It’s Time to Stop Spreading Sewage Sludge on Washington Farms Say Environmental and Food Safety Advocates

Report on the June 24 WA Dept. of Ecology Public Hearing on the Draft General Permit for Biosolids Management

and

An Article on Some of the History of Washington’s Anti-sludge Activism Over the Years

(Please note: This is a current issue where your input is needed before July 5 Comment period extended to July 12! Go HERE to read the Action Alert)

June 28, 2021, Tumtum, WA – In 1992, the Washington State legislature deemed “biosolids”to be a beneficial resource and mandated that the Washington State Department of Ecology promote its use on soil, including disposing of it on farms where crops for human consumption are grown and on forest lands. The practice is called “land application”.

“Biosolids,” is a made-up, euphemistic trade name. It’s the non-liquid sewage sludge byproduct of municipal wastewater treatment. After the sewage has been filtered, the treated watery effluent is discharged into rivers and natural water systems, but the sludge remains.

This year, the Department of Ecology proposes to re-issue a five-year Statewide General Permit for Biosolids Management which expired in September, 2020, but somehow remains in effect. This permit sets the regulations for Washington biosolids facilities, many of which are involved in the spreading of sewage sludge on farm and forest land. Ecology is accepting public comments on a draft permit until 11:59 PM July 5, 2021. Ecology held public hearings on the proposed Statewide General Permit for Biosolids Management on June 22nd and 24th, 2021.

On June 24, 2021 at 7:00pm Pacific time, the Dept. of Ecology held the second of two public hearings on the renewal of the five-year General Permit for Biosolids Management. The event consisted of an introduction by Emily Kijowksi, Biosolids permitting specialist with the Dept. of Ecology.Then there was a question and answer period followed by the formal public hearing.

The way the biosolids program within Ecology was described during the introduction was telling in the skillful use of language Ecology spokespeople used to try and normalize everything about spreading toxic chemicals on farmland. “In the state of Washington, biosolids are not handled as a waste.Instead they’re seen as a valuable resource,” said Kijowski, cheerfully. A la peanut butter sandwiches, you’re a valuable resource. Poof!

“We do know that people are concerned about emerging contaminants in biosolids that come from the products-- shampoos and soaps-- that we use,” said Kijowksi.

Alright, so what are “emerging contaminants?” The term “emerging contaminants of concern” is used in scientific and regulatory documents meaning chemicals, or families of chemicals, that have either only recently been discovered, or the ability to detect them wasn’t available before or the degree of their potential toxicity has been updated with newer research.

Obviously, emerging contaminants are not a current threat, right? I mean, they’re just emerging. And according to Kijowksi, we’re just talking about soaps and shampoos, after all. Most of us are concerned enough to buy the natural, biodegradable brands anyway. Kijowksi assured us that “Ecology utilizes ‘Chemical Action Plans’ to address emerging contaminants and potential exposures including the role wastewater treatment plants and biosolids play.“

So, what’s wrong with this rosy picture? The contaminants are not emerging. They’re here! The first EPA report on emerging contaminants of concern in the wastewater industry was way back in 2009. How long does it take the EPA or the Dept. of Ecology to recognize an “emerging” poison has become a clear and present danger?

That 2009 report looked for and found the following contaminants of concern in the wastewater at nine waste water treatment plants (WWTPs): Pesticides, Pharmaceuticals and Personal Care Products, Steroids and Hormones, Alkylphenols and Alkylphenol Ethoxylates (surfactants used in some detergents and cleaning products), Bisphenol A (the now much-eschewed white coating on the inside of food cans), and Polybrominated Diphenyl Ethers (PBDEs - components of commercial formulations often used as flame retardants in furniture and non-stick cookware – The current umbrella term for these “emerging” contaminants is “PFAS,” Per- and PolyFluoroAlkyl Substances that have been found in biosolids in other states where testing, unlike Washington state, has been conducted).

This list goes way beyond what soap or shampoo you use. It’s what your local auto body shop puts down its drain when it cleans up from painting car parts all day. It’s what your local hospital sends into the municipal sewer as it operates 24/7 keeping hundreds of people alive and well with an arsenal of medicines. It’s the hospitals’ out patients with their long lists of prescription drugs that come out in their poop. It’s the pesticide residues your local produce warehouse washes off the crops when they come in from the field.

The researchers back in 2009 wanted to find out two things: Which and how much of these chemicals of concern were present in the wastewater going into WWTPs and which and how much of them had been taken out of the treated water during the treatment process. It’s noteworthy that in many cases, the amounts of chemicals detected in the treated water were less than in the original untreated water. It works! But where did some of those chemicals go? They went into the sludge! The non-liquid by-product of waste water treatment. The stuff our food is grown in.

They found the contaminants of concern. They knew that some of them ended up in the sludge and yet, not one contaminant of concern has ever been added, by the EPA or by the Dept. Of Ecology using its much-touted Chemical Action Plan process, to the list of contaminants that sewage sludge must be tested for before it’s used on cropland. Not one.It’s still just the original nine heavy metals from when the rules were first promulgated. In 2018, the EPA’s Inspector General ruled that “…the EPA identified 352 pollutants in biosolids … [including] sixty-one designated as acutely hazardous, hazardous or priority pollutants in other[Federal] programs ... The EPA does not have complete risk assessment information on these pollutants; therefore the agency cannot say whether the pollutants are safe or unsafe when found in biosolids … ”

It’s not working. The pollutants are in the sludge. Ecology prefers to ignore them because nobody told them to test for them. Ignorance is bliss.

Only six people attended the June 24 public hearing. This is despite a vigorous grass roots effort to get word out about the public comment period on the biosolids permit on the part of organizers who hail from every corner of the state and in between: Morton Alexander of Davenport and Spokane, WA (Protect Mill Canyon Watershed), Doris Cellarius of Portland, OR (Sierra Club Wastewater Residuals Team), Ed Kenney of Yelm, WA (Preserve the Commons), Jean Mendoza of Yakima, WA (Sierra Club member), Chrys Ostrander of Tumtum, WA (Protect Mill Canyon Watershed) and Tim Pellow of Davenport, WA (Organic Farmer). With no budget to speak of, this group hoped nevertheless to generate a wave of public opposition to the practice of sewage sludge land-application. A press release was issued to over a hundred newspapers and media outlets in WA, but not one news organization picked up on it. An entreaty was sent to over fifty Washington environmental organizations that are of course very busy with other crises as temperatures soar into triple digits during this usually-mild Pacific Northwest June. Sludge is not an enticing issue, it’s hard to grab folks’ interest talking about sewage. But to advocates who want an end to land-application, every load spread on Washington soils is an unconscionable crime against nature-- the same nature that humans are not apart from.

The question and answer session revealed Ecology to be more vested in defending the normalization of toxic waste as fertilizer than to acknowledge there’s more to an iceberg than its tip.

One participant in the hearing asked, “how does the general permit address micro-plastics in biosolids and septage?” As our “plastic age” society continues manufacturing and tossing plastics like packaging and single-use items (not to mention everything else that's made of plastic), all that discarded detritus is being continually ground to dust like boulders into sand by the same inexorable processes of time. It never stops being plastic no matter how small it gets and it’s everywhere now, even, you guessed it, in biosolids. Kyle Dorsey, State Biosolids Program Coordinator with the Dept. ofEcology, knows that micro-plastics are a common contaminant found in sewage sludge.He knows about the studies that indicate micro-plastics in soil can have negative effects on soil microbiology, but to him, it’s enough just to answer the question saying, “right now, there aren’t any regulations or standards for micro-plastics in septage or biosolids.” Next question.

There aren’t likely to be any new regulations about micro-plastics in biosolids any time soon. Then they'd have to decide, well, how much micro-plastic pollution would be an acceptable amount? And we'll try not to put more than an acceptable amount of micro-plastics into the soils of our state for the next millennia or so. Quicker and cleaner would be to just stop dumping them on our farmland.

Next came the question, “what testing will be done of biosolids to ascertain toxics?”

Again, Dorsey was back with his usual refrain, “as far as testing goes, right now they’re required to analyze for the nine pollutant metals that EPA and the state both regulate … there is not a requirement to analyze for other potential pollutants.”

Obviously, that’s inadequate. There might not be a regulatory requirement. How about a moral imperative? We’re talking about polluting ecosystems. We’re talking about polluting our food.

During the question and answer, Dorsey admitted that if they ever were to test for an additional pollutant in biosolids, “PFAS has a good potential” to be the one, but he goes on to say (and this is going to sound familiar), “right now there is not an approved method for the analysis of PFAS in biosolids” and until there is one (who knows how long that will take), Washington is not testing biosolids for PFAS as other states have started to do.

In response to this claim about not testing for PFAS because there’s no “approved” way to do it, one questioner asked: “Other states have tested biosolids for PFAS. They are using testing protocols they seem to be happy with. Mr. Dorsey must be mistaken that there is no approved testing method. Could that be?”

Dorsey was again emphatic that Ecology ain’t gonna have the biosolids industry test for PFAS until hell freezes over (or until the EPA “approves” a testing method, whichever comes first). He said Ecology might start to test biosolids for PFAS using a“verified” testing method as part of the agency’s Chemical Action Plan for PFAS, but again he claimed there was not even a verified method, so testing has not begun.

It’s noteworthy here to refer to one of the sixty or so written comments that Ecology has received as of this writing and has posted on their website (the comments, by the way, at this writing, overwhelmingly favor ending the land-application of sewage sludge). This comment goes right to this point and is written by Denise Trabbic-Pointer, a Chemical Engineer with a BS and MS in Hazardous Materials Management and retired from a career in health and environmental management. She says:

Other states require that WWTPs use an isotope dilution method like Method 537.1, ASTMD7979-19M, or CWA Method 1600 for PFAS analysis of biosolids in the interim and until EPA completes its work. As with drinking water guidelines, states cannot afford to sit and wait for EPA to determine and put protections in place. The environment and people’s health are at significant risk by waiting when there are perfectly acceptable methods for analyzing for PFAS out there that are used globally. EPA’s website for current research and validation information [has this information]. Such methods are reliable for biosolids because they use an isotope-dilution method to measure sample extraction recoveries and correct for matrix suppression effects in the LCMSMS. Ecology should allow the use of these methods as do other states.

All this talk of hundreds of pollutants, testing protocols,“probabalistic risk-screening tools” and regulatory shortcomings seems to have prompted one person to ask a basic question.

It was a simple question. If our society did not choose to continue to dispose of biosolids on farm and forest land, would we need all of this? All this regulation? All these tests and risk assessments. Whole bureaucracies assembled around the practice? Would there be any risk that needed assessing?

Q: "One way to avoid needing to assess the risk of other pollutants present in biosolids when they are land-applied, in fact to zero out the risk, would be to end land-application. Isn't this true?"

A: "No."

Yes, go ahead and read that Q&A again.

The answer was provided by Kyle Dorsey, State Biosolids Program Coordinator, Dept. of Ecology. Kafka could have written the scene.

Here is a good example of the Dept. of Ecology displaying its preferred unscientific approach to the regulation of the land application of sewage sludge. It’s worth mentioning this myopic approach seems to violate the claims by the agency that it "is committed to considering how agency activities, including permitting, may adversely affect the environment, and health of people, and communities of our state." The unscientific approach is the result of politicians and sludge industry boosters, not scientists, directing the agency to promote the concept that spreading unknown quantities of poisons and pollutants on farmland is a "beneficial use" of sewage sludge. The science says it’s instead a very harmful use. Trump lost. Let's go with the science now.

The public hearing closed the evening with a single offering of oral testimony from Alan R. (Bob) Gunther, a forty-year resident of Chehalis. He lives right across the road from a state-licensed biosolids facility. “The odors have been horrific at this house,” he said. In fact, so horrific that a county commissioner who had been called to witness the smell, puked in the ditch as soon as he got out of his car. “I fought this biosolids issue in Lewis County for a long time.” Even so, says Gunther, “I’m not against applying biosolids in a proper manner,” but he goes on to say “I don’t believe in the past, we had been doing it in a proper manner.”

Something to consider is, there might not be a proper manner to dispose of municipal toxic waste on delicate soil feeding fragile people. Let’s quit while we’re ahead.

Tell the Washington State Dept. of Ecology one thing today. Tell them: The State of Washington must cease issuing any permit that allows the disposal of sewage sludge in any form on homes, farmland, forestland or parkland.

Send your comments now. Comment period extended to July 12!

https://swm.ecology.commentinput.com/?id=SpmPs

Chrys Ostrander
June, 2021
Tumtum, WA

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The following unfinished article was written by me in 2019, but since nothing at all has been done officially to respond to the science that clearly indicates land-application of sewage sludge is a practice that needs to end, the background, history and content of this unfinished article are still current. The science indicates there are too many knowns and unknowns regarding the potential toxicity of biosolids. The science tells us there is no justification for turning a blind eye and remaining full speed ahead with sewage sludge land-application. It’s time to make land-application of sewage sludge a closed chapter and let it recede into history along with many other “bright ideas” from the ecocidal 20^th Century.

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For Goldie.

Feb. 2019 - Next time you're at lunch with friends or colleagues, ask for a show of hands. Ask “How many of you know that some of this food we're eating might have been grown on municipal sewage sludge?' Your meal mates might not be pleased about this unpleasant turn in the conversation. Unfortunately, as unpleasant as it is, it's a subject none of us should ignore any longer. We tend to ignore it because literally and metaphorically we already flushed that toilet and it went “away.” But haven’t we learned the hard way, there is no “away?” Even as you read this, sewage sludge is being spread on agricultural land where food for people and for livestock is grown– not just in Washington state but all over the world. Many fields have had multiple applications. Forest land, too, is subjected to sewage sludge dumping.

Some at your lunch table might ask “What is municipal sewage sludge?”You dutifully explain that municipal sewage sludge is everything your tax dollars have been spent on taking out of sewage with the intent of cleaning the remaining water sufficiently that it can safely be returned to natural water systems. Sludge is what's left over. It's a foul amalgam of just about every natural and synthetic substance our industrialized society collectively pours or flushes down our drains. It’s impossible to know what any batch of sludge contains because no one can know what ended up in the sewers on any given day to begin with. It just so happens sewage sludge also has nitrogen in it. If you spread it on a field, the nitrogen will make the crops grow greener. Farmers can have sewage sludge applied to their soil at no cost– free fertilizer that makes crops grow– an attractive prospect for farmers. Organic farmers are not allowed to use sewage sludge on their soils, but the organic rule only pertains to the three years prior to the farm becoming certified organic. Three years is not enough time, in some peoples’ estimation, to feel comfortable about eating organic food grown on farmland that might have had sludge applied four or five years ago. There is yet no requirement to label foods that have been grown on sludge or foods from livestock raised on sludge-fertilized feed.

Sewage sludge has euphemistically been given the name “biosolids” by industry, lobbyists, legislators and regulators who promote as “beneficial” the dubious practice of disposing of sludge as purported “fertilizer” on farms, forests, parks, playgrounds and home gardens. Phrases like “Biosolids are the ultimate in recycling,” “Biosolids are a beneficial resource,” “Properly managed municipal sewage sludge is a valuable commodity and can be beneficially used in agriculture” and “land application of biosolids is a widely used, practical option” abound in almost any official government document on the subject. It is a dangerous fallacy. Sewage sludge has always been and continues to be a toxic solid waste entirely and uniquely inappropriate for release back into the environment. Sewage sludge is, in fact, so toxic that provisions for its responsible disposal should rival those of nuclear waste disposal. The term “biosolids” is not used in this article.

Some at your table will be shocked to learn about the land application of sewage sludge. These very same folks might have enlightened and progressive views on how other cultures have traditionally utilized human excrement as fertilizer and how that makes sense since it’s a way to recycle and reduce waste, but they might also understand that traditional human manure¹ and municipal sewage sludge are two entirely different things. After all, there is so much other stuff in sludge besides poop– everybody's disposables (commercial and domestic), drugs people have taken. Industrial waste, too. And that’s not all.

Others at your table might be incredulous. “Really?” they might ask.“That doesn't sound like a good idea. I can't believe it’s legal.” Not only is it legal, but the Washington state legislature,in a “finding,” promotes this use of sewage sludge as “beneficial” and forces the Department of Ecology to facilitate the spreading of sludge on farms and forests by having the agency administer the application process and the permits to do it. Private companies are paid by municipal sewage treatment plants (using your tax dollars) to dispose of treated sewage sludge on farmland.According to the EPA, there are 87 sewage treatment plants in Washington.² Ecology says about 380 facilities in Washington have been issued permits to handle, transport and dispose of sewage sludge under Ecology’s “biosolids” program that regulates how sewage sludge is applied to land. Kyle Dorsey, State Biosolids Program Coordinator​ at Ecology, estimates the state of Washington generates 120,000 dry tons of “biosolids” annually³. Another source reports 150,000 tons of sewage sludge is generated in King County alone. Dr. Richard Honour, a microbiologist and plant pathologist from Kenmore, WA and long-time critic of the land-application of sewage sludge, estimates upwards of 350,000 tons of sludge is produced annually in Washington based on his calculations of treatment plant inflows and out flows. According to Dorsey, the state is revising its numbers regarding how much sludge is produced after having found errors in their record-keeping but correcting the errors “hasn’t been the highest priority,” he says. Truckloads of sewage sludge are traversing the breadth of Washington state every day. When the mountain passes are closed in winter, they even have huge lagoons to store the sludge in until the roads clear. These lagoons, and others where sewage sludge is processed prior to land application, are spread out all over the state. They are themselves great sources of concern for the people who live near them. They have been known to leak and overflow during big rain events.

“It was about two years ago … [Fire Mountain Farms'] manure lagoon was in an area where it would have been less than a mile from my house and what Ecology had told me was that … the lagoon had sprung a leak.” Melody Allen of Chehalis, WA says she started losing an unusually high number of young male ducks and baby goats to miscarriage and still birth in late 2015 and her yearling male ducks also died. Earlier that year, Fire Mountain Farms (FMF), a sewage sludge hauling and disposal company, had resumed mixing sewage sludge in the nearby lagoon and spreading it on fields adjacent to her land.Because of a damaged fence, her goats escaped one day and were grazing on the field that had received the sludge. The following spring there were heavy rains and part of Allen’s land down-gradient from the FMF facility and sludge-treated fields flooded. Her goats and ducks had access to that standing water. Allen called Ecology and voiced her concerns and several officials from Ecology, including Peter Lyon and Kelsey Dunne, came out to her place. She says they confirmed that runoff from some of the treated fields could have flowed onto her land via a drainage ditch that connects several properties in the area. She says they told her that an illegal sludge mixture that had been stored and spread at the site in previous years had tested high for chromium and plasticizers(pthalates), but Ecology didn’t do any testing of her land or livestock. She says neighbors of hers also had excessive livestock losses in 2016. Allen said the people from Ecology were not very helpful. She sought help from the university and from goat experts. “Nobody had any information for me. It was frustrating,” she said. The company had resumed operations (processing sludge in the lagoon and spreading it on nearby and far-away fields) after being shuttered by Ecology for a year for having been discovered to be illegally mixing hazardous industrial waste that was not legal and spreading it on farm land along with sewage sludge that was legal to be spread.⁴ During the shut-down, FMF had to clean up this site and others and dispose of the illegal toxic mixture. “Records show that [Emerald Kalama Chemical, LLC, the source of the toxic industrial waste,] contracted with FMF to land apply their sludge beginning October 1995. Emerald's sludge was mixed with sewage sludge from other locations then land applied at numerous locations around the state or stored at three FMF locations in Lewis County [including the lagoon neighboring Ms. Allen’s home]. In 2014 Ecology issued an order that Emerald's sludge could no longer go to FMF because it is classified as a hazardous waste.”⁵ “When I first moved there and I had no idea what was going on,”says Allen, “I was looking on-line for hay and I saw that the owner of FMF happened to be right close to my house was selling, so I went and I had a friend help me and I purchased hay there. When I got home and was unloading it, it looked like it had chunks of dirt in it.”Neighbors she asked informed her the chunks were sewage sludge. I called [FMF] and I asked to return it and they let me return it.”After this episode, Allen always asks her hay suppliers if sludge had ever been applied. “Now we're looking at trying to find another place and I don't want to be anywhere near anything that [FMF is] doing. I was thinking about calling the Department [of Ecology] to see if they can give me a map or something where I can see a location where I don't have to worry about it. I lost so many baby goats…. I lost hundreds of dollars in goats.”

The land application of sewage sludge is steady revenue both for the municipalities who collect tax dollars to pay for sludge disposal, including the government workers whose job is to ready sludge for transport, and for the companies who handle, process and dispose of sewage sludge– revenue these stakeholders are not willing to give up without a fight if someone comes to the legislature seeking a ban on land application or other restrictive proposals. They have their influential trade organization, Northwest Biosolids⁶, that promotes land application, lobbies policy-makers to maintain the status quo, and spends copious resources trying to denigrate emerging science that indicates land application of sewage sludge is not as safe and benign as they would like to have you believe. NW Biosolids says they spend $200,000/yr. on sludge research more to their liking.NW Biosolids shares the same address as the King County Wastewater Treatment Division of the county government. Some say, even organized crime is involved with sewage sludge disposal in Washington state, it’s such a steady stream of dollars.

The science clearly indicates that we are poisoning our landscape with sludge– a fact regulators continue to deny. Runoff from fields and forests where sludge has been applied is polluting our state’s natural water systems.⁷ Sludge is contaminated with thousands of chemicals, but the Washington State Department of Ecology only tests for nine heavy metals and nitrogen. If levels of those pollutants in sludge are under the maximum allowable in the regulations, Ecology considers it “in compliance” and allows them to be spread on land. If sludge contains amounts is excess of the regulations, the sludge is classified as a hazardous solid waste and must be landfilled or incinerated. Some chemical pollutants known to be present in sludge can end up right in the food grown with it. This is called ‘plant uptake.’ You might have eaten some of that food, but you would not know it because food grown with sludge does not need to have that fact disclosed on the label. Other chemicals in sewage sludge might blow off a treated field in the wind and settle on neighboring crops, wash into adjacent fields or residences during rains or flooding, or seep into ground water.

Because of the very real risk to people (and livestock and wildlife) getting sick from sewage sludge dumping, Ecology also tests sludge for “indicator pathogens.” If levels of the indicator pathogens are below the regulatory limits,the sludge can be land-applied. Under guidelines set out by the EPA, Ecology looks for fecal coliform, Salmonella, enteric viruses (viruses that live inside other intestinal organisms and can be extremely poisonous), and Viable Helminth Ova (Helminths are parasitic worms). There are thousands of kinds of organisms living in sewage sludge, even in sludge that has been treated in ways to reduce those populations, but Ecology only tests for a handful– the “indicators.” The agency assumes that if sludge is treated and tests reveal that the populations of indicator organisms have been reduced by those treatments, “one can be reasonably assured that they are effective for most other viruses and bacteria.”⁸ That is a very big assumption.

Dr. Richard Honour has been researching sewage sludge since the early1970’s. He realized very soon how toxic sewage sludge really is and became actively opposed to the practice of disposing of sludge on farmland and forests. He is known for helping stop the wholesale dumping of sewage sludge in the Mt. Baker-Snoqualmie National Forest and for chasing sludge trucks on his mountain bike to document violations when they try to dump in the forest anyway.

Dr. Honour is critical of the “indicator pathogen” approach taken by regulators to monitor sludge destined for land application. He says it’s wrong to assume other pathogens are not present if indicator populations are at “allowable” levels. Sewage sludge, he says, is a good environment for organisms not only to grow and reproduce, but also to mutate and evolve. He notes that pathogen sampling of sludge occurs very soon after treatment and might show allowable levels of pathogens, but those pathogen populations can grow and reproduce, even at accelerated rates, once the sludge is applied to land where rain water and the warmth of the sun promote cell division. Dr. Honour says a good example is the reproduction of Methicillin-resistant Staphylococcus aureus bacteria (MRSA) in sludge which accelerates after land application. Honour and other researchers have cautioned that antibiotic-resistant pathogens could arise from sludge because some antibiotic-resistant genes have the capability of inserting themselves into other organisms. These and other illness-causing organisms are not tested for at treatment plants and biological processes continue after the sludge is dumped on land. There is no official testing of soils for pathogens after the sludge is applied.

Geologic time can be fast or slow but there is no stopping it. A big landslide is fast. The movement of tectonic plates is slow, usually. The movement of chemicals in sewage sludge applied to soil can also be fast or slow. Floods and heavy rains can wash sludge into neighboring fields or into creeks and wetlands. Even when sewage sludge is applied to land with low erosion potential, as the regulations require, eventually, pollutants dumped on soil in sewage sludge can enter water systems. That is the way of nature. You paid to prevent those pollutants from reaching aquatic resources with your taxes for waste water treatment. Spreading the sludge back onto the ground completely defeats that purpose and wastes your money.

Recently, Doctor Honour has been doing contract work consisting of sampling and analysis in the Yakima Valley. He is testing the runoff from Confined Animal Feeding Operations (CAFO’s, farms where tens of thousands of head of livestock are raised in confined areas) and sludge from King, Yakima and Benton Counties. He is sampling the soils and well waters along the Yakima River and the streams and drains that run into it for the presence of pollutants from sludge runoff and leachates. The list of chemicals he is testing for include dioxins, furans, lead, arsenic, nitrates. He says he is now able to track 17 dioxins and furans that start in King County’s waste water treatment plants, get dumped on the forests, row crops, vineyards, hops fields and orchards in the Yakima valley and, as a result of the rains and snow melts and the irrigation of crops mobilizing the pollutants in sludge, he is able to measure contamination from King County’s sludge in the streams and wetlands that feed into the Yakima River and on into the Columbia River waters.

One component of some sewage sludge that is not widely known is landfill leachate. This is the fluid that accumulates and emerges from beneath landfills. Dr, Honour calls landfill leachate “the most toxic material in the state.” He says typically, landfill leachate goes right into rivers. In the case of King County, it goes into one of King County’s treatment plants and is mixed with the sludge that goes onto the forest floors and farm soils of Washington state.According to Honour, landfill leachate is “extremely toxic and it has never been characterized. Not one agency-- not UW, not WSU nor any of them-- nobody knows what's in it. This is the basic question: Why on Earth would someone dispose of toxic waste on our lands, on our crops, in our waters, when they don't even know what's in it? They don't waste a moment trying to characterize any effluents or sludges and it's just unfortunate. As citizens we are victims and so we really need citizen activists to take up the issue and change things.”

Citizen action

As the sludge trucks spread their pollutant-laden cargos on the state’s soils, concerned citizens rise in opposition. Here is a sampling of other people and organizations who have been and continue to organize and advocate for an end to this dangerous practice.

Patricia Martin is the former Mayor of Quincy, WA who helped expose the illegal use of hazardous and other industrial wastes in fertilizer in the 1990’s. The dramatic story was chronicled in a Seattle Times investigative series “Fear in the Fields: How Hazardous Waste Becomes Fertilizer”⁹ and the book “Fateful Harvest, the True Story of a Small Town, a Global Industry and a Toxic Secret” (Harper Collins, 2001). Farmers in her area were suffering crop losses and livestock deaths. Hair samples taken from area farmers and their children showed elevated levels of aluminum, antimony, lead, arsenic and cadmium. Martin “and others began researching fertilizer manufacturing. They discovered that, as a result of landfill costs and the stringent environmental laws of the 1970s, a lot of heavy industries were recycling and marketing their hazardous waste as fertilizer.”¹⁰ Martin lead an investigative campaign that ultimately resulted in Washington’s “Waste-derived fertilizer law” that requires registration, testing and labeling of fertilizers containing industrial waste products. Martin has never felt the law went far enough. She says the regulations do nothing but enable the continuance of a practice that should have been banned. Martin co-founded a non-profit, Safe Food and Fertilizer¹¹, in response to the fertilizer crisis that helped build a strong statewide political campaign around the issue. More recently, Martin has become active advocating for a ban on the land application of sewage sludge. In 2013, she and Richard Honour assisted citizens of Ellensburg, WA successfully stop sewage sludge from being trucked into their area by Spokane-based waste handling company PacifiClean Environmental. Martin, along with Dr. Honour and Christian Stalberg (Sewage sludge Action Network¹²), formed Save Our Soils dedicated to “the abolition of land-disposed toxic waste to preserve our air, food, soil and water, and to protect human and environmental health.” Martin is also President of the Northwest Toxic Communities Coalition¹³ which is comprised of non-profit groups from EPA Region 10 areas(western US) which address local hazardous substances and environmental health issues and serves as a conduit of relevant information and resources to its members. In 2016, together with the Sierra Club of Washington,¹⁴ Martin and her colleagues had legislation introduced that would have required labels on foods grown with sewage sludge, but there wasn’t sufficient clamor from constituents for the bill to make it out of committee– a failing resulting from lack of organizing capacity on the part of these very grassroots organizations, not the merits of labeling sludge-grown food.

Lincoln County:
In 2016, some neighbors in a rural canyon in eastern Washington became alarmed by a proposal to spread sewage sludge on farmland adjacent to and up elevation from their properties where residents utilize creek, spring and well water for drinking, household use and crop irrigation– water from the same watershed where the sludge was proposed to be disposed of. The neighbors organized an informal citizens’ committee they call Protect Mill Canyon Watershed¹⁵ and did everything they could think of to stop the sludge from being dumped. They attended Ecology’s public hearings, enlisted science advisors and submitted pages of written testimony. Eventually they published a website describing their struggle, issued press releases, organized a letter writing campaign, utilized social media and had newspaper articles written about their issue. Due to their efforts and the publicity that ensued, the farmer agreed not to apply sludge to the lands immediately adjacent to the canyon where these people live. The scale of the win for the committee was significant. The total acreage that would have had sludge applied was reduced from the original 887.45 acres to 157.77 acres in the final permit. The original application indicated sewage sludge would have been applied less than one mile from Mill Canyon residents’ farms, gardens and wells and less than half a mile from the source of a private spring used for drinking water. The 157.77 acres is five miles away from the canyon. Apparently, it’s too small an area to be worthwhile for the sludge hauling company, Fire Mountain Farms of Onalaska, WA, to bother with since according to the farmer who owns the site, to date, no sewage sludge has been disposed of there either. For their efforts and success, Protect Mill Canyon Watershed received the 2019 Water Guardian award from the Sierra Club’s Upper Columbia River Group at the group’s Winter Waters Celebration in Spokane in March. Protect Mill Canyon Watershed continues to advocate against the land application of sewage sludge in Washington. They are calling for a moratorium on the approval by Ecology of permits for the spreading of sludge and legislation to ban the land-application of sewage sludge, to get safety warning labels on all consumer products that contain biosolids and to label foods that were grown using sewage sludge.

Yelm:

While Fire Mountain Farms LLC is not the only sludge-slinging company in Washington, when their name pops up related to new sewage sludge permit applications, people take note. Part of that stems from FMF’s checkered reputation as the subject of multiple investigations by Ecology and several enforcement orders resulting from serious violations of sewage sludge regulations. FMF has applied for a permit to spread municipal sewage sludge on 180 acres of land only 1000 feet away from the Nisqually River in Yelm, WA. A local organization in Yelm, Preserve the Commons,¹⁶ is leading the struggle against yet another ecological onslaught by the sewage sludge disposal industry. In an unusual move for a grassroots organization, they have leveled a credible threat of legal action to prevent biosolids in Yelm in the event Ecology grants FMF the permit.

Part of that credibility is due to the vocal opposition of the Nisqually Tribe as well as the Thurston County Commissioners to a recent action taken by the Department of Ecology regarding the FMF permit application. The Tribe and the County take issue with one aspect of the sewage sludge permitting process that has also angered and perplexed many anti-sludge crusaders over the years. Each sludge-disposal applicant must fill out and submit what’s known asa “SEPA Checklist” as part of the permit application. SEPA stands for State Environmental Policy Act. According to Ecology, SEPA “helps state and local agencies identify environmental impacts likely result [sic] from projects and decisions”¹⁷ It’s highly questionable that the process as administered by Ecology ever really helps identify environmental impacts. It is fundamentally flawed because it is the applicant who checks off the criteria on the checklist, not trained scientists from Ecology. If the applicant checks the boxes the right way, Ecology will make an official “determination of non-significance” (DNS) which frees the applicant from requirements to do more thorough, often expensive,environmental impact assessments. After Ecology makes the determination of non-significance, which it does with rubber-stamp efficiency for nearly every sludge application that comes its way, the agency quietly schedules a public comment period of about 45 days on the DNS. So, in practice, Ecology approves an applicant’s SEPA checklist without much investigation into the applicant’s accuracy or completeness and relies on the general public during the comment period to identify weaknesses, omissions or falsifications in the presentations made by sludge vendors. Usually, the public is too distracted with other matters to scrutinize every DNS Ecology mass produces, but not this time. This time there’s Thurston County and the Nisqually Tribe to contend with.

After review of the SEPA checklist, Ecology issued a determination of non-significance (DNS) for the Thurston County site on Dec. 17, 2018. Ecology announced a public hearing on FMF’s biosolids application for January 24, 2019 and began taking written comments for a period that ended on Feb. 13..

In a letter dated February 13, 2019, the Thurston County Commissioners/Thurston County Board of Health sent an official comment letter to Peter Lyon, Solid Waste Management Program, SWRO Section Manager, Washington State Department of Ecology that said, in part “Thurston County staff have reviewed the biosolids application for Fire Mountain Farms’ Mid-Mountain Site and believe it is incomplete and that additional information is needed before a decision can be rendered on the permit. We believe the Determination of Non-significance (DNS) should be withdrawn and that thorough site evaluation, including ground water monitoring, is needed to assess the risks to public health and the environment posed by this proposal.” The letter went on to list nine specific concerns the County has with the site and the application and eleven recommendations it made to ecology to address the concerns.

The Nisqually Tribe was able to fire off a detailed and scathing rebuke to Ecology’s DNS during the comment period. At the same time, the Tribe hired Jay Manning as its lawyer as it prepares its response to Ecology’s DNS. Manning, with the Cascadia Law Group of environmental attorneys, was formerly Director of the Washington State Department of Ecology and Chief of Staff during the term of former Gov. Christine Gregoire. The Tribe’s letter to Ecology was written by David A. Troutt, Natural Resources Director for the Nisqually Indian Tribe, it says in part “based on our review of available materials, the Tribe believes that the treaty protected rights of the Nisqually Indian Tribe will not be sufficiently protected through this DNS and proposed action, that the DNS violates the State Environmental Policy Act (SEPA) and that the proposed DNS is inconsistent with the State’s commitment to protect and restore salmon and Southern Resident Killer Whale … FMF failed to disclose in its SEPA Checklist a distinguishing characteristic between its current locations and this one: The Nisqually watershed is home to fall Chinook and steelhead—two species listed as “threatened” under the Endangered Species Act … This failure to disclose critical environmental information contradicts the precautionary principle of impact avoidance and the Tribe’s treaty rights and violates SEPA’s most fundamental requirement of disclosure of potential adverse environmental impacts.” The letter also states that “the FMF DNS fails to consider or even mention the possible presence of PBDE’s or other toxic materials in the biosolids they seek to land apply in the immediate vicinity of the Nisqually River.”Unfortunately, those are among the thousands of chemicals Ecology ignores as it stubbornly clings to testing exclusively for the nine heavy metals that are the only pollutants besides nitrogen they are bound by regulations to monitor through sludge sampling. But the Tribe’s letter serves to point out how inconsistent Ecology’s entrenched stance on toxic sludge contaminants is with other state and federal environmental laws and with Washington Governor Inslee’s emergency Orca task force which recommends, in part, that Washington Department of Fish and Wildlife, Washington Department of National Resources and Washington Department of Ecology strongly apply and enforce existing habitat protection and water quality regulations. The Tribe’s letter points out that “when Ecology receives‘significant new information indicating a proposal’s probable significant adverse environmental impacts,’ such as the Tribe has presented here, it must withdraw its DNS [or] if it ‘was procured by misrepresentation or lack of material disclosure,’” both of which conditions seem to have been met with FMF’s errant checklist. The comment period on the application and DNS ended on Feb. 13. It remains to be seen what Ecology will do with that information it received in the comments.

Ed Kenney, retired, lives in Yelm. He is an active member of the Preserve the Commons group that is organizing against sludge facilities and dumping in Thurston County. An active member of the Nisqually Delta Association and Nisqually River Council, Kenney has spent three decades working with others to keep the Nisqually River clean and its fish runs healthy. His activism around the sludge issue in Yelm began 30 years ago when he was part of Nisquallly Valley Neighbors which organized in 1988 to defeat a similar sludge proposal.

Regarding the current proposed expansion of FMF sludge disposal sites to Yelm and the DNS that Ecology issued, Kenney says the department of ecology “really made an error which I think shows the way this whole biosolids program has been going. You know, they give that 5-year permit [to biosolids disposal companies] and then they just give a DNS and it doesn’t seem like they really do much research out on the site because key facts that even a cursory search on Google gave us the first day, they [Fire Mountain Farms] didn’t know.” Kenney complains Ecology isn’t trying hard enough to scrutinize claims made by sludge vendors in their SEPA checklists. He says biosolids regulators “still believe in this whole thing I heard about clear back in the eighties— ‘sludge magic.’ Somehow the sludge, all these chemicals, get together and fight it out and they’re not significant anymore. It’s ridiculous.”

Kenney points out that the Nisqually River constitutes 50% of the South Sound’s water. “Governor Inslee just ordered all agencies to make sure Orca’s are protected. This doesn’t show any consideration of Orcas.”

Kenney says the timber group that bought this property did so with the understanding that they wanted to spread biosolids there, but the property has an underlying easement with the USDA. Two members of the Preserve the Commons committee “found out that there is a USDA deal with the previous owner of the property. The USDA gave them over $1million dollars not to cut any trees or spread any sewage on it. That by itself, we may be able to put this off until they come up with a million dollars.”

This isn’t the first sewage sludge dust-up to involve Yelm and Ed Kenney.

A 1988 debate over proposals to bring sewage sludge dumping to Yelm was linked to a landmark constitutional court case that brought fundamental change to the way King County and its municipalities structure their governments. Yelm residents were successful in stopping a sludge operation, although their campaign didn’t succeed in tempering Metro’s zeal for promoting the dumping of sludge on land. Here is an excerpt from an historical essay about the“Municipality of Metropolitan Seattle”, commonly known as Metro, an intergovernmental corporation whose original 1958 purpose was to build and manage infrastructure for municipal waste water treatment and later expanded into mass transit.¹⁸

“Metro was designed to provide regional solutions for the problems of King County's fast-growing metropolitan area. In 1958, after rejecting a proposal for an agency with authority over a range of issues, voters approved a plan authorizing Metro to deal with a single pressing problem -- wastewater treatment. Over the next decade, the agency designed and built a coordinated sewer system that ended discharges into Lake Washington, dramatically improving water quality, and began treating sewage entering Puget Sound.”

But when Metro started promoting the spreading of sewage sludge on farm and forest land, it spurred powerful citizen opposition during an era when the environmental movement was passionate, well-organized and effective.

“Beginning in 1972, Metro worked to recycle biosolids -- treated sewage sludge,which is rich in nutrients -- that other sewer agencies burn or place in landfills. Metro sold biosolids to be used in making soil compost and to enrich soil in parks, and spread or sprayed them on forest land belonging to Weyerhaeuser and other forest-products companies.When Metro acquired its own forest land for recycling biosolids in the late 1980s, it triggered fierce opposition from residents who did not want sewage sludge sprayed near their homes.

“Actress Linda Evans and self-proclaimed channeler J. Z. Knight, who lived near Metro forest property in Yelm, Thurston County, supported a well-organized campaign that deterred Metro from using the Yelm site. Valerie Cunningham, from Cumberland in southeast King County, not only led the opposition to spraying biosolids in a forest near her home, but soon became the lead plaintiff in [an ACLU] lawsuit that brought Metro to an end [forced its reorganization].”

Kenney said that during the Nisquallly Valley Neighbors campaign between 1988 and 1991, they tested the sludge that Metro was spreading. “Some of us struggled, clear back in ’88, against the Seattle proposal” to spread sewage sludge around Yelm. “We won.It wasn’t called Biosolids in those days, it was called sludge. We did some assessments of sludge and we found 93ppm of cadmium and over1000ppm of lead … We had a march in Seattle, we had several hundred people come up in buses to the little town of Yelm.”

Partially as a result of this citizen activism, rules were put into place, such as requiring some industries to divert toxics away from municipal wastewater sewers (pre-treatment) and changing the pH of waste waters to lower lead concentrations, that helped reduce some of the toxic load of the sludge “The pre-treatment does get out a lot of the metals as the sludge haulers claim, but the organics are still there and some of these new flame retardants, which have been banned in our county— there are some pretty high numbers in sludges.”

The current maximum allowed level for Biosolids are 85ppm cadmium and840ppm lead. Any sludge tested having higher than those concentrations of cadmium or lead, or any sludge having higher concentrations of the metals listed in the following table, cannot be spread on land and must be landfilled or incinerated.

pollutant	ceiling concentration19 milligrams per kilogram (dry weight basis)
Arsenic	75
Cadmium	85
Copper	4300
Lead	840
Mercury	57
Molybdenum	75
Nickel	420
Selenium	100
Zinc	7500

 

There are no provisions in the regulations for the testing of soils for heavy metal build-up after sludge has been applied; only for nitrogen. Despite regulations governing how to estimate how many times sewage sludge can be applied to any one piece of land before the build-up of metals in the soil exceeds the regulatory limits,without soil testing, there’s no way to know if the complicated estimation process is working. Many farmers who apply sewage sludge might also be applying commercial waste-derived fertilizers and soil amendments that themselves contain heavy metal contamination. Until recently, Ecology didn’t factor in the potential of redundant applications of heavy metals from two different sources (sludge and waste-derived fertilizer), each governed by its own separate set of regulations. Such redundancy could have potentially doubled the soil concentrations of heavy metals in some locations. And nowhere in the regulations is any provision made for testing the sludge or the soil for the thousands of organic compounds and other pollutant contaminants known to exist in sludge.

Increasingly, the Department of Ecology is finding itself compelled to make adjustments to the way it regulates the land application of sewage sludge in response to legitimate concerns brought to its attention by informed citizens who submit comments to the agency when these biosolids permit hearings come around. Many people who hear this kind of thing wonder why Ecology isn’t more proactive to reduce risk to the public from biosolids rather than relying on the citizenry to do the due diligence.

Mason County:

One 2015 case where citizens exposed poor sludge management regulations and caused Ecology to attempt some reform involved BioRecycling’s North Ranch/Webb Hill facility near Union in Mason County. In the early2000’s, groundwater near fields where BioRecycling was disposing of sewage had been testing at unacceptably high nitrate concentrations.Local opponents of sludge disposal were able to get TV cameras and Ecology officials out to a site to document where BioRecycling was spreading sludge on a very rainy, muddy winter day. It forced Ecology to recognize “that applying biosolids during times of high precipitation unacceptably increases the risk of leaching and surface runoff of nitrates,” prompting Ecology to develop a “Biosolids Application Management Matrix” for the North Ranch facility “that precisely describes what standards Bio Recycling will be held to and what the consequences will be if they fail to do so.” Kelsey Dunne, Ecology permit manager has said that the Biosolids Application Management Matrix developed in response to that episode is a new tool that Ecology developed with the hope that the agency will be able to reuse it in some form with other facilities.²⁰ In other words, Ecology was forced to acknowledge weaknesses in the Washington State Biosolids regulations, brought to its attention by informed, active citizens, that very well might have resulted in excessive exposure of the public and the environment to biosolids. Ecology acknowledged it needs tighter regulations that should be applied broadly among the various sludge disposal operations in the state. The citizens in Yelm were successful in forcing Ecology to rescind the Determination of Nonsignificance it issued for the Fire Mountain Farms operation. Only because the public turned the spotlight on the agency’s failure to correctly police its own SEPA checklist process. Now that entire process is called into question across the state.

Some activists say these and other serious flaws in the way sewage sludge is regulated in Washington expose the public and the environment to known risks and constitute a public health crisis that can’t wait to be addressed. Some advocate for an immediate moratorium on issuing any new permits for sludge disposal in the state until a thorough rewrite of sewage sludge regulations that incorporate current science is completed. They acknowledge that a thorough revision of sludge regulation has a good chance of resulting in the outlawing of land application altogether, so it would make very good sense for government and industry to prepare for transitioning to alternative disposal means sooner rather than later.

The Mason County activists won when they were able to get Ecology to put prohibitions on the spreading of sewage sludge during the rainy season, but they were not happy with the alternative plan that Ecology and BioRecycling came up with. What was BioRecycling supposed to do with all the sewage it gets during the rainy season that it can’t spread? They decided they want to build a septic lagoon to store it until the growing season when it can be applied (and it is assumed plants will take up enough of the nitrogen to keep it from seeping into groundwater). It’s a scheme that comes complete with its own set of public health risks and ecological threats.

Mason County citizens have been vocal in their opposition to the proposed construction of BioRecycling's new sewage sludge “filtrate” storage lagoon at North Ranch. One group, “the No Sewer Sludge Alliance is a Mason County organization acting as a united body of individuals opposing processing, storage and application of sewage into biosludge for sale to the general public or for storage and application to feed pasture for the purposes of livestock feed for raising of meat for human consumption.”²¹ In May, 2018, the Hood Canal Improvement Club, an 80 year-old community organization held an informational meeting on the proposal featuring a presentation by Dr. Honour. One public comment was sent to Mason County Commissioners from Victor Cummings whose family has owned and lived on a 40-acre former-homestead on Webb Hill for almost 60 years, portrays the frustration: “Out of necessity we and our neighbors rely solely on our excellent well water, so we are all understandably alarmed about findings of elevated nitrates as well as likelihood of other untested-for toxins in the soil and ground water from the existing sewage spraying operation … Now--an 18,000,000-gallon proposed sewage “lagoon” accepting and spraying toxic sewage waste from surrounding counties and cities? Seriously, who in Mason County was asking for this? The only possible path to an answer to this question is simply, ‘Follow the money.’ This project is now being railroaded--without proper science or public process--into Mason County over the urgent and informed objections of many hundreds of people throughout the county.”²² “A Facebook group called ‘Mason County Septic Lagoon,’ composed of people who oppose the project, attracted 500 members in two days and has now [May 31, 2018] reached more than 1,600 members.”²³

In a letter to Mason County residents, the Department of Ecology wrote"there has been a biosolids and septage management site at Webb Hill since 1986, originally operated by a company named Solganics,and later by Bio Recycling Inc. Bio Recycling accepts septage - the solids removed from septic tanks and portable toilets during regular maintenance. Bio Recycling is the only commercial site on the Olympic Peninsula that accepts this material. The facility has also accepted treated sewage from wastewater treatment plants..."

What about tests finding pharmaceuticals and other chemicals in groundwater on the site?

In late 2017, Bio Recycling tested two monitoring wells on its site fora number of common pharmaceuticals and chemicals found in personal care products, such as antibiotics, sunscreen and artificial sweeteners. This testing was done in response to questions from a neighboring property owner about water quality impacts.

Bio Recycling shared the test findings with Ecology. Ecology's biosolids staff discussed the test results with the other agency personnel and with the Washington State Department of Health. They determined that the test results were consistent with what we would expect, given the material Bio Recycling accepts, and that these levels do not pose a threat to human health...²⁴

 

1 See: The Humanure Handbook
http://humanurehandbook.com/

2 EPA Enforcement and Compliance Facility Search
https://echo.epa.gov/facilities/facility-search/

386,000 land-applied in 2019 per Emily Kijowski, June 24, 2021.

4 State of Washington Department of Ecology Administrative Order Against Emerald Kalama Chemical, LLC And Fire Mountain Farms, Inc.. Administrative Order No. 10938.

5 Ibid.

6 NW Biosolids “Northwest Biosolids is advancing environmental sustainability through the beneficial use of biosolids.” https://nwbiosolids.org/
 

7 Phone call with Dr. Richard Honour, 02/17/2019. Based on his unpublished sampling analysis he is currently performing in the Yakima Valley watershed.

8 Basic information: Pathogen Equivalency Committee, USEPA Biosolids Program
https://www.epa.gov/biosolids/basic-information-pathogen-equivalency-committee/

9 Fear In The Fields -- How Hazardous Wastes Become Fertilizer -- Spreading Heavy Metals On Farmland Is Perfectly Legal, But Little Research Has Been Done To Find Out Whether It's Safe

By Duff Wilson, Seattle Times Staff Reporter, July 3, 1997
http://community.seattletimes.nwsource.com/archive/?date=19970703&slug=2547772

10 Ibid.

11 Safe Food and Fertilizer
https://safefoodandfertilizer.org/

12 Sewage Sludge Action Network
https://sewagesludgeactionnetwork.com/

13 Northwest Toxic Communities Coalition
https://nwtoxiccommunities.org/

14 Sewage Sludge Free Washington, Sierra Club of Washington, North Olympic Group.

https://www.sierraclub.org/washington/north-olympic/sewage-sludge-free-washington

15 Protect Mill Canyon Watershed
http://www.protectmillcanyon.org/

16 Preserve the Commons
http://preservethecommons.org/

17 Overview of Washington State Environmental Policy Act (SEPA), Department of Ecology.
https://ecology.wa.gov/Regulations-Permits/SEPA/Environmental-review/SEPA-guidance/Basic-overview

18 Metro: Municipality of Metropolitan Seattle By Kit Oldham, Posted 6/18/2006, HistoryLink.org Essay 7813

https://www.historylink.org/File/7813

19 173-308-160 Washington Administrative Code, Biosolids pollutant limits.
https://app.leg.wa.gov/WAC/default.aspx?dispo=true&cite=173-308&full=true

20 Ecology grants Webb Hill facility final coverage, grace period, by Arla Shephard Bull, Mason County Life Published 8:51 a.m. PT Nov. 6, 2017

https://www.kitsapsun.com/story/news/local/communities/mason/2017/11/06/ecology-grants-webb-hill-facility-final-coverage-grace-period/823665001/

21 Letter to Mason County Planning from

22 Public Comment by Victor Cummings sent to Mason County Commissioners, Department of Community Development, April 8, 2018.

23 Residents opposed to Mason 'septic lagoon' despite state paving way for approval, Arla Shephard Bull, Special to Kitsap Sun. Published May 31, 2018.
https://olyopen.com/2018/06/01/residents-opposed-to-mason-county-septic-lagoon-despite-state-paving-the-way-for-approval-kitsap-sun/

24 Department of Ecology letter to Mason County Residents dated May 29, 2018.