This is in response to The Chronicle’s article on delisting of material classed as hazardous waste in Fire Mountain Farms storage units.
The material, biological solids from Emerald Kalama’s industrial wastewater treatment facility, was recycled as fertilizer in Lewis County for twenty-five years. First at the Centralia coal mine in their efforts to reclaim and restore the mine. Then Fire Mountain Farms land-applied it on their fields as fertilizer.
When Ecology changed their mind on what the rules were in 2014 it was reported as “unapproved material.” This was not really correct. This organic material was reviewed and approved by Lewis County Health Department six times that we have been able to document and recycled under solid waste permits. Ecology’s industrial section reviewed where this material was going and how it was being used annually. Ecology’s solid waste section reviewed and approved it every five years as part of Emerald’s Solid Waste Management Plan. And lastly Ecology’s biosolids section approved storage with the biosolids we managed.
The biological solids from Emerald were the best organic material we have recycled in our thirty years of operation across four states. It never contained any hazardous waste characteristics but was classified as such because of what might have been in it prior to treatment. It presented significantly less environmental and human health risk than application of cow manure or commercial fertilizer.
We had a choice of continuing our legal challenge to Ecology’s determination or process a delisting through EPA and haul to class D landfill. The legal challenge was going to be expensive and take three to five years. EPA and Ecology stated the delisting would take 18 months, but has taken twice that.
The delisting requires the material to be taken to a Class D landfill, land application is not an option. There are no landfills in Lewis County so it will be hauled out of county. Expected quantity to be hauled is 3500 to 4000 cubic yards.
Benzene waste code was attached to this material because Emerald used benzene in their lab experiments. Once experiments were complete, glassware was put on a rack to drain into hazardous waste container. But the next day they would wash the glassware and there may have been a molecule or two stuck to the glass and washed into the waste stream. This waste-water went to the treatment plant designed to break down an organic chemicals. In 25 years of analytical testing Benzene was never detected in the material we recycled.
Toluene was in the waste stream to the treatment plant but only detected in the material once in 25 years at 0.041 ppm, (parts per million). Compare that to biosolids where the national average is 83.2 ppm and required by state law to be recycled. Toluene is a natural organic chemical found throughout our environment from natural sources anywhere organic material is decomposing.
It is an insult to those of us who believe in environmentally sound recycling of our waste for the material in our storage units to be hauled to a landfill. But that is what our dysfunctional regulatory system is requiring.
Robert Thode
Fire Mountain Farms, Inc.
