‘FLUSH WITH SUSPICION’

(RE: Milwaukee’s WWTP Milorganite Sludge Product)

by: Will Fantle

Milwaukee Magazine, Vol. 21, No. 11, pgs 48-55.

Reprinted with permission by Editor John Fennell [Copyright November, 1996]

c/o 312 E. Buffalo St., Milwaukee, WI 53202, email: milmag@qgraph.com) 

With environmentalists charging that Milorganite is full of toxins and heated competition from other cities, the country’s venerable fertilizer is looking less and less like Milwaukee’s Miracle.

Tom Crawford bursts into the room, drops a legal ruling on the table, then launches into an unsolicited five-minute summation of the finer points of the Appeals Court case. Seemingly driven by a coffee jag, Crawford is off and running. He’s the point man and chief defender for Milorganite, the venerable sludge-based fertilizer produced by the Milwaukee Metropolitan Sewerage District (MMSD). Wearing the team colors - a white polo shirt bearing the green and orange Milorganite logo - Crawford is eager to squelch any potential criticism of the city’s fertilizer. The court case that has the district’s senior legal counsel all fired up concerns the level of risk posed by toxic pollutants in sludge.

During his days as a lawyer and former state legislator, Crawford honed his persuasive skills, now kept busy protecting Milorganite’s turf. Clouding Milorganite’s future are new competitors and environmental critics. Other big cities have cranked up production of similar sludge-based fertilizers, slicing into Milorganite’s traditional markets. And environmental critics are raising new concerns, suggesting that the prominent "100% natural organic" label on the Milorganite fertilizer bag masks a toxic stew of heavy metals and poisons like dioxin.

Undeterred, Crawford insists that "Milorganite is the best in the industry." And it’s an industry with deep roots in Milwaukee. Like most cities, Milwaukee once flushed its sewage into surrounding water bodies. The Milwaukee, Menomonee and Kinnickinnic rivers acted as large sewer lines, carrying the waste out into Lake Michigan. This unacceptable situation (especially to those who wanted to swim, fish and drink from these waters) led to the construction in 1923 of a new kind of large-scale central sewage treatment plant at Jones Island.

The activated sludge plant cost $15 million. Toss in another $20 million for interconnecting sewer lines and the plant serviced a population of 575,000 people. But the city still had to find a way to dispose of the sludge created by the plant. It was the experimental and innovative work of O.J. Noer, first for the University of Wisconsin and then for the MMSD (after they hired him in 1925), that solved the riddle and transformed the proverbial pig’s ear into a silk purse.

Noer concluded that the dried sludge could work as a fertilizer; commercial greenhouses and golf courses proved as the largest single public works project ever undertaken in America. "We remove from the aquatic environment 99-plus percent of sewage solids," boasts Rubin, who holds a Ph.D. in chemistry.

The sludge, left over after sewage treatment, has to go somewhere, creating a disposal dilemma. The muck got deeper when the EPA later banned ocean dumping of sewage sludge (commercial fishers and the public frowned on dead and diseased fish). Many coastal communities that relied on this disposal option were forced to hunt for other alternatives. Several big cities chose to copy Milorganite, a product Rubin calls the "flagship" and "model" for the industry.

This effort was made easier when, with Rubin at the helm, the ideal candidates. Milorganite was selected as the name for the new product in 1925 from among 233 entries in a contest sponsored by the MMSD and advertised in the national Fertilizer Magazine.

The explosion of golf as a sport and a savvy marketing campaign sent sales soaring. By the mid-1930’s, 50,000 tons of Milorganite was sold annually and the city’s toilets couldn’t be flushed fast enough to keep up with product demand. Milorganite dominated the sludge fertilizer market for most of this century; occasional tweaks were necessary, but Noer’s and the MMSD’s research kept demand high, both in bulk and individual-bag markets.

Happy with their sludge disposal system, the Sewerage District embarked on a massive $2 billion upgrade in the 1980’s that included a new Milorganite manufacturing plant to replace the aging Jones Island facility (see "From Poop to Pellets," page 52). Today, the MMSD services 28 municipalities with 1.4 million people.

But the world has changed and now, for the first time, Milorganite has serious competition. New York, Tampa, Baltimore and Boston are out to mimic the Milwaukee miracle by marketing similar products. Crawford and Al Nees, Milorganite’s marketing manager, complain that their new competitors are basically giving their product away for free and have gobbled up important bulk markets, including Florida’s orange groves and golf courses.

"We’ve decided to get the hell out of that market and concentrate on the bag market," says Nees. In the Milwaukee area, Milorganite captures about 14 percent of retail fertilizer bag sales and about 1 percent throughout the rest of the country. It, too, is a tough market. Milorganite, with only a 6 percent nitrogen level and tiny amounts of other nutrients, competes against commercial brands containing three or four times its quality of plant food.

Jokes Crawford: "If we can’t sell it, we’ll start returning bags with sewer bills."

Federal laws and regulations are partly responsible for Milorganite’s competitive troubles. The Clean Water Act, passed in 1972, led to a dramatic cleansing of the nation’s

waterways. "The EPA committed one heck of a lot of money in building sewage treatment plants," says the gregarious Al Rubin, the federal agency’s self-described Sultan of Sludge. Indeed, the nearly $50 billion spent over the past two decades on sewage facilities rivals the Superfund EPA began another regulatory step in the 1980s that redefined how sludge could be disposed of. The new "beneficial use" policy, formally adopted in 1993, loosened standards controlling the amount of toxic pollutants permissible in sewage sludge. Sludge farming was given a qualified green thumbs-up for widespread use.

While human-generated "night soil" is a centuries-old traditional fertilizer, it’s more than the morning flush that washes into municipal treatment plants. Modern industry discharges a considerable volume of different types of waste into the same system. Heavy metals - such as mercury, lead, copper and arsenic - and chemical pollutants - including pesticides and PCBs - all wind their way through common sewers to the same municipal treatment plants. This industrial crud, once siphoned from the sewage, mostly filters into municipal fertilizers.

The EPAs new regulations changed allowable limits for all sorts of toxins in sludge. For example, the amount of poisonous arsenic from sludge that can be annually applied to the farm fields rose from 12.5 pounds per acre to 36 pounds per acre. Lead’s limits jumped from 111 pounds to 267 pounds per acre and mercury’s ceiling was lifted from 13.4 pounds to 50 pounds per acre. Even New York City’s sludge containing petroleum hydrocarbon levels far in excess of those the state would require for cleanup at oil and gas spills, was deemed beneficial fertilizer.

The prospect of the nation’s farmland covered by this goo has raised the hackles of some critics. "There’s real slight of hand her," charges John Stauber, co-author of the recent book, Toxic Sludge Is Good for You. "This is a massive scam designed to provide municipalities the cheapest way of getting a toxic product out of sight and out of mind."

Class B liquid sludges carry tighter application standards for use with food crops (see "Sludge Wrestling in Waukesha," opposite page).

This easing of the rules was welcome news for operators of many of the nations 15,000 sewage treatment plants constrained by sludge disposal problems. In fact, the EPA’s tight relationship with the sewage industry’s trade and lobbying group - the Water Environment Federation - is chronicled by Stauber in his book.

A Madison-based watchdog of the public relations industry, Stauber and co-author Sheldon Rampton wanted a catchy title for their new book about the marketing and shaping of public opinion by the nation’s giant PR firms. The book actually had nothing to do with sludge disposal; when they dreamed up its whimsical title, they hoped to capture the public’s eye and, of course, their publishers fancy.

Several months later, fate intervened. Nancy Blatt, a PR representative for the Water Environment Federation (once known as the Federation of Sewage and Industrial Wastes Associations), caught wind of the forthcoming book and contacted the authors. She asked them to change the title because it could interfere with a pending $300,000 PR campaign by the federation aimed at improving sludge’s image. "it’s not toxic," she told Stauber. The federation also was planning to push popular adoption of their new name for sludge - "biosolids," the term employed by the EPA in its rule change and taken from the Federation’s Name Change Task Force.

Surprised by inquiry, Stauber says "we smelled a story and decided we had to investigate." They found a twisted mix of corporate and governmental collusion littered with conflicts of interest. They had so much material that they added a chapter to their book discussing the EPA’s regulatory rewrite.

Dr. Terry Logan, a soil chemistry professor at Ohio State University. Led the EPA’s science squad studying the new sludge regulations. He was, Stauber leaned, a paid consultant and board member holding stock options for a company that turned sludge into fertilizer. Logan was named "man of the year" in 1994 by the EPA and received money from Congress to promote his company’s product.

The Water Environment Federation landed a $300,000 grant from the EPA in 1992 to educate the public about the "beneficial uses of sludge." The EPA’s Rubin - whose other favored nickname for himself is the "Bambino of Biosolids" - took a two-year leave from the agency to work as a sludge promoter for the federation. The EPA continued to pay 49 percent of his salary while he toured the country touting sludge farming.

Rubin calls his "assignment" with the federation "the best two years of my professional career."

Stauber is particularly galled by the lack of information given to the buying public about pollutants contained in the 40-pound Milorganite bags. "This," he says, " is a product that’s being sold to the consumer as 100 percent organic. It sounds pretty damn good, but I’m appalled."

One of the most hazardous of the toxic metals found in fertilizers like Milorganite is lead. It’s poisonous in all forms and its health effects are cumulative and potentially severe. Children and their developing brains and nervous systems are especially vulnerable to the metal’s warping punch.

"If you consistently spread Milorganite on your garden plot, you’re going to end up with a lot more lead in the soil," says Dr. Stan Tackett, who specializes in analytical chemistry. He earned his Ph.D. at Ohio State and recently retired from the faculty at Indiana University in Pennsylvania. He’s had a long and keen interest in lead pollution, published academic papers on lead contamination and appeared as a expert witness at trials on the subject.

Milorganite, according to Tackett, contains lead levels nine times greater than what’s found in uncontaminated soil. He’s especially troubled by conflicting policies at the EPA. The agency that once worked so hard to remove lead from gasoline because of its human health impacts, he says, now seems intent on pumping lead back into the soil via sludge farming. When lead eventually combines with water in the soil, Tackett explains, plants tissues will absorb the metal.

Would he advise people not to use Milorganite? Tackett says yes. "The amount of plant (fertilizer) nutrients, "Tackett adds," are very, very low. Why on earth would you want to even think about spreading industrial wastes on your land?"

Crawford, parrying like a pit bull, attacks Tackett’s concerns. " He is pretending, because of his stature as a Ph.D. Emeritus, that he knows what he’s talking about and he’s talking about good science. He’s not talking about good science. If he wrote his views up in a scientific journal and would be peer-reviewed, he’s get ripped to shreds. I promise you that."

Crawford and Rubin both mention that the EPA’s risk analysis for sludge included an extreme scenario where a mythical child actually ate soil containing the stuff with out developing any health effects. "I hate to sound like those morons from the nuclear power industry that used to say plutonium could be safely put on your breakfast cereal," says Crawford. "We’re really saying it tongue in check that Milorganite is safe enough to eat, though we certainly don’t recommend it and it’s not tasty."

"One of the big problems I see with his scheme," responds Tackett, " is that 11 to 12 percent of the nation’s children, according to the Center for Disease Control, already have a blood level of lead at a danger level. They can’t stand even a tiny amount of additional lead into their system." Tackett insists that medical and clinical experts have not challenged his views on lead in sludge. "The people who object the most are those who support the beneficial use of sludge," he asserts.

One sludge contaminant that the EPA’s regulatory rewrite chose not to consider is dioxin. "Dioxin is the most hazardous poison ever studied by the EPA," says Mike Drescher, research associate for the Citizens Clearinghouse on Hazardous Waste. The group grew out of America’s most infamous dioxin disaster, Love Canal, Agent Orange, the deadly herbicide used in Vietnam, was also laced with dioxin and takes the blame for numerous physical ailments suffered by the war’s veterans.

At higher exposure levels, Drescher explains, dioxin causes cancer; at lower levels, the effects include immune system disorders, kidney damage, bizarre skin rashes and chemical sensitivity reactions. Incredibly tiny amounts of dioxin, levels on the order of 13 to 20 parts per trillion, can cause health effects. The human body stores dioxin in fatty tissues and it’s the buildup of the toxin over time that poses problems.

Minute amounts of dioxin, between 1 and 2 parts per trillion, appear on Milorganite’s sampling analyses. Still, Drescher advises against spreading products known to contain dioxin directly on food crops or even on pastures where animals may absorb them.

Crawford indicates that he’s unsure where the dioxin in Milorganite comes from, but Drescher thinks the heating process used for drying the sludge and killing disease-carrying bugs could be a source. Temperatures near 400 F are known to spawn dioxin when they scar industrial pollutants like PVCs. Milorganite’s drying ovens range as high as 800 F.

The thorny politics of dioxin kept the poison from inclusion in the rewriting of the EPA’s sludge rules. The agency intends to address it later, but for now, Rubin says, the agency relies upon its general policy for cancer-causing substances. Carcinogens may be discharged into the environment as long as the quantities meet acceptable risks. Says Crawford: "Biosolids and soil is where you want this stuff, if it’s anywhere. You want it out of the air, you want it out of the water."

One point Crawford repeatedly raises concerns the progress made in reducing Milorganite’s heavy metal content. The MMSD has pushed an aggressive pretreatment program for industry, encouraging it to minimize and treat wastes before washing the residues into the sewer system. "I thing all of the criticism of the safety of sewage sludge is more well-founded if you take it back 15 years ago," he mentions, referring to the days before pretreatment.

Indeed, the MMSD has achieved dramatic metals reductions. Lead levels are only 22 percent of what they were 15 years ago, the amount of copper has fallen more than 50 percent and nickel quantities are down by two-thirds. Milorganite’s level of toxins is generally much lower than what other big cities are achieving.

"We have our bad days," admits Crawford. "Shit happens, and we understand that." He contends, though, that the march toward zero discharge of toxic pollutants is occurring. "You can criticize the pace but not the philosophy."

Someone who has a quarrel with the philosophy is Abby Rockefeller. The waste-handling solution she advocates is strict source separation at industry level and in the home. Rockefeller is president of Clivus Multram, a company making waterless composting toilets. Her travels to Europe, where she saw the destruction of land from sludge farming, opened her eyes to the need for change.

If industries don’t know how to handle or remove the toxins they are discharging, she says, the shouldn’t be using them in the first place. "The key is knowing what you have in the waste," says Rockefeller. Industries know what they have. Waste treatment should mean recovering the value, not rendering it harmless.

"Sewers," she explains, "are fundamentally destructive waste management technology. I don’t believe in using water to transport waste." Mixing pollutants with water creates monumental headaches and disperses poisons throughout the sludge. "To call this sludge ‘fertilizer’ is tantamount to calling a soup ‘food,’ which, though it contains some meat and vegetables, also contains a bit of lead, a little arsenic and perhaps hundreds or even thousands of other toxic organic and inorganic materials."

In large cities, Rockefeller advocates a building-by-building approach for residential areas. Toilets (not her company’s waterless kind) would carry wastes with a minimum of water to digesters in the building. These would produce methane (fuel for the building) and night soil for nearby farms. Wash water, or gray water, would be collected and sprinkled on nearby grounds, assuming that the cleansers in the water are non-toxic.

Rockefeller acknowledges that adopting such a radically different approach won’t occur overnight, will undoubtedly be expensive and will require massive public education. Nothing the billions of public funds spent on sewage treatment plants, she believes we have the resources to retool waste-handling practices. In the near term, she supports a ban on new sewer extensions, with source separation applied in its place and funded by the Clean Water Act.

Stauber echoes Rockefeller’s views: "We need to admit that sewage systems are not the answer-sewage plants are sludge plants. It’s a great example of what happens when big government and big industry collude to develop the cheapest solution."

Rockefeller’s perspective may seem fanciful. Undoubtedly, some people thought O.J. Noer’s ideas were 76 years age when he pioneered Milorganite. Crawford is far harsher. "This person," he says, " is really living in la-la land." Crawford believes in pretreatment, wants to keep the MMSD’s links to discharges from sources like the food industry (for their nitrogen load) and thinks people will have problems properly maintaining on-site treatment systems.

Waxing graphic, Rockefeller assesses modern sewage treatment practices. "People say, ‘holy shit,’" she observes, and suggests they think twice, for "shit is the only holy thing in sludge."

 How Milorganite Is Produced!: From Poop to Pellets

 Whether it’s the whoosh of a toilet or the surge an industrial waste discharge, the metro area’s sewage mingles and flows through a maze of sewers to one of two treatment plants. The Jones Island facility cleans and strips the water of its contaminants before releasing it back into Lake Michigan. The plant also manufactures Milorganite from the leftover sludge. The Milwaukee Metropolitan Sewerage District’s South Shore treatment plant performs a similar task. Its sludge, however is converted into a lesser-known product, a slurpy liquid called Agri-Life, which is injected into farm fields in a 50-mile radius around Milwaukee.

The new $200 million Jones Island Milorganite plant was part of MMSD’s huge $2 billion upgrade of the metro area’s sewage system that began in the 1980s. On-line for nearly 18 months, the Jones Island facility handles 120 million gallons of waste during an average day. Sewage pouring into Jones Island first encounters a series of screens and grates designed to remove sticks, branches and other big objects. Large circular ponds, or clarifiers, then skim off greases and oils.

Next, the sewage enters long, rectangular bubbling aeration pools where it’s mixed with bacteria hungry for organic matter. The bugs feast away. "Milorganite," says Al Nees, the product’s sales manager, "is not fecal matter, but really dead bugs who died eating the fecal matter." The bugs’ brief lives soon end when another set of clarifiers removes oxygen from the stew, leaving raw sludge.

Inside the imposing seven-story plant, the conversion of wet sludge into dried material begins. Conveyors pull the sludge through a series of presses, wringing water from the material and crushing it into smaller pieces. Perhaps the most important step occurs inside the 800 F ovens. Blowers suspend the ground sludge inside the ovens while the heat kills bacteria and viruses and finishes the drying process.

The remaining granules, ready for labeling as Milorganite, are dumped into silos. Five days after the sewage first enters the Jones Island site, 625 gallons of residential and industrial waste have been reduced to a single pound of fertilizer.

The mostly automated complex (a work crew of only five employees typically operates the plant) has not been without its problems, though. Just as raw sewage leaves a residue of heavy metals and poisons, in Milorganite, the venting of gases from the sludge-drying process contains its own chemical footprint. Emissions of volatile organic compounds (VOCs) have exceeded by 18 times the amount allowed by the plant’s DNR permit (VOCs help create ozone pollution during summer weather). The MMSD is pondering possible design changes to reduce VOC emissions and also is seeking modifications to its pollution permit from the DNR.

A deadly combination of dust and gas inside the facility caused an explosion last February 20, seriously injuring one employee and closing the plant for six weeks. It cost $1 million for safety improvements, and Tom Crawford, the MMSD’s legal counsel, indicates they may seek reimbursement from the plant’s designer.

The unexpected plant shutdown did not dampen Milorganite sales, as inventories carried the MMSD into the spring season. Sales of Milorganite generate about $5.5 million from the 55,000 tons produced each year at Jones Island. While this barely dents the MMSD’s $78 million annual operating budget, Nees certainly doesn’t expect the product to turn a profit. He calls it "cost avoidance." "It’s a lot better deal than landfilling," he says.

Agri-Life, the MMSD’s companion sludge fertilizer, generates no revenue, as it is given away. Last year, 22 million gallons were spread on area farm fields. 

 Letter to the Editor #1 

Will Fantle’s article ("Flush With Suspicion," November) raised several important points regarding sewage disposal methods nationwide….(The article’s primary intent appeared to be to raise questions regarding the safety of land-applied sludge. Unfortunately, the author relied too much on unsubstantiated claims made by self-styled "experts" and too little on readily available facts. No error was more glaring than the suggestion that the drying process used to make Milorganite produces dioxin. It is clear that the drying process does not produce dioxin. The Milwaukee Metropolitan Sewerage District (MMSD) is required by the Wisconsin Department of Natural Resources to test Milorganite for many pollutants, including dioxin. Since 1985, when we began testing for dioxin, only once has it been found, and then at the trace level of 3.4 parts per trillion. Even Mr. Fantle’s expert says that dioxin has to appear in the range of 13 to 20 parts per trillion to show health effects.

Milorganite has been a safe and effective lawn fertilizer for over 75 years…Not only does MMSD stand behind (it’s) safety, but so does the U.S. Environmental Protection Agency.

 Anne Spray Kinney

Executive Director, MMSD

Letter to the Editor #2

 As a scientist with a long history in soil research, I thought it necessary to respond to "Flush With Suspicion."

I have been on the soils faculty at the University of Wisconsin-Madison for more than forty years. For more than 25 years, I have been studying all aspects of land application of organic wastes. In 1992, I was named "man of the year" by the EPA.

In order to avoid being labeled a part of the corporate and government cabal that John Stauber, who the author quotes liberally, alleges is setting environmental policies, let me also add that I do not have any stock in a company producing sludge fertilizer nor have I received federal grants for research.

Regretfully, it would seem to me that the author was biased from the outset concerning the beneficial reuse of bio-solids. Critics of the industry like Stauber continually ignore scientific evidence that disproves their assertions. The author followed suit.

For 15 years, the Department of Soil Science at UW-Madison conducted research on land at Lakeland County Farm, near Elkhorn, where sewer sludge was applied. The intent of the study was to determine the long-term effect of sludge application on crop land. Soil samples were taken to depths of four feet to determine the nutrient and heavy-metal quantities. In addition, 24 wells monitored the effect of sludge application on groundwater.

The research…shows that with proper application, there is no hazard to the environment from sludge application. All analyses showed that the present heavy metals have been well within limits set by the EPA.

Sludge applied to the farmland had lead concentrations of 250 parts per million (ppm). According to EPA standards, this sludge could be applied annually for 178 years before exceeding permitted lead levels. Milorganite contains 78 ppm of lead; it could therefore be applied to the field for about 550 years before harmful lead limits were reached. These findings are hardly a cause for the alarm your article spreads.

The author also quotes a so-called "expert" who contends that plant tissues absorb excessive lead in the growing process. The research that we conducted dismisses that assertion as false.

A chemical analysis of the corn grain grown on land where sludge was applied was conducted annually to determine the corn’s lead levels. Chemical analyses were also done on corn grain grown on untreated land. In 1995, as in previous years, the lead level in the corn that grew on land where sludge was applied was the same as that found in corn from the treated area- less than 1 ppm. This shows that the sludge applications have had very little effect, especially compared with the normal lead levels occurring naturally in untreated soil.

Our research further showed that the application of sludge has had positive results. Soil tilth, water-holding capacity and crop yields improved in land where sludge was applied.

After 15 years of study, the findings speak for themselves. All of the results are available to the public. It is regrettable that the author apparently did not read them before he wrote the article.

 Arthur E. Peterson

Professor Emeritus, Madison