Changes may triple waste tonnage

New effluent guidelines proposed by the Environmental Protection Agency (EPA) for wastewater discharge from meat and poultry-processing (MPP) facilities could result in as much as 1.2 million more tons of residual sludge, per year, according to an EPA Environmental Assessment (EA).

The proposed new guidelines (released in December) are designed to offer additional protections to surface water and, thereby, public drinking water systems that source water from surface features. However, if implemented, the guidelines could have the opposite effect in southwest Missouri.

The EA said “while the proposed new restrictions may eliminate or reduce one form of pollution, they may create or aggravate other environmental problems.”

Southwest Missouri residents are already familiar with the environmental problems created — so far — by the land-application of sludge, one of which involves the smell. But, the EA spells out the possibilities for future problems.

Along with an increase in the quantity of sludge, the quality of the sludge could deteriorate, the EA said.

With the removal of more contaminants from the liquid portion of the wastewater, which will be released into surface water, larger quantities of sludge with greater pollutant content will be left behind. The pollutants of concern can include metals, excess nutrients, pathogens and the additional chemicals needed to create cleaner wastewater liquids.

Per- and Polyfluouralkyl Substances (PFAS), too, can be part of the mix, according to a Missouri Department of Natural Resources (DNR) disclaimer in pending proposed permits for waste-haulers Synagro Central and HydroAg Environmental, who are seeking to land-apply meat-processing sludge to some 8,500 acres in Barry County.

For the first time, last week, the EPA imposed drinking water limits for PFAS, a group of thousands of man-made chemicals which have become prevalent in the environment.

Heather Peters, Chief of the Water Pollution Control Branch of DNR, said it will take some time for the department to establish state regulations for PFAS.

The presence of multiple pathogens in the sludge is typical, according to the EA.

“Meat sludge byproduct in effluent can provide the nutrients needed for the long-term survival and proliferation of some microorganisms,” the EA said. “Prevalent bacteria in MPP wastewater include Escherichia coli (E. coli), Giardia (e.g., Giardia lamblia), Enterococcus, Salmonella ssp., Campylobacter (e.g., Campylobacter jejuni), and Staphylococcus (including S. aureus and Methicillin-resistant Staphylococcus aureus [MRSA]).”

According to the EA, poultry by-products can also harbor the Avian Flu virus. Avian flu has recently been diagnosed, not only in birds, but in cattle herds in five states, and in a human who had contact with an infected animal.

While Missouri’s proposed DNR permits contain limits for certain metals and for E-coli, no other pathogens are included in the required wastewater sampling, which is proposed for once a year for facilities permitted in Missouri, and once quarterly, for facilities permitted outside of the state.

Newton County resident James Carter believes southwest Missouri is being “sold down the river” by the DNR.

“That’s the only way to describe the DNR’s permitting of millions of gallons of industrial waste sludge on our fields,” he said.

Of particular concern to Carter is the lack of a DNR requirement for independent testing of the sludge by third-party labs who would report directly to the department.

With the land application of sludge, the contamination of groundwater is a concern for many southwest Missouri residents, who draw their drinking water from private wells. The EPA’s environmental assessment confirms that they have reason to be concerned.

“Effects are not limited to the property on which waste is disposed, because contaminants can percolate into groundwater, accumulate in waterways, and cause air, soil, and water pollution elsewhere,” the EA said.

In spite of southwest Missouri’s karst topography, which allows land-contaminates to easily drain downward into groundwater, the DNR’s proposed permits for sludge-haulers do not include any requirements for groundwater monitoring “because there are no subsurface discharges,” the DNR permits state. That rationale is questionable in light of the contaminated groundwater at multiple EPA Superfund sites in the Ozarks, where toxic materials have been land-applied or otherwise disposed of on the surface.

“We can require groundwater monitoring if there is evidence of discharge into groundwater,” Peters said.

“A poultry company in Sussex County, Del., was sued for groundwater contamination as a result of waste discharge practices,” the EA said. “The facility sprayed poultry waste contaminated with nitrates and bacteria onto nearby farm fields, where it subsequently seeped into the groundwater system. The nitrates and bacteria reached nearby wells and were associated with gastrointestinal illnesses in nearby residents.”

With the proposed Missouri DNR permits for sludge-haulers, pinning liability for contaminated water (and resulting sicknesses) on the producers of the sludge may be hard to do, because the proposed permits do not include the names of the processing facilities. When asked if the DNR would have the names of those processors on file — the majority of whom, based on last year’s list, will be located outside of Missouri — Peters did not reply. She did, however, say that it would be a suggestion to include as a public comment on the proposed permits.

In reference to waste haulers bringing out-of state sludge into Missouri for disposal, Peters said that they’ve had that permission indefinitely.

“That permission isn’t up to the department,” she said. “It’s up to the state legislature.”

“The health impacts [from] changes in waste management result from both chemical and biological contamination,” the EA said. “Sludge and wastewater deposited on fields may contain both pathogens and potentially harmful compounds, such as ammonia, nitrates, and dihydrogen sulfide. Harmful pollutants can be transported by groundwater to wells or drinking water sources and exposed to residents. Exposure to and ingestion of these pollutants in sufficient concentrations is reported to cause respiratory issues, gastrointestinal issues including enteritis, nervous system impairment, multiple cancers and death.

“The environmental impacts of changes in waste management can include hypoxic/anoxic conditions, eutrophication, fish kills, and high ammonia levels in nearby water bodies,” the EA said.

“Changes in waste management” is a euphemistic way of saying southwest Missouri residents can expect more sludge if sludge-haulers can convince enough landowners to accept it – a task made much easier since they’re offering it at zero to minimal charge.

And just how much more sludge, with its accompanying environmental impacts, can Barry County expect?

Cathy Milbourn, with the EPA’s Office of Administration in Washington, D.C., said that three proposed rule options for effluent restrictions from meat and poultry processing plants could result in incremental increases in solids-generation (sludge) ranging from 384,000 tons to 1,210,000 tons per year.

Based on a semi-tanker capacity of 6,000 gallons, that increase could translate to anywhere from an additional 16,000 to 50,000 tanker loads for waste-haulers like Synagro Central and Denali Water Solutions, who land-applied poultry and meat-processing sludge on southwest Missouri farms last year.

Those additional tankers could represent a financial windfall for those companies and their competitors if they are able to land-apply it.

Whether enough farmers accept the sludge or not, “the frequency of land-application may change,” the EA said. That change can only mean one thing: there will be more land-applications made in an attempt to keep up with the increased quantity of sludge, which in turn will create greater opportunity for over-applications.

Previously (while the companies were permitted under the Missouri Fertilizer Control Board), her department didn’t have the authority to regulate the companies who land-apply processing waste, Peters said. She expects that to change this year.

When the rules are spelled out by the DNR and the companies’ permits are approved, the department will have the jurisdiction to enforce the regulations, she said.

Public comments may be submitted through 5 p.m., April 21, on DNR’s proposed permits for Synagro and HydroAg, for the land-application of meat-processing sludge on some 8,500 acres of land in Barry County and 700-plus acres in McDonald County.

For Synagro’s permits: https://dnr.mo.gov/ calendar/event/251416 For HydroAg’s permits: https://dnr.mo.gov/ calendar/event/251426 Comments may be submitted by email to: publicnoticenpdes@dnr.mo.gov .

Please include permit numbers on comments.

The complete EPA Environmental Assessment quoted from in this article can be found at https://www. epa.gov/system/files/ documents/2023-12/ mpp_envir-assessment_ proposed_dec-2023.pdf.