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Shellfish Restriction Correspondence
See www.VaBayBlues.org for more information
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11/8/2001 letter to Shellfish Division, VA Dept. of Health
Dr. Lynton S. Land
125 Airstrip Lane
PO Box 539
Ophelia, Virginia 22530
Dr. Robert Croonenberghs
VDH, Shellfish Sanitation Division
1500 E. Main St.
Richmond VA 23219
Dear Dr. Croonenberghs:
I am writing this letter requesting a response to what I perceive as a major inconsistency within the Virginia Department of Health.
As a retired scientist and an oyster gardener, I have investigated the reasons and methodology behind the shellfish restrictions on the Little Wicomico River, where I live. The White Stone office has been most cooperative, and I have been impressed with their efficiency and their concern. I understand the reasons for the extremely strict standards, namely 14 MPN/100 ml. I have tried to explain to local watermen why their oyster grounds are restricted on the basis of very few high bacterial analyses (due to a flock of birds just prior to sampling?) within the 30 month sampling interval. I applaud VDH’s efforts to utilize emerging DNA technology to identify the source(s) of the bacteria. It is my understanding that wildlife is the most likely vector, especially raccoons and birds.
The inconsistency exists because VDH continues to permit the land application of sewage sludge in counties where oysters are harvested. EPA requires that Class B sludge contains less than two million CFU per gram of dry solids. It is my understanding that VDH does not analyze the sludge, but simply accepts the contractor/ wastewater facility analyses. EPA actually relaxed their 1993 rules in 1999 in several ways with regard to the levels of bacteria in sludge, and with respect to the timing and method of analysis and certification. Irrespective of the actual, and unknown, levels of bacteria in the sludge spread on our land, I am certain you will agree with me that it is immense. At 2 million CFU/gram a 20 ton truck would contain in excess of a trillion CFU. There is absolutely no doubt that the land application of Class B sludge imports huge numbers of pathogens to our soils. That is an uncontestable fact.
The issue, of course, is whether or not the pathogens from sludge enter our waterways. I submit that we can be absolutely certain that some pathogens from the sludge do enter our waterways and contribute to shellfish restrictions. There are many vectors. If the sludge is properly incorporated into the soil by plowing, it is likely that runoff and erosion by wind will be minimal. Likewise, if the 100 foot standoff is enforced, it is likely that most bacteria which might enter the groundwater will die before the groundwater can enter the waterways. Even if the probability of contamination by these processes is low, the certainty of contamination is high because of the huge numbers of microbes involved and the vagaries of the weather. But more important, the very same vectors thought to be responsible for the naturally high bacterial levels observed in the headwaters of all our waterways ASSURE that contamination of our waterways by bacteria from sludge will take place. Every farmer knows “birds follow the plow.” In this county the birds are often gulls.
The Division of Shellfish Sanitation works hard to protect the public health from bacterial infection. Another branch of the same agency knowingly permits huge numbers of bacteria to be imported into the county and disseminated in a manner that virtually assures increased contamination of some of our waterways. Restricted oyster grounds prevent oystermen from pursuing their chosen profession. Farmers, on the other hand, can always buy fertilizer and continue to pursue their livelihood. I look forward to your explanation for this inconsistency, as well as to responses from other responsible officials.
Yours sincerely,-
Dr. Lynton S. Land
Email: JandL@rivnet.net
(804) 453-6605
cc: Health Commissioner, VDH; White Stone Office, VDH; Gov. Gilmore; Del. Pollard; Sen. Chichester; Northumberland County Board of Supervisors; Doug Jenkins; Lake Cowart; Calvin Keyser.
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11/15/2001 Response from VDH
Department of Health
P. O. Box 2448
Richmond, VA 23218
November 15, 2001
Dr. Lynton S. Land
125 Airstrip Lane
PO Box 539
Ophelia, Virginia 22530
Dear Dr. Land,
Thank you for your letter of November 8, 2001 concerning the application of biosolids to fields on the watershed of shellfish growing areas. I appreciate your concern for the protection of shellfish growing areas, and certainly thank you for indicating how hard our Division works to protect those waters.
If I may paraphrase your words, you indicate that the Department is being inconsistent by working to protect shellfish waters on the one hand, yet is allowing the application of biosolids to the upland watershed of those shellfish growing areas. Furthermore, you indicate that contamination of those growing waters will inevitably occur due to weather-related runoff from the land.
I believe that the answer to your question lies not in an explanation of the care both Departmental programs take concerning their separate responsibilities in the matter, but rather why both programs exist. The tone of your letter supports the shellfish program, which allows shellfish to be sold in interstate commerce. You however contest the justification for the land application of biosolids.
Simply put, the Code of Virginia, § 32.1 164.5, requires the Department to develop regulations that allow the land application of biosolids. Until the General Assembly changes the law, the Department will do all it can to minimize any adverse impact due to biosolids. While some people see the land application of biosolids as an environmental degradation, others see it as a means to improve soil tilth and recycle a waste product. Clearly, resolution of these conflicting interests is best decided by the General Assembly.
Thank you for the opportunity to comment on this issue.
Sincerely,
Robert E. Croonenberghs, PhD, Director
Division of Shellfish Sanitation
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11/2001 Letter to Acting Commissioner, VDH
125 Airstrip Lane
P. O. Box 539
Ophelia VA 22530
November 27, 2001
Dr. Robert Stroube, Acting Commissioner, VDH
P. O. Box 2448
Richmond VA 23218
Dear Dr. Stroube:
I thank Dr. Croonenberghs, by copy of this letter, for his rapid response of November 15 to my letter of November 8 regarding the conflict of policy within VDH that I identified. I am now responding directly to you because it is clear that the Division of Shellfish Sanitation is not where the problem lies. On one hand, the Division of Shellfish within VDH works hard to analyze our tidal waterways for bacterial contamin-ation so as to permit the safe harvesting of oysters. On the other hand, VDH also permits trillions of the same bacteria to be imported into the county in each truck load of sewage sludge which is land applied to our fields. Restricted waters impose economic hardship on some oyster-men and on some citizens who lease state waters. The land application of sludge provides a saving of only about $15.00/acre/year, as one farmer testified at a VDH public hearing on April, 2002, in Heathsville. This small economic benefit is only realized by the small minority of farmers who choose to request permits to use sludge. For your convenience I enclose a copy of my original letter and Dr. Croonenberghs’ reply.
Dr. Croonenberghs did not contest my assertion that bacteria from land-applied sludge are a source of contamination of our waterways. Thus I am glad we have at least taken a positive first step. I do, however, object to his statement that I claim solely that “…contamination of those growing waters will inevitably occur due to weather-related runoff from the land.” Apparently I did not make myself sufficiently clear. I believe the primary source of contamination is exactly the same one thought to be responsible for natural contamination, namely wildlife, especially birds. “Birds follow the plow”, as every farmer knows. As the sludge is tilled into the land, according to our county ordinance, birds, especially gulls, forage in the field. In coastal plain counties such as ours, waterways are never far from fields, which can hardly be classified as “upland” in any formal geographic sense. Because of the immense numbers of bacteria involved, it is inevitable that wildlife will transport bacteria to our waterways and contaminate them. This is not to say, of course, that runoff and/or wind might not also be vectors under some weather conditions.
Dr. Croonenberghs stated “….the Code of Virginia, § 32.1 164.5, requires the Department to develop regulations that allow the land application of biosolids.” I believe his reading of the Code is incorrect. The Code of Virginia states, in part: “B. The Board of Health, with the assistance of the Departments of Environmental Quality and conservation and Recreation, shall promulgate regulations to ensure that……(ii) land application, marketing and distribution of sewage sludge is performed in a manner that will protect public health and the environment, and (iii) the escape, flow or discharge of sewage sludge into state waters, in a manner that would cause pollution of state waters, as those are defined in § 62.1-44.3, will be prevented.” Nothing in the Code directs VDH to “…develop regulations that allow the land application…” Quite to the contrary, the Code demands that VDH “…promulgate regulations to ensure…” that land application protects the public and the environment. Once it is admitted that wildlife vectors do, in fact, permit “escape” of bacteria from the land application of sewage sludge, contributing to “pollution of state waters”, then VDH is clearly in violation of the Code of Virginia for failing to deny permits for land application in tidewater counties. The local land application of sewage sludge certainly contributes to shellfish restrictions intended to protect the “public health and the environment”.
The fact that VDH appears to be in violation of the Code of Virginia, at least as I read the intent of the Code, must to be resolved by VDH, by the General Assembly, by the new Governor, or by the Courts. I look forward to a continued dialog on this issue, from you or from any other responsible official(s), so as to resolve the problem in the best interest of all citizens of tidewater counties and any citizen of the State concerned about the health of the Chesapeake Bay and the oyster fishery.
Yours sincerely,
Dr. Lynton S. Land
Email: JandL@rivnet.net
(804) 453-6605
cc: Dr. Croonenberghs, VDH; White Stone Office, VDH; DCR; DEQ; EPA; NAS’ Gov. Gilmore; Gov. elect Warner, Del. Pollard; Sen. Chichester; Rep. Davis; Northumberland County Board of Supervisors; Doug Jenkins; Lake Cowart; Calvin Keyser, Billy Dawson, E. E. Delano.
12/21/2001 Letter from VDH
Department of Health
P. O. Box 2448
Richmond, VA 23218
December 21, 2001
Dr. Lynton S. Land
125 Airstrip Lane
Post Office Box 539
Ophelia, Virginia 22530
Dear Dr. Land:
Thank you for your letter of November 28, 2001, concerning biosolids use in Northumberland County and possible effects of land application of biosolids on the quality of shellfish harvesting waters.
As a result of over 30 years of research and field data, the land application of biosolids has been demonstrated to be safe and beneficial, and there have been no documented cases of biosolids causing illness when land applied according to the Biosolids Use Regulations (12 VAC 5-585) (Regulations). There are numerous checks and balances within the regulatory system that ensure that the producers of the biosolids and the applier of the biosolids comply with requirements designed to protect human health. The application of biosolids to agricultural land is widely practiced across the United States and has had a successful history in Virginia since 1980. No information has been reported in the literature that indicates that birds contribute to water pollution through transport of biosolids. Further, our staff has not observed any significant bird activity on land application sites either during or following these operations that could result in damage to adjacent water quality.
The land application of biosolids is performed in accordance with the standards published in the Regulations that are designed to protect human health. These Regulations mandate treatment methods to reduce pathogens in biosolids and specify the conditions under which these biosolids can be used as a soil amendment. Biosolids are treated in accordance with federal and state requirements to both reduce the level of disease causing, or pathogenic, microorganisms present in the organic matter and to reduce the vector, or insect, attraction potential of the material applied to land. The Federal Regulations were based on risk assessment methods that included conservative measures to protect public health. The State's regulation is even more restrictive than the EPA 503 Rule for the use of biosolids. Advisory Committees are now developing additional recommendations for possible revisions to the Regulations designed to address many of the concerns expressed about the permitted land application of biosolids. In addition, regulations are being developed to provide for biosolids fees, to be collected and used by VDH, to reimburse local governments for monitoring of land application operations as specified in an adopted ordinance.
Data collected by the producer or generator verifies that the level of the indicator microorganism, Fecal Coliform bacteria, in biosolids land applied in Virginia, is an order of magnitude less than the maximum allowable for Class B pathogen control. This data is submitted regularly to the permitting Federal and State agencies under penalty of law, including imprisonment, for falsifying such data. Previous studies on sewage characteristics indicate that the actual number of pathogenic microorganisms in such wastewater is a fraction of the measured Fecal Coliform levels. Additional studies on the microorganism content of treated sewage sludge indicate that a similar relationship exists for pathogens in biosolids. The minimum setback or buffer distances specified in the Regulations have been established from such studies of biosolids characteristics. Organic materials associated with biosolids have not demonstrated significant movement from soils due to precipitation, especially when incorporated into the soil. In addition, Best Management Practices (BMP) designed to minimize runoff are required for biosolids surface applied onto grassland or hay fields. The Regulations require that a 50-foot buffer distance be maintained from waterways if biosolids are surface applied and, if incorporated, the distance can be reduced to 35 feet.
Biosolids contractors are regulated through site-specific permits issued through the Regulations to protect public health and the environment. The requirements established in biosolids permits have been designed to minimize the risks to public health associated with the pollutants monitored in biosolids including pathogenic microorganisms. These requirements, including verification of biosolids quality and site specific land application management practices, provide a high degree of environmental and health protection and satisfy the requirements specified in section 32.1- 164.5 of the Code of Virginia.
The Regulations specify the requirements for obtaining a permit to land apply biosolids. If a permit applicant complies with the stated requirements, VDH must have verified scientific information of a specific risk to public health that would support the denial of a requested permit. A search of the National Library of Medicine's comprehensive Medicine database revealed no scientific article claiming that sewage sludge has caused disease. Upon completion of required notification and comment time periods, permit applications could be found complete and a permit issued. Should there be any confirmed reason to believe that the land application of biosolids is unsafe, we would immediately take actions to terminate the program.
Should you desire further information, please contact C. M. Sawyer, Director, Division of Wastewater Engineering, VDH, 1500 East Main Street, Room lO9, Richmond, Virginia 23219 by telephone at (804) 786-1755, FAX: (804) 786-5567, or e-mail:
csawyer@vdh.state.va.us.-
Sincerely,
Robert B. Stroube, M.D., M.P.H.
Acting State Health Commissioner
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2/28/2002 Letter to Dr. Robert Stroube, Acting Commissioner, VDH
125 Airstrip Lane
P. O. Box 539
Ophelia VA 22530
February 28, 2002
Dr. Robert Stroube, Acting Commissioner, VDH
P. O. Box 2448
Richmond VA 23218
Dear Dr. Stroube:
The Code of Virginia states, in part: “B. The Board of Health …….shall promulgate regulations to ensure that …… (iii) the escape …… of sewage sludge into state waters …… will be prevented.” (my emphasis). I submit that gulls foraging on fields to which sewage sludge has been applied guarantee the escape of bacteria and increase the natural bacterial pollution of state waters. Not only are tidewaters restricted for the harvesting of shellfish as a result of high levels of bacteria, but the waters are also formally designated as “impaired” under the Clean Water Act.
Your two page response of December 21 deals with this specific issue in exactly two sentences. You stated “No information has been reported in the literature that indicates that birds contribute to water pollution through transport of biosolids.” There is absolutely no doubt that birds contribute to bacterial pollution of waterways. The article entitled “Coliform Contamination of a Coastal Embayment: Sources and Transport Pathways (Env. Sci. Tech. 1996, v. 30, p. 1872-1881) clearly documents water birds as causing at least 2/3 of the contamination in that Massachusetts Bay, where direct defecation in the water was the cause. There is, in fact, a very large scientific literature on contamination of water by various kinds of birds, especially for Salmonella and Campylobacter (e.g. “Study of the bacterial content of Ring-bill gull droppings….” 2000 Wat. Res. v. 34, p. 1089-1096). Gulls are known to feed at sewage outfalls and contaminate nearby waterways (e.g. “Abundance, Diet and Salmonella contamination of gulls feeding at sewage outfalls” 2000 Wat. Res. v. 34, p. 2653-2660). I seriously doubt that you, or any microbiologist, would dispute, in a court of law, the premise that birds which land in the water contaminate that water after foraging in fields in which trillions of bacteria per truckload had recently been spread. Gulls are known to be highly resourceful and aggressive opportunistic omnivores, and several states such as Massachusetts and New Jersey have gull control programs which attempt to reduce the transmission of disease from landfills.
You also stated “Further, our staff has not observed any significant bird activity on land application sites either during or following these operations that could result in damage to adjacent water quality.” At several VDH meetings in Heathsville, Ms. D. Lopasic led us to believe that because VDH has only two inspectors for the entire state, most of the actual spreading operations are not monitored. If this is incorrect, please correct this misimpression, and tell me what percentage of the actual spreading is directly observed by VDH, and how often follow-up observations are made. As far as birds are concerned, they are such a natural part of the landscape, and so unremarkable on recently tilled fields, as to be hardly worthy of note. At a hearing in Heathsville on Feb. 14, a representative of Milton F. Wright Trucking, Inc. contradicted your statement about bird activity before the Board of Supervisors in response to a direct question. You may rest assured that quantitative observations are easily made to confirm or refute your assertion that bird activity is insignificant after sludge has been spread in tidewater Virginia.
The solution to this problem is both simple and obvious. There are very few counties in Virginia where the Shellfish Division imposes harvesting restrictions and where permits for the land application of sewage sludge are granted. If VDH continues to approve permits in those counties, now that this problem has been articulated, then VDH is clearly in conscious violation of both the Code of Virginia and the Clean Water Act, in my opinion.
I would appreciate your response to two direct questions, which apply specifically to Northumberland County:
1) Do you concur with the current scientific consensus that water birds are an important natural vector of bacterial contamination of impaired waterways, and
2) Do you concur that there is a near-certain likelihood that gulls foraging in fields to which sewage sludge has recently been applied (say within 30 days) will further contaminate waterways on which they land by both the direct transport of bacteria and in their feces?
I look forward to an official response from the senior administrator of VDH to these two specific questions and to this specific issue.
Yours sincerely,
Dr. Lynton S. Land
cc: Dr. Croonenberghs, VDH; DCR#; DEQ#; EPA#; NAS#; Gov. Warner#; Del. Pollard; Sen. Chichester; Sen. Bolling#; Rep. Davis; Sec. Murphy#; Sec. Woods#; Northumberland County Board of Supervisors; Doug Jenkins, Milton Wright Trucking#
(#Includes cover letter)
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3/18/2002 Reply From Dr. Robert Stroube, Acting Commissioner, VDH
Department of Health
P O Box 2448
March 18, 2002
Dr. Lynton S. Land
Post Office Box 539
Ophelia, Virginia 22530
Dear Dr. Land:
Thank you for your recent letter regarding the potential impacts that birds foraging on biosolids may have on shellfish growing waters. I appreciate your concern for the quality and safety of the Commonwealth's shellfish resources, and can assure you that the Virginia Department of Health is committed to the preservation of a safe, high quality shellfish resource.
As you stated in your letter, birds, like virtually all warm-blooded animals, have the potential to contribute to coliform contamination of waterways. This potential is certainly documented in the literature regardless of the nature of their feeding habits. The relative importance of birds as a source of contamination compared to other animals however is a matter of debate. In spite of the fact that birds may often defecate directly in the water, our staff as well as staff from the Maryland shellfish sanitation program have looked at water samples that were taken in the presence of large flocks of geese and not found elevated levels of fecal coliform in the water. Further, the article you refer to entitled "Coliform Contamination of a Coastal Embayment: Sources and Transport Pathways" (Environmental Science and Technology, 1996, V30, p. 1872-1881), also found that "While direct waterfowl inputs constitute a large potential source of FC to Buttermilk Bay waters, sampling did not support a direct relationship between this input and bay water column densities." Additionally, due to the relatively small total volumes of fecal material contributed by each bird, and the extensive dilution and dispersion of the material once in a waterway, the cumulative affect on the bacteriological quality of the water body is minimal except in shallow headwaters with low tidal flushing with extensive bird fecal deposition.
In spite of the degree to which any particular animal may contribute to the contamination of a shellfish growing area, the National Shellfish Sanitation Program (NSSP) acknowledges that contamination of a shellfish growing area from these sources has the potential to affect the safety of shellfish harvested from the area. As a result, the NSSP has established strict water quality standards for shellfish growing areas to which all of the shellfish producing states in the United States as well as a number of foreign countries adhere. The Division of Shellfish Sanitation examines samples of water from our shellfish growing areas monthly to determine if any of a multitude of these potential sources of fecal contamination exists in an area; and, as required by the NSSP, will impose harvest restrictions on any area that fails to meet these standards. Currently, there are over 200 shellfish area closures in Virginia. Although your letter stated that "there are very few counties in Virginia where the Division of Shellfish Sanitation imposes harvesting restrictions and where permits for the land application of sewage sludge are granted", the fact is that these closures are distributed across virtually every county that has a watershed draining directly to a shellfish growing area, including those where permits for the land application of sewage sludge have been granted.
The U.S Environmental Protection Agency (EPA) has defined waters that are closed to the harvest of shellfish as impaired. This designation is independent of the specific source or sources of the contamination that is the cause for the closure, which is rarely known. The Virginia Department of Health is, however, currently working with the EPA and a number of Virginia state agencies and academic institutions to determine the sources of contamination to these areas and to establish a Total Maximum Daily Load (TMDL) for each of these areas as required by the EPA. This work will be difficult and time consuming, but we hope to learn a great deal from this process and certainly hope to reclaim some shellfish area acreage that is currently closed as a result.
Birds are a natural part of the landscape around Virginia's waterways, and some species certainly are known to naturally feed in pastures, feedlots, and other areas where coliform concentrations are high. Although birds do have the potential to contribute to the bacterial contamination of a water body, there is no evidence to support that foraging in a field where biosolids have been applied increases the role that they may play in water body contamination over other foraging sites. Regardless of the source, if a shellfish growing area is found to be receiving coliform contamination that causes it to exceed the NSSP water quality standards, these waters are closed to the harvest of shellfish thus providing public health protection to the citizens of the Commonwealth and to shellfish consumers.
Should you desire further information, please contact Robert E. Croonenberghs, Director, Division of Shellfish Sanitation or C. M. Sawyer, Director, Division of Wastewater Engineering, Virginia Department of Health, 1500 East Main Street, Room 109, Richmond, Virginia 23219 by telephone at (804) 786-5567, or by email:
Sincerely,
Robert B. Stroube, M.D., M.P.H.
Acting State Health Commissioner
c: Govern Mark R. Warner
Secretary Jane H. Woods
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6/6/2002 Letter to Dr. Robert Stroube, Acting Commissioner, VDH
125 Airstrip Lane
P. O. Box 539
Ophelia VA 22530
June 6, 2002
Dr. R. B. Stroube, State Health Commissioner
Department of Health
P. O. Box 2448
Richmond VA 23218
Dear Dr. Stroube
I am gratified that your letter of March 18, 2002, acknowledges that you accept that birds, especially gulls, are vectors of bacterial contamination of waterways. Attached is a bibliography of peer-reviewed scientific publications, which I am sure is incomplete, supporting that incontrovertible fact. It is obvious, and not requiring scientific “proof”, that birds which land in water after foraging on fields to which Class B sewage sludge has been land-applied, will contaminate that water with bacteria from the sludge through simple physical transport, and possibly through their feces.
Enclosed are two photographs taken on March 28, 2002, between 10:30 and 11:30 AM, from VA 653. The field is east of VA 3, between Warsaw and Lyells, in Richmond County. The site is less than 2 miles from Totuskey Creek, an impaired waterway restricted for the harvesting of shellfish. Sludge had been spread on this field the previous day. As incorporation proceeded, Herring Gulls (Larus argentas) landed behind the tractor and foraged actively, while other birds slept in furrows that had been previously disked. I counted more than 400 birds. Photograph A shows a flock of approximately 200 birds “sleeping” in the foreground, while in the background more birds are actively foraging behind the tractor. Photograph B, taken somewhat later, shows the long stream of birds behind the tractor, while the flock of “sleeping” birds remained in the field (upper right). I trust you will retract your previous contention (Dec. 21, 2002) that VDH “… has not observed any significant bird activity on land application sites either during or following these operations…” as being due to VDH’s lack of observations, not the absence of birds. As every farmer knows, “Birds follow the plow.”
You objected to my assertion of 02/28/01 that “there are very few counties in Virginia where the Division of Shellfish Sanitation imposes harvesting restrictions and where permits for land application of sewage sludge are granted.” The following data confirm that assertion. Data for land application of sludge in 2000 are from the most recent EPA Inspector General’s report, which can be found online at www.whistleblowers.org/OIGFinalSludgeReport.htm. This second IG report is even more highly critical of EPA’s, and by extension, VDH’s policies regarding the land application of sewage sludge than was true of the first IG report. Impairments, and restrictions on the harvesting of shellfish, are from www.epa.gov/owow/tmdl.
County dry tons sludge spread waterways impaired
Northumberland 0 38
Westmoreland 17185 25
Lancaster 0 24
King George 6203 8
Richmond 1612 4
Essex 5958 3
King William 14744 2
Sewage sludge is not the cause of shellfish closings, which are almost certainly due primarily to bacterial contamination by wildlife. But the land application of sewage sludge unquestionably worsens an already unsatisfactory situation. By granting permits for the land application of sewage sludge in these counties, VDH sanctions the import of exceedingly high numbers of fecal coliform bacteria (as well as other potentially dangerous microbes such as Salmonella) into areas where shellfish closures and EPA impairments exist because of high concentrations of those same bacteria. This is not only a violation of common sense, but a clear violation of the Code of Virginia (§ 32.1 164.5), which requires VDH “…to ensure that……(ii) land application, marketing and distribution of sewage sludge is performed in a manner that will protect public health and the environment, and (iii) the escape, flow or discharge of sewage sludge into state waters, in a manner that would cause pollution of state waters, as those are defined in § 62.1-44.3, will be prevented.”
Yours sincerely,
Dr. Lynton S. Land
cc: DEQ#; EPA#; Gov. Warner; Del. Pollard; Sen. Chichester; Sen. Bolling#; Rep. Davis; Sec. Murphy#; Sec. Woods#; Northumberland County Board of Supervisors; Doug Jenkins.
(#Includes cover letter).
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