Two, analysis and discussion

 

1The scientific question, ""

Environmental regulations need science and data support.503Regulations in quantitative terms appears to be doing very fine, very complete, for example, it has a maximum limit of sludge containing pollutants, have accumulated amount in unit hectares limits, there are limits on pollutants, and pollutants accumulated application limit. These tables can be completely shut sb. seemingly sludge of high concentration of pollutants, but also avoid the pollution and damage the long-term accumulation of low concentration in soil, but also can avoid too dense fertilizer may other problems. Most people reading will feel the standards set in "very strict".

In accordance with theEPAStatement.503Value standard are large-scale survey of America sewage treatment plant, to obtain complete, based on real data. Here said that the census1988National Census (sludgeNSSSSee the article, "what") pollutants in sewage sludge. But the census to census, even if the results of the analysis are extremely reliable, these data or to analyze and explain the. In fact, the problem may be out of here.

1988Census selected only208A sewage plant sampling, and the178Samples were analyzed by chemical analysis, in the United States16000A plurality of wastewater treatment plant (there were about11407Two level of sewage treatment plant), several specimens were detected only for the total1.1%. Representative sampling is a problem.

According to the1992The results of the census statistics published report (Statistical Support Documentation for the 40 CFR Part 503 - Final Standards for the Use or Disposal of Sewage Sludge), it is a hypothesis, namely the pollutant concentration distribution is lognormal distribution. The model considers multiple correction factor to calculate the coefficient of variation, including sewage plant type (with the average daily sewage treatment capacity is divided into4A, is divided into4A series of, respectively is: the total number of sewage plant11346Sewage treatment plant, the number of census208Remove the invalid number, effective process adjusted8497The census numbers, effective185A), target (disposal to disposal path into6A), formed a multi-level analysis system.

Mathematical statistics has been widely used in the economic life, such as the quality of industrial production in the sampling, is used in this method, the number of samples from a given batch of the products are qualified. But the pollutants in the sewage plant influent is changes with seasons, date, time, location, source, standard of living, the significant change of sludge have at different times of a sewage plant, the scope of quality differences between this and industrial products is probably very different. An industrial product tolerance if0.1%Within the considered qualified, more than the number of unqualified, the biggest difference between qualified and unqualified products on the tolerance value may not exceed1mm. And the concentration of pollutants in sewage sludge is different, the difference is in the hundreds and thousands of times, a million times also is completely possible. In this case, to make meaningful environmental standards, these data even if using the mathematical tools modified near perfect if there is significance?

 

2Why, Cr index from503Disappear?

In the1988 NSSSReports of the second listed in the annex to the volumeEPAThe attention at28Contaminant detection concentration values, among which is the heavy metal chromium. From the lowest (not detected6A), to the highest2320 mg/kg, Co197A, the arithmetic average value239mg/kg. Note, this is not the original testing data, but according to the method described previously modified.

1994Years503After the promulgation of,MilwaukeeA leather company, (Leather Industries of America, Inc) willEPAOn the court, reason isEPAInNSSSThe census will not have any receiving tannery sewage plant included, chromium content of the sewage in the general30000 ppmThe above, soEPAThe highest values recorded in chromium sludge3750mg/kgFar from representative. BecauseNSSSThe sampling is undeserved, cause this standard is too strict, so that the company could not land use of sludge.

The judge ruled thatEPADoNSSSStudy on the multiple interpretation is not clear, lack of representative sampling. Columbia Circuit Court of appeals that,503The formulation is notEPAThat have scientific basis,"EPAThe excessive protection 'mistakes', but not by pure chance". The final ruling is: "because of the lack of risk based on data support (chromium limit3000mg/kg), the court will rule this part of the backEPAModified or additional evaluation".

Anyone who will compare these values, will see the clue: chromium limit atNSSSInspection record for3750mg/kgThe statistical analysis, the highest2320mg/kgAfter correction, the arithmetic average of only239 mg/kgThe standard, in the3000mg/kgThe highest value, is close to the practical detection, this value and what is the relationship between the statistical results? No, in the1993Years503No explanation was promulgated in the file. The judge does not need the help of what mathematical tools, you knowEPASo-calledNSSSThe data support is kick up a cloud of dust ("a").

In the development of environmental standards, pollutant limit how much is appropriate, it should be determined by environmental toxicology. For example, the toxicity of chromium, a dog if from inhalation6.48 mg/kgPotassium dichromate(K₂Cr₂O₇)Can be fatal (Wu Yujing "common toxic chemicals emergency rescue manual" Zhongshan University press2006). To kill a weight20Kg dog, only need22.9mgSix chromium.503Regulations on1993First announced, this is10A heavy metal detection index, the chromium concentration limit3000 mg/kgWithout considering the cumulative concentration values. According to this limit, a kilo of sludge can theoretically be poisoned many dogs?

Want to come503Regulators are Americans, not too may not understand EnglishRemand(return, back) what's the meaning of this word. The judge was supposed toEPAGet back to modify, forward basis, they are, simply to chromium requirements completely removed. No wonder some people doubtEPAThis is on the slope next to a possible, remove the trouble of limited value index.

 

3The regulations, tailor

Standard as a threshold, threshold level, defined the spanning condition. If you do not meet this condition, must not cross over.

Standard also like a barrier dam, its role is to intercept, but if the discharge gate, then call diversion.

503Sludge disposal regulations is a barrier dam, but the name is trash, is actually a shunt. The different disposition is different gate. Gate size, determines the fate of pollutants. At the three gate (incineration, landfill, land application), land application, the most wide, the largest minimum gate.

It is the product of special historical circumstances. In the1972"Regulations" under the clean water act, the two level sewage treatment in the basic80In the late 1990s in place, the need to find a cheap disposal export. Marine dumping has go into a cul-de-sac, the high cost of incineration, landfill costs are rising, and there is the bottleneck of high water resources shortage, filling rate, only the land application is the most likely to solve the problem of export. So in the70In the late 1990sEPABegan to recommend the most inexpensive sewage disposal mode. However, size design on the gate, there was a fierce controversy.

In the1989Years of503To seek the views of edition, included in the21Carcinogenic pollutants and25Pathogenic bacteria.21Carcinogenic chemical pollutants, onlyAs,Be,Cd,Cr,NiFive kinds of heavy metals, the rest are organic pollutants, pollutant limit is according to the risk of environmental toxicology in the human intake dose to assess. For example, six chromium limit is41mg/kg.dFor one20For kg weight children, the daily intake of more than820MG is carcinogenic limit, the value of clinical data from epidemiological.

Draft of this standard has been widely criticized,EPAUnder pressure from all sides, a Tennessee Senator Gore oppressor, who became Clinton's vice president in three years, and immediately issued in the Office503Laws and regulations. The final version of the503Will limit the pollutants from the draft5Heavy metal,16Organic pollutants,25Species of bacteria, into the9Heavy metals and2Indicator bacteria.

As the New York environmental protection bureau directorSchultz 1989Years6Month5ByEPASaid the letter: "New York to the provisions in the draft standards for pollutants discharge, if not impossible, it will be very difficult, at least80%Sludge disposal still cannot find way out. Considering the economic and environmental importance to these regulations, could potentially use the huge amount of sludge, the cost and the shortage of landfill space, I advise you to devote the necessary resources, in accordance with the best technical information to modify the existing503......".

Standard why no organic pollutant limits? This,EPAThere is a saying. They say: all the major organic pollutants because of the following three reasons and were excluded:1The pollutants in America production);2)NSSSLack of the census found that the number of samples5%;3) pollutant concentration low enough that no more than the application of rate risk consideration.

1988 NSSSThe display of data, a large number of pollutants such as strong carcinogenicityPCB(PCBs) with high concentration is ubiquitous in the environment, and non degradable, cycle in the environment; the new pollutants are still being produced, were not be detected or recognized, after allEPAA small part of the detection content but potentially dangerous pollutants (see the "sludge" what pollutants), and the final destination and harmful cognition is limited. The presence of organic pollutants in such grim facts, he wasEPAIn two words or three so easily to a over.

Do Chinese people can understand simple analogy: if you need to make a strike, also set up three exclusion criteria:1Who has criminal record) in prison;2) on the632A city of6A random sampling investigation, crime type belongs to the rate of not more than5%The;3Crime is not serious) will not harm the social order; does this strike is ready for what?

EPAMathematical tool (set theory?) Application of really wonderful!

The actual situation asEPAA former senior officialsHugh KaufmanPointed out:1989The draft with the world's major developed countries such as Canada, Germany is similar, but the politicians argue that the standard will make the region cannot land application of sludge. ThereforeEPAIn the big city to do a survey, to determine the maximum pollutant these city sludge, and modify the limit value according to these results, so that all the city especially those problems such as the cityKnoxville, Nashville, New YorkCan pass......

       I see.

       If you don't know503There is also a1989Year edition, if not their own lookNSSSThe original data, if not chromium limit in enacting and be rather baffling to cancel, not this a chain of evidence, we can be on the503"Scientific" suspicious?!

 

4The magical effect of packaging, PR

Do product, must advertise. Can you hear the government to formulate policies also need advertising company?

503And behind a very key advertising company, is precisely the Public relations company, which is a first-class professional image design team. Discover this secret was the two journalist,1995They published a very interesting book, entitled "Toxic sludge is good for you Lies, damn lies and the public relations industry"(which can be translated into: toxic sludge on hi -- lies, lies and the public relations industry hundred-percent). This book503Sell sludge as a classic case and take the title, revealed for the first time USA PR industry a lot of secrets.

EPAPR report shows, they recommended sludge application on land policy process, long bear for sludge notoriety and very low public acceptance and big nerve racking. In order to solve the sludge problem,80In the late 1990sEPAFind the Water Environment Federation (Water Environment FederationAbbreviationWEF), a name that sounds like spring waterfall lies. In fact, this is a41000Members, millions of dollars budget Industry Association, predecessor was founded in1928Drainage Association years "("Federation of Sewage Works Associations),1950Years due to the high speed growth was renamed the "industrial waste drainage and industrial waste association".1960Years changed again a better listen to some name is "water pollution control federation".1977President of the UnionR.CanhamStill criticsEPAThe zeal of the land application of sludge, which he believes will lead to contamination of food chain, the result will be disastrous. But to the1990Years, the association of attitudes180Degree turn, a staunch supporter of land administration.

"If names be not correct, language is not in accordance with the truth of things.WEFConfucius theory of the rectification of names can be said to be a faithful believer. Carry on the fine tradition of decades incognito, they set up a committee, specifically for the sludge organized a prize zhengminghuodong. From the250Several design schemes, finally chose "biosolids" (BiosolidsThe name). A mysterious material and so on1991Summer was born.

After a few months, "Water Pollution Control Federation" to sign "pollution" removed, replaced by the term "environment". In the annual meeting, President of the League renamed the explanation says: we no longer control pollution, we must put an end to it.

How to eliminate the contamination? Rename.503Regulations for disposal on land administration did not destroy any kind of pollutants, and also there is no reduction, but the magic is, it is no longer a waste, but fertilizer.

All this is who plan? Is not God, is called aPowell TateThe blue chip Public relations company. It is good at high technology, safety and the environment relations, many of their customer base in the tobacco, pharmaceutical, electronic and aerospace industry predators.Jody PowellFormer president Carter's press secretary,Sheila TateFor President Bush and President Reagan's wife, Nancy served.

1992Years, known as the non-profit agenciesWEFFrom theEPAGet30Million dollars, "for land application of biosolids" publicity and public education. This is the only reported a pen.

Since then,EPAWillWEFTightly in the sludge tank on their own. In the past20Years, tens of millions of funds throughEPA,WEF,USDA(America Department of Agriculture) channel flows503Land use policy "escort" small fleet.

 

5, experts how to become Queen's scholars?

       In the case of California v. Kern County (see the "refused to sludge pollution rights -- a health and interests of legal battle"), California has hired an expert witness luxury group. Among them:

1.  Albert PageHonorary Professor, California University: soil, dr..1927Year of birth, engaged in Soil Science Research50Years, since the1975Years beginning to2000Years14Time andEPAProject cooperation, dedicated to the study of land application of sludge.1994Years as chairman of special committees America Academy of Sciences, presided over503Regulations of the peer review. Published monographs18Department, professional papers139Article, CO authored books29Department, review articles3Article, semi professional articles13Article, the professional cooperation seminar76Article, special technical report33Article.

2.  Charles GerbaProfessor: University of Arizona soil water environment science department, dr.. Published monographs11Department, professional papers322Article, CO authored books79Department, review articles131Article, semi professional articles27Article. Accept the project cost165Pen, involving a total of ten million dollars (too much, too lazy to statistics, interested to accumulate.)!

3.  Ian PepperProfessor: University of Arizona soil water environment science department, dr..1946Year of birth, engaged in research work in40Years. Published monographs7Department, professional papers139Article, CO authored books65Department. Accept the project cost63Pen, involving a total also has millions of dollars more (ibid.).

The three is the three big master USA sludge land application aspects. From the numbers of books, I'm afraid nobody can instead of "subject ability, take charge of course can not be, it can be estimated the global peer envy even Dutch act heart some.

But, writing and topic quantity, just let a person produce a question: why?

In American, a popular academic corruption is called"Sound ScienceThe surface ", means" scientific ", free translation is the" Queen's academic. ". It is the enterprise public relations department and government agency spokesman for a class of scientific research to protect their position, interests and provide proof of title.

In the previously mentionedAugustaIn the case, judge ruled against USA Ministry of agriculture, the main reason isMesserlySewage factory manufacturing false, forged sludge application record never existed and leakage. The case is a very key lies in, it is the understandingEPAHow to use the Royal scholars503Escort a "key".

AugustaThe two relates to pasture (in the case ofBoyce and McElmurrayApplication of sewage sludge are in the beginning)503Regulations promulgated before, so the problems earlier, this case death of large quantities of dairy cowsEPAIt belongs to the typical negative news.EPASet up a fire mechanism(Biosolids Incident Response Team, BIRT Biosolids incident response team)Their task was not, however, communication, understanding and victims of pollution causes and remedial measures, but to "expose and sludge horror story". In order not to get your hands dirty, they are looking forWEF.EPAGiveWEFFunds, allocated by the state, established the water environment research foundation (Water Environment Research Foundation WERF)Sponsored by the Queen's scholars to carry out targeted research "".

In theAugustaIn the case of,BIRTHeadBob BrobstFirst in the line of fire. He was1998Years11Commissioned by the University of Georgia (month and guideUGAA scientist ()Julia W. Gaskin) takeMesserlyFalse data of wastewater treatment plants forged as the basis, research report events completely unrelated to the death created a farm is not contaminated, sludge and farm cattle, the report in the2002The important research literature as the land application of sludge will not produce pollution was published, celebrities and common agencyEPAThe fire fighting team.

One of the hazards of pseudo scientific research's is that it takes up valuable resources, make the study of normal, serious squeezed, so the formation of the grass cover crops phenomenon. That is why the land application of sludge field USA particularly and especially why the concentration.

 

6Environmental safety assessment is operated, the

AugustaIn case there is a layer of meaning is more important, the Queen's academic approach to allow people to503The rule itself credibility of doubt.

1993Years,EPARequest (USA Academy of SciencesNational Academy of Sciences, NAS) Set up a committee of experts on503Evaluation of the environmental safety regulations. Have a look this assessment patron:EPAEnvironmental protection agency,USDAThe Ministry of agriculture,FDAThe food and drug administration,Bureau of ReclamationThe Bureau of reclamation,WERF(WEFThe foundation),AMSA (Association of Metropolitan Sewerage AgenciesCity Drainage Management Association), the National Food Processors Association, some city drainage department and private enterprises...... Almost all of the same colour, the related interest groups. Have a look again experts invited (mentioned earlier, hired expertsA. PageThe chairman Professor is the review committee), also know what it is.1996The Commission issued the assessment report (Use of Reclaimed Water and Sludge in Food Crop Production), damage to the risk, the spread of pathogens of organic pollutants are the lack of proven harm and disease records of the fact is, that503Regulations to implement low - risk conclusion.

2001Years to answer congressional produce harm to many facts lawsuit questioning about sludge,EPAPlease America academy review503Science based regulations. This timeNASThe report (Biosolids Applied to Land: Advancing Standards and Practices) in sludge pose a public health risk to give a more direct answer, this sentence has become one of the criteria for all cases must reference: "no documented evidence to prove503Failed to protect the public health laws and regulations". Even the most authoritative USA Academy of Sciences say so, what can you say?!

However, this time a review committee (Ellen HarrisonProfessor of Cornell University), in2004A congressional hearing on the facts revealed by years of this is a lie: in fact, the members of the jury have already received aD. Lewis And University of Georgia colleagues at1999Years to complete, has beenEPADetained until2002Years of published papers, this paper describes the resulting sludge carried pathogens Staphylococcus aureus and two people sick because of sepsis and pneumonia deaths 10 people infected surrounding residents how to spread through the air. Some of the content has been cited, but inNASThe final version, a Wisconsin Review Committee (coordinator of the state sludge disposal plan) insisted on this piece of literature references deleted requirements, because he thinksEPAShould not be criticized.

 

7Honest scientists, deprived of the right to

In the impression of people,EPAAuthority is USA aspects of environmental protection. It must have its own scientific research team, all the assessment should be done internally, to accept external inspection.

But should return should. Fact.EPAHas its own independent research and Evaluation Division (Office of Research & Development, ORD), but it is in503Formulation of regulations in blocked.

1992YearsEPASpecialized agencies responsible for the scientific basis of reviewing internal regulations of theORDTo do (waterOffice of Water, OWSubmitted)503Regulations for review, but the scientists concluded that: there is a huge gap between the scientific basis, can not guarantee that the public health and environmental safety. The conclusion that natural. YesORDReview questions,OWThis year will invest $two million for five consecutive years of research to fill the gap, but in fact, only a small amount of money into the independent.EPACommitted to the development of external resources, i.e.WEFClose cooperation, through a large number of extracorporeal circulation of funds, to support the construction of the "imperial scientists separate scientific basis".

ByEPAResearch on the application of safety of sludge land agent and negative conclusions of the report, in the503 Before and after the introduction of both, but because the conclusion is not suitable are secret and undisclosed. At present there are two known copies:1981Years of research University of Florida (heavy metals and pathogens of livestock health and food effect),1998 YearsOak Ridge National Research Laboratory (forest ecological system may be damaged).

For theAugustaCase andConnerCase made important contributionsDavid L. LewisIs a doctorEPAMicrobiology senior researchers.1999British famous "natural" magazine published his article, the article points out, the land of sludge could change the soil chemical properties, so that the risk of pesticides in agriculture to improve. The article causedEPAWater Office of leadership is not quick, hisAthensDirector of the laboratory for consentLewisFor the study Dr. was removed, after the appeal hearing was reinstated. She was immediately approved by theLewisDr. to a group of sludge and has high gold aureus infection carries a two-year epidemiological studies, research results confirm the relevance of sludge. Just then he as a free expert witness deposition in the Shane Connor case. So, he is with theSynagroForged liangzi.SynagroThroughEPASenior relationship began to purge the scientist, and in2003At the end of the year to put him out of theEPAAt the same time, also made him toUGAHe hopes.

EPA Around503Regulatory initiatives have become a very strange phenomenon: the internal research unitORDThe review is invalid; spend a huge amount of publicly funded research results were secretly dispose of; researchers have scientific conscience, dare to speak the truth to be fired;...... Look, this is a bright halo symbol of the environment, has in fact become a loyal advocate some interest groups. This can not be said to be the global environmental community of sorrow.

 

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