Ft Worth Sewage Sludge Program

The purpose of this paper is to show how subtle wording can be to promote sewage sludge. The average farmer or citizen would be influenced by the way Ft Worth Sewage Industry tells the story. We will attempt to give you a choice so you can decide. Also most of Ft Worth references are from 1996. Others from 2003. The data on this web site averages 2009 and up.

“The Village Creek Water Reclamation Facility discharges treated effluent into the West Fork of the Trinity River, a sensitive stream that during dry months may be composed of up to 95 percent treated effluent. Village Creek was built in 1958 to serve East Fort Worth. The original treatment capacity then was 5 million gallons per day (mgd). Today,

Village Creek has a capacity of treating 166 mgd and it serves more than 20 other surrounding communities in addition to the more than 700,000 Fort Worth residents. The plant is owned and operated by the City of Fort Worth Water Department. Its service area includes most of Tarrant County and parts of Johnson County.

The treated wastewater from Village Creek is environmentally converted safely(1.) and beneficially land applied at numerous sites around North Texas. (2.) Both, the treated effluent and biosolids are regulated under a permit issued by the Texas Commission of Environmental Quality (TCEQ). The Texas Pollutant Discharge Elimination System (TPDES) permit contains effluent limits as well as reporting, record keeping, monitoring, testing, and pretreatment requirements. The TCEQ web site has more information on the TPDES program”

(1.) How would Ft Worth know if their BS was "safely and beneficially" land applied since Renda is doing top applications and processing the sewage sludge?

(2.) Ft Worth will not look at current research data. They hide behind 1970 research done by the EPA. Namely, part 503. They will not consider the 2009 TNSSS or U.S. Office of Inspector General reports :14-P-0363: / More Action Is Needed to Protect Water Resources from Unmonitored Hazardous Chemicals”/ More Action Is Needed to Protect Water Resources from Unmonitored Hazardous Chemicals” or 19-P-0363:/ “EPA Unable to Assess the Impact of Hundreds of Unregulated Pollutants in Land-Applied Biosolids on Human Health and the Environment” or 19-N-0115 4-8-2019 / While conducting the Audit of the Impact of Toxic Release Inventory (TRI) Late Reporters on the EPA’s Annual TRI National Analysis (Project No. OA&E-FY18-0002), the U.S. Environmental Protection Agency’s (EPA’s) Office of Inspector General (OIG) decided to issue an immediate management alert informing the agency of our discovery that its TRI data pertaining to releases of hazardous substances from Publicly Owned Treatment Works (POTW) are inaccurate. As a result, the public is not receiving complete and timely information about environmental conditions affecting human health."

The current 503 came about because of pressure from US Congress, the sewage industries, municipalities who wanted to continue to have a cheap way of getting rid of sludge after they could no longer dump in the ocean. The first draft of 503 was much stricter, actually with stricter rules for land that would be used for growing produce and it also required testing for a number of toxic chemicals (besides metals).

But the sewage industry screamed in protest claiming that if these more protective rules became law, it would end the land application of biosolids and then what would cities do? So EPA changed the draft which resulted in the current 503. Go figure. This has turned farmer that use it into laterally suckers for the sewage industry. Their farms are permanently contaminated by thousands of hazardous and acute hazardous chemicals.

Next we would like to address data on the brochure labeled “Ft Worth BS Marketing” Again BS = Bio-Solids.

“CITY OF FORT WORTH QUICK FACTS

Fort Worth’s goal is to beneficially land apply 100% of all Biosolids. (3.)

Biosolids facility is operated by Renda Environmental Inc., in a public/private partnership. (4.)

“The City of Fort Worth’s biosolids program received EMS (Environmental Management System) certification through the National Biosolids Partnership on July 20, 2005; making it the first program in Texas to be awarded this certification.“(5.)

At typical biosolids application rates (7 dry tons/acre), each acre of land receives 120lbs of plant available nitrogen, 70lbs of plant available phosphorus, and 20lbs of plant available potassium.” (6.)

(3.) Currently there is no protection for citizen exposure to millions of tons of sewage sludge coming from Ft Worth. Adjacent Counties are literally at the mercy of the metro areas. There is no consideration for putting this toxic waste next to populated areas even when Texas has thousands of square miles of land no where near populated areas.

(4.) Renda has a reputation. I would recommend searches on OSHA and Google.

(5.) EMS is the same old tired cry from the EPA who never finished research on sewage sludge and the millions of possibilities. Sewage Sludge has considerable Risk. The largest being the human involvement and money.

(6.) In order for these values to be valid, we would have to believe Renda’s accounting. Again, human and money.

“Biosolids produced at the Village Creek Water Reclamation Facility are processed, monitored, and agronomically land applied to thousands of acres of farmland and pastureland in Tarrant and six surrounding counties in the North Texas area.” (7.)

(7.) Biosolids are NOT produces at the Village Creek Facility. They are produced several hundred yards away at the Renda facility. Renda is a third party contractor. Do a search in OSHA on Renda. Check out the monitoring schedule in the marketing piece attached to this page.

“By City contract, the Contractor uses an independent certified laboratory to analyze the biosolids produced at Village Creek Water Reclamation Facility”. (8.)

The contractor is Renda. Notice how Ft Worth does not disclose the laboratory.

“Samples of biosolids are taken from the process areas and analyzed for fecal coli-form, pathogens, metals, PCBs, pH , and percent solids.” (9.)

(9)From this statement it looks like everything is AOKAY. But what the citizen and farmers do not know is what they are actually testing for. The EPA only requires testing on “fecal-coli-form” and one strain of 2000 of salmonella. Ft Worth use of the word “pathogens” is nebulous since “pathogens” is a general term for diseases. It makes the reader think they are testing more than they are. TWO out of hundreds are tested.

The EPA only requires testing on these heavy metals: arsenic, cadmium, copper, lead, chromium 6, mercury, molybdenum, nickel, selenium and zinc. ALL are cancer causing. Thousands of other chemical contaminate are ignored. (See the TNSSS on this webpage)

PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until their manufacture was banned in 1979. “pH” is increase with lime but once the sewage sludge hit the ground the pH starts to decrease causing regeneration of bacteria and pathogens.

“Since 1991, the City of Fort Worth has produced Class “A” Exceptional Quality biosolids. Until 2015 when they were downgrade to Class AB which they lie on their web page stating: "The final product is Environmental Protection Agency (EPA) Class A Exceptional Quality (EQ) Biosolids, also known as TCEQ Class AB Biosolids." Texas has Class A , class AB and class B. there is no such this as Class A EQ that is also Class AB. This is a bald face lie and fraud.

This is the highest quality recognized by The Environmental Protection Agency.” (10.)

(10.) “Biosolids”, “Class A”, Exceptional Quality” and “highest quality” are all marketing ploys created by the sewage industry to fool the public into thinking sewage sludge is safe. Sewage Sludge is not safe and no one can prove that it is. How can concentrated pollution be anything but a risk to heath and environment?

“It has been estimated that biosolids within 95% of the ceiling limits (EPA requirement) would need to be applied to an area for 75 years before the soil concentration of those elements increased to a level of concern National Research Council. 1996.” (11.)

(11.) “Estimate?” Since those estimates were made in the 70s and sewage sludge is constantly changing how can responsible public servants, including the EPA, continue to take this stance without checking land that have been dumped on for the last 15 to 20 years? Irresponsible! What about run off into lakes?

"In one study, cattle were fed a diet consisting of 12 percent biosolids material for 94 days and showed no adverse effects. Another study fed cattle a diet of 6 percent biosolids material for 141 days and again no adverse effects were observed. National Research Council 1996" (12.)

(12.) (See link call Cattle Foraging) this page. Just imagine cattle forging for 4 to 8 years on top applied sewage sludge. 94 days is laughable. Cattle pick up 6 to 8 ounces of top soil a day while forging. The contaminate DO find pathways into organs and muscle

“A multi-year study of people living near biosolids application sites was conducted. This study showed no significant differences in the health of the people near bio-solids application versus people not near biosolids application. The same held true for their domestic animals. National Research Council. 1996” (13.)

(13.) “Multi-year study” Could Ft Worth be more vague? The EPA’s study on effects and risk near sewage sludge top applied was done on a 25 year old in good health. I have seen and experienced the effects of top applied sewage sludge and it DOES cause respiratory irritation and in a lot of cases vomiting. The long term effects have never been study but with the diseases coming over the boarder today, antibiotic resistant bacteria like Staphylococcus aureus, Ebola hemorrhagic fever and a nasty little bug called prion it is coming to a head.

“In biosolids amended fields the concentration of trace elements in crops does not increase” 2003. On-Farm Assessment of Biosolids Effects on Soil and Crop Tissue Quality. Journal of Environmental Quality. (14.)

(14.) This would be our favorite. How would Ft Worth know it does not increase since they have never done any studies? Any body reading this might be fooled. Take Lead or Chromium 6 and tell me when you apply it over and over to a field it does not concentrate? Has anyone ever noticed where money is involved common sense is out the door? What about all the thousands of trace elements that have never been tested?

Water Conservation

Our product contains approximately 20% solids material which means the other 80% is water. This acts to reduce the irrigation needs in the hot Texas summers month”. (15.)

(15.) Take a look at picture provided on the right. See for yourself what 20% solids 80% liquids look like according to Ft Worth.

“When properly applied, biosolids pose almost no risk to groundwater or surface water. National Research Council. 1996” (16.)

(16.) Who makes sure they are properly applied? “Almost no risk” Arlington reports pharmaceuticals in their tap water. Ft Worth will not release their studies on tap water. There is a picture of dead fish in a pond where run off of sewage sludge killed them all. Common sense.

“SOIL STABILITY

Biosolids add organic material to the soil, which help bind soil particles into aggregates which in turn increase the pore space of the soil. One study observed an increase of aggregates of almost one-third. National Research Council. 1996” (17.)

(17.) At the same time lime, which is used to change the ph and kill pathogen, leaches into the ground repelling water and turns the soil hard. Go Figure.

“The increase in aggregate formation acts to reduce the erosion potential of the soil. Biosolids Decomposition after Surface Applications in West Texas. 2003. Journal of Environmental Quality” (18)

(18.) Everyone needs to look up “Aggregate formations” in soil.

“Aggregate stability also increases with the addition of biosolids. An-other study showed this increase to be approximately 24 percent. National Research Council. 1996

CROP PRODCUTION

Biosolids contain inorganic forms of nitrogen which are immediately available to crops. The organic component must undergo mineralization to become available. National Research Council. 1996

Crops in fields supplemented with biosolids tend to have an increased leaf biomass.

Biosolids contain many trace elements, essential for plant growth. National Research Council. 1996

Due to the slow release component of biosolids, beneficial effects are seen up to three years after application.” (19)

(19.) All outdated rhetoric.

Press Middle of Picture

To Zoom

Ft Worth and Renda are Partners in BS

To Keep Ft Worth Beautiful and Complain about them dumping Toxic Sewage Sludge on your County call 817-392-4965 or send the City Manager an email at david.cooke@fortworthtexas.gov

Mayor Price at Betsy.Price@fortworthtexas.gov

Cooke

Price

bio-solids (BS)

FT Worth putting bio sludge out during a rain even breaking Texas Administration Code Regulations

my business copyright 2000 no animals were harmed in the making

Ft Worth Mayor Price