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Re: questions about co-mingled compost testing and then some...



Susan K. Snow wrote:
> 
> Does anyone know when in the analysis of co-mingled compost takes
> place?  Is it before or after the batteries and other materials in the
> mix begin to corrode?

The answer is YES, both before and after.
> 
> I've learned that a serious problem with analytical data from MSW
> compost is that it does not typically pick up these heavy metal levels
> in the analysis because the batteries are often still intact when the
> test is done, only to decompose over time and leak their toxic contents
> years later.

Who did you learn this from?
> 
> It is my understanding that mixed waste composting basically takes the
> commingled solid waste stream, commercial and residential, and processes
> it into smaller particles that are subsequently composted.

Yes, this is my understanding too.

  This is
> contrasted with source-separated composting which takes yard trimmings,
> food scraps, non-recycled paper, and commercial organics before they are
> commingled.

And more often than not, those people working with these products,
create a stinking mess, along with winged vermin and RATS(or at least
that's what they say on the WASTE list). They also say that the problem
can be solved by releasing Gehkos in the vicinity to eat the flies and
remove the food so the rats will have nothing to eat. You know what?
Most don't even test for plant or animal pathogens, chemical sprays that
can be on the green waste and food. At best, most of what we've seen has
been closer to a mulch than compost.
> 
> Mixed solid waste is high in paper and generally very dry, so that many
> companies use sewage sludge to provide moisture and nitrogen.

We also use septage, carwash trap waste with their solvents, fats, oils
and greases, petroleum sludge, landfill leachate and drinking water from
the hydrant.
> 
> Again, it is my understanding that hammermilling systems shred plastics,
> batteries, and such into little bits that may ultimately contaminate the
> compost.

We fully agree that hammermills are guilty of this nefarious act. Other
grinders however, are quite up to the task.

  Other systems, I've heard tell, twist plastics into tiny
> toothpick-like bits.  And, there are companies that sell dyes to color
> compost the desirable dark brown or black color characteristic of earth
> rich in organic matter.

This is a great example of people that don't know how to compost. If
you've got a machine though that twists plastic into toothpicks, this
may be the beginning of a REAL recycling market! 
> 
> Mixed waste composting will still have the full gamut of heavy metals,
> particularly metals from household batteries such as mercury, lead,
> nickel, cadmium, and zinc.

This is a good point that we would like to see you expound upon. Since
last July, you have of course been reviewing and verifying test
protocol, data, and samples for independent testing. We are looking
forward to your posting to all lists the results of your study. 

  I understand that PCB levels in mixed waste
> compost are often over 10 PPM as well, of which I and many states have
> concerns with levels over 1 PPM.

What did you think of our test results using MSW and landfill leachate 
that showed NONE DETECTED for ALL PCB isomers at ppb?

  Moreover, the USEPA does not regulate
> mixed waste compost!

If this is so, how come all states refer to existing standards set by
the EPA? I know there is no written regulation but in the 17 states
we've been involved with, most of which have no composting regs of their
own, they all follow multiple EPA standards. May I submit to you in REAL
WORLD time and order, that mixed waste/sludge composting, is regulated
more than landfills, incineraters and land applied sludges. You see,
with no written regs, they apply ALL the regs that govern the above to
composting.
> 
> The fact is that household batteries are in mixed waste, and that they
> are concentrated into a mixed waste compost.  It is also a fact that
> they are high in heavy metals, and that if they are not removed, they
> contaminate the compost to levels far in excess of even the most liberal
> guidelines, much less the EPA 503 sludge rules which are liberal
> compared with those in the Netherlands and Germany.

Anxiously awaiting your post to the list after you finish your review of
compost made from MSW/sludge/landfill leachate. We would like your fair
and unbiased opinion as to how it stacks up against the standards you
mentioned above.
> 
> We have learned from the Seattle Times series how hazardous wastes
> become fertilizer and the consequences of this action to farmers health,
> the health of the fields, and grazing animals.
> http://www.seattletimes.com/todaysnews/browse/html97/fert_070397.html

What does this have to do with composting???? If you test the sludge on
the front side, and it has been blessed for direct land application, I'm
not sure I follow your concerns about further processing in order to
meet or exceed the same standards you listed above.
> 
> How will the recycling of industrial or municipal solid waste into
> compost affect the health of farmers and their families, communities
> down wind, especially when dust blows or fields are burned, such as with
> sugar cane?

In the material that was offered to you, did you check directly with the
Health Depts who tested for airborn pathogens, heavy metals and all
organic compounds on the RCRA list? If so, please report to everyone
what you found.
> 
> Will the soil to dust to lungs or hands to mouth series poison our
> children, ourselves, as well as the food chain?

The Center for Disease Control can answer this question for you. You may
be surprised to learn that there are more pathogens on a circulated
dime, than are found in a quality compost operation. Don't tell me you
wash your money before you give it to the kids to buy candy?

  Does this sustain
> agriculture or sustain disposal of such materials?

An unequivocal YES! Both. Isn't it wonderful to be able to clean up the
waste and grow food at the same time! With >6% nationwide recycling,
it's great to be able to clean it up well below any regulatory limits,
while at the same time detoxifying the organics to be returned to the
earth from where they came. It just doesn't make sense to me to bury
them, burn them or spread them partially processed over the ground.
Standards based on science certainly need to play a fact in all
regulations and we agree they need to be tightened up. Standards,
definitions, and process and product certification is what we should all
be working for. You can't solve the problem with emotion, opinion and
the Chicken Little syndrome when you get bopped on the head with an
acorn, running and telling everyone you can " THE SKY IS FALLING"!!
 
 My concerns and
> others have been echoed in The Case for Caution.
> http://www.cfe.cornell.edu/wmi/PDFS/PDFS.html

We share the same concerns, but Cornell's report is not based on Zero
Tolerance. How do the test results that you are reviewing compare with
the Cornell concerns?

Phil Fredericks
http://www.uark.edu/~ecti/

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