1)      There have been many health complaints, noxious odor complaints and environmental concerns associated with sludge exposure.

2)       Every year there are over 24,000 wet tons of Class “B” sludge applied in Loudoun County.  This is applied to approximately 1,000 acres.

3)        Under current State regulations, Loudoun County cannot impose an outright ban on sludge spreading, but other legal remedies may be available.

4)       According to the Loudoun County Health Department, 45% of the sludge spread in Loudoun County is from other states. Some communities ban all sludge, some ban Class "B" or have far more restrictive regulations than Virginia . Sludge which does not meet stricter requirements elsewhere often ends up in Virginia and Loudoun County .

5)      Only the application of Class B sludge needs a permit. Class A and EQ do not require permits. We do not know the amount of Class A and EQ spread in the County.

6)       The total net economic benefit of "free" Class "B" sludge to farmers is under $150,000/year. 

7)       While sludge may have some initial beneficial qualities as fertilizer, it also contains pathogens, heavy metals and toxins that can be harmful to human health, livestock, wildlife, and the environment. Long-term use can result in problems like crop reduction and toxin build-up.   While crop reduction affects only the farmer, toxin build-up can affect the farmer and his neighbors.  Incorrectly processed or stored sludge can destroy crop output.

8)       Sludge emissions include the immediate airborne release as well as long-term pollution to streams and groundwater (the sole water supply for most of western Loudoun County).

Existing Legal Regulations (and recommendations) in Virginia affecting Loudoun County

9)   Virginia Biosolids Regulations 
http://www.biosolids.state.va.us/regulations.htm

    10)  Loudoun County Sludge Ordinance, Land Application of Biosolid 
http://inetdocs.loudoun.gov/health/docs/ehrural_/landapplication/office2k/office2k.htm
           Note: The Loudoun County Ordinance is now obsolete.

    11)  Ellen Z. Harrison, Director,  Cornell Waste Management Institute Center
           for the Environment 
           Recommendation:  Virginia Sludge Ordinance   3/31/03

Below are a few comments regarding our experience in dealing with Health Department record keeping:

           "While one would expect clear and accessible records are a requirement 
           for a regulated industry, it is not a requirement for the sludge program. It
           is axiomatic that regulators must have relevant, accurate and timely
           information about the industry they regulate. As just one more proof of 
           the failure of effective public regulation of the land application of sewage
           sludge in Virginia, one need only point to the state of record keeping.
           Records should be available on the State and local level for all sludge
           activities. This is not the case. Complete sets of records are not kept in
           both locations. Those that are kept, are thrown into cardboard boxes in
           no particular order. Attempts to locate important records is extremely
           frustrating and sometimes not possible. Public access is deemed a
           nuisance and barely tolerated."                Loudoun NATS
      

In the images below, cows are being feed Class "B" (Lime) sludge in Florida.

            
  (Click to open new window and enlarge)