Through land application of waste, anaerobic digesters in ag have re-created a dead zone in Lake Michigan that had been mostly gotten rid of through the Clean Water Act in the early 1970’s. Ag digesters in Iowa are adding more ag pollution to Iowa’s already number one ranked contributor of ag pollution to the dead zone in the Gulf of Mexico. There have been leaks, explosions, fires, people injured, and a death recently in Iowa ag digesters.
We are here today because the ag digester industry is justifying, in part, digester use in ag by using the fact that the wastewater industry has used anaerobic digesters for years with success. That assumes that digesters in ag are the same as digesters in wastewater. They are not and I will list for you today the many ways that they are not. This presentation should be useful for you if you ever get involved in a conversation about this issue. We do not create dead zones as ag does, we do not increase our pollution yearly as ag does, and we do have regulations, which ag doesn’t, that protect workers, the public, urban and rural neighborhoods, and the larger environment. The wastewater industry is not an unregulated, technically uneducated, and unlicensed industry, and should not be associated with that kind of industry. Ag has adopted wastewater digesters, but they have not adopted the regulations, education, and protections for the workers, the public, and the environment that wwtp digesters have matured with.
The easiest way to show you the differences is to discuss some recent incidents that have involved ag digesters in Iowa. I will discuss the incidents, from least harmful to most harmful, and then compare what, why, and how these incidents would have been different, or never happened, if they happened in a wastewater treatment plant.
A Colorado company built an ag digester in Western Iowa a couple years ago. Shortly after start up, it was reported that the digester had leaked 376,000 gallons of manure into waters of the state. For some reason the DNR would not let their head ag engineer go and find out what caused the leak. At your wwtp, you would not have filled a digester being constructed before you submitted a construction certification form, or a similar form, noting that the construction had been done correctly. The ag digester construction company didn’t check the construction first to make sure all construction was done correctly, and didn’t send in the required certification form to the DNR before they pumped manure into the digester. The digester then had a leak of 376,000 gallons because of faulty construction. After the leak the digester construction company corrected the construction and paid a fine of $10,000 to the state. This would not have happened at your wastewater treatment plant during construction. Ag digesters and wwtp digesters are not treated the same.
There was a rumor that there had been an explosion and a fire at an Iowa ag digester. I called the State Fire Marshall’s office and asked about that. The answer I got was the State Fire Marshall’s office had not heard anything about an explosion and a fire. A journalist, with the help of locals, did an investigation and found that there had been a methane explosion and a fire with two workers being injured. If that would have happened at your wwtp, you would have had the DNR and OSHA doing an immediate investigation into the explosion, the fire, and the injuries to the workers. Again, a report, a demand to fix the reason for the incident happening, and probably a fine would have been issued by the DNR and OSHA. None of that happened for the same reasons I mentioned in the leak incident. No DNR or OSHA regulatory oversight happens with ag digesters.
At a SE Iowa digester, a diver was contracted to fix a problem that was occurring in the digester. Because there are no regulations, and their education components, the diver did not know what he was getting into. There was no SOP that he could work off of, and he was told that the temperature would be 99 to 105 degrees. When he went into the digester liquid, he radioed to his girlfriend who was helping him, that he was having trouble and taking his helmet off. She started pulling on the air lines, this was a hard hat diver, there was not a safety line or safety equipment, and all that came up was his helmet. They brought in 3 professional divers from Chicago to retrieve the body. They found that the temperature was 120 degrees and not the 105 that he was told. They had to add 100,000 gallons of water to cool the liquid down and get rid of the foam before they could go in and get his body. The divers said he had the wrong diving equipment, and apparently didn’t know what he was getting into. Because there were no regulations on ag digesters, no education or SOP’s were available to the diver. And, the local law enforcement said that because there was no OSHA regulatory department involved there would be no investigation of what happened. And, the death was simply ruled an accident.
[A later note on the death: The temperature of the digester was supposed to be 99 to 105 degrees. The temperature was actually 120 degrees and too hot for the commercial divers that were brought in to recover the body. Nearly 100,000 gallons of water had to be brought in to cool the digester enough for the divers to recover the body. From the Gazette article, ‘Frank Frosolone, owner of the company that recovered the body, said it did not appear Baenziger had on the proper gear for a dive into liquids contaminated with manure and food waste. “It’s a contaminated dive, so we had to use specialized suits with double seals and triple backup air supply and communications. You got to have the right stuff,” he said. Frosolone said he did not believe Baenziger was using protective equipment, such as a harness or a backup air source. “He didn’t have any of that stuff,” he said.’]
For many reasons, this probably would not have happened at a wwtp. If this happened at a wwtp, DNR and OSHA would have been involved doing an investigation, a report on what went wrong, a demand that problems be fixed, and a fine. The ag industry cannot say that ag and wwtp digesters are the same when ag digesters have none of the regulations protecting workers, the public, and the environment. And have no education of workers that is required to be a licensed wwtp operator.
Iowa is the major contributor of ag pollution creating the dead zone in the Gulf of Mexico. The first attempt at lowering that ag pollution was the Iowa Plan, a forerunner by five years of the Iowa Nutrient Reduction Strategy. Since the introduction of those voluntary to ag plans, Iowa’s agricultural pollution has doubled. As part of the INRS, wastewater treatment plants were given more strict discharge limits that we had to meet which lowered out pollution contribution. Because most existing dairies have to expand their herds to meet the amount of waste needed for ag digesters to operate efficiently, each ag digester adds to this already doubled pollution going into our surface and ground waters when ag waste is land applied. By expanding herds, ag digesters will add to the already record ag pollution. Because of the stricter limits, wwtp digesters lower the pollution that wwtp’s discharge. In fact, to meet the stricter limits on wwtp’s discharge permits, many plants are going away from anaerobic digesters to aerobic digesters, and/or going to tertiary treatment. The ag industry does not use either of those technologies.
15 to 20 years ago the percentage of pollution added to Iowa’s waters was 92% from ag, 4% from wastewater, and 4% from others (parking lots, roads, lawns, golf courses, cities, etc.). Because ag’s contribution has doubled during that time, and because wastewater’s contribution is smaller due to stricter discharge limits, the percentages today are approximately 96.5% from ag, 1.5% from wastewater, and 2% from others.
More differences:
1. Feedstock. Your sewer systems hold and transport human waste to your treatment systems. In that sewer system, do you leave the tops of manhole covers off manholes, put blowers down into those manholes and blow all the sewer gasses up into your city neighborhoods? I’m pretty sure that is against both federal and state regulations. And, your city wouldn’t allow it anyway.
Most ag digester waste comes from pigs and dairy cows. That waste comes from confinements with either pits below slatted floors, or lagoons and tanks outside storing that waste. In order to keep the pigs, dairy cows, and workers alive and healthy, all those sewer gasses, and other pollutants, created in the confinements are constantly, 24/7/365, blown out of the confinements into rural neighborhoods and the larger environment. Those pollutants – hydrogen-sulfide – ammonia – methane – particulates – antibiotic resistant organisms – VOC’s – harm the human central nervous system, the digestive system, the respiratory system, eyes and skin, and as we know, hydrogen-sulfide will kill you. Our lawsuit asking the DNR to regulate the air pollution coming from confinements had 867 peer-reviewed journal studies showing the harm that pollution causes. My granddaughters’ school was part of a study focused on asthma and children based on proximity to confinements. Ammonia can cause asthma. That school had hog confinements upwind of it. In that school, the students’ rate of asthma was almost four times the state’s average rate of asthma.
The difference is we don’t blow sewer gasses into our neighborhoods. In ag, you cannot regulate confinement air pollution. The DNR has no regulations for confinement air pollution, as I know from suing them. And in Iowa, OSHA cannot regulate agriculture, so rural neighborhoods, by law, must endure this health harming pollution, where city neighborhoods don’t.
2. WWTP digesters are part of a multi-step treatment process. Do any of you use digesters as the only technology in your wastewater treatment system? In wastewater, digesters are only one part of a multi-step treatment process. Anaerobic digesters are a stand-alone technology in agriculture. There is little difference between the pollution kinds and amounts that go into an ag digester, and what is land applied after being in the digester. WWTP’s treat waste to limits that result in our discharges being cleaner than the existing ag pollution in the streams and rivers that we discharge into. Many operators who fish will fish below the discharge pipe as that area of rivers and streams are the cleanest areas of rivers and streams as we have seen from the percentages of contributing pollution. So the difference in digester use is multi-step treatment at wwtp’s, versus one step stand alone digester technology in ag.
3. Wastewater treatment plants and their digesters are run by licensed, think education levels, operators who need to pass tests in order to attain different levels of licenses, and need to attend CEU classes to keep their licenses up to date. There is no requirement to have licensed operators running ag digesters. I know that for a fact as I was on the DNR TAC committee (when they still had TAC committees) that was writing regulations for ag digesters. When the Iowa Legislature found out we were writing those regs, they passed Senate File 534 in 2019 that said the DNR couldn’t regulate agricultural digesters, and the committee was disbanded.
4. Wastewater operators have to follow federal OSHA occupational safety and health regulations. OSHA cannot, by law, regulate agriculture in Iowa. So there are no federal or state regulations that would protect workers and people who live, work, or go to school in proximity to ag digesters.
5. OSHA considers digesters a “confined space”. Confined spaces are the most dangerous places in the treatment process. Confined spaces protection does not exist in ag because confined spaces, because of no regulations, do not exist in ag.
6. Hazardous wastes exist in wastewater treatment plants and have to be dealt with carefully. In ag, there are no hazardous waste designations. My first contribution to the DNR TAC committee writing digester regulations was mentioning that even though the draft regulations said that no hazardous waste was to be allowed in these ag digesters, hog confinement and dairy confinement waste, major waste streams for these digesters, fit Iowa’s definition of hazardous waste to a “T”.
Iowa Code 455B.411 subsection 3:
3.
a. “Hazardous waste” means a waste or combination of wastes that, because of its quantity, concentration, biological degradation, leaching from precipitation, or physical, chemical, or infectious characteristics, has either of the following effects:
(1) Causes, or significantly contributes to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness.
(2) Poses a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. “Hazardous waste” may include but is not limited to wastes that are toxic, corrosive or flammable or irritants, strong sensitizers or explosives.
The gasses hydrogen-sulfide and ammonia, the green house and explosive gas methane (which is what ag digesters are after), antibiotic-resistant organisms, particulates, and toxic VOC’s are cooked up during anaerobic digestion in hog and dairy confinements and are contained in that confinement waste. This pollution is blown or vented out of hog and dairy confinements 24/7/365 so the pigs and cows inside won’t die.
High concentrations of hydrogen-sulfide can cause respiratory paralysis and may cause coma after a single breath and may be rapidly fatal. Also convulsions, acute conjunctivitis with pain, lacrimation, and photophobia; rhinitis, pharyngitis, bronchitis, and pneumonitis among others are mentioned. Ammonia vapor is a severe irritant of the eyes, especially the cornea, the respiratory tract, and skin. Also mentioned are dyspnea, bronchospasm, chest pain and pulmonary edema which may be fatal; bronchitis, pneumonia, and asthma are also problems. There can be health problems when people are colonized by antibiotic-resistant organisms such as MRSA. There are respiratory problems from particulates. And the 100 or so toxic VOC’s also are harmful to human health. These fit the Iowa hazardous waste definition.
These health problems, and deaths, of Iowans from hog and dairy confinement waste should give you serious pause because hog and dairy confinement waste is the major feedstock of these ag digesters. Similar to other bandaids for industrial ag like CO2 pipelines, edge of field practices, and ethanol, ag digesters used this way are a bandaid that tries to give industrial hog and dairy confinements relevance, but actually enable those confinements to continue polluting no matter the inherent ongoing human health and environmental problems that exist by using them.
When I made the DNR Chair of the committee aware of this hazardous waste problem, his answer to me was that the feds and the state say that because this is ag, this waste cannot be described as hazardous. I quote: “The Code citation is a legislative decision and matches the federal exclusion. I don’t believe Iowa DNR can do anything contrary to the state and federal statutes.”
So something that is known to be a hazardous waste is not a hazardous waste in ag just because the feds and the state say it isn’t. Think about that for a second. Are people whose health is affected by these hazardous wastes told they are not really affected? Are Iowa families who have lost family members told that the deaths were not from a hazardous waste? The statement that “this is not really hazardous waste so we don’t protect you from it” is not really a satisfactory response for families who have had members die, and for people who have serious health issues from this waste. Historically, the wastewater industry made relevant changes to its processes when they discovered health problems associated with how we processed our waste.
7. Before you land apply digester waste in the wastewater industry that waste needs to be tested. Because of the law that was passed by the Legislature, the DNR told me that waste from digesters cannot be tested. So we have no idea what is being land applied from digesters in ag.
8. We know we are environmentalists. The Iowa Governor has signed a proclamation each year for the last 15 years honoring the work that we do to keep people and the environment as clean and safe as possible as we can. Ag digester people have said ag digesters are an environmentally positive technology. That is hard to justify when ag digesters enable more hog and dairy confinements. Those digesters and confinements contribute to Iowa’s ever growing ag pollution through air emissions, and through land application of waste. Again, that ag pollution has doubled in the last 20 years.
Dairies and ag digesters, through land application of waste in NE Wisconsin, have recreated a dead zone in the Green Bay of Lake Michigan that was pretty much cleaned up by the Clean Water Act in the early 70’s. Today that dead zone is back with a vengeance. A study showed that some 47% of that dead zone is from phosphorus from confinement dairies and ag digesters land application of their waste. If you add in nitrogen from those sources, it ends up that some 90% of the pollution in the dead zone is from confinement dairies and ag digesters. Hardly an environmental positive.
Ag doesn’t even need digesters to capture methane. I ended my EPA ag digester presentation by identifying an unlimited, and unregulated, source of methane from industrial agriculture which can be accessed without building new digesters or transporting any waste streams.
In our DNR lawsuit asking that the DNR regulate air emissions coming from hog confinements, the judge wrote in the “Order Granting Motion To Dismiss” this: “Section 459.207 is one of many “Air Quality” protections contained in Subchapter II. Section 459.207 expressly addresses the emission of “airborne pollutants,” including the emission of “ammonia” and “hydrogen sulfide,” from “confinement feeding operation structure[s].” And it expressly authorizes the DNR to take various measures to “control” and “reduce” the emission of those pollutants “from animal feeding operations.”
But, in May 2003, SJR 5 nullified the ambient air standards for hydrogen-sulfide and ammonia. So the law exists on the books, but the DNR can’t enforce it. Essentially it is illegal to regulate the air emissions coming out of hog confinements which happens 24/7/365 and includes methane.
Therefore, there is an unlimited, unregulated supply of methane that can be captured at the some 13,000 hog and dairy confinements that exist in Iowa. You don’t have to build new taxpayer subsidized ag digesters. You don’t have to transport any waste. Just put your methane capture equipment on any hog confinement you want.
So I have gone over the differences between ag digesters and wwtp digesters. I hope this will help you explain the differences if you are ever involved in conversations where ag digester people are comparing their use of digesters with our successful use over the years. We should not let them use us to justify their different use of digesters.
This document will be on my website if you want to review or copy it, www.civandinc.com . Just click on the title “2025 IAWEA digester presentation” at the top of the website page.
I’ll leave you with this thought, using anaerobic digesters in ag is a moral and ethical quagmire.
Thank you. Questions and comments?
Bob Watson
My Nov 7, 2023 presentation at the EPA – Iowa State – Iowa U ag digester conference:
A Contextual History of Digester Technology
This will be a contextual history of digester technology, where it came from, how it was originally used, what was transferred with it and what was not when it was transferred to industrial agriculture. This presentation will include a conversation about regulations, or their absence, federal and state legislation, a major waste stream which will be used as a feedstock for these digesters, the human health and environmental problems from that waste stream, and a discussion of recent problems, including a death.
This presentation will end by identifying an unlimited, and unregulated, source of
methane from industrial agriculture which can be accessed without building new digesters or transporting any waste streams.
I was a member of the Iowa Department of Natural Resources committee that was writing draft regulations for industrial agricultural anaerobic digesters. There were no regulations for digesters in ag. Although called Waste Conversion Technology in ag, these were anaerobic digesters based on wastewater digesters that were part of wastewater treatment processes. A draft document was partially done when I joined that committee.
My first contribution to the committee was mentioning that even though the draft regulations said that no hazardous waste was to be allowed in these ag digesters, hog confinement waste, a major waste stream for these digesters, fit Iowa’s definition of hazardous waste to a “T”.
Iowa Code 455B.411 subsection 3:
3.
a. “Hazardous waste” means a waste or combination of wastes that, because of its quantity, concentration, biological degradation, leaching from precipitation, or physical, chemical, or infectious characteristics, has either of the following effects:
(1) Causes, or significantly contributes to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness.
(2) Poses a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. “Hazardous waste” may include but is not limited to wastes that are toxic, corrosive or flammable or irritants, strong sensitizers or explosives.
The gasses hydrogen-sulfide and ammonia, the green house and explosive gas methane, antibiotic-resistant organisms, particulates, and toxic VOC’s are cooked up during anaerobic digestion in hog confinements and are contained in hog confinement waste. This pollution is blown or vented out of hog confinements 24/7/365 so the pigs inside won’t die.
High concentrations of hydrogen-sulfide can cause respiratory paralysis and may cause coma after a single breath and may be rapidly fatal. Also convulsions, acute conjunctivitis with pain, lacrimation, and photophobia; rhinitis, pharyngitis, bronchitis, and pneumonitis among others are mentioned. Ammonia vapor is a severe irritant of the eyes, especially the cornea, the respiratory tract, and skin. Also mentioned are dyspnea, bronchospasm, chest pain and pulmonary edema which may be fatal; bronchitis, pneumonia, and asthma are also problems. There can be health problems when people are colonized by antibiotic-resistant organisms such as MRSA. There are respiratory problems from particulates. And the 20 or so toxic VOC’s also are harmful to human health. These fit the Iowa hazardous waste definition.
I will mention three studies that move these health problems from “can happen” to “do happen” to Iowa people. The Sigurdarson-Kline study shows that if a rural school has a confinement within 10 miles, 11.7% of the children exhibit asthma health outcomes – nearly two times the state rate. If a confinement is within ½ mile of a school, 24.6% of children exhibit asthma health outcomes – nearly four times the state rate. The Merchant study shows that if you are a kid that lives on a farm with a confinement that adds antibiotics to feed, there is a 55.8% chance you will experience asthma health outcomes – more than eight times the state rate.
The Smith study shows that if you are a veteran who lives within one mile of a confinement in Iowa, you are almost three times more likely to be colonized by MRSA than a veteran who lives outside that 1 mile limit. This can lead to serious health issues where antibiotics will not help you.
I met Dr. Kelley Donham in the early 2000’s. One thing we were both looking at were deaths in hog confinements from hydrogen-sulfide. Because confinements are not covered by OSHA, deaths do not have to be recorded, so we were looking through Iowa newspapers counting up the deaths we could find. Adding our counts together, we counted some 25 deaths which more than likely were not the complete numbers at that time.
These health problems, and deaths, of Iowans from hog confinement waste should give you serious pause because hog confinement waste is a major feedstock of the digesters this conference is about. Similar to other bandaids for industrial ag like CO2 pipelines, edge of field practices, and ethanol, ag digesters used this way are a bandaid that tries to give industrial hog confinements relevance, but actually enable those confinements to continue polluting no matter the inherent ongoing human health and environmental problems that exist by using them. But, you are here at this conference, so maybe this is new information for you.
When I made the DNR Chair of the committee aware of this hazardous waste problem, his answer to me was that the feds and the state say that because this is ag, this waste cannot be described as hazardous. I quote: “The Code citation is a legislative decision and matches the federal exclusion. I don’t believe Iowa DNR can do anything contrary to the state and federal statutes.”
So something that is known to be a hazardous waste is not a hazardous waste in ag just because the feds and the state say it isn’t. Think about that for a second. Are people whose health is affected by these hazardous wastes told they are not really affected? Are Iowa families who have lost family members told that the deaths were not from a hazardous waste? The statement that “this is not really hazardous waste so we don’t protect you from it” is not really a satisfactory response for families who have had members die, and for people who have serious health issues from this waste.
The 2014 Jillian Fry Johns Hopkins study goes into great detail showing and discussing the gap between known public health threats from industrial agriculture and what is being done to protect the public through regulations from those known health threats. From the study: “Research has found that the main foci of environment agencies have shifted to permitting, enforcement, record keeping, and standard setting, and away from public health evaluations.” In other words, no one seems to care about the health of people in proximity to hog confinements, and there are no regulations protecting them.
I didn’t hear anything from the committee after that and figured I was dropped from the committee for mentioning that observation. I found out subsequently that I wasn’t dropped from the committee, but rather the Iowa Legislature passed Senate File 534 in 2019 that said the DNR couldn’t regulate agricultural digesters, and the committee was disbanded.
Imagine my surprise when a couple of years later, the Legislature passed a law, House File 522, that said that anaerobic digesters could be used in conjunction with hog confinements in Iowa. The state also said that they would subsidize these digesters with taxpayer funds. In articles supporting this move, it was stated that the wastewater industry has used anaerobic digesters for decades with success.
Well yes, but those digesters are only one part of a treatment process, and those treatment plants are run by licensed, think education levels, operators. Wastewater digesters have to follow design standards. Operators have DNR regulations that they have to adhere to. They have to follow federal OSHA occupational safety and health regulations, and OSHA considers digesters a “confined space”, which are the most dangerous places in the treatment process. Remember, the Iowa Legislature said that ag digesters could not have DNR regulations applied to them, and in Iowa, OSHA does not regulate agriculture. So there are no regulations protecting workers or the public.
Because of regulations, this is an example of an SOP (standard operating procedure) when working on an anaerobic digester at a wastewater treatment plant. (SOP is printed below this presentation) Remember, ag digesters don’t have regulations.
Well, what could happen when there are no regulations for ag digesters? A headline in the CR Gazette: “No OSHA probe of man who died in dive into farm digester.” “Questions raised abut diver’s equipment and temperature of tank” by Erin Jordan, CR Gazette, June 17, 2021. “Bob Baenziger Jr., 54, of East Moline died around 10am June 8th when he was unable to return to the top of the liquid in the tank at Sievers Family Farm in Stockton, according to New Liberty Fire Chief Chad Petersen.” “As his fiancée was trying to pull him up, there were complications and he didn’t surface,” Scott County Sheriff’s Capt. Joe Caffery said. “For whatever reason, he relayed to her through radio communications that he was taking his helmet off. So when she pulled the rope up, the helmet came up.” Since OSHA regulations were not involved, the investigation was closed. No education, no safety equipment. In a rather morbid irony, the day he died was the same day that Gov Reynolds signed the law that allowed on-farm digesters, House File 522. House File 522 also led to this conference.
[A later note on the death: The temperature of the digester was supposed to be 99 to 105 degrees. The temperature was actually 120 degrees and too hot for the commercial divers that were brought in to recover the body. Nearly 100,000 gallons of water had to be brought in to cool the digester enough for the divers to recover the body. From the Gazette article, ‘Frank Frosolone, owner of the company that recovered the body, said it did not appear Baenziger had on the proper gear for a dive into liquids contaminated with manure and food waste. “It’s a contaminated dive, so we had to use specialized suits with double seals and triple backup air supply and communications. You got to have the right stuff,” he said. Frosolone said he did not believe Baenziger was using protective equipment, such as a harness or a backup air source. “He didn’t have any of that stuff,” he said.’]
A little know fact is that even though the Iowa Nutrient Reduction Strategy (INRS) is completely voluntary for ag, it is not voluntary for wastewater treatment plants which do have actual new nitrogen and phosphorus limits. To meet the required INRS limits, many plants in the wastewater industry are changing their treatment processes and moving away from anaerobic digesters. Agriculture is going to use digesters as a stand alone piece of equipment when that technology is historically only one part of a wastewater treatment process. Ag is going to use a technology that many in wastewater are moving away from. Ag is going to use a very dangerous “confined space” technology without any of the regulations that protect the workers and the public.
This ag digester legislative sleight-of-hand is similar to the legislative sleight-of-hand that happened with hog confinements, which ag digesters are supposed to enhance, but actually will be enabling that continuing confinement use. In passing the law which directed the DNR to regulate hog confinements, the Legislature only wrote language which allowed the water pollution avenue to be regulated, and not the other pollution avenue, the air pollution avenue. Because of this legislative omission, it is illegal in Iowa to regulate air pollution which is, and has been, coming out of hog confinements 24/7/365 for years causing the deaths and human health problems I have mentioned. This pollution is blown or vented out of the confinement so the pigs inside won’t die, but with no regard for the people who live in proximity, or the larger environment.
So now the Legislature and the Reynolds’ Administration are patting themselves on the back, and you are attending this conference, for coming up with the idea that ag digesters can capture methane from hog confinement waste transferred to ag digesters and help in the climate crisis. Meanwhile the Legislature made it illegal to regulate any of the pollutants, including methane, already spewing out of the some 13,000 Iowa hog confinements. Ag producers don’t have to worry about regulations. And, Iowans will have to help pay for these ag digesters through our tax money being used as subsidies.
Ag digesters are a bandaid attempt to give the inherently polluting industrial ag model relevance, and a “climate washing” attempt to mislead the public into thinking hog confinements and ag digesters can help clean up the environment and therefore are a good thing for Iowa.
I have discussed digester technology, where it came from, how it was originally used, what was transferred with it and what was not when it was transferred to industrial agriculture. I have discussed regulations, or their absence, both federal and state legislation, a major “hazardous waste” stream which will be used as a feedstock for these digesters, human health and environmental problems from that waste stream, and a discussion of recent problems, including a death.
As I mentioned at the beginning, I will end this presentation by identifying an unlimited, and unregulated, source of methane from industrial agriculture which can be accessed without building new digesters or transporting any waste streams.
In our DNR lawsuit, the judge wrote in the “Order Granting Motion To Dismiss” this: “Section 459.207 is one of many “Air Quality” protections contained in Subchapter II. Section 459.207 expressly addresses the emission of “airborne pollutants,” including the emission of “ammonia” and “hydrogen sulfide,” from “confinement feeding operation structure[s].” And it expressly authorizes the DNR to take various measures to “control” and “reduce” the emission of those pollutants “from animal feeding operations.”
But, in May 2003 SJR 5, which nullified the ambient air standards for hydrogen-sulfide and ammonia, was signed into law. So the law exists but you can’t enforce it. Essentially it is illegal to regulate the air emissions coming out of hog confinements which happens 24/7/365 and includes methane.
Therefore, there is an unlimited, unregulated supply of methane that can be captured at the some 13,000 hog confinements that exist in Iowa. You don’t have to build new taxpayer subsidized ag digesters. You don’t have to transport any waste. Just put your methane capture equipment on any hog confinement you want.
I’ll leave you with this thought, using anaerobic digesters in ag is a moral and ethical quagmire.
Thank you.
Bob Watson
Standard Operating Procedures – WWTP Digester Work:
Pre-Arrival to Job Site:
• Tank is structurally safe. Lid is safe. The lid will support a 700 Lbs pump and 400 lbs. of manpower and additional equipment.
• The tank lids, if required, have been opened by the customer. Ventilation is in process. There are no unusual or high readings by customer’s gas monitoring equipment.
• Access to the tank or tanks is clear of equipment and traffic.
• The customer has arranged for a qualified lifting devise and operator for placement of or pumping equipment on the tank lid.
• The customer has arranged for qualified elections who know the plant power specifications and our pump specification for 3- phase power.
• The customer has supplied a telephone list of plant personnel for contact by our crew.
• Emergency telephone numbers for Fire, Ambulance and Police have been provided by the customer.
• Power source has been identified for 3-phase and 110 power.
• Tank design specifications can be obtained from the customer.
• The customer has identified any potential hazards in and around the plant.
• Lock-out tag out information has been identified by the customer for any feed lines to the tank to be cleaned.
• The contractor’s gas monitor has been calibrated to specification.
Set-up for Tank Work/Cleaning.
* The atmosphere around the tank has been tested. The tank atmosphere has been tested.
* All power cords to pumps, lights and repairable air systems have been inspected. Cords have been covered for chaffing or wear.
• Pumps have been inspected for proper clearances from impeller to chopper plate.
• The chain hoist has been inspected for proper operation.
• The Fall protection winch has been inspected.
• Harnesses have been inspected. Web, seams, D-Ring, and buckles
• The repairable air system has been inspected for proper operation. Both filters have been inspected.
• SCBA (self contained breathing apparatus) system has been inspected. Tank volume is sufficient. Face mask has been cleaned.
• The power panel has been inspected and the ground rod installation is complete with the proper cord connection.
• Ladders and rope ladders have been inspected. Stokes retrieval basket is on site and inspected.
• While the tank is being cleaned continuous gas monitoring will be completed by a (4) gas meter BW-Gas Alert Micro Clip X3 or the equivalent.
• Gases monitored while staff are in the tank or around the tank shall be the following: Hydrogen Sulfide, Flammable gases, Carbon Monoxide, Oxygen in the event of an alarm all personnel shall immediately exit the tank until tank is ventilated further and safe entry can be completed.