DATE:        21   SEP 1978

SUBJECT: Standards for Landspreading of Hazardous Waste

FROM:      William Sanjour, Chief
                  Assessment & Technology Branch, HWMD (WW-565)

TO:            John P Lehman, Director
                  Hazardous Waste Management Division (WW-565)

    Gary Dietrich had a meeting in his office on September 20, 1978, to discuss the 3004 standards. Present were myself, Tim Fields, John Schaum, and Howard Beard. On the subject of landspreading of hazardous wastes for the purpose of growing food, Gary made the following points:

  • The Agency would soon. be making a decision which would probably allow some amount of cadmium into human diets from the use of sewage sludge as a fertilizer on food crops.

  • The fact that our 3004 standards ban the use of hazardous waste as a fertilizer if any amount of cadmium can enter the human diet would be inconsistent with this anticipated decision. (I gather he is concerned that our standards might prove to be an embarrassment to the Agency.)

  • Therefore, he instructed us to strike the prohibitions on cadmium increase in the human diet from the 3004 standards on the use of hazardous waste as a fertilizer, and to replace it with a requirement that section 4004 guidelines in regard to cadmium shall apply.
  • I made the following points in arguing against his decision:
  • The authors of the 4004 guidelines have made it plain on numerous occasions that they did not feel that the 4004 guidelines were sufficiently protective of human health (you will recall John Skinner's remarks at the recent Desk Officer's meeting that they were pressured into those standards).
  • We cannot anticipate how much cadmium will be admitted to the human diet by this decision. Although we have no statistics, we know of many examples of industrial chemical and mining wastes used as soil amendments and fertilizer.

  • When the hazardous waste regulations are promulgated making landfills very expensive, we can expect the practice of using industrial wastes as soil amendment and fertilizer to increase enormously for the same reason that it is so popular with sewage sludge, i.e., it's the cheapest way of getting rid of the stuff.

  • There is much much more industrial waste than sewage sludge, so the potential for creating a tremendous public health problem by EPA's allowing chemicals contained in industrial waste to contaminate food is made much greater by this decision.
  • The 3004 standards are being revised in accordance with our new instructions.

    cc: Gary Dietrich
         Bruce Weddle
         Tim Fields
         John Schaum
         Howard Beard
         Larry Weiner
         3004 Docket

    William Sanjour's home page

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