Paxton and the TCEQ have this great concern for “air quality standards for sulfur dioxide” here in Texas and I agree it should be reviewed.  

However, here is where the rubber is NOT meeting the road with these two: The land application of municipal industrial, hospital, storm, and household so call processed sewage sludge (Class A, B, and AB). This would be the concentrated contaminated residuals from cleaning sewage.

One very red flag is that regulation EPA 40 CFR 261.30(d) and 261.33 (4), every US industry connected to a sewer can discharge any amount of hazardous and acute hazardous waste into sewage treatment plants. Potentially 80,000 plus chemicals and growing. The TCEQ will not even talk about it nor do they require discloser to a farmer or landowner looking at using it.

Example: Here is a question ask to the TCEQ. "Are you allowing, though CFR 40-part 503, chemicals of unknown amounts, concentrations and degree of hazard onto farms, ranches and forests without the consent or knowledge of those farmers, ranchers and landowners labeled as Class A, Class AB(Texas), and Class B bio-solids?"

Answer from the TCEQ, David Galindo, david.galindo@tceq.texas.gov  Director Water Quality Division TCEQ replied: 01/2016 "TCEQ authorizes the land application of treated domestic sewage sludge (biosolids) that is compliant with all existing federal (40 CFR Part 503) and state regulations (30 TAC Chapter 312) for meeting pathogen reduction, vector attraction reduction, and pollutant limitations."

Let me paraphrase the answer: The EPA does not require the TCEQ to disclose so they do NOT.

In fact, Commissioner Shaw has repeatedly exclaimed just “how beneficial biosolds are.” This would be the same Shaw that thinks reducing smog in Houston will not provide any “public benefits” to Texans.

Another red flag is EPA's Office of Inspector General's (OIG) Report No. 14-P-0363 from 09/2014. Just Google the number. There are other reports of interest on this subject: OIG 2000-P-10 03/2000, 2004-P-10 09/2004, 2004-P-00004 02/2004, 10-P-0066 02/2010 and 12-P-0508 05/2012. You can google any of them.

We have asked repeatedly what has been done about Report No. 14-P-0363 to the EPA and TCEQ. The EPA refuses to answer and here is the TCEQ’s response:

Answer from the TCEQ: David Galindo, david.galindo@tceq.texas.gov  Director Water Quality Division TCEQ: 01/2016 “TCEQ would be required to implement any changes to the existing federal biosolids regulations, including any potential EPA rule amendments in response to the OIG report. We are unaware of any EPA response addressing the validity of the statements made in the report or determination on the need for a rule amendment at this time.” 

Should you ask any sewage proponent, including the TCEQ, about industrial chemicals in sewage they will exclaim from what appears to be a script, “Industrial chemicals are strictly regulated by pretreatment.” I hope that you read OIG report 14-P-0363 and have drawn your own conclusion about this statement.

There are volumes of independent studies that show just how contaminated processed sewage sludge is. EPA regulation CFR 40-503 written from data collect in the 70s and 80s. The EPA, TCEQ and all State Environmental Agencies stand ridged that sewage has not changed in 47 years and refuse to review CFR 40-503 I believe for fear it would show how ill-conceived the practice is today. 

So when I see Paxton and the TCEQ get together to bring “air quality standards for sulfur dioxide” up for review I just have to wonder about why they would not look into this known issue. Maybe it is the pecking order of who wants to keep status quo. US Legislature / EPA, FDA, CDC, USDA, NA / State Legislature/ State Environmental Agencies / River Authorities/ Municipalities / the multi-billion dollar Waste Water Processing Plants , sludge dumpers and even some colleges who get grants from the state and sewage syndicates.

Respectfully,

Craig Monk

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