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  • Chuck Simmons (Synagro) Appeals To Franklin County Commission

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    NYC Sludge
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    The proposed regulations seek to ban a valuable recycling practice that benefits many fanners in Franklin County. Biosolids recycling is approved by the u.s. Environmental protection agency. Over half of America's sewage sludge is recycled to the land as biosolids.

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    Chuck Simmons (Synagro) Appeals to Franklin County Commission

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    The proposed regulations seek to ban a valuable recycling practice that benefits many fanners in Franklin County. Biosolids recycling is approved by the u.s. Environmental protection agency. Over half of America's sewage sludge is recycled to the land as biosolids.

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    127 views8 pages

    Chuck Simmons (Synagro) Appeals To Franklin County Commission

    Uploaded by

    NYC Sludge
    The proposed regulations seek to ban a valuable recycling practice that benefits many fanners in Franklin County. Biosolids recycling is approved by the u.s. Environmental protection agency. Over half of America's sewage sludge is recycled to the land as biosolids.

    Copyright:

    Attribution Non-Commercial (BY-NC)
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    synacro ee ane A Residuals Management Company April 14, 2009 VIA HAND DELIVERY Franklin County Commission Franklin County Solid Waste Department 405 Jackson Avenue N 203 Carroll Avenue SE Russellville, Alabama 35653 Russellville, Alabama 35653 Re: Amendment of Franklin County Solid Waste Rules and Regulations Dear Sir or Madam: recycling practice that benefits many farmers in Franklin County. Biosolids recycling is approved by the United States Environmental Protection Agency (EPA), state environmental cider ind is practiced on many thousands of farms sere America. There is no scientific evidence to support such a ban and itis illegal under federal and state law, Synagro respectfully asks that th i i it 01 Woodall Road * Decatur, AL 38601 Ph: (256) 351-0959 « Fax (256) 351-0961 POSS eee ae ee ee eee ee ee eer ee ee eee ee ett April 14, 2009 Page 2 The EPA, state environmental agencies, and researchers at major universities have long adorsed and encouraged the land application of biosolide aa safe altemative in residuals Caanegement.' EPA first regulated land application of bicocids 1979. In 1987 the US. Goneress amended the Clean Water Act to direct EPA es update the regulations with arraiamtive national standards 10 reduce any risks and mate es the benefits of land application of biosolids. After years of risk assessment studies, peer review, and notice and Pare sn gle making, in 1993, EPA issued its Biosolids Use and Disposal Regulation, 40 CFR Part 503, commonly referred to as “Part $03.” Part 503 mandates a continuing review and improvement of biosolids science and ulations. “Every two years, EPA assesses whether addons chemicals potentially found in biosolids should be regulated. In addition, EPA. ia Cooperation with state governments and Wastewater authorities, has made important progress in managing and reducing the levels of industrial pollutants in treated water and biosolide through industrial pre-treatment requirements, In fact, the amount of ‘trace elements and other Pollutants in biosolids has declined significantly in recent decades, a fact confirmed again by EPA's lat National Sewage Sludge Survey, released in January 2009. ee oe Ss EPA, Biosolids Resycling: Beneficial Technology for a Better Environment (1994); California State ater Resources Board, Statewide Program Environmenee Impact Report for Biosolids Land Application (2004), En PEPE et al, Environmental and Polluion Saco, (2d ed. 2006); Gary Pierzynski et al, Soils ant Environmental Quality (3d ed. 2005). jS2t- £8 Steven Smith, Imperial College, The Jnektations for Human Health and the Environment of Recycling Seeds on Asricutaral Land (2007); Rao Surampallv toh Long-Term Land «pplication of Biosolids 4 Care ‘Study, $7 Water Sci & Tech. 345 (2008) April 14, 2009 Page3 Synagro is aware that EPA is currently snvestigating the presence of perfluorinated compounds (PFCs) that were discovered ip TLroselids received for land application from Dest Cuties. It is Synagro’s understanding that due 0 Their widespread use in various industrial applications and consumer products, mine ants of PFCs can be found throughout the ‘world (ez, PFCs have been measured in Polat tears), Decatur Utilities, with the concurrence of Synagro, has ceased land ‘applying its biosolids. Synagro thas been cooperating with EPA's eyrectigation by providing information regarding 1 *Nlabama operations. Moreover, Synagro has never land applied biosolids from Decatty Uulides in Franklin County. Rather, only es aids from outside Alabama are land applied in Franklin County. Unconstitutionality of Proposed Changes 10 the Solid Waste Rules and Regulations If approved, the proposed changes t0 the Franklin County Solid Waste Rule and Regulations would effectively ban the land application of biosolids in Franklin Court) In particular, the $35.00 per ton land application na the requirement that trucks transporting peveolids in Franklin County be weighed twice st & me ral Tocation renders land application of ree ptids economically and practically impossible 2 amounts to a total ban. Banning the land application of biosolids in Franklin County berms ae gnvironment by depriving farmland of the apPTonmental and conservation benefits of Tiosalids, particularly in drought, conditions, Farmers in Franklin County also benefit from saowtds by not having to purchase fertilizer and by reducing chemical inputs to the sei ‘Controlling fertilizer costs and reducing chemical by dizer is eritical to sustainable agricultre in Franklin County, especially in the current economic climate. Furthermore, because it is Synagro’s understand that the only biosolids that are curently land applied in Franklin County come from sade the state of Alabama, the proposed

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