EPA 430/9-80-015
SEPTEMBER 1980
A GUIDE TO REGULATIONS AND GUIDANCE
FOR THE
UTILIZATION AND DISPOSAL OF MUNICIPAL SEWAGE SLUDGE
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER AND WASTE MANAGEMENT
WASHINGTON, D. C. 20460
MCD-72
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CONTENTS
Section Page No
Preamble i
Introduction 1
Treatment and Volume Reduction Methods
Incineration (Thermal Reduction) 11
Composting 20
Surface Impoundments 25
Ultimate Utilization and Disposal Methods
Landfills 29
Ocean Dumping and Discharge 34
Landspreading 37
Distribution and Marketing (Giveaway/Sale) 46
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PREAMBLE
Beginning on May 14, 1980, the Environmental Protection Agency
distributed for comment over 600 copies of a draft guidance document, "A
Guide to Regulations and Guidance for the Utilization and Disposal of
Municipal Sewage Sludge". Drafts were sent to other Federal agencies,
state regulatory agencies, Canadian governmental units, environmental
groups, the environmental press, municipalities, counties, cities,
consultants, university extension and research groups, industries, trade
associations, and special interest groups. This document provides a
concise outline of the different Federal regulations and guidelines that
pertain to each alternative for sludge utilization and disposal and
points out how these regulations and guidelines should be addressed.
This guidance document is not an assessment of health and environ-
mental risks. It assumes that such risks will be adequately minimized
when regulations and guidelines are followed. Discussions, however, are
included for dealing with potential environmental, health and other
problems not addressed by the regulations and guidelines.
The written comments received were in strong support of the document
and offered many constructive comments for its improvement. The comments
were greatly appreciated and have been carefully considered by EPA in
revising and producing this final document. We believe that the quality
of the document has been significantly improved as a result of these
comments.
The following is a summary of the major comments that were received
and how the comments influenced the revision of this document.
1) Many commentors felt certain areas of the document required
greater discussion. For example, several commentors thought that the
discussion on: a) implementing disposition facilities on the local level
(introduction), and b) the relation of sewage sludge disposition to the
hazardous waste regulations (introduction) were inadequately dealt with.
In the revised document, the discussion on both of these issues has been
expanded.
A few commentors wanted a more detailed and complete cost table and
an energy analysis (introduction). The cost information is given only
as general guidance and more specific information was not available from
the sources used. The reader should also recognize that costs are highly
variable and will differ significantly depending on the individual
facility. The energy analysis has not been added to the revised document,
since this type of data was not available.
Many commentors felt additional discussion was needed on the many
different treatment methods involved in sludge management. The Agency
believes that this document's purpose can best be attained by addressing
the major items of confusion in the area of sludge management: namely,
guidance on what are the suitable methods for the ultimate disposition of
sewage sludge and on how a facility can meet the regulatory requirements.
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The only treatment methods receiving appreciable discussion were incineration
and composting, since many individuals also consider that incineration
and composting are major methods in the ultimate disposition of sludge.
The section on incineration has been slightly expanded to include minor
mention of the different methods of thermal reduction.
Many commentors requested that additional information be added to
the revised document on the design of sludge disposition facilities.
The Agency believes that this information is more appropriate for the
Agency's design manuals. Also, some commentors requested a greater
extensiveness in the problems and solutions sections. For the most
part, this guidance document is limited in scope to discussing problems
not: alleviated by regulations. In this context, this document attempts
to give general solutions to some of the more major problems encountered
with the disposition of sewage sludge. More specific solutions to
problems in facility design, operation and maintenance can be found in
the Agency's design manuals.
One commentor felt that we should have been more specific in our
discussion of the preproposal distribution and marketing regulations.
This specific discussion, however, was not included since these regulations
are in the early developmental stage and may, therefore, undergo frequent
changes.
A few commentors requested the inclusion of more monitoring require-
ments for each disposition procedure, along with the specific quantitative
standards. These monitoring standards have not been included in the
revised document, since the Agency does not intend for this guidance to
be used in place of regulations. However, specific numbers are given in
this document to guide the reader to a specific regulation or to help
clarify a regulation. For example, the landspreading section includes a
discussion of monitoring and recordkeeping, since the regulations
regarding this method of disposition are new and controversial.
Two commentors asked that the underground injection control (UIC)
regulations (40 CFR, Part 146) be included in the revised document.
After investigating this method of sludge disposal, the Agency has
determined that the underground injection of sludge has occurred rarely
and without much success. Furthermore, states have been given the
authority to operate the UIC regulatory program, and hence, the state
should be able to provide the needed guidance. For these reasons, the
underground injection method of sludge disposal has not been addressed
in the revised document.
2) Many commentors offered suggestions for improving the document's
structure, thereby permitting greater readability. They also indicated
a number of specific inaccuracies in the document. In the revised
document, these inaccuracies were corrected and many of the suggestions
given to improve the document's structure were incorporated (e.g., the
separate problem and solution sections have now been combined into one
section).
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3) One commentor suggested that too much emphasis was placed on
disposal methods and that too little emphasis was placed on utilization
methods. As that commentor also pointed out, most regulations are developed
to deal with conventional systems. Therefore, this document covers these
regulatory areas. Unfortunately, the implementation of regulations usually
lags behind the initiation of innovative and alternative technology.
However, the Agency does give a favorable advantage to utilization projects
in the Federal Construction Grants regulations (40 CFR, Part 35, Subpart E).
4) Some commentors pointed out that additional references would be
useful. In the revised document, several more references have been added,
including new publications that were not available when the draft document
was sent out for review and comment.
5) A number of commentors pointed out that recycling of sewage sludge
is an environmentally sound program that results in a reuse of a "waste"
resource and conservation of energy. They expressed concern that sludge
reuse regulations impose strict limitations in order to protect users from
several contaminants. They pointed out that very strict reuse regulations
could effectively eliminate the recycling option and could cause a shift to
disposal options. They indicated, however, that disposal options also
result in public exposure to some of the contaminants through soils and
crops, drinking water and the atmosphere. They also indicated that disposal
options may pose risks to the public and the environment which are equal to
or greater than those from reuse options and that the disposal options may
provide less benefit at costs that are equal to or greater than for the
reuse options.
Finally, these commentors indicated that regulating one method for
sludge disposition affects all remaining methods of disposition. They
pointed out that these interacting effects among regulations should be
examined, and that the risks and benefits of all methods should be compared,
before imposing very stringent regulations on any one method of sludge
disposition. They pointed out further that EPA should consider setting up
a procedure to arbitrate a solution when different regulatory authorities
promulgate regulations with restrictions that are not compatible. The
Agency agrees that the impact of regulations should be carefully examined
and that EPA should coordinate its regulatory efforts to the fullest extent
possible. These concerns are being reconciled during the development of
the comprehensive sewage sludge management regulations under the authority
of section 405 of the Clean Water Act and other authorities.
6) Many commentors were concerned with specific provisions of the
different regulations. In response to these comments, the development of
this document is not a rulemaking activity and does not permit changes in
the regulations. However, EPA will consider these comments in future
research activities and in the development of policies concerning
comprehensive sewage sludge management.
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7) One commentor suggested that the guidance document be updated
periodically. With the rapidly changing regulatory requirements, this
possibility is under consideration.
Dated September 12, 1980
Eckardt C. Beck
Assistant Administrator
Water and Waste Management
US Environmental Protection Agency
Washington, DC 20460
IV
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INTRODUCTION
This document has been prepared to provide Environmental Protection
Agency (EPA) Regional Administrators, managers and operators of publicly-
owned treatment works (POTW's), consulting engineers, state and local
regulatory authorities and others with a concise outline of current EPA
regulations and guidelines that need to be addressed, and the problems
frequently encountered, when planning and operating a sewage sludge
disposition (utilization and/or disposal) facility. This document is a
supplement to these regulations and guidelines (not a substitute) and
should aid in the selection and implementation of an appropriate disposi-
tion technique. Coverage of each method discussed includes:
(I) background information
(II) applicable laws, regulations and guidelines
(III) procedure needed for implementing the disposition method
(IV) problems frequently associated with the disposition method that
are not covered by regulations and solutions to these problems
(V) references
The background information section provides data on the current
proportion of sewage sludge handled by the described disposition alterna-
tives, salient technical facts, limitations, and other information which
helps establish the current status. The applicable laws, regulations,
and guidelines are brought together for each method of disposition in the
second section. The procedures for implementing a disposition method,
given in the third section, show which regulations need to be addressed,
what the regulations require, and recommendations for meeting the regulatory
requirements. This third section also addresses those regulatory measures
and requirements which are necessary to safeguard human health and the
environment. The fourth section addresses problems that are associated
with the planning and operation of the disposition facility and various
public health and environmental problems which are not covered by the
regulations. In cases where Federal regulations and guidelines have not
addressed a problem, examples of how state and local governments have
attempted to handle the problem are given.
The disposition alternatives discussed in this guidance document can
be classified into two general areas: 1) treatment and volume reduction
methods and 2) ultimate utilization and disposal methods. Incineration,
composting and surface impoundments are considered treatment and volume
reduction methods. Landfill ing, ocean disposal, landspreading, and
distribution and marketing are considered ultimate utilization and disposal
methods. There is some overlap between these two general classifications.
Some sections of this report are longer than others, e.g., the land-
spreading section, because of the need to help clarify the many questions
that are arising concerning these practices.
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Presently, the regulations pertaining to the utilization and disposal
of municipal sludge are located in various sections of the Code of Federal
Regulations (CFR). This paper attempts to bring the regulations together
for each disposition method. This effort is an important step in the
Agency's development of a comprehensive sewage sludge management regulation
under the authority of section 405(d) of the Clean Water Act. This
comprehensive regulation will bring together all regulations that pertain
to sludge management. The comprehensive sludge regulation will appear in
40 CFR, Part 258. The first segment of this regulation will be the
sewage sludge distribution and marketing regulations.
This guidance document is written so that only the disposition
method of concern need be read by the user. As a result, there is some
redundancy in the various sections discussing each disposition alterna-
tive. This introduction gives general information that is applicable to
all disposition methods.
General Procedure for Implementing Practices at the Local Level
Existing regulations and guidelines often give the EPA Regional
Administrators flexibility to deal with certain site specific needs.
Therefore, it is best to check with Regional EPA and state or local
officials on the applicable local regulations, policies, and procedures
pertaining to the different sludge disposition options.
It should be emphasized that the roles of state and local authorities
are paramount in the successful planning, construction, and operation of
facilities and practices for sludge disposition. These tasks are mostly
all handled locally arid are overseen at the state and Federal levels.
Specific information which local authorities can use to obtain
Federal grant assistance for the planning and construction of sludge
disposition facilities is contained in the construction grants regulations
(40 CFR, Part 35, Subpart E). Federal funds for assisting with the
operation of these facilities are not available. Other possible sources
of Federal funding are discussed in the various sections discussing each
disposition alternative.
The following is an example of how a sewage sludge disposition
practice might be implemented at the local level. In Montgomery County,
MD, an applicant who wants to operate a sewage sludge disposition
facility must supply information, each year, to the county Department of
Environmental Protection. The information must include the name and
location of the disposition facility, the mode of sewage sludge transpor-
tation and disposition, and the physical characteristics of the disposition
site. After adequate public hearings and administrative scrutiny (by the
Offices of Environmental Planning, Water Quality Control and Air Pollution
Control), the county then submits the information to the State Department
of Health. The State Department of Health will then consult with the
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Department of Natural Resources, the Water Resource Administration, the
Maryland Environmental Service, and the Maryland National Capital Park
and Planning Commission. If the planned disposition practice is found to
be acceptable by all the concerned county and state agencies, the State
Department of Health will then issue permits to approved facilities. A
facility needs to allow about a year for approval and permit issuance.
Landspreading facilities follow an additional procedure that can be found
in the landspreading section of this document. Public hearings are not
required for the individual landspreading sites. The county Agriculture
Extension Service recommends rates of sludge application after testing
the soil, and recommends how many years the sludge can be applied at
minimal risk. Maryland is currently finalizing regulations governing the
distribution and marketing of sludge products in the state.
General Factors for Consideration in the Planning of Disposition Practices
Three of the most important considerations for implementing any of
the sewage sludge disposition options are that the option be environmentally
safe, reasonable in cost, and acceptable to the public. The regulations
described in this guidance document have been written to assure environ-
mentally safe disposition. Ranges in costs for the different disposition
options are given in Table 1. General guidance for obtaining acceptable
disposition sites and gaining public acceptance is given below.
(1) Environmental Considerations
Regulations and guidelines have been developed so that sludge
disposition facilities and practices will not result in an adverse impact
on human health and the environment. These regulations and guidelines
have been developed over a period of time under the authority of different
laws. The guidance, given in the different sections of this document,
attempts to update and clarify these various regulations and guidelines.
(2) Operating and Maintenance Costs
Table 1: Estimated Operating and Maintenance Costs for Sewage
Sludge Disposition Methods in 1979 dollars (2)
Disposition Method $/dry ton
Incineration 80-2401
Composting (11) 70-2002
Surface impoundments (facultative lagoon) (8) approx. 253
Landfills 73-226k
Ocean dumping 30-505
Ocean discharge approx. 206
Landspreading 40-21O7
Distribution (11) income of 12 to
cost of 28
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1 - includes fuel costs and dewatering costs
2 - includes costs for dewatering, bulking agents, labor, capital
amortization and distribution
3 - located at POTW and excludes sludge removal costs
4 - includes treatment, dewatering and transportation, but excludes
monitoring
5 - cost is; based on transportation costs
6 - through outfalls at Los Angeles, CA
7 - includes treatment, dewatering, transportation and application
8 - data is only for finished composted sludge (20-50% moisture);
excludes treatment and preparation costs
(3) Siting of Facilities - Federal, State, and Local Roles
One of the most difficult tasks facing waste management authorities
is locating "acceptable sites" for high volume waste treatment and disposal
facilities. Ideally, locating these sites in relatively remote locations
with buffer zones and downwind from local residences helps obtain public
acceptance and lessens problems from any odors produced. Such ideal site
locations, however, are rare. Thus far EPA has maintained that locating
these sites is a function of the state and local government and the
private sector. Historically, proposed Federal entry into land use
planning activities has been vigorously opposed by state and local
governments.
Political! pressures from local citizens have placed local control
for siting in an extremely vulnerable position. Local officials have to
respond to the fears of local citizens. The broader social need for safe
waste management facilities has generally not been strongly represented
in the siting process. The result has been that many facilities have not
been sited.
States have been taking a more active role in the siting process.
For example, a number of states have passed hazardous waste siting acts,
including elaborate procedures by which the state can designate a site
for waste treatment or disposal. In the Maryland Hazardous Waste
Facilities Program Act of 1980, provisions are included by which a site
location cannot be overruled by local zoning or other ordinances once it
has been formally designated. States may also pass similar legislation
for siting norihazardous waste treatment and disposal facilities.
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EPA is preparing handbooks that describe the methods that state and
local authorities can use to gain public approval for siting waste
treatment and disposal facilities. Roles are being described for the
private sector, consultants, and state and local governments. Topics
covered will also include possibilities for community compensation and
impartial mediation, how to consult with the public, how to identify
risks, and how to select siting criteria.
(4) Public Acceptance
Securing public acceptance for a planned sludge disposition facility
is necessary in order to implement the various practices. Gaining
public acceptance is enhanced by working from the beginning with respon-
sible local officials, landowners, and other affected parties. Useful
recommendations for gaining public acceptance are contained in The Process
Design Manual for Sludge Treatment and Disposal (8). These steps involve
holding public hearings, conducting surveys and workshops, distributing
pamphlets, advertising, etc. The public should be made aware of the
different sludge disposal options available, along with their benefits,
risks and monetary costs. Public acceptance can be increased by open
discussions of the pros and cons of the various alternatives and where
necessary by conducting demonstrations that can help determine the most
cost effective and environmentally acceptable disposition alternative for
a particular location.
Applicable Federal Laws
(1) CWA (Clean Water Act of 1977, PL 95-217 and the Federal Water
Pollution Control Act of 1972, PL 92-500) authorizes Federal funding
of 75% (85% for innovative and alternative technology projects) of
the eligible costs involved in the construction of municipal waste-
water treatment plants and sludge treatment and disposition facilities;
authorizes EPA to issue comprehensive sewage sludge management
guidelines and regulations; authorizes the NPDES (National Pollution
Discharge Elimination System) for point source discharges and
development of areawide waste treatment or water quality management
plans for non-point source pollution; requires the implementation of
pretreatment standards for industrial discharges that enter POTW's;
and establishes a major research and demonstration program to
develop improved wastewater treatment and sludge management practices.
(2) RCRA (Resource Conservation and Recovery Act of 1976, PL 94-580)
provides financial assistance to state and local governments for
development of solid waste management plans which provide for the
safe disposal of solid waste; provides that technical assistance be
provided to help establish acceptable solid waste management methods;
requires regulations for the safe disposal of hazardous and non-
hazardous wastes; and encourages the research and demonstration of
more effective solid waste disposal and resource conservation
technologies.
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(3) MPRSA (Marine Protection Research and Sanctuaries Act of 1977,
PL 92-532) effectively phases out ocean disposal of sewage sludge by
December 31, 1981. MPRSA also gives EPA the authority to determine
a reasonable compliance schedule for the implementation of land-
based disposal alternatives.
(4) CAA (Clean Air Act Amendments of 1970 and 1977, PL 91-604 and
PL 95-95) authorized the development of State Implementation Plans
(SIP's) for the purpose of meeting Federal ambient air quality
standards. To meet the CAA objectives, EPA has developed an emission
offset policy for new or modified incinerator and heat drying facilities
and a procedure for preventing the significant deterioration of
ambient air quality. CAA also authorizes regulations for the control
of hazardous air pollutants and new source performance standards.
(5) SDWA (Safe Drinking Water Act of 1975, PL 93-523) requires coordination
with the CWA and RCRA to protect drinking water from contamination.
(6) NEPA (National Environmental Policy Act of 1969, PL 91-190) authorizes
Regional Administrators, at their discretion, to require Environmental
Impact Statements (EIS) (40 CFR, Part 6) if potential adverse social,
economic or environmental impacts are suspected for a new or modified
sludge disposition facility or practice. An EIS or negative declaration
(40 CFR, Part 35, Sect. 35.925-8) is also required when applying for
Federal Construction Grants.
(7) TSCA (Toxic Substances Control Act of 1976, PL 94-469), Section 9,
requires coordination with the Clean Air Act and the Clean Water Act
to restrict disposal of hazardous wastes. Presently only PCB
(polychlorinated biphenyl) is specifically regulated in regards to
sludge disposition.
Applicable Regulations
The following regulations apply to the various sludge disposition
methods. More detailed coverage of these regulations is given in the
appropriate sections of this guidance document, except for the regulations
dealing with hazardous waste, industrial pretreatment and PCB's. These
latter three regulations potentially apply to all disposition methods.
Therefore, to avoid redundancy, they are discussed below and not in the
individual sections of this guidance document.
(1) Criteria for the Classification of Solid Waste Disposal Facilities
and Practices (40 CFR, Part 257; Federal Register, Sept. 13, 1979)
is authorized by Section 405(d) of the CWA and 4004(a) and 1008(a)(3)
of the RCRA, and is referred to in this guidance as the "Criteria".
Guidance Manual SW-828 should be consulted to determine if a facility
complies with the Criteria.
(2) NPDES (National Pollution Discharge Elimination System, 40 CFR, Part
125) is authorized by Section 402 of the FWPCA.
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(3) Federal Construction Grants Regulations (40 CFR, Part 35, Subpart E;
Federal Register, Sept. 27, 1978) are authorized by section 201 of
the CWA.
(4) State or Areawide Waste Treatment Management Plans are authorized by
Sect. 208 of the CWA.
(5) Air Regulations are authorized by the CAA.
(6) Ocean Dumping Regulations are authorized by MPRSA and CWA
(7) Hazardous Waste Regulations (40 CFR, Parts 260-265; FR May 19, 1980)
Subtitle C of RCRA authorized the development of hazardous waste
regulations. Under the proposed hazardous waste regulations, issued on
December 18, 1978 in the Federal Register, municipal sewage sludges were
excluded from coverage under Subtitle C of RCRA. Subsequently, in the
final regulations promulgated in the Federal Register on May 19, 1980,
municipal sewage sludges were no longer excluded from coverage and thus
are potentially subject to control as hazardous waste.
Domestic sewage and any mixture of domestic sewage and other wastes
that passes through a sewer system to a POTW for treatment is not considered
a solid waste [40 CFR Part 261 .4(a) (1 )]. Under all circumstances, however,
municipal sewage sludge that is separated from the sewage during treatment
is considered a solid waste [261. 2(a)]. In general, a solid waste is a
hazardous waste if it has been listed as such by the Administrator or if it
exhibits any of the defined characteristics of a hazardous waste [261. 3(a)].
EPA has not listed municipal sewage sludges as hazardous wastes.
Therefore, municipal sewage sludges are not considered hazardous unless
tested and shown to be hazardous. While not included in the Agency's
listing of hazardous wastes under Subpart D, of Part 261, specific municipal
sewage sludges will be considered hazardous if they exhibit any one of
the four characteristics of hazardous waste (261.21 through 261.24 i.e.,
ignitability, corrosivity, reactivity, and EP toxicity). Specific municipal
sewage sludges would also be considered hazardous if they were mixed with
any hazardous waste other than those entering the publicly owned treatment
works (POTWs) through a sanitary sewer system [261 .3(a) (2)(ii ) and
Municipalities have an obligation to determine if their sludge meets
the definition of a hazardous waste. This does not mean that each POTW
must test their sludge. Rather, POTW's or other waste handlers must make
a determination that the waste is not hazardous, based upon knowledge of
the waste, including the contaminants, etc. EPA advises testing, particularly
EP toxicity testing, where there are significant contributions of industrial
wastewater or stormwater into the POTW or where there is any reason to
believe that the sludge may exhibit the EP toxicity characteristic. EPA
believes that POTW sludge will rarely, if ever, exhibit the other three
characteristics of a hazardous wastes and believes that a determination
can be made based on knowledge about the sludge, without need of testing.
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The regulations place the responsibility of determining whether a
POTW sludge is a hazardous waste squarely on the owner or operator of the
POTW. He may choose any method he likes to make this determination. If
he determines that his sludge is not a hazardous waste or fails to make a
determination, and EPA finds that the sludge is a hazardous waste, then
he is in violation of the regulations.
EPA believes that the vast majority of the POTW's do not generate a
sludge which is a hazardous waste. However, we do not have a large
amount of data to indicate which POTW's would be the likely sources of
hazardous waste sludges. The characteristic most likely to cause a
sludge to be hazardous would be toxicity, determined by the extraction
procedure (EP). In very limited tests by EPA, cadmium is the only known
element that has caused a sludge to fail the EP, i.e., be considered
hazardous.
Any POTW that generates or transports a municipal sewage sludge
which it believes to be hazardous and who plans to continue to generate,
transport, treat or dispose of more than 1000 kg at any time, must notify
EPA of their activity. A POTW, which is only a generator of a hazardous
municipal sewage sludge and that does not also treat, store, or dispose
of the sludge, does not require a hazardous waste permit. This POTW
generator, however, does have a major responsibility to follow all the
provisions of 40 CFR Part 262. A POTW would also require a hazardous
waste permit if it engaged in treating, storing, or disposing of hazardous
municipal sludge in the quantities described above. As part of this
permitting process, an existing POTW must obtain interim status as a
hazardous waste treater, storer, or disposer. To obtain this interim
status the applicant POTW would have had to notify EPA by August 18, 1980,
and submit a completed Part A permit application to the appropriate EPA
regional office by November 19, 1980.
If interim status has not been obtained, then the POTW would not be
able to operate under the interim status provisions of the hazardous
waste regulations. The POTW would have to notify EPA that they are
generating a hazardous sludge. The POTW would also have to comply with
the applicable requirements of Parts 262 and 263. Finally, if the POTW
treated, stored, or disposed of its hazardous sludge onsite, then it must
submit Part A and Part B of a permit application in accordance with
Section 122.26(b). And, because the POTW did not have Interim Status it
would have to refrain from treating, storing, or disposing of its sludge
onsite after November 19, 1980, until it were issued a RCRA, Subtitle C
permit. While waiting for the issuance of a permit, the POTW would have
to send its hazardous sludge to a hazardous waste treatment, storage, or
disposal facility that has Interim Status or has been issued a RCRA,
Subtitle C permit.
EPA recognizes that the lack of interim status may and often will
present a very difficult problem for POTW's caught in this predicament.
This is because (a) it will take time to issue a permit, (b) in the
interim, it forecloses onsite digestion, dewatering and storage (except
90-day accumulation) of the large volumes of sludge typically generated
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by a POTW and (c) it requires unanticipated off-site transportation of the
sludge to hazardous waste facilities that may not be available or may be
located long distances away. EPA is currently examining the unique problems
of POTW's regarding compliance with this provision. Any POTW that generates,
treats, transports, stores, or disposes of a hazardous municipal sewage
sludge without filing the notification is subject to civil or criminal
penalties.
See POM 80-4 arid addendum 1 to POM 80-4 for additional information on
the effect of hazardous waste regulations on management of municipal
sewage sludge.
(&) Industrial Pretreatment Regulations
Section 307 of the CWA authorized regulations (40 CFR, Part 403) for
industrial pretreatment. One of the objectives of the pretreatment
regulations is to prevent the introduction of pollutants into POTW's which
will contaminate the sludge and thereby impair opportunities for the
utilization and cost-effective disposal of sludge. Therefore, with the
various new industrial pretreatment regulations taking effect in the near
future, the amount of sewage sludge suitable for disposition via the
various options discussed should increase. For example, POTW's involved
in landspreading practices may need to insist upon effective pretreatment
of industrial waste for control of contaminants of concern in order to
meet regulations designed to protect human health and the environment in a
cost-effective manner.
Applicable Guidelines
The following guidelines apply to the various disposition practices.
Additional specific guidelines are given in the appropriate sections of
this document.
(1) US EPA, 1980. Classifying Solid Waste Disposal Facilities, A Guidance
Manual. SW-828.
(2) US EPA, 1979. Process Design Manual for Sludge Treatment and Disposal.
US EPA Center for Research Information. EPA-625/1-79-011.
(3) US EPA, 1978. Process Design Manual: Municipal Sludge Landfills.
EPA-625/1-78-010. SW-705.
(4) US EPA, 1978. Sludge Treatment and Disposal. Technology Transfer.
Vol. 2. EPA-625/4-78-012.
(5) US EPA, 1978. Applications of Sludges and Wastewaters on Agricultural
Land: A Planning and Educational Guide. Office of Water Program
Operations. MCD-35.
(6) US EPA, 1977. Municipal Sludge Management: Environmental Factors.
Technical Bulletin. Office of Water Program Operations. MCD-28. EPA
430/9-77-004. (Referred to in this guidance document as the Sludge
Technical Bulletin or STB).
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(7) Guidelines Establishing Test Procedures for Analysis of Pollutants
(40 CFR, Part 136).
(8) A. US EPA. Construction Grants Program Operations Memorandum POM
80-4. The Effect of the Hazardous Waste Regulations on Management
of Municipal Sewage Sludge, July 1980.
B. Addendum 1 to POM 80-4, August 1980.
(9) US EPA, 1980. Draft: Construction Grants Program Requirements Memorandum
(PRM). Eligibility of Land Acquisition Costs (By Either Fee Simple
Purchase, Lease, or Easement) for Land Treatment of Wastewater and
Sludge, and Policy Regarding "No Cost" Arrangements for Sludge Application
Office of Water Program Operations.
References
(1) Haug, R.T., L. D. Tortorici and S. K. Raksit, 1977. Sludge Processing
and Disposal, A State of the Art Review. Prepared for Regional
Wastewater Solids Management Program, Los Angeles/Orange County
Metropolitan Area.
(2) US EPA. 1979. Comprehensive Sludge Study Relevant to Section 8002(g)
of the RCRA of 1976. SW-802.
(3) US EPA. 1980. Evaluation of Sludge Management Systems: Evaluation
Checklist and Supporting Commentary. EPA 430/9-80-001, MCD-61.
(4) US EPA, 1980. Handbook of Procedures, Construction Grants Program
for Municipal Wastewater Treatment Works, 2nd Ed. Office of Water
Program Operations. MCD-03.
(5) US EPA, 1978. Innovative and Alternative Technology Assessment Manual.
EPA 4-30/9-78-009. MCD-53.
(6) US EPA, 1976. Municipal Sludge Management: EPA Construction Grants
Program, An Overview of the Sludge Management Situation. EPA 430/9-76-009.
(7) US EPA, 1978. Multimedium Management of Municipal Sludge. Analytical
Studies for the US EPA. Vol. IX. National Academy of Sciences,
Washington, DC.
(8) US EPA, 1979. Process Design Manual for Sludge Treatment and Disposal.
EPA 625/1-79-011.
(9) US EPA, 1977. Sludge Handling and Disposal Practices at Selected
Municipal Wastewater Treatment Plants. EPA 430/9-77-007, MCD-36.
(10) US EPA, 1977. Transport of Sewage Sludge. EPA 600/2-77-216.
(11) Walker, J.M., M. S. Winsten and J. E. Hall, 1979. A Critical Review
of the Performance of Sewage Sludge Composting Operations. Presented
at the National Conference on Municipal and Industrial Sludge Composting,
New Carrollton, MD. Sponsor: Information Transfer, Inc., Silver Spring,
MD, November, pp 5-14.
10
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TREATMENT AND VOLUME REDUCTION METHODS
INCINERATION (THERMAL REDUCTION)
I. Background
(A) in 1978, approximately 22% of all sewage sludge was incinerated
(13,14)
(B) an effective process for volume reduction and stabilization.
Approximately 35% (dry wt.) and 20% (volume) of the solids remain
after incineration and require disposal.
(C) in 1979 approximately 350-400 municipal sludge incinerators were
in operation (13,17)
(D) 80% of sludge incinerators are multi-hearth; remainder are
mostly fluidized bed reactors (11)
(E) ash may contain variable amounts of fertilizer nutrients, but
the usefulness as a fertilizer can be limited by concentrated
metals
(F) other methods of thermal reduction include:
(1) coincineration - with refuse, refuse derived fuel (RDF),
coal, etc. (reduces the need for gas and oil as an auxiliary
fuel)
(2) starved air combustion (SAC) or pyrolysis - still early in
the development stage, SAC may possibly require less fuel,
emit fewer particulates than conventional incinerators, and
produce a low energy content gas, oil, and char
(3) heat drying - produces a usable fertilizer product that
retains most of the plant available nitrogen
11. Applicable Laws, Regulations and Guidelines
(A) laws
(1) CWA
(2) CAA
(3) RCRA
(4) SDWA
(5) TSCA
(6) NEPA
(B) regulations
(1) New Source Review (NSR) is authorized by Section 110, 172 and
173 of the CAA
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(2) National Ambient Air Quality Standards (NAAQS) is authorized
by Section 109 of the CAA
(3) National Emission Standards for Hazardous Air Pollutants
(NESHAP) is authorized by Section 112 of the CAA
(4) New Source Performance Standards (NSPS) is authorized by
Section 111 of the CAA
(5) Prevention of Significant Deterioration (PSD) is authorized
by Section 160-169 of the CAA
(6) State Implementation Plans are authorized by Section 110
of the CAA
(7) Criteria for the Classification of Solid Waste Disposal
Facilities and Practices (40 CFR, Part 257; FR, Sept. 21,
1979)
(8) Construction Grants Regulations (40 CFR, Part 35, Subpart E)
(9) PCB Regulations (40 CFR, Part 761)
(10) NPDES Permits (40 CFR, Part 125)
(11) Hazardous Waste Regulations (40 CFR, Parts 260-265; FR,
May 19, 1980)
(12) Distribution and Marketing Regulations (Preproposal Draft,
May 6, 1980)
(C) guidelines
(1) Sludge 3rocess Design Manual (EPA-625/1-79-011 )
(2) Sludge Technical Bulletin (EPA/430-9-77-004)
III. Procedure for Starting a_ jlew or Modified
Three basic regulatory areas need to be addressed when a facility is
planning to dispose of sludge by incineration. These include: air quality
regulations, ash disposal regulations, and Federal Construction Grants
regulations. The same regulations apply for thermal drying of sludge
that apply for incineration, except that the distribution and marketing
regulations (now being developed) will cover the dried sludge product
(instead of the Criteria which pertains to ash disposal). The process
required to obtain the necessary permits can take from 6 to 42 months to
complete (1 ) .
(A) air quality regulations
Air quality regulations apply to all the methods used in the
thermal reduction of sludge, e.g., conventional incineration,
coincineration, pyrolysis, heat drying, etc.
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For certain air pollutants, EPA has set primary and secondary
National Ambient Air Quality Standards (NAAQS; 40 CFR, Part 50).
The CAA of 1970 required that each state develop its own control
strategy or State Implementation Plan (SIP), subject to EPA
approval, to meet the NAAQS. Federal standards have also been
developed for the control of hazardous pollutants and for new
source performance.
The SIP (40 CFR, Part 51 and 52) is required to provide for
emission controls, source and ambient air quality monitoring,
emission offset policies, procedures for the review and approval
of new sources of air pollution prior to construction (New Source
Review Rule; 40 CFR, Part 51, Sect. 51.18), and procedures to
prevent the significant deterioration of ambient air quality
(Prevention of Significant Deterioration; 40 CFR, Part 51, Sect.
51.24 and Part 52, Sect. 52.21).
There are three general air quality requirements that sludge
incinerators should comply with: 1) compliance with the SIP; 2)
compliance with National Emission Standards for Hazardous Air
Pollutants (NESHAP) and New Source Performance Standards (NSPS)
(unless the state in question included the NESHAP and NSPS in
their SIP); and 3) compliance with any additional provisions of
the SIP, not required by Federal law.
(1) compliance with State Implementation Plan (SIP)
SIP's require the preconstruction or new source review (NSR)
for any new sludge incinerator construction or modifications
if a specified emission rate is expected to be exceeded.
SIP's have EPA approved compliance schedules to meet primary
and secondary ambient air quality standards. National
primary ambient air quality standards define levels of air
quality which are necessary and which include an adequate
margin of safety to protect the public health. National
secondary ambient air quality standards define levels of air
quality which are necessary to protect the public welfare
from any known or anticipated adverse effects of a pollutant.
National primary and secondary ambient air quality standards
are given for the following pollutants: sulfur dioxide,
particulate matter, carbon monoxide, photochemical oxidants,
hydrocarbons, nitrogen dioxide and lead.
(a) SIP's will have strict emission limits if the facility
is in a non-attainment area for a specific pollutant. A
non-attainment area has an ambient air quality that is
worse than the NAAQS for a specific pollutant. For
pollutant emissions in a non-attainment area the facility
may need to acquire an emission offset that is greater
than one-to-one from within the facility or from a
13
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neighboring facility; demonstrate that, based on
technical feasibility, the facility is producing the
Lowest Achievable Emission Rate (LAER) for the violating
pollutants; and assure that all other major sources
within the facility are on an approved compliance
schedule for the violating pollutants included in the
SIP.
Coincineration is exempt from the Federal emission
offset policy for non-attainment areas (however, it may
not be excluded from the state policy), if the Best
Available Control Technology (BACT) is used to limit
emissions and if more than 50% of the heat input is
used for generating steam or electricity. In addition,
the use of refuse derived fuel in an existing boiler
would not be considered a modification and, hence,
would not be subject to the emission offset policy (FR,
Jan. 16, 1979, 3274-3285).
(b) if the facility is in an attainment area (an area where
specific pollutant emissions result in ambient air
quality at a level equivalent to, or better than the
NAAQS) then the facility must comply with regulations
pertaining to the Prevention of Significant Deterioration
(PSD). The PSD regulations (40 CFR, Part 51, Section
51.24 and Part 52, Sect. 52.21) require the facility to
perform air quality modeling and monitoring for the
specific pollutants to assure that neither the PSD
increments nor the NAAQS are violated. Also, the
facility must demonstrate that based on cost, energy
and technical feasibility, the Best Available Control
Technology (BACT) is used to limit emissions of any
pollutants controlled under the CAA.
(c) since the NSR regulations apply to pollutants on an
individual basis, most facilities will likely have to
follow the permitting procedures for each specific
pollutant (depending upon the area's designation for
the specific pollutant as a non-attainment or attainment
area).
(2) compliance with National Emission Standards for Hazardous
Air Pollutants (NESHAP) and New Source Performance Standards
(NSPS)
Federal standards for mercury emissions are given in
NESHAP (40 CFR, Part 61, Subpart A and E). Minimum Federal
requirements for particulate matter discharge, opacity and
monitoring are given in NSPS (40 CFR, Part 60, Subparts A,
E, and 0). Some states incorporate NESHAP and NSPS into
the EPA approved SIP, so the facility should consult with
a state air quality official to determine the extent of
the SIP coverage.
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(3) compliance with additional SIP provisions, not required by
Federal law
The facility should consult with appropriate state officials
to determine what further requirements of the SIP must be
met, that are not required by Federal law
(B) ash disposal regulations
An incinerator facility that disposes of its ash in a landfill
must comply with the Criteria for Classification of Solid Waste
Disposal Facilities and Practices (40 CFR 257; 44 FR 53438) for
floodplains, endangered species, surface water, ground water,
air., disease and safety. Refer to the section of this document
on landfills for a more detailed discussion of the requirements
of the Criteria for disposal into a landfill.
(C) Federal Construction Grants regulations (40 CFR, Part 35,
Subpart E)
(1) sewage sludge incinerator construction or modification may
be eligible for a maximum 75% Federal construction grant
funds (generally 75% funding of eligible capital costs).
The modification must meet applicable regulations and
result in a water quality benefit.
(2) a "self-sustaining" facility may be eligible for additional
Federal grant support as an innovative/alternative technology.
A "self-sustaining" facility produces an equal or greater
amount of energy than it consumes, which includes energy
used for dewatering, afterburning, etc.
(3) sludge related parts of coincineration facilities with
heat recovery equipment may also be eligible for additional
Federal grant support as an alternative technology at the
85% level. The amount of funding for the sludge related
part is determined using the Alternative Justifiable
Expenditure Method (AJE) found in PRM 77-4.
(4) energy efficient facilities for thermally drying sewage
sludge that will be used as a fertilizer may also qualify as
an alternative technology
(D) PCB recommendations
EPA recommends that if a sludge contains greater than 25 ppm
PCB, then the incinerator facility should increase the temperature
and residence time to ensure that at least 95% of the PCB is
destroyed (5). However, if the sludge contains greater than 50
ppm, then the incineration facility must comply with the PCB
regulations (40 CFR, Part 761).
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IV. Problems Associated with Sludge Incineration and Solutions
one of the biggest problems facing municipalities that operate
sludge incinerators is the high cost of energy that is needed
both for the actual incineration process (including the evaporation
of excess moisture) and for air pollution control (e.g. it
requires about 50 gallons of number 2 fuel oil to burn I ton
dry solids or 4-5 tons dewatered sludge) (21). The use of
afterburners for air pollution control may require an additional
70-IS5 gallons of number 2 fuel oil per I ton dry solids
incinerated (22). Approximately 15-20% of sludge incinerators
constructed since 1970 are no longer in operation (8) primarily
due to high operating costs for energy. Furthermore_, conventional
sludge incineration and ash disposal waste a valuable fertilizer
and soil conditioning resource.
The 1978 EPA Needs Survey (17) estimates that there are approxi-
mately 350 municipal sewage sludge incinerators. In a recent
survey conducted for EPA (19) 3 150 sludge incinerators were
studied. Of this number^ IS were shut down either because they
were unable to meet "the air quality standards, but more often
because of the high cost of energy; and 26 were in violation of
their SIP.
the high cost of energy for operating municipal sludge incinerators
may be reduced by a number of measures including the following:
(1) installation and use of heat recovery equipment, e.g., hot
exhaust gases can be used directly for drying sludge,
conditioning sludge, for pre-heating intake air or to heat
water to produce steam for electricity production
\%
manner
(2) install dewatering equipment that can produce a 30-35'
solids sludge that will burn autogenously. In this manner ,
supplemental fuel requirements would be drastically reduced (20)
(3) use alternative fuel sources (e.g., coincineration with
refuse or refuse derived fuel, coal, methane, etc.).
Approximately 75% of the contents of municipal refuse is
combustible with an energy potential of 9 million Bill's/ton
(15). Coincineration facilities that are presently operating
in this country are located in Ansonia, CT; Harrisburg, PA;
and Duluti, MM.
(4) operate the facility with frequent and properly engineered
combustion analysis, making appropriate adjustments for
air flow, fuel injection, temperature, etc.
16
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(5) new interest in energy recovery and energy efficient
designs in incineration (thermal conversion) systems may
help overcome the current energy consumption and cost
problems facing many conventionally designed incinerators
(6) dry and market the sludge, rather than incinerating and
disposing of the ash
(7) a number of municipalities have abandoned their incinerators
to save on fuel costs. For example, by converting from
incineration to lime stabilization for land application,
East Fitchburg, MA saved $95,000 in 1978 in fuel costs and
gained about $25,000 worth of nutrients (20). But, land
application is not advised when the sludge contains a
relatively high concentration of contaminants.
(B) existing municipal sludge incinerators, that utilize low pressure
scrubbers for particulate removal, have been found to emit up
to 30% of the cadmium that is incinerated into the atmosphere.
High pressure scrubbers may not be much more efficient in
cadmium removal (II). Thus far, there are no Federal standards
directed specifically at controlling cadmium emissions from
incinerators.
Further research is needed to determine the amount of cadmium
and other metals that are emitted from new sludge incinerators
that have efficient particulate removal devices. Research
should also determine whether the amount of metals, released
into the environment from sludge incinerators, is sufficient to
result in a potential impact on human health and the environment.
Therefore, future research may show a need for increased removal
of metals like cadmium and, hence, a Federal standard to limit
such emissions.
V. References
(1) Dunlap R.W. and M.R. Deland, 1978. Latest clean air requirements
Hydrocarbon Processing, pp 91-97. October, 1978 (clarifies
the NSR regulations).
(2) Federal Register, 1978. Air Quality Control Regions, Criteria,
and Control Techniques - Attainment Status Designations.
43 FR 8962-9059, March 3.
(3) Federal Register, 1979. Criteria for the Classification of
Solid Waste Disposal Facilities and Practices. 44 FR 53438 -
53468, September 13.
(4) Federal Register, 1979. Emission Offset Interpretative Ruling.
44 FR 3274-3285, January 16.
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(5) Federal Register, 1977. Municipal Sludge Management: Environmental
Factor; Technical Bulletin, pp. 57427, November 2.
(6) Federal Register, 1978. National Primary and Secondary Ambient
Air Quality Standards for Lead. 43 FR 46246, October 5.
(7) Federal Register, 1978. Prevention of Significant Air Quality
Deterioration. 43 FR 26380-26410, June 19.
(8) Gordian Associates, Inc., 1978. Assessment of the Use of Refuse-
Derived Fuels in Municipal Wastewater Sludge Incinerators.
Prepared for US EPA by Office of Solid Waste.
(9) Report to Congress. May 16, 1979. Codisposal of Garbage &
Sewage Sludge - A promising solution to two problems. CED-79-59.
(10) Sweitzer, T. A., 1980. Understanding the ambient air monitoring
regulations. Pollution Engineering. February.
(11) US EPA, 1979. A Review of Standards of Performance for New
Stationary Sources - Sewage Sludge Incinerators. EPA 450/2-27-010.
(12) US EPA, 1980 Codisposal of Municipal Solid Waste and Sewage
Sludge - An Analysis of Constraints. Office of Solid Waste.
SW-184c.
(13) US EPA, 1979. Comprehensive Sludge Study Relevant to Section
8002(g) of the RCRA of 1976. Office of Water and Waste Management,
SW-802.
(14) US EPA, 1980. First Draft: Current Production and Utilization of
Wastewater and Sludge. Office of Water Program Operations.
Washington, DC.
(15) US EPA, 1978. Innovative and Alternative Technology Assessment
Manual. EPA-430/9-78-009, MCD-53.
(16) US EPA, 1977. Letter from J. Rhett, Dep. Asst. Adm. for OWPO, to
Hon. John D. Dingall, US House of Rep. Subj: Energy Inventory
of Sewage Sludge Incinerators.
(17) US EPA, 1979. 1978 Needs Survey Conveyance and Treatment of
Municipal Wastewater. Summaries of Technical Data. Office of
Water Programs Operations. EPA-430/9-79-002, FRD-2.
(18) US EPA, 1976. Refuse-Fired Energy Systems in Europe: An Evaluation
of Design Practices. Office of Solid Waste. SW-771.
(19) US EPA, 1980. Retrieval Edit Report, Compliance Data System:
Incinerators Compliance Status. Office of Enforcement, Washington,
DC, March 13.
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(20) Walker, J.M., 1979. Overview: Costs, Benefits, and Problems of
Utilization of Sludges. In Proc. of 8th National Conference on
Municipal Sludge Management. Miami, Florida, March 1. Information
Transfer, Inc., Silver Spring, MD.
(21) Walker, J.M., 1979. Using Municipal Sewage Sludge on Land Makes
Sense. Compost Science 19:28, 29, 43.
(22) Wells, J. F. and F. J. Drehuring, 1977. Sludge Incineration
Takes on New Image or What to Do Before You Get Burned Trying to
Incinerate Waste Activated Sludges. 15th Conf. WPCF, Phila, PA.
19
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COMPOSTING
I. Background (10)
(A) process involves sludge stabilization by aerobic microbial
decomposition
(B) compost is useful as a soil conditioner and low grade fertilizer,
but typically contains lower concentrations of nitrogen than
uncomposted sludge. The usefulness of compost, as with other
forms of sludge, may be limited if there is a relatively high
concentration of heavy metals and/or toxic organics
(C) the most common composting methods are the aerated pile method
for raw or digested sludge and the windrow method for digested
sludge (using raw sludge in the windrow method can create
excessive odors)
(D) in-vessel systems for composting sewage sludge have been utilized
successfully "in Europe. These facilities have generally processed
less than 10 dry tons of sludge per day. These in-vessel systems
are beginning to be tested for operation in the United States.
(E) composted sludge is generally more publicly acceptable (marketable)
for land application than liquid or vacuum dewatered sludges for
several reasons:
(1) reduced odor potential
(2) easy to store
(3) decreased levels of persistent organics and pathogens
(F) sludge composting facilities presently operating include those
located in Washington, DC; Camden, NJ; Bangor, ME; Durham, NH;
Windsor, Ontario, Canada; Los Angeles County, CA; Upper Occoquan,
VA; Philadelphia, PA; and Beltsville, MD.
11. Applicable Laws, Regulations & Guidelines
(A) laws
(1) CWA
(2) RCRA
(3) TSCA
(4) NEPA
(5) SDWA
(B) regulations
(1) Criteria for the Classification of Solid Waste Disposal
Facilities and Practices (40 CFR, Part 257; FR September 13,
1979)
20
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(2) Federal Construction Grants Regulations (40 CFR, Part 35,
Subpart E)
(3) Distribution and Marketing Regulations (Preproposal Draft,
May 69 1980)
(4) Hazardous Waste Regulations (40 CFR, Part 260-265; FR, May 19,
1980)
(c) guidelines (10)
(1) Process Design Manual for Sludge Treatment and Disposal (EPA-
625/1--79-011)
(2) Technical Bulletin: Composting Processes to Stabilize and
Disinfect Municipal Sewage Sludge. Preliminary Draft. Office
of Water Program Operations. July, 1980.
III. Requirements for Implementing a New Sludge Composting Facility
(A) compost process
(1) data from presently operating windrow and aerated pile
composting facilities have shown that approximately 1 acre of
land is needed for each 4 dry tons of sludge composted each day
(10). Additional land is needed for storage and curing.
(2) meet the requirements of the Criteria. The pathogen reduction
provisions can be met by satisfying the composting time and
temperature requirements given in Appendix II, Sections A and
B of the Criteria.
(B) disposition of compost
(1) currently, composted sludge is applied to land, sold, given-
away or hauled away for a fee
(2) for a discussion of the disposition methods appropriate for
composted sludge refer to the selections on landspreading,
distribution and marketing, and landfills
(C) Federal Construction Grants
(1) composting of sewage sludge is considered an alternative
technology by the EPA and may be eligible for up to an 85%
Federal construction grant funds to pay for land, equipment,
and construction costs
21
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IV. Problems Associated With Sludge Composting Operations and Solutions
to Problems
(A) tine composting of large amounts of sewage sludge is a relatively
new technology. The simplist systems (static aerated pile and
windrow) are becoming well established in the United States. In
order to make their operations less labor intensive and more
mechanically reliable, several municipalities have been modifying
their static aerated pile and windrow operations with more capital
intensive equipment. Also, other municipalities are considering
the adoption of various in-vessel composting systems. The modifi-
cations in the static aerated pile and windrow systems have not
always resulted in a more efficient operation, and the proposed
in-vessel systems have had limited testing and operational
experience for composting sewage sludge in the United States.
refinements in static aerated pile and windrow methods and adoption
of the in-vessel system should be piloted before being operated
on a full scale, in order to establish the system's efficiency
and reliability
(B) excessive rainfall usually creates a potential for poor aeration,
odor, and leachate runoff
odor production and leachate runoff have been successfully managed
by using overhead roofs for initial mixing sites, scrubber piles
for trapping malodorous gases from forced air systems and/or turning
during processing, use of a paved base that is cleaned regularly,
temporary storage or landfill backup for handling excessive amounts
of sludge that cannot be composted during periods of wet weather,
and sejparate treatment or recycling of leachate back to the POTW
(C) low cost bulking agents may not always be available and a change
in bulking agents may create problems in initial mixing and
subsequent recovery of bulking agents from the finished compost
provide a flexible system design, so that machinery and equipment
can easily accept and process alternative bulking agents, including
previously composted sludge
(D) a suitable give-away or sale market should be developed
development of a suitable market takes considerable expertise and
time, especially where large quantities of composted sludge are
involved (1). A continual supply of compost is required, since a
sudden cutoff can cause a permanent shift to the use of a substitute
product. Proper instructions for safe use must accompany the
compost to the user.
22
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A variety of options for the disposition of the compost product
should be available, since the compost may not be usable if an
occasional batch is improperly composted or adversely contaminated.
Such alternative options for disposition may include temporary
storage facilities, landfills, and use on certain government
owned lands.
(E) there is a concern for the possibility of an adverse health
impact on compost workers and nearby residents from the inhalation of
an excessive number of spores of the fungus, AspergiIlus fumigatus
the amount of dust released should be limited. Compost workers
could be required to wear dust masks and be tested periodically
for sensitivity to Aspergillus fumigatus. The use of recycled
compost as a bulking agent may reduce the level of A. fumigatus.
(F) ease of handling_, low cost and low nitrogen content may prompt
'the user to exceed recommended application rates. This could
result in higher soil additions of contaminants.
clear labeling should accompany the product for its proper use.
In addition, the compost distributor may want to charge an
amount comparable with other competitive commercial products.
Hence, users; would tend not to exceed the recommended application
rate.
References
(1) Kellogg, H. C. 1973. Marketing Sewage Sludge. Compost
Science. V4 (4):16-18.
(2) Olver, W. M. Jr. 1979. Static Pile Composting of Municipal
Sewage Sludge: The Process as Conducted at Bangor, ME. US
EPA Draft Report, Office of Solid Waste, Washington, D.C.
October.
(3) USDA, 1979. A Guide to Recent Literature on Aspergillus
Fumigatus. Science and Education Administration. ARM-NE-5.
(4) USDA, 1979. Use of Sewage Sludge Compost for Soil Improvement
and Plant Growth. Science and Education Administration.
ARM-NE-6.
(5) USDA, US EPA, 1980. Manual for Composting Sewage Sludge by
the Beltsville Aerated-Pile Method. EPA-600/8-80-022.
(6) US EPA., 1978. A Study of Forced Aeration Composting of
Wastewater Sludges. Office of Research and Development.
EPA-600/2-78-057.
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(7) US EPA 1979. Comprehensive Sludge Study Relevant to Section
8002(g) of the Resource Conservation and Recovery Act of 1976.
Office of Solid Waste. SW-802.
(8) US EPA, 1977. Municipal Sludge Management: Environmental
Factors,. Technical Bulletin. Office of Water Program
Operations. MCD-28. EPA 430/9-77-004.
(9) US EPA, 1977. User Acceptance of Wastewater Sludge Compost.
Environmental Protection Technology Series. Office of Research
and Development. EPA-600/2-77-096.
(10) Walker, J. M., M. S. Winsten and J. E. Hall, 1979. A
Critical Review of the Performance of Sewage Sludge Composting
Operations. Presented at the National Conference on Municipal
and Industrial Sludge Composting, Sponsor: Information
Transfer, Inc., New Carrollton, MD, November.
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SURFACE IMPOUNDMENTS (LAGOONS AND STORAGE BASINS)
I. Background
(A) in 1978, 11% of the sewage sludge produced was disposed of in
lagoons (2)
(B) surface impoundments can be used as a back-up or temporary storage
method for other disposition options, a sludge stabilization
method prior to land application, or as a dedicated (permanent) or
long-term disposal site for liquid, dewatered, heat-dried or
composted sludge
(C) in humid areas, sludge has been stored in lagoons for long periods
of time, although there may be some problem of water build-up during
wet seasons. In areas where there is net positive evaporation,
such as the southwestern U.S., a liquid stabilized sludge can be
permanently disposed of in a surface impoundment by utilizing
solar energy and by limiting the sludge loading rate. However, a
permanent surface impoundment can waste a usable resource.
(D) surface impoundments tend to increase the sludge solids concentra-
tion, stabilization, and pathogen destruction, with the use of
minimal energy, but tie up the land involved
II. Laws, Regulations, and Guidelines
(A) laws
(1) CWA
(2) RCRA
(3) SDWA
(4) TSCA
(5) NEPA
(B) regulations
(1) Criteria for the Classification of Solid Waste Disposal Faci-
lities and Practices (40 CFR, Part 257; FR, September 13, 1979)
(2) PCB Regulations (40 CFR, part 761)
(3) Federal Construction Grants Regulations (40 CFR, Part 35, Subpart E)
(4) NPDES Regulations (40 CFR, Part 125)
(5) state regulations
(6) Hazardous Waste Regulations (40 CFR, Parts 260-265; FR,
May 19, 1980)
25
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(C) guidelines
(1) Classifying Solid Waste Disposal Facilities, A Guidance Manual
(SW-828)
(2) A Manual for Evaluating Contamination Potential of Surface
Impoundments (EPA 570/9-78-003)
(3) Sludge Process Design Manual (EPA 625/1-79-011)
III. Procedure for Implementing a Surface Impoundment Practice
(A) meet local arid state requirements for surface impoundments. The
state requirements are to be based upon the minimum standards
contained in the Criteria for the Classification of Solid Waste
Disposal Facilities and Practices. State regulations can, however,
be more restrictive than the Criteria.
(B) meet the EPA Criteria for Classification of Solid Waste Disposal
Facilities and Practices for safety, surface water, ground water,
endangered species, disease (vectors), floodplains, and air
(1) facilities must immediately be in compliance with the Criteria,
If the facility is not in compliance, the facility must either
cease operations or apply to the state solid waste management
authority for a compliance schedule. The state may grant any
facility built prior to January 1986 up to five years (not to
extend beyond January, 1986) to meet the Criteria. The com-
pliance schedule will involve steps to either upgrade or close
the facility. EPA recommends that the factors used by the
state to determine if a compliance schedule should be granted
or how the compliance schedule should be formulated should be
based on the following: availability of disposal at other
facilities, cost constraints, existing contractual agreements,
likelihood of incremental environmental damage and other
pertinent factors.
(2) the Criteria is enforceable through the solid waste management
programs; of each state and/or through the Federal courts under
RCRA provisions. If a state does not enforce the Criteria
directly through its solid waste management program, the state
or a private citizen could seek enforcement of the Criteria in
Federal court through the "citizen suit" provision of RCRA.
The Criteria is enforceable by EPA under Section 405(e) of the
CWA.
(3) the practice must use fences or other methods to control
public access to the facility
(4) the facility must obtain an NPDES permit if there is a point
source discharge into surface waters. Point source discharges
can be avoided by proper site selection, design, operation
and maintenance practices, such as leachate management and
protecting the site from floodwaters. Facilities must also
comply with areawide plan for non-point source pollution of
surface water, authorized by Section 208 of the CWA.
26
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(5) facilities must avoid the contamination of underground
drinking water sources beyond the waste boundary as described
below. "Contaminate" and "underground drinking water source"
are terms specifically defined in the Criteria. Appendix I
of the Criteria lists contaminant levels of concern, based
on the SDWA. The Criteria provides a mechanism by which
States can establish alternative boundaries to be used in
lieu of the waste boundary. Compliance may be achieved by
proper site selection, design, operation, and maintenance
practices. Natural or artificial liners beneath the surface
impoundment may be needed for leachate management. The use
of ground water wells is advisable to monitor the effective-
ness of compliance controls and analytical methods for
monitoring should be consulted (40 CFR Part 141).
(6) if the facility is located in the critical habitat of an
endangered or threatened species then the facility must not
contribute to the taking of the species, or result in an
adverse modification of the species critical habitat. A
list of endangered or threatened species and their critical
habitats is contained in 50 CFR, Part 17.
(7) the facility must minimize the onsite population of disease
vectors (e.g. mosquitos). This can be accomplished by
several methods. For lagoons, mechanical surface mixers can
be used for agitation to eliminate stagnant water. If
necessary, insecticides can be used, but biological controls
are preferred (e.g., predatory and reproductive controls).
(8) in general, surface impoundments can be located in floodplain
areas if the facility does not (a) cause the restriction of
base flood waters (base flood has a 1% or greater chance of
recurring in any year or a flood of a magnitude equalled or
exceeded once in 100 years on the average), (b) reduce the
temporary water storage capacity of the floodplain or (c)
result in the washout of the stored sludge (SW-828). Berms
or dikes can be used to meet these requirements. The con-
struction of berms or dikes requires a Section 404 (CWA)
dredge and fill permit if the facility is also located in a
wetland.
(C) apply for Federal construction grant funding (40 CFR, Part 35,
Subpart E). Seventy-five percent Federal funding is available
for eligible costs, i.e., for the planning, design, construction
and land that is needed for a surface impoundment, if the
practice is the most cost-effective and environmentally acceptable
alternative and if necessary state and Federal requirements are
met.
27
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IV. Problems Associated with Surface Impoundments and Solutions to Problems
(A) suitable sites ai>e difficult to obtain due to the following reasons:
(1) public opposition to nearby surface impoundment
discussion on public acceptance and siting is given in the
introduction section of this document
(2) some sites are not adequate for preventing migration of
contaminants to ground water
these site limitations can be mitigated by appropriate design.
For example, the lack of a clay layer can be compensated for
by installation of plastic liners
(B) a major problem with surface impoundments is their potential for
odor production. Odors occur when an inadequately stabilized
sludge is stored^ where the impoundment is overloaded^ and/or
where the impoundment is improperly designed.
odor potential can be minimized by surface impounding well stabi-
lized sludge (e.g. Chicago, Illinois, uses an anaerobic lagoon
with an approximate loading rate of 36 to 50 pounds of volatile
solids/1000 ft2/day from liquid sludge that has been well stabi-
lized by anaerobic digestion) (3). Chicago reports that they
digest their sludge in high-rate heated anaerobic digestors at
98°F for an average retention of 14-15 days and that they presently
experience no odor problems. Dewatered sludge can also be stock-
piled. However, adequate anaerobic digestion is necessary to
minimize problems with odor. Nonetheless, there may be some odor
problems when removing stockpiled dewatered sludge or when removing
lagooned sludge.
well stabilized liquid sludge can also be surface impounded with
minimal odor production in facultative (aerobic and anaerobic)
lagoons (e.g., Sacramento, California, presently operates 40 acres
of facultative sludge lagoons with no odor problems). To
maintain the aerobic portion of the lagoon, two procedures are
practiced at Sacramento: 1) the loading of volatile solids is
limited to 20 lbs/1000 ft2/day (double in the summer), and 2)
mechanical surface mixers are utilized. The costs for mitigating
odors, however, were appreciable at Sacramento.
V. References
(1) US EPA, 1978. A Manual for Evaluating Contamination Potential of
Surface Impoundments, EPA 570/9-78-003.
(2) US EPA, 1980. First Draft. Current Production and Utilization
of Wastewater and Sludge. Office of Water Program Operations,
Washington, D.C.
(3) US EPA, 1978. Process Design Manual: Sludge Treatment and Disposal,
EPA 625/1-79-011.
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ULTIMATE UTILIZATION AND DISPOSAL METHODS
LANDFILLS
I. Background
(A) in 1978, approximately 33% of the sewage sludge produced was
landfilled [5)
(B) landfill ing is a suitable disposal method for sludges that are
currently high in heavy metals or toxic organics and of limited
value for use in land application. Industrial pretreatment may
improve the quality of these sludges in the future. Hence, sludge
recycling opportunities may increase. Landfill ing is also suitable
as a backup disposal option to other sludge management alternatives,
(C) landfill ing can be a cost-effective method of disposal^ but suitable
sites are becoming difficult to obtain
(D) generally, sludges should be dewatered to at least a 15% solid
content for disposal in a sludge-only landfill (6). Sludges with
a solid content less than 15% may be codisposed with municipal
refuse, if the sludge makes up only a small portion of the total
amount of waste being landfilled. An acceptable ratio of refuse
to sludge depends on many factors (e.g., sludge solids content,
type of refuse, site characteristics and climate). Refuse to total
liquid ratios from 5:1 to as low as 2:1 have been reported (1).
(E) before the issuance of the Criteria for Classification of Solid
Waste Disposal Facilities and Practices, the disposal of sludge
into landfills was regulated by EPA Guidelines for Land Disposal
of Solid Wastes (40 CFR, Part 241). Landfill ing is now regulated
by the Criteria.
11. Laws, Regulations and Guidelines
(A) laws
(1) CWA
(2) RCRA
(3) SDWA
(4) TSCA
(5) NEPA
(B) regulations
(1) Criteria for the Classification of Solid Waste Disposal
Facilities and Practices (40 CFR, Part 257; FR, September 13,
1979)
(2) PCB Regulations (40 CFR, Part 761)
29
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(3) Federal Construction Grants Regulations (40 CFR, Part 35,
Subpart E)
(4) NPDES Regulations (40 CFR, Part 125)
(5) state regulations
(6) Hazardous Waste Regulations (40 CFR, Parts 260-265; FR,
May 19, 1980)
(C) guidelines
(1) Classifying Solid Waste Disposal Facilities, A
Guidance Manual (SW-828)
(2) Sludge Technical Bulletin (EPA-430/9-77-004)
(3) Sludge Treatment and Disposal (EPA-625/4-78-012)
(4) Process Design Manual: Municipal Sludge Landfills
(EPA-625/1-78-010; SW-705)
(5) Sludge Process Design Manual (EPA-625/1-79-011)
III. Procedure for Implementing a Landfill ing Practice
(A) meet local and state requirements for landfills. The state require-
ments are to be based upon the minimum standards contained in the
Criteria for the Classification of Solid Waste Disposal Facilities
and Practices. State regulations can, however, be more restrictive
than the Criteria. For example, some states require that the sludge
be dewatered prior to landfill ing to avoid leachate production and
possible contamination of ground water or surface water.
(B) meet EPA Criteria for the Classification of Solid Waste Disposal
Facilities and Practices for floodplains, surface water, ground
water, disease (vectors), safety, air and endangered species
(1) facilities must immediately be in compliance with the Criteria.
If the facility is not in compliance, the facility must either
cease operations or apply to the state solid waste management
authority for a compliance schedule. The state may grant any
facility built prior to January 1986 up to five years (not to
extend beyond January, 1986) to meet the Criteria. The com-
pliance schedule will involve steps to either upgrade or close
the facility. EPA recommends that the factors used by the
state to determine if a compliance schedule should be granted
or how the compliance schedule should be formulated should be
based on the following: availability of disposal at other
facilities, cost constraints, existing contractual agreements,
likelihood of incremental environmental damage and other
pertinent factors.
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(2) the Criteria is enforceable through the solid waste management
programs of each state and/or through Federal courts under
RCRA provisions. If a state does not enforce the Criteria
directly through its solid waste management program, the
state or a private citizen could seek enforcement of the
Criteria in Federal court through the "citizen suit" provision
of RCRA. The Criteria is enforceable by EPA under Section
405(e) of the CWA.
(3) in general, landfills can be located in floodplain areas if
the facility does not (a) cause the restriction of base flood
waters (base flood has a 1% or greater chance of recurring in
any year or a flood of a magnitude equalled or exceeded once
in 100 years on the average), (b) reduce the temporary water
storage capacity of the floodplain or (c) result in the
washout of landfilled sewage sludge (SW-828). Berms or dikes
can be used to meet these requirements. The construction of
berms or dikes requires a Section 404 (CWA) dredge and fill
permit if the facility is also located in a wetland.
(4) the facility must obtain an NPDES permit if there is a point
source discharge into surface waters. Point source discharges
can be avoided by proper site selection, design, operation
and maintenance practices, such as leachate management and
protecting the site from floodwaters. Facilities must also
comply with areawide plan for non-point source pollution of
surface water, authorized by Section 208 of the CWA.
(5) facilities must avoid the contamination of underground
drinking water sources beyond the waste boundary as described
below. "Contaminate" and "underground drinking water source"
are terms specifically defined in the Criteria. Appendix I
of the Criteria lists contaminant levels of concern, based on
the SDWA. The Criteria provides a mechanism by which States
can establish alternative boundaries to be used in lieu of
the waste boundary. Compliance may be achieved by proper
site selection, design, operation, and maintenance practices.
Natural or artificial liners beneath the landfill may be used
for leachate management. The use of groundwater wells is
advisable to monitor the effectiveness of compliance controls
and analytical methods for monitoring should be consulted (40
CFR Part 141).
(6) the facility must minimize the onsite population of disease
vectors by periodic application of cover material or other
appropriate techniques (e.g., increased sludge stabilization;
leachate management; if necessary, chemical control agents).
(7) access restrictions (e.g., fencing) are required. There also
are provisions regarding bird hazards to airports and hazards
from explosive methane gases.
31
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(8) if the facility is located in the critical habitat of an
endangered or threatened species then the facility must not
contribute to the taking of the species, or result in an
adverse modification of the species critical habitat. A
list of endangered or threatened species and their critical
habitats is contained in 50 CFR, Part 17.
(C) Federal construction grant funding of 75% (40 CFR Part 35, subpart
E) is available for eligible costs, such as the planning, design,
and construction of landfills for sludge disposal if landfill ing
is the most cost-effective and environmentally acceptable alterna-
tive and if other necessary state and Federal requirements are
met. Co-disposal and methane recovery are considered alternative
technologies and may be eligible for up to an 85% Federal grant.
If the landfill accepts both sludge and other solid waste, then
multipurpose funding considerations apply. The amount of funding
for the sludge related part is determined by using the Alternative
Justifiable Expenditure Method (AJE) found in PRM 77-4. Land for
landfill ing may also be grant eligible (PRM 75-39).
Funding to support the development and implementation of the State
Solid Waste Management Plan is available under RCRA (FR, July 31,
1979, pp. 45066). These funds go to the state and are not available
to the municipality for funding the construction of landfill
facilities.
IV. Problems Associated with Sludge Landfills and Solutions to Problems
(A) suitable sites are diffiou.lt to obtain due to the following reasons:
(1) public opposition to nearby landfill
discussion on public acceptance and siting is given in the
introduction section of this document
(2) some sites are not adequate for preventing migration of
contaminants to groundwater
these site limitations can be mitigated by appropriate
design. For example, lack of a clay layer can be compensated
for by installation of plastic liners. Also, co-disposal
can be used to reduce leachate problems that are associated
with sludge-only landfills.
(B) waste of a useable resource
to be potentially eligible for 85% Federal construction grant
funding as an alternative technology, the facility should investigate
the possibility for methane recovery from the landfill. The
facility should also investigate other disposition methods that
are also considered alternative technologies (e.g., landspreading,
composting, distribution, and heat recovery from coincineration).
32
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(C) odor
adequate stabilization of sludge and prompt application of cover
material are necessary to minimize odors
VI. References
(1) Huitric, R., S. Raksit and R. Haug, 1979. In Place Capacity of
Refuse to Absorb Liquid Waste. Presented at 2nd Nat. Conf. on
Hazardous Materials Management. Feb. 27 - March 2. San Diego,
CA.
(2) US EPA, 1980. Classifying Solid Waste Disposal Facilities, A
Guidance Manual. SW-828.
(3) US EPA, 1980. Co-disposal of Municipal Solid Waste and Sewage
Sludge, An Analysis of Constraints. SW-184.
(4) US EPA, 1980. Design and Construction of Covers for Solid Waste
Landfills. EPA-600/2-79-165.
(5) US EPA, 1980, First Draft. Current Production and Utilization of
Wastewater and Sludge. Office of Water Program Operations.
Washington, D.C.
(6) US EPA, 1978. Process Design Manual: Municipal Sludge Landfills.
EPA-625/1-78-010. SW-705.
(7) US EPA, 1978. Sewage Sludge Entrenchment System for Use by Small
Municipalities. EPA 600/2-78-018.
(8) US EPA, 1975. Trench Incorporation of Sewage Sludge in Marginal
Agricultural Land. EPA 600/2-75-034.
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OCEAN DUMPING AND DISCHARGE
I. Background
(A) in 1978, approximately 10 percent of the sewage sludge produced
was disposed of in the ocean (3)
(B) ocean dumping provisions of the MPRSA are sufficiently stringent
that they effectively phase out ocean dumping of sewage sludge by
December 31, 1981
(C) ocean dumping is regulated by interim permits under authority of
Section 102(a) of the MPRSA
(D) ocean discharge through outfalls is regulated by conditional NPDES
permits, or an EPA approved state compliance plan, authorized by
Section 301(h), 402 and 403 of the CWA
(E) presently there are no sewage sludges that comply with the ocean
dumping and ocean discharge criteria and standards. Hence, all
sludges currently being disposed of in the ocean are authorized
by interim and conditional permits. These permits provide for
implementation of other alternatives to ocean disposal of sludge,
according to compliance schedules.
(F) since 1973, 118 ocean dumping practices have been phased out.
Presently, there are 26 ocean dumpers, with 23 on compliance
schedules. There are currently only two municipalities discharging
sewage sludge (through outfalls) into the ocean.
II. Applicable Laws, Regulations and Guidelines
(A) laws
(1) CWA
(2) MPRSA
(3) RCRA
(4) TSCA
(5) NEPA
(B) regulations
(1) NPDES (40 CFR, Part 125)
(2) Ocean Dumping Permits (40 CFR, Parts 220-230)
(3) PCB Regulations (40 CFR, Part 761)
(4) Ocean Discharge Criteria (45 FR 9548)
(5) Secondary Treatment Information (40 CFR, Part 133)
(6) Hazardous Waste Regulations (40 CFR, Parts 260-265; FR,
May 9, 1980)
34
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(C) guidelines
(1) Guidelines Establishing Test Procedures for Analysis of
Pollutants (40 CFR, Part 136)
(2) Bioassay Procedure for Ocean Disposal Permit Program
(EPA-600/9-78-010)
HI. How to Get an Ocean Dumping Interim Permit Reissued
(A) apply for reissuance of an interim permit with the Regional
Administrator. Sewage sludges currently being generated are not
meeting the criteria for obtaining an ocean dumping permit, so
interim ocean dumping permits are only reissued to facilities
that are already ocean dumping on a compliance schedule. An
interim permit may be reissued if the Regional Administrator
determines that the applicant has made his best effort to satisfy
all the requirements of the interim permit previously issued.
(B) interim permits are issued for no more than one year
(C) when specific provisions are absent, any permit revisions or
revocations are at the discretion of the Regional Administrator.
However, the Regional Administrator is authorized to request that
the information provided on previous applications be updated or
revised when needed.
(D) 40 CFR, Part 224 requires that records be kept on the physical and
chemical characteristics of the material dumped, pursuant to the
permit; the precise times and locations of dumping; and any other
information required by the Regional Administrator.
The physical and chemical characteristics of the sludge, which
must be analyzed in order to keep acceptable records, are usually
the concentrations of mercury, cadmium, organohalogens, oils and
greases, liquid constituents immiscible with or slightly soluble
in seawater (eg. benzene, zylene, toluene), radioactive materials
and pathogens. Other sludge characteristics that must be deter-
mined are the pH, BOD and calculation of the limiting permissible
concentration (LPC) of the sludge, size of the release zone and
degree of initial mixing (1). Calculation procedures (40 CFR, Part
227, Subpart G) require that a bioassay be performed on an appro-
priate marine organism. Bioassay procedures that are approved by
EPA are found in "Bioassay Procedure for Ocean Disposal Permit
Program" (EPA-600/9-78-010).
(E) the decision of the Regional Administrator to reissue, revise or
deny an interim permit is based, in part, on the applicant's
effort to meet the compliance schedule of the previous permit
IV. How to Get a Conditional NPDES Ocean Discharge Permit Reissued
(A) apply for the reissuance of a conditional NPDES Ocean Discharge
Permit with the Regional Administrator. Sewage sludges currently
being generated are not meeting the Criteria and Standards for the
35
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NPDES Ocean Discharge permit, so conditional NPDES permits are only
reissued to the facilities that are already ocean discharging on
a compliance schedule. Generally, conditional NPDES permits are
issued for no more than 9 months. The Regional Administrator's
decision to reissue, revise, or deny a conditional NPDES Ocean
Discharge Permit is based on the applicant's ^effort to meet the
compliance schedule of the previous permit. The Regional Admini-
strator has the authority to request that additional information
be provided from the applicant for permit revisions.
(B) proposed Ocean Discharge Criteria (40 CFR, Part 125, Subpart M),
which will apply to sludge disposal through outfalls, were
published in the Federal Register, February 12, 1980, p. 9548.
The toxic control program (Section 125.126) of the proposed
criteria requires the submittal of a quantitative chemical analysis
for the toxic pollutants potentially found in the discharge. The
discharge must be analyzed for a list of 65 toxic pollutants
found in 40 CFR, Part 403, Appendix B. Analysis methods are
provided in "Guidelines Establishing Test Procedures for Analysis
of Pollutants" (40 CFR, Part 136).
V. Problems Associated With Ocean Disposal of Sludge
and Solutions to the Problems
since those sewage sludges that are currently being disposed of in the
ocean are exceeding the regulatory criteria established to protect the
marine environment., no new permits are being issued at this time for
ocean disposal of sewage sludge and enforcement compliance schedules
are being issued to phase out existing ocean disposal practices
investigate and implement other sludge disposition methods
VI. References
(1) Teeter, A.M. and D.J. Baumgartner. 1978. Predictions of
Initial iMixing for Municipal Ocean Discharges. Environmental
Research Laboratory Publication 043. Corvallis, Oregon.
(2) US EPA, 1979. Annual Report to Congress. January-December
1978. On Administration of MPRSA of 1972, as Amended
(PL 92-532) and Implementing the International Ocean Dumping
Convention. Office of Water Programs. June 1979.
(3) US EPA, 1980. First Draft. Current Production and Utilization
of Wastewater and Sludge. Office of Water Program Operations.
Washington, D.C.
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LANDSPREADING
I. Background
(A) in 1978, approximately 24% of the sludge produced was applied to
land (7)
(B) municipal sewage sludge is a useful material for conditioning soils
and providing plant nutrients, but its usefulness becomes limited
when concentrations of pollutants are high
(C) the utilization of municipal sludge for plant production or land
reclamation helps fulfill the goal of Congress and EPA for waste
recycling
11. Applicable Laws, Regulations, and Guidelines
(A) laws
(1) CWA
(2) RCRA
(3) TSCA
(4) SDWA
(5) NEPA
(B) regulations
(1) Criteria for the Classification and Solid Waste Disposal Faci-
lities and Practices (40 CFR, Part 257; FR, September 13, 1979)
(2) Federal Construction Grants Regulation (40 CFR, Part 35,
Subpart E)
(3) state regulations
(4) PCB Regulations (40 CFR, Part 761)
(5) NPDES Regulations (40 CFR, Part 125)
(6) Hazardous Waste Regulations (40 CFR, Parts 260-265; FR,
May 19, 1980)
(C) guidelines
(1) Classifying Solid Waste Disposal Facilities, A Guidance Manual
(SW-828)
(2) Sludge Technical Bulletin (EPA 430/9-77-004; MCD-28)
(3) Application of Sludges and Wastewaters on Agricultural Land:
A Planning and Educational Guide (MCD-35)
(4) Sludge Treatment and Disposal (EPA-625/4-78-012)
(5) Sludge Process Design Manual (EPA-625/1-79-011)
37
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III. Procedure for Implementing Sludge Landspreading Practices
(A) meet local, state, and Federal requirements for landspreading.
The state requirements are to be based upon the minimum standards
contained in the Criteria for the Classification of Solid Waste
Disposal Facilities and Practices. State regulations can, however,
be more restrictive than the Criteria
(B) an existing or planned facility for landspreading sewage sludge
must comply with the Criteria
(1) facilities must immediately be in compliance with the Criteria.
If the facility is not in compliance, the facility must either
cease operations or apply to the state solid waste management
authority for a compliance schedule. The state may grant any
facility built prior to January 1986, up to five years (not
to extend beyond January, 1986) to meet the Criteria. The
compliance schedule will involve steps to either upgrade or
close the facility. EPA recommends that the factors used by
the state to determine if a compliance schedule should be
granted or how the compliance schedule should be formulated
should be based on the following: availability of disposal at
other facilities, cost constraints, existing contractual
agreement, likelihood of incremental environmental damage and
other pertinent factors.
(2) the Criteria is enforceable through the solid waste management
programs of each state and/or through Federal courts under
RCRA provisions. If a state does not enforce the Criteria
directly through its solid waste management program, the state
or a private citizen could seek enforcement of the Criteria
in Federal court through the "citizen suit" provision of RCRA.
The Criteria is enforceable by EPA under Section 405(e) of
the CWA.
(3) a landspreading facility must meet the provisions in the
Criteria for surface water, ground water, disease, endangered
species, safety, floodplains, air, and food-chain crops.
Provisions in the Criteria relating especially to sludge
landspreading (i.e., sections 257.3-5, 257.3-6(b) and
Appendix II of the Criteria) are interim final. Interim
final status is the same as final status for regulations with
respect to enforceability (i.e., the interim final provisions
in the Criteria apply now as written). The difference,
however is that comments are received and considered for
possible change. Finalization with possible change is
expected by early 1981.
(a) a landspreading facility, where the waste has been
incorporated into the soil for the enhancement of
vegetative growth, is not normally considered as having
a point source discharge (EPA Criteria Guidance, SW-828).
This is true even though there may be a discharge to waters
of the United States from an outfall or clearly delineated
channel that drains the landspreading area. "Incorporate
into the soil" means the injection or mixing of the sludge
into the soil.
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A landspreading facility must also comply with the state
or local areawide plan for non-point source pollution of
surface waters (authorized by Section 208 of the CWA).
Non-point source pollution from landspreading can be
minimized by good soil conservation management practices,
including use of a grassed border (e.g., 15 feet in width)
downs lope from an application site. Research in Minnesota
has shown that polluted surface water runoff can be mini-
mized when liquid sludge (about 1/2 inch) has been applied
at about one half to one day before the next rainfall.
(b) all waste disposal facilities, including landspreading
operations, must generally avoid the contamination of
underground drinking water sources beyond the waste
boundary (257.3-4). A sludge landspreading practice will
not; normally contaminate underground drinking water where
the sludge has been applied to the soil for the enhance-
ment of vegetative growth, especially where the sludge
application rate provides nitrogen in amounts equivalent
to the needs of the vegetation. The potential for ground
water contamination from landspreading increases as sludge
application rate and level of contaminants increase, where
the soil is more porous, and where there is appreciable
rainfall. The Sludge Technical Bulletin (STB) guidance
for determining the nitrogen needs of the crop and subse-
quent rates of sludge application to avoid nitrogen con-
tamination of ground water should be followed.
(c) interim final provisions in the Criteria in the disease
section, regarding pathogen reduction, must be met by all
practices that apply sewage sludge to the soil surface or
incorporate it into the soil. Sludge must be treated by a
Process to Significantly Reduce Pathogens (PSRP) before
the application or incorporation. Public access to the
facility must be controlled for at least 12 months, and
grazing by animals whose products are consumed by humans
must be prevented for at least 1 month. PSRP are defined
in Appendix II of the Criteria.
Sludge must be treated by a Process to Further Reduce
Pathogens (PFRP) prior to application to land (i) where
crcps for direct human consumption are planted within 18
months after application and (ii) if the sludge will be in
contact with the edible portion of the crop. PFRP are
defined in Appendix II of the Criteria. Contact between
the edible portion of the crop and the sludge is considered
to be by either direct application of the sludge to the
growing crop or by rainfall splash after the sludge
application. The points of concern in determining the
potential for contact are the timing and method of appli-
cation and the type of crop grown. Taller growing crops
such as many grains and citrus fruits can be considered as
not having contact with the sludge as long as it is applied
in a manner or at a time that direct contact with the crop
does not occur.
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(d) if a landspreading facility is properly designed and
operated, then access by the public to the landspreading
site should not result in potential health and safety
hazards. If there is some aspect of the operation that
could expose the public to potential health and safety
hazards (e.g., spray application of liquid sludge and
surface application in playgrounds), then the practice
may need fences or other methods (e.g., hedges, ditches,
remoteness, and/or controls within the facility) to
control public access to the site. If the sludge has
undergone PFRP prior to landspreading, then the
facility would not need access controls.
(e) sewage sludges can be applied to soils in floodplains
provided the facility does not (i) cause the restriction
of base flood waters (base flood has a 1% or greater
chance of recurring in any year or a flood of a magnitude
equalled or exceeded once in 100 years on the average),
(ii) reduce the temporary water storage capacity of the
floodplain or (iii) result in the washout of the sludge.
EPA expects that if sludge is applied to the surface and
incorporated into the soil and if vegetation is grown,
the Criteria should be satisfied.
(f) the interim-final provisions for food chain landspreading
provide limits on the amount of cadmium and PCB that can
be added to the soil. Food chain crops are defined as
crops grown for human consumption, tobacco and feed for
animals whose products are consumed by humans. When the
project involves high application rates of sludges with
a relatively high concentration of contaminants, it may
be necessary for the Regional Administrator to consult
with USDA and FDA as part of the review process.
(i) Cadmium: Two options are provided for controlling
cadmium additions to food chain land. Option I
specifies phased in controls on annual application
rates and maximum cumulative cadmium loadings, with
the soil pH being controlled. Annual limits for
cadmium additions to soils on which vegetables,
rootcrops, and tobacco are grown are initially more
restrictive than for other food chain crops.
Option II allows unlimited application providing
(1) crops grown are used only for animal feed, (2)
soil pH is controlled, (3) facility operating plan
prevents human ingestion of crops, and (4) future
owners of the land are provided notice in the land
deed that the soil has received high cadmium
additions and that food chain crops should not be
grown.
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(ii) Polychlorinated biphenyls (PCB): PCB limits in the
sludge have been based upon causing levels in soils
and crops to be low enough to meet FDA's tolerance
levels for animal feeds and milk fat. Currently,
therefore, the Criteria allow for the surface
application of sludges containing up to 10 mg/kg
PCB, dry weight basis. Where PCB levels in the
sludge are above 10 mg/kg, direct contact with
crops could cause the FDA tolerances to be violated.
In this case the Criteria requires that the waste
be incorporated into the soil rather than spread on
the soil/crop surface. If analysis of the sludge
shows PCB to be greater than 50 ppm, see 40 CFR
Part 761 for the appropriate disposal procedures.
(C) funding
(1) Federal construction grant funding (85 percent of eligible
costs, 40 CFR Part 35, subpart E) is available for the design,
and construction of landspreading facilities for sludge utili-
zation if it is the most cost-effective and environmentally
acceptable alternative and if the various necessary state and
Federal requirements are met. The purchase or lease of land
for landspreading is also potentially grant eligible (PRM 75-39)
(2) funding to support the development and implementation of the
State Solid Waste Management Plan is available under RCRA
(FR, July 31, 1979, p. 45066). These funds go to the state
and are not available to the municipality for funding the
construction of landspreading facilities.
(D) monitoring and recordkeeping
Federal regulations are currently being drafted by the Office of
Water and Waste Management. In these draft regulations, EPA is
considering requiring that records be kept for landspreading
practices. Until the regulations are finalized (expected sometime
in 1981), the following voluntary monitoring and recordkeeping
recommendations are provided to assure that the landspreading
practice does not result in an adverse environmental effect.
(1) as mentioned in the STB, the monitoring plan should be
specifically designed for local conditions, including site
and sludge characteristics, proposed rate of application,
crops to be grown, size of the project, etc. In addition to
the contaminants of concern that are presently addressed in
the Criteria, the monitoring plan should also address other
heavy metals, persistent organics, and pathogens, as well as
nitrates in ground water, surface water, sludge and soils.
If the facility is aware of a high contaminant input into the
treatment plant by a local industrial source, or if the
treatment process adds contaminants to the sludge (e.g.,
chlorination of sludge for stabilization), then these con-
taminants should also be addressed in the monitoring plan.
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(2) the STB guidance that heavy metal additions be most restricted
and the least amount of sludge be applied to privately owned
agricultural land should still be followed. Since the levels
of sludge and metals added to privately owned agricultural land
would be low, the level of monitoring suggested is minimized.
On the other hand, sludge contaminant limits are higher on
dedicated disposal sites. Likewise, the degree of necessary
control, via monitoring, permits, etc., increases. In other
words, where the potential for pollution is greater, the level
of control and monitoring should also be greater.
(3) municipalities are generally responsible for the analysis of
their sludges. They should maintain records on the sludge pH;
lime level; N, P, K, Mg, and organic matter contents; con-
centrations of Zn, Pb, Cu, Ni, Cd, and PCB; and method and
extent of stabilization.
(4) soils that receive sludges should also be analyzed. Important
parameters include pH, cation exchange capacity, and cadmium
concentration. There also should be a knowledge of the crops
that will be grown. A number of states (e.g., MD, OH, WI, and
OR) have arranged for testing of the soils by the State or
County Agricultural Extension Service. These groups also
recommend rates of sludge application and years of effective
site life based upon the soil, crop, and sludge character-
istics. Records should also be maintained by each municipality
on site locations, the annual and total amounts of sludge each
site has received, the crops grown, and the soil pH.
(E) in the Criteria, the Agency has indicated its preference for the
application of sewage sludge to non-food chain land rather than to
agricultural lands. However, the Agency believes that food chain
land application practices which comply with the Criteria will pose
no reasonable probability of adverse effects on public health or the
environment.
IV. Problems Associated with Sludge Landspreading Practices and Solutions
to Problems
(A) many sludge land application systems have been publicly opposed -in
the past; even though facilities that have undergone proper environ-
mental assessments are operating with no apparent demonstrated odor,
health or safety problems
the public should be made aware that the landspreading of sewage
sludge can be a cost effective and beneficial method for waste
recycling (e.g., plant production, land reclamation). The public
should also be made aware that all methods of sludge disposal have
risks and that few adverse environmental effects result from
landspreading when regulations and good management practices are
followed. A general discussion on gaining public acceptance is
contained in the introduction section of this document.
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(B) Federal regulations for non-food chain landspreading have not been
developed for the control of cadmium and PCB additions to the
soil. However, after receiving sludge applications, non-food
chain-land may be converted to food chain land. Hence, it is
argued that the regulations should be the same for both types of
landspreading.
the issue of conversion of non-food chain land to food chain land
will be considered more fully in the rulemaking process at a later
time. Meanwhile where it is rather certain that non-food chain
land will not be converted to food chain uses, more liberal amounts
of contaminants such as cadmium and PCB's might be permitted.
(C) operators of landspreading facilities and food processors who
utilize crops grown on sludge ammended soils have expressed
concern that they may be held liable for possible adverse environ-
mental and health effects that may result from landspreading
sewage sludge
the issue of liability for any possible adverse consequences of
landspreading municipal sewage sludge has been raised in the
various states where sewage sludge is spread on privately owned
land. Ultimately such questions of liability are matters for the
courts to resolve and are primarily matters of State law. Under
most circumstances, compliance with Federal or state and regulations
guidelines concerning landspreading may provide a strong defense
for POTW's against charges that they are responsible for the
adverse consequences associated with the landspreading of their
sludge. Likewise, written disclaimers of responsibility for the
effects of the sludge may also protect a POTW from liability.
Nevertheless, it should be made clear that neither compliance with
Federal or state regulations, nor written disclaimers, can guarantee
that those participating in a sludge landspreading program would
not be held liable for adverse consequences. While EPA does not
necessarily endorse their approach, the following are examples of
state programs that could be relevant to questions of liability:
(1) Maryland (1): -Guidelines are provided for the application of
sewage sludge to land by the University of Maryland. These
guidelines give guidance for submitting soil samples to the
University's Agronomy Department for determining the sludge
application rate. The State Department of Health issues
permits for sludge landspreading projects. While the
University indicates that sewage sludge can provide valuable
plant njtrients in its sludge application recommendation, the
University disavows responsibility for possible unforeseen
long-term effects of sewage sludge on the environment.
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(2) Ohio (4): Ohio provides guidelines for land application of
sewage sludge. These include the need for information on the
composition of sludge to be applied, the properties of the
soil, and the nature of the crop to be grown. The Ohio
Extension Service provides a soil testing service, makes
recommendations for amounts of sludge to be added and provides
for reporting to the Ohio Environmental Protection Agency
(OEPA). The guidance states that an approved plan for sludge
application does not remove a landowners responsibility for
water pollution or health hazards that may result from the
application of sludge on their land. Plan approval means
that in the judgement of OEPA, the proposed system should
function satisfactorily. If unforeseen problems arise, OEPA
gives the landowner a reasonable period of time to rectify
the problem. The guidance suggests that a written contract
be negotiated between the landowner and the sewage sludge
applicator and suggests items for inclusion in the contract.
The treatment plant is responsible for keeping accurate
records of the sludge quality.
(3) Oregon (2): The Oregon guidelines provide guidance for safe
beneficial use of sludge. Oregon regulates land application
practices by issuing permits to municipal authorities in
charge of operating POTW's. These authorities must keep
records of the sludge quality and application sites and
rates. The authorities are responsible for conducting their
landspreading in accord with the Oregon guidance and the
facility permit.
(4) Michigan (3): The Michigan guidelines were prepared by the
Michigan Department of Natural Resources. The guidelines
emphasize beneficial use in a safe manner. They utilize
state-issued NPDES permits to regulate sludge disposal. The
wastewater treatment plant has the responsibility for effec-
tive sludge management.
(D) availability of sites may be limited by the weather, cropping
patterns and the allowable annual or cummulative application rates
since landspreading is seasonal and an adequate number of
landspreading sites may not always be available, the facility
should have adequate storage and/or a back-up disposal method.
(E) some landspreading practices can lead to odor production
odor from landspreading sludge can be minimized by proper sludge
stabilization before application and prompt incorporation of
sludge into the soil.
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V. References
(1) Guidelines for the Application of Sewage Sludge to Land, 1976.
University of Maryland Agronomy Mimeo No. 10, June.
(2) Land Application of Treated Sewage Sludge: Guidelines for Communities
and Farm Operators, 1978. Extension Special Report 499, Oregon State
University, February.
(3) Municipal Wastewater Sludge Management/Application to Land, 1979.
Staff Report to Michigan Environmental Review Board, February.
(4) Ohio Guide for Land Application of Sewage Sludge. 1979 Research
Bulletin 1079 (Revised) CARDC and Bulletin 598 (revised) CES, Ohio
State University, June.
(5) US EPA, 1976. Application of Sewage Sludge to Cropland, Appraisal of
Potential Hazards of the Heavy Metals to Plants and Animals. MCD-33.
(6) US EPA, 1977. Cost of Landspreading and Hauling Sludge From Municipal
Wastewater Treatment Plants, Case Studies. EPA/530/SW-619.
(7) US EPA, 1980. First Draft. Current Production and Utilization of
Wastewater and Sludge. Office of Water Program Operations. Washington,
DC.
(8) Walker, J. M., 1978. Municipal Sludge on Land Utilization/Disposal
Guidance, Regulations and Guidelines, p. 6-11. In 5th National Conf.
on Acceptable Sludge Disposal Techniques, Orlando, FL. Information
Transfer, Inc., Rockville, MD.
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DISTRIBUTION AND MARKETING (GIVEAWAY/SALE)
I. Background
(A) regulations concerning distribution and marketing of sludge and
sludge products are currently being drafted by the EPA Office of
Water and Waste Management. A preproposal version was released to
the public for comment on May 6, 1980. Publication of the proposed
regulations in the Federal Register is planned by the end of 1980.
(B) at present there are no Federal regulations that pertain speci-
fically to the distribution and marketing of sludge and sludge
products. However, the Criteria and the Sludge Technical Bulletin
(STB) have some applicability with respect to cadmium, PCB's,
pathogens, monitoring, recordkeeping, and surface and ground water
protection.
(C) distribution and marketing of sewage sludge to the public means
that the POTW does not have a comprehensive management role in the
landspreading or specialty use that follows the transfer or sale
of the POTW sludge. Such landspreading or specialty use generally
includes the domestic use of sludge, as well as use on urban and
community parks, recreation areas, roadsides, nurseries, golf
courses, and the like. In general, controls on the site and the
use of sludge products, as well as comprehensive site recordkeeping
requirements, cannot be practically implemented by an individual
POTW for sites which are very small or numerous. Therefore, the
sludge quality and type of use must be regulated.
(D) many municipalities presently are involved in giving away sludge
and sludge products free to the public: e.g., Philadelphia's
Philorganic and the giveaway of air-dried sludges by many small
communities
(E) sludge products currently sold commercially include Milwaukee's
"Milorganite" (heat dried), Kellogg's "Nitrohumus" (composted),
and Houston's "Houactinite" (heat dried). Chicago, Illinois and
Largo, Florida are also involved in distributing heat-dried sludge
products.
11. Applicable Laws, Regulations, and Guidelines
(A) laws
(1) CWA
(2) RCRA
(3) TSCA
(4) NEPA
(5) Consumer Product Safety Act (CPSA)
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(B) regulations
(1) a preproposal draft has been released by the Office of Water
and Waste Management for comment. This proposal draft
should not be considered as Agency policy, nor should it be
used to regulate the distribution and marketing of sludge,
since it has not been through the formal Agency review and
clearance process. It is likely that significant changes
will be made to the draft prior to publication of proposed
regulations in the Federal Register.
(2) at the present time the Criteria provides some guidance (see
landspreading section).
(3) Hazardous Waste Regulations (40 CFR, Part 260-265; FR,
May 19, 1980)
(C) guidelines
(1) at the present time the STB provides some guidance (see
landspreading section)
III. Potential Requirements of the Distribution and Marketing Regulations
The following are ideas which are being considered for incorporation
into draft regulations on distribution and marketing (give-away and
sale) of sludge products. Since these regulations are in the early
developmental stage, each idea may undergo substantial change as a
result of the comments received and of all other data obtained during
the rulemaking process.
(A) the manufacturer of the sludge product will likely be regulated.
The manufacturer is defined as the firm or POTW that produces,
packages and labels the finished sludge product for use.
(B) regulations will likely deal with sludge fertilizer products and
sludge soil conditioners separately, based in part on nitrogen,
moisture contents, and possibly end use
(C) the sludge constituent of the fertilizer product or soil conditioner
may require treatment by a Process to Further Reduce Pathogens as
described in Appendix II, Part B of the Criteria
(D) sludge fertilizer products may be less stringently regulated than
sludge soil conditioners, but have a nitrogen/contaminant limit
and may require labels specifying instructions for use
(E) the controls on sludge soil conditioners may recognize the concept
of a "good sludge"
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(1) minimal requirements to define a good or clean sludge (Note,
the concept of a good or clean sludge may also be applied to
soil fertilizer products.) for unrestricted use might include
specific limiting concentrations for certain contaminants
such as cadmium, PCB's and lead; a requirement for a minimal
content of lime as an internal protection against heavy
metal availability; adequate stabilization to eliminate
pathogens and malodor; and controlling the cadmium to zinc
ratio in the sludge as another internal protective mechanism
to preclude problems with cadmium in the diet.
(F) sludge soil conditioners not meeting the "good sludge" requirements
may be classified into two separate categories based on the end
use of the product
(1) products for restricted-general use may require the sludge
producer to include labels or invoices that give the user
application rates and instructions for use. The label may
also contain warnings which restrict certain usage based on
the specific contaminant content.
(2) products for governmental use may be utilized under govern-
mental or POTW supervision on publicly-owned land, and the
product would have maximum concentration limits for specific
contaminants
(G) sludge producers may be required to analyze their sludges and
keep records on levels of cadmium, lead, PCB, nitrogen, phosphorus,
potassium, lime, boron and certain other metals contained in the
sludge (e.g., zinc, copper, and nickel). Also, records may be
required on the method used to reduce pathogens (e.g., temperature,
residence time, etc.).
IV. Problems Associated with the Distribution and Marketing of Sludge and
Sludge Products and Solutions to Problems
uncertainty about how to proceed with the distribution and marketing
of sludge products until regulations have been promulgated
some useful guidance for the use of sludge products has been developed
by the US Department of Agriculture (2)
VI. Reference
(1) Black, C.A. (ed.), 1965. Methods of Soil Analysis, Agronomy
Monograph No. 9. Amer. Soc. of Agronomy. Madison, Wisconsin.
(2) Hornick, S.B., J.J. Murray, R.L. Chaney, L.J. Sikora, J.F. Parr,
W.D. Burge, G.B. Willson, and C.F. Tester, 1979. Use of Sewage
Sludge Compost for Soil Improvement and Plant Growth. US Department
of Agriculture, SEA, Agricultural Review and Manuals ARM-NE-6,
August.
(3) US EPA, 1980. Pre-Proposal Draft Regulation. Distribution and
Marketing of Sewage Sludge Products. Office of Solid Waste. May 6.
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