Test Protocol for Synagro Experiment, Official Web Site for The City and County of Honolulu

I. Title of Project: Analysis of Synagro Biosolid Pellets and Pellets Applied to Hawaiian Soil for Detection and Growth of Salmonella

III. Directive for this Study: The Resolution (Honolulu City Council Resolution No.03-193, FD1, dated 1/28/04). This resolution grants a permit to the Department of Environmental Services (ENV) and Synagro Company for the construction of a new in-vessel bioconversion facility at the Sand Island Wastewater Reclamation Treatment Facility. However, a condition of this permit is described in section B of this Resolution as follows: “No building permit for construction of the bioconversion facility (Facility) shall be issued until receipt by the Department of Environmental Services (with a copy to the Council) of a letter from Dr. Roger Fujioka of the University of Hawaii WRRC stating that he has successfully performed an appropriate U.S. EPA test from EPA Guidance Document (EPA/625/R-92/013) Environmental Regulations and Technology: Control of Pathogens and Vector Attraction in Sewage Sludge) designed to test survivability of viable helminth ova, enteric virus, salmonella or fecal coliform upon Class A biosolids pellets from Synagro’s Pinellas County Florida Plant. One of the tests shall involve Hawaiian soil application testing and determination by WRRC as proven by the test(s) necessary to show that public health will not be substantially adversely affected by the land application of biosolids pellets similar to those to be produced at the Facility. Public comments on the test protocol shall be reviewed by WRRC within 14-20 days of the Council’s receipt of the test protocol from WRRC”.

IV. Charge to Roger Fujioka and Expectations of Directed Experiment. Roger Fujioka of Water Resources Research Center (WRRC), University of Hawaii, has served as an expert scientist in Hawaii to advise both the ENV and the City Council on the proposed use of the Synagro system to treat the sewage sludge produced by the Sand Island Wastewater Reclamation Facility as well as plans to apply the treated sludge (pelletized biosolids) as a form of soil amendment and fertilizer. His involvement started on Dec. 4^th when he was invited by Frank Doyle of ENV to participate in a discussion on needed tests to be done, which was the basis for Council’s decision on Dec. 3^rd not to approve the ENV application to use the Synagro System. Since that day, he has participated in most of the key discussions leading to the Resolution, which was completed on Jan. 28, 2004. During these discussions he had agreed to assist ENV and the Council in resolving their differences to include conducting the necessary but valid tests. However, Fujioka was not present when the wording of the Resolution was agreed upon and makes two important comments on the wording of that resolution. First, the wording does not provide details on the test to be done and relies on Fujioka to conduct the appropriate test. Second, the statement “ One of the tests shall involve Hawaiian soil application testing and determination by WRRC as proven by the test(s) necessary to show that public health will not be substantially adversely affected by the land application of biosolids pellets similar to those to be produced at the Facility” is an over-statement of what can be achieved by the expected testing. The results of a single experiment as directed by the Resolution cannot be used to make sweeping conclusions on public health effects related to land application of Synagro biosolids. In this regard, EPA has been conducting experiments for decades to address this very issue and has concluded that Class A biosolids can be applied to land without endangering public health. However, many people in Hawaii, including some in the Council have not accepted this conclusion by EPA. In summary, the sweeping generalization as stated in the Resolution raises the false expectation by people who read the Resolution that the tests as directed by the Council will result in definitive conclusions.

Having stated the problems in the wording of the Resolution, Fujioka recognizes that language in a Resolution must be general in nature and does not conform to scientific language and scientifically validated expectations. Based on his understanding of the problem in Hawaii and the oral guidance he has received from key people in ENV and the Council, he will accept the directive of the Resolution to use his best scientific judgment in designing and completing the most effective experiment to provide evidence to address two questions. First, has the Synagro pellet been sufficiently treated to disinfect all pathogens, including salmonella bacteria? Second, will salmonella bacteria multiply when Synagro pellets are applied to a soil sample from Hawaii? The realistic expectation of conducting this experiment is that a UH scientist will be conducting tests on the Synagro pellet and will be available to address the problems of using the Synagro pellet for land application in Hawaii. The results of the tests should provide data, which will better define the public health concerns as it relates to application of Synagro pellets to Hawaii soil environments.

V. Authorization and Agreement for Fujioka to Conduct the Tests as Stated in the Resolution. Mr. Frank Doyle, Director of ENV sent an email to Dr. James Moncur, Director of WRRC, requesting that Roger Fujioka of WRRC complete the testing as described in the Resolution. The official version of this letter is dated March 05, 2004. Fujioka agreed to meet the following sequences of events in that email:

Two-week period for City Council, ENV and Synagro to provide comments and seek clarification on the submitted protocol.
March 8. Expected time to initiate experiment.
March 25. Expected time for experiment to be completed.
March 31. Report of results to be sent to City Council, ENV, and Synagro.

VI. Goals, Objectives and Guidelines Used for this Proposed Study. As stated earlier, the goal of this study is for Fujioka to use his best scientific judgment in designing and completing the most effective experiment to provide evidence to address two questions raised by the Council. First, has the Synagro pellet been sufficiently treated to disinfect all pathogens, including salmonella bacteria? Second, will salmonella bacteria multiply when Synagro pellets are applied to a soil sample from Hawaii? To design a scientifically valid experiment, relevant information and advice must be obtained from experts from various disciplines. The experts consulted to obtain relevant information are listed in Section VIII. Some information took longer to obtain and were not entirely definitive. One such important information is the length of time it will take for the Synagro pellets to release their nutrients once they are applied to soil. This information is relevant in designing an experiment because it is the release of nutrients from biosolid pellets that has been purported to stimulate the growth of fecal bacteria as well as pathogenic salmonella in soil. Under field conditions it has been reported that biosolid pellets release their nutrients slowly over several months. However, Jack Recheigl from University of Florida reported that under laboratory controlled experiments, and when ground up pellets were used, most of the nutrients were released from the pellet during the first month. Based on these kinds of information, the following steps will be taken to ensure that the nutrients will be released from the biosolid pellets during the period of the experiment. First, the size of the biosolids will be reduced to increase their contact to soil. This will enhance subsequent degradation and release of nutrients by physical, chemical and microbial activities in soil. Second, Synagro pellets will be added to soil at the higher recommended dose of 40 lbs per 1,000 sq feet and five times that dose. Third, stimulation of growth of natural soil microorganisms (culturable heterotrophic bacteria) will be used as evidence that nutrients have been released from the pellets. Fourth a nutrient addition test will be included. In this test, readily available nutrients (nitrogen, phosphorus) in the form of Hoagland Solution will be added to soil samples. Fifth, the experimental design for all soil test will be to maintain adequate soil moisture, temperature and pH to enable multiplication of soil microorganisms throughout the experiment. For the soil experiments, samples will be analyzed for microbial growth every other day over 12 days. Two types of soil, (Waimanalo, Molokai) used to grow crops were selected for this experiment.

The specific objectives of the experiment are as follows: 1) To determine the selected microbial load (total coliform, E. coli, salmonella group of bacteria, culturable heterotrophic bacteria) in the pelletized biosolid produced by the Synagro plant in Florida. 2) To determine the selected microbial load in two kinds of soil (Waimanalo, Molokai) on Oahu. 3) To determine whether any residual salmonella (pathogen) in the Synagro pellet or in the two soil samples will multiply when the pellet is added to the two soil samples and kept at 25 °C for up to 12 days. 4) To determine whether any residual salmonella in the two soil samples will multiply when readily available nutrients in the form of Hoagland solution are added to the soil samples and kept at 25 °C for up to 12 days.

VII. Experimental design and testing methods

2. Salmonella. MPN method described in Standard Method. Salmonella group of bacteria is the most likely sewage-borne pathogen to multiply in soil.

3. Culturable Heterotrophic Bacteria: MPN method as described by Standard Method. This assay will culture indigenous soil bacteria whose natural habitat is the soil environment. These bacteria are expected to be the most likely to grow under these experimental conditions. Their extensive growth will be taken as evidence that nutrients have been released into the soil by either the Synagro pellet or the Hoagland solution.

B. Waimanalo and Molokai soil. These soil samples will be obtained from areas used for farming. Samples with adequate moisture, indicating healthy soil microbial population will be used. For experiment (up to 12 days under laboratory conditions), soil moisture (about 35% moisture), temperature 25 +/- 2 °C and pH (6.0 – 7.5) will be controlled to enable bacteria to grow.

C. Synagro pellets from Florida plant. The size of pellets will be reduced from approximately 2 mm diameter to less than 0.5 mm. This will allow for more even mixing of pellet into soil, maximum exposure of pellets to soil and will allow for maximum release of nutrients from the pellets. Application rate will include the higher recommended rate of 40 lbs per 1,000 sq feet and five times that dose. These steps will ensure adequate release of nutrients.

VII. Experimental design and testing methods

VIII. Experts Consulted