THE SLUDGE HITS THE FAN

In addition, a 1994 investigation by the US General Accounting
Office found that “the full extent of the radioactive contamination of
sewage sludge, ash and related by-products nationwide is unknown.”
Most of the radioactive material is flushed down the drain by hospitals,
businesses and decontamination laundries, a practice which
has contaminated at least nine sewage plants in the past decade. [12]

In 1977, EPA Administrator Douglas Costle estimated that by 1990
treatment plants would be generating 10 million tons of sludge per
year, a thought that “gives us all a massive environmental headache.” [13]
Today there are about 15,000 publicly-owned wastewater
treatment works in the United States, discharging approximately 26
billion gallons per day of treated wastewater into lakes, streams and
waterways. Before treatment, this wastewater contains over a million
pounds of hazardous components. Sewage plants use heat, chemicals
and bacterial treatments to detoxify 42 percent of these components
through biodegradation. Another 25 percent escapes into the atmosphere,
and 19 percent is discharged into lakes and streams. The remaining 14
percent — approximately 28 million pounds per year —
winds up in sewage sludge. [14]

Once created, this sludge must be disposed of in some fashion.
The available methods include: incineration (which releases pollution
into the air), dumping into landfills (which is expensive, and
often lets contaminants leach into groundwater), and ocean dumping
(where it has created vast underwater dead seas). A fourth
approach — gasification, using sludge to generate methanol or energy
— is favored by EPA’s Hugh Kaufman as the “most environmentally
sound approach, but also the most expensive.” [15] A fifth approach —
using sludge as plant fertilizer — was considered hazardous to health
and the environment until the 1970s, but it has the advantage of being
inexpensive. As budget concerns mounted in the late 1970s, the EPA
began to pressure sewage plants to adopt the cheapest method available
— spreading sludge on farm fields. [16]

A Rose By Any Other Name

To educate the public at large about the benefits of sludge, the EPA
turned to Nancy Blatt’s employer, known today as the “Water Environment
Federation.” Although its name evokes images of cascading mountain
streams, the WEF is actually the sewage industry’s main
trade, lobby and public relations organization, with over 41,000
members and a multi-million-dollar budget that supports a 100-
member staff. Founded in 1928 as the “Federation of Sewage Works
Associations,” the organization in 1950 recognized the growing significance
of industrial waste in sludge by changing its name to the
“Federation of Sewage and Industrial Wastes Associations.” In 1960,
it changed its name again to the cleaner-sounding “Water Pollution
Control Federation.” [17]

In 1977, Federation director Robert Canham criticized the EPA’s
enthusiasm for land application of sludge, which he feared could
introduce viruses into the food chain. “The results can be disastrous,”
he warned. [18] By the 1990s, however, Federation members were running
out of other places to put the stuff. The Federation became an
eager supporter of land farming, and even organized a contest among
its members to coin a nicer-sounding name for sludge.

The proposal to create a “Name Change Task Force” originated
with Peter Machno, manager of Seattle’s sludge program, after protesters
mobilized against his plan to spread sludge on local tree farms.
“If I knocked on your door and said I’ve got this beneficial product
called sludge, what are you going to say?” he asked. At Machno’s
suggestion, the Federation newsletter published a request for alternative
names. Members sent in over 250 suggestions, including “all
growth,” “purenutri,” “biolife,” “bioslurp,” “black gold,” “geoslime,”
“sca-doo,” “the end product,” “humanure,” “hu-doo,” “organic residuals,”
“bioresidue,” “urban biomass,” “powergro,” “organite,” “recyclite,”
“nutri-cake” and “ROSE,” short for “recycling of solids
environmentally.” [19] In June of 1991, the Name Change Task Force
finally settled on “biosolids,” which it defined as the “nutrient-rich,
organic byproduct of the nation’s wastewater treatment process.” [20]

The new name attracted sarcastic comment from the Doublespeak
Quarterly Review, edited by Rutgers University professor William
Lutz. “Does it still stink?” Lutz asked. He predicted that the new name
“probably won’t move into general usage. It’s obviously coming from
an engineering mentality. It does have one great virtue, though. You
think of `biosolids’ and your mind goes blank.” [21]

According to Machno, the name change was not intended to
“cover something up or hide something from the public. . . . We’re
trying to come up with a term . . . that can communicate to the public
the value of this product that we spend an awful lot of money on
turning into a product that we use in a beneficial way.” [22]

James Bynum, director of an organization called “Help for Sewage
Victims,” saw a more sinister motive behind the name change. In
1992 the EPA modified its “Part 503” technical standards which regulate
sludge application on farmlands. The new regulations used the
term “biosolids” for the first time, and sludge which was previously
designated as hazardous waste was reclassified as “Class A” fertilizer.
“The beneficial sludge use policy simply changed the name from
sludge to fertilizer, and the regulation changed the character of sludge
from polluted to clean so it could be recycled with a minimum of
public resistance,” Bynum wrote. “Sludge that was too contaminated
to be placed in a strictly controlled sanitary landfill was promoted
as a safe fertilizer and dumped on farmland without anyone having
any responsibility. . . . There is a real concern for everyone, when
a bureaucrat can write a regulation which circumvents the liability
provisions of the major Congressional mandated environmental laws,
by simply changing the name of a regulated material.” [23]

A few months after the debut of “biosolids,” the Water Pollution
Control Federation dropped the words “pollution control” from its
own name and replaced them with “environment.” At the group’s
64th annual conference, WEF President Roger Dolan explained the
reasoning behind the latest name change: “We don’t control pollution
anymore; we eliminate it. To the outside world, our people came
to be seen as pollution people. In today’s world, the word `control’
just isn’t good enough.” In fact, this claim was largely rhetorical. “Virtual
elimination has not been achieved for one single persistent
toxic,” said E. Davie Fulton, a Canadian official involved in sagging
efforts to clean up the Great Lakes. [24]

So You See, It Is Good For You

In 1992, the Water Environment Federation, describing itself as a
“not-for-profit technical and educational organization” whose “mission
is to preserve and enhance the global water environment,” [25]
received a $300,000 grant from the EPA to “educate the public” about
the “beneficial uses” of sludge. “The campaign will tie in with the
Federation’s ongoing efforts to promote use of the term `biosolids,’ “
reported the Federation’s December 1992 newsletter.

“Beneficial use” is the industry euphemism for the practice of
spreading sludge on farm fields. Even before the current push, sludge
has been applied to soil for decades. Milwaukee’s sewage sludge has
been dried and sold nationally for almost 70 years as “Milorganite,”
a lawn and garden fertilizer. In 1982, the state of Maryland banned
Milorganite after it was found to contain high levels of cadmium, a
heavy metal.[26] In recent years, other cities have followed Milwaukee’s
example offering varieties such as “Nu-Earth” from Chicago,
“Nitrohumus” from Los Angeles, and “Hou-actinite” from Houston. [27]

Milorganite and other commercially-marketed sludge products
usually carry labels warning that they should not be applied on food-producing soil. But most consumers and journalists are unaware that
tens of thousands of acres, from Midwest dairy land to Florida citrus
groves and California fruit orchards, are already routinely “fertilized”
with byproducts of industrial and human sewage. In theory, this
approach harkens back to the time-honored natural system of composting.
Of course, the organic farmers of previous centuries didn’t
have to worry that their “night soil” contained a synergistic soup of
dioxins, asbestos, DDT and lead that could contaminate themselves,
their groundwater, and their food.

“I am appalled at what I would term the `total disregard for human
health’ and the fact that the Environmental Protection Agency is
actively promoting and is, in fact, lulling communities throughout
the United States into initiating programs for the composting of
sewage sludge,” said Melvin Kramer, an infectious disease epidemiologist
who has been researching the issue since the late 1970s. He
says the EPA’s plan for sludge disposal poses “a significant health
hazard to the population in general, but especially to the elderly,
children, and the infirm, both in terms of nuisances as exemplified
by excessive putrid odors and minor allergic reactions . . . to life-
threatening diseases.” [28]

Some environmental activists with Greenpeace and the Citizens
Clearinghouse on Hazardous Waste have warned about the dangers
of sludge, but most groups have bought into the argument that sludge
farming is the least offensive way to deal with the problem of waste
disposal. Some groups even support sludge farming. During the
1970s, these environmentalists worked for passage of the Clean Water
Act. Now they find themselves in the awkward position of defending
its consequence — huge mountains of poisonous sludge that need
to be put somewhere. Sarah Clark, formerly of the Environmental
Defense Fund, claims that sludge farming “is the best means of
returning to the soil nutrients and organic matter that were originally
removed. It is recycling a resource just as recycling newspapers or
bottles is. If the right safeguards are taken, it can be environmentally
protective and even beneficial.” [29]

Unfortunately, “the right safeguards” are not being taken. Joseph
Zinobile, a risk management consultant with the Pennsylvania-based
Waste Risk Education Fund agrees that “human waste residue can
be applied to land in a safe manner.” The problem, he says, is that
“it is often not done safely at this time. The primary reason that it is
not always done safely at this time is a nearly complete subjugation
of safety concerns by the US EPA in favor of their concern over solving
their `disposal dilemma.’ ” [30]

Dr. Stanford Tackett, a chemist and expert on lead contamination,
became alarmed about sludge on the basis of its lead content
alone. “The use of sewage sludge as a fertilizer poses a more significant
lead threat to the land than did the use of leaded gasoline,”
he says. “All sewage sludges contain elevated concentrations of lead
due to the nature of the treatment process. . . . Lead is a highly toxic
and cumulative poison. Lead poisoning can cause severe mental
retardation or death. It is now known that lead interferes with the
blood-forming process, vitamin D metabolism, kidney function, and
the neurological process. From the standpoint of lead alone, sludge
is `safe’ only if you are willing to accept a lowered IQ for the young
children living in the sludge area. And what about the other toxins?” [31]

Tackett is appalled “that the government would take the citizens’
money and use it in such an odious way. The land spreading program
for sewage sludge is a scam of enormous proportions, driven
mainly by money,” he charges. “The high sounding justifications such
as `sludge is a beneficial resource’ and `sludge is just as safe as
manure’ are clever excuses designed to fool the public. . . . In truth,
only one to three percent of the sludge is useful to plants. The other
97 to 99 percent is contaminated waste that should not be spread
where people live. . . . Land spreading of sewage sludge is not a
true `disposal’ method, but rather serves only to transfer the pollutants
in the sludge from the treatment plant to the soil, air and ground
water of the disposal site.” [32]

One Hand Washes the Other

Tackett also condemns the “selective science” and “manipulation
of research money” used to rationalize sludge farming. “Millions of
dollars have been made available through EPA and other federal,
state and local agencies, for `beneficial use’ research. Toxicologists,
public health scientists and medical researchers have not had a
similar money pot available to study the potential dangers and
adverse health effects of sewage sludge. It is no wonder then that
the scientists selected by the EPA to serve on sludge advisory committees
are the `beneficial use’ researchers, and the only research
reports they deem acceptable for the purpose of adopting new
sludge spreading regulations are from the `beneficial use’ studies. . . .
The claims now made for `sludge safety’ sound eerily like the
earlier claims that `DDT is perfectly safe’ and `asbestos is a miracle
fiber that poses no danger at all.” [33]

In fact, the researchers, advocates, regulators and practitioners of
sludge farming are a closely interwoven group. Dr. Alan Rubin, for
example, served as chief of the Environmental Protection Agency’s
sludge management branch where he oversaw the development of
new regulations for land farming of sludge fertilizer. In 1994 the EI’A
loaned Rubin to the Water Environment Federation, while continuing
to pay half of his salary. Now Rubin the regulator is a full time
cheerleader for “biosolids.” Together he and Nancy Blatt are a team,
barnstorming the nation, meeting the press, schmoozing with politicians,
and debating critics. [34]

Dr. Terry Logan, a professor of soil chemistry at Ohio State University,
is another sludge advocate who has conflicting roles and interests. He
co-chairs the US EPA Peer Review Committee, a group
described by the EPA as “the best scientific talent and data assembled”
to help develop recent federal regulations that eased restrictions on sludge
farming. Logan also receives $2,400 per month as a
paid consultant and board member of the N-Viro International Corporation,
which has developed a patented process for converting
sludge into fertilizer by mixing it with dust from concrete kilns and
heat-drying it to kill germs. N-Viro, a client of Hill & Knowlton PR,
handles sludge treatment and disposal for sewer plants in New Jersey,
Minnesota, Ohio and Harsham, England. At the recommendation of
Logan’s committee, the EPA promulgated a modification of its “Part
503″ regulations that increased the allowable heavy metals in sludge
fertilizer. At the same time that Logan was involved in developing
the new, relaxed regulations, he held stock options in N-Viro whose
value could have dropped substantially if he had recommended
stricter requirements. [35]

Despite its many customers, N-Viro is in shaky financial condition.
Since 1993, the value of its stock has plummeted from $9.50 to
$1.50 a share. [36] One of its major problems has been the slow rate
of acceptance of land farming of sludge. The company is banking
on sludge regulator/promoter Alan Rubin to help overcome political
and PR obstacles so the company and industry can flourish. In
1994, Dr. Logan was named “man of the year” by the EPA, and
N-Viro, along with the Compost Council and the Rodale Institute,
received a $300,000 grant from the US Congress to help promote
its product. [37]

Criticism of EPA’s sludge policy has emerged from within the EPA
itself. William Sanjour has spent 16 years supervising hazardous waste
management programs. In 1990 he testified before the Georgia State
Senate on the “close working relationships formed with government
officials who are lured by the huge profits made by the waste management
industry. . . . There are many examples. . . . The power of
this industry to influence government actions is further enhanced by
the ease with which government regulatory officials are hired by the
industry. Over thirty state and federal officials have gone over to the
waste management industry in the southeast region alone including
a former EPA Regional Administrator in Atlanta. This practice extends
even to the highest levels of government. William Ruckelshaus, a
former Administrator of EPA and a close advisor to President Bush,
is CEO of the second largest waste management company in America.
He is credited with getting William Reilly, the present Administrator,
his job. . . . With this kind of influence and power, trying to
have a meaningful hazardous waste reduction program . . . is, frankly,
like trying to have a meaningful egg laying program after you’ve let
the fox into the chicken coop.” [38]

Our Sludge Doesn’t Stink

The EPA’s PR strategy for sludge was first outlined in a 40-page report
published in 1981 with a classic bureaucratic title: “Institutional Constraints
and Public Acceptance Barriers to Utilization of Municipal
Wastewater and Sludge for Land Reclamation and Biomass Production”
(imagine the acronym: ICPABUMWSLRBP). It warns that there
is an “irrational component” to the public’s attitude toward sludge,
including the widely-held notion that sludge smells bad: “It is difficult
to say to what extent odors emanating from sludge may be imagined.
However, it is the most common ground voiced by opponents in taking
action against land application projects.” In addition, “the growing
awareness about hazardous wastes and the inadequacy of their past
disposal practices will inevitably increase public skepticism.” [39]

While national environmental groups are usually no threat to
sludge farming, ICPABUMWSLRBP warns that projects may be
blocked by small local groups. Citizens who “feel their interests
threatened” may “often mount a significant campaign against a project.”
To counter this opposition, ICPABUMWSLRBP advises project
advocates to choose a strategy of either “aggressive” or “passive”
public relations. “Aggressive public relations” uses “glossy brochures
describing the project; open public meetings; presentations to specific
interest groups; presentation of films about similar projects; local
media coverage; technical education campaigns for the public and
in schools; establishment of a hotline for quick response questions;
and presentation of material stressing community benefits from the
project.” This approach, however, entails some risk: “A highly visible
public relations campaign . . . would in itself alarm and harden opinion
against the project.” In some communities, therefore,
ICPABUMWSLRBP recommends using “a passive public relations
campaign” to introduce sludge farming. A “passive” campaign makes
“little effort to reach out to particular segments or constituents of the
public. Rather, information about the project [is] made available for
individuals and groups which made the effort to obtain it.” This
secretive approach works best in small, rural communities “where
the application site is relatively isolated.” [40]

Kelly Sarber, a PR specialist in sludge crisis management, offered
her advice to other sludge marketers in a 1994 article titled
“Campaign Tactics: How to Strategize for Successful Project Development.”
The article warns that “public opposition has taken its toll”
on the sludge industry, which is experiencing “new, unprecedented
levels of interest, discomfort and complaints from the public..” To
counter these stirrings of community self determination, Sarber uses
tactics that she attributes to sludge opponents, such as “creating
photo opportunities, using a small number of vocal people to make
it appear like a majority, and undermining messages through counter
messages. . . . Countering the opposition without letting them determine
the approval process is the most important goal of a good campaign
manager. . . . This is called `controlling the debate.’ ” [41]

To control the local media’s coverage of the sludge issue, Sarber
recommends “a pre-emptive strike” to “get positive messages out
about the project before the counter-messages start.” She advises
sludge companies to identify and develop “several advocates or opinion
leaders” who can persuade other community members that they
“have taken the time to learn about the project and are comfortable
with it from an environmental standpoint.” They should be careful,
however, to avoid seeking early public support from local politicians,
because “a local community can be very unforgiving of a political
leader believed to have come to some type of conclusion about what
is best for the rest of the community before anyone else has heard
about the project. . . . A better positioning of the politician is to provide
education . . . while promoting the importance of the community
having `an open mind’ about the project.” [42]

Sarber is especially proud of her PR work in 1991-1992 for Enviro-Gro
Technologies, a sludge hauler now operating under the name
Wheelebrator. Sarber quietly approached business leaders and politicians
in the rural town of Holly, Colorado (population 1,400), which
Enviro-Gro had targeted as a dumping-site for New York City sludge.
When the proper groundwork had been laid, the pro-sludge campaign
struck like a blitzkrieg, quickly deploying “third-party” scientific
advocates to assure local citizens of the safety of sludge. Sarber
bragged about stealing the media spotlight at a public meeting organized
by opponents of sludge farming: “[Pro-sludge] advocates were
placed directly on stage and demanded participation in the forum,
which was granted. In addition, local advocates promoted the project
through general grandstanding activities in the audience. . . By
targeting the press during the event, the spin of the story changed
from an opposition meeting to one which showed that several farmers
wanted to find out how they could get more biosolids. Rather
than allowing the opposition to have a press `success’ in blasting the
project the media stories show support, with only a few dissenters.
When Governor Romer of Colorado came out to throw a shovel full
of New York City biosolids on a field, it was apparent that the initial
siting of the project had been successful.” [43]

Flush With Victory

Kelly Sarber has fought on the front lines of several other sludge
campaigns involving sludge disposal for New York City. In addition
to Enviro-Gro, her employers have included the New York Organic
Fertilizer Company and Merco Joint Venture, the major players in
the Big Apple’s billion-dollar sludge disposal game. The city has
signed contracts totalling $634 million with Merco and New York
Organic, in exchange for which the two companies have committed
to haul away over a thousand tons per day of city sewage sludge. [44]

New York has an especially messy history of waste disposal problems.
In addition to sewage, the city used to dump its garbage into
the ocean, and is famous for the 1987 “garbage barge” that was forced
to sail for nearly 3,000 miles in search of a place to dump its cargo.
New York’s practice of dumping sludge into the ocean first came
under fire from the EPA in 1981, prompting the city to file a lawsuit
arguing that ocean dumping was environmentally preferable to land-based
alternatives. In 1985, however, the EPA found that New York’s
ocean dumping site, located 12 miles offshore, had suffered heavy
degradation, including bacterial contamination of shellfish, elevated
levels of toxic metals, and accumulations of metals and toxic chemicals
in fish. Federal legislation in 1987 forced New York to close
the 12-mile site and begin dumping at a new site 106 miles from
shore. Shortly afterwards, fishermen near the 106-mile site began to
complain of decreased catches and diseased fish. In 1988, Congress
passed the Ocean Dumping Reform Act, requiring a complete end
to ocean dumping by June 1991 and imposing fines of up to $500,000
per day if New York failed to comply. [45]

As the city scrambled to meet the deadline, Merco and New York
Organic used both “aggressive” and “passive” PR to persuade small
towns in other states to take their sludge. Their efforts met with mixed
success. Alabama residents shut off all attempts to export New York
sludge to their pastures, and Merco’s efforts in Oklahoma failed
in four towns. In Thomas, Oklahoma (population 1,244), news of
Merco’s interest triggered what Thomas Mayor Bill Haney described
as a “civil war.” Within two weeks after the plan went public, state
officials had received over 200 angry letters from Thomas residents. [46]
The public outcry prompted the Oklahoma legislature to vote
unanimously for a moratorium, signed into law by the governor on
April 17, 1992, prohibiting land application of sludge that contains
“significantly higher” concentrations of heavy metal than sludge produced
in the state.” [47]

“It’s a scary thing at first to take New York’s waste and spread it
on the land that supports you,” Sarber admitted. “In fact to some
people it’s the most scary thing they can think of. But after a little
education most people eventually come around.” [48]

In her work as an “environmental media consultant,” Sarber faced
questions that went beyond issues of nitrogen content and pH balance.
She was called upon repeatedly to deny allegations that
her employers were engaged in environmental violations, influence
peddling and organized crime.

Merco came under criticism, for example, when it was discovered
that one of its partners, Standard Marine Services, belonged to
the Frank family barge empire, a group of companies labeled by the
state as New York Harbor’s worst polluter. Standard Marine owed
over $1 million in taxes and judgments and was forced to drop out
of Merco after it was unable to get financial bonding. [49]

In 1992, Newsday reported that New York deputy mayor Norman
Steisel, whose duties included oversight of the city’s sludge program,
was a partner in New York Organic Fertilizer Co., and noted that
the brother of New York Senator Alfonse D’Amato was a partner in
the law firm that negotiated New York Organic’s contract with the
city. A probe was launched to investigate possible influence-peddling,
and company spokesperson Sarber promised that “we will
cooperate fully.” [50]

A few months later, Alphonse D’Arco, a former boss for the
Luchese crime family, testified during a June 1992 murder trial that
two Merco partners — the John P. Picone and Peter Scalamandre &
Sons construction firms — had paid $90,000 a year in payoffs to the
Luchese family. [51] In separate but corroborating testimony, D’Arco and
Gambino family turncoat Salvatore (“The Bull”) Gravano also
described Picone’s involvement in a sweetheart deal involving bid-rigging
and manipulation of New York labor unions to benefit
the Gambino, Genovese, Luchese, Colombo and Bonanno crime
families. [52] Picone and Scalamandre were unavailable for comment,
but Sarber was brought out to state that her employers “have had
no business or personal relationships with any of these people.” [53]

In 1994, Newsday reported that Merco was using the Cross Harbor
Railroad to ship its sludge even though Salvatore Franco, a major
Cross Harbor investor, had been banned for life from the waste
industry in New Jersey. In response to a reporter’s inquiry,
spokesperson Kelly Sarber said Merco had no idea that Franco was
involved with Cross Harbor. [54]

Walk Softly and Carry a Big Slick

On December 10,1991, Newsday reported that “stealth is New York
City’s new weapon in its war on sludge. The city has decided to
make a secret of where it plans to ship tons of the sewage gunk
beginning next month. It hopes to secure permits for sludge disposal
in some towns before the local gadflys can get all riled up about
it. Thus, the names of towns where New York Organic Fertilizer . .
has applied for sludge permits are strictly hush-hush. Only town
officials have been told. . . . The city . . . wants to avoid a political
circus such as the one in Oklahoma, where three towns rejected
another New York plan for sludge because they feared it could carry
everything from AIDS to organized crime with it.” [55]

Bowie, Arizona (population 400), was one of the communities
targeted with “passive public relations” in 1992, when Bowie resident
Ronald K. Bryce received state approval to apply 83 million
pounds per year of New York sludge on his cotton fields. The rest
of the community found out about the plan when someone overheard
a conversation in a restaurant in the summer of 1993, shortly
before the first deliveries of sludge were scheduled to begin. Bryce
had received his permits without public hearings or even public
notice. Arizona Daily Star reporter Keith Bagwell sought an explanation
from Melanie Banon, a solid waste official with the Arizona
Department of Environmental Quality. “Our approval was based on
guidelines which are like rules but without the public comment,”
Barton said. She added that sewage sludge had been applied to crops
in Arizona at least since 1978. “But we still don’t have rules,” Barton
said. “Only guidelines. We have no ability to enforce them legally.”

Exposure of the sludge plan created a public furor, and the state
hastily scheduled “informational” public meetings, but their explanations
failed to allay fears. “Who knows what will happen in 20
years — we don’t want another Love Canal,” said Rhonda Woodcox,
vice-president of the Bowie Chamber of Commerce. [56]

Further inquiry by Bagwell discovered that over 100 million
pounds of sludge from Arizona’s own Pima County sewers had also
been spread on area farms since 1983. EPA regulations had enforced
limits for only one metal and one chemical in the sludge, even
though Pima County sewage treatment superintendent Donald Armstrong
admitted that the county sewer system received wastes from
about 1,500 industries, roughly half of which use toxic chemicals.
Test data showed that the Pima County sludge contained over 80
“priority pollutants,” including dioxin, phenol and toluene, along with
high levels of cadmium, lead and other toxic heavy metals.

Actually, the Arizona sludge was relatively clean compared to the
stuff being shipped in from New York. “Sludge from San Diego, Los
Angeles or New York you have to look at carefully — it’s different in
highly industrialized areas,” said Ian Pepper, a soil and water science

professor involved in studying Pima County’s sludge-use program.
“The metal content of Tucson sludge is relatively low,” Pepper said.
“There isn’t as much impact from heavy industry.” [57]

“I’ve been eyeball deep in sewer sludge disposal on agricultural
land for years,” said Kirk Brown, a soil science professor at Texas
A&M University. “Some sludge you could use for 50 years before
having problems — not New York City’s.” Brown’s assessment was
confirmed by Ian Michaels, a spokesman for the New York City
Department of Environmental Protection, who estimated that the city
had 2,000 unregulated companies discharging industrial waste into
the sewers, but admitted that his department had “no way of knowing
how many . . . there are.” Michaels said half of New York’s 14
sewage treatment plants were built in the 1930s, and only 11 meet
modern treatment standards. [58]

Despite this information, Ronald Bryce began spreading New York
sludge on his farm in Bowie on April 5, 1994. Town residents complained
that the state allowed him to spread millions of pounds of
sludge before receiving any test results on the incoming material.
Tests on the April shipment were finally completed in July, showing
that the New York sludge contained petroleum hydrocarbons at 14 to
22 times the level at which state regulations require a cleanup from
oil and gasoline spills. [59] The tests also showed fecal coliform bacteria
at 33.5 times the limit allowed under federal law.

“That sounds more like untreated sludge,” said Laura Fondahl, an
engineer at the EPA’s San Francisco office. “It couldn’t be
land-applied — it would have to go to a municipal landfill, a dedicated
sludge-only landfill, or to a treatment plant. Those are binding
rules.” [60] Nevertheless, Bryce was allowed to resume spreading on
his farmland in August 1994.

When Push Comes to Sludge

After Merco’s rejection in Oklahoma, it turned to an alternate
site — the Mexican border town of Sierra Blanca (population 500), one
of the poorest towns in one of the poorest counties in Texas. Once
again, citizens quickly mobilized to protest Merco’s plans to spread
sludge on desert grazing land — nine miles from a planned repository
for nuclear waste from power plants in Maine and Vermont.

To placate the town, Merco offered money to buy a new fire
engine, donated $10,000 to the school board, set up a scholarship
fund, threw barbecues, handed out Christmas turkeys, and promised
$50,000 a year to the local community development corporation.
Merco executives also contributed $5,000 to Texas Governor Ann
Richards, whose appointees on the water commission approved
Merco’s permit in record time.

“These host community benefits are considered normal in these
types of projects,” explained Merco representative Kelly Sarber. [61]

Critics, however, noted that the money Merco was spending in
Austin and Sierra Blanca was a drop in the bucket compared to the
$168 million the company was receiving from New York City.

Local supporters of the plan included George Fore, ranch manager
of the Merco site and President of the “Texas Beneficial Use
Coalition,” a Merco front group. Fore accused opponents of behaving
irrationally: “It’s like that (salsa sauce) commercial. When the cowboys
find out the stuff they have is from New York City, they want
to string someone up. It’s the same way with land application. People
get particularly bothered when they find out you’re bringing sludge
out here from the big city.” [62]

Critics, however, expressed more visceral objections. “I’ve smelled
cow manure, the rice paddies in Vietnam they use human manure
to fertilize. That’s a different smell,” said Sierra Blanca resident
Leonard Theus. “This is like a chemical smell.” [63]

In February 1994, several opponents of the sludge farm said they
had received anonymous death threats. Bill Addington, leader of an
anti-sludge citizens’ group called “Save Sierra Blanca” blamed Merco
for a recent fire in which his family’s lumber company had burned
to the ground, a claim that Merco attorney Jon Masters described as
“absolutely ludicrous.” [64]

In August 1994, EPA tests of Merco sludge in Sierra Blanca showed
35 times the safe level of fecal coliform bacteria. “We don’t perceive
it as a problem,” responded Masters. “The fecal coliform testing is
erratic in its results.” [65]

“The Smell of Money”

The town’s sludge war hit the national airwaves in 1994 when it was
featured on TV Nation, a satiric show hosted by investigative filmmaker
Michael Moore. TV Nation accompanied a trainload of New
York sludge cake (“rich and moist like most finer cakes”) from
New York to Sierra Blanca, where Merco representative Kelly Sarber
led a tour of the farm site. “There’s been a lot of thought and there’s
a lot of integrity in how we’re doing this, and the proof is in the
pudding,” Sarber quipped. Asked about the smell, another Merco
employee smiled. “It’s the smell of money,” she said. [66]

The cheap humor turned serious as the camera cut to the Washington
office of Hugh Kaufman. “This hazardous material is not
allowed to be disposed of or used for beneficial use in the state of
New York, and it’s not allowed to be disposed of or used for beneficial
use in Texas either,” Kaufman said. “What you have is an illegal
`haul and dump’ operation masquerading as an environmentally
beneficial project, and it’s only a masquerade. . . . The fishes off of
New York are being protected, the citizens and land of New York
are being protected, and the people of Texas are being poisoned.
Something is rotten in Texas.”

TV Nation aired bitter complaints from local residents interviewed
on the dusty streets of Sierra Blanca. “You can smell it all over, and
I don’t see why New York has any right to dump their shit on us,”
one woman said angrily. Another said, “We’ve gotten a lot of allergies.
People who have never had allergies in their lives have come
up with a bunch of stuff like that.” [67]

Soon after the show aired, Merco filed a lawsuit seeking $33 million
in damages from Kaufman and TV Nation‘s producer, Sony
Entertainment Pictures, Inc., accusing them of “defamatory and
disparaging statements . . . made with actual malice and a reckless
disregard for the truth.” The lawsuit complained that Merco had spent
about $600,000 in direct public relations efforts to establish good will
in Texas, half of which had been lost as a result of the program.
Hugh Kaufman counter-sued for $3 million, accusing Merco of ties
to organized crime, violating Texas and New York laws and interfering
with a federal investigation. [68]

In the past, Kaufman has blown the whistle on toxic contaminations
of Love Canal and Times Beach, Missouri. Under the Reagan
administration, he took on EPA Administrator Anne Burford, who
was forced to resign after being found in contempt of Congress for
not turning over documents. Burford’s assistant administrator, Rita
Lavelle, served four months in jail for lying to Congress about diverting
superfund money for political purposes.

“This issue is much bigger,” Kaufman said, “because this i
obstructing a criminal investigation of companies affiliated with
organized crime involved in the illegal disposal of waste with an
illegal contract at great taxpayer expense. The Burford-Lavelle
thing was just using superfund for political shenanigans — determining
which site would be cleaned up or not cleaned up based on politics.”

In Sierra Blanca, Kaufman said, “We’re talking about government
basically taking a dive for organized crime during an open criminal
investigation.” [69]

Victimless Grime?

Chemicals, pesticides, acids, heavy metals, radioactivity — to some
extent these risks can be quantified. However, assessing the health
threat from the human disease pathogens inhabiting sewage sludge
defies the capabilities of current science. This is especially true given
the ability of mutating microbes to withstand antibiotics, and growing
concerns over newly emerging diseases such as ebola virus, mad
cow disease, killer e-coli and hanta virus.

In 1993, a team of researchers at the University of Arizona published
an article titled “Hazards from Pathogenic Microorganisms in
Land-Disposed Sewage Sludge.” Their study found that “significant
numbers” of dangerous human disease organisms infect even treated
sewage sludge. “Thus, no assessment of the risks associated with the
land application of sewage sludge can ever be considered to be complete
when dealing with microorganisms.” [70]

The viruses, bacterea, protozoa, fungi and intestinal worms present
in sewage and sludge is mindboggling. Many of the pathogens cause
diseases that sicken, cripple and kill humans including salmonella
shigella, campylobacter, e-coli, enteroviruses (which cause paralysis,
meningitis, fever, respiratory illness, diarrhea, encephalitis;
giardia, cryptosporidium, roundworm, hookworm, and tapeworm.
Sludge pathogens can move through many environmental pathway — direct contact with sludge, evaporation and inhalation, contaminated
groundwater, contamination of rodents burrowing in sludge,
and uptake through the roots of crops. [71]

Already, victims have begun to emerge. In Islip, New York, 25-year-old
Harry Dobin ran a coffee truck at a Long Island Railroad
station 1000 feet away from a sludge composting site. In July 1991
he began suffering health problems. Doctors treated him for asthma,
arthritis, Weggener’s disease, Lyme disease, kidney disorder and
bronchitis. Finally in January 1992 when he could no longer breathe,
they performed a lung biopsy and discovered Aspergillus fumigatus,
a common byproduct of sludge composting. By the time the disease
was diagnosed, it was unstoppable, spreading to his spine, his legs,
and finally his heart, leading to his death on September 23, 1992. [72]
Other residents of Islip complained of chronic coughing, nausea and
other reactions. A study by the state Department of Health found
that neighborhoods downwind of the composting plant had four
times the average background level of Aspergillus. State officials
concluded that “the study did not find that the higher concentration of
mold spores increased health problems . . . [but] such a connection
might, in fact, be present . . . further study was needed to come to
a definitive conclusion.” [73]

Outside Sparta, Missouri, a tiny rural town whose sewage plant
began operations in the late 1980s, dairy farmer Ed Rollers began
having problems with his cows in 1990. They were falling sick and
dying, and no veterinarian or university scientists could tell him why.
The death and disease continued until late 1993 when the farm
declared bankruptcy. Someone suggested to Rollers that his cows
could be victims of sludge which was dumped on a nearby field in
1989-1991, and suggested he read journalist Ed Haag’s articles on
the topic which had recently appeared in two farm magazines.

Eventually Rollers initiated scientific soil tests. “We found lots of
heavy metal contaminants. The field where the sludge was dumped
ran into our fields.” They tested a dead cow and found “lead,
cadmium, fluoride in the liver, kidneys, bones and teeth.” Rollers
hired an attorney. His situation is especially difficult because the
landowner who accepted the sludge is a public official in Sparta,
and sits on the hoard of Rollers’ bank. As of 1995, the Rollers case
was still pending, and Ed’s father was experiencing health problems
suspected to result from his exposure to sludge.

“I can’t believe what’s happening,” Rollers said. “There are very
few places to turn. . . . I don’t want a government agency to cover
this up.” [74]

In Lynden, Washington, dairy farmers Linda and Raymond Zander
began to lose cows a year after sludge was spread on an adjoining
farm. “We noticed . . . lameness and other malfunctions,” said Linda
Zander. Tests found heavy metals in soils at the sludge disposal
site and in water from two neighborhood wells that serve several
families. Since then, Raymond Zander has been diagnosed with
nickel poisoning, and several family members show signs of
neurological damage which they believe is linked to heavy metal
poisoning including zinc, copper, lead and manganese. Sixteen
neighboring families have experienced health problems ranging from
flu symptoms to cancer. Linda Zander formed an organization called
“Help for Sewage Victims,” and began to hear similar stories of sickness
and death from farmers near sludge sites in Virginia, Pennsylvania,
North Carolina, Georgia and other parts of the country.

Sludge is often marketed to farmers as “free fertilizer,” but environmental
consultant Susan Cook, who tested the Zanders’ water
supply, warned that “farmers may be happy initially but the problems
don’t show up overnight. It was nearly two years before Ray
and Linda realized what was happening.” [75]

In fact, says toxicology professor Karl Schurr of the University of
Minnesota, “some of the same chemicals found in sewage sludge
were also employed by Cesare Borgia and his sister Lucrezia Borgia
in Italy during the 1400s to very slowly poison their opponents.” [76]

Let Them Eat Cake

As horror stories like these have begun to leak out, advocates of
sludge farming are responding. “There is no doubt, among sludge
scientists in general, that their long and arduous efforts to convince
society of the safety of sludge have been set back a few years,” wrote
Gene Logsdon in BioCycle magazine. “One good effect . . . is that it
should become easier . . . to get funds to mount education programs.”
Logsdon advocated “funding a road show” starring scientist-advocates
like Terry Logan “and a star-studded supporting cast of wastewater treatment plant operators. Put another way, this is a job for a
creative advertising agency. If the nuclear industry can convince the
public that `nuclear energy means clear air,’ then improving the image
of sludge would be, pardon the pun, a piece of cake.” [77]

As we go to press, the “biosolids” PR blitz is picking up steam.
The Water Environment Federation met in July 1995 to examine the
“public debate on biosolids recycling in all parts of North America. . .
critique local media footage . . . share special strategies, tactics,
and materials developed for targeting specific audiences and analyze
their region’s successes and failures.” Sludge newsletter reported
that Charlotte Newton of Powell Tate PR, whose firm has received
EPA tax dollars to push sludge farming, advocated getting tough with
opponents. “Attack them in a way that does not demonize them. . .
You can’t play to those who act weirdest,” she recommended. [78]

One measure of the success of the WEF’s “Biosolids Public Acceptance
Campaign” is that major food companies and associations are
reversing their long-standing opposition to sewage sludge. Until
recently, for instance, the National Food Processors Association — the
main lobby group representing the food industry, with members
such as Del Monte, Heinz and Nestle — strongly opposed accepting
and selling sludge-grown fruits and vegetables. In the wake of the
PR blitz from WEF and EPA, that opposition is waning.

In 1992 the tomato and ketchup conglomerate Heinz responded
to a consumer inquiry about sludge by writing, “Heinz Company feels
the risk of utilizing municipal sludge, which is known to be high in
heavy metals such as cadmium and lead, is not a health risk which
we need to take. Root crops such as potatoes, carrots and other vegetables
which are grown under the ground can take up unacceptable high levels
of heavy metals. . . . It should be noted that once
the lead levels are present in the soil they stay there for an indefinite
period of time. . . . We have at times dropped suppliers who
have used the municipal sludge on their crop land.” [79]

In 1995, however, a Heinz representative said they were reconsidering
their policy. Other companies are following suit. Chris Meyers,
a PR representative for the huge Del Monte company, explained that
his company’s “long-standing position . . . to avoid using raw agricultural
products grown on soils treated with municipal sludge” was
likely to change. “The EPA has asked the National Academy of
Sciences (NAS) to conduct an extensive study of the outstanding
safety issues. Del Monte is an active supporter of this study, which
we hope will facilitate sludge use in the future.” [80]

Once “biosolids” are accepted as a crop fertilizer, the powerful
National Food Processors Association lobby will “strongly oppose”
any labeling of food grown on sludge land. According to NFPA
representative Rick Jarman, consumers don’t need to know whether their
food has been grown in sludge. [81]

Currently, “certified organic” farmers are prohibited from using
sludge on their crops, but the sludge industry is pushing for acceptance
by organic farming organizations, and this will be a battleground for
industry PR in the future. The amount of farm acreage
dedicated to organic farming is currently very small. However, said
Brian Baker of California Certified Organic Farmers, “imagine what
great PR it would be for the sewage sludge promoters to say that
sludge is so clean it can even be certified organic — what a way to
`greenwash’ sewage sludge!” [82]

Footnotes:

[1] Nancy Blatt, letter to John Stauber, May 3, 1995.
[2] Myron Peretz Glazer and Penina Migdal Glazer, The Whistle Blowers, (New York: Basic Books, 1989), p. 135.
[3] Interview with Hugh Kaufman.
[4] Abby Rockefeller, “Sewage Treatment Plants vs. The Environment” (unpublished document), Oct. 1992, p. 1.
[5] Pat Costner and Joe Thornton, “Sewage Treatment Plants,” We All Live Downstream: The Mississippi River and the National Toxics Crisis, Dec. 1989, p. 35.
[6] Debra K. Rubin, Tom Ichniowski, Steven W. Setzer and Mary Buckner Powers, “Clean Water Act Debate Swirls On,” Engineering News-Record, Vol. 227, No. 14, Oct 7, 1991, p. 27.
[7] Ronald A. Taylor , “Clean-Water Campaign Springs Some Leaks,” US News & World Report, Dec 24, 1979, p. 59.
[8] Tim Darnell, “Till the Cows Come Home: Rural Wastewater Treatment Plants,” American City & Country, Vol. 106, No. 10, p. 26.
[9] Rockefeller, p. 2.
[10] Gareth Jones, et al., HarperCollins Dictionary of Environmental Science, (New York: HarperPerennial, 1992), p. 372.
[11] Stephen Lester, “Sewage Sludge . . . A Dangerous Fertilizer,” Everyone’s Backyard, Oct. 1992, p. 9.
[12] Jim Wells et al., “Nuclear Regulation: Action Needed to Control Radioactive Contamination at Sewage Treatment Plants,” GAO Reports B-255099, June 23, 1994.
[13] “In Waste Water, the Talk is About Toxics,” Chemical Week, Oct. 12, 1977.
[14] Costner and Thornton, pp. 35-37.
[15] Interview with Hugh Kaufman.
[16] “Recycling Sludge Onto Farmlands,” Business Week, Nov. 7, 1977, p. 84B.
[17] “For WPCF: New Directions,” Engineering News-Record, April 10, 1986, p. 60.
[18] “Recycling Sludge Onto Farmlands.”
[19] Geordie Wilson, “New Name Sought to End Grudge on Sludge, er, Biolife,” Seattle Times, May 22, 1991, p. A1. Also see “WPCF Reports Strong Support for Name Change Campaign,” Sludge, Vol. 16, No. 9, April 24, 1991.
[20] “Water Group Plans Earth Day Launch for National Campaign on Biosolids Recycling,” PR Newswire, April 21, 1994.
[21] Geordie Wilson, “Its Name Is Mud, So Sludge Gets a New One,” Seattle Times, Jan. 31, 1992, p. A1.
[22] “WPCF Pins Hopes on Biosolids’ to Replace the Term Sludge,” Sludge Vol. 16, No. 17, Aug. 14, 1991.
[23] James W. Bynum, “EPA-Sludge: The Fox Guarding the Chicken House” (unpublished manuscript), May 8, 1995, pp. 3, 14.
[24] Debra K. Rubin, “New Name for an Old Group,” Engineering News-Record, Vol. 227, No. 16, p. 9.
[25] “Water Group Plans Earth Day Launch.”
[26] “State Bans Milwaukee Sewage Plant Fertilizer,” United Press International, Aug. 15, 1982.
[27] Paul Hodge, “Trying to Cope with a 600-ton-a-day Sludge Problem, Naturally,” Washington Post, Jan 6, 1977.
[28] Melvin N. Kramer, Ph.D., executive summary of testimony given Oct. 1, 1992 before the U.S. House of Representatives, Committee on Merchant Marine and Fisheries, Subcommittee on Coast Guard Navigation, Hearing on Ocean Dumping Enforcement and the Current Status of Research Efforts, pp. 1-2.
[29] Dianne Dumanoski, “Specialists Debunk Claim of Sludge-Pellet Hazards,” Boston Globe, July 16, 1992, p. 27.
[30] Joseph Zinobile, letter to Environmental Quality Board, Harrisburg, PA, Dec. 27, 1994.
[31] Stanford L. Tackett, “The Myth of Sewage Sludge Safety,” delivered at the Municipal Sewage Sludge Conference, State College, PA, May 21, 1994.
[32] Stanford L. Tackett, “The Sewage Sludge Scam,” The Gazette, Indiana, PA, Oct. 2, 1994.
[33] Ibid.
[34] Interview with Alan Rubin.
[35] Jane Beswick, “Some Interconnected Persons and Organizations in Sludge” (unpublished manuscript), 1994.
[36] 1994 Annual Report and Form 10-K of N-Viro International Corporation, p. 1.
[37] Ibid., pp. 2-4.
[38] William Sanjour, statement to the Georgia State Senate Committee on Natural Resources, Feb. 14, 1990.
[39] Patricia L. Deese, et al., Institutional Constraints and Public Acceptance Barriers to Utilization of Municipal Wastewater and Sludge for Land Reclamation and Biomass Production (Washington, DC: US Environmental Protection Agency, 1981), pp. 22, 27.
[40] Ibid., pp. 3, 33-34.
[41] Kelly Sarber, “How to Strategize for Successful Project Development,” BioCycle, April, 1994, p. 32-35.
[42] Ibid.
[43] Ibid.
[44] Dennis Hevesi, “Investigation Begun Into New York City Sludge Removal Program,” New York Times, April 16, 1992, p. B3.
[45] “Ocean & Medical Waste Dumping, P.L. 100-688,” Legislative History, Senate Report No. 100-431, pp. 5869-5872.
[46] Kevin Flynn, “Sludge Withdrawals Leave City Mired,” Newsday, Nov. 15, 1991, p. 21.
[47] “Oklahoma Places Moratorium on Sludge from Out-of-State,” Sludge, Vol. 17, No. 9, April 22, 1992.
[48] Michael Specter, “Ultimate Alchemy: Sludge to Gold: Big New York Export may Make Desert, and Budget, Bloom,” New York Times, Jan. 25, 1993, p. B1.
[49] Michael Toss, “Officials Seek Probe on Sludge Haulers,” Newsday, Feb. 4, 1991, p. 21.
[50] Kevin Flynn, “Sludge Plan Probe: DA Checks Ties Between Firms and Politicians,” Newsday, April 15, 1992, p. 23.
[51] Kevin Flynn, Tom Curran and Kathleen Kerr, “Mobster: Sludge Firm Tied to Crime Family,” Newsday, June 4, 1992, p. 110.
[52] Selwyn Raab, “Mafia Tale: Looting the Steel of the West Side Highway,” New York Times, May 9, 1993, Section 1, p. 27.
[53] Kevin Flynn and Michael Moss, “Stink Over Sludge: Arizona Says City’s Waste Contaminated,” Newsday, Aug. 2, 1994, p. A08.
[54] Ibid.
[55] Kevin Flynn, “City Sludge Plan Kept Under Wraps,” Newsday, Dec. 10, 1991, p. 21.
[56] Keith Bagwell, “Sewer Sludge from NYC is Deposited on Farmland,” Arizona Daily Star, May. 22, 1994, p. 1B.
[57] Keith Bagwell, “Tainted Sludge Used for Years on Pima Farms,” Arizona Daily Star, Oct. 2, 1994, p. 1B.
[58] Bagwell, “Sewer Sludge from NYC.”
[59] Keith Bagwell, “Sludge Test Could Result in Cleanup,” Arizona Daily Star, June 25, 1994, p. 1B.
[60] Keith Bagwell, “Sludge is Found to Harbor Germs Far Beyond Limit,” Arizona Daily Star, June 28, 1995.
[61] “Texas County Tempted by Financial Rewards of Dumps,” National Public Radio All Things Considered, March 21, 1994, Transcript #1428-6.
[62] Sludge, Sept. 27, 1994.
[63] Maggie Rivas, “W. Texans Fight to Reject Dumping Sites: Climate to Store Nuclear Waste, Sludge Called Ideal,” The Dallas Morning News, March 20, 1994, p. 45A.
[64] “Abraham Angry with TNRCC,” Texas Industry Environmental Advisor, Vol. 7, No. 4, Feb. 25, 1994.
[65] Michael Moss and Kevin Flynn, “Flushing, Texas: Exported City Sludge is Tainted,” Newsday, Aug. 3, 1994, p. 7.
[66] Transcript of TV Nation Program, NBC Television, Aug. 2, 1994.
[67] Ibid.
[68] “EPA Whistleblower, Sony Inc. Named in $33 Million Libel Suit,” BNA Chemical Regulation Daily, Jan. 6, 1995.
[69] “Whistleblower Seeks Special Prosecutor, Alleges Obstruction in Texas Sludge Case,” BNA National Environment Daily, April 5, 1995.
[70] Timothy M. Straub, et al., “Hazards from Pathogenic Microorganisms in Land-Disposed Sewage Sludge,” Reviews of Environmental Contamination and Toxicology, Vol. 132, (New York: Springer-Verlag, 1993), p. 55-91.
[71] Ibid.
[72] Letter from Kenneth Dobin to Sandra Messner, Feb. 10, 1994.
[73] “Community Organizers: Some Compostind Sites Could Be Harming Neighbors’ Health,” Sludge, Vol. 19, No. 7, March 29, 1994.
[74] Interview with Ed Rollers.
[75] Ed Merrimen, “Farmers, Public Warned of Sludge Danger,” Capital Press, July 19 1991, p. 3.
[76] Statement of Karl Schurr, presented to the Coshocton County Board of Health, Coshocton, OH, Nov. 1992.
[77] Gene Logsdon, “Public Acceptance: How Does Society Learn About Sludge Safety?” BioCycle, May 1992.
[78] “Acceptance Strategy Should Include World Wide Web Site, Media Relations,” Sludge, Vol. 20, No. 16, Aug. 1, 1995, p. 127.
[79] Letter from J.M. Dryer, Heinz USA, to Jane Shumaker, Nov. 19, 1992.
[80] Letter from Chris Meyers, Del Monte, to Alice Gallagher, March 24, 1995.
[81] Interview with Rick Jarman.
[82] Interview with Brian Baker.

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