Abstract:Sono filter uses a composite iron matrix (CIM) to remove arsenic from water. The innovator of the filter received Grainger Challenge Prize Gold award from the National Academy of Engineering (NAE) based on a number of criteria. Cowley College arsenic research team has found the innovator to violate the criterion #3 on the ability to collect and dispose of spent residues containing As in a safe and cost effective manner. Also, the team has found that he misinterprets EPA's TCLP data and promotes indiscriminate disposal of the toxic wastes against EPA's regulations (EPA/6000/R-00/025, May 2000, Regulations on the Disposal of Arsenic Residuals from Drinking Water Treatment Plants: 3.3 Solid/Sludge Residuals, 3.3.1 Solid Waste Landfill: RCRA Subtitle D).

The indiscriminate disposal of the arsenic waste from Sono and other filters is potentially hazardous for air, water, and soil media. People will have nasal intakes(inhalation) of the wastes from breathing polluted air. Also, they will have oral intakes(ingestion) from eating the bottom-feeder fish species, cattle and poultry products, and crops, vegetable and fruits produced on contaminated soil and in irrigation of arsenic contaminated water.

Under the above violation of environmental regulations and potential environmental hazards, the Cowley College team suggests abandoning of Sono and other filters. Further, the team suggests the cost-effective and environment-friendly water supply method of (1) filtration and chlorination of river water, (2) abstraction of arsenic-free groundwater from dug wells, (3) abstraction of arsenic-free groundwater from uncontaminated tube wells, and (4)abstraction of arsenic-free groundwater during the wet season (6-7months) from 3-5 feet above the contaminated zone either by installing new tube wells or by pulling back the existing tube wells (if they are strong and good), and the dry season method of sharing water from nearby uncontaminated tube wells, and other good water supply sources.

US EPA Regulations on the Disposal of Arsenic Residuals from Drinking Water Treatments Plants (DWTPs):

3. Federal Statutory and Regulatory Requirements:

3.3 Solid/Sludge Residuals

Solid residuals from DWTPs typically occur in the form of sludges (or precipitates) generated as residuals from the treatment process. They may also include spent resins and filter media that can no longer be used as part of the treatment process. Typically, sludges are disposed through either landfilling, in municipal or industrial landfills, or through land application. Interim management may also include storage in lagoons. Spent resins and filter media when not disposed, may be sent back to the vendor for reactivation, recovery, or disposal. Although no specific studies were identified that examine whether arsenic treatment residuals typically constitute a hazardous waste ( i..e., exhibit the hazardous characteristic of toxicity), none of the literature reviewed suggests that significant quantities of arsenic (or other drinking water) treatment residuals typically constitute hazardous waste. Rather, it appears that currently federal regulation of solid and sludge arsenic treatment residuals occurs predominantly under RCRA Subtitle D (non hazardous waste). Nevertheless, since arsenic treatment residuals can constitute a hazardous waste they must be evaluated on a case-by-case basis and, where they do exhibit a hazardous characteristic, the residual must be managed pursuant to the requirements of RCRA Subtitle C (hazardous waste).

"3.3.1Solid Waste landfill: RCRA Subtitle D

Depending upon the type of treatment technology employed, a DWTP may generate solid residual in the form of sludge. Once a facility has determined that its solid residual is not a hazardous waste per 40 CFR Sec 261.24(toxicity characteristic) (see also 40 CFR Sec. 262.11(c)(2)), then the residual may be disposed in a municipal or industrial landfill. Municipal landfills must meet minimum requirements established under 40 CFR part 258. Under part 258, MSWLFs must comply with requirements addressing location, operation, design, groundwater monitoring, corrective action, closure and post-closure care, and financial assurance. The groundwater monitoring requirements include mandatory detection monitoring for arsenic (among other constituents) followed by assessment monitoring where a statistically significant increase over background is identified. It is noteworthy that although the requirements imposed under part 258 have been developed at the federal level, these provisions are implemented under state and local solid waste programs ( i.e., the part 258 provisions are only imposed to the extent required by state laws and regulations).

Industrial landfills, which may include mono fills (landfills design and dedicated to the disposal of single type of waste), are typically regulated under state and local laws. Such laws generally impose requirements addressing location, design, operation, permeability ( i.e., requirements for the use of liners), run-on/runoff controls, and cover. Many industrial landfills and mono fills are located on-site of the residual generator.

Finally, it is important to keep in mind that under no circumstances may sludges be disposed of in navigable waters, streams, rivers, lakes or oceans) and care must be taken that sludges do not enter navigable waters as a consequence of transfer operations. Also, DWTPs are considered to be industrial facilities for purposes of the Phase I storm water regulations (40 CFR Sec.1222.26) and if a plant elects to store or dispose of sludge on-site that facility may have to comply with CWA storm water regulations.”

3. Federal Statutory and Regulatory Requirements:

3.3 Solid/Sludge Residuals

Solid residuals from DWTPs typically occur in the form of sludges (or precipitates) generated as residuals from the treatment process. They may also include spent resins and filter media that can no longer be used as part of the treatment process. Typically, sludges are disposed through either landfilling, in municipal or industrial landfills, or through land application. Interim management may also include storage in lagoons. Spent resins and filter media when not disposed, may be sent back to the vendor for reactivation, recovery, or disposal. Although no specific studies were identified that examine whether arsenic treatment residuals typically constitute a hazardous waste ( i..e., exhibit the hazardous characteristic of toxicity), none of the literature reviewed suggests that significant quantities of arsenic (or other drinking water) treatment residuals typically constitute hazardous waste. Rather, it appears that currently federal regulation of solid and sludge arsenic treatment residuals occurs predominantly under RCRA Subtitle D (non hazardous waste). Nevertheless, since arsenic treatment residuals can constitute a hazardous waste they must be evaluated on a case-by-case basis and, where they do exhibit a hazardous characteristic, the residual must be managed pursuant to the requirements of RCRA Subtitle C (hazardous waste).

"3.3.1Solid Waste landfill: RCRA Subtitle D

Depending upon the type of treatment technology employed, a DWTP may generate solid residual in the form of sludge. Once a facility has determined that its solid residual is not a hazardous waste per 40 CFR Sec 261.24(toxicity characteristic) (see also 40 CFR Sec. 262.11(c)(2)), then the residual may be disposed in a municipal or industrial landfill. Municipal landfills must meet minimum requirements established under 40 CFR part 258. Under part 258, MSWLFs must comply with requirements addressing location, operation, design, groundwater monitoring, corrective action, closure and post-closure care, and financial assurance. The groundwater monitoring requirements include mandatory detection monitoring for arsenic (among other constituents) followed by assessment monitoring where a statistically significant increase over background is identified. It is noteworthy that although the requirements imposed under part 258 have been developed at the federal level, these provisions are implemented under state and local solid waste programs ( i.e., the part 258 provisions are only imposed to the extent required by state laws and regulations).

Industrial landfills, which may include mono fills (landfills design and dedicated to the disposal of single type of waste), are typically regulated under state and local laws. Such laws generally impose requirements addressing location, design, operation, permeability ( i.e., requirements for the use of liners), run-on/runoff controls, and cover. Many industrial landfills and mono fills are located on-site of the residual generator.

Finally, it is important to keep in mind that under no circumstances may sludges be disposed of in navigable waters, streams, rivers, lakes or oceans) and care must be taken that sludges do not enter navigable waters as a consequence of transfer operations. Also, DWTPs are considered to be industrial facilities for purposes of the Phase I storm water regulations (40 CFR Sec.1222.26) and if a plant elects to store or dispose of sludge on-site that facility may have to comply with CWA storm water regulations.”

Meer Husain
USA
E Mail : matribhumi_bd@yahoo.com

http://www.umasssoils.com/forms/preliminary.pdf
http://www.umasssoils.com/posters2008/arsenic.htm
Dangers of Sono Filter's Arsenic Waste Disposal Method in Bangladesh

Meer Husain, P.G., Professional Geologist, Cowley County Community College and Kansas Dept. of Health & Environment, 4501 E. 47th St. south, Wichita, KS 67210, USA. Email:husainm@cowley.edu
Leslie Berryhill, Biologist, Director of Natural Science, Cowley County Community College, 4501 E. 47th St. south , Wichita, KS 67210, USA. Email: berryhill@cowley.edu
Dr. Thomas M. Bridge,Ph.D., Professor of Geology (emeritus), Emporia State University, Strong City, KS,USA.
Ernie Morrison, P.G., Exploration Geologist, Mull Drilling Co. and Cowley County Community College, Wichita, KS, USA. Email: EMorrison@MULLDRLG.com
Dr. Miah M. Adel, Ph.D., Professor of Physics and interdisciplinary sciences, University of Arkansas, Pine Bluff, Arkansas, USA. Email: adelm@uapb.edu
Dr. Mahbub Alam, Ph.D., Professor, Extension Irrigation Specialist, Kansas State University, Garden City, KS, USA. Email: malam@ksu.edu
Bhuiyan O. Hoque, Environmental Geologist, Dhaka, Bangladesh
B.H. Chowdhury, Environmental Geologist, Dhaka, Bangladesh
M.Badruddoja,MD.,FRCS.,FRACS, American Board Certified Surgeon, Chicago, Illinois, USA
Dr A K M B Karim, FRCP(Edin) FRCP(Glas)., London, U.K.
Jason Swink, Adjunct Faculty, Cowley College, Chemical Engineer and Physician, Wichita, KS,USA.
Mir Fazlul karim, Exploration Geologist, New York,USA.
Jasim Uddin, Exploration Geologist, Dhaka, Bangladesh
Ahasanul Bashar, Hydrogeologist, Dhaka, Bangladesh