8/9/2019 Response from Syangro on questions about its operations in North-West Alabama

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March 24, 2010

Statement of Layne Baroldi, Synagros director of regulatoryaffairs and technical services, in response to questions on thecompanys operations in north-west Alabama:

Thank you for the opportunity to respond to questions about our business. As you mayknow, Synagro is a nationwide recycling and residuals management company providing servicesfor managing organic residuals that are the byproduct of municipal wastewater treatmentfacilities. Biosolids are the treated organic residuals that are rich in plant nutrients and can besafely recycled and land applied to benefit agriculture and horticulture. Biosolids provideprimary and secondary nutrients for plants and bulk organic matter that improves soil tilth andquality, properties that cannot be duplicated by commercial fertilizers.

Thousands of American cities and towns have recycled biosolids to farmland for manydecades, providing a valuable fertilizer and soil conditioner that have particularly benefited smallfarms and pastures throughout the country, including in Franklin County, Alabama. Over half of Americas sewage sludge is recycled to the land as biosolids. Without land application, citiesand towns would have to turn to landfilling and incinerating biosolids, expensive alternativeswith no environmental benefits.

The EPA, state environmental agencies, and researchers at major universities have longendorsed and encouraged the land application of biosolids as a safe alternative in residualsmanagement. 1 EPA first regulated land application of biosolids in 1979. In 1987 the U.S.Congress amended the Clean Water Act to direct EPA to update the regulations withcomprehensive national standards to reduce any risks and maximize the benefits of landapplication of biosolids. After years of risk assessment studies, peer review, and notice andcomment rule making, in 1993, EPA issued its Biosolids Use and Disposal Regulation, 40 CFRPart 503, commonly referred to as Part 503.

The Part 503 regulations are comprehensive, risk-based rules that protect human healthand the environment. Part 503 sets strict standards for treatment plants, land appliers, andfarmers that are enforced by EPA. Among many requirements, the Part 503 regulations limittrace elements in biosolids and in farm fields, mandate technologies that reduce bacteria orviruses to negligible levels, limit the total amount of biosolids that can be applied to a field,require setbacks from waterways, and require extensive record keeping by wastewater plants andland appliers like Synagro.

1 See, e.g., EPA, Biosolids Recycling: Beneficial Technology for a Better Environment (1994); CaliforniaState Water Resources Board, Statewide Program Environmental Impact Report for Biosolids Land

Application (2004); Ian Pepper et al., Environmental and Pollution Science (2d ed. 2006); Gary Pierzynskiet al., Soils and Environmental Quality (3d ed. 2005).

8/9/2019 Response from Syangro on questions about its operations in North-West Alabama

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Part 503 mandates a continuing review and improvement of biosolids science andregulations. Every two years, EPA assesses whether additional chemicals potentially found inbiosolids should be regulated. In addition, EPA, in cooperation with state governments andwastewater authorities, has made important progress in managing and reducing the levels of industrial pollutants in treated water and biosolids through industrial pre-treatment requirements.

In fact, the amount of trace elements and other pollutants in biosolids has declined significantlyin recent decades, a fact confirmed again by EPAs latest National Sewage Sludge Survey,released in January 2009.

There is an overwhelming scientific consensus that land application of biosolids poseslittle if any risk to public health and the environment. The National Research Council (NRC) of the National Academy of Sciences studied extensively the use of biosolids in land applicationand issued two major reports in 1996 and 2002. The NRC concluded in both reports that theapplication of biosolids to land, when practiced in accordance with existing federal guidelinesand regulations, is beneficial and protects human health and the environment. The Academys2002 Report, Biosolids Applied to Land: Advancing Standards and Practices concluded thatThere is no documented scientific evidence that the Part 503 Rule has failed to protect publichealth. Peer-reviewed scientific studies around the world continue to endorse the benefits andsafety of recycling biosolids. 2

As for your five specific concerns related to the use of Ney York City biosolids inAlabama, please refer to the following responses:

As with many organic materials used in agriculture, such as chicken litter, cow manure orvegetable composts, biosolids may have odors caused when proteins in biosolids breakdown. While the odors are not harmful, Synagros biosolids processing facility wasselected specifically because the nearest residence was located more than one mile awayfrom the processing facility. Frequent monitoring of the area confirmed that the odordissipated into the atmosphere readily to the point where it could not be detected within100 yards of the facility. It is our understanding that reports of odors traveling as far asfive miles away from the facility were investigated by the State of Alabama Agricultureand Industry agency and were found to be without merit. Indeed, most of the complaintswere determined to be as a result of poultry litter odors.

This is a general statement, and we are not aware of any such occurrences. If you wouldlike to provide us with an alleged specific occurrence, we would be glad to investigatefurther. In general, however, Synagros biosolids land application program utilizes asystematic approach to insure environmental compliance. Biosolids are applied atagronomic rates, land use is restricted to sites which meet requirements for biosolids landapplication, buffer zones are incorporated into land application sites to prevent runoff,land application does not occur during precipitation events and land application onsaturated soils is prohibited. Synagro did not receive any notices of violation (NOV)from any regulatory agency for this project. Further, Region IV EPA inspection of the

2 See, e.g. , Steven Smith, Imperial College, The Implications for Human Health and the Environment of Recycling Biosolids on Agricultural Land (2007); Rao Surampalli et al., Long-Term Land Application of Biosolids -- A Case Study , 57 Water Sci & Tech. 345 (2008).

8/9/2019 Response from Syangro on questions about its operations in North-West Alabama

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