLANTING CROPS OR
STABILIZING COMPOSTED SLUDGE. IF IT IS USED PROPERLY
THIS WOULD DEFINITELY DISCOURAGE THE USE OF QUALITY
SITES."
IF YOU WANT TO PLANT SOMETHING WITH GOOD,
COMPOSTED SEWAGE SLUDGE, YOU CAN DO IT IMMEDIATELY.
WE NEED A POSITIVE APPROACH, NOT A NEGATIVE ONE.
IF YOU ARE GOING TO HAVE LIMITS, THEN INSTEAD OF
SAYING "YOU CANNOT USE MORE THAN 'X' TONS PER HECTARE,"
SAY, "YOU CAN UP TO 'X' TONS PER HECTARE." YOU ARE

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SAYING THE SAME THING BUT YOU ARE RECOMMENDING THE
USE OF IT RATHER THAN SAYING "DON'T USE IT."
THERE IS A LAW ON THE BOOKS IN WASHINGTON, D.C.
THAT WAS INITIATED DURING WORLD WAR II WHERE CERTAIN
CONTRACTORS ARE REQUIRED TO USE CADMIUM ON STEEL,
ET CETERA. I HAVE TALKED -- AND A NUMBER OF PEOPLE
HERE HAVE TALKED TO PEOPLE IN THE METALLURGY ASSOCIATION
IN THE STATE OF CALIFORNIA AND ASKED THEM "WELL, IF YOU
COULD USE ZINC OR HAD TO USE ZINC," THEY SAID, IN MANY
INSTANCES, "THAT WOULD BE FINE."
AND THERE IS A ZINC DEFICIENCY IN OUR DIET.
BUT IF WE JUST CHANGED THAT LAW TO WHERE INSTEAD
OF SAYING "YOU HAVE TO USE IT," SAYING "IF YOU ARE GOING
TO USE IT THEN YOU REGISTER	"WELL, YOU KNOW WHO
YOU ARE, WHERE YOU ARE —" AND THEN THAT WILL REALLY
HELP ON THE MONITORING THING.
A LOT OF PEOPLE THAT ARE USING CADMIUM TODAY
BECAUSE THEY HAVE TO BY LAW, WOULDN'T, AND THOSE THAT
DID NEED TO USE IT, THEY'D GO RIGHT AHEAD AND USE IT
AND THEY'D BE MONITORED AND THEIR RESIDUE MIGHT HAVE
TO BE KEPT SEPARATE AND HAULED OFF TO THE LANDFILL SO
WE CAN KEEP TRACK OF WHERE THE;Y ARE, AND THEY WOULDN'T
MIND.
WHAT THEY WOULD DO ON CASES WHERE CADMIUM-COATED
STEEL IS BEING USED, THEY WOULD UP THEIR PRICES.

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THEY'D COVER IT. IN THE MEANTIME YOU KEEP A LOT OF
CADMIUM OUT OF THE SEWERAGE.
EXCESSIVE GOVERNMENT REGULATIONS ARE HARD TO
REVERSE -- SORT OF THE ANDREA DORIA STORY, IT TAKES
THREE MILES TO STOP AND THEY ONLY HAD A HALF MILE TO
DO IT. IT'S AT THE BOTTOM OF THE ATLANTIC OCEAN NOW.
JUST LIKE IN LOS ANGELES BEFORE THAT LAST BIG
STORM, THEY WERE SEEDING CLOUDS SEVEN HOURS BEFORE THE
WORST STORM HIT LOS ANGELES, AND NOW THE RESERVOIRS
ARE ALREADY FULL.
YOU REALIZE WE ARE CONCERNED THAT THERE IS NO
REASONABLE PROBABILITY OF ADVERSE EFFECT ON THE HEALTH
AND TO THE ENVIRONMENT.
WELL, AS DR. WALKER STATED AT THE CALIFORNIA
CHAPTER OF AGRONOMY IN FRESNO, HE SAYS, "REALLY, DO YOU
REALIZE WHAT YOU'RE TALKING ABOUT?" HE SAYS, "WHAT
WE'RE REALLY TALKING ABOUT AS FAR AS CADMIUM TO THE
HEALTH OF MAN AND HOW IT WOULD BE DETRIMENTAL IS IF
YOU HAD'THE	DR. WALKER IS WITH PHA, HE WAS WITH
WATER, HE WAS WITH HEALTH BEFORE — SAID, "IF YOU HAD
A PATCH OF SOIL AND YOU GREW LEAFY VEGETABLES, ROOT
CROPS, AND THAT WAS YOUR ENTIRE DIET FOR 55 YEARS AND
THAT IS ALL YOU ATE, THERE IS A POSSIBILITY IT MIGHT
BE DETRIMENTAL TO YOUR HEALTH." NOW, FIRST OF ALL,
THAT IS NEVER GOING TO HAPPEN. ,OKAY.

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WELL, IN CLOSING I JUST SAY THAT WELL-COMPOSTED,
STABILIZED SLUDGE IS A NATURAL RESOURCE. AND THERE IS
A REPLACEMENT FOR IT. AND THERE ISN'T TOO MUCH OF IT.
IF WE USED ALL OF IT WE COULDN'T COVER ONE PERCENT OF
OUR FARMLANDS IN THE UNITED STATES.
DR. SKINNER: THANK YOU.
ANY QUESTIONS?
MR. DE GEARE.* I HAVE JUST A FEW,
I THINK YOU SUGGESTED AN APPLICATION CONTROL
BASED ON SLUDGE CADMIUM CONCENTRATION; IS THAT CORRECT?
MR. KELLOGG: AS RAISED — AS OPPOSED --
MR. DE GEARE: FOR FARMERS.
MR. KELLOGG: YES, BUT I DON'T KNOW WHAT THOSE
FIGURES ARE. I DON'T KNOW WHO KNOWS WHAT THOSE FIGURES
WOULD BE.
I'M SAYING THAT YOU COULD MARKET IT ON THAT BASIS
AND DO IT SUCCESSFULLY AND GO OUT WITH A POSITIVE
ATTITUDE.
MR. DE GEARE: YOU ARE SPEAKING OF A CONCEPT
PREFERABLE TO WHAT?
MR. KELLOGG: BEING PREFERABLE TO THE NUMBER TWO
IN YOUR LIST WHERE IT SAID THAT TO ESTABLISH A MINIMUM
LEVEL OF PERFORMANCE BASED ON COMPARISON! WITH THE
CADMIUM LEVEL IS OF ONE PIECE OF GROUND AND THEN FIRST
THING YOU KNOW TELL US THAT ALL OVER CALIFORNIA, AND IT

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REALLY DOESN'T MAKE SENSE. MAYBE IT WOULD IN SALINAS
ONLY BUT THAT'S ONLY A FEW MILES.
DR. SKINNER: I AM NOT SURE IF I UNDERSTAND YOUR
POINT.
THE ITEM -- THE FIRST APPROACH TOWARDS DEALING
WITH CADMIUM IS BASED UPON A CERTAIN APPLICATION RATE
IN TERMS OF KILOGRAMS PER HECTARE OF CADMIUM.
NOW, THAT IS TRANSLATABLE INTO CERTAIN TONS PER
HECTARE OF SLUDGE IF YOU KNEW THE CADMIUM CONTENT.
ARE YOU SAYING THAT THAT IS A PREFERABLE APPROACH?
MR. KELLOGG: NO. I'M SAYING — FIRST OF ALL, I
WISH THERE WASN'T ANY AT ALL. BUT IF YOU HAD TO USE
THE APPROACH TO WHERE YOU COULD APPLY SLUDGE ON LAND
ONLY WHERE IT DOESN'T SHOW AN INCREASE OVER THE LOCAL
CADMIUM CONTENT, IT WOULD BE TOTALLY IMPRACTICAL AND
IMPOSSIBLE TO GOVERN AND YOU'D HAVE A HEADACHE ON —
YOU JUST AS WELL HAUL IT ON A LANDFILL. NO WAY YOU CAN
TOUCH IT.
DR. SKINNER: I HAVE ONE OTHER QUESTION.
WHEN YOU STARTED YOUR STATEMENT YOU INDICATED
THAT THE CURRENT MARKET IS MAINLY ORNAMENTALS.
MR. KELLOGG: FOR OUR COMPANY. ORNAMENTALS,
GOLF COURSES, SCHOOLS, CEMETARIES. IF YOU LIKE THE
WAY LOS ANGELES IS LAID OUT YOU CAN SEE IT HAS NITROGEN
USE.

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DR. SKINNER: SO THE COMPOSTED SLUDGE THAT YOU
ARE DEALING WITH IS NOT FOR AGRICULTURAL USAGE
PRIMARILY?
MR. KELLOGG: IF SOMEBODY WANTED TO BUY IT.
BUT WE HAVE HAD IT ON ALLOCATION FOR THE LAST THREE
YEARS.
L. A. COUNTY WAS PRODUCING 30, 000 TONS A YEAR AND
WE WERE SELLING 50. AND SO WHEN OUR INVENTORY WENT
DOWN I HAD TO PUT IT ON ALLOCATION FOR THREE YEARS AND
CUT IT ALL, EVEN TO THE GOLF COURSES.
DR. SKINNER: SO ALL YOUR MARKET IS GOING TO
ORNAMENTAL USES?
MR. KELLOGG: CURRENTLY, UNTIL WE -- OH, WE USED
IT IN ORANGE GROVES FOR A YEAR AND HAD A LOT OF
ADVANTAGES OVER OTHER ORGANIC MATERIALS.
THERE ARE A LOT OF PEOPLE THAT DON'T KNOW THE
DIFFERENCE BETWEEN HORSE MANURE AND SEWERAGE SLUDGE.
AND IT'S JUST -- AND YET THEY SPEAK OF BOTH OF THEM AS
BEING THE SAME AND YOU KNOW THEY ABSOLUTELY ARE NOT.
DR. SKINNER: YES. BUT THE POINT -- FOR
CLARIFICATION, I GUESS — YOU'RE AWARE THAT THE CADMIUM
RESTRICTIONS IN THE CRITERIA ONLY APPLY TO FOOD CHAIN
CROP USES AND WOULD NOT APPLY TO ORNAMENTAL OR LAWN
USES.
MR. KELLOGG: WELL, I KNOW THAT IS THE SUBJECT

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OF THIS MEETING --
DR. skinner: YES.
MR. KELLOGG: ~ BUT I KNOW WHAT THE SUBJECT IS
GOING TO BE FOR THE MATTER NEXT ON HAND OF BAG PRODUCTS
WE SELL.
DR. SKINNER: I UNDERSTAND THAT. I GUESS I WAS
JUST CONCERNED THAT YOUR COMMENTS WERE NOT BEING MADE
WITH RESPECT TO THE ORNAMENTAL MARKET.
MR. KELLOGG: WELL, MY COMMENTS WERE BEING
DIRECTED INTO THE AGRICULTURE MARKET --
DR. SKINNER: I SEE.
MR. KELLOGG: -- VERY MUCH, BECAUSE THERE ARE
AREAS THAT MAYBE WE WILL MOVE INTO IN OTHER PARTS OF
THE UNITED STATES AND WORK THE SANITATION DISTRICTS,
AND THAT MIGHT BE OUR NUMBER ONE MARKET, WILL BE THE
FARM MARKET.
DR. SKINNER: I SEE. THANK YOU.
ANY OTHER QUESTIONS?
THANK YOU.
THAT COMPLETES EVERYONE WHO HAS REGISTERED AND
INDICATED THEY WOULD LIKE TO MAKE A STATEMENT. IS THERE
ANYONE WHO I HAVE NOT COVERED THAT REGISTERED WHO WOULD
LIKE TO MAKE A FORMAL STATEMENT?
ARE THERE ANY QUESTIONS FROM THE AUDIENCE?
WERE THE CARDS PASSED OUT?

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CVOICE ANSWERED IN THE AFFIRMATIVE.)
DR. SKINNER: IF THERE ARE ANY QUESTIONS FROM
THE AUDIENCE YOU CAN PASS THE CARDS TOWARD THE CENTER.
OKAY, I HAI7E ONE QUESTION. IF THERE ARE ANY
OTHERS, PASS THEM FORWARD.
THE QUESTION IS "WHAT DOES EPA EXPECT TO HAPPEN
TO SLUDGE IF Cl) DISCHARGE TO WATER IS PROHIBITED;
AND (2) DISCHARGE TO AIR IS NOT PERMITTED; AND
(3) LAND APPLICATION IS PRECLUDED; AND CO TECHNOLOGY
IS NOT ON LINE TO DE-WATER SLUDGE GREATER THAN
30 PERCENT SOLIDS."
I WILL ANSWER THAT ONE.
OBVIOUSLY, THAT IS AN IMPOSSIBLE SITUATION. THAT
IS NOT THE INTENT.
WITH RESPECT TO THE CURRENT REGULATION, THE
INTENT IS NOT TO PRECLUDE THE USE OF SLUDGE ON
AGRICULTURAL LAND BUT IS TO PROVIDE PROTECTION WHEN
THAT SLUDGE IS USED ON AGRICULTURAL LAND AND OTHER
LAND USES, AND THE REGULATION WAS DEVELOPED IN ITS
CURRENT FORM -- AND WE ARE VERY INTERESTED IN COMMENTS
ON ITS ADEQUACY AND ITS IMPACT — AND OBVIOUSLY WE
COULD NOT ALLOW A SITUATION TO OCCUR WHERE ALL FOUR
OF THESE SITUATIONS DID EXIST.
ARE THERE ANY OTHER QUESTIONS?
MR. SELNA: I HAVE A QUESTION. CAN I MAKE IT

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VERBALLY?
DR. SKINNER: YES.
MR. SELNA: WOULD IT INVOLVE AN INORDINATE
AMOUNT OF PAPER TO DELINEATE THE METHOD USED IN
DERIVING THE NUMERICAL REGULATIONS FOR CADMIUM?
IN OTHER WORDS, COULD YOU APPEND TO YOUR
REGULATIONS THE METHOD THAT COULD BE USED TO ARRIVE
AT THOSE NUMBERS?
DR. SKINNER: YES. THEY WILL BE IN THE EIS, AND
BASICALLY THEY ARE BASED UPON SEVERAL THINGS. THEY
ARE BASED UPON FDA RECOMMENDATIONS. IN FACT, THE
ACTUAL PROPOSED LEVELS ARE LESS STRINGENT THAN THE
RECOMMENDATION MADE BY FDA. WE ARE ASKING FOR FDA
COMMENTS ON THE PROPOSAL THAT WE MADE, AND THEY ARE
'A', BASED UPON OUR OBSERVATION OF THE CADMIUM LEVELS
IN VARIOUS SLUDGES AND VARIOUS COMMUNITIES AROUND THE
NATION, AND AN ESTIMATE OF WHETHER OR NOT THEY WOULD
BE ABLE, TO COMPLY WITH THOSE LEVELS, AND WHEN THEY
WOULD BE ABLE TO COMPLY WITH THEM.
BUT THAT WILL BE COVERED IN THE EIS.
MR. GARVIN: JOHN, HAVE YOU ALREADY INDICATED
THAT EIS WILL BE AVAILABLE TO THE PUBLIC AND WHERE THEY
MAY OBTAIN A COPY?
DR. SKINNER: YES, THE EIS WILL BE AVAILABLE TO
THE PUBLIC AT THE END OF THIS MONTH. IT WILL BE

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ADVERTISED -- OR ANNOUNCED IN THE FEDERAL REGISTER AND
THE FEDERAL REGISTER WILL INDICATE WHERE YOU APPLY FOR
A COPY, AND THEN THERE WILL BE A 45-DAY COMMENT PERIOD
ON THAT.
ANOTHER QUESTION -- ACTUALLY IT'S THREE PARTS.
THE FIRST PART IS "LIMITS FOR CADMIUM ARE EXPRESSED IN
TERMS OF KILOGRAMS PER HECTARE. DOES THIS RELATE TO A
SURFACE APPLICATION OR IS IT BASED UPON THE WEIGHT OF
A VOLUME OF SOIL."
IT'S KILOGRAMS OF CADMIUM IN THE SLUDGE PER
HECTARE OF LAND.
MR. PAGE: -YOUR LIMITS ARE BASED ON A MAXIMUM
APPLICATION --
DR. SKINNER: I'M SORRY, I CAN'T HEAR THE
QUESTION.
MR. PAGE: YOUR LIMITS FOR CADMIUM ARE BASED
UPON A MAXIMUM APPLICATION TO LAND ANNUALLY AND THEN
OVER THE LIFETIME OF THE PROJECT. DOES THIS REFER TO
A SURFACE APPLICATION OR DOES IT REFER TO THE WEIGHT
OF THE VOLUME OF SOIL?
ALBERT L. PAGE, UNIVERSITY OF CALIFORNIA,
RIVERSIDE.
DR. SKINNER: IT RELATES TO SURFACE APPLICATION.
MR. PAGE: THAT IS NOT CLEAR IN THE REGULATIONS.
DR. SKINNER: THANK YOU.

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MR. page: THAT MAKES IT MORE RESTRICTIVE,
INCIDENTALLY.
DR. SKINNER: LET ME FINISH THESE OTHER TWO
QUESTIONS AND THEN I WOULD APPRECIATE IT IF YOU HAVE
YOUR QUESTION IN WRITING IF YOU HAVE ANOTHER QUESTION.
IT SAYS "IF THE LIMITS REFER TO THE WEIGHT OF
A VOLUME OF SOIL, CAN ONE TILL TO GREATER DEPTHS TO
DILUTE APPLICATION RATES?"
THAT DOES NOT APPLY TO VOLUME OF SOIL.
THE THIRD QUESTION IS "IN TERMS OF
NON-AGRICULTURAL USE H3W DOES EPA PROPOSE TO INSURE
THAT AT SOME FUTURE POINT IN TIME THIS LAND WILL NOT
BE USED FOR FOOD CROPS?"
THE REGULATION DOES NOT ADDRESS THAT ISSUE AT
ALL AND I DON'T HAVE A PROPOSAL FOR THAT.
ANOTHER QUESTION IS: "WILL YOU DEVELOP A MAILING
LIST FOR THE EIS? IF SO, WHO CAN WE WRITE TO NOW TO
GET ON THAT LIST WITHOUT WAITING UNTIL THE END OF THE
MONTH?"
WRITE TO THE ADDRESS — THE ADDRESS IS AT THE
REGISTRATION DESK. ADDRESS IT TO MR. SHUSTER AND HIS
MAILING ADDRESS IS AT THE REGISTRATION DESK.
WE WILL PUT YOU ON THE MAILING LIST FOR EIS.
OKAY, A NUMBER OF QUESTIONS. "DO WE HAVE ANY
FEELING FOR THE STATES' ABILITY TO CARRY OUT THE OPEN

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DUMP INVENTORY IN ONE YEAR AS REQUIRED UNDER RCRA?"
TRUETT, WOULD YOU LIKE TO RESPOND TO THAT?
MR. DE GEARE: OUR FEELING NOW IS THAT IT WILL
NOT BE POSSIBLE TO COMPLETE THE INVENTORY IN ONE YEAR'S
TIME PERIOD.
THE STATUTE DID SAY THAT THE INVENTORY WOULD BE
PUBLISHED BY EPA ONE YEAR AFTER FINALIZATION OF THE
REGULATION THAT WE ARE PRESENTLY DISCUSSING.
AFTER COMING THIS FAR IN THE DEVELOPMENT OF THE
REGULATION IT IS APPARENT TO US THAT THE COMPLEXITIES
AND COSTS INVOLVED IN EVALUATING DISPOSAL FACILITIES
AGAINST CRITERIA OF THIS NATURE WOULD PRECLUDE THE
POSSIBILITY OF BEING TIME-SCHEDULED.
SO WE WOULD ENVISION A TIME PHASING OF THE
INVENTORY EVALUATION PROCESS WITH THE FIRST PHASE —
FIRST INSTALLMENT OF THE INVENTORY BEING PUBLISHED ONE
YEAR AFTER FINALIZATION OF THIS REGULATION, AND
SUBSEQUENT PHASES OR INSTALLMENTS BEING PUBLISHED EVERY
YEAR THEREAFTER.
DR. SKINNER: THEY ARE ACTUALLY -- I THINK YOU
ADDRESSED THAT TO THE OTHER TWO PARTS. "WILL THERE BE
EXTENSIONS AS REQUIRED?" AND "HOW WILL THE EXTENSIONS
BE GRANTED?"
THOSE EXTENSIONS WILL BE GRANTED THROUGH THE STATE
GRANT PROGRAM.

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THE DATE OF THE PORTLAND HEARING. THERE IS A
QUESTION ON THAT. 26TH OF APRIL.
"WILL THERE BE ANOTHER PUBLIC HEARING ON THE
£1
WEST COAST AFTER ISSUANCE OF THE *S?"
YES, THE PORTLAND HEARING WILL COVER BOTH THE
EIS AND THE CRITERIA AS WILL THE REMAINING THREE ^
HEARINGS.
YES, TWO QUESTIONS. NUMBER ONE, "COULD THE
TOXI COLOG ICAL BASIS FOR THE CADMIUM LOADING RESTRICTIONS
BE INCLUDED AS A PREAMBLE IN THE REGULATION IN ORDER
TO ESTABLISH THE CREDIBILITY OF THE BASIS FOR THE
PROPOSED RESTRICTIONS?"
AND THE SECOND PART TO THAT "HAS AN ESTIMATE
BEEN MADE AS TO THE PERCENTAGE OF TOTAL U.S.A.
MUNICIPAL SLUDGE PRODUCTION WHICH WOULD BE DISQUALIFIED
FROM APPLICATION AT THE 0.5 KILOGRAM PER HECTARE LEVEL
TODAY?"
WITH RESPECT TO THE FIRST PART OF THAT QUESTION,
THE PREAMBLE TO THE EIS DID INDICATE THAT WE DID BASE
OUR CADMIUM LOADING RESTRICTIONS ON RECOMMENDATIONS
FROM FDA, AND ALSO AN ESTIMATE OF WHAT THE IMPACT ON
CURRENT PRACTICES WOULD BE, AND ALSO AN ESTIMATE OF
WHAT PRE-TREATMENT WOULD BE AVAILABLE TO ACCOMPLISH —
IN ORDER TO BRING CURRENT CADMIUM LEVELS IN THE SLUDGE
DOWN TO — TME EFFECTIVENESS OF PRE-TREATMENT IN

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REDUCING CADMIUM LEVELS IN THE SLUDGE.
MORE INFORMATION ON THAT WILL BE INCLUDED IN
THE EI S, AS WILL AN ESTIMATE OF THE PERCENTAGE OF
MUNICIPAL SLUDGE PRODUCTION WHICH WOULD BE DISQUALIFIED
FROM APPLICATION AT THE .5 PER KILOGRAM PER HECTARE
NUMBER TODAY.
I DON'T HAVE THAT NUMBER RIGHT IN FRONT OF ME,
BUT WE DO HAVE AN ESTIMATE OF THAT AVAILABLE.
DR. COHEN: JOHN, I BELIEVE YOU STATED THAT WAS
DISCUSSED AT THE PREAMBLE TO THE EIS.
DR. SKINNER: IN THE PREAMBLE TO THE REGULATION.
IT EXPLAINS IN GENERAL TERMS THE BASIS FOR THE LEVEL.
DR. COHEN: CRITERIA?
DR. SKINNER: THE LEVEL CONTROL.
DR. COHEN: EXCUSE ME, I WROTE THAT QUESTION.
THERE ARE SEVERAL METABOLIC MODELS THAT ARE FLOATING
AROUND BEING QUOTED. CAN YOU SPECIFICALLY, OR CAN IT
BE STATED WHICH ONE IS THE CRITERIA THAT EPA IS USING?
DR. SKINNER: I CANNOT, NO. IF YOU WOULD LIKE TO
LEAVE YOUR NAME I THINK WE WOULD GET BACK TO YOU ON
THAT.
ANY OTHER QUESTIONS?
MR, GARVIN: SOMEONE GAVE ME A QUESTION THAT IS
"WHAT LIABILITY WILL EPA OR LOCAL AGENCIES HAVE FOR
LAND WHICH MAY POTENTIALLY BE CONTAMINATED BY CADMIUM

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OR PATHOGENS?"
GENERALLY, THERE WOULD BE NO LIABILITY FOR
REGULATORY AGENCIES, EPA AND STATE AGENCIES. AND AS
LONG AS THE MUNICIPAL AGENCIES SELLING THE SLUDGE
WERE COMPLYING WITH THE STANDARDS THAT EPA HAS
PROMULGATED, IF EPA DOES, IN FACT, PROMULGATE A
CADMIUM STANDARD, THERE WOULD BE -- IT WOULD BE
EXTREMELY DIFFICULT TO PROVE LIABILITY OR ESTABLISH
LIABILITY ON THE PART OF THAT MUNICIPAL AGENCY BECAUSE
AS LONG AS AN INDIVIDUAL OR ENTITY IS COMPLYING WITH
PROMULGATED REGULATIONS THAT IS ALL THAT IS NECESSARY
TO MEET THE REASONABLE MAN TEST THAT IS ESTABLISHED
GENERALLY IN TORT LAW. SO I DON'T THINK THERE WOULD
BE MUCH LIKELIHOOD OF A SUCCESSFUL CASE HOLDING A
MUNICIPAL AGENCY LIABLE.
DR. SKINNER: THIS IS A QUESTION THAT, KEN,
PERHAPS YOU CAN ANSWER. "WILL UN-LINED INDUSTRIAL
WASTE PONDS BE CLASSIFIED AS OPEN DUMPS? IF YES,
WILL EPA/STATE COMPLIANCE SCHEDULES ALLOW THEIR
EXISTENCE, IF THE SCHEDULE IS MET?"
MR. SHUSTER: OKAY. THE CRITERIA DOES APPLY TO
INDUSTRIAL LAGOONS AND PONDS.
THE GROUNDWATER CRITERION ALLOWS FOR TWO
OPERATIONAL METHODS. ONE IS UNfiR, THE OTHER IS THE
UTILIZATION OF ATTENUATION MECHANISMS. AND THE BASIC

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7k
PERFORMANCE THAT HAS TO BE MET IS THAT YOU DON'T
ENDANGER THE GROUNQWflTfcP. BEYOND THE PROPERTY BOUNDARY.
ENDANGERMENT IS CONTAMINATION TO THE EXTENT THAT A
GROUNDWATER USER, IF IT IS USED FOR DRINKING WATER,
WOULD HAVE TO TREAT THE GROUNDWATER TO USE IT OR THE
GROUNDWATER WOULD BE RENDERED UNFIT FOR HUMAN
CONSUMPTION.
ANOTHER ALTERNATIVE IS IN THE SECOND CASE IN
THE GROUNDWATER CRITERION, IS THAT IF IT IS NON-
DRINKING WATER THE STATE CAN DESIGNATE OTHER USE
BESIDES DRINKING WATER AND SET A DIFFERENT STANDARD IF
IT CAN BE ACHIEVED.
DR. SKINNER: THANK YOU.
ANOTHER QUESTION IS "WILL THE EIS COVER THE COSTS
OF PRE-TREATMENT TO ACHIEVE REQUIRED CADMIUM LEVELS, AND
COMPARE SUCH COSTS TO THE BENEFITS TO BE DERIVED UNDER
THE REGULATIONS?"
IT WILL NOT. THE EIS WILL NOT COVER THE COSTS
OF PRE-TREATMENT TO ACHIEVE REQUIRED CADMIUM LEVELS,
BECAUSE THE CRITERIA DO NOT SET STANDARDS FOR
PRE-TREATMENT. THERE ARE PRE-TREATMENT REGULATIONS
BEING DEVELOPED 8Y THE AGENCY AND THOSE REGULATIONS
SHOULD CONSIDER THE COSTS OF PRE-TREATMENT.
THE EIS WILL MAKE ESTIMATES OF THE COSTS OF
COMPLYING WITH THE CRITERIA FOR ALL ASPECTS OF THE

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75
CRITERIA INCLUDING THOSE DEALING WITH CADMIUM
APPLICATION.
BUT ESTIMATE OF THE DOLLAR VALUE OF THE BENEFITS
IS VERY, VERY DIFFICULT AND WAS NOT DONE IN THE EIS
EXCEPT IN A FEW SPECIAL CASES WHERE THERE WAS SOME
INFORMATION.
BUT THERE WILL NOT BE ESTIMATES OF THE DOLLAR
BENEFITS WITH RESPECT TO CADMIUM.
DR. SKINNER: THERE IS A QUESTION WOULD I PLEASE
ASK OF THOSE IN ATTENDANCE HOW MANY ARE INTERESTED
CITIZENS RATHER THAN REGULATORY AGENCY OR SPECIAL
INTEREST PERSONS.
HOW MANY ARE INTERESTED CITIZENS RATHER THAN
REGULATORY AGENCIES OR SPECIAL INTEREST PERSONS?
I SEE TWO HANDS.
MR. MNOIAN: COULD I SAY SOMETHING, JOHN,
PLEASE?
DR. SKINNER: YES.
MR. MNOIAN: PAUL MNOIAN, M-N-O-I-A-N, PRIVATE
DUMP OPERATOR. YOU KNOW, I HAVEN'T HAD THE PRIVILEGE
OF READING THE CRITERIA THAT YOU HAVE WRITTEN, BUT I
HAVE READ A LOT OF OTHER REGULATIONS THAT HAVE COME
FROM THE AGENCIES, THE WATER QUALITY AND OTHERS, OVER
THE PAST FEW YEARS, AND I FIND THAT THE INTERPRETATION,
WHEN IT FINALLY GETS DOWN TO THE DUMP SITE ITSELF, THE

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PEOPLE THAT ARE INTERPRETING THE CONDITIONS THAT YOUR
AGENCY IS WRITING AND OTHERS, IS ALTOGETHER DIFFERENT,
AND THERE IS TOO MANY DUAL STANDARDS. THEY WILL LET
CERTAIN OPERATORS GET AWAY WITH CERTAIN CONDITIONS AND
OTHERS THAT ARE IN THE SAME FIELD NOT GET AWAY WITH
THEM.
FOR INSTANCE, SOME OF THE REGULATIONS LIKE CLASS
III DUMP SITES, OR THE PORTER-COLOGNE WATER AUTHORITY
SAYS THAT YOU CAN HAVE MINOR AMOUNTS OF WOOD IN A
CLASS III DUMP SITE.
OTHER AGENCIES FURTHER DOWN IN THE WATER QUALITY
IN THIS AREA SAY "NO, YOU CAN'T HAVE ANY." BUT OTHER
DUMP SITES THAT ARE IN OTHER LOCATIONS -- THEIR
INSPECTORS ARE INTERPRETING IT ACCORDING TO THE
PORTER-COLOGNE WATER AUTHORITY.
NOW, THERE WILL BE SOMEBODY FOR THE PROTECTION OF
THE PEOPLE IN THE BUSINESS THAT ARE TAKING THIS
MATERIAL EVERY DAY, DISPOSING OF IT, SO THAT THE PUBLIC
CAN OPERATE -- THERE SHOULD BE SOME GRANDFATHER CLAUSE
OR AGENCY THAT CAN SUPERSEDE SOME OF THE SMALLER
AGENCIES DOWN THE LINE THAT ARE DOING THIS INTERPRETING.
THE REGULATIONS, LIKE WHAT YOU'RE READING
TONIGHT, ACTUALLY CREATE AN ENVIRONMENTAL BOGEYMAN
IN THE MINDS OF THE PUBLIC, THEY JUST GET SCARED THE
MINUTE THEY HEAR THE WORD "TOXIC"; THEY JUST CLAM UP,

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THEY DON'T WANT A SITE HERE, THEY DON'T WANT ONE WITHIN
20 MILES OF WHERE THEY LIVE.
AND SO I THINK, IF YOU'RE GOING TO COME UP WITH
THESE NEW REGULATIONS -- AND I THINK THAT THERE NEEDS
TO BE SOME ORDER AND GUIDELINES, BECAUSE THERE ARE
CHEMICALS AND MATERIALS THAT ARE COMING OUT THAT ARE
DANGEROUS. FOR INSTANCE, SOME MATERIAL YOU CAN HANDLE
SAFELY BUT ONCE THEY GET INVOLVED IN A FIRE THEY GIVE
OFF POISONOUS SMOKE OR ODOR, AND THEY SHOULD BE GUARDED.
FOR INSTANCE, ASBESTOS.
OVER THE PAST 50 YEARS IN THIS AREA AND THE AREA
THAT I HAVE BEEN INVOLVED IN, RUBBISH PICKING UP IN
LOS ANGELES COUNTY, AND MY COMPANY ALONE HAS HANDLED
APPROXIMATELY THREE AND A HALF MILLION TONS OF RUBBISH
IN THE PAST ttO YEARS AND HAS DISPOSED OF IT, WE HAVE
HANDLED ALL SORTS OF TOXIC MATERIALS: PAINTS, THINNERS,
ACIDS, RUBBISH, GARBAGE -- GARBAGE IS ONE OF THE WORST
AND NO ONE HAS DIED FROM HANDLING ANY OF THIS MATERIAL.
THEY HAVE BEEN RUN OVER BY A TRUCK OR FALLEN OFF THE
TRUCK, BUT THEY HAVEN'T DIED FROM IT.
I KNOW YOU GENTLEMEN UP THERE LOOK PRETTY YOUNG
TO ME, AND I DON'T BELIEVE YOU HAVE EVER WORKED ON A
SANITARY-VIC-TANNEY-RUBBISH TRUCK, AND I HOPE YOU NEVER
DO, BUT IT WON'T KILL YOU, WON'T HURT YOU, AND WHAT
I'M TRYING TO SAY IS THAT THESE MATERIALS ARE BEING

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PRODUCED ALL THE TIME IN THE COMMUNITY AND THEY
HAVE TO BE HAULED TO A PLACE, AND IN THIS PARTICULAR
AREA ON THE WEST COAST THE SANITARY LANDFILL -- IT'S
REALLY MOST PROMISING, AND THE MOST LONG LIVED, AND THE
ONE THAT HAS THE MOST HISTORY, THE LONGEST HISTORY OF
ITS OPERATION. IT WORKS OUT.
BUT WE JUST CAN'T HAVE REGULATIONS THAT ARE
SCARING THE PUBLIC IN WHICH PRIVATE ENTERPRISE WILL
LOOK FOR A SITE, WILL MEET THE CRITERIA OF THE STATE,
PASS ALL OF THOSE, DO ALL THE GEOLOGY.
AND YET SOME PEOPLE CAN COME UP TO THE PLANNING
COMMISSION HERE, GO TO A COUNCIL HEARING, AND SAY
"OKAY, WE KNOW IT PASSES ALL OF THIS, ALL THE
REQUIREMENTS, THE ZONE IS CORRECT, BUT PUT JT SOMEWHERE
ELSE."
IT IS GOING TO GO SOME PLACE AND IT CAN'T GO TOO
FAR AWAY FROM THE COMMUNITY.
AND SO ALONG WITH THESE REGULATIONS YOU SHOULD
ALSO STIPULATE THAT THERE HAS TO BE A SITE THAT THE
PUBLIC CAN -- VERY CLOSE BY -- THAT IS NOT DANGEROUS,
THEIR CHILDREN WON'T FALL IN IT AND DIE.
THIS IS ALL I'M ASKING, BECAUSE WE ARE GOING TO
NEED THESE SITES FOR A LONG TIME.
DR. SKINNER: THANK YOU. LET ME ASSURE YOU
THAT IT IS NOT THE INTENTION OF THE REGULATIONS TO

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79
PRECLUDE THE USE OF DISPOSAL OPERATIONS AND RESTRICT
THE USE OF THE DISPOSAL OPERATION, BUT INSURE THOSE
DISPOSAL OPERATIONS ARE OPERATED IN A WAY THAT
PROVIDES PROTECTION OF THE ENVIRONMENT.
I THINK WE DEFINITELY" RECOGNIZE THAT DISPOSAL
IS A NECESSARY SERVICE AND NEEDS TO BE PROVIDED FOR
THE FUTURE.
MR. MNOIAN: THANK YOU.
DR. SKINNER: THANK YOU.
LET ME RESPOND TO A QUESTION THAT WAS RAISED OVER
HERE WHICH I DON'T THINK I ANSWERED ADEQUATELY.
WITH RESPECT TO THE BASIS OF CADMIUM LOADING
RESTRICTIONS THERE WAS A QUESTION AS TO WHAT MODEL WE
USED.
THE BASIS FOR THE CADMIUM LOADING RESTRICTIONS
COMES FROM A POLICY POSITION TO THE AGENCY AS ADOPTED
BASED UPON RECOMMENDATIONS FROM FDA THAT FUTURE
INCREASES TO THE DIET OF CADMIUM BE PREVENTED.
THE ACTUAL CADMIUM NUMBERS THAT WERE DERIVED
WERE BASED UPON A REVIEW OF DATA WHICH SHOWED FOR.
VARIOUS CROPS, VARIOUS SPECIES, LEAVES, LEAF VERSUS
CORN -- GRAIN -- WHAT THE INCREMENTS OF CADMIUM WOULD BE
BASED UPON;CONTROL OF THE PH, AND THE ACTUAL ANNUAL
CADMIUM APPLICATION RATE.
THE DATA IS VERY SCATTERED AND IT SHOWED THAT IN

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80
SOME CASES YOU ACTUALLY COULD -- YOU COULD EXCEED
THESE APPLICATION RATES AND NOT PRODUCE SIGNIFICANT
INCREASES, WHILE IN OTHER CASES APPLICATION RATES
EVEN BELOW THE RECOMMENDED RATES IN THE INCREASES
WERE SEVERALFOLD.
AND THAT FORMS THE BASIS FOR THE SECOND PART
OF THE CRITERIA WHICH ALLOWS A CASE-BY-CASE
DETERMINATION BASED UPON CROP MONITORING. THAT IS
THE POLICY THAT THE CRITERIA TRIED TO -- ARE BASED
UPON. THEY ARE NOT BASED UPON A MODELING OF THE
UPTAKE OF HUMANS AND THE INCREASE IN CADMIUM LEVELS
IN ANY PART OF THE BODY BASED UPON CERTAIN CONSUMPTION
LEVELS BUT BASED UPON POLICY POSITION THAT FDA HAS
ADOPTED THAT FUTURE INCREASES BE PREVENTED.
NEXT QUESTION, "PLEASE PROVIDE A COPY OF THE
SAN DIEGO HEARING TRANSCRIPT. IF THERE IS A CHARGE
PLEASE ADVISE."
THERE WILL BE A COPY AVAILABLE IN THE DOCKET,
AND I THINK WE CAN PROVIDE COPIES AVAILABLE AT A
CHARGE AND WE WILL GET BACK TO THIS PERSON AND MAKE
ARRANGEMENTS FOR THAT.
YES?
DR. COHEN: I HAVE A QUESTION.
HAS EPA ACTUALLY CONSIDERED THE PROHIBITION OF
CADMIUM IN CONSUMER AND INDUSTRIAL PRODUCTS?

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81
DR. SKINNER: I'M SORRY, I CANNOT HEAR THE
QUESTION. SPEAK LOUDER.
DR. COHEN: HAS THE ENVIRONMENTAL PROTECTION
AGENCY CONSIDERED PROHIBITING CADMIUM IN CONSUMER
AND INDUSTRIAL PRODUCTS, AND IF NOT, WHY NOT?
DR. SKINNER: WE DO NOT HAVE THE AUTHORITY TO
PROHIBIT CADMIUM IN INDUSTRIAL OR CONSUMER PRODUCTS.
WITH RESPECT TO CONSUMER FOOD PRODUCTS, THE
AUTHORITY THERE WOULD BE FDA'S AUTHORITY, AND I KNOW
THAT THEY HAVE EXPLORED THAT FOR A NUMBER OF YEARS.
BUT AT THIS POINT IN TIME HAVE NOT UNDERTAKEN DOING
THAT.
NOW, THE TOXIC SUBSTANCE ACT PROVIDES FOR
CONTROL OF THE USE AND THE MANUFACTURE AND THE
REGISTRATION OF VARIOUS INDUSTRIAL TOXIC CHEMICALS,
AND I THINK CADMIUM WILL BE CONSIDERED UNDER THE TOXIC
SUBSTANCE ACT.
I DON'T THINK THAT THAT WILL RESULT IN A
SPECIFIED LEVEL OF CADMIUM IN ANY PARTICULAR TYPE OF
PRODUCT, THOUGH.
ANY OTHER QUESTIONS?
OKAY, THANK YOU.

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STATEMENT OF THE
CALIFORNIA DEPARTMENT OF HEALTH
EPA HEARING ON MARCH 1, 1978
IN SAN DIEGO, ON EPA's
PROPOSED CRITERIA ON THE
ADDITION OF SEWAGE SLUDGE
TO SOIL THAT WILL PRODUCE
AN EDIBLE CROP
My name is Michael L. Klado. I am a registered civil engineer employed by
the California Department of Health, Public Health Division. It is my
responsibility to develop the Department of Health's proposed policy and/or
guidelines pertaining to the use of sewage sludge. I am presenting comments
today on behalf of the Department of Health. My comments are on the topic
of cadmium in sewage sludge that may be added to privately-owned agricultural
land or to soil which may become a home vegetable garden.
As we see it, the critical issue regarding the addition of sewage sludge to
privately-owned agricultural land 1s that representatives of the federal Food
and Drug Administration appear to be seriously concerned about possible increases
1n the amount of cadmium in the diet. FDA representatives have displayed their
concern by Indicating that FDA may establish maximum permissible cadmium concen-
trations In foods. If FDA takes actions adverse to the sale of foods which
violate an FDA standard on cadmium, a farmer whose soil 1s rich in cadmium that
is available for uptake by plants might have to restrict his plantings to:
(1)	species which transfer relatively little cadmium to the edible portion;
(2)	plants that do not produce food eaten by humans; or (3) plants not eaten
by an animal that produces a product eaten by humans. To our knowledge, FDA
has not indicated that it would exempt high cadmium produce from a standard
to facilitate the use of cadmium-rich waste 1n agriculture.
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EPA's proposed criteria, published in the Federal Register on February 6, 1978,
would allow agricultural soils to be made extraordinarily rich in cadmium
through the addition of cadmium-rich sewage sludge. It appears essential that
state and local agencies who regulate the use and disposal of wastes, and who
advise fanners, know whether compliance with the numerical criteria proposed
by EPA in the February 6, 1978 Federal Register will guarantee a farmer that
his crops will not violate an FDA standard.
It has been observed that solid organic matter in soil adsorbs cadmium and
thereby helps restrict the transfer of cadmium to the soil solution where
it might be taken up by plants. The addition of a substantial amount of
sewage sludge to a soil that has little organic matter to start with (like
many of the soils in the arid southwestern states) will cause a substantial
percentage increase in the amount of solid organic matter in such soil. A
substantial percentage increase in the amount of solid organic matter in the
soil may provide a substantial percentage increase in the amount of cadmium
which can be held in the soil without release to the soil solution.
After sludge applications are permanently ceased much of the solid organic
matter that was added to the soil by sludge applications will be lost due to
decomposition. Completion of decompositon could take more than 15 years in
upland soils.
An upland soil in an arid southwestern state that had little organic matter
before receiving sludge may again have little organic matter at the end of the
period of decomposition. It appears reasonable to question whether the amount
of cadmium taken up by plants from a sludge-treated, cadmium-rich soil that
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has little organic matter at the end of the period of decomposition might
differ substantially from the amount of cadmium taken up by plants in the
first few years after sludge is applied -- that is, when the soil is a
newly-created, cadmium-rich soil containing a substantial amount of organic
matter. We are not aware of any findings that assure that the adsorption
capacity or other function of matter that will remain in soils of arid
southwestern states at the end of the period of decomposition will be great
enough to prevent an increase 1n the availability of cadmium for uptake by
plants. Thus we question whether "worst case" situations have actually been
revealed in past experiments 1n which the crops that were analyzed were grown
soon (i.e., within a few years) after sludge was applied to soil.
EPA could greatly aid state and local agencies who contemplate the use of the
proposed criteria, by publishing the following information:
1.	cadmium concentrations in non-leafy crops and leafy crops that will
be avoided by compliance with the proposed criteria -- during a
multi-year period preceding the permanent ceasing of applications
of sludge;
2.	cadmium concentrations in non-leafy crops and leafy crops that w11l
be avoided by compliance with the proposed criteria — after applica-
tions of sludge have been permanently ceased and added sludge-borne
organic matter has been decomposed to the extent possible 1n the arid
southwestern states;
3.	statements on whether those cadmium concentrations in non-leafy crops
and leafy crops have been demonstrated to be avoidable by compliance
with the proposed criteria 1n long-term experiments that represent
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the full range of non-leafy crops and leafy crops for which a
California farmer may desire his soil to remain usable, and that
represent the range of conditions that will occur in the root
zone of a California farmer's soil when the farmer uses sludge and
otherwise manages his soil 1n a conventional manner;
4.	a description of the relationships between annual and cumulative
amounts of cadmium applied, and cadmium concentrations in crops,
that have been demonstrated to support the proposed criteria;
5.	a description of the combinations of crops and soil conditions
involved in experiments that demonstrated those relationships;
and
6.	statements on whether compliance with the proposed criteria will
suffice to avoid violation of standards FDA may be expected to set
on cadmium concentrations in non-leafy foods, and in leafy foods.
In the absence of assurances that compliance with the proposed criteria will
avoid the occurrence of specified cadmium contents in foods, it would appear
appropriate that a sewerage agency that wishes its sludge to be used in
agriculture has three reasonable alternative courses of action. The first
alternative 1s to undertake appropriate field experiments which represent
conditions that would occur in a farmer's soil after sludge is added, and
which Indicate cadmium concentrations 1n the greatest cadmium-accumulating
crops eaten by humans for which the fanner desires his soil to remain usable.
The second alternative is try to find a farmer who does not wish his land to
remain usable for production of food for which an FDA standard is apt to be
set (e.g., food eaten by humans). And a third alternative is to purchase
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agricultural land to avoid motivations to produce food for which FDA standards
are apt to be set.
It appears that experiments undertaken or cited to support the addition of
sludge to land not owned by a sewerage agency should be designed to represent
the range of conditions that would occur 1n the root zone : (1) when the farmer
uses sludge and otherwise manages his soil in a conventional manner; and (2)
after the fanner stops applying sludge and does not replenish the solid organic
matter which the sludge provided over and above that provided by crop residues
and other sources. Methods by which the latter situation can be represented,
or assumed to be represented, have shortcomings either with respect to practicality
or lack of verification. However they appear better than proceeding without
relevant data. Those methods include analyzing crops grown in sludge-treated
soM 15 to 25 years after sludge applications have been stopped. Another
method might be to simulate future chemical conditions by not adding sludge
but adding readily degradable organic compounds of cadmium and other chemical
substances as are 1n sludge.
State and local agencies would be aided by Information pertaining to conversion
of sludge-treated agricultural soil to residential lots where home vegetable
gardens might be established. We recommend that EPA publish estimates of
the amount of cadmium that would be 1n the diet of vegetarian and non-vegetarian
home gardeners who produce as much of their own food as is practical In soil
which was, until a time at least 15 years before the establishement of the
home garden, treated with sludge by a farmer who added as much cadmium as
allowed by the proposed EPA criteria, when the current pH level of the soil is:
(1) as high as might occur 1n a calcareous soil after treatment with sludge;
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(2) 6.5, the level cited in the proposed EPA criteria; and (3) a lower pH
which might occur in a formerly acidic soil where pH was raised to 6.5
during the period of sludge utilization.
We wish to note that we have reviewed a paper by EPA staff in Cincinnati,
entitled "An Appraisal of the Relative Health Risks Associated with Land
Application of Municipal Sludge", and find no adequate support therein for
the numerical criteria proposed in the Federal Register. We will shortly
submit to EPA and the public our appraisal of that paper, which is contained
in our technical bulletin entitled "Consideration of Chemical Substances in
Sewage Sludge Added to Soil that will Produce an Edible Crop: A Public
Health Perspective."
We have scheduled three full-day seminar-public forums in March to discuss
the topics covered by our bulletin and to hear the concerns of people who have
reviewed it, and of other members of the public. These meetings will be:
In Sacramento on Wednesday, March 22; in Berkeley on Tuesday, March 23; and in
Los Angeles on Friday, March 24. The purpose of these meetings is: (1) to
Involve the public as much as possible in decisions that will be made by the
Department of Health, which pertain to the use of sewage sludge; and (2) to
provide the public with technical information which they desire. We hope to
obtain participation by EPA personnel in these meetings to discuss technical
Issues, such as those 1 have mentioned today.
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STATEMENT OF CLARENCE E. KAUFMAN
SOLID WASTE PROGRAM MANAGER
COUNTY OF SAN DIEGO
THE COUNTY'S SOLID WASTE STAFF HAS CAREFULLY REVIEWED THE PROPOSED CLASSIFICATION
CRITERIA FOR SOLID WASTE DISPOSAL FACILITIES IN CONJUNCTION WITH OUR COUNTY HEALTH
DEPARTMENT, REGIONAL WATER QUALITY CONTROL BOARD, AND OTHER INTERESTED PARTIES.
OUR NORMAL PRACTICE IN REVIEWING PROPOSED REGULATIONS IS TO BE AS CRITICAL AS
POSSIBLE, AND ON THIS OCCASION, I THINK IT IS FAIR TO SAY OUR INTENT WAS TO BE
MORE CRITICAL THAN EVER. CERTAINLY, THESE REGULATIONS ARE VITALLY IMPORTANT TO
THE COUNTY, AND ANY OTHER AGENCY WHICH HAS RESPONSIBILITY FOR OPERATING OR REGU-
LATING LAND DISPOSAL OF SOLID WASTES.
TO OUR SURPRISE, WE FOUND VERY LITTLE TO CRITICIZE. I CAN ONLY CONGRATULATE THE
EPA STAFF FOR DEVELOPING SOLID WASTE FACILITY CRITERIA WHO) WILL EFFECTIVELY PRO-
TECT THE ENVIRONMENT FROM DEGRADATION BY SOLID WASTE DISPOSAL FACILITIES, AND YET
ALLOW RESPONSIBLE AGENCIES TO CONTINUE TO PROVIDE DISPOSAL SERVICE WITH A
REASONABLE AMOUNT OF REGULATION. YOUR PROPOSED CRITERIA HAVE BEEN WISELY DIRECTED
TOWARD A STANDARD OF PERFORMANCE TO BE ATTAINED, RATHER THAN ARBITRARY RESTRICTION'S
TO BE IMPOSED ON DISPOSAL FACILITY LOCATION, DESIGN, OPERATION, AND MAINTENANCE.
IT APPEARS THAT THE INTENT IS TO PLACE RESPONSIBILITY FOR THE ESTABLISHMENT AND
ENFORCEMENT OF DETAILED REGULATIONS AT THE STATE AND LOCAL LEVEL, WHICH WILL
CERTAINLY ENHANCE THEIR EFFECTIVENESS.
THESE CRITERIA WILL IMPACT SOLID WASTE DISPOSAL IN SAN DIEGO COUNTY IN SEVERAL
WAYS. FIRST, THE PROHIBITION 01: OPEN BURNING OF RESIDENTIAL WASTES WILL INCREASE
THE' AMOUNT OF SOLID WASTE TO BE DISPOSED IN THE MOUNTAIN AND DESERT REGIONS OF
THE COUNTY. LAST YEAR, 956 BURNING PERMITS WERE ISSUED TO- RESIDENTS OF THESE
AREAS AND AN UNKNOWN NUMBER OF ADDITIONAL RESIDENTS BURNED THEIR WASTES WITHOUT
HAVING OBTAINED A PERMIT. SINCE THE COUNTY PROVIDES A NUMBER OF BIN SITES AND
LANDFILLS IN THESE AREAS WITHOUT COST TO THE AREA RESIDENTS, THE INCREASE IN WASTE

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Pa^e 2
VOLUME WILL INCREASE THE COUNTY'S COST IN PROVIDING THIS SERVICE. THE AMOUNT OF
THIS INCREASE CANNOT BE ESTIMATED AT THIS TIME.
ALTHOUGH SAN DIEGO COUNTY HAS I'OR MANY YEARS OPERATED ITS SANITARY LANDFILLS IN
COMPLIANCE WITH ALL LAWS AND REGULATIONS, IT APPEARS THAT SOME ADDITIONAL EFEORT
WILL HAVE TO BE EXPENDED ON OUR PART IN PROVIDING SUFFICIENT MONITORING FOR
LEACHATE AND GAS MIGRATION TO PROVIDE ASSURANCE THAT THE STANDARDS SET FORTH IN
THE PROPOSED CRITERIA ARE MET. WE DO NOT EXPECT THIS EFFORT TO SIGNIFICANTLY
IMPACT OUR DISPOSAL OPERATIONS.
SOME SEWAGE SLUDGE IS PRESENTLY BEING DISPOSED OF IN THE COUNTY'S LANDFILLS, AND
THERE IS A STRONG LIKELIHOOD THAT THESE QUANTITIES WILL GREATLY INCREASE WITHIN
THE NEXT FEW YEARS, PARTICULARLY IF SECONDARY TREATMENT OF SEWAGE IS APPLIED.
ALTHOUGH THE COUNTY BELIEVES ITS EXISTING INDUSTRIAL WASTE CONTROL PROGRAM PRO-
VIDES EFFECTIVE CONTROL OVER QUANTITIES OF HEAVY METALS ENTERING THE SEWERAGE
SYSTEM, THE PROI'OSED PROGRAM WILL PROVIDE ADDED ASSURANCE THAT THE FOOD CHAIN IS
PROTECTED FROM HEAVY METAL INTRUSION. WE DO NOT HAVE ANY ESTIMATE OF THE ADDI-
TIONAL COSTS OF THIS PROGRAM AS YET.
IN SUMMARY, I WOULD LIKE TO EMPHASIZE THAT WE BELIEVE THE PROPOSED CRITERIA ARE
WORKABLE AND REASONABLE, AND WILL LEAD TO SUCCESSFUL IMPLEMENTATION OF THE MANDATE
OF PUBLIC LAW 94-580.

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Attendees: Public Hearing, March 1, 1978
Cecil Lue-Hing, D.Sc., P.E.
Director Research and Development
The Metropolitan Sanitary District
of Greater Chicago
100 East Erie Street
Chicago, Illinois 60611
Henry C. Hyde
Study Manager, San Francisco Bay Region
Wastewater Solids Study
Mosswood Park Building
3505 Broadway, Suite 815
Oakland, California 94611
Herb Iwahiro
California StateSolid Waste Mgmt. Bd.
Chief Div. of Planning and Implementation
1709 "11"th Street
Sacramento, California 95814
William A. Jones
Site Manager
Nuclear Engineering Company, Inc.
P.O. Box 578
Beatty, Nevada 89003
Joseph A. Kaminster
U.S. Navy
Sanitary Engineer
1220 Pacific Highway Code 114H
San Diego, California 92132
Clarence E, Kaufman
Solid Waste Program Manager
County of San Diego
5555 Overland Avenue
San Diego, California 92123
E.A. "Skip" Kazmarek
Coordinator, Chemical Substances
Georgia Pacific Corporation
900 S.W. Fifth Avenue
Portland, Oregon 97204
H. Clay Kellogg, Jr., President
Kellogg Supply Inc.
23934 S. Figueroa Street
Carson, California 90745
Micheal L. Kiado
California Department of Health
Senior Waste Management Engineer
714 "P" Street
Sacramento, CA 95814

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David Cohen
Office of Water Recycling (SWRCB)
Special Consultant
Post Office Box 100
Sacramento, California 95814
Thorn Coughlin
Met. Engineer
The Bunker Hill Company
P.O. Box 29
Kellogg, Idaho 83837
Bill Davis
Project Manager, LA/OMA Project
P.O. Box 4998
Whittier, California 90607
M-F. Debonis
EPA Region II
Chief, Solid Waste Branch
26 Federal Plaza
New York City, New York 10007
Raymond R. Edwards
Orange County EMA
Chief, Water Resources
P.O. Box 1078
Santa Ana, California 92702
Lawrence P. Gazda
Chief, Waste Management Branch
U.S. Environmental Protection Agency
I860 Lincoln Street
Denver, Colorado 80203
Dale Gruel
Hirsch & Company Consulting Engineers
7850 Mission Center Court Suite 101
San Diego, California 92108
j. Mark Helm
Marketing Applications Manager
BSP Division, Envirotech Corp.
One Davis Drive
Belmont, California 94002
Robert E. Van Heuit
Division Engineer, County Sanitation Districts of L.A. County
1955 Workman Mill Road
P.O. Box 4998
Whittier, California 90607

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R.D. Amber
EPA Region VI
904 Waste Management Rep.
1201 Elm Street
Dallas, Texas 75270
William E. Anderson
Chemist
Dow Chemical USA
P.O. Box 1398
Pittsburg, California 94565
Keith Amundson
5130 Patti Jo Drive
Carmichael, CA 95608
Glenn G. Baker
Project Officer
SCA Services, Inc.
Western Region
P.O. Box 967
311 F Street
Chula Vista, California 92012
David L. Bauer
Corporate Director of Environmental
Engineering Affairs
IT Corporation
4575 Pacheco Blvd.
Martinex, California 94553
John Beale
Manager, Environmental Information
Dow Chemical USA
2030 Dow Center
Midland, Michigan 48640
Richard A. Boettcher, P.E.
Technology Representative
Civil Engineering Laboratory, NCBC
Port Hueneme, California 93043
Jerry D. Boyle
CH2MHill
1200 3rd Avenue Suite 400
San Diego, California 92101
Robert Bulman
County of San Bernadino
Refuse Disposal Analyst
825 E. 3rd Street
San"Bernardino, California 92415

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J. Keith McCartney
Cousins Associates
152 South Pacific
Oceanside, California 92054
Hector H. Mendieta, P.E.
Texas Department of Health, Division
of Solid Waste Mgmt.
1100 W. "49"th Street
Austin, Texas 78756
Paul Mnoian
NU-WAY
Solid Fill Dump
14 5 W. Duarte Road
Monrovia, California
A.L. Page
University of California
professor
Riverside, California 92506
Charles H. Powell, Sc.D
PPG Industries, Inc.
One Gateway Center
Pittsburg, Pennsylvania 15222
Chris Robbins
Hirsch & Company
Environmental Analyst
7850 Mission Center Court
San Diego, California 92108
Robert Romaine
County (SD) Health Dept.
Assistant Sanitarian
Sanitation Division
County Building
William Schremp, P.E.
EPA Region III
Solid Waste Program
6th & Walnut Street
Philadelphia, Pennsylvania 19106
Micheal W. Selna
Los Angeles County Sanitation District
Supervising Civil Engineer
Post Office Box 4998
Whittier, California 90607
Barney Simonsen
Vice President
IR Corporation
336 W. Anaheim Street ,
Wilmington, California 90744

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Douglas L. Strauch, P.E. Chief
Enforcement Division
1709 "ll"th Street
Sacramento, California 95814
John Sudol
EPA
Environmental Engineer
215 Fermont
San Francisco, California 94105
Morris G. Tucker
U.S.E.P.A.
Chief, Waste Management Section
1235 Baltimore
Kansas City, Missouri 64108
Howard Wright
Environmental Specialist
State of California
2014 "T" Street
Sacramento, California 95814

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Region I
John F. Kennedy Bldg.
Boston. MA 02203
(617) 223-7210
Region II
26 Federal Plaza
New York. NY 10007
(212) 264-2515
Region III
6th & Walnut Sts.
Philadelphia, PA 19106
(215) 597-9814
Region IV
345 Courtland St., N.E
Atlanta, GA 30308
(404) 881-4727
Region V
230 South Dearborn St.
Chicago, IL 60604
(312) 353-2000
Region VI
1201 Elm St., First International Bldg.
Dallas. TX 75270
(214) 749-1962
Region VII
1735 Baltimore Ave
Kansas City. MO 64108
(816) 374-5493
Region VIII
1860 Lincoln St.
Denver, CO 80203
(303) 837-3895
Region IX
215 Fremont St
San Francisco, CA 94105
(415)556-2320
Region X
1200 6th Ave.
Seattle, WA 98101
(206) 442-5810
U.S. ENVIRONMENTAL PROTECTION AGENCY
Regional Offices
*.j. (View Y 0*k
Philadelphia
£U

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