-------
household, $187.64, while plants using ponds or lagoons had the lowest charges, $124.70 per
household.
The NSSS solicited information regarding methods of raising capital. Table 3-26
presents the resulting national estimates based on responses. As shown, a large majority of
POTWs rely on bonds and user fees for financing construction projects.
3.9 EXISTING REGULATIONS REGARDING THE USE OR DISPOSAL OF SEWAGE
SLUDGE AND DOMESTIC SEPTAGE
A number of current federal regulations govern the use or disposal of sewage sludge
under several legislative mandates. Table 3-27 summarizes the existing federal regulations
pertaining to the various sewage sludge use or disposal practices. This section provides a brief
overview of existing federal regulations.
3.9.1 Incineration
'.• The incineration of nqnhazardous sewage sludge is regulated under the Clean Air Act
(CAA), the Toxic Substances Control Act (TSCA), and Subtitle C of Resource Conservation
and Recovery Act (RCRA).
Two types of regulations under the CAA affect the incineration of nonhazardous sewage
sludge: (1) ambient air quality standards and (2) point-source numerical emissions limits. The
National Ambient Air Quality Standards (NAAQS) govern the overall ambient air quality in the
United States. States must develop and enforce State Implementation Plans (SIPs) designed to
meet and maintain NAAQS. NAAQS have been promulgated for six pollutants: ozone,
particulates, sulfur oxides, nitrogen dioxides, carbon monoxide, and lead. The areas that do not
meet NAAQS are designated as "nonattainment areas." Areas that meet the standards are '"in
attainment." In nonattainment areas, states must have measures in their SIPs to bring ambient
air quality into compliance with the NAAQS.
3-63
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TABLE 3-26
NATIONAL ESTIMATES OF METHODS USED TO RAISE CAPITAL
FOR POTWS WITH AT LEAST SECONDARY TREATMENT
Method
Bond Issue
Increase User Rates
Loan
Other Response
Estimated Frequency Used
6,111
5,934
3,577
1,905
Percent of Total Estimated
POTWs
56.1
54.5
32.8
17.5
Note: Frequencies do not add to the total estimated number of POTWs because some POTWs
did not respond and other POTWs responded in more than one category.
Source: 1988 National Sewage Sludge Survey, EPA.
3-64
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TABLE 3-27
A SUMMARY OF EXISTING SEWAGE SLUDGE
USE OR DISPOSAL REGULATIONS
Use or Disposal Practice
Landfill
Land Application
Incineration
Existing Federal Regulations
40 CFR 761
40 CFR 261-268
40 CFR 258
40 QFR 257
40 CFR 761
40 CFR 61
40 CFR 60
40 CFR 50
Source: Compiled by ERG.
3-65
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The ambient standards may influence whether incineration is a viable option for sewage
sludge use or disposal. A POTW in a nonattainment area cannot use incineration unless a
reduction in emissions from existing sources will at least equal'the expected incremental
emissions from the new source. In attainment areas, an incinerator could be added only if the
additional emissions would not affect attainment status.
In addition to the NAAQS program, sewage sludge incinerators are covered by two
federal programs that establish numeric limits on incinerator emissions: the National Emissions
Standards for Hazardous Air Pollutants (NESHAPs) and New Source Performance Standards
(NSPS). The NESHAPs give EPA the authority to promulgate point-source emission standards
for specific pollutants. To date, EPA has promulgated standards pertaining to sewage sludge
incinerators for mercury and beryllium (40 CFR 61). For sewage sludge incinerators, mercury
emissions are limited to less than 3,200 grams and beryllium to less than 10 grams per 24-hour
period. NESHAPs also stipulate stack and sewage sludge sampling and monitoring practices.
The NSPS regulations apply to incinerators constructed or significantly altered since
June 11, 1973, and to those that burn more than 10 percent sewage sludge (on a dry basis) or
more than 1,000 kg of sewage sludge per day. These standards restrict particulatcs in and
opacity of emissions (40 CFR 60).
Subtitle C of RCRA designates incinerators burning hazardous sewage sludge as
Treatment Storage Disposal Facilities (TSDFs) and requires these facilities to obtain a special
permit. Also, under RCRA, federal agencies operating incinerators that process 50 tons or
more per day of "municipal-type solid wastes" arc subject to the thermal processing guidelines
set forth in 40 CFR 240. These guidelines specify minimum levels of operating performance.
Recommended operating procedures and designs are included in the code as well. The residue
of thermal processing (ash) must be disposed of in an environmentally acceptable manner.
These thermal processing guidelines are recommendations to state and local government
agencies as well.
TSCA regulates incineration of sewage sludge that has 60 parts per million or more of
PCBs (40 CFR 761). If sewage sludge PCB concentrations exceed this level, TSCA requires
3-66
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that EPA approve the incinerator before operation. The operator must also abide by technical
and procedural requirements specified in the law, such as monitoring and recordkeeping.
3.9.2 Use or Disposal of Sewage Sludge and Domestic Septage on Land
Existing federal regulations pertaining to land disposal of sewage sludge have been
promulgated under Subtitles C and D of RCRA. Subtitle C requirements apply if the sewage
sludge is considered a hazardous waste. If it is not considered hazardous, use or disposal of the
sewage sludge through landfilling, land application, and lagooning is currently regulated under
Subtitle D of RCRA.
Subtitle C Requirements
Subtitle C of RCRA governs the generation, storage, transport, and disposal of
hazardous waste. Sewage sludge is subject to toxicity testing to determine whether it should be
designated as hazardous waste. (40 CFR 261 Appendix II defines the pollutant limits for
determining whether a waste is hazardous.) The owner or operator of the POTW is responsible
for determining whether the sewage sludge or incinerator ash is hazardous. If sewage sludge is
hazardous, the POTW must participate in the permit program for treatment and storage of
hazardous waste and dispose of the sewage sludge at a permitted Subtitle C facility.
Subtitle D Requirements
Under current requirements, sewage sludge that does not fall under the hazardous waste
classification and is used or disposed on land must meet requirements set forth in Subtitle D of
RCRA. Land application and surface disposal sites are all subject to the rules in 40 CFR 257.
These rules specify management practices that protect floodplains, surface water, and ground
water.
3-67
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Regulations in 40 CFR 257 also protect human health by restricting the level of
pathogens in sewage sludge used or disposed on land. Any sewage sludge applied to or
incorporated into the soil, except in trenching or burial operations, must be treated by a Process
to Significantly Reduce Pathogens (PSRP) before it is applied to soil. In addition, public access
to land application sites must be restricted for a minimum of 12 months, and animals intended
for human consumption may not graze this land for a minimum of 1 month.
Septic tank pumpings applied to land as a soil amendment must be treated in a PSRP
prior to application unless public access to the site is controlled for at least 12 months and
unless grazing by animals whose products are consumed by humans is prevented for at least one
month.
Further, if crops intended for human consumption are to be grown in soil amended with
sewage sludge or domestic septage within 18 months of the amending process, the sewage sludge
or domestic septage must be treated by a Process to Further Reduce Pathogens (PFRP) before
application.
Section 257 of RCRA imposes numeric limits on the allowed application rates for
cadmium and PCBs on soil that will support food-chain and nonfood-chain crops. Food-chain
crops are defined as crops grown for human consumption (including tobacco) and feed for
animals whose products are intended for human consumption. The specific requirements are as
follows:
Cadmium. Applications to sites growing crops are limited to 0.5 kilograms per
hectare per year (kg/ha/yr); Cumulative cadmium applications are limited
depending on the pH and cation exchange capacity of the soil. In general, soil
pH must be at least 6.5 or greater at the time of planting, and EPA recommends
that pH be permanently maintained at or above 6.2. In the case of crops grown
exclusively for animal fodder, cadmium is not specifically limited; however, pH
must be maintained at or above 6.5. A facility growing animal feed on sewage
sludge-amended soil must have an operating plan that outlines measures to
ensure against human ingestion of the feed and safeguards public health from the
hazards of cadmium entering the food chain.
PCBs. Sewage sludges containing between 10 and 50 mg/kg of PCBs must be
incorporated into the soil when applied to land if the land is to be used to
3-68
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produce animal feed, including pasture crops for animals raised for dairy
products. Sewage sludge does not have to be incorporated into soil if PCB
concentrations are less than 0.2 mg/kg (actual weight) in the resulting animal
feed or less than 1.5 mg/kg (fat based) in the resulting milk.
When PCB levels in sewage sludge exceed 50 mg/kg, sewage sludge falls under the strict
requirements of 40 CFR 761 (TSCA). Under these requirements, such sewage sludge can only
be incinerated or disposed in a chemical waste landfill.
Criteria for Subtitle D solid waste disposal facilities were promulgated in 1991 (40 CFR
258). These pollutant limits apply to landfills, including those that accept sewage sludge along
with other solid waste (codisposal). Part 258 has location restrictions, operating and design
criteria, ground-water protection provisions, closure and post-closure care requirements, and
financial assurance criteria that apply to solid waste disposal facilities.
A summary of state regulations pertaining to land application of sewage sludge was
prepared to assist in the impacts assessment of required management practices under the final
regulation. The degree to which existing state regulations comply with management practices
required by the final regulation is presented in Table 3-28. All the states with land application
regulations currently require pollutant testing of sewage sludge to be land applied. The majority
of states have existing provisions similar to the management practice requirements in the Part
503. Existing compliance with management practices is discussed in Section Four.
3-69
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3-73
-------
NOTES TO TABLE 3-28
If "257" appears in the table, this indicates that the state regulation references 40 CFK 257 for that provision.
a Five states (III, MT, NV, ND, and UT) do not appear in the table for various reasons. Hawaii has
no written rules or guidelines because very little sludge is land applied, and the sludge which is land
applied is controlled through their permit system. All restrictions are on a case-by-case basis, though
the state does enforce Part 257 when issuing permits. Montana has no regulations or guidelines.
Control over land appliers is maintained through their permit system which requires compliance with
Part 257, monitoring, and agronomic rates of application. In Nevada, almost all of the sewage sludge-
is landfilled. One facility practices land application, and this facility must meet permit requirements
that were set up on a case-specific basis. Nevada has no official guidance document or regulations
regarding the land application of sewage sludge. North Dakota has no regulations covering land
application. 'Hie state claims that 98 percent of wastewater sludge is disposed in wastewater
stabilixation ponds, making sludge land application regulations a minor concern. After Part 503 is
finali/ed, the stale may pursue regulation. Utah had not established regulations as of January 1992,
though some are being written and will be updated after Part 503 is finali/ed. Some regulation'
occurs through discharge permits. Utah's regulations reference 40 CFR 257 in the Utah
Administrative C'ode.
b Nebraska has a voluntary permitting program. Facilities practicing land application are not required
to submit information to the permitting organization, though all but the smallest facilities participate.
Application within the 10-year floodplain is restricted.
Application shall not restrict the flow of the base flood, reduce temporary water storage capacity of
the floodplain, or result in washout of solid waste, so as to pose a ha/ard to human life, wildlife, or
land or water resources.
Application within the 100-year floodplain is restricted.
Runoff controls must be installed to prevent drainage from maximum rainfall in i\ 24-hour period
during the last 25 years.
Application not permitted in wetlands, floodplain, or flood-prone areas.
Run-off from a 10-year 1-hour storm must not contain sewage sludge.
Sludge must be incorporated within 48 hours if in floodplain.
Facilities in floodplain must be filled to bring the site above flood elevations.
Sludge shall not be in the runoff from a 100-year 24-hour storm event.
Application not permitted within two months of seasonal annual floods.
Application site in floodplain must have vegetative cover established before rainy season.
Application not permitted in areas with runoff problems.
Sludge shall be protected from upslope runoff from a 10-year 24-hour storm event.
Massachusetts requires a minimum distance of 2,500 feet between a sludge application site and class
'A surface waters, but determines buffer distances for other classes of surface water on a case-by-case
basis.
New Mexico has water quality control standards for ground water that limit the concentrations of
certain metals in ground water. Sewage sludge applied to the land is regulated in this section and
can not cause the limits expressed in the standard to be exceeded.
Oregon does not require PSRP or PFRP but requires written authori/.alion to be obtained before
application of any non-digested sludge. Part 257 is not mentioned with regard to pathogen control.
Sludge must have aged for three years after stabilization before application.
l.eafy green vegetables and root crops should not be planted until one growing season after the
sludge is applied, usually 12-18 months.
Lactating domestic animals are not permitted to grax.e for a period of 30 days. 'Iliere is no
restriction for other animals.
Public access permitted once vegetative cover is established.
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3-74
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REFERENCES TO SECTION THREE
Mctcalf & Eddy, Inc. 1978. Wastcwater Engineering Trcatrncnt/Disposal/Reuse. Second
Edition, McGraw Hill Publishers.
U.S. EPA. 1991. Report to Congress on the National Pretreatmcnt Program. Office of
Wastewater Enforcement and Compliance, U.S. EPA, 1991.
U.S. EPA. 1989. National Wastcwater User Fee Study. Draft. Office of Water Standards and
Regulations, U.S. EPA, December 1989.
3-75
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SECTION FOUR
REGULATORY COSTS OF 40 CFR PART 503
This section estimates the costs and economic impacts associated with the final 40 CFR
Part 503 regulation governing the use or disposal of sewage sludge. The regulatory costs of Part
503 are estimated for the three major sewage sludge use or disposal practices (see Section 3.3 for
definitions of these practices):
Land application (including agricultural and nonagricultural end uses, as well as
end uses associated with the sale or giveaway of sewage sludge).
Surface disposal (including monofills, sewage sludge piles, sewage sludge
impoundments, and landspreading surface disposal).
Incineration.
These disposal practices are covered by three subparts of the regulation: Subpart B (La.nd
Application), Subpart C (Surface Disposal), and Subpart E (Incineration), each of which is
summarized and analyzed separately. The requirements in Subpart A (General Provisions) are
discussed separately as well. The requirements in Subpart D, covering pathogens and vector
attraction reduction requirements, however, are discussed as they apply to the relevant disposal
practices rather than in a separate section.
Section 4.1 of this report discusses general aspects of the regulation including information
on the regulated population and derivation of per-hour labor costs for all use or disposal
practices. A discussion of Subpart A requirements is presented in Section 4.2 along with
estimates of costs associated with general requirements and costs not specific to any one subpart.
Sections 4.3 through 4.5 discuss each of the major use or disposal practices. These three sections
present an overview of each relevant subpart and estimate the costs associated with the major
types of regulatory requirements: general requirements; pollutant limits; management practices;
pathogen and vector attraction reduction requirements, where relevant; and frequency of
4-1
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monitoring, recordkeeping, and reporting requirements. Section 4.6 presents the total costs of
the Part 503 regulation. The base year for all these cost analyses is 1992.
4.1 GENERAL ASPECTS OF THE REGULATORY COST ANALYSIS
4.1.1 Overview of the Regulated Population
Section Four of the RIA investigates the impacts on five groups of treatment works that
are affected by the Part 503 regulation: secondary or advanced treatment works, whose numbers
have been estimated from the 1988 National Sewage Sludge Survey (NSSS)(EPA, 1988a);
primary treatment works, whose numbers have been derived from the 1988 Needs Survey (EPA,
1988b); privately owned treatment works, whose numbers have been estimated based on
information from individual states and EPA's Permit Compliance System Database (1991);
federally owned treatment works, whose numbers were also estimated using the Permit
Compliance System Database; and domestic septage haulers, whose numbers have been
estimated based on state information and discussions with the domestic septage hauler trade
association (see Section Five and Appendix D). The populations of affected treatment works
used in this section of the report are identical to those presented in Section Three, with the
exception of primary, secondary, and advanced treatment works. Numbers of secondary and
advanced treatment works are derived differently from the way in which they were estimated in
Section Three because'of constraints imposed by the survey design of the NSSS, as discussed
below. Furthermore for the puipose of the analysis in this section of the RIA, the estimated
total numbers of primary treatment works remain the same, but unknown use or disposal
practices are distributed among land application, surface disposal, incineration, and not regulated
in the same proportions as those for the known use or disposal practices (see Table
4-1).
The numbers of affected secondary or advanced treatment works differ from those
presented in Section Three because a different basis was used to derive the estimates in Section
Three than that used in Section Four. The estimated number of secondary or advanced
treatment works were derived, in Section Three, from answers to the questionnaire portion of the
NSSS. Section Four, however, uses the analytical survey, which collected data on sewage sludge
4-2
-------
TABLE 4-1
DISTRIBUTION OF PRIMARY TREATMENT
POTWS AMONG USE OR DISPOSAL PRACTICES
Major Use or
Disposal Practice
Land Application
Surface Disposal
Incineration
Not Regulated
Total
Reported Flow Rate (MGD)
>100
5
1
0
3
9
>10 to 100
23
7
2
13
45
>1 to 10
107
31
9
63
210
^1
813
234
64
480
1,591
AH
POTWs
948
273
75
559
1,855
Source: ERG estimates based on 1988 Needs Survey and 1988 National Sewage Sludge Survey,
EPA.
4-3
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quality, as the basis for all estimates. As noted in Section Two of the RIA, the treatment works
surveyed in the analytical survey are a subset of the larger group of treatment works surveyed in
the questionnaire. Although it is the smaller survey, we used the analytical survey in Section
Four because estimates of numbers of treatment works failing the pollutant limits could only be
based on data obtained from the analytical survey. The differences arise not only because of the
smaller size of the analytical survey, but also because it is stratified differently from the
questionnaire survey. The questionnaire survey is stratified by reported flow group (size of
treatment works in terms of amount of wastewater processed in MGD) and by use or disposal
practice. The analytical survey, however, is stratified only by reported flow group. Estimates of
numbers of treatment works by reported flow group will therefore be very similar to those
derived using the questionnaire survey, but the estimates of numbers of treatment works by use
or disposal practice will be slightly less accurate estimates than those derived using the
questionnaire survey (i.e., the confidence intervals are larger). Additional information on survey
design and other pertinent information on the development of the NSSS data base can be found
in the Statistical Support Document for the 40 CFR Part 503 Final Rule for Sewage Sludge Use or
Disposal (EPA, 1992).
Table 4-2 presents the total numbers of secondary or advanced treatment works estimated
using the analytical survey by reported flow group and use or disposal practice (see EPA [1992]
for the definition of differences between survey design and reported flow group). The numbers
of treatment works in each use or disposal practice estimated using the analytical survey vary by
less than 10 percent from the estimates presented in Section Three, with two exceptions.
Numbers of treatment works practicing surface disposal are greater than 10 percent higher when
based on the analytical survey than when based on the questionnaire survey, and numbers of
treatment works practicing codisposal or coincineration practices not regulated by Part 503 are
greater than 10 percent lower than estimates derived based on the questionnaire survey. Despite
this limitation, for consistency, EPA was constrained to use these estimates to derive costs. As
Table 4-2 shows, 10,939 secondary or advanced treatment works are estimated to be potentially
affected by the regulation based on the analytical survey. Additionally there are 1,855 primary
treatment works (9 processing greater than 100 MGD, 45 processing 10 to 100 MGD, 210
processing 1 to 10 MGD, and 1,591 processing less than 1 MGD), 4,829 privately owned
4-4
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TABLE 4-2
NATIONAL ESTIMATES OF THE NUMBER OF POTWS WITH AT LEAST
SECONDARY TREATMENT BY FLOW AND MAJOR USE OR DISPOSAL PRACTICE
WEIGHTED USING ANALYTICAL SURVEY WEIGHTS
Major Use or
Disposal Practice
Incineration
Land Application
Not Regulated
Surface Disposal
Unknown3
Total
Reported Flow Rate (MGD)
100
5
7
3
1
0
16
10 to 100
78
121
90
42
141
472
1 to 10
150
1,089
586
586
0
2,411
-------
treatment works, 248 federally owned treatment works, and 17,000 domestic septage haulers, for
a total potentially affected population of 34,871 entities.
Table 4-2 also presents the total number of practices by reported flow group and use or
disposal practice. Because some POTWs employ more than one disposal practice, the number of
practices represents the total number of POTWs employing a particular use or disposal practice
and is greater than the total of 10,939 POTWs. Most impacts must be calculated using the
number of POTWs employing a particular use or disposal practice, not just the total number of
POTWs that employ a particular use or disposal practice for the majority of their sewage sludge.
Therefore, the numbers of practices are used throughout Section Four to represent numbers of
secondary or advanced treatment POTWs affected by each of the regulation's subparts.
One group of POTWs is handled very differently in this section than in Section Three.
Ocean-disposing POTWs, which were tallied in Section Three, have been redistributed among
other use or disposal methods. These POTWs no longer practice ocean disposal of sewage
sludge because of the Ocean Dumping Ban Act of 1988. EPA has selected the 1992 use or
disposal practices of the affected POTWs as the relevant use or disposal practice. Six ocean-
disposing POTWs were included in the analytical survey. Three of these (POTWs 263, 273, and
299) currently practice codisposal and are thus considered not regulated. These POTWs
represent 142 POTWs nationwide1. The other three (POTWs 280, 296, and 300, which
represent themselves only) practice land application. More specifically they transfer sewage
sludge to a composting firm, which is equivalent to the compost broker/contractor end use
designation (see Section Three).
'EPA recognizes that the estimate of the numbers of POTWs ocean disposing sewage sludge
is greatly overestimated using the analytical survey weights. The actual number of ocean
disposing POTWs is 28 plus one additional POTW that transfers to an ocean disposer. This
discrepancy does not, however, have a major impact on the analysis, since the 1992 use or
disposal methods of the ocean-disposing POTWs that were in the analytical survey appear to be
representative of the use or disposal practices of the 28 actual ocean disposers (ERG, 1992).
4-6
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4.1.2 Derivation of Per-Hour Labor Costs
Throughout Section Four, labor costs for three classes of employees have been used for
publicly owned treatment works (POTWs): clerical labor, technical labor, and management
labor. Using Bureau of Labor Statistics (BLS) data on employment and earnings (BLS, 1992),
EPA selected median wages for these job categories and included benefit and overhead costs.
EPA estimated that total wages with all benefits and a share of overhead costs included would
be approximately double the actual wage received by employees. The average wage for clerical
workers in the BLS statistics was $9.13/hr (assuming a 40-hour work week); for engineering
technicians, this wage was $13.08/hr; and for engineering management, we assumed wages
equivalent to those for a civil engineer at $20.22/hr. Based on these wage figures, the fully
loaded total labor cost for an hour of clerical work (with rounding) is estimated to be $20.00/hr.
For an hour of technical work, we estimate $30.00/hr, and for an hour of managerial work,
$40.00/hr. For privately and federally owned treatment works, which are typically much smaller
than POTWs, we used a technician's labor cost of $30.00/hr to represent managerial time as
well. For domestic septage haulers and treatment works, EPA assumes a fully loaded labor cost
for all employees of $20.00 which roughly doubles the BLS wage for truck drivers of $lQ.73/hr.
For the owner/operator of domestic septage hauling firms, we used an estimate of baseline
profit/wage plus overhead per hour ranging from $25.00 to $43.00 per hr., depending on the size
of the firm, as the cost to the owner of his or her time for meeting regulatory requirements.
Appendix D discusses the derivation of this cost in detail as a part of developing a detailed
financial model of domestic septage hauling firms.
4.2 COSTS OF THE GENERAL PROVISIONS
4.2.1 Overview of the General Provisions
The general provisions for Part 503 define the purpose of the regulation, the regulated
entities, and the regulated sewage sludge use or disposal practices; indicate the compliance
period; discuss permitting and enforceability; delineate the relationship with other regulations;
provide for additional or more stringent standards; list exclusions to coverage; state
4-7
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requirements for persons who prepare sewage sludge; present analytical methods that must be
used on sewage sludge samples; and present general definitions. These general provisions are
discussed briefly below.
The general provisions open with a discussion of the purpose and applicability of the
Part 503 regulation, which establishes standards for the use or disposal of sewage sludge.
Sewage sludge is defined to include sewage sludges generated from the treatment of domestic
sewage in a treatment works, which arc further defined as POTWs, federally owned treatment
works, and private treatment works treating domestic sewage. Sewage sludge is also defined to
include domestic scptage. The paragraphs covering purpose and applicability detail the types of
requirements in the regulation and identify the regulated entities, use or disposal practices, and
other items. As described, the regulation applies to all persons (individuals, associations,
partnerships, corporations, municipalities, state or federal agencies, or agents or employees of
any of these groups) engaged in the use or disposal of sewage sludge, including preparers and
appliers, persons who fire sewage sludge in a sewage sludge incinerator, and owner/operators of
surface disposal sites. The regulation is also stated to cover exit gas from a sewage sludge
incinerator stack, land on which sewage sludge is applied, surface disposal sites, and sewage
sludge incinerators.
All regulated entities that use or dispose of sewage sludge under the three regulated
practices of land application, surface disposal, or incineration must comply with the Part 503
regulation within 1 year of its publication, unless new facilities need to be constructed. In this
case, the compliance period is 2 years after publication. THC monitoring, recordkeeping, and
reporting must be initiated within 1 year, unless new facilities must be built to comply with THC
requirements, in which case the compliance period is 2 years. All other requirements for
frequency of monitoring, recordkeeping, and reporting arc effective within 120 days of the
effective date of Part 503.
The permits and cnforccability section indicates that the standards, frequency of
monitoring requirements, recordkeeping requirements, and reporting requirements may be
implemented through permits, in accordance with 40 CFR Parts 122 and 124 or in accordance
with 40 CFR Part 123 or 501, or another applicable permit program. Permits may also be
4-8
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issued under Subtitle C of the Solid Waste Disposal Act; Part C of the Safe Drinking Water
Act; the Marine Protection, Research and Sanctuaries Act; or the Clean Air Act. Permit
applications must be submitted in accordance with 40 CFR Section 122.21 or an approved state
program. The regulation is directly enforceable against any person using or disposing of sewage
sludge through any of the regulated practices.
The general provisions continue with a discussion of the relationship of Part 503 to other
regulations. Disposal of sewage sludge in municipal solid waste landfills that comply with
40 CFR Part 258 is considered to meet the requirements of Section 405(d) of the Clean Water
Act, as amended. The sewage sludge also must meet Part 258 requirements concerning the
quality of materials disposed in a municipal solid waste landfill.
Part 503 also allows (on a case-by-case basis) the permitting authority, the state, other
political subdivision, or interstate agency to impose more stringent requirements for the use or
disposal of sewage sludge to protect public health and the environment.
Part 503 excludes a number of wastes, processes, and entities from coverage. Excluded
are any processes for treating sewage sludge (except those for pathogen and vector attraction
reduction). For example, aerated wastewater treatment lagoons, in which sewage sludge
accumulates, are exempted from coverage. The sewage sludge in these lagoons is covered by
the regulation only when it is removed for final use or disposal or when the unit is otherwise
reclassified as a final disposal site. Part 503 does not cover the selection of a use or disposal
practice, which is left up to local determination. Part 503 does not apply to sewage sludge
cofired with a large portion of other wastes in an incinerator. Also excluded from coverage are:
industrial sewage sludges (even those treated with domestic septage in a private facility);
hazardous sewage sludges; sewage sludges with high PCB concentrations; incinerator ash, grit,
and screenings; drinking water treatment sewage sludges; and commercial and industrial septage.
Part 503 further requires all persons who prepare sewage sludge to ensure the applicable
requirements in Part 503 are met when sewage sludge is used or disposed through any one of
the regulated practices.
4-9
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Part 503, Subpart A, requires that representative samples of sewage sludge that is land-
applied, surface-disposed, or fired in a sewage sludge incinerator be taken and analyzed.
Subpart A also defines the analytical methods that must be used to analyze sewage sludge
samples for the presence of enteric viruses; fecal coliform; helminth ova; inorganic pollutants;
Salmonella sp. bacteria; specific oxygen uptake rate; total, fixed, and volatile solids; and percent
volatile solids reduction. The remainder of Subpart A is devoted to general definitions, many of
which have already been summarized in this section.
4.2.2 Costs Associated with the General Provisions and Other General Costs
This section discusses costs specific to the general provisions as well as to the overall
regulation, i.e., those costs not specific to any one subpart. Included in the latter costs are those
for reviewing, understanding, and implementing portions of the regulation not discussed in the
sections covering the individual subparts.
4.2.2.1 Costs of the General Provisions
EPA has identified only one paragraph in the General Provisions that might be
associated with a cost. Because disposal of sewage sludge in a municipal solid waste landfill that
complies with 40 CFR Part 258 constitutes compliance with Section 405(d), treatment works
shipping sewage sludge to municipal landfills might need to certify that the landfill complies
with Part 258. The treatment works operator should be able to request a copy of the landfill's
permit, but might be assessed copying and postage charges. EPA makes the following
assumptions to estimate the costs of this paragraph in the regulation: only one landfill per
disposing treatment works is used, the cost of this request is $10, and the cost recurs annually (a
reasonable worst-case assumption). EPA further estimates that there are 4,125 POTWs and
privately or federally owned treatment works using codisposal, based on the analytical survey
counts of secondary and advanced treatment works codisposing sewage sludge, the counts of
POTWs practicing primary treatment that codispose sewage sludge (from the 1988 Needs Survey
and estimates of secondary and advanced POTWs practicing codisposal from the NSSS), and the
4-10
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estimated numbers of private treatment works believed to be codisposing their sewage sludge
(the number of domestic septage haulers believed to be codisposing domestic septage is very
small, and EPA did not model this practice in estimating impacts on this segment of the
regulated population). At $10 per treatment works, the total cost is estimated to be $41,250
annually for all affected treatment works. Any cost for meeting the Part 258 requirements that
disposed material meet certain quality standards is assumed to be associated with 40 CFR Part
258, since compliance with Part 258 will be required before the Part 503 compliance period is
completed.
4.2.2.2 Costs of Reading and Understanding the Regulation
All treatment works and domestic septage firms, regardless of type of use or disposal
practice, will incur costs for someone at the treatment works or firm to read and interpret the
regulation. Reading the regulation will take approximately the same time regardless of the size
and complexity of the organization. EPA estimates that reading the regulation will require 8
hours of time at each potentially affected entity (including those treatment works whose use or
disposal practices are not covered by the regulation). Determining what needs to be done to
comply with the regulation is a more complex task. This task includes determining whether
current practices are equivalent to practices mandated by the regulation, identifying potential
problem areas where practices may need to be changed, etc. (the costs for implementing any
changes to existing practices is estimated in later sections; these costs are for preliminary
scoping activities only). All treatment works and firms that determine that their use or disposal
practice is covered by Part 503 will have to devote a certain amount of time to these types of
activities. The more complex the treatment works' operations, the more difficult and time
consuming this task will be.
EPA assumes that domestic septage haulers, private treatment works operators, federal
treatment works operators, and the smallest POTW operators (under 1 MGD) using a regulated
use or disposal practice, will be able to determine what they need to do to comply with the
regulation as they read it. Larger POTWs (1 to 10 MGD) are expected to need an additional 4
hours to determine what they need to do to comply. POTWs in the 10 to 100 MGD range are
4-11
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expected to need 8 hours, and the largest POTWs (greater than 100 MOD) are expected to
need 16 hours to determine what they need to do to comply. Any treatment works or firm
whose use or disposal practice is not covered by the regulation is expected to incur only the cost
of reading the regulation (an 8-hour task) to determine that their practice is not, in fact,
covered by the regulation. Table 4-3 presents the number of treatment works, the number of
hours EPA estimates each treatment works will need to read and interpret the regulation, and
the total cost of this time (based on a manager's time at $40/hr, loaded, for POTWs, $30/hr for
privately owned or federally owned treatment works, and $25/hr to $43/hr for domestic septage
haulers). The total cost of reading and interpreting the regulation for all treatment works is
expected to be $9.5 million, or $1.6 million when this cost is annualized (see Table 4-3)2.
43 LAND APPLICATION
4.3.1 Overview of the Regulatory Requirements of Part 503, Subpart B
Part 503, Subpart B, covers land-applied sewage sludge and domestic septage. The
subpart addresses both agricultural and nonagricultural land application. Agricultural land is
defined as land on which human food crops (including tobacco, animal feed crops, and fiber
crops such as cotton), arc grown. Agricultural land also includes pasture land and range land.
Nonagricultural land is forest land; reclaimed land; or a public contact site, such as a park, plant
nursery, or turf farm.
Subpart B also covers sewage sludge that is distributed and marketed. The subpart
requirements arc not specifically targeted to sewage sludge that is distributed and marketed, but
the subpart docs distinguish between requirements for bulk sewage sludge and those for sewage
2A11 costs arc annualized in Section Four over 20 years at 8 percent for treatment works (a
typical planning horizon for treatment works and a typical nominal bond rate) and over 5 years
at 12 percent for septage haulers (a more conservative assumption necessitated by the shorter
planning horizons and higher nominal interest rates available to sole proprietorships). Nominal
interest rates arc used to provide a conservatively high estimate of annual impact.
4-12
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sludge sold or given away in bags or other containers and/or for bulk sewage sludge used on
lawns and home gardens.
Seven types of requirements must be met regardless of land application end
use—general requirements, pollutant limits, management practices, an operational standard
covering pathogen and vector attraction reduction requirements, frequency of monitoring
requirements, rccordkeeping requirements, and reporting requirements. These seven types of
requirements arc discussed in the sections below.
4.3.1.1 Overview of the General Requirements
The general requirements cover sewage sludge that docs not meet three high-quality
requirements: the more stringent pollutant concentration limits, the more stringent Class A
pathogen requirements, and vector attraction reduction requirements (these limits and
requirements are discussed in detail in later sections). The sewage sludge covered by general
requirements, however, docs meet minimum quality requirements for pollutants, pathogens, and
vector attraction reduction. The general requirements are designed to ensure that all preparers
and applicrs of sewage sludge that docs not meet the three high-quality requirements have the
information necessary to meet all the relevant requirements of Subpart B. Because this type of
sewage sludge might need to meet requirements limiting the amount of pollutants that can be
applied to a site and management practice requirements, the preparer of bulk sewage sludge
must provide any subsequent preparers and any applicrs (if the applier is not the preparer) with
appropriate "notice and information" necessary to comply with Subpart B (e.g., pollutant
concentrations, class of pathogen and vector attraction reduction achieved by the sewage
sludge). The preparer must also provide the applier of bulk sewage sludge with the nitrogen
content of that sewage sludge. The preparer who provides sewage sludge to a person who
further prepares it, e.g., for sale or giveaway in a bag or other container, must also provide
notice and information to that subsequent preparer. Furthermore, the applier must ensure that
he or she has received appropriate notice and information before applying bulk sewage sludge
and to provide the land owner or lease holder of the land on which the sewage sludge is applied
with the same type of information. The main intent of these requirements is to provide a
4-14
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"paper trail" of information ensuring that all the affected parties can effectively follow the
requirements of Subpart B.
The requirements outlined above are interpreted to mean that the preparer of sewage
sludge not meeting the three quality requirements must have a written agreement with the
subsequent preparer (including persons who prepare the sewage sludge for sale or giveaway in a
bag or other container) or any applier before sewage sludge can be applied to the land.
Likewise all subsequent preparers of bulk sewage sludge must also have a written agreement
with the applier of that bulk sewage sludge. Although not specifically required by the
regulation, all preparers are assumed to keep a copy of the agreement in their records to limit
any future liabilities. This written agreement can be a contract, but does not have to be a
formal contract as long as the agreement lists the proper application rate and management
practices to be followed when the sewage sludge is applied. Implicit in this requirement is that
the treatment works and preparers and/or appliers sign the agreement to show that the
information has been transferred and that the signatories have received a copy of the
agreement.
The general requirements are also designed to ensure that cumulative pollutant limits on
any plot of land are not exceeded, even if sewage sludge from different preparers is applied to
the land by different appliers. The regulation ensures that persons preparing bulk sewage
sludge that does not meet the three high-quality requirements contact the state permitting
authority in the state in which the sewage sludge is to be applied if the sewage sludge is
prepared in another state. The preparer must provide the state authority with information on
site location; time period of application; and the name, address, telephone number, and NPDES
permit number of the preparer and the applier. The regulation further ensures that cumulative
pollutant limits are not exceeded by requiring all appliers of bulk sewage sludge that is subject
to the cumulative pollutant limits (see discussion of pollutant limits below) to provide written
notification to the state permitting authority in the state in which the bulk sewage sludge is to
be applied (whether or not the sewage sludge crosses state lines). This written notification must
include site location and the name, address, telephone number, and NPDES number of the
applier. The applier of sewage sludge subject to cumulative pollutant limits must also contact
the permitting authority to determine whether sewage sludge subject to cumulative pollutant
4-15
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limits has been applied to the site since 120 days after the effective date of the regulation. If
bulk sewage sludge has not been applied since that time, the applier can proceed without
additional calculations, other than those needed to determine the cumulative amount of
pollutants in the bulk sewage sludge being applied. If bulk sewage sludge subject to cumulative
pollutant limits has been applied since that time, the existing cumulative amount of pollutants
applied to the site must be used to determine the additional amount of each pollutant that can
now be applied to the site. If for any reason bulk sewage sludge subject to cumulative limits has
been applied to the site but the cumulative amount of pollutants applied is not known, no
further amount of sewage sludge can be applied to the site unless it can meet the more stringent
pollutant concentration limits (see discussion of pollutant limits below).
4.3.1,2 Overview of Pollutant Limits
A central feature of the Subpart B requirements is pollutant limits. The pollutant limits
are divided into two types: pollutant loading rate limits (i.e., limits on the amount of pollutants
applied to the land); and pollutant concentration limits (i.e., limits on the concentrations of
pollutants in the sewage sludge itself). Treatment works must meet one or more of these limits.
Pollutant concentration limits are divided into two types: pollutant concentration ceiling
limits, which govern whether a sewage sludge can be land applied at all; and pollutant
concentration limits, which define sewage sludge that is exempted from meeting pollutant
loading rate limits, certain rccordkecping requirements, and possibly other requirements as well
(see discussion below). The pollutant concentration limits arc used as one of three components
defining the high-quality requirements, which are discussed above.
Pollutant loading rate limits are also divided into two types: cumulative pollutant
loading rates and annual pollutant loading rates. Bulk sewage sludges that meet ceiling limits
but that do not meet pollutant concentration limits must meet cumulative pollutant loading
rates, which specify the total lifetime quantity of pollutant that can be applied to a site. Sewage
sludge sold or given away in bags or other containers meeting ceiling limits but not meeting
4-16
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pollutant concentration limits must meet annual limits, which specify the total amount of
pollutant that can be applied to a site in any one year.
Pollutant limits are specified in Part 503, Subpart B, for 10 metals: arsenic, cadmium,
chromium, copper, lead, mercury, molybdenum, nickel, selenium, and zinc. Each of these
pollutants in the sewage sludge must not exceed the ceiling limits, in mg/kg, presented in Table
4-4. Treatment works whose sewage sludge fails to meet these ceiling limits will no longer be
able to land apply that sewage sludge after Part 503 is promulgated. Those POTWs whose
sewage sludge does meet ceiling limits then must meet either the pollutant concentration limits
(presented in Table 4-5), cumulative pollutant loading rates (listed in Table 4-6), or, for sewage
sludge placed in bags or other containers, annual pollutant loading rates (see Table 4-7).
POTWs whose sewage sludge can meet pollutant concentration limits (limits on the
concentration of pollutants in the sewage sludge itself) are offered two advantages: (1) there are
no limits on the lifetime quantity of pollutants that can be applied to a site and (2) the sewage
sludge application rate is dependent only on the agronomic rate (which is derived from the
amount of nitrogen needed by the crops and the amount of available nitrogen in the sewage
sludge). Recordkeeping and reporting requirements are reduced for treatment works whose
sewage sludge meets pollutant concentration limits, and sewage sludge meeting pollutant
concentration limits may even be exempted from coverage by some or all requirements of the
Part 503 Subpart B regulation. This case occurs when sewage sludge either in bags or other
containers or in bulk, meets pollutant concentration limits and the more stringent Class A
pathogen and vector attraction reduction requirements (see discussion of pathogen and vector
attraction reduction requirements in Section 4.3.1.4). When sewage sludge meets pollutant
concentration limits, Class A pathogen requirements, and vector attraction reduction
requirements, the general requirements and management practice requirements in Subpart B do
not apply, unless the regional administrator or state director determine on a case-by-case basis
that, for bulk sewage sludge, these requirements are necessary to protect public health and the
environment. Furthermore, if the sewage sludge meeting these requirements is used to produce
a material, such as a fertilizer/sewage sludge blend, then this material is exempted from any
coverage by Subpart B (for example, although the component sewage sludge must be tested for
pollutant concentrations, the material produced from sewage sludge does not have to be tested
4-17
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TABLE 4-4
POLLUTANT CEILING LIMITS
FOR LAND APPLICATION OF SEWAGE SLUDGE
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Limit
(milligrams per kilogram)"
75
85
3,000
4,300
840
57
75
420
100
7,500
"Dry-weight basis.
Source: 40 CFR Part 503 Regulation. Subpart B.
4-18
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TABLE 4-5
POLLUTION CONCENTRATION LIMITS
FOR LAND APPLICATION OF SEWAGE SLUDGE
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Limit
(milligrams per kilogram)8
41
39
1,200
1,500
300
17
18
420
36
2,800
aDry-weigh't basis.
Source: 40 CFR Part 503 Regulation, Subpart B.
4-19
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TABLE 4-6
CUMULATIVE POLLUTANT LOADING RATES
FOR LAND APPLICATION OF SEWAGE SLUDGE
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Cumulative Pollutant
Loading Rate
(kilograms per hectare)"
41
39
3,000
1,500
300
17
18
420
100
2,800
"Dry-weight basis.
Source: 40 CFR Part 503 Regulation, Subpart B.
4-20
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TABLE 4-7
ANNUAL POLLUTANT LOADING RATES FOR
SEWAGE SLUDGES PLACED IN BAGS OR OTHER CONTAINERS
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Annual Pollutant Loading Rate
(kg per hectare per 365-day period)3
2.0
1.9
150
75
15
0.85
0.90
21
5.0
140
"Dry-weight basis.
Source: 40 CFR Part 503 Regulation, Subpart B.
4-21
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for pollutant concentrations). This exemption, for bulk material, can also be revoked by the
regional administrator or state director as discussed above.
If a treatment works' sewage sludge cannot meet pollutant concentration limits, the
treatment works must meet cumulative limits on the lifetime quantity of pollutants applied at a
site (if sewage sludge is applied in bulk) or annual limits (for sewage sludge in bags or other
containers).
The cumulative limits (Table 4-6), referred to as cumulative pollutant loading rates
(CPLRs), and annual limits, or annual pollutant loading rates (APLRs)(see Table 4-7), are
measured in kilograms per hectare (kg/ha). In the case of CPLRs, once the pollutant loading
rate limit for any one pollutant has been reached, cither in the first year or over a number of
years, no more sewage sludge can be applied to that site again. This provision reflects the fact
that metals tend to accumulate in the soil over time. When the sewage sludge preparer cannot
directly control the number of sewage sludge applications made to a site (when sewage sludge in
bags or other containers is given away or sold), annual pollutant loading rates must be met. In
this case, as long as the annual limits arc met, the Agency believes the total pollutant load to
the site over time will not exceed levels identified as protective of human health and the
environment.
Two critical factors that must be considered when bulk sewage sludge is applied to land
arc the application rate and the site life. As application rate increases, site life declines,
assuming sewage sludge quality remains the same. Preparers or appliers of bulk sewage sludge
may wish to determine, using the CPLRs, either (1) a maximum site life based on a given
application rate or (2) a maximum annual whole sewage sludge application rate (AWSAR) in
terms of dry metric tons (dmt) per hectare, given a certain site life. The latter approach
typically would be used only where sewage sludge pollutant concentrations constrain site life and
where the applier wishes to adjust its AWSAR downward to extend the site life. This approach
is particularly useful in situations where the primary roles of the land-applied sewage sludge arc
to provide moisture and to condition the soil rather than to meet the full nutrient needs of a
crop. The calculation can be performed using the method discussed below, solving for AWSAR
instead of years.
4-22
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In most cases, treatment works will use their existing application rate (AWSAR), if the
rate is at or below the agronomic rate, to determine the site life. First, annual pollutant loading
rates (APLRs)3 must be calculated by multiplying the concentration of each pollutant in the
sewage sludge by 0.001 (a conversion factor) and then multiplying this number by the AWSAR.
This calculation provides the total amount of each pollutant applied to a site annually in kg/ha.
For example, suppose the concentration of arsenic in a sewage sludge is 10 mg/kg dry weight.
As Table 4-6 shows, the CPLR for this pollutant is 41 kg/ha. If the agronomic application rate
is 12 dmt/ha, the calculation becomes:
APLR = C x 0.001 x AWSAR or
APLR = 10 x 0.001 x 12 = 0.12 kg/ha
where:
C = the concentration of a pollutant in mg/kg dry weight.
Site life then can be calculated by dividing the CPLR by the APLR:
CPLR/APLR = 41/0.12 = 342 applications (or 342 years at one application per year)
When site life is calculated for each pollutant, the shortest site life becomes the maximum site
life for the sewage sludge in question.
Site life is not an issue for sewage sludge in bags or other containers; only the
appropriate annual application rate needs to be determined. To compute the maximum
application rate for sewage sludge in bags or other containers, the APLR limits in Table 4-7 are
used. The concentration of each regulated pollutant in the sewage sludge is multiplied by 0.001.
The APLR from Table 4-7 is then divided by this product to compute the application rate:
APLR/CC x 0.001) = AWSAR
3These are not the APLRs set as limits in Table 4-7.
4-23
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where:
C = the concentration of a pollutant in mg/kg dry weight.
In the case of an arsenic concentration of 10 mg/kg dry weight, this calculation becomes:
2.0/(10 x 0.001) = 200 dry metric tons per hectare
When AWSARs for all regulated pollutants arc calculated, the lowest AWSAR calculated
becomes the limiting application rate for the sewage sludge in bags or other containers.
Domestic septagc is not required to meet the specific ceiling, cumulative, or pollutant
concentration limits. If a domestic septage hauler chooses not to meet these limits, domestic
septagc applications must not exceed a number of gallons per acre per year (annual application
rate) depending on the nitrogen need of the vegetation on the site where domestic septagc is
applied. The annual application rate is derived with a simple equation that uses the amount of
nitrogen needed annually by the crop or vegetation on the site. The amount of nitrogen to be
used in the equation must not exceed the amount needed by the crop or vegetation. In this way,
the regulation can reduce the impacts on domestic septage haulers to the extent possible by
taking into account the small size of the businesses affected and the relatively low concentrations
of pollutants in domestic septage, while still protecting human health and the environment from
metals and excess nitrogen.
4.3 J.3 Overview of Management Practice Requirements
Land-applying treatment works (and domestic scprage haulers) must meet management
practice requirements unless their sewage sludge meets the three high-quality requirements.
Bulk sewage sludge must be applied such that threatened or endangered species arc not
adversely affected. Sewage sludge (and domestic septagc) must be prevented from entering
waters of the United States, including wetlands, when bulk sewage sludge (or domestic septage)
is applied to land that is flooded, frozen, or snow-covered. This latter restriction does not apply
4-24
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if the applier has a Clean Water Act Section 402 or 404 permit that provides for the application
of sewage sludge in the waterbody or wetlands. Bulk sewage sludge (and domestic septage) also
cannot be applied within 10 meters of a waterbody or wetlands. Bulk sewage sludge must be
applied to agricultural land, forest, or a public contact site at an agronomic rate. Bulk sewage
sludge applied at a reclamation site must also be applied at an agronomic rate unless otherwise
specified by the permitting authority. Sewage sludge sold or given away in a bag or other
container is required to have a label attached or a handout sheet provided. The information
required on the label or handout includes the name and address of the preparer, a statement
prohibiting application except in accordance with instructions on the label, and the AWSAR that
does not cause the APLR to be exceeded.
4.3.1.4 Overview of Operational Standard Covering Pathogen and Vector Control Attraction
Reduction
At a minimum, Class B pathogen requirements must be met for all land-applied sewage
sludge. One vector attraction reduction method must also be used, as specified in Subpart D of
Part 503. To meet Class B pathogen reduction requirements, as per Subpart D, a treatment
works must meet one of three alternatives. First, a treatment works may test during each
monitoring period for fecal coliform using a minimum of seven samples taken at the time the
sewage sludge is used or disposed. The samples must show that geometric mean of the fecal
coliform is less than either 2 million most probable number (MPN) per gram of total solids (dry
weight) or 2 million colony forming units (CPU) per gram of total solids. Second, a treatment
works may use a process to significantly reduce pathogens (PSRP), which was defined in the
former version of 40 CFR Part 257, and which is now defined in Appendix B, Part 503. This
definition is reproduced in Table 4-8. Third, treatment works may also use a process determined
by the permitting authority to be equivalent to PSRP.
Domestic septage is offered a less burdensome requirement. For pathogen control,
domestic septage must either meet harvesting and site restrictions, which are outlined below, or
be treated such that its pH is raised by alkali addition to 12 and, without the addition of more
alkali, remains at 12 for 30 minutes. The site on which alkali-treated domestic septage is land
4-25
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4-27
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applied is subject to food-crop harvesting restrictions only (animal grazing, turf harvesting, and
public access restrictions do not apply).
When Class B sewage sludge or septagc that is not alkali-treated is applied to land, the
following crop-harvesting and public-access restrictions apply:
« Food crops with harvested parts that may touch the soil/sewage sludge mixture
can be harvested no sooner than 14 months after sewage sludge application.
• Root crops cannot be harvested for 38 months after sewage sludge application.
However, when sewage sludge is not immediately incorporated into the soil, and
4 months or more pass before sewage sludge is incorporated, then harvesting can
occur 20 months after application.
• Feed crops cannot be harvested for 30 days after application.
• Animals arc not allowed to graze on land for 30 days after application.
• Turf may not be harvested for a year after sewage sludge application when placed
on land with a high potential for public contact or on a lawn, unless otherwise
specified by the permitting authority.
• Public access to land with a high potential for public exposure, such as parks and
median strips, must be restricted for 1 year after application.
• Public access to land with a low potential for public exposure (e.g., private
farmland), must be restricted for 30 days after application.
Land-applied sewage sludge may also meet Class A requirements; however, all sewage
sludge applied to lawns or home gardens and all sewage sludge sold or given away in a bag or
other container must meet Class A requirements. Sewage sludge that meets this more stringent
level of pathogen control is not subject to any harvesting or access restrictions. This is true even
if the sewage sludge docs not meet pollutant concentration limits and therefore must meet other
management practice requirements.
To meet Class A pathogen requirements, treatment works can choose one of six
approaches. They can either (1) use a time/tcmperaturc-based process used to treat the sewage
sludge while meeting a pathogen limit in sewage sludge based on an indicator organism
(bacteria) or Salmonella sp. bacteria; (2) use an alkali/air-drying stabilization process while also
4-28
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meeting a pathogen-based limit; (3) demonstrate the performance of the process for reducing
enteric viruses and helminth ova while meeting the bacteria-based pathogen limit; (4) test for
pathogens—bacteria, enteric viruses, and helminth ova—at the time of use or disposal; (5) treat
the sewage sludge in a process to further reduce pathogens (PFRP); or (6) use a process
deemed equivalent to PFRP by the permitting authority (see Table 4-8).
The first four alternatives are described more fully below.
Alternative 1. The sewage sludge must meet pathogen requirements using either
fecal coliform or Salmonella sp. bacteria as indicator organisms. The sewage
sludge must be shown to contain fewer than 1,000 MPN fecal coliform per gram
of total dry solids or less than 3 MPN Salmonella per 4 grams of total dry solids
at the time the sewage sludge is used, disposed, or prepared for use or disposal.
Additionally, the temperature must be maintained at a specified level and for a
period of time based on two equations, which are selected based on percent
solids and type of heating processes.
Alternative 2. In Alternative 2, the same pathogen limit as for Alternative 1
must be met. Additionally, the treatment works must raise the pH of the sewage
sludge to 12 for 72 hours while the temperature remains above 52°C for at least
12 hours and the pH remains at 12. At the end of the 72-hour period, the
sewage sludge must be air-dried to 50 percent solids.
.Alternative 3. The same pathogen limit as for Alternative 1 must be met.
Additionally, in this alternative, the effectiveness of a Class A process must be
demonstrated. Demonstration of a Class A process requires that the sewage
sludge meets certain requirements. The sewage sludge must be analyzed before
pathogen reduction for enteric viruses and viable helminth ova. When enteric
viruses do not exceed 1 plaque-forming unit (PFU) per 4 grams of total dry
solids and when viable helminth ova do not exceed 1 per 4 grams of total dry
solids, the sewage sludge is Class A with respect to enteric viruses and helminth
ova until the next monitoring episode. When one or the other limit is exceeded
before processing, but the final requirements are met following the treatment
process, then the operating parameters for the pathogen reduction process must
be documented. The sewage sludge exiting the treatment process is then
considered Class A with respect to enteric viruses and helminth ova if the
operating parameters documented to achieve reduction are met during
processing.,
Alternative 4. Sewage sludge can be tested at every monitoring episode for
either fecal coliform or Salmonella, and must also be tested for enteric viruses
and viable helminth ova. If fecal coliform is less than 1,000 MPN per gram of
total solids or Salmonella is less than 3 MPN per 4 grams of total dry solids, and
enteric viruses and viable helminth ova are present at less than 1 plaque-forming
4-29
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unit and one viable helminth ovum per 4 grams of total dry solids, then the
sewage sludge meets Class A pathogen requirements.
Most of the vector attraction requirements for Class A sewage sludge are identical to
those for meeting Class B requirements and apply to both bulk sewage sludge and sewage
sludge placed in a bag or other container:
• Reduce the mass of volatile solids by 38 percent. If the sewage sludge cannot
meet this requirement, laboratory testing can be performed. Vector attraction
reduction is shown to be achieved when, after further digestion of the sewage
sludge for 40 days at a temperature between 30° and 37°C, the volatile solids in
an anacrobically digested sewage sludge are shown to be reduced by less than 17
percent, or when, after further digestion of the sewage sludge for 30 days at a
temperature at 20°C, the volatile solids in a less-than-2-percent solids aerobically
digested sewage sludge arc reduced by less than 15 percent.
• Show that the specific oxygen uptake rate of an aerobically digested sewage
sludge docs not exceed 1.5 milligram of oxygen per hour per gram of total dry
solids at a temperature of 20°C.
• Treat the sewage sludge in an aerobic process for 14 days or longer, during which
time the temperature of the sewage sludge is greater than 40°C and the average
temperature is greater than 45°C.
• Raise the pH of a sewage sludge to 12 by alkali addition. Without the addition
of more alkali, the pH must remain at 12 for 2 hours and at 11.5 for an
additional 22 hours.
• Show that the percent solids in a sewage sludge that docs not contain primary
treatment sewage sludge is greater than 75 percent.
• Show that the percent solids in a sewage sludge containing primary treatment
sewage sludge is greater than 90 percent.
The following vector attraction reduction methods arc available only when bulk sewage
sludge is applied to agricultural land, forest, a public contact site, or a reclamation site or when
domestic scptage is applied. These methods cannot be used when bulk sewage sludge is applied
to lawns or home gardens or when sewage sludge is placed in a bag or other container. These
methods also cannot be used to meet the high-quality requirement for vector attraction
reduction.
4-30
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Inject the sewage sludge below the land surface. No significant amount of
sewage sludge may be present on the surface within 1 hour and, if a Class A
sewage sludge is injected to achieve vector attraction reduction, this procedure
must be done within 8 hours after the sewage sludge is discharged from the
pathogen reduction process.
Incorporate the sewage sludge into the soil within 6 hours of land application.
When Class A sewage sludge is incorporated, the sewage sludge must be
incorporated within 8 hours after the sewage sludge is discharged from the
pathogen reduction process.
For domestic septage, the pathogen reduction requirement (raising the pH of the domestic
septage to 12 for 30 minutes, using alkali addition) meets the vector attraction reduction
requirement as well. The domestic septage can also be injected or incorporated as outlined
above, to meet the vector attraction reduction requirement.
4.3.1.5 Overview of Frequency of Monitoring Requirements
Sewage sludge applied to agricultural land, forest, a public contact site, or a reclamation
site must be monitored for pollutant concentrations and pathogen and vector attraction
reduction requirements. The annual amount of sewage sludge applied to the land or received
by a preparer of sewage sludge material for sale or giveaway in bags or other containers
indicates how frequently the sewage sludge must be tested. Treatment works or others applying
or receiving 0 to less than 290 dmt of sewage sludge annually must test once per year; those
applying or receiving 290 to less than 1,500 dmt must test once per quarter; those applying or
receiving 1,500 to less than 15,000 dmt must test once per 60 days (6 times per year); and those
applying or receiving 15,000 dmt or more must test once per month, unless otherwise specified
by the permitting authority. After 2 years the Agency may reduce the minimum monitoring
frequency for pollutant concentrations and pathogen density requirements for enteric viruses
and viable helminth ova in Class A sewage sludge when Alternative 3 is selected (see discussion
above on pathogen and vector attraction reduction).
If the pathogen and vector attraction reduction requirements for domestic septage are
met using alkali addition, each container, i.e., truck load, of domestic septage must be tested for
4-31
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pH before it is applied to agricultural land, forest, or a reclamation site to ensure that pathogen
and vector attraction reduction requirements arc met. Domestic septage that is not treated by
pH adjustment docs not need to be monitored.
4.3,1.6 Overview of Recordkeeping Requirements
Recordkeeping requirements vary depending on whether sewage sludge is land-applied in
bulk or placed in a bag or other container. They also vary depending on whether pollutant
concentration limits arc met, whether Class A or Class B pathogen requirements are met, and
the type of vector attraction reduction procedures used. The person responsible for keeping
certain records also varies in some cases. For example, those who prepare sewage sludge for
land application must keep pollutant concentration data, whereas the applier (if different from
the prcparcr) must keep information pertaining to management practices (see Table 4-9). Note
that in all cases, where more than one certification must be made, only one statement covering
certification of all requirements is needed.
Bulk Sewage Sludge Subject to Cumulative Limits
The most elaborate recordkeeping is required for bulk sewage sludge that meets ceiling
limits but not pollutant concentration limits, i.e., that is subject to cumulative limits. This
sewage sludge is subject to general and management practice requirements, and both the
prcparcr and the applier (if different) arc required to keep certain recordkeeping information
for at least 5 years, and in a few cases indefinitely.
As the table shows, for Class A sewage sludge that does not meet pollutant
concentration limits, the prcparcr must keep pollutant concentration data, management practice
certifications and descriptions, and pathogen and vector attraction reduction certifications and ,
descriptions (unless the sewage sludge is injected or incorporated to meet vector attraction
reduction requirements, in which case the applier must certify and describe this procedure).
The applier is required to maintain information on the land application site location, number of
4-32
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hectares in the site, date and time of application, cumulative amount of pollutant applied
(including the total amount of pollutants applied during previous applications), total amount of
sewage sludge applied in that application, and certifications and descriptions of information
obtained from the preparer and other sources. This information includes the notice and
information from the preparer, the nitrogen content of the sewage sludge (also obtained from
the preparer), and information collected from the permitting authority on past applications of
sewage sludge subject to cumulative limits. This applier information is the only information
Part 503 requires to be kept indefinitely. If the sewage sludge meets only Class B pathogen and
vector attraction reduction requirements, then the applier must also keep for 5 years (in
addition to the .site and application information described above) management practice and site
restriction certifications and descriptions. The applier might also need to retain information
certifying and describing the vector attraction reduction methods of injection or incorporation of
sewage sludge into the soil, if one of these methods was used to effect vector attraction
reduction for either Class A or Class B sewage sludge. Otherwise the preparer is responsible
for maintaining the vector attraction reduction certification and description.
Sewage Sludge Meeting Pollutant Concentration Limits and Class B Pathogen and
Vector Attraction Reduction Requirements
If the bulk sewage sludge meets the pollutant concentration limits and Class B pathogen
and vector requirements, the applier does not have to keep as much information as those using
or disposing sewage sludge that does not meet pollutant concentration limits. None of the site
location and application information is required to be recorded or kept. The preparer must
keep records of pollutant concentrations, Class B pathogen certification and descriptions, and
vector attraction reduction certifications and descriptions (if sewage sludge was not injected or
incorporated to meet these requirements). The applier must certify and describe management
practices, site restrictions, and vector attraction reduction (if injection or incorporation was used
to meet this requirement).
4-35
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Sewage Sludge or Material Meeting Pollutant Concentration Limits and Class A
Pathogen and Vector Attraction Reduction Requirements
Sewage sludge or material derived from sewage sludge that meets pollutant
concentration limits and Class A pathogen and vector attraction reduction requirements has the
fewest recordkeeping requirements associated with it, whether in bulk or in bags or other
containers. The prcparcr must only maintain information on pollutant concentrations, and
pathogen and vector attraction reduction certifications and descriptions, unless the sewage
sludge is injected or incorporated to meet vector attraction reduction requirements. If this is
the case, then the applicr must certify and describe the vector attraction reduction and must
also certify and describe management practice requirements (this type of sewage sludge is not
exempt from general requirements and management practices, since this vector attraction
reduction procedure is not one of those that meets the high-quality requirement for vector
attraction reduction).
Note, however, that material further derived from sewage sludge that itself meets
pollutant concentration limits and Class A pathogen and vector attraction reduction
requirements is not subject to any Subpart B requirements whether used in bulk or placed in
bags or other containers. Thus a fertilizer that contains as one of its components sewage sludge
meeting pollutant concentration limits and Class A pathogen and vector attraction reduction
requirements is not covered by Part 503, and no recordkeeping or other requirements apply.
Sewage Sludge Not Meeting Pollutant Concentration Limits That Is Placed in Bags or
Other Containers
Treatment works or others that prepare sewage sludge in bags or other containers, but
whose sewage sludge does not meet pollutant concentration limits, must include in their files the
annual whole sewage sludge application rate that does not cause the annual pollutant loading
rates in Table 4-7 to be exceeded; pollutant concentrations and pathogen and vector attraction
reduction certifications and descriptions; and a certification that the labeling management
practice has been met.
4-36
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Domestic Septage
Domestic septagc haulers must develop and keep the following information for 5 years:
• The location of the site on which domestic septage is applied
• The number of acres in the application site
• The date and time domestic septage is applied
• The nitrogen requirement of the crop or vegetation grown on the site jn a 365-
day period
• The rate in gallons per 365-day period at which domestic septage is applied
• Certifications that pathogen and vector attraction reduction requirements have
been met
• Descriptions of how pathogen and vector attraction reduction requirements have
been met
4.3.1.7 Overview of Reporting Requirements
Once per year certain treatment works must report certain types of information required
in the recordkceping section. Any information required to be maintained only by appliers is not
required to be reported, except when a sewage sludge subject to cumulative limits is applied on
a site that is within 90 percent of the cumulative pollutant loading rate. In this case, all of the
site-specific information, e.g., site location, number of hectares, pollutant loadings and quantity
of sewage sludge applied, must be obtained from the applier and submitted, Treatment works
that must report include Class I sludge management facilities and POTWs with a flow rate equal
to or greater than 1 MOD or that serve a population of 10,000 or more. Treatment works
whose host industries arc required to pretreat (typically those processing 5 MOD or more of
wastewater) are considered Class I treatment works. Additionally, some treatment works can be
designated as Class I based on the potential for the treatment works's sewage sludge use or
disposal practice to adversely affect public health or the environment, regardless of flow rate.
4-37
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4.3.2 Compliance Cost Analysis
Four types of treatment works arc analyzed to determine compliance costs:
• POTWs practicing secondary or advanced treatment.
• POTWs practicing primary treatment.
• Private and federally owned treatment works.
• Domestic scptagc haulers.
These treatment works arc covered separately because the NSSS results are directly applicable
only to POTWs practicing secondary or advanced treatment. The results of compliance analyses
based on the NSSS arc used, however, to make some assumptions about whether POTWs
practicing primary treatment and privately or federally owned treatment works are likely to
meet the pollutant limits and what the impacts of the pollutant limits might be. Impacts on
domestic scptage haulers arc of a much different nature and demand a separate analysis.
4.3.2 J Compliance Costs for Secondary and Advanced Treatment POTWs Practicing Land
Application
EPA estimates, based on the analytical portion of the NSSS, that 4,328 secondary and
advanced treatment works practice some form of land application in the United States (this
number corresponds to the total number of practices presented in Table 4-2). These treatment
works arc estimated to practice a total of 5,401 end uses.4 Of these treatment works, 10
process greater than .100 MOD of wastewater (Reported Flow Rate Group 1), 139 process
between 10 and 100 MOD (Reported Flow Rate Group 2), 1,119 process between 1 and 10
""End use is defined by the NSSS respondents. In general, respondents filled out a separate
survey part if the type of crop differed (e.g., human food crop vs. animal feed crop) or if the
type of crop was the same but site-specific information was different (for example, application
rates were different, the way in which sewage sludge was applied was different, or the type of
landowner was different). Respondents practicing distribution and marketing indicated
percentages of sewage sludge going to various end uses. A few facilities provided no
information on end use. They were assumed to practice one end use.
4-38
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MOD (Reported Flow Rate Group 3), and 3,060 process 1 MOD or less (Reported Flow Rate
Group 4). These POTWs land applied a total of 1.5 million dry metric tons (dmt) of sewage
sludge in 1988 (see Table 4-10).
The compliance cost analysis for POTWs practicing secondary or advanced treatment
consists of five parts. First, the number of treatment works that cannot meet the ceiling
concentration limits or cannot meet the pollutant concentration limits or the cumulative
pollutant loading rate limits without changing their practices in some way are determined (the
pass/fail analysis). Second, the types of changes these treatment works might make to comply
with the pollutant limits are identified (the compliance strategy analysis). Third, costs for
making these changes are estimated. Fourth, any costs for incremental general requirements;
management practices; pathogen and vector attraction reduction requirements; and monitoring,
recordkeeping, and reporting requirements are estimated. Finally, all costs for these POTWs
are summed to produce total compliance costs for all land-applying POTWs practicing
secondary or advanced treatment.
Pass/Fail Analysis
Pass/Fail Methodology. The basic requirements for compliance outlined in Section 4.3.1
call for land-applied sewage sludge to meet the ceiling limits for all regulated pollutants.
Furthermore, the sewage sludge also must meet cumulative pollutant loading limits or pollutant
concentration limits, as presented in Subpart B. It is also assumed that treatment works
providing sewage sludge for application to lawns or home gardens or to compost brokers or
contractors for sale or giveaway must provide sewage sludge that passes pollutant concentration
limits to continue these end use practices. Compost brokers and contractors will prefer to deal
only with sewage sludge that meets pollutant concentration limits and Class A pathogen and
vector attraction reduction requirements because the brokers themselves will not have to meet
any of the Subpart B requirements. If most sewage sludges now going to brokers or contractors
for sale or giveaway meet these requirements (as this analysis supports), these firms will have
little reason to accept any sewage sludge that does not meet this requirement.
4-39
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TABLE 4-10
NUMBER OF SECONDARY OR ADVANCED TREATMENT POTWS
PRACTICING LAND APPLICATION
Reported Flow Rate Group
>1(K) MOD
> 10-100 MOD
>I-10MGD
£1 MOD
Total
Number of POTWs
Practicing Land Application
10
139
1,119
3,060
4,328
Quantity of Sewage Sludge
Land Applied (dmt)
184,067
591,914
539,372
165,547
1,480,900
Source: 1988 National Sewage Sludge Survey, EPA. Weights based on analytical survey.
4-40
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Prior to determining whether treatment works' sewage sludge meets ceiling and other
limits, we made one adjustment to pollutant concentration data. Based on information EPA
received on dilutions of pollutants achieved when sewage sludge is composted (personal
communication between ERG and Alan Rubin, EPA, May 16,1991), the pollutant
concentrations for sewage sludge from treatment works that compost their sewage sludge were
adjusted downwards to reflect an assumed 40-percent dilution of pollutants (see Appendix A for
more details). Under this scenario, if the sewage sludge had an arsenic concentration of 20
mg/kg (dry weight), the compost would be calculated to have an arsenip concentration of 12 (60
percent of 20).
The first step in the pass/fail analysis was to determine which treatment works have
sewage sludge that exceeds the ceiling limits using all treatment work in the analytical portion of
the NSSS that practice land application. These POTWs fail the requirements of Subpart B and
are analyzed further to determine compliance strategies and compliance costs. The next step of
the pass/fail analysis determined which treatment works meet pollutant concentration limits,
using the remaining treatment works in the analytical portion of the NSSS that practice land
application. Those meeting these limits were not analyzed further, except to determine whether
any treatment works' application rate appeared to exceed a reasonable agronomic rate.
Treatment works that did not meet pollutant concentration limits were analyzed further.
Only two of the survey treatment works failing pollutant concentration limits prepare sewage
sludge in bags or other containers or provides sewage sludge to brokers or contractors, and
analysis of these POTWs was handled separately outside the pass/fail model. For the other
POTWs failing pollutant concentration limits, cumulative pollutant loading rates were used to
determine pass/fail. EPA therefore calculated ASWARs for these POTWs. These AWSARs
were based on responses to questions in the NSSS concerning the application rates and the
number of applications per year per site, where this information was available. The application
rate was multiplied by the number of applications per year per site to produce an annual
application rate. If information on the number of applications per year was missing, EPA
inferred that the sewage sludge was applied only once to a site each year (most treatment works
indicated they apply sewage sludge only once per year per site and we assumed respondents
skipped the question because they thought the question was irrelevant to their operation).
4-41
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Where the application rate was missing, we used the median annual application rate of
treatment works of the same size (reported flow group) and with the same land application end
use to impute the annual application rate for the treatment works in question (sec Appendix A).
Treatment works that identified themselves in the NSSS as practicing distribution and marketing
did not complete the portion of the survey's questions on application rates. EPA did not
develop a methodology to apply to these treatment works, however, since it was assumed that
sewage sludge from these POTWs must meet the pollutant concentration limits in order to pass.
Certain problems arose in using the application rate multiplied by the number of
applications. When the annual rate was calculated in this way, a number of unusually high rates
was produced. EPA adjusted the clearly improbable application rates, cither by using the total
volume of sewage sludge disposed annually and the site acreage reported or by contacting
certain treatment works to confirm application rate (see Appendix A).
The last part of the analysis looked at existing annual application rates to determine if
any treatment works appeared to be exceeding agronomic rates. We could not definitively
select a cutoff point, because the appropriate agronomic rate depends on the type of crop,
nitrogen content of and form of the nitrogen in sewage sludge, and other site-specific factors.
We decided that any treatment works that applied more than 55 dmt/ha and indicated that
nitrogen needs were not used to determine the application rate possibly exceeded an application
rate based on the nitrogen needs of any crop. This decision was based on the upper limit of
application rates reported in the NSSS that were associated with a "yes" response to a question
of whether the treatment works considered the nitrogen needs of the crops in establishing the
sewage sludge application rate. Appendix A discusses the agronomic rate issue in more detail.
Pass/Fail Results. A total of 92 treatment works in the NSSS analytical survey were
identified as practicing land application. Of these, 87 meet the ceiling limits. A total of 5 thus
fail the ceiling limits, representing 49 facilities nationwide and 80,000 dmt of sewage sludge, or 1
percent of all land-applying facilities and 5 percent of all land-applied sewage sludge.
4-42
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A total of 66 survey POTWs are able to meet the pollutant concentration limits.5 These
66 treatment works represent 3,216 treatment works nationwide, practicing a total of 3,837 end
uses, or 74 percent of all land-applying treatment works, and 71 percent of all land-application
end uses. POTWs meeting the pollutant concentration limits are estimated to land apply 1.2
million dmt annually or about 80 percent of all land-applied sewage sludge.
The remaining 21 treatment works that meet ceiling limits but that do not meet the
pollutant concentration limits represent 1,063 treatment works with 1,463 end uses. These
POTWs land-apply 224,000 dmt, or 15 percent of all land-applied sewage sludge. As discussed,
only two of these treatment works that fail pollutant concentration limits provide sewage sludge
for use on lawns/home gardens or to brokers/contractors for sale or giveaway. These POTWs
(POTW 417, representing 6 POTWs and POTW 366, representing 135 POTWs nationwide) are
therefore estimated to fail to meet appropriate requirements (an economic fail not a regulatory
fail) and are analyzed in subsequent sections for an appropriate compliance strategy and costs of
compliance.
The 19 remaining treatment works failing to meet pollutant concentration limits
(excluding POTWs 417 and 366), were analyzed further to determine if their existing application
rates allowed them to meet the cumulative pollutant limits over an economically viable site life.
Table 4-11 presents the listing of all 21 survey treatment works that do not meet pollutant
concentration limits, with existing application rate, maximum application rate based on
cumulative limits and a 20-year site life (except for reclamation, with a 1-year site life), and site
life based on existing application rate. The treatment works are represented by their survey
number assigned in the NSSS and are listed in ascending order by site life.
5Five POTWs that fail the pollutant concentration limits compost their sewage sludge. Even
though their sewage sludge fails pollutant concentration limits, since the sewage sludge is diluted
by 40 percent, the composted sewage sludge is considered to pass pollutant concentration limits.
Three of these POTWs blend their sewage sludge together for shipment to a composter. The
blended sewage sludge fails the pollutant concentration limits for copper and lead, but after
composting, all of the material is expected to meet pollutant concentration limits. Finally, one
POTW fails the pollutant concentration limit for arsenic, but its sewage sludge is blended before
being collected by a broker. The blended sewage sludge is judged to meet pollutant
concentration limits (see Appendix A).
4-43
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TABLE 4-11
PASS/FAIL RESULTS FOR SECONDARY OR ADVANCED TREATMENT WORKS
PRACTICING LAND APPLICATION THAT DO NOT MEET
POLLUTANT CONCENTRATION LIMITS
POTW
Number
096
096
096
129
034
454
454
454
454
349
334
454
252
336
349
310
Reported
Flow Rate
Group
1
1
1
2
3
2
2
2
2
2
3
2
4
4
2
3
End Use
Public Contact
Site
Reclamation
Public Contact
Site
Agriculture
(Feed Crop)
Public Contact
Site
Other Non-
Agricultural
Public Contact
Site
Reclamation
Forestry
Agriculture
(Pasture)
Reclamation
Forestry
Agriculture
(Feed Crop)
Agriculture
(Food Crop)
Agriculture
(Feed Crop)
Agriculture
(Food Crop)
Existing
Application
Rate
(dmt/ha)
3,201
421
125
45
95
55
45
45
34
49
45
18
11
16
21
13
Maximum
Application
Rate
(dmt/ha)
41
825
41
18
38
24
24
486
24
45
855
24
20
33
45
29
Site Life
Based on
Existing
Application
Rate (Years)
Cannot
Apply Once
1
6
7
7
8
10
10
14
18
18
26
36
40
42
44
Number
of End Uses
Represented
Nationwide
1
1
1
6
30
6
6
6
6
6
6
6
135
135
6
30
Pass/
Fail
Result
Fail
Fail'
Fail
Fail
Fail
Fail
Fail
Pass
Fail
Fail
Pass
Pass
Pass
Pass
Pass
Pass
4-44
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TABLE 4-11 (cont.)
POTW
Number
096
441
127
336
090
096
349
209
417
209
116
334
334
393
426
Reported
Flow Rate
Group
1
3
3
4
3
1
2
3
2
3
2
3
3
3
3
End Use
Agriculture
(Other)
Other Non-
agricultural
Other Non-
agricultural
Agriculture
(Feed Crop)
Agriculture
(Feed Crop)
Agriculture
(Feed Crop)
Agriculture
(Food Crop)
Agriculture
(Feed Crop)
Agriculture
(Pasture)
Agriculture
(Food Crop)
Agriculture
(Feed Crop)
Agriculture
(Food Crop)
Agriculture
(Food Crop)
Agriculture
(Feed Crop)
Public Contact
Site
Existing
Application
Rate
(dmt/ha)
16
16
16
10
15
11
10
9
9
7
5
5
5
3
1
Maximum
Application
Rate
(dmt/ha)
41
49
50
33
48
41
45
50
48
50
34
43
43
36
21
Site Life
Based on
Existing
Application
Rate (Years)
•- 52
62
63
66
66
75
91
110
111
138
144
158
158
239
424
Number
of End Uses
Represented
Nationwide
1
30
30
135
30
1
6
6
6
6
6
6
6
30
30
Pass/
Fail
Result
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
4-45
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TABLE 4-11 (cont.)
POTVV
Number
141
359
090
124
366b
366b
Reported
Flow Rate
Group
4
4
3
4
4
4
End Use
Agriculture
(Pasture)
Agriculture
(Feed Crop)
Agriculture
(Pasture)
Agriculture
(Food Crop)
Agriculture
Sale
Existing
Application
Rate
(dmt/ha)
1
1
1
0.1
NA
NA
Maximum
Application
Rate
(dmt/ha)
76
30
48
25
35
35
Site Life
Based on
Existing
Application
Rate (Years)
1,089
1,126
3,346
5,466
NA
NA
Number
of End Uses
Represented
Nationwide
135
135
30
135
135
135
Pass/
Fail
Result
Pass
Pass
Pass
Pass
Pass
Pass
' Based on failure to meet reasonable agronomic rate assumption of 55 dmt/ha; maximum application
rate reflects amount that could be applied assuming one year of application only, with pollutants the
only limiting factor.
b POTW 366 answered the distribution and marketing portion of the survey questionnaire, so existing
application rates are unknown. However, based on an evaluation of the maximum application rate,
EPA judges that this sewage sludge could be applied at an economically viable agronomic rate.
Note: Reported Flow Rate Group 1 = >100 MOD; Reported Flow Rate Group 2 = > 10-100 MGD;
Reported Flow Rate Group 3 = >1-10 MGD; and Reported Flow Rate Group 4 = <1 MGD.
The economically feasible site life of reclaimed land is only one year.
Source: ERG estimates based on 1988 National Sewage Sludge Survey, Analytical Survey, EPA.
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EPA determined that in addition to the five survey treatment works that fail the ceiling
limits, five additional survey treatment works (POTWs 034, 096, 129, 349, and 454) with seven
end uses could not apply sewage sludge at their current rates for the minimum economic site
life defined above, and are thus designated as failing treatment works. One additional end use
(reclamation at 421 dmt/ha by POTW 096) fails because of appearing to exceed an agronomic
rate that would be likely to be approved by a permitting authority. The five failing treatment
works represent 49 treatment works nationwide (096 represents itself only, 034 represents 30
treatment works, and 129, 454, and 349 represent 6 each), with 63 end uses.
Compliance Strategies
Compliance strategies were developed based on the following factors: (1) the treatment
works that failed to meet either the pollutant ceiling limits, the cumulative pollutant loading rate
limits using their existing application rates and an economically feasible site life, or the pollutant
concentration limits (for sewage sludge going to a broker); (2) the alternative disposal practices
the treatment works had noted as feasible in the NSSS questionnaire; (3) costs of alternatives;
and (4) information from callbacks.
This section on compliance strategies is split into three subsections. One subsection
covers compliance strategies for POTWs that fail the pollutant ceiling limits, one covers
compliance strategies for the POTWs that fail cumulative limits, and one covers compliance
strategies for the POTW that fails pollutant concentration limits that sends its sewage sludge to
a broker.
Pollutant Ceiling Limit Compliance Strategies. For the five survey POTWs that fail
ceiling limits, EPA investigated the pollutants that were problematic for these POTWs and the
magnitude of the problem (i.e., by how much the problem pollutants have to be reduced in
order for the POTWs to meet the pollutant ceiling limits). In general, at these POTWs, only
one pollutant caused the failure. Table 4-12 indicates the POTWs that fail the pollutant ceiling
concentrations, the pollutants that fail, the concentration of that pollutant in each POTW's
sewage sludge, and the percent decrease in concentration needed to meet the pollutant ceiling
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TABLE 4-12
POTWS THAT FAIL POLLUTANT CEILING CONCENTRATIONS
POTVV
097
128
440
117
436
Pollutants
That Fail
Cadmium
Nickel
Arsenic
Nickel
Zinc
Nickel
Concentration of
Failing Pollutants
136.5
976.0
258.7
694.0
33,400.0
431.0
Percent Decrease
Needed in Pollutant
Concentration to
Meet Limit
37.7%
57.0%
71.0%
39.5%
82.9%
2.6%
Source: ERG estimates based on 1988 National Sewage Sludge Survey, EPA.
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limits. EPA assumed these POTWs would investigate the feasibility of more stringent
pretreatment before shifting to another disposal method.
If the POTWs indicated that further pretreatment was both technically and practically
feasible, EPA investigated whether the reductions in pollutants needed to meet ceiling limits
could be achieved. All five POTWs indicated that pretreatment was technically achievable and
three indicated that pretreatment was practically achievable. EPA made its own determination
of practical achievability, however.
POTW 097, which fails the cadmium ceiling, applies sewage sludge at much greater than
agronomic rates. Even though this POTW indicated that pretreatment was technically and
practically achievable, it could not continue to land apply at such extreme rates. Codisposal was
selected as the most likely compliance strategy for this POTW, since a large portion of its land-
applied sewage sludge might have to be shifted from land application in order to meet
agronomic rate requirements, even if the cadmium concentration could be lowered.
EPA then looked in more depth at the remaining four POTWs. In all cases, EPA
identified firms that were likely to be the source of the problem with sewage sludge quality.
POTW 128, which fails the ceiling limit for nickel, has four metal finishing firms arid one paint
manufacturing firm. These two industries are associated with nickel discharges, according to
data published in the RIA for the proposed regulation (see Appendix E). POTW 436 also fails
the ceiling limit for nickel. The major contributors appear to be seven electroplating firms.
POTW 440 serves a specialty glass-making firm. This firm, according to its industrial waste
survey, discharges very high levels of arsenic in its wastewater. Finally, POTW 117, whose
sewage sludge fails the ceiling limit for both nickel and zinc, has only one industrial
contributor—a metal finishing firm. Metal finishers are associated with both nickel and zinc
discharges, according to the RIA for the proposed regulation.
All four POTWs were determined to have two viable alternatives: more stringent
pretreatment or codisposal. The cost of each alternative is discussed in the compliance cost
section.
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Cumulative Limits Compliance Strategies. As discussed previously in the pass/fail
analysis, five survey POTWs cannot meet cumulative pollutant limits—POTWs 096, 034, 129,
349, and 454. POTW 096 fails primarily because it applies sewage sludge in enormous
quantities. As note in Table 4-11, this POTW could apply sewage sludge at up to 41 dmt/ha/yr
and still meet cumulative limits for a period of 20 years. This is a relatively large amount of
sewage sludge, but is considered a reasonable agronomic rate assuming careful selection of crop
or vegetation. Pretrcatmcnt is not really an option for this POTW, because even if pollutant
concentrations were not limiting, the nitrogen need of crops would be. The sewage sludge
represented by this POTWs failing end uses makes up a very minor portion of its overall
sewage sludge production. The treatment works indicated that it could send at least one-third
of its sewage sludge to a codisposal landfill (monofilling and surface disposal were other choices,
but are considered less likely choices given the requirements associated with the surface disposal
subpart—sec Section 4.4). The treatment works could maintain its land application end uses at
lower rates, so we assumed that after adjusting its application rate downward, the leftover
sewage sludge that can no longer be-land-applicd will be disposed in a codisposal landfill, once
Part 503 is implemented.
Three of the remaining treatment works, POTWs 034, 129, and 349, have already
changed their operations since 1988 (the year of the NSSS) because of state regulatory
requirements. The treatment works, in fact, were not in compliance with state regulations in
1988. POTW 034 has begun in-vcssel composting of its sewage sludge, which, based on a
dilution factor, is estimated to allow it to meet alternative pollutant limits. POTW 129 has
expanded the amount of land on whteh it applies sewage sludge and now applies at much lower
than its maximum allowable rate. POTW 349, which (according to the NSSS) practices land-
application end uses with uncomposted and composted sewage sludge, noted in the NSSS that it
will be composting all of its sewage sludge because of state regulatory requirements. When the
sewage sludge is composted, the dilution factor should allow the sewage sludge to pass the
pollutant limits at its current application rate and to meet alternative pollutant limits for its land
application end use (the treatment works requires a 10-percent reduction in pollutant
concentrations in its sewage sludge to meet pollutant concentration limits).
4-50
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Finally, POTW 454 must reduce either application rates or site lives for three end uses.
In one case, the reduction in application rate or site life is relatively small (from 34 dmt/ha. to 24
dmt/ha or from 20 years to 14 years). In another case, the treatment works must reduce its
application rate from 45 dmt/ha to 24 dmt/ha or reduce site life from 20 years to 10 years.
Finally, under a third end use, the POTW must reduce its application rate from 55 dmt/ha to 24
dmt/ha or its site life from 20 years to 8 years. This treatment works practices several other end
uses. It has two major silviculture operations, a land reclamation program, and thousands of
additional acres that it could have access to, if needed (see Appendix A). The POTW can land-
apply for as little as 8 years at these sites, and when needed, can shift to other land application
end uses or to other sites.
Pollutant Concentration Limit Compliance Strategies. POTW 417 narrowly misses
meeting pollutant concentration limits. Its measured level of cadmium is 40.75 mg/kg dry
weight. The regulation sets cadmium at 39 mg/kg dry weight. EPA assumes this POTW will
attempt to reduce cadmium through more stringent pretreatment requirements. The percent
reduction (4 percent) it needs to meet the pollutant concentration limits is considered within the
range achievable with more closely monitored pretreatment operations at its host industries.
POTW 366 also does not meet pollutant concentration limits. However, it provided only
about 50 dry Ibs of sewage sludge for sale or giveaway in 1988. The remainder was land applied
on farm land. EPA assumes that the POTW discontinues the sale or giveway of this sewage
sludge to comply with Part 503. EPA has also determined that the maximum application rate
for this POTW's sewage sludge will allow the economically viable agricultural land application of
this sewage sludge (the actual application rate is not known).
Cost Estimates for Compliance Strategies
Ceiling Limit Costs. POTW 097—This POTW fails not only ceiling limits, but
agronomic limits as well on most of its land application end uses. This POTW is assumed to
shift to codisposal, which was indicated in the NSSS as one of its alternatives. Although the •
POTW indicated that it could use this disposal practice for up to one-third of its land-applied
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sewage sludge, the other choices did not appear cost-effective (monofilling/surface disposal).
Furthermore, this POTW is operated by an authority that operates several other POTWs, one of
which also indicated the same alternative disposal method in the same proportions. Additionally,
most of the sewage sludge prepared at the POTWs operated by this authority codispose sewage
sludge. EPA assumes that all of the sewage sludge currently being land applied by this POTW
could be codisposed. We determined that this POTW would be able to codispose of its sewage
sludge for about $7 per dmt incrementally (see discussion below under compliance costs for
POTW 096, one of its "sister" POTWs in the section devoted to POTWs failing cumulative
limits). The POTW has 28,323 dmt of sewage sludge affected by the ceiling limits, for a total
annual incremental cost of $198,261. The POTW represents only itself.
The remaining four POTWs are more likely pretreatment candidates. We have estimated
a cost for both pretreatment and codisposal for these four POTWs (see Table 4-13).
POTW 440—This POTW serves a specialty glass-making firm that discharges high levels
of arsenic in its effluent. Lime treatment is the most likely approach for dealing with this
problem. Even though a high level of removal is needed (71 percent), the high initial
concentration makes it likely that this level of removal is possible. Although the POTW
indicated that additional pretreatment was not practically feasible, EPA believes that such a
"cheap fix" (i.e., lime addition) will not be difficult for the POTW to implement. This procedure
is very simple and relatively inexpensive. This POTW, which represents 6 POTWs, should
contribute less than $0.5 million to the national level costs (or less than $80,000 per firm, which
is on the lower end of costs for the most stringent pretreatment technologies presented in the
RIA for the proposal, reproduced as Appendix E).
Codisposal costs for this POTW are estimated to be $247 per dry metric ton, based on
the mean cost for codisposal in this size class. The POTW currently spends $184 per dry metric
ton to land apply sewage sludge. Incremental costs are thus $63 per dmt. The POTW will need
to dispose of 845 dmt of sewage sludge, costing the POTW an additional $53,235 per year. The
POTW represents 6 POTWs, so the total nationwide cost associated with this representative
POTW is $319,410 for codisposal. Because the costs for pretreatment are not a precise
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TABLE 4-13
COSTS OF CEILING LIMITS—COMPARISON OF
PRETREATMENT AND CODISPOSAL SCENARIOS
POTW
097
128
440
117
436
Pretreatment Costs
—
$2,330,256
500,000
2,912,820
4,077,948 .
Codisposal Costs
$198,261
1,785,234
319,410
5,486,580
3,679,200
Source: ERG estimates.
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estimate, EPA chose codisposal as the compliance strategy for this POTW. Pretrcatment may
be a less expensive alternative, however.
POTW 117—This POTW has one industrial contributor—a metal finisher. The POTW's
sewage sludge fails the ceiling limits for nickel and zinc. The nickel concentration is about 40
percent above the ceiling limit, but the zinc concentration is nearly 6 times higher than the
ceiling limit. The firm should be able to retrofit more efficient pretrcatment technologies,
which appear to achieve virtually 100 percent removal of both nickel and zinc. The POTW
indicated that prctreatmcnt was both technically and practically achievable. Although removal
levels needed are very high, so arc the concentrations of zinc and nickel in the sewage sludge.
The RIA for the proposal cites case studies in which removals range from about 7 percent to
100 percent for nickel and from 0.5 to 98.3 percent for zinc. EPA believes that the removals
needed arc reasonably achievable, particularly since the problem originates with one industrial
source. (EPA was unable to obtain this POTW's industrial waste survey.) Costs for meeting
the most stringent level of pretrcatment for metal finishers were presented in the RIA for the
proposal. Costs in 1987 dollars were $111,000 in capital costs and $67,000 for O&M costs.
Annual costs would therefore be $78,302. Updated to 1992, these costs are estimated to be
$97,094 (based on a 24 percent inflation factor). This POTW represents 30 firms, so
pretreatmcnt costs might add about $2.9 million annually.
Codisposal costs for this POTW are calculated as follows. The average cost of
codisposal in this size class is $358 per dmt. The POTW land applies sewage sludge at a cost of
S32 per dmt. The incremental cost is thus $326 per dmt. The POTW would need to dispose of
561 dmt for a total cost to the POTW of $182,886. The POTW represents 6 POTWs
nationwide. Total national-level costs arc thus $5.5 million for codisposal. Based on this
analysis, EPA has selected pretrcatment as the most likely compliance strategy for the POTW.
POTW 436—This POTW serves seven clectroplaters, which, according to its industrial
waste survey, account for a large portion of the nickel influent to this treatment works. More
efficient prctreatment equipment should remove about 98 percent of nickel from electroplating
effluent, according to the RIA for the proposal (sec Appendix E). Based on analysis of this
POTW's industrial waste survey, using the same methodology outlined in the RIA for the
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proposal, EPA calculated that the POTW could reduce its sewage sludge pollutant
concentration of nickel to 393.5 mg/kg, thereby meeting the pollutant ceiling limit of 420. As
discussed above, the equipment needed for more stringent pretreatment (which is the same for
electroplaters as it is for metal finishers) costs $97,094 on an annual basis. Total costs to the
seven electroplaters are $679,658 annually. The POTW represents 6 such POTWs, thus total
annual costs of pretreatment associated with this POTW and those it represents total $4.1
million.
The POTW indicated that it could send all of its sewage sludge to a codisposal landfill if
land application were no longer possible. Codisposal costs are estimated at $247 per dmt in this
size class. Currently, the POTW incurs a cost of $28 per dmt for land application. Codisposal
is therefore estimated to cost the POTW an additional $219 per dmt. Total cost of disposal at
this POTW would be $613,200. Extrapolated to the national level, total costs are $3.7 million.
EPA chose codisposal as the compliance strategy for this POTW.
POTW 128—This POTW serves 100 firms. Its sewage sludge exceeds the ceiling value
for nickel. Contributors of nickel appear to be its four metal finishing firms and its one paint
manufacturing firm, based on information appearing in the RIA for the proposal. Both of these
industries can achieve virtually 100 percent removal of nickel with the most stringent level of
pretreatment. As noted above, metal finishing firms are expected to incur $97,094 per firm in
annual costs for more stringent pretreatment. Total costs for the metal finishing industry would
thus be $2.3 million annually nationwide (4 firms x 6 POTWs x $97,094). The paint formulating
industry has a very small flow compared to the metal finishers (52,000 gallons per day versus
400,000 gallons per day). It may thus be sufficient to increase pretreatment only at the metal
finishing firms.
If the POTW shifted to codisposal, the cost of disposal would increase from $126
currently to $247 per dmt (the average cost of codisposal on this reported flow rate group), for
an incremental cost of $121 per dmt. The POTW would need to dispose of 2,459 dmt. Total
incremental cost for this POTW is therefore $297,539. Nationally, the POTW represents 6
POTWs, so total national level costs would be $1,785,234 for codisposal. EPA estimates that
this POTW will shift to codisposal since it is a relatively less expensive approach.
4-55
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Table 4-13 shows the costs to each POTW for both pretreatment (if applicable) and
codisposal. In several cases, codisposal is either less expensive than pretreatment, or is felt to be
a more exact estimate.
Based on the assumption that all POTWs except POTW 117 shift to codisposal, the costs
of failing pollutant ceilings total $8.9 million with 63,323 dmt of sewage sludge that must be
shifted out of land application (or 5 percent of all land applied sewage sludge). Additionally, we
assume that either in the case of more stringent pretreatment or in the case of shifting to
codisposal, the POTWs will incur planning costs. We have estimated that planning costs might
require up to 80 hours of a manager's time at $40 per hour or $326 on an annual basis. Based
on 49 POTWs nationwide that fail the ceiling limits, the cost for planning would add an
additional $16,000 annually to this cost. Total costs are thus estimated to be $8.9 million, and
are shown in Table 4-14.
Cumulative Limit Costs. Of the five treatment works in the NSSS failing cumulative
limits, only one is significantly affected by the Part 503 regulations. POTWs 034, 129, and 134
have already (since 1988) made changes to their operations as required by state regulations. The
costs to alter their methods of sewage sludge use or disposal are attributable to these state
regulations, not to Part 503. POTW 454 is estimated to maintain its land application to its
public contact sites for 8, 10, or 14 years. Since these are fairly long site lives and since the
treatment works can easily move sewage sludge from one end use to another and has numerous
additional sites available to it (see Appendix A), we estimate that the costs of complying with
Part 503 will be negligible for this treatment works and for the other treatment works it
represents (6 treatment works nationwide). Only POTW 096 will need to markedly change its
use or disposal practices. The percentage of sewage sludge that can continue to be land applied
was calculated by dividing the existing application rate into the maximum allowable application
rate based on CPLRs. For example, the maximum allowable rate is 41 dmt/ha based on
pollutant concentrations (this was also considered a reasonable agronomic rate); in the case of
one end use, the actual rate was 125 dmt/ha. Thus the quantity of sewage sludge that could
continue to be land-applied in this end use in one year was calculated to be 33 percent of the
existing quantity for this end use, since 41 is 33 percent of 125.
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TABLE 4-14
TOTAL COSTS OF MEETING CEILING LIMITS
USING SELECTED COMPLIANCE STRATEGIES
POTW
097
128
440
436
117
Total
Number of
POTWs
Represented
1 •
6
6
6
30
49
Cost per
POTW
$198,261
297,539
53,235
6131200
97,094
—
I mplementation
Costs
$198,261
•• 1,785,234
319,410
3,679,200
2,912,820
$8,894,925
Annualized
Planning Costs
$326
1,956
1,956
1,956
9,780
$15,974
Total Cost of
Compliance
$198,587
1,787,190
321,366
3,681,156
2,922,600
$8,910,899
Source: ERG estimates.
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As stated above, we anticipate that this treatment works will shift a large portion of its
land-applied sewage sludge to codisposal (see Table 4-15). The sewage sludge at this treatment
works is very dry (65-69 percent solids), and should be quite suitable for landfilling. It is
assumed that additional capital equipment will not need to be purchased, since the same trucks
that currently handle this sewage sludge can also haul it to a codisposal landfill.
POTW 096 land applies only a small fraction (about 5 percent) of their sewage sludge.
Most of its sewage sludge is used as landfill cover, which is considered codisposal and is not
covered by this regulation. Another treatment works operated by the same authority ships its
sewage sludge to a codisposal landfill for disposal (POTW 098). The operating and maintenance
(O&M) cost for POTW 098 is $5 per dry metric ton for disposal, based on the POTW's response
to the NSSS. The O&M costs of land application at POTW 096 is $5 based on its NSSS
response. EPA believes that the cost of disposing the relatively small amounts of sewage sludge
that can no longer be land applied will not cost much more than the $5 per dry metric ton
incurred by the third treatment works operated by this authority. Even if the cost of disposal for
POTW 096 is double that for the third treatment works ($10 per dry metric ton), the total
incremental cost of disposal would be $8,855. Added to this cost is a planning cost. Codisposal
landfills must be contacted and a disposal contract may need to be arranged. EPA estimates that
possibly 80 hours of a manager's time ($40/hr) may be required to make the shift to codisposal,
or $3,200. This would be a one-time cost, adding only $326 per year to the cost of disposal.
Total annual costs are thus $9,181.
Pollutant Concentration Limit Costs. POTW 417 is assumed to institute minor
operational changes in its pretreatment program, i.e., host industries will be asked to keep a
closer eye on their pretreatment systems and make necessary repairs or other minor corrections
to achieve "closer-to-spec" operations. The cost of repairing or maintaining the equipment is
associated with a properly operated pretreatment program and is not a cost of Part 503. Any
cost for reducing cadmium by the 4 percent necessary for meeting the pollutant concentration
limit is therefore expected to be minimal.
POTW 366 is expected to discontinue the sale or giveway of its 50 Ibs per year of sewage
sludge. The cost of this shift is considered negligible because even though this POTW represents
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TABLE 4-15
PROPORTION OF SEWAGE SLUDGE THAT MUST BE SHIFTED FROM LAND
APPLICATION TO CODISPOSAL—SECONDARY OR ADVANCED TREATMENT WORKS
POTW
096
Total
End Use
Public Contact
Reclamation
Public Contact
Quantity (dmt)
671
1,005
671
2,448
Percentage That
Can Continue to
Be Applied (%)
17
24
33
Quantity Left
Over for
Codisposal
(dmt)
. 557
764
450
1,771
Source: ERG estimates.
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135 POTWs the loss in any possible revenue should be quite small. Furthermore, finding
farmland for this small amount of sewage sludge should not be a problem.
Total Costs for AH Compliance Strategies. The total cost for all failing POTWs to'
institute compliance strategies is $8.9 million based on the $8.9 million required for POTWs
whose sewage sludge fails ceiling limits and the $9,181 for all other POTWs failing a limit.
Cost Estimates for Other Requirements
General Requirements. The general requirements pertain only to persons preparing and
applying sewage sludge that does not meet pollutant concentration limits, Class A pathogen
requirements and vector attraction reduction requirements not including injection or '
incorporation. Clauses 503.12(f) and (g), require "notice and information" to be given to the
applier or preparer of sewage sludge, if the applier or final preparer is not the treatment works.
Clause (d) also requires the preparer to provide the applier with information on the nitrogen
content of bulk sewage sludge. Clause (h) requires the applier to provide the landowner or
leaseholder with information as well. The cost of this last clause is considered negligible,
amounting to a copy of information needed to be retained by the preparer and/or the applier.
The first notice and information requirement as well as the requirement to provide information
on nitrogen content are associated with the costs of developing written agreements with appliers
of the sewage sludge. These agreements are assumed to be primarily off-the-shelf material with
some site-specific information added to each agreement, such as that provided by EPA as an
example in Environmental Regulations and Technology: Use and Disposal of Municipal Wastewater
Sewage Sludge (EPA, 1984) (see Appendix A). The NSSS does not provide any information on
the number of appliers, but does indicate whether the POTWs apply the sewage sludge
themselves and whether, among those that do not apply themselves, written agreements are used.
Among the land appliers surveyed in the NSSS, a total of 5 analytical survey POTWs,
representing 97 treatment works nationwide, do not apply sewage sludge themselves and do not
have a written agreement with the distributor or applier of the sewage sludge, although they
provide written instructions, have verbal agreements, or otherwise appear to have provided some
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information to appliers, who are, for this analysis, assumed to be the landowners. Appendix A
presents the methodology and results of this analysis.
Information must also be given to the preparer of sewage sludge as provided in clause
503.2(g). This situation usually only occurs when sewage sludge is transferred to another POTW
or when the sewage sludge is provided to a broker or contractor for further preparation (as
indicated in questions pertaining to distribution and marketing in the NSSS). The sewage
sludge transferred from POTWs to brokers appears to meet the three high-quality requirements,
thus these POTWs are assumed to be exempted from this general requirement. A total of 862
POTWs, however, are estimated to transfer their sewage sludge to another POTW. EPA does
not know in many instances whether the subsequent POTW is a land applier. We assume that
since approximately one-third of all POTWs are land appliers, that approximately one-third of
these 862 POTWs (287) will need to provide notice and information. It is not known whether
these POTWs provide information equivalent to that required by Part 503. If it is assumed that
all of these 287 POTWs must provide notice and information incremental to current practices,
then each must provide one preparer with notice and information once per monitoring episode.
EPA estimates that the 97 treatment works not currently providing appliers with notice
and information and the 287 treatment works that must provide preparers with notice and
information will need to set up a form each monitoring period that incorporates the results of
the sewage sludge pollutant analyses and states the allowable application rates, nitrogen content,
management practices, and harvest restrictions, if any (all other treatment works are assumed to
have the mechanisms for providing notice and information in place, and minor changes, such as
including the nitrogen content, will result in minimal incremental impacts). A total of 1 hour of
technical time (at $30/hr) and 1/2 hour of clerical time (at $20/hr) is anticipated each monitoring
episode for a total of $40 per monitoring period. Additionally, for information going to appliers
(but not preparers), 1/2 hour of clerical time is estimated for filling in the name of the applier,
and signing and copying the form for each site on which sewage sludge is land applied, for a
total of $10 per site. Based on the NSSS and an assumption about average site acreage of 40
acres, EPA estimates that each POTW will provide notice and information to between 5 and 40
appliers, depending on the quantity of sewage sludge land applied. Table 4-16 shows the cost of
4-61
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form setup to be $31,000 annually and the cost of providing this information to each applier to
be $27,000 annually, for a total cost of about $57,000 annually.
Clause 503.12(e) requires the applier to obtain all information necessary to comply with
Part 503, including information from the permitting authority concerning the prior application
of sewage sludge pollutants on the site to ensure that cumulative limits are not exceeded. The
applier must also provide written notice to the permitting authority. These tasks are expected
to entail about 1.5 hours per site per year of clerical time to contact'the relevant authority (EPA
assumes one application per year per site) and to provide the name, address, telephone number,
and NPDES permit number of the applier, and the location of the site. Based on the estimated
number of sites served by the different size POTW, subject to cumulative limits, the total cost
for this task is expected to be $187,000 (Table 4-17). Although the applier is responsible for
this information, EPA assumes this cost is borne by the POTWs. POTWs either apply sewage
sludge themselves or will most likely endeavor to ease any burden on the farmers—who are
often the appliers when the POTW does not apply the sewage sludge—to promote the use of
the sewage sludge.
Clause 503.12(i) requires the preparer to contact state authorities when the sewage
sludge is to be applied in a state other than the one in which the sewage sludge was prepared.
This occurrence is relatively uncommon and is not expected to substantially increase the amount
of time already estimated for other notice and information tasks.
Total costs for general requirements are estimated to be $0.2 million based on costs
incurred for providing notice and information and for obtaining information necessary to comply
with Clause 503.12(e).
Management Practices. The management practice 503.14 (a), which protects
endangered species, is also a requirement of Part 257.302 (Endangered Species), and Clauses
(b) and (c) are currently covered by Part 257.303 (Surface Water), which prohibits discharge of
pollutants into waters of the United States. Because the requirements in these clauses are
covered in existing regulations, no costs are considered attributable to these clauses.
Furthermore, Clause (b) in Part 503 requires a Part 404 permit only when sewage sludge is
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TABLE 4-17
COST OF ESTABLISHING POLLUTANT LOADING
HISTORY AT LAND APPLICATION SITES
Reported Flow
Rate Group
>100 MOD
> 10-100 MOD
>!-!() MOD
i£l MOD
Total
Number of
POTWs
Subject to
Cumulative
Limits
1
30
222
675
928
Number of
Sites per
POTW
40
20
10
5
-
Cost per
Site
$30
30
30
30
-
Total
Annual
Cost
$1.200
18,000
66,600
101,250
$187,050
Source: ERG estimates.
4-64
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applied to flooded, frozen, or snow-covered ground such that sewage sludge enters a wetland,
and many states prohibit application of sewage sludge to frozen or snow-covered ground. Good
management practices, such as slope restrictions, can prevent sewage sludge from entering
wetlands during application where sewage sludge application to frozen or snow-covered ground
is allowed. Thus, we anticipate little, if any, impact from this requirement.
Clause (c), requiring a 10-meter buffer zone to surface water, is consistent with general
good management practices, and many states that regulate the land application of sewage sludge
require buffer zones (see Section Three). Furthermore, this requirement can be interpreted as
a specific statement of the intent of Part 257.303 (Surface Water), since the requirement is
intended to prevent sewage sludge from entering surface water during rain storms. EPA is
aware of no comments from land appliers that indicate any problems complying with this
requirement. Based on all of the foregoing, we anticipate little to no impact from this clause.
Clause (d) requires sewage sludge to be applied at agronomic rates, although sewage
sludge applied to reclamation sites could be allowed by the permitting authority to be applied at
higher than agronomic rates. This issue was discussed in detail in previous sections and in
Appendix A. These clauses are expected to have little impact because these requirements
appear to be consistent with current practices. In the one case in which a POTW was applying
at a reclamation site at much higher than agronomic rates, the cost of reducing this rate was
estimated and included in the cost of the compliance strategy. The labeling requirement in
Clause (e) is not an issue. All sewage sludge in bags or other containers or sewage sludge going
to brokers either meets all three high-quality requirements or the POTWs and other preparers
currently providing sewage sludge in bags or other containers are expected to bring pollutant
concentrations below the pollution concentration limits to achieve the quality requirements.
Thus, all POTWs providing sewage sludge in bags or other containers are expected to be
exempted from the labeling requirement.
Based on the fact that all management practice requirements in Subpart B are either
requirements of Part 257, current practice, or otherwise estimated to result in negligible costs,
we estimate that little or no costs are associated with management practice requirements.
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Pathogens and Vector Attraction Reduction. The Class B pathogen and vector attraction
reduction requirements for treatment works have been written to be basically the same as those
in Part 257. Any treatment works not meeting Part 257 is considered out of compliance, and
the cost of meeting pathogen and vector attraction reduction requirements is not credited to
Part 503. Thus, no incremental costs for meeting the specific pathogen and vector attraction
reduction requirements arc anticipated. Other costs involving harvesting and site restrictions
arc possible and are discussed below.
Class B sewage sludge must meet crop-harvesting restrictions. These requirements are
somewhat similar to the restrictions in Part 257. The differences are presented in Table 4-18.
The limit for harvesting abovcground crops has been reduced from 18 months to 14 months.
The limit for harvesting root crops has, however, been extended from 18 months to 38 months,
if sewage sludge is incorporated into the soil less than 4 months after application. If sewage
sludge is not incorporated into the soil until after 4 months or more have passed since
application, the limit is 20 months. Since the vast majority of crops are nonroot crops,
according to the NSSS questionnaire survey, the economic benefits of reducing the time to
harvest nonroot crops should outweigh any costs associated with delaying harvests of root crops.
The 14-month delay specified by Part 503 means that, in most cases, sewage sludge can be
spread in the spring of one year and most types of crops harvested the next year. With an 18-
month wait, as specified in the previous version of 40 CFR Part 257, sewage sludge might have
needed to be applied earlier in the spring than convenient, and only those crops harvested late
in the year could be planted. Otherwise, farmers might have had to wait at least two full
growing seasons before planting food crops for human consumption. Time delays before
allowing grazing on sewage sludge-amended pastures remains 1 month (30 days), although feed
crops must now be harvested no less than 30 days after sewage sludge has been applied. This
new restriction should not have a major impact, since sewage sludge is usually added before
feed crops are planted. In most cases, crops would be harvested later than 30 days from
application.
The public access restrictions are less stringent than those in Part 257. Public access is
restricted for 1 year (as also required by Part 257), but only when there is high potential for
public exposure. Public access is restricted for only 30 days if the land has a low potential for
4-66
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TABLE 4-18
COMPARISON OF PSRP AND CLASS B
CROP HARVESTING AND ACCESS RESTRICTIONS
Type of Restriction
Food Crop (Nonroot)
Harvesting
Food Crop (Root)
Harvesting
Turf Farms
Feed Crops
Animal Grazing
Public Access
Harvesting or Access Restriction
Class B
14 months
38 months/20 monthsa
1 year
30 days
30 days
1 year/30 daysb
PSRP
18 months
18 months
—
—
30 days
1 year
aTwenty months if sewage sludge is incorporated into the soil after 4 months have passed; 38
months if incorporated sooner.
bOne year on land with high potential for public exposure, 30 days on land with low potential
for public exposure.
Source: ERG estimates.
4-67
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public exposure (i.e., privately owned land). This change could result in a small cost savings in
some cases. '
The costs and savings associated with harvesting and access restrictions are difficult to
quantify; however, these costs and cost savings may balance. EPA estimates that little to no
incremental costs from these requirements will be incurred.
Class A pathogen requirements correspond to PFRP requirements. Any treatment
works that currently provides sewage sludge for unrestricted use is considered out of compliance
with Part 257 if PFRP (and thus Class A requirements) is not met. Thus, EPA estimates that
no incremental costs will be incurred by POTWs providing sewage sludge for lawn and home
garden use, or by brokers and contractors for meeting Class A pathogen requirements. Since
these POTWs are assumed to treat their sewage sludge in PFRP processes, they will only have
to test for fecal coliform or Salmonella in samples taken at the time the sewage sludge is used
or disposed. EPA assumes that all sewage sludge will be able to pass this requirement. Testing
costs arc calculated below under Frequency of Monitoring.
All treatment works, whether meeting Class A or Class B pathogen requirements, that
do not inject sewage sludge or incorporate sewage sludge into the soil within 6 hours of
application, will have to demonstrate vector attraction reductions. Most treatment works are
assumed to demonstrate vector attraction reduction by measuring the mass of volatile solids
reduced by the digestion process because they already analyze volatile solids as part of
monitoring the efficacy of their wastcwater treatment process. All treatment works are believed
to be able to meet the vector attraction reduction requirements with their current processes.
Therefore, only the costs of monitoring for vector attraction reduction will be incurred (see
below).
Frequency of Monitoring. All land-application treatment works must monitor for
pollutant concentrations. Although some vector attraction reduction requirements will not
require monitoring (e.g., injection, incorporation), EPA assumes, for simplicity, that all POTWs
will have to test for vector attraction reduction. Sewage sludge must be tested, however, only
when the treatment works prepares sewage sludge to meet Class A pathogen requirements.
4-68
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EPA assumes that all monitoring is incremental to existing practice, although many states
currently require monitoring of some metals (see Section Three). Based on data gathered from
laboratories that analyzed the sewage sludge samples taken for the NSSS, the cost of an
individual sewage sludge test should be about $190 for the metals of concern at the detection
levels needed to demonstrate compliance with the pollutant limits. (Personal communication
between ERG and Dave Tompkins, ETS Analytical, 1992.) All treatment works will also have
to monitor, at a minimum, volatile solids (assumed to be the parameter of choice for indicating
compliance with vector attraction reduction requirements) in sewage sludge. Class A sewage
sludge must also be monitored for fecal coliform, at a minimum.
Currently, treatment works must monitor wastewater for fecal coliform and volatile
solids and generally have the capability to measure these parameters in-house. The fecal
coliform test on digested sewage sludge is not time consuming (personal communication
between ERG and Al Vinosa, EPA, March 3, 1992). It takes about 1/2 hour to collect the
seven samples required; an hour to prepare the samples for incubation; and about 1/2 hour to
read and record the results. Volatile solids testing is also uncomplicated (personal
communication between ERG and Joe Farrell, EPA, March 3, 1992). Testing includes about 10
minutes to collect samples; 5 minutes to weigh the initial samples; 5 minutes to weigh the
samples after baking in the oven; and 10 minutes to record the observations.
Thus, the incremental effort to monitor fecal coliform and volatile solids in sewage
sludge is assumed to be no more than 2-1/2 hours of a technician's time at $30/hr (2 hours for
the fecal coliform testing and 1/2 hour for volatile solids testing), or $75 per monitoring episode.
The total cost of a monitoring episode (for metals, pathogens., and vector attraction reduction
parameters) is expected to be $265 for Class A sewage sludge; for Class B sewage sludge, the
cost for monitoring is expected to be $205. Table 4-19 shows the number of treatment works by
flow group and by monitoring frequency size groups, the monitoring frequencies required, and
the annual costs for each group for monitoring. As the table shows, 6 treatment works must
test monthly; 154 treatment works must test bimonthly; 729 treatment works must test quarterly;
and 3,420 treatment works must test annually. Total costs for monitoring metals are $1.4
million annually, and for pathogens and vector attraction reduction, $0.2 million. Thus, the total
4-69
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Recordkeeping. The types of recordkeeping activities required of secondary or advanced
treatment POTWs can be divided into three types: recordkeeping requirements for treatment
works whose sewage sludge does not meet pollutant concentration limits; those for treatment
works whose sewage sludge meet pollutant concentration limits and Class B pathogen and vector
attraction reduction requirements;6 and those for treatment works whose sewage sludge or
material derived from sewage sludge meets pollutant concentration limits and Glass A pathogen
and vector attraction reduction requirements. In the following analyses, we have assumed for
simplicity that the POTW is also the applier. This simplification should not affect the magnitude
of costs, since we calculate a per-site recordkeeping cost that should be equivalent to an
individual farmer's cost of recording and maintaining information, assuming the farmer is the
applier.
Recordkeeping requirements for treatment works whose sewage sludge meets ceiling
limits but does not meet pollutant concentration limits are the most complicated of the three
types. In this first type of recordkeeping requirement, a recordkeeping system must be
established to keep track of the potentially numerous site-specific records that must be
maintained.
The first step in creating a recordkeeping system is setup. EPA assumes that filing space
is available, but that a filing system must be initiated at a cost of 1 clerical hour at $20/hr for
treatment works testing sewage sludge, pathogens, and vector attraction reduction parameters
once per year ($20); 3 hours for treatment works testing once per quarter ($60); 8 hours for
treatment works testing 6 times per year ($160); and 16 hours for treatment works testing
monthly ($320). (These are all first-year costs and appear under initial setup costs in
Table 4-20). Next, forms must be designed to record location; date and time; reporting period's
sewage sludge quality; and certification that management practices, site restrictions, and
pathogen and vector control requirements have been met (as well as descriptions of how these
have been met), based on data generated during monitoring episodes. Form setup is assumed to
6Almost no sewage sludge sold or given away in bags or other containers is expected to fail to
meet pollutant concentration limits following more scrutiny of existing pretreatment programs,
and the small amount that does continue to fail is expected to be shifted to bulk land application
end uses, thus the requirement to keep labels, etc. is not applicable.
4-71
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Table 4-20). Next, forms must be designed to record location; date and time; reporting period's
sewage sludge quality; and certification that management practices, site restrictions, and
pathogen and vector control requirements have been met (as well as descriptions of how these
have been met), based on data generated during monitoring episodes. Form setup is assumed
to take 2 hours of management time at $40/hr ($80) and 4 hours of clerical time ($80) at the
outset for a total first-year cost of $160 (also included under initial setup costs in Table 4-20),
with an additional 1 hour of management time and 2 hours of clerical time each reporting
period ($80) to update the sewage sludge quality (this activity is independent of treatment works
size or volume of sewage sludge used or disposed and recurs each monitoring period—see
monitoring episode setup in Table 4-20). Copies must be generated at a cost of $0.05 per site
(this cost is added to the per-site costs discussed below).
As noted above, for the purpose of recordkeeping, the POTW is assumed to be the
applier and thus directly incurs the cost of performing the application recordkeeping. At the
site, the applier fills in the site location, date and time, and application rate. Pollutant loads are
calculated from application rate and the sewage sludge quality and are recorded in terms of
mg/kg concentrations of pollutants. The time required for this activity is assumed to be 1/2 hour
per site technical time at $30/hr ($15). A description of the methods used to obtain information
on prior pollutant loadings on the site must also be written. This description is expected to be
somewhat generic, but modified to suit the findings on the site. One-quarter hour of '
technician's time and one-quarter hour of clerical time are expected to be needed to prepare a
description for each site. Finally, the time required to file the record is assumed to be 1/2 hour
of clerical time per 10 records ($l/site). Thus, total per-site costs are $28.55 (including the
$0.05 per page copy charge discussed above). Numbers of sites were estimated above in the
discussion of notice and information requirements.
Table 4-20 presents the total number of treatment works nationwide whose sewage
sludge is estimated to meet ceiling limits (either before or after compliance strategies are
initiated) but fail to meet pollutant concentration limits (1,087 treatment works—the original
1,112 minus 6 expected to tighten up pretreatment requirements and 19 that fail ceiling
concentrations and do not use pretreatment to continue land application), along with cost
4-73
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estimates for each step of the rccordkecping task. Total annual costs for this group arc
estimated at $0.4 million.
Rccordkecping is significantly simplified for treatment works whose sewage sludge meets
pollutant concentration limits. EPA assumes that the task of setting up a potentially large filing
system is not required. In addition, no site-specific information needs to be retained. Only the
initial forms setup and monitoring episode updates are required (at $160 and $80, respectively).
Annual costs for rccordkeeping for the 2,808 treatment works that meet pollutant concentration
limits and Class B pathogen and vector attraction reduction requirements arc estimated to be
S0.4 million (sec Table 4-21).
The last type of rccordkeeping requirement is for those treatment works whose sewage
sludge meets pollutant concentration limits and Class A pathogen and vector attraction
reduction requirements. Because less information is required to be kept (e.g., management
practice certifications and descriptions and harvest restriction information are not required),
EPA estimates that only half the time is needed by both managerial and clerical staff to set up
forms. Updating forms should take the same amount of time as that for Class B sewage sludges
that meet pollutant concentration limits. For the 414 treatment works whose sewage sludges arc
estimated to meet pollutant concentration limits and Class A pathogen and vector requirements,
EPA estimates annual recordkecping costs to be $0.06 million (see Table 4-22). Total
rccordkeeping costs for land-applying secondary or advanced treatment POTWs, regardless of
type of pollutant pathogen and vector requirements met, arc $0.9 million annually (see
Table 4-23).
Reporting. Class I treatment works and all treatment works processing more than 1
MGD (or serving more than 10,000 persons, which is approximately equivalent to a 1 MOD
flowrate) will have to report once per year to the permitting authority. The report will basically
encompass the records compiled for the year required by the rccordkeeping portion of Subpart
B. Only a portion of all treatment works are considered Class I. For the most part, Class I
treatment works are those required to have a pretrcatment program (i.e., generally those
processing 5 MGD or more daily). Some states, however, are able to impose pretrcatment
requirements on industry directly, and POTWs that process the effluent from these industries
4-74
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TOTAL ANNUAL RECORDKEEPING COSTS FOR ALL LAND-APPLYING
SECONDARY OR ADVANCED TREATMENT WORKS
Reported Flow
Rate Group
>100 MGD
> 10-100 MGD
>1-10 MGD
<1 MGD
Total
Costs for
Treatment
Works Subject
to Cumulative
Limits
$2,151
25,046
137,593
195,278
$360,068
Costs for
Treatment
Works Passing
Pollutant
Concentration
Limits/Class B
$1,953
42,665
174,084
220,177
$438,879
Costs for
Treatment
Works Passing
Pollutant
Concentration
Limits/Class A
$3,889
5,858
24,302
26,444
$60,493
Total Annual
Recordkeeping
Costs for All
Land Appliers
$7,993
73,569
335,979
441,899
$859,440
Source: ERG estimates.
4-77
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arc also considered Class I treatment works. In addition, EPA can designate any other
treatment works Class I. EPA believes, however, that the vast majority of these latter types of
POTWs are those processing between 1 MOD and 5 MOD. Thus EPA assumes that only those
POTWs with flows greater than 1 MOD will need to report their records. Table 4-24 presents
the numbers of treatment works estimated to be Class I for the purposes of the cost estimate.
A total of 277 treatment works fail to meet the pollutant concentration limits while 972 meet
the pollutant concentration limits, for a total estimated number of 1,249 Class I land-applying
treatment works. This number docs not include the estimated 19 POTWs that shift from land
application to codisposal. Treatment works that meet the pollutant concentration limits have
much less record material to report. Costs for these treatment works are estimated to be $10
per treatment works for 30 minutes of clerical labor at $20/hr (cost of postage and copying
considered negligible). Treatment works that do not meet the pollutant concentration limits
must maintain site-specific records. Costs for these treatment works arc compiled on a per-site
basis, which is estimated as follows: EPA assumes that it takes 30 minutes at $20/hr to collect
10 site records ($l/sitc), 1 hour at $20/hour to package and send 10 site records ($2/site), and
$0.35 copy and postage costs pcr-site record. Thus the cost per site for reporting is estimated at
$3.35. As Table 4-24 shows, the total annual costs for reporting for all Class I treatment works
are estimated at $20,000.
Total Costs of Subpart B for POTWs Practicing Secondary or Advanced Treatment
Table 4-25 presents the total costs of Subpart B for land-applying secondary or advanced
treatment POTWs, which is approximately $11.6 million. As the table shows, the bulk of the
costs for these treatment works is the costs for meeting pollutant limits ($8.9 million). About 77
percent of total costs for secondary or advanced treatment POTWs to comply with Subpart B
arc for meeting pollutant limits. Average costs per treatment works for all requirements range
from $426 for the smallest treatment works to $43,507 for treatment works processing 10 to 100
MOD of wastewatcr.
4-78
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-------
4.3.2.2 POTWs Practicing Primary Treatment
The NSSS was not designed to collect information from primary treatment works; thus
the survey cannot be used directly to determine whether primary treatment works can meet the
Part 503 pollutant limits. However, EPA undertook a study (SAIC, 1991) comparing the quality
of sewage sludge from primary treatment waste streams with that from secondary treatment
waste streams at the same treatment works. These data were collected during the "40-City
Study" (EPA, 1982) on which EPA had based its assumptions about sewage sludge quality in the
proposal. The result of this analysis supported the hypothesis that primary sewage sludge was no
worse in quality than secondary sewage sludge for the pollutants regulated in Subpart B. Based
on this information, we have determined that the failure rate for POTWs generating primary
sewage sludge should be no worse than the failure rate for POTWs generating secondary or
advanced treatment sewage sludge. As Table 4-26 shows, 948 primary treatment works are
estimated to practice land application. EPA believes that the average per-treatment works cost
of complying with the Part 503 regulation, by flow group, should approximate the impacts in this
group of treatment works. Average costs per treatment works for all costs of complying with
Part 503 ranged from $426 to $43,507, depending on flow group. Based on the estimated
number of primary treatment works, EPA estimates total costs for this group are $1.9 million.
4.3,2.3 Privately Owned Treatment Works
The NSSS was not designed to collect information on privately owned treatment works.
Little is known about the quality of sewage sludge in privately owned treatment works, except
that these treatment works are very small (generally less than 0.1 MGD) and the private
treatment works typically process only domestic wastewater. Based on these characteristics, and
barring any information that would indicate otherwise, EPA assumes that privately owned
treatment works have sewage sludge quality no worse than that of Reported Flow Group 4
POTWs (those with less than 1 MGD total flow) in the NSSS. Thus, we estimate that privately
owned treatment works will have no difficulty meeting the pollutant limits. As noted in Section
Three, EPA estimates that 4,829 privately owned treatment works might be operating, of which
21.3 percent, or 1,029 are estimated to practice land application. It is not known whether these
4-81
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TABLE 4-26
COSTS FOR PRIMARY TREATMENT WORKS PRACTICING LAND APPLICATION
TO COMPLY WITH THE PART 503 REGULATION
Primary
Treatment Works
Flow Rate
Group
>100 MOD
>10-100 MOD
>1-10 MOD
£1 MOD
Total
Number of
Primary
Treatment
Works
5
23
107
813
948
Average Annual Cost
Per Land-Applying
Treatment Works of
Complying with Part
503 (from Table 4-25)
$24,048
43,507
3,618
426
$1,946
Total Annual Costs of
Primary Works
Practicing Land
Application to Comply
with Part 503
$120,240
1,000,661
387,126
346,338
$1,854,545
Source: ERG estimates based on 1988 Needs Survey data on numbers of primary treatment
works and NSSS survey results.
4-82
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treatment works apply their sewage sludge themselves. It is EPA's belief that most of these
treatment works contract out sewage sludge disposal and thus can meet the requirement for
notice and information by indicating whether the sewage sludge meets pollutant concentration
limits or providing the appropriate application rate and management practice information to the
contractor. Since private treatment works have been subject to Part 257, the remaining
management practice requirements and pathogen and vector control requirements will have
negligible costs, as was outlined above for secondary and advanced treatment POTWs. Other
costs relevant to these treatment works are monitoring, recordkeeping, and reporting costs. EPA
estimated total compliance costs to privately owned treatment works based on costs per
treatment works at the smallest secondary and advanced treatment works ($426 per treatment
works). Costs for all privately owned treatment works are therefore estimated to be $0.4 million,
based on 1,029 privately owned treatment works estimated to practice land application.
4.3.2.4 Federally Owned Treatment Works
As for privately owned treatment works, little is known about federally owned treatment
works. EPA estimates, based on permit information, that there are 248 federally owned
treatment works, nearly all of which process less than 1 MOD. The distribution of use or
disposal practice is assumed to follow a pattern similar to that for privately owned facilities, and
thus 21.3 percent or 53 federally owned treatment works are estimated to land apply sewage
sludge. EPA furthermore assumes that sewage sludge quality and other factors will be similar to
those associated with POTWs in the NSSS that process less than 1 MOD of wastewater. The
per-POTW costs of $426 for the NSSS POTWs are expected to be a reasonable estimate of
impact on federally owned treatment works. Thus, EPA estimates that costs for the 53 federally
owned treatment works assumed to land apply sewage sludge will incur costs of $0.02 million per
year to comply with Part 503.
4-83
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4.3.2.5 Domestic Septage Haulers
EPA estimates, based on state data (ERG, 1989), that 28 percent of all domestic scptagc
haulers, or 4,760 pumpers, land apply domestic scptagc. These domestic septage haulers are
required to meet less elaborate requirements for complying with Part 503 than those for sewage
treatment works. As discussed in Section 4.1.1, land-applying domestic scptagc haulers have six
major requirements:
• Meet general requirements.
• Meet annual application rates calculated in gallons per acre per year.
• Meet management practice requirements.
• Meet pathogen or vector attraction reduction requirements.
• Monitor for pH (if pH adjustment is used)
• Keep records on each site.
The following discussion addresses all five major cost items.
General Requirements
All domestic septage haulers arc expected to land apply domestic septage themselves on
land they themselves own, thus no information transfers arc estimated to be needed.
Additionally, domestic septage is not subject to cumulative limits, so paragraphs relating to
notification of the permitting authority do not apply. No costs arc expected to be incurred for
General Requirements.
4-84
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Annual Application Rates
The equation for determining annual application rate allows for typical annual amounts
of septage to be applied to typical types of crops or vegetation. A typical nitrogen need for
many feed crops is about 100 Ibs/acre/year, which would yield an annual application rate of
nearly 40,000 gallons'of septage per year to be applied per acre. Additionally, where annually
application rates are currently higher than this rate, septage haulers are assumed to be able to
select a crop or vegetation to grow on the site that requires a higher than average amount of
nitrogen. EPA estimates that there are no significant impacts associated with this requirement.
Management Practice Requirements
As for POTWs, domestic septage haulers have in the past been required to meet 40
CFR Part 257 management requirements. Since the majority of the Part 503 management
practice requirements are consistent with previous Part 257 requirements, EPA believes that
impacts from management practice requirements on domestic septage haulers will be minimal.
Pathogen and Vector Attraction Reduction
Domestic septage haulers will have to meet pathogen and vector attraction requirements
by one of several means: either by adding alkali (lime) or by injecting or incorporating domestic
septage into the soil. Public access restrictions and harvesting restrictions must also be
implemented. By offering domestic septage haulers these choices, Part 503 basically echoes Part
257, which states that "periodic application of cover material or other techniques, as
appropriate," must be used to control vectors. Since it is not practical to apply cover material at
a land application site, most domestic septage haulers have probably adopted injection or
incorporation to meet Part 257. EPA believes there are no "other techniques" beyond alkali
addition, injection, or incorporation that would meet the vector control requirements of Part
257.
4-85
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To control exposure to pathogens, Part 257 also requires domestic septage to meet either
PSRP or PFRP, or to control public access for 12 months and prohibit for 1 month the grazing
of animals whose products are consumed by humans, if no human food crops are grown. If
human food crops are grown within 18 months, PFRP or PSRP must be met. It is therefore
assumed no domestic septage is applied where food crops are grown within 18 months. It is
unlikely that septage is applied at turf farms, and also unlikely that feed crops are harvested
within 1 month of application, since the application should go on the land before feed crops are
sown. Harvesting would thus take place more than 1 month later.
Based on the foregoing, any domestic septage hauler in compliance with Part 257 should
meet the requirements of Part 503. Therefore, no cost has been assigned to this requirement.
Frequency of Monitoring
Because EPA assumes domestic septage haulers will comply with pathogen and vector
attraction reduction requirements using injection or incorporation and site restrictions, no
monitoring requirements apply.
Recordkeeping
All land-applying domestic septage haulers will be required to keep records of their sites
and of each truckload of domestic septage. The major portion of the recordkeeping
requirements pertains to establishing the site information; thus little additional effort will be
required to maintain or modify the site, information. The effort to set up a record for each site is
small and can be annualized as a one-time cost. EPA assumes small firms operate one 3-acre
site, loading 36,000 gallons per acre per year at this site; medium firms operate two 14-acre sites
at the same loading rate; and large firms operate five 17-acre sites at the same loading rate.
Each site is expected to take 1/2 hour of the owner's time to set up recordkeeping. Total costs
for setup are $29,000 annually (see Table 4-27). Additionally, domestic septage haulers will have
to indicate the date and time domestic septage is applied to each site (the results of monitoring
4-86
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TABLE 4-27
COST OF RECORDKEEPING SETUP FOR DOMESTIC SEPTAGE
HAULERS PRACTICING LAND APPLICATION
Number of
Sites per
Firm
Cost per Site
Total Setup
Note: Setup costs have been annualized at 12 percent for 5 year.
Source: ERG estimates.
4-87
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to certify that the pathogen requirements are met will not be necessary since EPA assumes
domestic septage haulers will meet the pathogen and vector attraction reduction requirements
using site restriction and injection or incorporation). EPA assumes that entering the date and
time into a site log will require no more than 0.5 minutes of a pumper's time ($20 for a truck
driver for the largest firms, $25-$28 for an owner at smaller firms) on a per-truckload basis.
Based on the 956,998 tankloads estimated in Table 4-28, EPA estimates that the cost of
recordkeeping will be about $0.2 million per year for recordkeeping of all tankloads and $0.2
million per year for all domestic septage haulers land applying domestic septage.
Total Costs of Part 503 to Land-Applying Domestic Septage Haulers
The total costs to land-applying domestic septage haulers is estimated to be just the cost
of recordkeeping—$0.2 million annually (see Table 4-29). The average cost to any one treatment
works ranges from $19 to $157.
4.3.2.6 Total Costs for Part 503 Subpart B, Land Application of Sewage Sludge
Table 4-30 presents the total costs for all treatment works and septage haulers to comply
with the Part 503, Subpart B, regulation. Roughly $14.2 million will be incurred annually, with
only about 16 percent of these costs incurred by the smallest treatment works, which also make
up the vast majority of the treatment works affected by the regulation. This $14.2 million
excludes the $0.5 million for meeting Class A requirements and reading and interpreting the
regulation. Approximately 2 percent of total costs are associated with domestic septage haulers.
About $13.4 million in incremental costs (or 95 percent) of total costs, are associated with
POTWs. The impact on domestic septage haulers is investigated in more detail in Section Five,
which covers the regulatory flexibility analysis.
4-8
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4-89
-------
TABLE 4-29
TOTAL COSTS OF PART 503 FOR LAND APPLYING DOMESTIC SEPTAGE
Size Class
Largo
Medium
Small
Total
Number of Firms
238
1,428
3.094
4.760
Total Costs
$37,443
129,856
59.695
$226,994
Average Cost per
Firm
$157
91
19
$48
Source: ERG estimates.
4-90
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4.4 SURFACE DISPOSAL
4.4.1 Overview of the Regulatory Requirements of Part 503, Subpart C
Part 503. Subpart C. covers all sewage sludge and domestic scptagc disposed in surface
impoundments, monofills. piles, or other land-based disposal not meeting the requirements of
Subpart B or excluded from coverage in Subpart A. This practice also includes dedicated sites
on which sludge is spread for disposal and not for beneficial use (dedicated-site surface
disposal). In the NSSS. respondents practicing dedicated-site surface disposal identified
themselves as practicing "dedicated land application."
Storage of sewage sludge is not covered by Part 503. If a treatment works needs to store
sewage sludge for more than 2 years, the treatment works must retain information and a
rationale for why more than 2 years are required for storage. Treatment of sewage sludge is
also not covered by Subpart C, so many lagoons arc not covered by this subpart; most arc used
for aeration or other treatment. The seven types of requirements that must be met by
treatment works practicing surface disposal are general requirements, pollutant limits,
management practices, operational standards for pathogen and vector attraction reduction,
monitoring requirements, rccordkceping requirements, and reporting requirements. These
requirements arc discussed in the sections below.
4.4.1.1 Overview of the General Requirements
The general requirements cover siting of surface disposal units and closure plans. Active
sewage sludge units must be properly sited. Units located within 60 meters of a fault or a stress
fracture that has displacement in Holoccnc time, located within unstable areas, or located in a
wetland, except as provided by a Clean Water Act Section 404 permit, must be closed, unless, in
the esc of location near a fault, as otherwise allowed by the permitting authority.
Closure plans for active sewage sludge units are required 180 days before the unit closes.
These plans must include a discussion of the Icachatc collection system and the methane
4-92
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monitoring system to be used over a 3-year post-closure period. Descriptions of how public
access will be restricted for 3 years must also be presented. Finally, written notification must be
provided to the subsequent owner of the site that sewage sludge was placed on the site.
4,4.1.2 Overview of Pollutant Limits
Pollutant limits are set for unlined surface disposal units (units with liners and leachate
collection systems are not covered by pollutant limits).
The pollutant limits for unlined surface disposal units are specified for three cases: a basic
case, a case where the unit is less than 150 ft from the property boundary, and a site-specific
case. Pollutant limits for the basic case, which is used for an unlined unit where the property
line is more than 150 ft from the unit, are presented in Table 4-31. Each pollutant in the
sewage sludge measured in mg/kg dry weight must not exceed the limit shown in Table 4-31 for
that pollutant.
Table 4-32 presents the limits in the case where unlined sewage sludge units are located
less than 150 feet from the property boundary. These limits are, predictably, more stringent
than those for sites with more generous buffer zones.
Finally, in the site-specific case, any unlined treatment works can elect, with approval from
the permitting authority, to provide site-specific information. This information would then be
used to develop site-specific pollutant limits using a pathway risk analysis. All site-specific
pollutant limits must be either equal to or greater than the pollutant limits shown in Tables 4-
31, or equal to the existing concentration in the sewage sludge, whichever is more stringent.
4.4.1.3 Overview of Management Practices Requirements
Active sewage sludge units must not adversely affect threatened or endangered species and
must not restrict the flow of a base flood. In addition, those units located in seismic zones must
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TABLE 4-31
POLLUTANT LIMITS FOR SURFACE DISPOSAL
SEWAGE SLUDGE UNITS WITHOUT A LINER
(milligrams per kilogram)"
Pollutant
Arsenic
Chromium
Nickel
Pollutant Limit
73
600
420
"Dry-weight basis.
Source: 40 CFR Part 503 Regulation, Suhpart C.
4-94
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TABLE 4-32
POLLUTANT CONCENTRATION LIMITS—UNIT BOUNDARY TO
PROPERTY LINE DISTANCE EQUAL TO OR LESS THAN 150 METERS
Unit Boundary to Property
Line Distance (meters)
0 to less than 25
25 to less than 50
50 to less than 75
75 to less than 100
100 to less than 125
125 to less than 150
Pollutant Concentration8
(mg/kg)
Arsenic
30
34
39
46
53
62
Chromium
200
220
260
300
360
450
Nickel
210
240
270
320
390
420
"Dry-weight basis.
Source: 40 CFR Part 503 Regulation, Subpart C.
4-95
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be designed to withstand the maximum recorded ground-level acceleration and must also be
located 60 meters or more from a fault or stress fracture that has had displacement in Holocene
time (unless the permitting authority allows the location near a fault under these circumstances).
Furthermore, active sewage sludge units must be located where the soil can adequately support
the structure of the unit; i.e., where the walls of monofills and impoundments arc not likely to
collapse because of the type of soil in which they are constructed. Location in wetlands is also
prohibited without a Clean Water Act Section 402 or 404 permit.
Pollution controls are mandated by management practices. First, runoff from 24-hour
storms with a probability of occurring once every 25 years must be controlled. Additionally, if
the unit has a liner and leachate collection system, Icachatc must be collected and properly
disposed of during the active life of the unit as well as for 3 years after closure. Limits on
methane concentrations in structures and at the property line during a unit's active life must be
monitored if daily or other cover is used on the active unit. Monitoring must be performed for
3 years after closure at units with a final cover.
The management practices section also contains restrictions on growing crops, including
fiber crops, and grazing animals on any sewage sludge units. These activities are only allowed if
the owner/operator of the site demonstrates to the permitting authority that public health and
the environment are protected when these activities arc undertaken. Access restrictions arc also
mandated. Ground-water contamination as a result of the sewage sludge disposal activity is
prohibited (which entails only nitrate contamination, since the pollutant limits control all other
possible pollutants). Either a ground-water monitoring program or a certification by a qualified
ground-water scientist that contamination is not likely to occur, based on, for example, soil type,
depth to ground water, or presence of a liner and leachate collection system, must be used to
show that the prohibition is met.
4.4.1.4 Overview of Pathogen and Vector Attraction Reduction Requirements
All sewage sludge units, regardless of type, must meet Class B pathogen requirements at a
minimum, or must be covered daily with soil or other material. Class B pathogen requirements
4-96
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are discussed in Section 4.3.1.4. Treatment works can choose to meet the vector attraction
reduction requirements outlined in Section 4.3.1.4 or may use daily cover to control vectors.
Domestic septage can be injected, treated with alkali to raise pH, or covered daily with soil or
other material to meet vector attraction reduction requirements.
4.4.1.5 Overview of Frequency Monitoring Requirements
All surface-disposal treatment works will have to. monitor pollutant concentrations and
pathogen and vector attraction reductions. Additionally, if daily cover is used, surface disposers
must continuously monitor the air in all structures within the surface-disposal site and at the
boundary for methane gas. The frequency of monitoring is determined by the annual amount of
sewage sludge disposed. Treatment works disposing 0 to less than 290 dmt of sewage sludge
annually must test once per year; those disposing 290 to less than 1,500 dmt must test once per
quarter; those disposing 1,500 to less than 15,000 dmt must test once per 60 days (6 times per
year); and those disposing 15,000 dmt or more must test once per month. After 2 years the
Agency can modify the minimum monitoring frequency for pollutant concentrations and certain
Class A tests for viable helminth ova and enteric viruses.
Domestic septage requires monitoring only if pH adjustment is chosen to meet vector
attraction reduction requirements. Each container of domestic septage to which alkali has been
added must be tested for pH before it is disposed to ensure that vector attraction reduction
requirements are met.
The air in all structures within a surface-disposal site and at the property boundary must be
monitored continuously for methane gas at any site where daily or other cover is used on an
active unit and for 3 years at any sites where a final cover is placed on a unit.
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4.4.1.6 Overview of Recordkeeping Requirements
The following types of records must he maintained for 5 years by all treatment works
practicing surface disposal: the concentrations of all pollutants listed in Table 4-31;
certifications that pathogen and vector attraction reduction requirements arc met; and
descriptions of how pathogen and vector attraction reduction requirements arc met when the
vector attraction reduction requirements do not include injection, incorporation, or a daily
cover. The owner/operator of the site must also keep: records on the pollutant concentrations
when property boundaries are less than 150 feet from the site or when site-specific limits have
been developed; certifications that management practice requirements have been met;
descriptions of these management practices: certifications that vector attraction reduction
requirements have been met if injection, incorporation, or daily cover has been used to meet
these requirements: and descriptions of these vector attraction reduction procedures.
Domestic septage haulers that use pH adjustment to meet vector attraction reduction
requirements must certify and describe the procedure. The owner/operator of the site where
domestic septage is disposed must ccrtiry and describe management practices and vector
attraction reduction methods used if injection, incorporation, or daily cover is relied on to meet
these requirements.
4.4.1.7 Oven'iew of Reporting Requirements
Once per year certain treatment works must report the information required in the
rccordkceping section. These treatment works include all POTWs treating 1 MOD of
wastcwatcr or more and Class I treatment works, which arc those required to have pretrcatment
programs (they process more than 5 MOD of wastewater), those that serve industries required
by states responsible for pretreatment programs to pretrcat their effluent, or those that have
been designated as Class I based on the potential for the treatment works's sewage sludge use
or disposal practice to adversely affect public health and the environment.
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4.4.2 Compliance Cost Analysis
As for the other subparts, five types of treatment works are analyzed: POTWs practicing
secondary or advanced treatment, POTWs practicing primary treatment, privately owned
treatment works, federally owned treatment works, and domestic septage haulers.
4.4.2.1 Compliance Costs for Secondary or Advanced Treatment POTWs Practicing
Surface Disposal
EPA estimates that 1,936 surface-disposing POTWs practice secondary or advanced
treatment. Of these, 3 (less than 1 percent) process greater than 100 MOD of wastewater
(Reported Flow Rate Group 1), 42 (2 percent) process between 10 and 100 MOD (Reported
Flow Rate Group 2), 616 (32 percent) process between 1 and 10 MGD (Reported Flow Rate
Group 3), and 1,275 (66 percent) process less than 1 MGD (Reported Flow Rate Group 4). The
types of surface disposers and numbers of treatment works practicing each type by size are shown
in Table 4-33. Included in these numbers are 301 POTWs that are estimated to store their
sewage sludge for more than 2 years and that might not have a sufficient rationale for'this
extended storage period/
As the table shows, the numbers of treatment works using each type of surface disposal
are distributed among monofills (25 percent), other surface disposal (46 percent), and dedicated-
site surface disposal (29 percent). In the discussion that follows, these groups have been divided
All POTWs storing for more than 5 years were assumed to have no reasonable rationale
None of the survey POTWs storing for 2 to 5 years are expected to be classified as surface
d,sposers however. Among survey POTWs noting storage for 2 to 5 years, nearl^aUmSice
land applicauon. EPA assumes that all of these land application POTWs will have a suffic ent
rationale; for example, they typically store for 1 to 2 years, but in the survey yea^d stored^ their
sewage sludge longer because of poor weather. Additionally, for some of tLse POTW a more
extensive storage period may be their means of meeting pathogen requirements Under'thiT
scenario, then- storage would be considered a treatment process. Two POW pracSg
wdisposal noted storage for more than two years. These POTWs are not counted a ufface
disposers but are assumed to be given sufficient incentive to remove their sewage sludge from
storage a little more frequently. The impact of more frequent disposal at these POIWs and
others they represent ,s discussed under Cost Estimates for Other Requirements.
4-99
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4-100
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into dedicated-site surface disposers (with 563 treatment works, or 29 percent of all surface
disposers) and monofill and other surface disposal treatment works (1,373 treatment works, or 71
percent of all surface disposers).
The compliance cost analysis consists of the same five parts used in the land application
analysis: a pass/fail analysis; a compliance strategy analysis; a compliance strategy cost analysis;
an incremental cost analysis for general, management practice, pathogen and vector attraction
reduction, monitoring, recordkeeping, and reporting requirements; and a summation of all costs.
Pass/Fail Analysis
Pass/Fail Methodology. In the first step of the analysis, EPA divided surface disposers
into two groups: dedicated-site surface disposers and monofill and other surface disposers. For
the dedicated-site treatment works, EPA assumed that if they could meet Subpart B
requirements, they would choose to be permitted as land appliers because Subpart B has
relatively fewer requirements compared with Subpart C. Those which either could not meet
cumulative limits over a 20-year site life or exceeded agronomic rates were assumed to choose to
be permitted as surface disposers. Only these latter dedicated-site surface disposers were
analyzed to determine pass/fail with respect to the surface disposal pollutant limits.
Next, EPA determined which pollutant limits applied to the treatment works remaining
classified as surface disposal. The basic requirements for compliance as outlined in Section 4.4.1
above call for all POTWs practicing surface disposal at unlined sites to meet various pollutant
limits, depending on the type of case into which the unit is classified, (i.e., distance to property
boundary).
EPA made several simplifying assumptions about the case. First, EPA assumed that all
treatment works would have boundaries equal to or greater than 150 ft from the disposal unit,
since this distance is considered to be a reasonable worst-case assumption. EPA further assumed
that only treatment works failing to meet the relevant pollutant limits would request site-specific limits.
4-101
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In the next step of the analysis, the pollutant limits were found to be appropriate for all
units (i.e., that all units arc unlincd). We determined from the NSSS that no monofills practice
leachate collection, although some arc lined. Because both liners and leachate collection
systems must be present for a site to be considered lined, all monofills were considered unlined.
We had no information from the NSSS on whether units other than monofills practice leachate
collection, so we assumed that none of these units were lined. Sewage sludge quality data for
all remaining surface disposal treatment works in the analytical portion of the NSSS were
therefore compared to the pollutant limits listed in Table 4-31. Sewage sludge for which any
one pollutant exceeded the pollutant limits for that pollutant was identified as "failing."
If any sewage sludge failed to meet the surface disposal pollutant limits, we assumed that
site-specific limits must be developed. Site-specific pollutant limits for the critical pollutants at
failing treatment works were generated by Abt Associates.
Pass/Fail Results. Eleven treatment works in the NSSS analytical survey are dedicated-
site surface disposers. These treatment works represent 563 treatment works nationwide. Of
these, three treatment works (POTWs 016, 400, and 224) cannot meet Subpart B requirements
at their current application rates or would not have a 20-year site life (see Table 4-34). These
three POTWs, representing 37 treatment works, are assumed to remain as surface disposers.
Therefore, a total of 526 dedicated-site treatment works out of a total 563 (93 percent) are
expected to be permitted as land applicrs under Subpart B, leaving only 1,410 treatment works
considered to practice surface disposal (37 dedicated-site surface disposers and 1,373 monofill
and other surface disposers). These remaining 1,410 treatment works arc the focus of the
following discussion.
Based on the foregoing, 24 survey POTWs were identified as either practicing
monofilling or other surface disposal or were dedicated-site surface disposers that were
estimated to be permitted as surface disposers. Twenty-one meet the pollutant limits
(representing 1,402 treatment works). Three survey treatment works (POTWs 097, 317, 232),
representing eight treatment works, arc estimated to be unable to meet the pollutant limits for
chromium (sec Table 4-35). The eight treatment works nationwide that are estimated to fail to
4-102
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TABLE 4-35
PASS/FAIL ANALYSIS OF SLUDGE SECONDARY OR
ADVANCED TREATMENT WORKS PRACTICING SURFACE DISPOSAL
1 POTVV
1 016
317
1 097
1 234
410
156
381
1232
400
432
224
353
235
315
434
1 065
| 089
I 227
| 340
1 398
414
423
451
463
Reported Flow
Rate Group
1
1
1
2
2
2
2
2
2
2
3
3
3
3
3
3
4
4
4
4
4
4
4
4
End Use
Dedicated Site
Monofill
Other
Other
Monofill
Monofill
Monofill
Other
Dedicated Site
Other
Dedicated Site
Other
Other
Monofill
Monofill
Monofill
Monofill
Other
Other
Other
Monofill
Other
Other
Other
Number of POTWs
Represented
1
1
1
6
6
6
6
6
6
6
30
30
30
30
30
135
135
135
135
135
135
135
135
135
POTW
Pass/Fail"
Pass
Fail (Chromium)
Fail (Chromium)
Pass
Pass
Pass
Pass
Fail (Chromium)
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Note: Reported Flow Rate Group 1 = >100 MGD; Reported Flow Group 2 = >10-100 MOD;
Reported Flow Rate Group 3 = > 1-10 MGD; and Reported Flow Rate Group 4 = <1MGD.
Source: ERG estimates and 1988 National Sewage Sludge Survey, EPA.
4-104
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meet the pollutant limits and that are expected to continue to practice surface disposal are
assumed to perform site-specific analyses.
Based on pathway risk analyses performed by Abt Associates for cadmium and chromium
at the three failing NSSS treatment works, site-specific pollutant limits were generated (see Table
4-36). EPA determined that none of these treatment works fails site-specific pollutant limits and
that the relevant limit is the existing concentration of chromium in the sewage sludge at these
POTWs. Therefore no POTW disposing of sewage sludge in surface disposal units is estimated
to fail pollutant limits.
Cost Estimates for Compliance Strategies
EPA has estimated that all failing treatment works will be able to pass site-specific
pollutant limits. The costs of compliance strategies are thus limited to the costs of gathering and
submitting site-specific data to the permitting authority. Site-specific information primarily
includes concentration of pollutants in sewage sludge, depth to ground water, and permeability of
soil. Data on depth to ground water and permeability of the soil are assumed to be required as
part of state permit information and thus should require no collection effort. EPA expects to
use tables generated by model runs that vary ground-water depth and permeability and will select
appropriate site-specific pollutant limits based on these data. Submitting the information to the
permitting authority is expected to require minimal time and thus no cost is assigned to this task.
The cost for the dedicated-site surface-disposing treatment works to be classified as land-
applying treatment works is expected to be zero (costs for applying for permits are covered in the
Information Collection Request for 40 CFR Part 503). These treatment works are assumed to
meet pathogen and vector attraction reduction requirements and management practices, because
they were formerly required to meet 40 CFR Part 257. Only general requirement, monitoring,
recordkeeping, and reporting costs will be incurred. These costs will be discussed in the section
below, along with the costs to other surface disposers (i.e., those using monofills, sewage sludge
impoundments, etc.) with the costs of the remaining surface disposers to meet these
requirements.
4-105
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TABLE 4-36
RESULTS OF RISK-BASED PATHWAY ANALYSES FOR SECONDARY OR ADVANCED
TREATMENT WORKS THAT FAIL POLLUTANT LIMITS FOR SURFACE DISPOSAL:
SITE-SPECIFIC LIMITS ON CHROMIUM
(mg/kg dry weight)
POTW
097
317
232
Reported
Flow Rate
Group
1
1
2
Sewage Sludge
Chromium
Concentration
1,895.0
1,010.0
752.5
Site-Specific
Chromium
Limit3
1,895.0
1,010.0
752.5
Site-Specific
Pass/Fail
Pass
Pass
Pass
Number of
POTWs
Represented
1
1
6
"The limit calculated was "unlimited" so the existing concentration in the sewage
sludge becomes the limit.
Note: Reported Flow Rate Group 1 = >100 MOD; Reported Flow Rate Group 2 = > 10-100
MGD; Reported Flow Rate Group 3 = >1-10 MOD; and Reported Flow Rate Group
4 = <] MGD.
Source: Abt Associates, site-specific model runs.
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Cost Estimates for Other Requirements
Applicability. As discussed in the footnote at the beginning of Section 4.4.2.1, two
survey POTWs (POTW 206 and 341) store sewage sludge for more than 2 years and may not
have an adequate rationale for this storage. EPA assumes that these two POTWs may therefore
codispose more sludge annually than they currently do, adding more costs to their annual
disposal costs. EPA further assumes that their costs will increase 10 percent per year because of
this requirement. This cost increase takes into account disposal costs transferred from the
future into the present. According to the NSSS, POTW 206 spent $118,367 disposing of 10,096
dmt of sewage sludge. A 10 percent increase would add $11,837 to the POTW's annual cost of
disposal. POTW 341 disposes of 10 dmt of sewage sludge at a total cost of $3,456. A 10
percent increase will add $346 to this POTW's costs. Each POTW represents 30 POTWs
nationwide. Total costs to all represented POTWs are estimated to be $365,490.
Costs for other POTWs storing sewage sludge for more than two years are as follows:
POTWs that need to store their sewage sludge for more than 2 years will need to write a
justification for this extended storage period and file this in their records. A total of 42 POTWs
that store for 2 to 5 years are expected to need justifications, based on NSSS data and EPA
assumptions about the likelihood of POTWs having valid reasons for the extended storage
period (see footnote in Section 4.4.2.1). We assume 4 hours of management time and 2 hours
of clerical time for a total cost of $200 per POTW. The cost of retaining this information is
negligible. Total first-year costs for this task are thus $8,400. On an annual basis, this cost is
$855. Total applicability costs are thus $366,345.
General Requirements. Locational issues (Clause [b]) are not considered a problem (i.e.,
treatment works are most likely not located in wetlands without a permit, in fault zones, or in
unstable areas), since other state or federal regulations apply in some cases, and good
engineering practices tend to limit poor location.
Clause (c) requirements specify a written closure plan. Some monofills and other surface
disposal units might already have written closure plans. Additionally, this activity (writing of
closure plans) takes place in the future (i.e., only at the time the active surface disposal unit
4-107
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closes), and thus these costs could be deferred for a considerable period of time). The NSSS
reports the time to closure on a few monofills, but we do not have any information on other
types of treatment works. EPA assumes that an equal number of surface disposal units make
their closure plans in each of 20 years (i.e., one-twentieth close in year 1, one-twentieth close in
year 2, etc.). Liners and leachate collection do not appear to be used currently at any NSSS
POTW. Furthermore, no POTWs are expected to add liners and leachate collection, so the
closure plans will not have to discuss these issues. The closure plans will have to discuss only
methane gas monitoring and public access restrictions over the 3-year post-closure period.
Closure plans are estimated to require 8 hours of a manager's time and 4 hours of clerical time
to develop ($400 per treatment works), addressing both methane monitoring and public access
restriction (which is the case at 1,410 POTWs since all monofills and other surface disposal units
are assumed to have a final cover). If public access restriction is the only issue to be addressed
(i.e., at POTWs practicing dedicated-site surface disposal [in which case no final cover is used]),
only 1 hour of a manager's time and 2 hours of clerical time are anticipated, or $80 per
treatment works (526 POTWs). The total one-time cost to all treatment works would be
$606,080. However, since one-twentieth of the treatment works are expected to write closure
plans each year, the annual cost of writing closure plans is expected to be $30,304.
For dedicated-site surface disposers who are permitted as land appliers, costs of meeting
notice and information requirements under Subpart B are not incurred or are very minimal, since
all dedicated-site treatment works are assumed to apply sewage sludge themselves to land they
own.
Total annual costs for all general requirements are thus estimated to be $30,304 per year.
Management Practices. Management practices prohibit the placement of sewage sludge if
it is likely to adversely affect or if it interferes with a threatened or endangered species or a base
flood (clauses [a] and [b]. These management practices are covered in Part 257.301 and 257.303.
Interfering with a base flood is determined to be a specific item covered by the general
prohibition in Part 257 against allowing sewage sludge to enter surface waters. Thus, these
clauses are expected to have no incremental impacts on POTWs.
4-108
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Clauses (c), (d), and (e) (siting requirements regarding seismic zones and soil stability)
are considered good engineering practices and are estimated to have a negligible impact on
costs. Clause (f), forbidding location in wetlands without a permit, is covered by Sections 402
and 404 of the Clean Water Act (sewage sludge is construed to be fill material), thus no impacts
are assigned to Part 503 for this requirement.
Clause (g) (runoff collection) is estimated to have minimal impact. EPA believes that
slope restrictions and other factors either mandated by states or embodied in good engineering
practices should limit the need to collect runoff or may require runoff collection already.
Furthermore, the surface water provisions of Part 257, which prohibit sewage sludge from
entering surface water, apply as well.
Collecting and disposing of leachate (Clauses [h] and [i]) through the active life of the
unit is assumed not to apply, since no treatment works currently have a leachate collection
system and EPA estimates no treatment works will need to install leachate collection systems.
Therefore, no cost is associated with this clause, nor with Clause (i), which requires leachate
collection systems to be operated and maintained for 3 years following closure of the unit.
Clause (j), which requires that if a final cover is used, methane gas must be monitored, is
also covered in Part 257. The terminology in Part 503 is consistent with the terminology in Part
257. The fact that no surface disposal units currently monitor for methane does not mean that
methane monitoring costs should be attributable to Part 503. Also, methane monitoring is
required for 3 years following closure. Part 257 does not specifically require methane
monitoring after closure, but the requirement to meet methane limits is not constrained to
active units. Thus, the requirement to monitor methane for 3 years following closure is assumed
to be inherent in Part 257 requirements, which appear to require methane monitoring
indefinitely.
Most surface disposal units are not used to grow crops or graze animals; we assume
minimal impacts from Clauses (k) and (1), which limit food and feed crops and grazing of
animals on surface disposal units. For dedicated-site surface disposers (i.e., those that are not
estimated to become permitted as land appliers, represented by three treatment works in the
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NSSS), only one appears likely to be growing a crop, based on the respo'nse to the question
about basing application rates on the nitrogen needs of a crop. This treatment works (POTW
224) represents 30 treatment works nationwide. Because the treatment works applies sewage
sludge at a reasonable agronomic rate (based on the nitrogen needs of the crop grown on the
site, according to the NSSS), and because a site-specific pathway risk analysis is very likely to
show that public health and the environment would not be affected by this practice. EPA
assumes that this activity would be allowed by the permitting authority. Any cost to continue this
activity is estimated to be negligible.
Clause (m) specifies public access restrictions. Public access restrictions are covered in
Part 257.308 and, thus, Part 503 will have no cost impacts associated with public access
restrictions.
Clause (n) involves procedures that must be undertaken to prove that the surface disposal
unit is not contaminating an aquifer. EPA assumes that geologists would be unlikely to certify
that an unlincd surface disposal site would not contaminate an aquifer and, therefore, all POTWs
are assumed to monitor the ground water under their surface disposal sites.
Three major components of ground-water monitoring costs are: developing the ground-
water monitoring plan, implementing the plan (e.g., installing monitoring wells), and performing
ground-water sampling. The development of the ground-water monitoring plan is estimated to
require 60 hours of a ground-water specialist's time at $60 per hour, for a total of $3,600 per site
(one-time cost), or $367 per year on an annual basis. The activities undertaken include siting
wells, overseeing the drilling contractor, sampling for initial assessment of ground-water quality,
developing a sampling program, developing a ground-water monitoring implementation schedule,
and writing a monitoring plan report.
Implementing the ground-water program requires that four monitoring wells be drilled.
EPA estimates that four 6-inch monitoring wells, PVC-lined and 60 feet in depth, are adequate
for the purposes of monitoring ground water. Based on information in Ground Water Age
(1990), costs for PVC-lined monitoring wells averaged $20.77 per foot to install. When updated
4-110
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to 1992, these-costs are estimated to be $22 per foot, or $1,320 per well and $5,280 per site, or
$530 per year on an annual basis.
Sampling and testing are assumed to occur on a semi-annual basis. Nitrate monitoring is
a very simple procedure. No complex sampling procedure must be followed, and a bailer can be
used. Test kits for nitrate testing in the field are available. One source was contacted (personal
communication between ERG and Hach, Inc., Loveland, CO, May 15, 1992), which provides a
nitrate test kit for $77. This test kit can be used for 100 samples. Assuming one sample at four
wells per monitoring episode, the cost of testing is estimated to be $3, or $6 annually per site,
assuming semi-annual testing. The sampling and testing procedure is expected to take no more
than 3 hours (which includes time to check ground-water elevations, take the sample, add the
reagent, dissolve the reagent, match the color to the chart, record the result, and file all results).
Thus sampling and testing costs are expected to be $186 per year.
Total costs for ground-water monitoring at each surface disposal site are expected to be
$1,083, based on the foregoing. A total of 1,410 POTWs will be continuing to surface dispose
their sewage sludge. Three survey POTWs, representing 8 POTWs nationally, currently monitor
their ground water. Because they may not now monitor nitrates, EPA assumes they will incur
all but the cost of installing wells for a cost of $553 annually, or $4,424 for the entire group.
The remaining 1,402 POTWs will need to install wells and will incur the full cost of $1,083 per
POTW, or $1,518,366 for all these POTWs. Total costs for ground-water monitoring are thus
$1.5 million.
For dedicated-site surface disposers that are permitted as land appliers, incremental
management practice costs are expected to be negligible because these practices are consistent
with current land application practices, as discussed in Section 4.3, and because these treatment
works have considered themselves land appliers.
Based on ground-water monitoring costs, total incremental annual costs for all
management practice requirements are estimated to be $1.5 million.
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Pathogen and Vector Attraction Reduction Requirements. Pathogen and vector attraction
reduction requirements are a cost consideration for many surface disposers, except for the
dedicated-site surface disposers not permitted as land appliers, who have been required to meet
PSRP. EPA studied the existing treatment processes described by the NSSS analytical survey
POTWs that practice surface disposal. Many use lime treatment processes, sand drying beds, or
other processes estimated to achieve Class B requirements, or use daily cover. A few POTWs (9
survey POTWs, representing 355 POTWs nationally) did not appear to have treatment processes
likely to achieve Class B requirements. Two of these POTWs (representing 141 nationwide)
dispose of sewage sludge in uncovered monofills. These POTWs are expected to use daily cover
to meet the pathogen and vector attraction requirements at a cost of $0.2 million (see Appendix
B). The remaining 7 survey POTWs (representing 214 nationwide) are assumed to include a
lime stabilization step in their processes to meet Class B requirements. Total costs for both
capital and operations are estimated to be $7.3 million for these POTWs. Lime stabilization,
however, increases the volume of sewage sludge to be disposed. A factor of 34 percent has been
added to the POTWs' current disposal costs to account for the shorter life of the surface disposal
site, caused by additional volumes disposed annually, leading to additional costs of $2.3 million.
Total costs of meeting pathogen and vector attraction reduction requirements are thus estimated
to be $9.6 million annually (see Appendix B for a more detailed description of all of these
analyses).
Frequency of Monitoring. All surface-disposal treatment works will have to monitor for
pollutant concentrations, pathogen and vector attraction reductions, and methane. As reported
in Section 4.2, costs for monitoring pollutant concentrations are expected to cost about $190 per
monitoring episode for metals. EPA assumes all monitoring is incremental to existing practices.
Pathogen and vector attraction reduction monitoring is expected to cost $75 (as discussed in
Section 4.2). Because a continuously recording methane monitor has been assumed to be
required as pan of meeting Part 257, methane monitoring is associated with a negligible cost.
Therefore, the total cost of a monitoring episode is expected to be $265. Costs for the treatment
works that also land apply sewage sludge have already been estimated for monitoring metals,
pathogens, and vector attraction reduction. Table 4-37 presents the 1,274 POTWs that do not
practice land application and for which monitoring costs were not estimated in Section 4.3.2.1.
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The total cost for monitoring sewage sludge among surface disposers who do not also land apply
sewage sludge is $0.5 million per year.
Recordkeeping. Rccordkccping requirements for surface disposers are expected to
generate few costs. Setup is assumed to be associated with negligible costs, since the small cost
incurred would be annualizcd. EPA further assumes that all treatment works own and operate
the surface disposal site, which appears to be r.he case in most instances when this information is
reported in the NSSS. Thus all recordkecping costs are assigned to the POTWs. Each treatment
works will need to record pollutant concentrations certifying that management practices and
pathogen and vector attraction reduction requirements have been met and describing how the
management practices and pathogen and vector attraction reduction requirements were met.
This recordkecping effort is expected to require no more than 1/2 hour of clerical time each
monitoring episode. The total cost of recordkecping for surface disposers is $19,950.
For dedicated-site surface disposers that are permitted as land appliers, land application
recordkecping costs will apply. Four survey POTWs (POTWs 101, 326, 057, and 327),
representing 435 POTWs nationwide, do not meet the pollutant concentration limits. However,
these POTWs will only have to maintain records for one site. All four monitor annually only, so
recordkecping set up is estimated at 1 hour of clerical time, or $20 per POTW (see Section
4.3.2.1). Form set up is estimated at $160 in the first year, for a total first-year cost of $180, or
SI 8 on an annual basis. Recurring costs include $80 per reporting period to update sewage
sludge quality information. EFA assumes these POTWs apply sewage sludge 260 times per year.
Forms recording date and time and application are filled in at this time, requiring about 30
seconds per application, or about 2 hours per year of a technician's time at $30/hour for a total
of $60. Total recurring costs are therefore $140 per POTW. Total annual costs (including the
$18 annual cost for setup) sum to $158 per POTW, or $68,730 for all 435 POTWs represented by
these four survey POTWs.
Four POTWs meet pollutant concentration limits (POTWs 012, 275, 430, and 148). Of
these, POTWs 148 and 012 already practice land application and have costs estimated in Section
4.3.2.1, and therefore are estimated to incur minimal incremental rccordkceping costs. The
4-114
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remainder will incur a $166 one-time cost for forms set up ($16 annually) and an $80 per
monitoring episode cost. Of the remaining two POTWs, POTW 275 monitors once per year, so
total annual costs for this POTW are $96. This POTW represents 30 nationwide; costs for all
are estimated to be $2,880. POTW 430 monitors four times per year, so total annual costs for
this POTW are $336. This POTW represents only itself. Total annual costs nationwide for
POTWs meeting pollutant concentration limits sum to $3,216. Total recordkeeping costs for
dedicated-site surface disposers who are permitted as land appliers are thus $71,946.
Total recordkeeping costs for both surface disposers and former surface disposers are
$91,896.
Reporting. Out of a total of 1,936 surface-disposing or reclassified land-applying
treatment works, 661 are estimated to need to report annually, i.e., they are either Class I
treatment works or they process 1 MGD or more. EPA anticipates that the time needed to
copy, package, and ship the records to EPA should not exceed 1/2 hour of clerical time. Costs
for copying and postage are expected to be minimal. Thus the total cost per year per treatment
works is estimated to be $10, or $6,610 for all Class I surface disposers required to report.
Total Costs of Subpart C for POTWs Practicing Secondary or Advanced Treatment
The total incremental costs for secondary or advanced treatment POTWs to comply with
Subpart C are estimated to be $12.1 million (see Table 4-38). Most of these costs will be
incurred for meeting pathogen and vector attraction requirements ($9.6 million) and
management practices ($1.5 million). The average costs per treatment works range from $3,925
for the smallest treatment works to $96,922 for treatment works processing 10 to 100 MGD of
wastewater.
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4-116
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4.4.2.2 POTWs Practicing Primary Treatment
As noted before, the NSSS is not representative of treatment works practicing primary
treatment. However, EPA undertook an analysis of the 40-City Study, which indicated that for
most regulated pollutants, primary sewage sludge was no worse than secondary sewage sludge for
the pollutants regulated in Subpart C (EPA, 1982). Thus the pass/fail results for primary
treatment works are assumed to be the same as those for secondary and advanced treatment
works.
The costs to primary treatment works are therefore assumed to be the same per-
treatment works costs faced by similarly sized secondary and advanced treatment works. Table 4-
38 shows the average cost per treatment works at secondary or advanced treatment works in each
reported flow group. Costs include those for meeting pathogen and vector attraction monitoring,
recordkeeping and reporting requirements, or a total of $3,925 to $96,922 per treatment works,
depending on size. Based on 273 primary treatment POTWs practicing surface disposal, with 1
primary treatment works with a flow greater than 100 MOD, 7 with flows in the 10 to 100 MGD
range, 31 with flows in the 1 to 10 MGD range, and 234 with flows in the less than 1 MGD
range, EPA estimates the total costs of meeting Subpart C requirements at primary treatment
works to be $1.8 million (see Table 4-39).
4.4.2.3 Privately Owned Treatment Works
The NSSS was not designed to collect information on privately owned treatment works.
EPA believes, however, that there is no reason that sewage sludge from these treatment works
should be worse than that from small (1 MGD or less) POTWs. Based on this assumption, EPA
believes that the average annual costs of compliance, per treatment works, for Reported Flow
Group 4 treatment works will reflect the likely impacts on private treatment works. The average
cost of compliance per treatment works among Reported Flow Group 4 treatment works is
$3,925 annually. A total of 551 privately owned treatment works are estimated to use surface
disposal. Therefore, EPA estimates that $2.2 million will be incurred by these treatment works
on an annual basis.
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TABLE 4-39
ANNUAL INCREMENTAL COSTS TO PRIMARY TREATMENT POTWS OF COMPLYING
WITH PART 503, SUBPART C
Reported Flow Rate Group
> 100 MOD
> 1 0-100 MOD
>1-10 MOD
<1 MOD
Total
Number of
POTWs
1
7
31
234
273
Cost per POTW
$31,603
96,922
4,741
3,925
$6,504
Total Annual
Incremental Costs of
Compliance
$31,603
678,454
146,971
918,450
$1,775,478
Source: ERG estimates.
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4.4.2.4 Federally Owned Treatment Works
As for privately owned treatment works, federally owned treatment works are expected
to have costs similar to those for Reported Flow Group 4 POTWs. Using the average cost of
compliance of $3,925, and an estimate of 28 federally owned surface-disposing treatment works,
EPA estimates that $0.1 million will be incurred annually by these treatment works.
4.4.2.5 Domestic Septage Haulers
EPA estimates, based on state data (ERG, 1989), that 21 percent of all domestic septage
haulers, or 3,570 pumpers, practice landfilling or lagooning. Of these domestic septage haulers,
8 percent are landfilling and 13 percent are lagooning domestic septage. However, domestic
septage lagoons are considered treatment methods, since a major purpose of lagooning is to
stabilize the septage. The sludge that might be dredged from these lagoons would be covered
by Subpart B or C, but this happens so infrequently that incremental costs associated with this
method of disposal have not been estimated. Thus, 1,360 domestic septage haulers that practice
landfilling are expected to be covered by Subpart C. Domestic septage haulers practicing
surface disposal are required to meet less elaborate requirements for complying with Part 503,
Subpart C, than those for sewage treatment works practicing surface disposal.' As discussed in
Section 4.1.1, surface-disposing domestic septage haulers (which are assumed not to store
septage) have five major requirements:
• Meet general requirements.
• Meet management practice requirements.
• Meet vector attraction reduction requirements.
• Meet frequency of monitoring requirements.
• Keep records on each site.
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Additionally, as discussed later in this section, EPA determined that the smallest
domestic scptagc haulers might choose to land apply domestic scptage because costs could be
lower for a shift to land application than those for continuing surface disposal. The costs of this
shift are discussed below as well. These haulers must also meet management practices,
pathogen and vector attraction reduction requirements, and recordkccping requirements
associated with Subpart B. Impacts on small domestic scptagc haulers arc discussed in the
relevant sections below.
General Requirements
Septagc haulers are not expected to have any siting problems, and notifying the
subsequent owner that septage was placed on the land should be associated with negligible costs.
Thus only the requirement to develop closure plans is expected to be associated with costs.
Based on assumptions outlined above concerning closure plans for surface disposal units
operated by POTWs, EPA makes several similar assumptions, i.e., that closure plans will only
have to address methane monitoring and public access restrictions. Closure plans are thus
expected to entail 4 hours of the owner's time and 2 hours of clerical time (assumed to be
provided by a service firm at $20 per hour). No domestic septage haulers expected to shift to
land application will need to develop closure plans, so this requirement pertains to only 476
domestic scptagc haulers. As Table 4-40 indicates, the total annual costs, using the assumption
that average site life is 10 years and 10 percent of all surface disposal sites for domestic septage
close each year, are $7,154.
Management Practice Requirements
As for POTWs, domestic septage haulers have, in the past, been required to meet 40
CFR Part 257 management practice requirements. Since the majority of the Part 503
management practice requirements are consistent with previous Part 257 requirements, EPA
believes that most impacts from management practice requirements on surface-disposing
domestic scptage haulers will be negligible, with the exception of the requirement to monitor
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TABLE 4-40
COST OF CLOSURE PLANS
Size
Class
Large
Medium
Small
Total
Number
of Firms
68
408
-
476
Cost per
Hour
Owner's
Time
$43
25
~
--
Total Cost of
Owner's
Time
(4 hours)
$172
100
-
--
Total Cost
to Firm8
$212
140
-
-
Total
Cost AH
Firms
$14,416
57,120
-
$71,536
Annual
Costb
$1,442
5,712
~
$7,154
"Including clerical cost of $40 per firm.
bAssuming 10-year average site life and one-tenth of all surface-disposing domestic septage
haulers closing a site each year.
Source: ERG estimates.
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ground water. For the domestic scptagc haulers estimated to shift to land application, the
management practice requirements of Subpart B arc also expected to have negligible impact
because of the consistency of these requirements with Part 257. The remainder of this section
focuses on ground-water monitoring costs.
As noted above under the discussion of ground-water monitoring costs for POTWs, 4
monitoring wells, 60 feet in depth arc considered adequate for monitoring ground water. These
wells arc expected to cost $22/ft to install, or $5,280 per firm, assuming one disposal site per
firm. If this cost in annualized at 12 percent over 5 years, each firm is expected to incur costs
for installing wells of $1,465 per year per firm. Annual testing costs, using the same
assumptions as those outlined above for surface-disposing POTWs, arc estimated to be $186 per
year. Developing a ground-water monitoring plan is expected to cost $3,600 per year (see
Section 4.4.2.1), or $999 annually. Total annual costs per firm arc thus calculated to be $2,650.
Total costs for all 476 firms that arc not expected to shift to land application are estimated to
be $1.3 million. The shift to land application is estimated to be more expensive, in general, than
installing ground-water wells (sec next section). However, the situation at individual sites can
vary, and where domestic septagc haulers do not incur a large expense for acquiring land and
where transport distances do not increase substantially, shifting to land application could be less
expensive for some domestic septagc haulers. This is the case for the 884 smallest domestic
scptage haulers.
Shift to Land Application
The most significant factor affecting the cost differences between land application and
surface disposal of domestic scptagc is the amount of land required for the use or disposal of
domestic scptage. EPA has very little data on current practices for surface disposal of domestic
scptagc. The Agency, however, believes that surface disposal is much less land intensive,
possibly by a factor of 10. Thus, to shift to land application, EPA has assumed that a domestic
scptagc hauler must acquire at least 10 times as much land as currently owned, leased, or
otherwise used.
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Since surface disposal of domestic septage is associated with numerous odor problems
(EPA, 1984), it is unlikely that this practice is occurring in heavily settled suburban or even
exurban areas. Surface disposal might, however, occur in areas with highly valuable agricultural
land but where resistance to domestic septage land application is strong. The land might thus
be expensive to buy or lease, and arrangements with farmers to land apply to their land might .
be difficult to make. EPA thus assumes that the surfacing-disposing domestic septage hauler
will have to buy (rather than lease or make other arrangements for) relatively expensive land on
which to land apply septage.
High-quality agricultural land is estimated to cost up to about $1,100 per acre. This
estimate was derived based on data from the U.S. Department of Agriculture (1992) using the
four regions of the United States with the highest value of farmland (not including buildings).
These regions include the Northeast, the Southeast, the "corn belt" states and the Pacific region
(including California). These four regions were selected to generate a reasonable worst-case
estimate of land prices. We assume that all domestic septage haulers select cover vegetation or
crops that allow an annual application rate of about 36,000 gallons per acre per year to be
used.7 The smallest firms will therefore require about 2.5 additional acres (assuming they were
surface disposing 100,000 gallons of domestic septage on 0.25 acres of land). Similarly, medium-
sized firms (handling 1,000,000 gallons annually) are expected to need an additional 25 acres of
land (currently they are estimated to use about 3 acres for surface disposal). Finally, the largest
firms (currently handling 3 million gallons annually are expected to need 75 additional acres.
Costs to the smallest firms for land are thus estimated to be $2,750; for medium-sized firms,
$27,500; and for the largest firms, $82,500.
Added to this cost is the cost of planning the shift to land application. This cost includes
time to investigate land opportunities, negotiate an offer, and obtain a mortgage or other loan.
It also includes legal fees and other closing costs. These planning costs are assumed'to add an
additional 15 percent to the cost of the land. Thus, total costs are expected to be $3,162,
$31,625, or $94,875, depending on the size of the firm.
Application rates could be higher than this; the 36,000 gallon figure ,was selected to be
conservative.
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Because of the different nature of these firms compared to POTWs, they are not
expected to be able to obtain the low 8 percent interest rates typically available to
municipalities. Thus a 10 percent interest rate (for land only) has been assumed over a 20-year
period. Annual costs arc thus estimated to be $366, $3,662, and $10,987 for the smallest to
largest firms. Just on the basis of land costs alone, it is apparent that costs for shifting to land
application for medium and large firms exceed those incurred for remaining as surface disposers
(primarily the cost of monitoring ground water at a cost of $2,560 per firm), thus only the
smallest firms arc considered further in this discussion. Total land costs for the 884 small
domestic scptage haulers expected to shift to land application arc estimated at $0.3 million.
Other incremental costs to the smallest domestic scptage haulers might also apply as
well. EPA looked at potential incremental operating and maintenance costs. These costs
include the incremental costs to transport and spread the domestic septagc to the land.
The small domestic septage haulers should be able to use the same trucks to land apply
domestic septagc that they now use to surface dispose it. These trucks might, however, make
longer trips than they do currently. Lacking any information, EPA investigated mileage
increases of 10 percent, 20 percent, and 30 percent over baseline mileages assumed to be 35
miles roundtrip per day per truck for small firms (sec Appendix D for a detailed description of
this analysis). EPA selected the 20 percent factor to estimate cost increase possibly associated
with increased transport distances involved with a shift to land application. Under this scenario,
costs per domestic septage tank serviced increase $6 for the small firm (see Appendix D).
Based on the approximately 100 septic tanks pumped annually and the 884 domestic scptage
haulers affected, EPA estimates that an additional $0.5 million will be incurred for additional
transportation costs.
Any additional amount of labor time needed to spread domestic septagc rather than
surface disposing it is not expected to be significant since surface disposal requires digging
trenches and covering over the domestic septage, which is a relatively time-consuming process.
In fact, land application of domestic septage might be less labor intensive. The operating costs
of equipment used to dig and cover trenches will also be associated with cost savings once this
equipment is no longer needed. Since so little data arc available, however, potential cost
4-124
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savings were not calculated. Total costs of shifting to land application for small domestic
septage haulers are therefore estimated at $0.9 million annually.
Pathogen and Vector Attraction Reduction
Domestic septage, whether land applied or surface disposed, will not be required to meet
Class B pathogen requirements. Surface disposers can use daily cover to meet vector attraction
reduction requirements; pathogen requirements are not specified. Because daily cover of
domestic septage landfills is standard practice and is required by Part 257 to control vectors, this
requirement is not expected to result in any incremental costs to surface disposers. At a
minimum, land appliers must meet harvesting and public access restrictions for pathogen control
and the septage must be injected or incorporated into the soil for vector attraction reduction.
Domestic septage is already covered by Part 257 for many of these same harvesting and public
access restriction requirements, thus the discussion under the cost estimates for meeting
pathogen and vector attraction reduction requirements of land-applying domestic septage
haulers in Section 4.3.2.1 applies to the domestic haulers that shift from surface disposal to land
application as well. This discussion indicates that these requirements should have negligible
impacts. Additionally, Part 257 requires that a cover "or other technique" be used to minimize
vectors for all land-based solid waste disposal. EPA knows of no "other techniques" for
domestic septage except for injection, incorporation, or pH adjustment that would meet this
existing requirement. Thus no incremental impact from Part 503 is expected.
Frequency of Monitoring
Because surface-disposing domestic septage haulers are expected to use daily cover to
meet pathogen and vector attraction reduction requirements for surface disposal and because
land appliers are expected to use site and harvest restriction and injection or incorporation, pH
adjustment will not be used. Domestic septage must be monitored only if pH adjustment is
used. Thus no costs are incurred as a result of this requirement.
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Recordkeeping
Domestic scptagc haulers will be required to keep records of their sites, as well as of
each truckload of domestic septagc. The major portion of the recordkceping requirements
pertain to the site, and, once established, will require little to no additional effort to maintain or
change, if sites change occasionally. Since the effort to set up a record for each site is minimal
and can be annualizcd as a one-time cost, and since most medium and large domestic septage
haulers most likely have only one or two sites on which they dispose of domestic septage, and
most small domestic septage haulers arc likely to have one land application site, EPA assumes
the site-based recordkceping costs are minimal.
Domestic scptagc haulers will also have to indicate the date and time domestic septage is
disposed at each site. Since pH adjustment is assumed not to be performed, the hauler will not
have to indicate the results of monitoring to certify that the pathogen requirements have been
met. EPA assumes that entering the date and time will require no more than 30 seconds of a
pumper's time on a pcr-tankload basis. Based on an estimated 273,428 tank loads, EPA
estimates that the cost of recordkceping will be about $0.06 million per year for all treatment
works (see Table 4-41).
Total Costs of Part 503 to Surface-Disposing Domestic Septage Haulers
The total costs to surface-disposing domestic scptagc haulers is estimated to be $2.2
million annually (see Table 4-42). The average annual cost to any one treatment works ranges
from $981 to $2,798.
4.4.2.6 Total Costs for Part 503 Subpart C, Surface Disposal
Table 4-43 presents the total costs for all treatment works and firms to comply with the
Part 503, Subpart C, regulation. Approximately $18.3 million will be incurred annually, with
about 57 percent of these costs incurred by the smallest treatment works and firms, which also
4-126
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make up the vast majority of the treatment works affected by the regulation, excluding $0.3
million associated with meeting Subpart A requirements and reading and interpreting the
regulation. A small part of total costs (about 12 percent) is associated with domestic septage
haulers. The larger part, $16.2 million in incremental costs, is associated with POTWs and
privately or federally owned treatment works. The impacts on domestic septage haulers are
investigated in more detail in Section Five, which covers the regulatory flexibility analysis.
4.5 INCINERATION
4.5.1 Overview of the Regulatory Requirements of Part 503, Subpart E
Part 503, Subpart E, covers all sewage sludge incinerated in sewage sludge incinerators,
with the exception of sewage sludge fired in municipal solid waste (MSW) incinerators. The
subpart includes six types of requirements that must be met: general requirements, pollutant
limits, management practices, monitoring requirements, recordkecping requirements, and
reporting requirements. These requirements are discussed in the sections below.
4.5.1.1 Overview of General Requirements
The general requirements dictate that no one shall fire sewage sludge in a sewage sludge
incinerator except in compliance with the requirements in this subpart.
4.5.1.2 Overview of Pollutant Limits
Subpart E regulates the concentration of metal pollutants in sewage sludge that is fired
in a sewage sludge incinerator and the concentration of total hydrocarbons (THC) in the sewage
sludge incinerator stack. The regulated pollutants arc arsenic, cadmium, chromium, lead, nickel,
and THC. The criteria for all metals (except lead) have been developed using a pathway risk
analysis. Lead limits are derived from the existing National Ambient Air Quality Standard
4-130
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(NAAQS) for Lead. The limit for THC is an operational standard, not a risk-based limit,
because a methodology for developing a risk-based approach for THC is not well developed.
These limits are stated as risk-specific concentrations in micrograms per cubic meter, with the
exception of lead and THC. Criteria for mercury and beryllium are incorporated by reference
to the National Emission Standard for Beryllium in Subpart C of 40 CFR Part 61 and the
National Emission Standard for Mercury in Subpart E of 40 CFR Part 61. (Since 40 CFR Part
61 is currently in effect, no impact from mercury or beryllium limits applies to Part 503.)
The risk-specific concentrations or the NAAQS for lead must be used in equations that
take into account the amount of sewage sludge incinerated in dry metric tons per day, the
incineration facility's dispersion factor (the ratio of the increase in ground-level air
concentration at the property line to the mass emission rate for the pollutant from the stack),
and the control efficiency of the incinerator (i.e., how much pollutant is retained in the ash and
the pollution-control system) to determine the allowable concentrations of pollutants in the
sewage sludge. This equation, for the metal pollutants, generally follows the form of:
C = (RSC x 86,400)/(DF x [1-CE] x SF)
where:
C = the average daily concentration of the pollutant in mg/kg dry weight
RSC = the risk-specific concentration specified in Subpart B (or 10 percent of the
NAAQS for lead8)
DF = dispersion factor
CE = the sewage sludge incinerator control efficiency
SF - the sewage sludge feed rate in dmt (measured either as design capacity
actual throughput)
or as
(0.1
to
4-131
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The dispersion factor is calculated using an EPA-approved air dispersion model, which
takes into account such factors as stack height, stack diameter, stack gas temperature, exit
velocity, and surrounding terrain. In most cases, the actual stack height of the incineration
facility is used in the model; if the sewage sludge incinerator stack height exceeds 65 meters,
however, a 65-meter stack height (the creditable stack height) is used in the model. The control
efficiency for each metal pollutant must also he determined. Control efficiency is determined by
undertaking a performance test of the incinerator.
The regulation provides RSC values for arsenic, cadmium, chromium, and nickel.
Optionally, POTW staff may calculate an RSC value for chromium based on the site-specific
value for the percentage of hexavalent chromium to total chromium in the incinerator emissions.
This calculation is:
RSC = 0.0085/r
where:
RSC = site-specific RSC for chromium in micrograms per cubic meter
r = decimal fraction of hexavalent chromium in the total chromium concentration
(measured in hundredths)
Table 4-44 presents the RSC values for arsenic, cadmium, and nickel, along with the standard
RSC values for chromium that depend on type of incinerator and pollution-control equipment
used.
The operational standard for THC requires that THC be measured in the exit gas from
a sewage sludge incinerator stack, corrected for 0 percent moisture and to 7 percent oxygen.
This measured value must then be multiplied by two correction factors calculated using the
following equations for moisture and oxygen:
Correction Factor = 14/(21-Y)
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TABLE 4-44
RISK-SPECIFIC CONCENTRATIONS FOR METALS
Pollutant
Arsenic
Cadmium
Chromium
Fluidized bed with wet scrubber
Fluidized bed with wet scrubber and
wet electrostatic precipitation
Other types with wet scrubber
Other types with wet scrubber and
wet electrostatic precipitator
Nickel
RSC
0.023
0.057
0.65 .
0.23
0.064
0.016
4.0
Source: 40 CFR Part 503, Subpart E.
4-133
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where:
Y = percent oxygen concentration in the stack exit gas (on a dry-volume basis).
Correction Factormoislurc = 1/(1-X)
where:
X = the decimal fraction of the percent moisture in the sewage sludge incinerator exit
gas in hundredths.
The THC concentration calculated in this manner must be equal to or less than 100 parts per
million (volumetric) when measured using a "hot" THC monitor (i.e., the sampling line must be
heated to at least 150°C at all times). This limit is based on a monthly average. Compliance
with the monthly 100 ppm THC emission limit is determined using hourly arithmetic averages
for each hour of the month that the incinerator is in operation. All measurements made within
the hour (a minimum of two measurements) must be used to compute the hourly average.
4.5.1.3 Overview of Management Practice Requirements
The management practices in Subpart E specify that four instruments must be used: an
oxygen monitoring and recording device, a moisture information monitoring and recording
device, a combustion temperature monitoring and recording device, and a THC monitoring and
recording device. The management practices specify that these instruments be installed,
calibrated, operated, and maintained. As noted above, the management practices also specify
that the sampling line to the THC monitor be maintained at a temperature of at least 150°C.
Furthermore, the THC monitor is required to be calibrated using propane at least once every 24
hours. Maximum combustion temperatures and operating parameters for the air pollution
control devices will be specified by the permitting authority, based on information obtained
during the performance testing to determine pollutant efficiencies.
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4.5.1.4 Overview of Frequency of Monitoring Requirements
All POTWs incinerating sewage sludge will have to monitor pollutant concentrations in
their sewage sludge for five metals: arsenic, chromium, cadmium, lead, and nickel. The
permitting authority can specify monitoring frequencies for mercury and beryllium. Combustion
temperature, as well as total hydrocarbons, oxygen concentration, and moisture content in the
exit gas, must be monitored continuously. Additionally, operating parameters for the air
pollution control device must be monitored as specified by the permitting authority. Pathogen
and vector attraction reduction will not have to be monitored. As for the other use or disposal
practices, the frequency of monitoring is determined by the annual amount of sewage sludge
disposed (in this case fired in a sewage sludge incinerator). POTWs incinerating 0 to less than
290 dmt of sewage sludge annually must test once per year; those incinerating 290 to less than
1,500 dmt must test once per quarter; those incinerating 1,500 to less than 15,000 dmt must test
once per 60 days (6 times per year), and those incinerating 15,000 dmt or more must test once
per month. After 2 years, the permitting authority may modify the minimum frequency of
monitoring for pollutants in sewage sludge.
4.5.1.5 Overview of Recordkeeping Requirements
. All the monitoring information required to meet the monitoring requirements outlined
above must be kept for 5 years. This information includes:
Concentrations of arsenic, chromium, cadmium, lead, and nickel in the sewage
sludge fed to the incinerator.
The concentration of THC and oxygen in and information used to measure the
moisture content of the exit gas from the incinerator stack.
Information indicating that beryllium and mercury requirements under 40 CFR
Part 61 are met.
Combustion temperature, including the maximum as set by the permitting
authority.
Operating parameter values for the air pollution control device.
4-135
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• The sewage sludge feed rate for each incinerator.
• The stack height and dispersion factor for the site.
• The control efficiency for lead, arsenic, cadmium, chromium, and nickel.
• The risk-specific concentration for chromium, if calculated.
• A calibration and maintenance log for the combustion temperature monitor,
THC monitor, oxygen monitor, and monitor used to determine moisture content.
4.5.1.6 Overview of Reporting Requirements
Once per year, all POTWs employing sewage sludge incineration must report some of
the information required in the recordkeeping section, since all incinerating POTWs are
designated as Class I by definition. The information required include: pollutant concentration;
THC and oxygen concentrations and moisture data; information on mercury and beryllium;
combustion temperature; and operating parameter values for the air pollution control device.
4.5.2 Compliance Cost Analysis
Only two types of POTWs are analyzed in this section: those practicing secondary or
advanced treatment and those practicing primary treatment. Neither privately nor federally
owned treatment works nor scptagc haulers arc likely to operate onsite incinerators. Privately
owned treatment works may take sewage sludge to POTWs that operate incinerators, however.
Also, domestic septage haulers may take domestic scptagc for further treatment to POTWs
operating incinerators. The potential for cost-passthroughs to these entities is discussed in
Section Five (Regulatory Flexibility Analysis); cost-passthroughs to small (under 1 MOD
treatment works) that ship their sewage sludge to offsite incinerators is also discussed in Section
Five. Note, however, that the total national cost of regulating incineration is calculated here.
Where these impacts ultimately may fall is discussed in Section Five.
4-136
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4.5.2.1 Compliance Costs for Secondary or Advanced Treatment POTWs Practicing
Incineration
The compliance cost analysis for POTWs practicing secondary or advanced treatment
consists of five parts: the pass/fail analysis; the compliance strategy analysis; the compliance
strategy cost analysis; an analysis of other costs; and a summation of all costs.
Pass/Fail Analysis
Pass/Fail Methodology. The basic requirements for compliance as outlined in Section
4.5.1 above call for all POTWs operating incinerators to meet pollutant emission criteria by
limiting the presence of the regulated pollutants in the sewage sludge fed to the incinerator.
Most POTWs indicated in the NSSS that they would use more stringent pretreatment as one
method of complying with the regulatory requirements of Part 503. In general, however, the
POTWs are expected to use additional pollution control devices to allow them to continue firing
their sewage sludge at its existing level of pollutants, as well as, possibly, additional pretreatment
requirements.
The pass/fail model developed for incinerators was used only for determining the ability
of incinerators to meet the metals criteria given their existing sewage sludge quality. Based on
data collected by EPA (see Appendix C), EPA assumes that all fluid-bed, multiple-hearth, flash-
drying, and electric incinerators currently meet or exceed the THC requirement.
As discussed in Section 4.5.1, the critical components of the equations calculating
allowable metals concentrations in sewage sludge are the feed rate, the dispersion factor, the
control efficiency of the incinerator, and the RSC or similar factor. In the pass/fail model, the
daily throughput of each incinerator in the NSSS survey was used, along with the NAAQS for
lead, the RSC values as listed in Table 4-44 for arsenic, cadmium, chromium, and nickel, a
dispersion factor developed by Abt Associates for each of the NSSS POTWs operating
incinerators in the analytical survey, and a median control efficiency for each metal derived from
numerous EPA studies of air pollution control equipment control efficiencies operating on
4-137
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sewage sludge incinerators and their control efficiencies (Abt Associates, 1991a). The
throughput values and dispersion factors for the NSSS incinerators arc listed in Table 4-45;
median control efficiencies for both conventional scrubbers and wet electrostatic prccipitators
(WESPs) arc presented in Table 4-46.
In some cases, the throughput value or certain information for input to the dispersion
model were not available from the NSSS. Some throughput data were estimated using total
annual sewage sludge volume reported to be incinerated rather than using the calculated annual
throughput based on average daily throughput times numbers of days of operation. Some
dispersion input data also were estimated by Abt Associates (1991b).
The median control efficiencies for conventional scrubbers were used with the
throughput and dispersion factors to calculate a maximum pollutant concentration for these
metals in each treatment works' sewage sludge. The actual pollutant concentrations in each
POTW's sewage sludge as reported in the NSSS survey were then compared to the computed
maximum values. Where the actual concentration of a metal in the sewage sludge exceeded the
maximum concentration calculated for the incineration facility, a "fail" designation was
generated for that metal. The POTWs that had one or more fails were then listed with a "fail"
designation for the POTW.
This pass/fail analysis used the RSCs in the regulation. For chromium, however, a site-
Specific RSC can be computed by the POTW. The site-specific RSC value depends on the
percentage of hexavalent chromium in the total chromium emissions, because hcxavalcnt
chromium is the primary component associated with health risks. To approximate the results of
using a site-specific RSC, an additional value for the chromium RSC can be used. However, the
pass/fail analysis used the RSC for chromium as listed in the regulation.
The output of the pass/fail analysis also includes the required control efficiency (i.e., that
efficiency needed to meet the emission criteria with the existing sewage sludge quality,
throughput, and other factors). These data were used to guide decisions on probable
compliance strategics.
4-138
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TABLE 4-45
SEWAGE SLUDGE FEED RATES AND DISPERSION
FACTORS FOR SEWAGE SLUDGE INCINERATORS
IN THE ANALYTICAL NSSS
POTW
051
181
221
084
210
212
209
214
314
317
157
172
040
319
351
353
447
244
076
Oil
149
287
Reported Flow
Rate Group
2
2
1
3
2
1
3
2
2
1
.2
2
2
1
1
3
2
2
2
2
3
2
Sewage Sludge Feed Rates
(Based on Annual Throughput)
(dmt/year)
19.7
55.0
218.2
27.5
14.6
626.9
7.6
78.1
11.1
160.2
14.0
16.0
18.5
104.3
96.8
3.9
39.1
6.8
60.0
69.2
13.1
23.0
Dispersion
Factor
3.26
0.76
1.37
26.58
1.26 ,
0.42
23.80
2.66 .
31.20
4.02
1.26
6.92
6.89
14.27
0.30
3.41
2.79
8.86
0.79
9.19
8.80
3.27
Note: Reported Flow Rate Group 1: >100 MOD; Reported Flow Rate Group 2: > 10-100 MGD.
Reported Flow Rate Group 3: >1-10 MGD; and Reported Flow Rate Group 4: < 1 MGD.
Source: 1988 National Sewage Sludge Survey, EPA, and Abt Associates (1991b).
4-139
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TABLE 4-46
CONTROL EFFICIENCIES ASSUMED FOR CONVENTIONAL
SCRUBBERS AND VVESPS
Pollutant
Arsenic
Cadmium
Chromium
Lead
Nickel
Conventional Scrubbers
Mu It ip Ie-I lea rt b
97.48
88.54
99.03
91.59
98.98
Fluid-Bed
99.91
99.27
99.91
99.89
99.84
WES Ps
Multiple-Hearth
98.68
99.69
99.88
99.71
99.90
Fluid-Bed
99.98
99.79
99.97
99.99 +
99.99+
Source: Abt Associates, 1991.
4-140
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Pass/Fail Results. The NSSS analytical survey contains information on 26 POTWs
practicing incineration, of which three POTWs transfer their sewage sludge to other POTWs for
firing in a sewage sludge incinerator. These three POTWs, which represent 195 POTWs
nationwide, are not considered in this analysis. (The costs of meeting the regulations are
assumed to be borne only by the operators of sewage sludge incinerators in this analysis; Section
Five discusses potential cost-passthroughs to smaller treatment works that ship their sewage
sludge to offsite incinerators. Note that these POTWs that transfer sewage sludge will not have
to test their sewage sludge before transferring, since sewage sludge must be sampled at the point
it enters the incinerator. Testing costs are also assumed to be passed through, but are not
assigned to smaller POTWs in this section of the RIA). A total of 23 analytical survey POTWs
operate 53 sewage sludge incinerator units. These POTWs represent 185 POTWs with 284 units
nationwide.
As Table 4-47 shows, four POTWs could potentially fail to meet the concentration limits
with their existing pollution control equipment. POTWs 214, 314, 317, and 319 are estimated to
be likely to fail to meet the emission limits for metals at their current sewage sludge quality,
based on assumptions about typical control efficiencies of conventional scrubbers and using the
RSC for chromium from the regulation. These four POTWs represent 14 POTWs nationwide
(317 and 319 represent only themselves; 214 and 314 represent 6 POTWs each). As discussed
earlier, all incinerators are assumed able to pass the THC requirements.
Compliance Strategies
All but one POTW (discussed later) were determined, based on professional judgment
and on responses to the NSSS, to be unlikely to shift to another disposal practice. EPA
determined that all POTWs could meet THC requirements (see Appendix C).
Several additional analyses were undertaken to see if failing POTWs could meet metals
limits using WESPs. The first analysis used the same pass/fail model, but control efficiencies for
WESPs were used instead of those for conventional scrubbers. The hexavalent chromium
percentage was also assumed to be the reasonable worst-case value used by the regulation to
4-141
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TABLE 4-47
PASS/FAIL ANALYSIS FOR METAL EMISSIONS FROM SEWAGE SLUDGE
INCINERATORS EQUIPPED WITH CONVENTIONAL SCRUBBERS-
SECONDARY OR ADVANCED TREATMENT WORKS
POTW
051
181
221
084
210
212
209
214
314
317
157
172
040
319
351
353
447
244
076
Oil
149
287
Reported Flow
Rate Group
2
2
1
3
2
1
3
2
2
1
2
2
2
I
1
3
2
2
2
2
3
2
Arsenic
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Cadmium
Pass
Pass
Pass
Pass
Pass
Pass
Pass
FAIL
FAIL
FAIL
Pass
Pass
Pass
FAIL
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Chromium
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
FAIL
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Lead
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
FAIL
Pass
Pass
Pass
FAIL
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Nickel
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
POTW
Pass/Fail
Pass
Pass
Pass
Pass
Pass
Pass
Pass
FAIL
FAIL
FAIL
Pass
Pass
Pass
FAIL
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Pass
Note: Reported Flow Rate
Reported Flow Rate
Group 1: >100 MOD; Reported Flow
Group 3: >1-10 MGD; and Reported
Rate Group 2: > 10-100 MGD.
Flow Rate Group 4: < 1 MGD.
Source: ERG estimates.
4-142
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estimate RSC for chromium. Only one POTW (POTW 319) might continue to have difficulties
meeting the chromium limit under the assumptions used in this analysis. This POTW represents
only itself. A further analysis was performed to determine the control efficiency need for this
POTW based on the existing sewage sludge quality. We estimated that a control efficiency of
99.92 percent would be needed. Typical WESP values average 99.88 percent (Abt Associates,
1991a). Although this control efficiency need is high, it is EPA's judgment that if the control
efficiency of this POTW's conventional scrubber is increased to a high but reasonably achievable
level and the most efficient WESP is purchased and installed, this POTW could also meet the
chromium limit (see Appendix C for a more detailed discussion). Therefore, all treatment
works are assumed able to meet Part 503 with the addition of WESPs, where necessary.
The one POTW determined likely to shift from incineration to another method of
disposal (even though it can meet metal limits) is POTW 072, which represents a total of 6
POTWs nationally. This POTW codisposed 7,636 dmt of sewage sludge in 1988 and incinerated
about 20 dmt, which is far below the annual design capacity of the incinerator. Based on this
observation and other information derived from the NSSS, which indicates that they were
currently evaluating alternatives to incineration in 1988-89, EPA assumes this POTW is unlikely
to continue to incinerate sewage sludge following promulgation of Part 503. In the short-term,
EPA assumes that this POTW will shift this very small portion of its sewage sludge from
incineration to codisposal, which is the POTW's major disposal practice. This shift can only
result in cost savings to the POTW, since in 1988, the POTW reported operating expenses of
about $3,000 per dmt of sewage sludge incinerated. This cost savings is not, however,
considered to be a result of Part 503, since it appears that the POTW may already be shifting
away from incineration, or may have already stopped incinerating some time early in 1988,
which is highly likely given the very small amount incinerated.
Costs of the Compliance Strategies
Several POTWs will need to install WESPs. As noted in the Pass/Fail results, 4 POTWs,
representing 14 POTWs nationally, were identified as definitely needing to install WESPs. All
4-143
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of these were assumed to need high efficiency WESPs. Total costs for purchasing, installing,
operating, and maintaining WESPs arc $3.6 million, which arc presented in Table 4-48.
No costs arc anticipated as a result of the Part 503 regulation to POTW 072, which was
estimated to shift to codisposal, and the others it represents, apart from the cost to treatment
works practicing eodisposal counted in Section 4.1.
Costs of Other Requirements
General Requirements. No costs arc associated with general requirements, which only
specify that no one shall fire sewage sludge in a sewage sludge incinerator except in accordance
with Subpart E.
Dispersion Modeling. Determining the dispersion factor that must be used to calculate
the maximum pollutant concentration allowed in the sewage sludge to be fired requires that
meteorological data be gathered for the site in question (available through the National Oceanic
and Atmospheric Administration [NOAAJ). It also requires gathering information such as
incinerator stack and building heights, exit velocities of exhaust gases, and stack diameters. To
assemble these readily available data, EPA estimates 1 hour of a manager's time at $40/hr and
1 hour of clerical time at $20/hr. Additionally, it is assumed that a consultant is hired to
perform the dispersion modeling and write a report summarizing the modeling results.
Four tasks arc assumed to be completed by the consultant:
• Read and interpret maps and meteorological data
• Input parameters and run the dispersion program
• Interpret the results of model runs and write the report
• Type and produce the report
4-144
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the program, is further expected to take 8 hours' time ($600). Interpreting the results and
writing the report is expected to entail 40 hours of time ($3.000). Finally, producing the report
is estimated to require 20 hours of clerical time at $20 per hour ($400). Total costs for the
dispersion modeling and report are thus $5,200 per POTW. Based on 179 POTWs, total costs
arc $930,800, or $94,804 annually over 20 years.
Emissions Testing. In 1988, EPA estimated the costs of emissions performance testing
in the RIA for the Part 503 proposal. At this time, EPA contacted several firms that provide
this service. As a result of these contacts, EPA determined that, on average, tests for setting up
a performance test for one or more units were estimated to cost about $7,900 in 1987 dollars;
costs for testing each unit and analyzing the results were estimated at $3,500 per unit. EPA
inflated these figures to 1991 costs using the consumer price index (CPI) inflator of 24 percent.
In 1992 dollars, EPA thus estimates a set up cost of $9,796. Added to this cost is the time for
the POTW manager to describe the needed tests, take bids from several firms, select a firm,
monitor the testing, and so on. A total of 24 hours of a manager's time at $40/hr and 8 hours
of clerical time at $20/hr are estimated, for a total cost of $1,120 per incinerator facility,
regardless of numbers of units. Total pcr-POTW costs arc thus $10,916. Testing on each unit is
expected to cost an additional $4,340 each. Based on these figures, total costs for all
incineration facilities are estimated to be $3.2 million, or $0.3 million annualized at 8 percent
over 20 years (see Table 4-49). These costs are for initial emissions testing only. Where
WESPs arc installed, additional emissions testing is assumed in the costs of installation.
Included in these costs is the cost of preparing a report, which should satisfy
rccordkccping and reporting requirements for emission testing results.
Management Practices. Four types of equipment must be purchased, installed,
calibrated, operated, maintained, and replaced if necessary: a combustion temperature monitor
and recorder, a moisture monitor and recorder, an oxygen monitor and recorder, and a THC
monitor and recorder. According to data from the NSSS, most POTWs already have
combustion temperature monitors and recorders, but only two analytical survey POTW have
THC monitors in place; no POTWs are believed to have moisture monitors in place, and EPA
4-146
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assumes that no POTWs have oxygen monitors for measuring this parameter in the stack gases.
EPA assumes all POTWs will install and operate THC, oxygen, and moisture monitors; none
will need to install feed rate monitors and none will need to install temperature monitors.
Costs for THC, oxygen, and moisture monitoring arc presented in Table 4-50. A total of $6.9
million annually is estimated for capital and operating costs.
Frequency of Monitoring Requirements. The primary costs for monitoring are those
associated with monitoring the five metals regulated by Subpart E. Costs for each test are $190
(the number of metals analyzed is not a major determinant of price; the tests will cost about the
same whether five or ten metals arc analyzed). The frequency of monitoring varies, as discussed
previously, depending on the quantity of sewage sludge incinerated annually. Total annual costs
for testing sewage sludge are estimated at approximately $0.1 million, based on the number of
POTWs and numbers of tests each POTW must perform annually (see Table 4-51). THC, feed
rate, temperature, oxygen concentration, and moisture must also be continuously monitored.
Continuous monitoring devices typically print out readings on strip charts. Costs for operating
and maintaining this equipment (which includes costs of blank strip-chart paper) were included
in the estimates under management practices. Additionally, costs for reading the strip charts is
included as part of the incremental costs of operating the pollution control equipment and
calibrating and maintaining the monitoring devices. Thus, no additional costs for monitoring
these parameters arc included here.
Recordkeeping Requirements. The rccordkccping requirements can be broken into two
groups: information established one time, and information that must be updated at the same
frequency as monitoring is required. The items that must be established only at the outset are
dispersion factor, emission performance test results, the risk-specific concentration for
chromium, if measured, stack height, and the values of operating parameters for the pollution
control device. Costs for setting up the filing system arc also one-time costs. The dispersion
factor for the site, the control efficiency of the incinerator desired from the emissions testing,
and the risk-specific concentration for chromium arc provided when the reports are prepared.
(Costs for developing these reports have been included in other sections of this analysis, where
appropriate.) Costs for filing these reports arc estimated to be negligible. Finally, costs for
4-148
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setting up a filing system, when annualized, are also considered negligible. Thus all one-time
costs are considered negligible.
The second group of potential recordkeeping costs is associated with activities that take
place periodically. These include filing sewage sludge testing reports at the same frequency as
the monitoring occurs, filing strip chart data from THC, temperature, oxygen, and moisture
monitors, and maintaining calibration and maintenance logs for all monitors. The testing
reports arc estimated to be filed once per monitoring period at 1/2 hour of clerical time per
period ($20/hr). The THC, oxygen, moisture, and feed rate monitoring charts are assumed to
be filed once per week at 1/2 hour of clerical time per week ($20/hr), or at an annual cost per
POTW of $520. Records of beryllium and mercury concentrations are collected under 40 CFR
Part 61 and no incremental costs are assumed here. Maintaining calibration and maintenance
logs is a part of the labor cost to maintain and calibrate monitors and has been accounted for
under management practices. Table 4-52 presents costs of recordkeeping. As shown, total costs
for recordkeeping arc $0.1 million annually.
Reporting Requirements. All incinerators must report all data for which recordkeeping
is required. This task entails primarily time to organize data, time and other costs for copying,
and mailing. Costs to report emission testing reports and other one-time items are assumed to
be negligible on an annual basis. Copying of all strip charts is assumed to entail a two-page
copy for each 24-hour period for each monitoring device, or 2,920 pages of copies annually. At
$0.05 per copy, this is $146 per year. Copying sewage sludge test results and maintenance logs
arc expected to entail just a few pages and arc considered to generate negligible copying costs.
The time to assemble and send this information is estimated to take 8 hours of clerical
time at $20/hr, or $160 per year. Mailing is estimated to cost an additional $10. The per-
POTW costs is thus $316. For 179 POTWs, the total cost of reporting is estimated at $56,564.
4-151
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Treatment
Table 4-53 presents the total costs of complying with Part 503 Subpart E for secondary
and advanced treatment POTWs. Of the total $11.2 million, 62 percent of costs are associated
with monitoring devices and their upkeep (management practices), and $3.6 million or 32
percent of total costs are associated with the emission control systems needed for meeting the
emission limits in Subpart E. All other costs total only a little more than $0.7 million.
Average annual costs per POTW range from $0.3 million for the largest POTWs to $0.04
million for the smallest POTWs. These lower costs reflect the greater number of fluid-bed
incinerators in this group, to which few modifications are estimated to be needed.
4,5.2.2 Compliance Costs for Primary Treatment POTWs Practicing Incineration
As discussed earlier, EPA believes that primary sewage sludge quality is no worse than
secondary sewage sludge quality. EPA also assumes that primary sewage sludge incinerators are
not significantly different from incinerators burning secondary or advanced sewage sludge, since
no factors that would tend to indicate otherwise are known. Using these assumptions, we
estimate, based on the average incremental costs of incinerating sewage sludge for each flow
rate group derived in the previous section that total annual incremental costs to this group of
POTWs are $0.5 million (see Table 4-54).
4.5.2.3 Total Compliance Costs for Incinerating POTWs under Subpart E
Based on the total annual incremental costs of Subpart E estimated for secondary or
advanced treatment works of $11.2 million, and those for primary treatment works of $0.5
million, EPA estimates the total compliance costs for all incineration POTWs under Subpart E
to be $11.7 million (see Table 4-55), not including $20,000 for meeting Subpart A requirements
and for reading and interpreting the regulation.
4-153
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TABLE 4-54
INCREMENTAL ANNUAL COST OF INCINERATING SEWAGE SLUDGE
AT PRIMARY TREATMENT POTWS
Reported
Flow Rate
Group
> 100 MOD
> 10-100 MOD
> 1-10 MOD
<1 MOD
Total
Number of POTWs
0
2
9
64a
75
Average Incremental
Cost
~
$78,000
37,000
—
•
Total Cost
—
$156,000
333,000
--
$489,000
aThese POTWs are estimated to transfer their sewage sludge offsite as do the secondary or
advanced treatment POTWs in this flow rate group. Cost passthroughs to these facilities are
calculated in Section Five.
Source: ERG estimates.
4-155
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TABLE 4-55
TOTAL COMPLIANCE COSTS FOR ALL TREATMENT WORKS
INCINERATING SEWAGE SLUDGE UNDER PART 503, SUBPART E
($000)
Reported Flow Rate
Group
> 100 MOD
>]0-100 MOD
>!-!() MOD
Total
Costs to Secondary
or Advanced
Treatment POTWs
$1.577
6.088
3,549
$11.214
Costs to Primary
Treatment POTWs
$0
156
333
$489
Total Annual
Incremental Costs
$1,577
6,244
3,882
$11,703
Source: ERG estimates.
4-156
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4.6 TOTAL ANNUAL INCREMENTAL COSTS TO ALL AFFECTED TREATMENT
WORKS AND FIRMS TO COMPLY WITH 40 CFR PART 503
Table 4-56 summari/es the cost to each type of affected entity by current disposal
practice. As the table shows, the total annual incremental cost of complying with Part 503 is
$45.9 million, of which 32 percent is associated with land application requirements, 41 percent is
associated with surface disposal requirements, and 26 percent is associated with incineration
requirements. An additional 1 percent is associated with treatment works whose use or disposal
practices are not directly covered by a Part 503 subpart, but that incur costs for meeting a
Subpart A requirement and for reading the regulation.
Secondary or advanced treatment works incur the largest portions of total costs,
representing over 75 percent of the total. The costs to secondary or advanced treatment works
are evenly divided between incineration, land application, and surface disposal. Over 90 percent
of the costs for domestic septage is associated with surface-disposed domestic septage.
4-157
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REFERENCES TO SECTION FOUR
Abt Associates. 1991a. Memorandum from Wendy Hughes Abt Associates, to Anne Jones,
ERG, re: Removal Efficiencies for Metal Contaminants in Sludge Incineration. June 14,
revised Aug. 12.
Abt Associates. 1991b. Memorandum from Wendy Hughes, Abt Associates, to Anne Jones,
ERG, re: Data Concerning Pass/Fail Facilities, May 14.
BLS. 1992. Employment and Earnings. U.S. Department of Labor, January.
EPA. 1992. Statistical Support Document for the 40 CFR Part 503 Final Rule for Sewage
Sludge Use or Disposal.
EPA. 1991. Permit Compliance System Data Base. Available on EPA's National Computer
Center IBM Mainframe Computer.
ERG. 1989. Memorandum from Dan Mandcll, ERG to Robert Esworthy, EPA, re: Septage
Hauling and Disposal, a Preliminary Profile of the Industry. October 30.
EPA. 1988a. National Sewage Sludge Survey. Available on EPA's National Computer Center
IBM Mainframe Computer
EPA. 1988b. 1988 Needs Survey. Available on EPA's National Computer Center IBM
Mainframe Computer.
EPA. 1984. Environmental Regulations and Technology: Use and Disposal of Municipal
Wastewater Sewage Sludge. EPA/625/10-84/003.
EPA. 1982. Fate of Priority Pollutants in Publicly Owned Treatment Works. PB-122788,
EPA/440/1-82/303. '
Ground Water Age. 1990. 1990 Water Well Industry Survey. Vol. 25, No. 1, Sept.
SAIC. 1991. Memorandum from Kathleen Stralka and Scott Henderson, SAIC, to Chuck
White, EPA, re: Nonparamctric Tests of Hypothesis Concerning Pollutant
Concentrations in Primary and Secondary Sewage Sludge, 40 City Study Data, August 28.
USDA. 1992. Agricultural Resources: Agricultural Land Values and Market Situation and
Outlook Report. Economic Research Service. Report # AR-26. June.
4-159
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SECTION FIVE
REGULATORY FLEXIBILITY ANALYSIS
5.1 INTRODUCTION
The Regulatory Flexibility Act requires the federal government to specifically consider
the impacts on small entities as part of rulemaking procedures. The goal of the analysis is to
ensure that small entities potentially affected by a new regulation will not be disproportionately
burdened. Small entities have limited resources, and it is the responsibility of the regulating
federal agency to avoid, if possible, disproportionately or unnecessarily burdening such entities.
The Part 503 regulation will affect how small POTWs, small privately owned treatment
facilities, and domestic septage haulers use or dispose of sewage sludge or domestic septage.
Section 5.2 discusses the analyses that must be undertaken according to EPA guidance; Section
5.3 presents the analyses required for a Final Regulatory Flexibility Analysis, including comments
on the proposal and alternatives specific to small entities that were or were not adopted in the
rule; Section 5.4 presents-a profile of the affected entities; and Section 5.5 determines the
aggregate and treatment works/firm-level impacts on small entities.
5.2 SUMMARY OF EPA GUIDANCE
EPA guidelines now require EPA Offices to perform Regulatory Flexibility Analyses
(RFAs) for regulations that have any effect on any small entities. Formerly, EPA determined
whether an RFA should be performed by determining whether the rule in question had a
significant economic impact on a substantial number of small entities. When using this approach,
EPA spent much of the time trying to determine whether the rule did have a significant impact
on a substantial number of small entities; with the new approach, EPA can bypass much of this
preliminary analysis and go on to address the impacts on the affected entities.
5-1
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EPA's approach is divided into two stages: an Initial Regulatory Flexibility Analysis
(IRFA), performed for the proposed rule, and a Final Regulatory Flexibility Analysis (FRFA),
performed for the final rule. The IRFA is divided into 6 requirements:
• Explain why the Agency is considering taking action.
• State succinctly the objectives of, and legal basis for, the proposed rule.
• Describe and, where feasible, estimate the number of small entities to which the
proposed rule will apply.
• Describe the projected reporting, recordkeeping, and other compliance
requirements of the proposed rule, including an estimate of the classes of small
entities that will be subject to the requirements and the type of professional skills
necessary for preparation of reports or records.
• Identify, to the extent practicable, all relevant federal rules that may duplicate,
overlap, or conflict with the proposed rule.
• Describe any significant alternatives to the proposed rule that accomplish the
stated objectives of applicable statutes while minimizing the rule's economic
impact on small entities.
The FRFA requires the following:
Succinctly state the need for, and objectives of, the rule.
Summarize the issues raised by public comments on the IRFA and the Agency's
assessment of those issues, and describe any changes in the rule resulting from
public comments.
Describe each of the significant alternatives to the rule consistent with the stated
objectives of applicable statutes and designed to minimize any significant
economic impact of the rule on small entities, which was considered by the
Agency, and explain why the Agency rejected any alternative it did not adopt.
Because the RIA for the proposal was written before this new guidance was issued, and
because the final rule has been changed because of concerns raised by domestic septage haulers
and others about the ability of some of the small entities to meet the requirements of the
proposal, this Regulatory Flexibility Analysis is a hybrid, incorporating some of the aspects of a
IRFA, while meeting the requirements of a FRFA. Therefore, Section 5.3 presents a discussion
5-2
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of issues relevant to an FRFA (the need for the regulation, issues raised by comments and
alternatives not adopted by EPA). The remainder of the section (Sections 5.4 and 5.5) is
devoted to analyses required for an IRFA, including a profile of small entities, a description of
aggregate and per-entity costs of compliance and, for potentially highly affected entities, a
discounted cash flow analysis and a closure analysis.
5.3 THE FINAL REGULATORY FLEXIBILITY ANALYSIS
This section presents the three required parts of an FRFA: the need for and objectives of
the rule; the issues raised by public comment; and alternatives adopted and not adopted in the
final regulation.
5.3.1 Need for and Objectives of 40 CFR Part 503
EPA is required to develop regulations covering the use or disposal of sewage sludge
pursuant to Sections 405(d) and (e) of the Clean Water Act, as amended in 1987. The proposed
regulation was issued in the Federal Register, Volume 54, No. 23, published February 6, 1989.
The Clean Water Act directs EPA to develop regulations to identify uses for sewage
sludge, including disposal, and to identify factors to be taken into account in the use or disposal
of sewage sludge. The regulation must specify concentrations of pollutants that would interfere
with sewage sludge use or disposal. Furthermore, EPA must identify the toxic pollutants in
sewage sludge that might adversely affect public health or the environment and, in the regulation,
specify management practices and establish numerical limits for each of the pollutants. The Act
requires that the standards be adequate to protect public health and the environment from any
reasonably anticipated adverse effects of the pollutants.
5-3
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5.3.2 Issues Raised by Public Comment
Two major issues were raise by public comment that pertain to impacts on small entities.
First, the Small Business Administration (SBA) commented that the RIA for the proposal did
not adequately support the rinding of no significant impact on a substantial number of small
entities. This issue is addressed in the Notice of Information published November 9, 1990, in the
Federal Register and in this Regulatory Flexibility Analysis. Using the new guidelines for
performing RFAs, the Agency has determined that an economic impact on some small entities
will occur and is thus performing this analysis to identify the severity of that impact, to present
the number of affected entities, and to identify alternatives considered by the Agency.
Second, domestic septage haulers indicated that the proposed Part 503 regulation would
be impossible for them to meet from both an economic and practicality perspective. EPA has
addressed this issue by providing septage haulers with simplified requirements in many instances,
including simplified pathogen and vector attraction reduction requirements, reduced
recordkeeping requirements, minimal monitoring requirements, and an exclusion from meeting
pollutant limits. EPA believes that Part 503 can now be met by domestic septage haulers.
5.3.3 Alternatives to Part 503 Considered by the Agency
The Agency considered the following alternatives to fully implementing all standards in
Part 503 to cover all small entities: alternatives to pollutant limits, alternatives to monitoring
requirements, alternatives to recordkeeping requirements, alternatives to reporting requirements,
and alternatives to pathogen and vector attraction reduction requirements. Alternatives to
management practices for small entities were not considered because these practices are in most
cases consistent with existing regulations, or the practices could not be eliminated without a
potential impact on public health and the environment.
5-4
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5.3.3.1 Alternatives to Pollutant Limits
The Agency looked at alternatives to meeting pollutant limits for domestic septage
haulers and other small entities. EPA determined that domestic septage is likely to be of
relatively uniform quality, and that if the amount of septage per unit of land did not exceed the
nitrogen uptake ability of the vegetation, it was unlikely that the land application of domestic
septage would have an adverse effect on human health and the environment based on the
Agency's limited data on concentrations of pollutants in septage. Thus EPA set a hydraulic
loading rate requirement based on the nitrogen uptake capacity of the vegetation actually grown
on the site where septage is land applied (i.e., a site-specific limit). Land-applied domestic
septage does not, therefore, have to meet pollutant limits. Furthermore, costly pollutant-specific
monitoring and recordkeeping are avoided.
Surface-disposed domestic septage is probably disposed of at greater than a typical annual
application rate limit, thus this approach is not appropriate for surface-disposed domestic
septage. Furthermore, because the amount of septage disposed on a unit of land could be quite
large, EPA felt that, given its very limited data on septage quality, the Agency could not be
assured that human health and the environment would be sufficiently protected if no ground-
water monitoring were performed for nitrates. Therefore, although the Agency does exempt
surface-disposed domestic septage from the pollutant limits, it does not exempt surface-disposed
domestic septage from ground-water monitoring.
An annual application rate approach also could not be taken for small treatment works,
because the Agency could not ensure that commercial or industrial effluent would not be a
component in the treatment works' influent stream as it could for domestic septage (the Agency
restricted coverage of Part 503 to domestic septage only, whereas virtually all POTWs have at
least a small commercial component to their influent). Because of the potential for sizeable
variations in sewage sludge quality at small treatment facilities, EPA did not believe the Agency
could allow small treatment works to apply sewage sludge up to an annual application rate limit
and still provide adequate protection to human health and the environment.
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5.3.3.2 Alternatives to Frequency of Monitoring Requirements
Although the Agency could not offer small treatment works a less stringent pollutant
standard, the Agency did provide for less frequent monitoring requirements based on amount of
sewage sludge used or disposed annually. Small treatment works typically generate small
amounts of sewage sludge, and most will probably be required to test sewage sludge for
pollutants of concern only annually (instead of monthly, bimonthly or quarterly, which is required
of the larger POTWs). Furthermore, many small treatment works do not dispose of sewage
sludge annually. Many store sewage sludge for several years in wastewatcr treatment lagoons
while they accumulate enough to make disposal worthwhile. Because Part 503 specifically
exempts sewage sludge generated in a wastewater treatment process until it is removed for
disposal, the sewage sludge has to be tested only when the treatment works removes the sewage
sludge for disposal. In fact, sewage sludge generated in a treatment process is not covered by
any section of Part 503 until it is removed for disposal. Finally, land-applying treatment works
that are currently using PSRP will not have to monitor for pathogens in a Class B sewage sludge.
Although this is an advantage for all treatment works, regardless of size, very few small treatment
works currently prepare sewage sludge to meet Class A requirements, thus most small treatment
works will not have to monitor for pathogens.
EPA considered requiring domestic scptage haulers to test each load of septage for pH,
since pH adjustment was the least expensive treatment option for domestic septage to achieve
pathogen and vector attraction reductions equivalent to those for Class B sewage sludge. The
final regulation, however, allows domestic septage haulers to use site restrictions and other
management practices to meet pathogen and vector attraction reduction requirements. When
domestic septage, haulers use these practices to meet the pathogen and vector attraction
reduction requirements, no testing of domestic septage is required. EPA determined that these
restrictions and management practices would provide the minimum amount of control necessary
to protect human health and the environment.
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5.3.3.3 Alternatives to Recordkeeping Requirements
For small treatment works, EPA has established pollutant concentration limits for land
applied sewage sludge. If a facility meets these pollutant concentration limits, recordkeeping
requirements are significantly reduced. In general, small facilities tend to have relatively high
quality sewage sludges, and a majority of small facilities use or dispose of sewage sludge that
meets the pollutant concentration limits. Although this alternative is also useful for larger
treatment works, it will minimize recordkeeping impacts on small treatment works. Furthermore,
most of the tasks require clerical skills only; see Section 4.2.
Most of the recordkeeping tasks for surface disposers are simple as well. Although
developing closure plans could require a consultant to be hired, EPA believes that the POTW
operator probably would be able to prepare an adequate closure plan, particularly since liners
and leachate collection systems are not required by Part 503 (detailing the operation of such
systems is the most elaborate portion of the closure plan). Complete closure plans for all surface
disposal units are considered vital for ensuring adequate protection of human health and the
environment. The remaining recordkeeping task require mostly clerical skills.
EPA's recordkeeping requirements for domestic septage are not significantly less detailed
than those for treatment works; however, the level of skill needed to maintain records is not high
for either domestic septage haulers or small treatment works. For domestic septage haulers, a
truck driver is expected to be able to indicate the date and time of application, the number of
gallons applied, and the pH measurement (if pH adjustment is used to meet pathogen and vector
attraction reduction requirements) when domestic septage is applied to or placed on land. The
owner/operator should be able to determine the location and size of the site and calculate the
total annual number of gallons applied to the site, as well as to provide certification pertaining to
adherence to management practice and pathogen and vector attraction reduction requirements.
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5.3,3.4 Alternatives to Reporting Requirements
EPA has established reporting requirements only for Class I treatment works and POTWs
processing more than 1 MOD of wastevvater or serving more than 10,000 persons. Class I
treatment works are typically POTWs treating 5 MGD or more of wastcwater. Most small
treatment works, therefore, will not have any reporting requirements. If any do have to report,
this task should require only clerical skills.
5.3.3.5 Alternatives to Pathogen and Vector Attraction Reduction Requirements
To meet Class B pathogen requirements, EPA has allowed land-applying treatment works
to continue using their PSRP process completely unchanged from Part 257 requirements. Since
few small treatment works prepare sewage sludge using PFRP, impacts on these land- applying
treatment works should be minimal. Small surface-disposing treatment works have not been
required to meet PSRP before. Some of the larger impacts on small treatment works practicing
surface disposal are associated with meeting pathogen and vector attraction reduction
requirements. EPA has, however, provided an alternative to further sewage sludge processing.
Where feasible, daily cover can be used to meet these requirements.
EPA has established alternatives to Class A and Class B Pathogen and Vector Attraction
Reduction Requirements for domestic septage haulers. These firms would not be able to meet
Class A and B requirements without significant changes to their operations (e.g., installing
centralized treatment facilities for treating domestic septage before use or disposal). EPA has
responded to this difficulty by allowing domestic septage haulers two choices. The first is more
expensive. In this procedure, domestic septage haulers must add alkali (typically lime) to the
domestic septage such that the pH of the septage is raised to 12 for a period of 30 minutes. This
type of treatment is already performed in at least one state (Wisconsin), and no major problems
have been identified with the use of lime in this manner.
The other alternative requires land applying domestic septage haulers to meet harvesting
and site restrictions while injecting or incorporating sewage sludge and requires surface-
5-8
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disposing domestic septage haulers to use daily cover. EPA believes these requirements closely
follow current practice and expects that pathogen and vector attraction reduction requirements
will have a negligible impact on domestic septage haulers.
Small treatment works have not been offered these alternatives because all land appliers
should be meeting PSRP requirements currently, which are used as one alternative for meeting
Class B pathogen and vector attraction reduction requirements. Additionally, according to EPA
data, very few small surface disposers, the only other group of concern, are likely to be unable to
meet Class B requirements. Many small POTWs have sewage sludge treatment processes that
are consistent with meeting at least Class B requirements, including drying beds and lime
treatment processes. Furthermore, EPA estimates that meeting Class B requirements is not
excessively costly on a per-treatment works basis at small treatment works, and primarily involves
adding a lime treatment step to existing processes. Additionally, as discussed above, use of daily
cover meets the pathogen and vector attraction reduction requirements for surface disposal.
5.4 PROFILE OF SMALL ENTITIES
This section profiles the small entities affected by Part 503. The discussion is divided
between small treatment works, including small POTWs and privately owned treatment works,
and domestic septage haulers, because of the differences in the types of analyses required for
these two groups of affected entities.
5.4.1 Small Treatment Works Affected by Part 503
For purposes of this RFA, small treatment works affected by the Part 503 regulation are
defined as small POTWs processing less than 1 MGD of wastewater (corresponding to a service
population of 10,000) and all privately owned treatment works. EPA considered all private
treatment facilities as small entities since virtually all (about 99%) are within the 1 MGD size
constraint applied to POTWs. The 1 MGD size definition is typically used by EPA for
designating small wastewater or drinking water treatment works. EPA discussed this size
5-9
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definition with the SBA at a meeting in July 1990 In addition, EPA proposed this size
definition in the Notice of Information Availability (55 FR 47210) and asked for comments.
EPA received no comments on this definition. Thus, the derivation of an alternative definition
of small entity for this RFA complies with the requirements outlined in the Regulatory Flexibility
Act.
Table 5-1 enumerates the total number of treatment works affected by the Part 503
regulation. Treatment works are grouped by size and type. As shown in Table 5-1, EPA
estimates that there are 14,460 small, publicly or privately owned treatment works, of which 8,040
are secondary or advanced treatment POTWs, 1,591 are primary treatment POTWs, and 4,829
are privately owned treatment works. Thus about 82 percent of all treatment works are
considered small. Small treatment works are further grouped in terms of whether their sewage
sludge use or disposal practice falls under Part 503 requirements. For instance, treatment works
practicing codisposal will not be subject to the Part 503 regulation, nor will treatment works that
do not use or dispose of any sewage sludge be covered in the year or years they do not use or
dispose of sewage sludge. These treatment works will incur very minimal costs of reviewing the
regulation to determine whether they arc subject to any requirements. Some privately owned
treatment works transfer their sewage sludge to POTWs. These 1,715 treatment works will be
subject to cost passthroughs, but Part 503 does not directly affect them, since they are not the
users or disposers of the sewage sludge. The publicly and privately owned treatment works in
the "not regulated" category (e.g., codisposers) will not be considered further in the RFA, since
their compliance costs are negligible. Therefore, of the 14,460 small treatment works, only 6,861
or 47 percent are considered to be both small and directly affected by the regulation, and only
8,576 or 59 percent are both small and directly or indirectly affected by the regulation.
Table 5-2 presents the total direct impacts of Part 503 on small treatment works as well
as cost-passthroughs. As Table 5-2 indicates, small treatment works are associated with direct
costs of $10.2 million annually (22 percent of total compliance costs) and with indirect costs
totaling $0.3 million. Total direct and indirect costs are $10.5 million, which is 23 percent of
total annual compliance costs of $45.9 million. Cost impacts might not, therefore, be severe.
However, before making any final determination of impact severity, the Agency analyzes impacts
at the treatment-works level in Section 5.5.
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TABLE 5-1
TREATMENT WORKS CONSIDERED SMALL UNDER RFA DEFINITIONS
Small Treatment Works
Non-Regulated"
Regulated
Transfer15
Total Large and Small
Treatment Works
Percentage of Total
Considered Small
Percentage of Total
Considered Small and
Affected
Publicly Owned Treatment
Works (POTWs)
Secondary or
Advanced
8,040
3,870
4,170
~
10,939C
73.5%
38.1%
Primary
1,591
480
1,111
~
1,855
85.8%
59.9%
Privately
Owned
Treatment
Works
4,829
1,534
1,580
1,715
4,829
100%
68.2%
Total
14,460
5,884
6,861
1,715
17,623
82.1%
48.7%
Note: aNon-regulated includes facilities not covered by Part 503 as well as facilities listed as
"Unknown" which have lagoons and will only incur compliance costs in the years they dredge
and dispose of the contents of the lagoon.
bOnly private treatment facilities were analyzed as transferring to POTWs.
°Based on analytical survey weights (see Section Four) and major disposal practice.
Source: ERG estimates.
5-11
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Pollutant impacts associated with small treatment works are measured based on the total
amount of dry solids used or disposed annually. Small treatment works use or dispose of 507,000
dmt of sewage sludge, of which 353,000 is used or disposed by secondary or advanced treatment
works, 54,000 dmt is used or disposed by primary treatment works, and 100,000 dmt (at a
maximum) are estimated to be used or disposed by privately owned treatment works. Thus small
treatment works are estimated to use or dispose only 9 percent of the total 5.4 dmt of sewage
sludge used or disposed annually by treatment works. Table 5-3 uses the National Sewage
Sludge Survey to estimate the total amount of regulated pollutants in the total quantity of sewage
sludge used or disposed in regulated practices, separated into large POTWs and small POTWs
and listed by pollutant. As the table shows, the quantity of each pollutant in sewage sludge used
or disposed annually by small POTWs ranges only from 0.4 percent (cadmium) to 11.3 percent
(arsenic) of the total amount of pollutant in all sewage sludges used or disposed annually.
Overall, small secondary or advanced treatment POTWs dispose of 316 dry metric tons of
regulated pollutants annually.
The average compliance cost per dry ton of pollutant disposed in sewage sludge from
secondary or advanced treatment POTWs is calculated to be about $3,300 for large treatment
works and $20,000 for small treatment works, which is somewhat disproportionate.
5.4.2 Domestic Septage Haulers Affected by the Part 503 Regulation
All septage haulers are considered small entities. An estimated total of 8.6 billion gallons
of domestic septage is collected by a estimated 17,000 domestic septage haulers annually. The
large majority of firms (95 percent) haul 1 million gallons of septage or less annually (1 million
gallons of septage is associated with revenues of approximately $70,000) and employ perhaps one
employee in addition to the owner/operator in a minority of cases. Even the largest haulers
would generally be considered small business entities based on annual revenues of under $1
million and fewer than 10 employees.
Of the 17,000 domestic septage haulers, 6,120, or about 36 percent, are estimated to be
directly affected by the Part 503 regulation. An additional 8,670 domestic septage haulers take
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TABLE 5-3
TOTAL ANNUAL QUANTITY OF POLLUTANTS IN SEWAGE SLUDGE
USED OR DISPOSED IN REGULATED PRACTICES
BY SECONDARY OR ADVANCED TREATMENT POTWS
(Dry Metric Tons)
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Total
Large POTWs
28.46
122.23
1,057.68
1,884.57
609.54
7.63
22.41
275.01
11.02
4,677.10
8,695.65
Small POTWs
3.63
0.55
20.30
102.38
12.56
0.74
1.55
3.32
0.51
170.48
316.02
Percentage of Total
Attributable to
Small POTWs
11.3
0.4
1.9
5.2
2.0
8.9
6.5
1.2
4.4
3.5
3.6
Source: ERG estimates based on 3988 National Sewage Sludge Survey, Analytical Survey, EPA.
5-14
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septage to POTWs; these haulers may be affected by cost-passthroughs, but they are not the
users or disposers of domestic septage or sewage sludge and are thus considered indirectly, not
directly, affected. This group does not include the 2,210 domestic septage haulers that treat
domestic septage in lagoons.
To assess the potential impact of regulating domestic septage, EPA developed an industry
profile, including a breakdown of size, type, and average annual volume of domestic septage
handled. Based on the distribution of firm size among the data provided by a number of states,
the 17,000 estimated haulers nationwide can be classified as follows: - - - • •
• 11,050 (65 percent) are small haulers who haul on average approximately 0.1
million gallons annually
« 5,100 (30 percent) are medium haulers who haul on average approximately 1.0
million gallons annually
• 850 (5 percent) are large haulers who haul on average approximately 3.0 million
gallons of domestic septage annually and 0.5 million gallons of
commercial/industrial septage.
Table 5-4 breaks down the number of domestic septage haulers by size and use or
disposal practice.
EPA used these size classifications to develop three model firms:
Small firm—A small domestic septage firm is a part-time business operated as a
sole-proprietorship. The owner/operator typically has no employees, although in
some cases, a family member might assist with bookkeeping or other work. The
business owns one small truck (purchased used) with the capacity to haul 1,500
gallons, maintained by the owner. A small firm services a 25-mile radius, and
during the 90 days of actual operation per year, pumps 100 home septic tanks (no
commercial or industrial tanks), hauling a total volume of 100,000 gallons. The
average daily round trip including septage pick-up and disposal, is 35 miles; the
truck therefore travels 3,150 miles per year.
Medium firm—A medium domestic septage firm is a full-time business, with
possibly one part-time employee assisting the owner/operator, who operates the
business as a sole-proprietorship. The business owns one truck (purchased used),'
holding 2,500 gallons and services three septic tanks per day from April through
November, and half that amount in December through March, within a 35-mile
radius. Medium size firms might occasionally collect septage from commercial
5-15
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TABLE 5-4
NUMBERS OF DOMESTIC SEPTAGE HAULERS BY SIZE AND
USE OR DISPOSAL PRACTICE
Size
Large
Medium
Small
Total
Land Application
238
1,428
3,094
4,760
Surface Disposal
68
408
884
1,360
Transfer to POTWs
434
2,601
5,635
8,670
Note: This table does not include 2,210 domestic septage haulers who treat septage in lagoons.
Source: ERG estimates.
5-J6
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firms, but most of their business comes from homes. For the purpose of this
analysis, all medium firms are assumed to handle domestic septage only. Each
truck travels about 110 miles per day, collecting septage. A full-time schedule of
260 days per year allows the medium firm to handle about 1 million gallons of
domestic septage per year.
Large firm—A large firm might be involved in other trades as well as domestic
septage, but domestic septage pumping and hauling remains a large part of the
business. The firm is usually owner-operated as a sole proprietorship, with three
employees in addition to the owner and four 4,000-gallon trucks (purchased new)
servicing a radius of 80 miles. Each truck services one to two home tanks per
day, collecting 3 million gallons of domestic septage annually, out of 3.5 million
gallons of total septage. Each truck travels about 120 miles per day (31,200 miles
per year) to service tanks and dispose of this septage.
Appendix D presents the baseline cost model developed for three domestic septage
hauler profiles. Based on the information above, an average price of $70 per tank pumped, an
overhead rate of 75 percent over labor costs, and other data (as discussed in Appendix D), a
financial profile of the three model firms was developed (see Table 5-5). As the table shows,
pre-tax profits range from $2,950 per year for the smallest firm to $54,123 per year for the
largest firm. Note that this profit does not reflect the impacts of compliance costs. As can be
seen, profits for the smallest firms are marginal, which is consistent with discussions with the
industry trade association (personal communications between ERG and Bob Kendall, various
dates, 1989). These small operators are typically farmers who pump septage to help pay for their
trucks, which they use in their farming operations. It does not reflect their full income.
In Section Four, EPA determined that annual incremental costs to domestic septage
haulers may be about $2.4 million to comply with Subpart B and Subpart C, or roughly $393 per
affected firm. Total costs for complying with Subparts B and C are about $32.5 million annually,
of which costs to septage haulers account for about 7 percent of these total costs. Additionally,
some septage haulers are subject to cost-passthroughs when they dispose of domestic septage at
POTWs. EPA assumes that POTWs pass through their incremental costs to septage haulers
proportionately to the amount of solids present in septage. Assuming that one gallon of
domestic septage weighs approximately 8 Ibs., the 4.4 billion gallons of domestic septage
estimated to be transferred to POTWs (51 percent of the total 8.6 billion gallons) is estimated to
be 16 million wet metric tons. A typical domestic septage is 3-percent solids, thus the annual
amount of domestic septage transferred to POTWs is estimated to be 0.48 million dmt. Total
5-17
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indirect costs to septage haulers that transfer septage to POTWs are estimated at $3.8 million
(based on incremental compliance costs averaging about $8/dmt at POTWs). Thus total direct
and indirect costs are $7.3 million to septage haulers (including $1.1 million for reading and
interpreting the regulation) or 16 percent of total compliance costs. Note that although the total
indirect costs are not small, the incremental cost per 1,000 gallons of septage is about $0.85. On
the basis of total direct and indirect costs, EPA considers that some septage haulers could be
potentially highly affected by the Part 503 regulation. Total costs alone are, however, not
necessarily an indicator of impact severity. Thus Section 5.5.2 will look further at measures of
impact to more accurately identify the type and severity of impacts.
Pollutant impacts associated with domestic septage haulers are calculated based on the
amount of dry solids used or disposed annually (not including that shipped to POTWs). Based
on the assumptions outlined above regarding the quantity of septage, in dry weight, the quantity
of septage not shipped to POTWs totals 0.46 million dmt. In comparison, all treatment works
are associated with 5.4 million dmt. Thus septage solids used or disposed of separately make up
only 8 percent of the combined total for domestic septage and sewage sludge. The total amount
of pollutants in domestic septage could not be quantified, but might not exceed the amounts
identified for small POTWs in Section 5.4.1., since small POTWs also use or dispose of
approximately 0.4 million dmt of sewage sludge annually. If the total quantity of pollutants is the
same as that for small treatment works (316 metric tons of regulated pollutants used or disposed
annually) the direct costs of compliance per ton of pollutant used or disposed would be about
$7,600 per ton of regulated pollutants per year.
5.5 IMPACTS ON SMALL ENTITIES
5.5.1 Small POTWs and Privately Owned Treatment Works
5.5.1.1 Aggregate Impacts
Small treatment works are associated with total annual direct and indirect compliance
costs of $10.5 million (see Table 5-2), which is 23 percent of the total annual compliance costs
5-19
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associated with the Part 503 regulation. This cost does not include $0.4 million for complying
with Subpart A. Over half of these costs are for surface disposal of sewage sludge.
5.5J.2 Per-Treatment Works Impacts
As discussed in Section Four, the annual per-treatment works impacts on small treatment
works practicing land application average about $426, while small treatment works practicing
surface disposal face annual compliance costs of $981 per treatment works. Average annual
revenues for small POTWs are estimated at $198,880, making the ratio of annual compliance
costs to total revenues, on average, about 0.3 percent. At the smallest of these small POTWs
(25th percentile) where revenues average $80,790 per year, the ratio is on average 0.7 percent.
The average amount of sewage sludge used or disposed by treatment plants in the less than 1
MGD flow rate group is 44 dmt annually (based on secondary or advanced treatment POTW
data in the NSSS). Thus surface disposal requirements might increase the cost of surface
disposal about $22 per dmt; land application requirements might cost an additional $10 per dmt.
On average, a treatment works processing less than 1 MGD services 895 households. The annual
cost increases passed through to households are estimated to be $1 for surface disposal and $0.50
for land application, which are very small increases relative to the current average household
charge of $151 (in 1992 dollars) for sewage treatment (EPA, 1989) (increases of 0.7 percent and
0.3 percent, respectively). Impacts on small treatment works and their households are thus not
expected to be severe.
5.5.2 Domestic Septage Haulers
5.5.2.7 Aggregate Impacts
Table 5-6 presents total costs to domestic scptage haulers broken out by size of firm and
type of cost (e.g., recordkeeping, alkali addition, etc.). In Section Four of this RIA, domestic
septage haulers that practice land application were estimated to incur only $0.2 million annually
to comply with Part 503 requirements. As Table 5-6 indicates, all of these costs are incurred by
5-20
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domestic septage haulers to meet the recordkeeping requirements. Surface disposers, on the
other hand, are affected by the need to either perform ground-water monitoring or to shift to
land application, which account for nearly 88 percent of all costs to surface-disposing septage
haulers. As Table 5-6 shows, average costs per firm are $48 for land appliers and $1,602 for
surface disposers. Total direct costs are $2.4 million, or about $0.78 per 1,000 gallons land-
applied or surface-disposed annually.
5.5.2.2 Per-Firm Impacts on Septage Haulers
Even if none of the costs of compliance can be passed through to homeowners, the
impact on the domestic septage industry will probably not be substantial. Based on the data
developed in this model approach EPA estimates that compliance costs for land-applying
domestic septage haulers could be 0.3 percent of total revenues for the smallest firms, 0.1
percent of revenues for the medium firms, and 0.1 percent of revenues.for the largest firms,
which indicates smaller impacts than those for small treatment works. Impacts on surface
disposers are somewhat larger: the smallest firms could be faced with impacts totalling 14 percent
of revenues; medium firms and large firms will incur impacts totalling 4 and 1 percent of
revenues. Although the smallest surface-disposing firms appear to be severely affected (based on
this percentage of compliance costs to revenues), it is not likely that compliance costs cannot be
at least partially passed through to homeowners.
Regulatory cost impacts on a firm are significantly affected by how much of the
compliance cost can be passed through to customers, which relates to the elasticity of demand
for the product or service. EPA is aware of no data on the elasticity of demand for domestic
septage hauling services. The Agency believes, however, that over the long term, demand is
relatively inelastic, even though over the short run, demand could be elastic.
Homeowners pump their tanks for at least two reasons. Some (possibly a minority) have
their tanks pumped every two years, which the industry recommends for proper functioning of
the tank. Demand for this type of service might be elastic, but demand among homeowners who
have experienced septic tank emergencies (and who now have their tanks pumped every 2 years)
5-22
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might be somewhat less elastic (because they might have had to make major repairs to their
system as a result of neglect and now realize that delaying pumping is a false cost savings). The
other group of consumers waits until septage tanks reach capacity to have the tanks pumped.
This group most likely is associated with very inelastic demand.
The per-tank compliance-cost increases that potentially can be passed through to
homeowners also are a factor in determining impacts. The costs per tank that might be passed
through are not large and should not have a major impact on the average cost of tank pumping.
Prices currently charged by pumpers vary widely by region. These prices range from $35 per
septic tank to over $200 per septic tank and average about $70. If the cost increases are passed
directly through to the estimated 4.0 million homeowners whose septic tanks are pumped in any
one year and whose septage is not sent to a POTW or to a treatment lagoon, the costs of septic
tank pumping could rise by about $0.78 per septic tank pumping ($0.39 per year since tanks are
assumed to be pumped once every two years). This is an increase of 0.4 percent to 2 percent
(averaging 1 percent) over current prices for tank pumping, based on the range of prices and
average price discussed above. Thus even if prices per pumping increase to an average of $70.78
(the existing price of $70 plus the additional $0.78, or still about $35 per year per household), the
cost of septage tank pumping will be considerably less, on ave'rage, than typical per-household
charges for sewage treatment at POTWs. EPA's User Fee Survey (EPA, 1989) indicates that the
average household charge (before Part 503 compliance costs are considered) for sewage
treatment is $151 per year (in 1992 dollars). Thus, assuming complete cost passthrough,
household costs of maintaining septic systems after compliance with Part 503 are only about 23
percent of the average household charge for sewage treatment. EPA believes that homeowners
will not be very sensitive to cost increases of this magnitude.
Given the relative inelasticity of demand and the relatively small cost per household
potentially passed through, EPA believes generally that the longer-term impacts may be even less
significant. However, because of the Agency's concerns about potentially severe impacts on the
smallest septage haulers currently practicing surface disposal resulting from the possibility of
short-term elasticity of demand, combined with a longer-term inelastic demand, an analysis of the
net present value (NPV) of this model firm is presented below. This analysis assumes that
domestic septage haulers increase their prices and homeowners forestall septage tank pumping
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for the first two years, leading to 30 percent (first year) and 15 percent (second year) reductions
in numbers of tanks pumped. Business is then assumed to rebound in the third year as
homeowners pump their tanks because of capacity problems. From year three to year ten, total
tanks pumped annually are 100 percent of baseline. The analysis further assumes a real discount
rate of 8 percent (12 percent minus 4 percent inflation) over a 10-year period and a federal plus
state tax rate of 33 percent. The results of the analysis are presented as reductions in net
present value for the model firm using the revenue decline scenario.
The NPV of revenues minus the NPV of expenditures is calculated assuming all
expenditures are fixed, and the compliance cost increase is fixed as well, i.e., not proportional to
tanks pumped (a conservative assumption). In the baseline (current expenditures and revenues),
the NPV of expenditures is $529 and the NPV of revenues is $901, leading to an NPV of
revenues minus expenditures of $372. The NPV of after-tax profits is $249. After Part 503 takes
effect, the NPV of expenditures becomes $652 and the NPV of revenues becomes $736, leading
to an NPV of revenues minus expenditures of $84. The NPV of after-tax profits is estimated at
$57. Thus, according to this analysis, profits decline somewhat after Part 503 is implemented, at
least for a few years, but the NPV of revenue minus the NPV of costs never becomes negative.
EPA therefore concludes that no domestic septage hauling firm is likely to close as a result of
Part 503 requirements.
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REFERENCES TO SECTION FIVE
U.S. EPA. 1989. National Wastewater User Fee Study. Draft. Office of Water Standards and
Regulations, U.S. EPA, December 1989.
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SECTION SIX
POPULATION RISK ASSESSMENT AND BENEFITS OF
THE PART 503 REGULATION GOVERNING THE USE OR DISPOSAL
OF SEWAGE SLUDGE1
6.1 GENERAL FRAMEWORK FOR RISK-BASED BENEFIT ANALYSIS
This section discusses current EPA methods and established Agency policy for performing
a risk assessment. This process was outlined originally by the National Academy of Sciences
(NAS, 1983) and was established as final Risk Assessment Guidelines in the Federal Register
(U.S. EPA, 1986a). Five types of guidelines were issued:
• Guidelines for Carcinogen Assessment
• Guidelines for Estimating Exposure
• Guidelines for Mutagenicity Risk Assessment
• Guidelines for Health Effects of Suspect Developmental Toxicants
• Guidelines for Health Risk Assessment of Chemical Mixtures
The Risk Assessment Methodology consists of four distinct steps: hazard identification,
dose-response evaluation, exposure evaluation, and characterization of risks.
6.1.1 Hazard Identification
The primary purposes of hazard identification are to determine whether the chemical
poses a hazard and whether there is sufficient information to perform a quantitative risk
"Much of the information in this section was developed by Abt Associates as part of their
work on the aggregate risk assessment. See the document, Human Health Risk Assessment for
the Use and Disposal of Sewage Sludge: Benefits of Regulation for a more detailed discussion
of the issues presented here.
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assessment. Hazard identification consists of gathering and evaluating all relevant data that help
determine whether a pollutant poses a specific hazard, then qualitatively evaluating those data on
the basis of the type of health effect produced, the conditions of exposure, and the metabolic
processes that govern chemical behavior within the body. Thus, the goals of hazard identification
are to determine whether it is appropriate scientifically to infer that effects observed under one
set of conditions (e.g., in experimental animals) are likely to occur in other settings (e.g., in
human beings), and whether data are adequate to support a quantitative risk assessment.
The first step in hazard identification is gathering information on the toxic properties of
chemical substances. The principal methods are animal studies and controlled epidemiological
investigations of exposed human populations.
The use of animal toxicity studies is based on the longstanding assumption that effects in
human beings can be inferred from effects in animals. There are three categories of animal
bioassays: acute exposure tests, subchronic tests, and chronic tests. The usual starting point for
such investigations is the study of acute toxicity in experimental animals. Acute exposure tests
expose animals to high doses for short periods of time, usually 24 hours or less. The most
common measure of acute toxicity is the lethal dose (LDSO), the average dose level that is lethal
to 50 percent of the test animals. LDSO refers to oral doses. LC50 designates the inhalation dose
at which 50 percent of the animals exposed died. LCSO is also used for aquatic toxicity tests and
refers to the concentration of the test substance in the water that results in 50 percent mortality
in the test species. Substances exhibiting a low LD50 (e.g., for sodium cyanide, 6.4 mg/kg) are
more acutely toxic than those with higher values (e.g., for sodium chloride, 3,000 mg/kg)
(NIOSH, 1979).
Subchronic tests for chemicals involve repeated exposures of test animals for 5 to 90 days,
depending on the animal, by exposure routes corresponding to human exposures. These tests are
used to determine the No Observed Adverse Effect Level (NOAEL), the Lowest Observed
Adverse Effect Level (LOAEL), and the Maximum Tolerated Dose (MTD). The MTD is the
largest dose a test animal can receive for most of its lifetime without demonstrating adverse
effects other than cancer. In studies of chronic effects of chemicals, test animals receive daily
doses of the test agent for approximately 2 to 3 years. The doses are lower than those used in
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acute and subchronic studies, and the number of animals is larger because these tests are trying
to detect effects that will be observed in only a small percentage of animals.
The second method of evaluating health effects uses epidemiology—the study of patterns
of disease in human populations and the factors that influence these patterns. In general,
scientists view well-conducted epidemiological studies as the most valuable information from
which to draw inferences about human health risks. Unlike the other approaches used to
evaluate health effects, epidemiological methods evaluate the direct effects of hazardous
substances on human beings. These studies also help identify human health hazards without
requiring prior knowledge of disease causation, and they complement the information gained
from animal studies.
Epidemiological studies compare the health status of a group of persons who have been
exposed to a suspected causal agent with that of a comparable nonexposed group. Most
epidemiological studies are either case-control studies or cohort studies. In case-control studies,
a group of individuals with specific disease is identified (cases) and compared with individuals
not having the disease (controls) in an attempt to ascertain commonalities in exposures they may
have experienced in the past. Cohort studies start with a group of people (a cohort) considered
free of the disease under investigation. The health status of the cohort known to have a
common exposure is examined over time to determine whether any specific condition or cause of
death occurs more frequently than might be expected from other causes.
Epidemiological studies are well suited to situations in which exposure to the risk agent is
relatively high; the adverse health effects are unusual (e.g., rare forms of cancer); the symptoms
of exposure are known; the exposed population is clearly defined; the link between the causal
risk agent and adverse effects in the affected population is direct and clear; the risk agent is
present in the bodies of the affected population; and high levels of the risk agent are present in
the environment.
The next step in hazard identification is to combine the pertinent data to ascertain the
degree of hazard associated with each chemical. In general, EPA uses different approaches for
qualitatively assessing the risk or hazard associated with, carcinogenic versus noncarcinogenic
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effects. For noncarcinogcnic health effects (e.g., mutagenic effects, systemic toxicity), the
Agency's hazard identification/wcight-of-evidcncc determination has not been formalized and is
based on a qualitative assessment.
EPA's guidelines for carcinogenic risk assessment (U.S. EPA, 1986a) group all human
and animal data reviewed into the following categories based on degree of evidence of
carcinogcnicity:
• Sufficient evidence.
• Limited evidence (e.g., in animals, an increased incidence of benign tumors only).
• Inadequate evidence.
• No data available.
• No evidence of carcinogenicity.
Human and animal evidence of carcinogenicity in these categories is combined into the
following wcight-of-evidcnce classification scheme:
• Group A—Human carcinogen
• Group B—Probable human carcinogen
Bl—Higher degree of evidence
B2—Lower degree of evidence
• Group C—Possible human carcinogen
• Group D—Not classifiable as to human carcinogenicity
• Group E—Evidence of noncarcinogenicity
Group B, probable human carcinogens, is usually divided into two subgroups: Bl,
chemicals for which there is some limited evidence of carcinogenicity from epidemiology studies;
and B2, chemicals for which there is sufficient evidence from animal studies but inadequate
evidence from epidemiology studies. EPA treats chemicals classified in categories A and B as
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suitable for quantitative risk assessment. Chemicals classified as Category C receive varying
treatment with respect to dose-response assessment, and they are determined on a case-by-case
basis. Chemicals in Groups D and E do not have sufficient evidence to support a quantitative
dose-response assessment.
The following factors are evaluated by judging the relevance of the data for a particular
chemical:
• Quality of data.
• Resolving power of the studies (significance of the studies as a function of the
number of animals or subjects).
• Relevance of route and timing of exposure.
• Appropriateness of dose selection.
• Replication of effects.
• Number of species examined.
• Availability of human epidemiologic study data.
Although the information gathered during the course of identifying each chemical hazard
is not used to estimate risk quantitatively, hazard identification enables researchers to
characterize the body of scientific data in such a way that two questions can be answered:
(1) Is a chemical a hazard? and (2) Is a quantitative assessment appropriate? The following two
sections discuss how such quantitative assessments are conducted.
6.1.2 Dose-Response Evaluation
Estimating the dose-response relationships for the chemical under review is the second
step in the risk assessment methodology. Evaluating dose-response data involves quantitatively
characterizing the connection between exposure to a chemical (measured in terms of quantity
and duration) and the extent of toxic injury or disease. Most dose-response relationships are
estimated based on animal studies, because even good epidemiological studies rarely have
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reliable information on exposure. This discussion, therefore, focuses primarily on dose-response
evaluations based on animal data.
There are two general approaches to dose-response evaluation, depending on whether the
health effects arc based on threshold or nonthreshold characteristics of the chemical. In this
context, thresholds refer to exposure levels below which no adverse health effects are assumed to
occur. For effects that involve altering genetic material (including carcinogenicity and
mutagenicity), the Agency's position is that effects may take place at very low doses, and they are
therefore modeled with no thresholds. For most other biological effects, it is usually (but not
always) assumed that "threshold" levels exist.
For nonthreshold effects, the key assumption is that the dose-response curve for such
chemicals exhibiting these effects in the human population achieves zero risk only at zero dose.
A mathematical model is used to extrapolate response data from doses in the observed
(experimental) range to response estimates in the low-dose ranges. Scientists have developed
several mathematical models to estimate low-dose risks from high-dose experimental risks. Each
model is based on general theories of carcinogenesis rather than on data for specific chemicals.
The choice of extrapolation model can have a significant impact on the dose-response estimate.
For this reason, the Agency's cancer assessment guidelines recommend the use of the multistage
model, which yields estimates of risk that are conservative, representing a plausible upper limit of
risk. With this approach, the estimate of risk is not likely to be lower than the true risk (U.S.
EPA, 1986a).
The potency value, referred to by the Carcinogenic Assessment Group as q^, is the
quantitative expression derived from the linearized multistage model that gives a plausible upper-
bound estimate to the slope of the dose-response curve in the low-dose range. The q," is
expressed in terms of risk-per-dose, and has units of (mg/kg'day)"1. These values should be used
only in dose ranges for which the statistical dose-response extrapolation is appropriate. EPA's
q," values can be found in the Integrated Risk Information System (IRIS), accessible through the
National Library of Medicine.
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Dose-response relationships are assumed to exhibit threshold effects for systemic
toxicants or other compounds exhibiting noncarcinogenic, nonmutagenic health effects. Dose-
response evaluations for substances exhibiting threshold responses involve calculating what is
known as the Reference Dose (oral exposure) or Reference Concentration (inhalation exposure),
abbreviated to RfD and RfC, respectively. This measure is used as a threshold level for critical
noncancer effects below which a significant risk of adverse effects is not expected. The RfDs and
RfCs developed by EPA can be found in IRIS.
The RfD/RfC methodology uses four experimental levels: No Observed Effect Level
(NOEL), No Observed Adverse Effect Level (NOAEL), Lowest Observed Effect Level (LOEL),
or Lowest Observed Adverse Effect Level (LOAEL). Each level is stated in mg/kg»day, and all
the levels are derived from laboratory animal and/or human epidemiology data. When the
appropriate level is determined, it is then divided by an appropriate uncertainty (safety) factor.
The magnitude of safety factors varies according to the nature and quality of the data from
which the NOAEL or LOAEL is derived. The safety factors, ranging from 100 to 10,000, are
used to extrapolate from acute to chronic effects, interspecies sensitivity, and variation in
sensitivity in human populations. They are also used to extrapolate from a LOAEL to a NOAEL.
Ideally, for all threshold effects, a set of route-specific and effect-specific thresholds should be
developed. If information is available for only one route of exposure, this value is used in a
route-to-route extrapolation to estimate the appropriate threshold. Once these values are
derived, the next step is to estimate actual human (or animal) exposure.
6.13 Exposure Evaluation
Exposure evaluation uses data concerning the nature and size of the population exposed
to a substance, the route of exposure (i.e., oral, inhalation, dermal), the extent of exposure
(concentration times time), and the circumstances of exposure.
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There are two ways of estimating environmental concentrations:
• Directly measuring levels of chemicals (monitoring)
• Using mathematical models to predict concentrations (modeling)
In addition, an analysis of population exposure is necessary.
6.1.3.1 Monitoring
Monitoring involves collecting and analyzing environmental samples. These data provide
the most accurate information about exposure. The two kinds of exposure monitoring are
personal monitoring and ambient (or site) monitoring.
Most exposure assessments are complicated by the fact that human beings move from
place to place and are therefore exposed to different risk agents throughout the day. Some
exposure assessments attempt to compensate for this variability by personal monitoring. Personal
monitoring uses one or more techniques to measure the actual concentrations of hazardous
substances to which individuals are exposed. One technique is sampling air and water. The
amount of time spent in various microenvironments (i.e., home, car, or office), may be combined
with data on environmental concentrations of risk agents in those microenvironments to estimate
exposure.
Personal monitoring may also include the sampling of human body fluids (e.g., blood,
urine, or semen). This type of monitoring is often referred to as biological monitoring or
biomonitoring. Biological markers (also called biomarkers) can be classified as markers of
exposure, of effect, and of susceptibility. Biological markers of exposure measure exposure either
to the exogenous material, its metabolite(s), or to the interaction of the xenobiotic agent with the
target cell within an organism. An example of a biomarker of exposure is lead concentration in
blood. In contrast, biological markers of effect measure some biochemical, physiologic, or other
alteration within the organism that points to impaired health. (Sometimes the term
biomonitoring is also used to refer to the regular sampling of animals, plants, or microorganisms
6-8
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in an ecosystem to determine the presence and accumulation of pollutants, as well as their effects
on ecosystem components.)
Ambient (or site) monitoring involves collecting samples from the air, water, soil, or
sediments at fixed locations, then analyzing the samples to determine environmental
concentrations of hazardous substances at the locations. Exposures can be further evaluated by
modeling the fate and transport of the pollutants.
6.1.3.2 Modeling
Measurements are a direct and preferred source of information for exposure analysis.
Such measurements are expensive, however, and are often limited geographically. The best use
of such data is to calibrate mathematical models that can be more widely applied. Estimating
concentrations using mathematical models must account not only for physical and chemical
properties related to fate and transport, but must also document mathematical properties (e.g.,
analytical integration vs. statistical approach), spatial properties (e.g., one, two, or three
dimensions), and time properties (steady-state vs. nonsteady-state).
Hundreds of models for fate, transport, and dispersion from the source are available for
all media. Models can be divided into five general types by media: atmospheric models, surface-
water models, ground-water and unsaturated-zone models, multimedia models, and food-chain
models. These five types of models are primarily applicable to chemicals or to radioactive
materials associated with dusts and other particles.
Selecting a model for a given situation depends on the following criteria: capability of
the model to account for important transport, transformation, and transfer mechanisms; fit of the
model to site-specific and substance-specific parameters; data requirements of the model,
compared to availability and reliability of offsite information; and the form and content of the
model output that allow it to address important questions regarding human exposures.
-------
To the extent possible, selection of the appropriate fate and transport model should
follow guidelines specified for particular media where available; for example, the Guidelines on
Air Quality Models (U.S. EPA, 1986b).
6.1.3.3 Population Analysis
Population analysis involves describing the size and characteristics (e.g., age/sex
distribution), location (e.g., workplace), and habits (e.g., food consumption) of potentially
exposed human and nonhuman populations. Census and other survey data often are useful in
identifying and describing populations exposed to a chemical.
Integrated exposure analysis involves calculating exposure levels, along with describing the
exposed populations. An integrated exposure analysis quantifies the contact of an exposed
population to each chemical under investigation via all routes of exposure and all pathways from
the sources to the exposed individuals. Finally, uncertainty should be described and quantified to
the extent possible.
6.1.4 Risk Characterization
This final step in the risk assessment methodology involves integrating the information
developed in hazard identification, dose-response assessment, and exposure assessment to derive
quantitative estimates of risk. Qualitative information should also accompany the numerical risk
estimates, including a discussion of uncertainties, limitations, and assumptions. It is useful to
distinguish methods used for chemicals exhibiting threshold effects (i.e., most noncarcinogens)
from those believed to lack a response threshold (i.e., carcinogens).
For carcinogens, individual risks are generally represented as the probability that an
individual will contract cancer in a lifetime as a result of exposure to a particular chemical or
group of chemicals. Population risks are usually estimated based on expected or average
exposure scenarios (unless information on distributions of exposure is available). The number of
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persons above a certain risk level, such as 10"6, or above a series of risk levels (10'5, 10"4, etc.), is
another useful descriptor of population risks. Thus, individual risks also may be presented using
cumulative frequency distributions, where the total number of people exceeding a given risk level
is plotted against the individual risk level.
For noncarcinogens, dose-response data above the threshold are usually lacking.
Therefore, risks are characterized by comparing the dose or concentration to the threshold level,
using a ratio in which the dose is placed in the numerator and the threshold in the denominator.
Aggregate population risks for noncarcinogens can be characterized by the number of people
exposed above the RfD or RfC. Recall that the hazard identification step for threshold
chemicals is addressed qualitatively because no formal Agency weight-of-evidence evaluation is
currently available for noncarcinogenic chemicals. The same approach can be used to assess
both acute and chronic hazards. For assessing acute effects, the toxicity data and exposure
assessment methods must account for the appropriate duration of exposure.
6.2 APPLICATION OF RISK-BASED METHODOLOGY TO SEWAGE SLUDGE USE OR
DISPOSAL
6.2.1 Health Effects Information
This section identifies the potential adverse health effects that might be associated with
chronic exposure to the sewage sludge pollutants of concern. Both qualitative (hazard
identification) and quantitative (dose-response assessments) data, where available and applicable,
have been used.
Three principal sources of information were used to obtain the health effects of the
sewage sludge pollutants of concern. EPA's Integrated Risk Information System (IRIS) was the
primary source. For those chemicals not yet included in the IRIS system, CAG and EPA's
Environmental Criteria and Assessment Office (ECAO) were contacted directly to obtain the
needed values. A third source was the EPA/OWRS technical support document for the relevant
chemical/sewage sludge disposal practice.
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Table 6-1 presents the sewage sludge pollutants that are known or suspected carcinogens
with their qualitative (hazard identification) evaluation of weight-of-evidence and the appropriate
q,* (dose response) value (see Section 6.1). Table 6-1 also presents the RfD values for each
relevant sewage sludge pollutant. These RfDs are used as threshold levels for critical
noncarcinogenic effects. A significant risk of adverse effects is not expected at intake levels
below the RfD. Note that for noncarcinogenic effects, EPA has not established a formal weight-
of-evidence classification system. Thus, the hazard identification process for noncarcinogens is
more qualitative than that for carcinogens.
For lead and cadmium, human health impacts were estimated in a slightly different way.
For these two pollutants, sufficient data are available to support improved methods of predicting
adverse health effects. Estimating the health effects of lead or cadmium involves predicting the
concentration of the pollutant in body tissues of exposed individuals; this "body burden" is in turn
affected by levels of environmental exposure. For lead, body burden is typically measured as the
concentration of lead in an individual's blood (jig/dL); for cadmium, it is measured as the
concentration of cadmium accumulated in an individual's kidney tissues (j*g/g). For both metals,
data are available (1) to describe background levels of tissue concentrations in the U.S.
population, (2) to link levels of environmental exposure to expected increments in these tissue
concentrations, and (3) to link tissue concentrations to possible or expected health consequences.
For lead, data to connect health effects with background levels of lead in blood (blood-
lead levels) are available for men, women, and children. Adverse fetal effects from lead have
been detected statistically for women with blood-lead levels as low as 10 jtg/dL; neurological and
developmental effects have been detected in children with blood-lead levels between 10 and 15
/ig/dL. For white men aged 40 and 59, increases in blood-lead levels have been found to be
associated with increased blood pressure at blood-lead levels as low as 7 jtg/dL. "Threshold"
values of 7,10, and 10 /tg/dL were therefore selected to represent blood-lead levels above which
men, women, and children, respectively, might be adversely affected by lead exposure.
Similarly, data connecting elevated cadmium levels in the kidney with health effects are
available for both smokers and nonsmokers in the United States. Adverse health effects from
cadmium have been observed in adults with kidney cadmium levels exceeding 200 jtg/g. A
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TABLE 6-1
SUMMARY OF HEALTH EFFECTS DATA FOR
SEWAGE SLUDGE POLLUTANTS OF CONCERN
Pollutant
Aldrin/Dieldrin
Arsenic
BEHP
Benzene
Benzidine
Benzo (a)py rene
Beryllium
Cadmium
Carbon Tetrachloride
Chlordane
Chloroform
Chromium
Copper
DDT
n-Nitrosodimethylamine
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Lead
Lindane
Mercury
Molybdenum
Nickel
Carcinogens
Weight of
Evidence
B2
A
B2
A
A
B2
B2
Bl
B2
B2
B2
A
—
B2
B2
B2
B2
C
—
B2
—
—
A
qt* Value
(ing/kg/day)-!
1.7 x 101
1.75 x 10°
1.4 xlO'2
2.9 x ID'2
2.30 x 102
7.3 x 10°
7.0 x 10°
5 x lO'4
1.3 x ID'1
1.3 x 10°
6.1 x ID'3
4.1 x 101
7.0 x 10'2
3.4 x ID'1
" 5.1 x 101
4.5 x 10°
1.6 x 10°
7.8 xlO'2
—
1.3 x 10°
—
—
1.7 x 10°
Noncarcinogens
RfD Value
(mg/kg/day)
3.0 x ID'5
3.0 x lO'4
2.0 x ID'2
—
3.0 x ID'3
—
5.0 xlO'3
5.0 x ID'4
7.0 x 10'4
6.0 x 10-5
'
5.0 x ID'3
5.0 x lO'3
5.0 x ID'4
—
5.0 x ID'4
—
2.0 xlO'3
a
3.0 x ID'4
3.0 x ID'4
5.0 xlO'3
2.0 x 10'2
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TABLE 6-1 (cont.)
Pollutant
PCBs
Selenium
Trichloroethylcne
Toxaphcnc
Vinyl Chloride
Zinc
Carcinogens
Weight of
Evidence
B2
—
B2
B2
A
—
q,* Value
(mg/kg/day)-l
7.7 x 10°
—
1.3 x ID'2
(inh.)
1.1 x 10-2
(ing-)
1.1 x 10°
1.9x10°
—
Noncarcinogens
RfD Value
(mg/kg/day)
—
4.5 x 1C'3
—
~
2.0 x lO'1
"Lead threshold values: males. 7 /ig/dL; females, 10 /ig/dL, children, 10
Source: Abt Associates estimates.
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"threshold" value of 200 jig/g was therefore used in estimating potential health effects from
cadmium.
From these data, the numbers of persons with cadmium and lead levels exceeding these
threshold values as a result of background exposures from sources other than sewage sludge were
calculated. The incremental increase in the levels of cadmium and lead in the kidney or blood
that could be attributed to sewage sludge use or disposal practices was then predicted.
The number of persons whose blood levels exceeded the thresholds for cadmium and
lead because of the use or disposal of sewage sludge was determined by subtracting the original
number of persons whose blood levels exceeded the thresholds from the number of persons
whose blood levels exceeded the threshold after the use or disposal of sewage sludge. The key
parameters in this analysis were background mean tissue concentrations, the coefficients of
variation, the incremental increase in body burdens of cadmium and lead caused by sewage
sludge use or disposal practices, and the lead or cadmium levels that might cause a health effect.
The "threshold" approaches described above were used to predict the number of exposed
individuals who might be vulnerable to adverse health effects as a result of exposure to cadmium
or lead from sewage sludge use or disposal. But not all of the individuals with lead or cadmium
levels above the selected thresholds would be expected to experience actual health effects. In
assessing health risks from lead, additional techniques were used to estimate the number of
individuals likely to suffer the effects under consideration. For white males, for example, results
from estimates of diastolic blood pressure versus blood-lead levels were used to relate shifts in
average blood-lead levels to expected increases in the numbers of men with high blood pressure.
As expected, the number of individuals expected to have high blood pressure as a result of lead
exposure from sewage sludge is smaller than the number of individuals exceeding 7 jig/dL blood
lead as a result of sewage sludge disposal. Similar methods were used to estimate other health
effects from lead use or exposure, and results were used to supplement those from the
"threshold" approaches.
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6.2.2 Limitations/Uncertainty
Several limitations affect the results of predicted benefits. Certain exposure pathways,
contaminants, or effects are excluded from the analysis, resulting in undercounted benefits. The
reasons for these exclusions are discussed below.
Most importantly, ecological effects are not quantified in either the baseline or benefits
analysis. Although some methodologies do exist for quantifying ecological effects, these typically
use indices rather than actual damage measurements. Because many uncertainties and data gaps
then become apparent, it is difficult to express results meaningfully. Consequently, ecological
effects are not examined quantitatively, but are reviewed qualitatively.
Another important limitation is that risks from pathogenic organisms are not included in
total risks. EPA plans to regulate pathogens using a technology-based approach; however, the
methodology for quantifying pathogenic risks is not complete. As a consequence, the baseline
risks and benefits of controlling pathogenic organisms have not been estimated.
The third way in which benefits might have been understated is by omitting certain
exposure pathways. For example, the removal and disposal of sewage sludge incinerator ash and
the deposition of incinerator pollutants on crop land and surface waters were not analyzed. All
these pathways could contribute to some additional baseline risk. Thus, to the extent that the
risk of exposure through these pathways could be reduced by the proposed regulation, benefits
will be undercounted.
In addition to these exclusions, there are further limitations and sources of uncertainty in
the overall analysis. Most of these limitations are specific to a particular disposal practice and
will be discussed in the relevant sections on risk assessment and benefits for each disposal
method. A few generic issues affecting the risk calculations of all disposal methods are
highlighted below.
First, it was not possible to perform site-specific analyses for any of the disposal methods,
with the exception of incineration. In part, this was because of insufficient data. Also, in the
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case of land application, for example, the number of sites made site-specific modeling
impractical. As a result, typical scenarios using averaged values of worst-case scenarios are
modeled. Second, contaminant concentrations are available for only a small set of POTWs.
These cross-sections of pollutants are assumed to be representative of the overall quality of
sewage sludge, although the selection of POTWs at which to sample sewage sludge was not based
on sewage sludge quality.
In addition to the concerns addressed above, several other problems are inherent in the
analysis. Population exposure estimates are generally limited since neither population growth nor
mobility are considered. Other behavior aspects of exposure, such as time spent indoors versus
outdoors, are not considered in the analysis. Moreover, timing of the exposure is not considered.
This last factor is especially relevant in the analysis of surface disposal, where exposure may not
occur for 200 years or more.
Despite these uncertainties, the approach used in this analysis provides a framework that
can relate regulatory action to environmental benefit. The use of sophisticated analytical tools
and the access to the "best" databases available ensure that the risk calculations presented in this
RIA represent meaningful predictions of human health risk.
6.3 RISK ASSESSMENT AND BENEFITS OF ANALYSIS OF THE THREE SEWAGE
SLUDGE USE OR DISPOSAL PRACTICES
6.3.1 Land Application
6.3.1.1 Analytical Methodology
Land application of municipal sewage sludge can cause pollution of ground water and risk
to human beings who use the contaminated ground water as their drinking water supply. It can
also lead to exposure through inhalation of organic contaminants volatilizing from the treated
land. When agricultural land is treated with sewage sludge, human beings are potentially
exposed through dietary pathways If pollutants from the sewage sludge are taken up into the
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tissues of crops growing on treated soil. Farm animals can ingest grain or pasture grasses from
land treated with sewage sludge; if human beings then ingest meat, eggs or dairy products from
the affected animals, they can be exposed indirectly to pollutants in sewage sludge. Finally,
surface-water bodies can be contaminated if treated soil erodes from sewage sludge management
areas to nearby surface water bodies. Human beings drinking the water or ingesting fish caught
in the contaminated stream or lake are potentially exposed. This analysis estimates total health
risks for individuals exposed through ground-water, surface-water, inhalation, and dietary
pathways from the application of sewage sludge to both agricultural and nonagricultural land.
In cases where sewage sludge is used on residential lawns or gardens, members of
households using sewage sludge as a soil conditioner for vegetable gardens might be exposed
through the ingestion of home-grown foods. In addition, young children might be exposed
through inadvertent ingestion of sewage sludge-amended soil. Exposure and risk through these
pathways is also considered for the analysis of aggregate risks.
To establish a baseline estimate of exposure and risk, EPA performed calculations based
on current estimates of the quantity and quality of land-applied sewage sludge and estimates of
the size of populations currently exposed. Because most POTWs are expected to comply with
the regulation under baseline conditions, the reduction in health risks to be achieved by the
regulation is expected to be significantly lower than the baseline estimate.
Data Sources
EPA estimated exposure and risk from the air, ground-water and surface-water pathways
for land application using mathematical models that require data on local geological,
hydrological, and meteorological conditions; the location of human populations; the dimensions
of treated areas; the quantity and quality of sewage sludge applied; and dose-response data for
each pollutant. Because several thousand POTWs are believed to use land application to
manage their sewage sludge, because the sewage sludge from each of these POTWs might be
applied to multiple sites, and because site-specific data sufficient for realistic modeling are
difficult to obtain for individual sites, this analysis uses a single set of physical parameters for
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simulating the migration of pollutants into ground water, surface water, ambient air, or crop
tissues. In general* the analysis uses a mix of typical and reasonable worst-case values for input
parameters to model the movement of sewage sludge pollutants into ground water, surface water,
air, and crop and animal tissues. Only three types of parameters—site dimensions, sewage sludge
quality, and the density of human populations—are allowed to differ by site. Values for these
parameters reflect site-specific conditions for the sample of land-applying POTWs in the analytic
component of the NSSS. EPA obtained data on the density of drinking water wells and human
populations from a data base maintained by the National Water Well Association for counties
containing individual sites.
For the dietary pathways of human exposure, EPA calculated exposure and risks using
assumptions about the quantity and mix of foods consumed by exposed individuals. This analysis
relies on data from the Pennington (1983) revision of a total diet study by the U.S. Department
of Agriculture (USDA, 1972, 1982) as modified by U.S. EPA (1989c) to calculate a time-
weighted lifetime average rate of consumption for each food group.
Dose-response data for both carcinogens and noncarcinogens were obtained from the
IRIS data base, supplemented by additional sources where necessary. Epidemiological data were
incorporated into the analysis for the special cases of lead and cadmium exposure.
Modeling Ground-Water Contamination
EPA modeled ground-water contamination by using a computer model consisting of three
separate components. A mass-balance module partitions pollutant losses from treated soil into
fractions lost to ground water, surface runoff, volatilization, and degradation.2 A second
module, the VADOFT component of the RUSTIC model (U.S. EPA, 1989d) simulates the
movement of pollutants from the bottom of the sewage sludge incorporation zone through the
unsaturated soil zone. The AT123D model (Yen, 1981) then simulates the lateral transport of
2A negligible fraction is assumed lost to plant uptake.
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pollutants to the downgradient edge of the site. Details of the linked model are provided in U.S.
EPA (1990).
For the scenario used in model calculations, EPA conservatively assumed that the top of
the saturated soil zone (or water table) is within 1 meter (m) of the sewage sludge incorporation
zone. The mixing zone, unsaturated soil zone, and saturated soil zones are all characterized as
sand.
Modeling Surface-Water Contamination
As mentioned above, EPA used a mass-balance module in the computer model to
partition pollutant losses among competing processes, one of which is the loss of pollutant
through soil erosion. Based on the estimated rate at which soil is lost from the sewage sludge
management area and the surrounding watershed, EPA derived an estimate for the fraction of
stream sediment originating in the sewage sludge management area. This estimate, coupled with
assumptions about equilibrium partitioning of pollutants between adsorbed and dissolved phases
within the surface-water body, and assumptions about the uptake and bioaccumulation of
contaminant in fish tissues, is used to derive estimates for both the likely concentration of each
pollutant in fish tissue and the likely concentration of dissolved pollutant in the surface water.
Modeling Ambient Air Contamination
The Agency estimated the rate at which pollutants volatilize from a land application site
and integrated this estimate into the mass-balance calculations mentioned above using a
mathematical model provided by Hwang and Falco (1986). After it is released into the air, the
volatilized pollutant can be transported by wind to reach human populations. This transport is
modeled with a conservative simplification of the ISCLT gaussian-plume dispersion model
(Bowers et al., 1980) discussed in U.S. EPA (1989c).
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Modeling Contamination of Agricultural Produce
Concentrations of pollutants in the tissues of crops grown on sewage sludge-amended
land (including home gardens) are assumed to be proportional to concentrations in treated soil.
As for the uptake of pollutants into crop tissue, uptake from feeds or pasture into animal tissues
is assumed to be proportional to the concentration of pollutants in the animal's feed. Small
amounts of sewage sludge applied to pasture land (without incorporation into soil) are assumed
to be ingested directly by grazing animals, resulting in additional contamination of meat or dairy
products.
Exposure Assessment
The Agency performed three independent analyses of exposure and risk for land
application of municipal sewage sludge. The first considers the dietary pathway of exposure in
which produce grown with sewage sludge-amended land is distributed nationally. Over a lifetime
of exposure, a small fraction (estimated to be about 0.02 percent of national production) of the
food ingested by the average individual is assumed to originate from sewage sludge-amended
land. Similarly, animal products in the average diet will have been produced with feed grains or
pasture from both sewage sludge-amended land and other land. This mixing of foods is
considered in the calculations by proportionally reducing the expected concentrations of
pollutants in individual foods. To calculate aggregate risks, the entire U.S. population is assumed
to ingest food products with the pollutant concentrations thus calculated. Both exposure and
population size are held constant for a 70-year average life expectancy.
The Agency performed a separate analysis for exposure through the ground-water, air,
and surface-water pathways. Based on population densities in areas near individual sites in the
NSSS, the population expected to live within 3 km of a land application site was calculated, along
with the fraction of that population using ground water as drinking water. Results from the
modeling described above are combined with these populations to calculate average individual
and aggregate health risks through these pathways. EPA assumed that all persons living near a
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land application site are potentially exposed through the ingestion of fish and through
simultaneous exposure to the air and either the ground-water or surface-water pathways.
A third analysis considers aggregate risks from the use of sewage sludge for home
gardening. Based on assumptions about the quantity of sewage sludge used for this purpose, and
average application rates and garden sizes, EPA estimated the number of households affected.
The Agency then estimated aggregate risks by combining estimates of pollutant concentrations in
treated soil and garden produce with estimates of the number of adults and children likely to be
exposed.
Uncertainties and Limitations
EPA based its estimates of exposure and risk from land application of sewage sludge on
numerous assumptions, mathematical models, and parameter values. As with almost any
mathematical modeling effort, significant uncertainty surrounds many of these elements of the
analysis. In particular to the extent that geological, hydrological, and meteorological conditions
at the average land application site are not well represented by the conservative assumptions and
models used for this analysis, EPA's estimate of exposure through ground-water, surface- water,
and air pathways might not be realistic. Because of numerous worst-case assumptions used in
the modeling, estimates provided by this analysis are likely to overstate aggregate risks through
these pathways; true risks are likely to be significantly lower.
6.3.1,2 Baseline Risks from Land Application
Based on the methods and data summarized above, EPA estimates that fewer than one
incremental case of cancer per year is caused by land application under baseline conditions.
Estimated noncarcinogenic risks are expected to encompass about 500 cases of lead- or
cadmium-related disease expected per year under current conditions.
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6.3.1.3 Benefits of Controls
Because relatively few POTWs currently practicing land application are expected to be
affected by the regulation, the reduction in health risks expected from the regulation should be
significantly lower than the estimates of risks under baseline conditions. In other words, the
regulation is expected to achieve a health benefit significantly lower than one incremental case of
cancer per year and 500 cases of noncarcinogenic disease per year for POTWs currently using
land application.
6.3.2 Surface Disposal!
6.3.2.1 Analytical Methodology
The surface disposal of municipal sewage sludge can cause pollution of ground water and
subsequent risk to human beings who use the ground water for drinking. It can also lead to the
emission of volatile organic pollutants and result in exposure and risk to human beings who
inhale the contaminated air. EPA assumes that significant pollution of nearby surface-water
bodies is controlled by responsible management practices at surface disposal facilities; potential
exposure through this pathway is not considered in this analysis.
EPA has defined the term "surface disposal" broadly: the definition includes the disposal
of sewage sludge in waste piles, lagoons, sewage-sludge-only monofills, and other practices. EPA
defined two idealized prototypes to represent this mix of related management practices. As with
the analyses described in Section 6.3.1, this analysis uses the sample of POTWs in the analytic
component of the NSSS to represent the complete national inventory of this type of POTW.
Surface disposal POTWs in the NSSS have been assigned to these two categories as appropriate.
Based on the modeling of human exposure and risk for each of the approximately 26 POTWs
from the NSSS believed to practice surface disposal (not including those that were classified as
surface disposal based on their storage time), EPA derived estimates of individual arid
population risks for each site. Results were then scaled to the national level based on sample
weights from the NSSS, to estimate risks for an estimated 1,400 surface disposal facilities.
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Exposure and risk are estimated both before and after the regulation takes effect. Based
on several worst-case assumptions, this analysis provides an upper-bound estimate of probable
risks under current or baseline conditions. Because most POTWs are expected to comply with
the regulation under baseline conditions, the reduction in health risks to be achieved by the
regulation is expected to be significantly lower than this baseline estimate.
Data Sources
EPA estimated exposure and risk from surface disposal using mathematical models that
'require data for geological and meteorological conditions, dose-response data for each pollutant,
population data for the areas surrounding surface disposal sites, and physical characteristics (e.g.,
site dimensions) of surface disposal sites. Because reliable data could not be obtained for several
of the geological and meteorological parameters at some or all sites, reasonable worst-case
assumptions have been used to model the migration of pollutants into ambient air or ground
water.
Only three site-specific considerations were included in the analysis. Using data from the
analytic component of the NSSS, EPA based its calculations on the actual quality and quantity of
sludge generated by each modeled POTW. In addition, EPA used data obtained from the
National Water Well Association to determine the number of persons likely to rely on ground
water drawn near each individual POTW and the number of persons likely to be exposed
through inhalation. As mentioned in Section 6.3.1, those individuals living within 3 km of each
site were considered potentially exposed through ground-water and air pathways. The method
and assumptions for modeling potential exposure through the air pathway were based on a worst-
case simplification of the ISCLT model (Bowers et al., 1980) as described in U.S. EPA (1988).
EPA considered two types of health effects: carcinogenic and noncarcinogenic effects.
Risks of cancer were estimated using EPA's human cancer potency values. For noncarcinogens,
EPA determined risks by comparing exposure to RfD values. For lead and cadmium, EPA used
additional techniques to provide estimates of the number of persons crossing body-burden
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thresholds and the number of cases of disease likely to result from the surface disposal of sewage
sludge.
Modeling Ground-Water Contamination
As discussed in Section 6.3.1, EPA modeled ground-water pollution near sewage sludge
use or disposal sites using a computer code consisting of linked versions of VADOFT and
AT123D. The VADOFT module simulates the flow of both water and pollutants through the
unsaturated soil zone. The AT123D component simulates the lateral movement of pollutants
through the saturated soil zone. For surface disposal POTWs, EPA assumed that the site's fence
line prevents the use of ground water within the POTW's property (which extends 150 m beyond
the edge of the site). For all sites, the depth to ground water is conservatively assumed to be
one meter (typical depths for actual sites are much greater). EPA conservatively applied the
maximum pollutant concentrations estimated within the first 300 years at 150 m in the
downgradient direction from each POTW to the entire estimated population currently drawing
ground water within 1,000 m of the property's boundary. Similarly, EPA applied estimated
concentrations at 1,000 m to the population within 3,000 m.
Modeling Ambient Air Contamination
The emission of pollutants from surface disposal sites differs according to the type of site
being considered. For the surface impoundment prototype, emissions can arise from the
impoundment's liquid surface, which remains uncovered throughout the life of the site. For the
monofili prototype, emissions must arise from a mixture of sewage sludge and soil and are
limited by the application of a daily and ultimately permanent layer of cover soil. EPA modeled
emissions from the liquid surface of the impoundment prototype using a two-film resistance
model (Thomann and Mueller, 1987) and modeled emissions from the monofili prototype using a
model described in U.S. EPA (1988). The Agency estimated emissions both for uncovered
monofili cells and for those protected by daily and permanent cover. A weighted average of
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these estimates was then used to predict average emissions over the expected lifetime of exposed
individuals.
After estimating emissions, the Agency calculated expected concentrations of pollutants in
ambient air based on a conservative simplification of the ISCLT model (Bowers ct al., 1980) as
discussed in Environmental Science and Engineering (1985) and U.S. EPA (1986). The
concentrations were estimated at the property boundary (150 m from the edge of the site) and
conservatively extended to the entire human population living near the POTW.
Exposure Assessment
Next, the Agency combined estimates of the concentrations of metals and organic
pollutants in ground water and organic contaminants in ambient air with estimates for the density
of human populations surrounding each POTW. Based on data from the National Well Water
Association, the number of households served by public or private wells was determined for the
county containing each surface disposal site. This value, when multiplied by the average
household size and divided by the total area of the relevant county, provides an estimate of the
average density of populations using ground water in each county. EPA then multiplied the
estimated density by the area of land thought to be affected by each site (one-fourth the area of
a circle extended 3 km from the edge of each POTW) to derive an estimate for the size of the
exposed population. Similarly, the number of persons potentially exposed through the air
pathway was derived from average population densities for the county containing each POTW.
Uncertainties and Limitations
The Agency's analysis for surface disposal is based on numerous simplifying assumptions
(almost all of them conservative). To the extent that actual conditions at individual POTWs
differ from those assumed, true exposure and risk will differ from the estimates provided here.
For example, if the local depth to ground water exceeds 1 m, or if the hydraulic conductivity of
the local soil medium is less than that of sand, actual ground-water pollution beneath a surface
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disposal site is likely to be lower than that calculated in this analysis. Similarly, pollutant
concentrations in ground water at distances greater than 150 m in directions other than
downgradient are likely to be lower than those calculated for this analysis. On the other hand, a
nonhoraogeneous or fractured medium beneath a surface disposal site might lead to the ground-
water pollution at higher levels than those predicted by VADOFT and AT123D. Moreover, if
the number of persons drawing ground water near a surface disposal site exceeds the average
density calculated for the county as a whole, risks at these sites may be underestimated. Finally,
if the density of human populations or concentrations of pollutants in sewage sludge for other
surface disposal POTWs differs systematically from those predicted based on the analytic
component of the NSSS, risks might be underestimated. Nevertheless, estimates of exposure and
risk derived in this analysis are believed to be conservative and are believed unlikely to
underestimate true risks.
6.3.2.2 Baseline Risks from Surface Disposal
Under current conditions, EPA estimates that the use of surface disposal for municipal
sewage sludge will cause less than one incremental case of cancer or other disease annually.
Average exposure to contaminants from sludge is significantly lower than RfDs for every
noncarcinogenic contaminant considered in this analysis.
6.3.2.3 Benefits of Controls
Based on an analysis of POTWs in the analytic survey of the NSSS reporting the use of
surface disposal for their sewage sludge, EPA believes that a significant number of POTWs using
surface disposal are unlikely to be affected by the regulation. Regardless of how many POTWs
are affected, the potential reductions in health risks to be achieved by the regulation cannot
exceed the total risks under current conditions, thus the reductions are not expected to exceed
one incremental case of cancer or other disease.
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Incineration
6.3.3.1 Analytical Methodology
Emissions from municipal sewage sludge incinerators can cause health risks to human
beings who inhale emitted pollutants. In addition, the deposition of emitted pollutants in areas
surrounding incinerators can result in indirect exposure through dermal absorption, ingestion of
contaminated food and water, and direct ingestion of contaminated soil by children. These
indirect pathways of exposure, however, are not considered in this analysis. Likewise, risks from
the disposal of incinerator bottom ash and potential adverse effects on plant and animal life are
not addressed.
This analysis derives estimates of risks from the incineration of sewage sludge, both
before and after imposition of regulatory controls. All calculations are first completed for
current, or "baseline," conditions. Mathematical models are used to predict expected human
exposure and risk based on data describing the type of incinerator unit, quantity and quality of
sludge incinerated, local meteorological conditions, and the geographical distribution of nearby
human populations for each sewage sludge incinerator unit. Next, based on predicted responses
by individual POTWs to regulatory controls, all calculations are repeated to determine risks after
additional pollution controls arc installed at selected POTWs. The difference between these two
estimates represents the expected "benefits" (or reductions in health risks) to be achieved by the
regulation.
Data Sources
Modeling of exposure and risk from incineration requires four types of data. Data on the
quality and quantity of sludge incinerated at each POTW, the type of furnace and pollution
control devices used, and other physical characteristics of the sewage sludge incinerator unit are
required for estimating emissions. Meteorological data and the physical characteristics of the
incinerator facility are needed to model the transport of emitted pollutants in ambient air. Data
for the location of nearby populations are used KO determine human exposure. Finally, dose-
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response data are required to translate estimates of human exposure into estimates of aggregate
health risks.
Meteorological data were obtained from the Stability Array (STAR) data base included in
the Graphical Exposure Modeling System for Personal Computers, or PCGEMS (U.S. EPA,
1989a,b). These data include measurements of average wind velocity, direction, profiles, mixing
heights and stability categories at STAR stations (usually airports) throughout the United States.
Population data were obtained from the 1980 U.S. Census, at the Block Group/Enumeration
District (BG/ED) level. Data were retrieved through PC-GEMS, aggregated as necessary and
assigned to locations on a concentration grid.
Two types of health effects are considered: carcinogenic and noncarcinogenic effects.
Each carcinogenic pollutant is characterized by a human cancer potency estimated by the
Agency. These potency values, when multiplied by estimates of lifetime average exposure from
incineration, yield the estimated incremental risk that an exposed individual will develop cancer
as a result of exposure. For noncarcinogenic emissions, each pollutant's predicted exposure is
compared to its RfD, a threshold dose beneath which no adverse health effects are expected.
The primary source for health effects data for both types of contaminants is the IRIS database
maintained by the Agency. Some organic compounds detected in stack emissions are not
included in IRIS, however; for these, reference doses have been derived directly from health
effect studies. Because of the availability of additional epidemiological data for the effects of
exposure to lead and cadmium, special nonlinear dose-response relationships have been derived
for these two metals and are used to calculate expected health risks from exposure. For lead,
two types of effects are reported: the number of persons crossing "threshold" concentrations of
lead in the blood (7 /ig/dL for men and 10 /ig/dL for women and children) and the number of
expected cases of disease resulting from that exposure.
EPA performed a site-specific analysis of emissions and expected exposure for each of 23
incinerating POTWs included in the analytic component of the National Sewage Sludge Survey
(NSSS). Data describing the quality and quantity of sewage sludge and the incinerator units at
these POTWs were obtained from the NSSS, supplemented by additional data from the 1986
Needs survey. Additional data (excluding the quality of sewage sludge) were obtained for 149
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incinerating facilities not included in the analytic component of the NSSS. The Agency used
simulation modeling of emissions for these additional POTWs to consider the overlapping of
pollutant plumes when scaling results from the smaller subset of POTWs to the national level.
Grid Mapping System
To estimate human exposure and risk from incineration, EPA mapped the dispersion of
emitted pollutants onto human populations residing near each POTW. In addition, where
multiple POTWs operating sewage sludge incinerators were sited within relatively short distances
of each other, the Agency needed to consider the potential overlapping of pollutant plumes from
nearby incinerator facilities. Because of such overlap, particular populations might be
concurrently exposed to contaminated air from several incinerator facilities. These two aspects
of exposure were represented by mapping both dispersion and human populations onto a single
cartesian grid system covering the entire United States.
For this analysis, EPA assigned locations to each of the POTWs on a rectangular grid by
transforming the known latitude and longitude coordinates of each POTW into approximately
equivalent locations on a flat surface. The companion document entitled Human Health Risk
Assessment for the Use and Disposal of Sewage Sludge: Benefits of Regulation presents a more
detailed description of these transformations. The resulting grid covers the continental United
States with 4-km by 4-km cells. To provide sufficient resolution in areas close to incinerators,
EPA subdivided each grid cell containing an incinerator into a finer grid of 200-m by 200-m cells.
Dispersioiti Modeling
EPA used the Industrial Source Complex Long Term or ISCLT model (Bowers et al.,
1980) to model air dispersion; all incinerator stacks were modeled as point sources. For lack of
sufficient data, the Agency ignored the effects of surrounding terrain. In addition, EPA
conservatively assumed that no degradation of pollutants occurs during air transport. Estimates
of exposure were then prepared by matching expected concentrations with human populations.
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Estimated Emissions
Emission rates for metals were determined based on the quantity of sewage sludge
incinerated by individual POTWs, concentrations of each metal in that sewage sludge, and the
pollution control devices operating at each POTW. Sewage sludge from each of the 23
incinerating POTWs in the analytic component of the NSSS was tested for the presence of
metals. Based on data describing the type of furnaces and pollution control devices in use at
each of these POTWs and on measured concentrations of metals in each POTW's sewage sludge,
the rate of emissions for each of the ten metals of concern were estimated for each POTW. As
mentioned earlier, EPA used model simulations for an additional 149 POTWs not included in
the analytic component of the NSSS. Because POTW-specific data were not available for sewage
sludge pollutant concentrations associated with these POTWs, EPA used the average sewage
sludge quality for each flow rate group in the NSSS to approximate sewage sludge quality at
POTWs operating sewage sludge incinerator that were not surveyed in the analytical portion of
the NSSS. The Agency estimated quantities of sludge incinerated by these POTWs by scaling the
total quantity to the estimated quantity derived from the NSSS. For estimating emissions from
incinerators under current conditions, EPA assumed that all incinerator units currently operating
include a scrubber system for removing toxic metals.
At this time, no useful correlation has been identified between .the mix of organic
compounds entering a sewage sludge incinerator unit and the mix of organic compounds released
in stack emissions. For this analysis, emissions of organic pollutants are considered a function of
the sewage sludge feed rate and the type of furnace and are not related to the concentrations of
organic compounds in the incoming sewage sludge. Assumed profiles of emissions of organic
compounds are based on measurements obtained from seven actual sewage sludge incinerators.
Of these seven POTWs, five were multiple-hearth incinerators and two were fiuidized-bed
combustors. This distinction is important because the improved burning conditions in fluidized-
bed combustors effect more complete oxidation of organic compounds and minimize the creation
of products of incomplete combustion (PICs).
EPA derived a worst-case estimate of organic emissions by considering all compounds
analyzed in the monitoring studies. Compounds not detected at individual POTWs were
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assigned the appropriate detection limits. Where possible, each "nondetect" observation was
assigned the detection limit for the particular chemical tested; otherwise it was assigned values
from detection limits at other sites or for similar compounds. Based on the available sample of
measured (or assigned) values, EPA derived a 99th percentile confidence estimate for the average
emission rate of each pollutant at each multiple-hearth unit or fluidized-bed combustor. The
Agency further adjusted estimated emissions to account for additional organic contaminants not
tested. U.S. EPA (1987) suggests that "a significant portion (80 percent or more) of the organic
emissions from the stacks of municipal waste combustors have not been identified and quantified.
Although some portion of the mixture may be carcinogenic, the carcinogenic fraction, its
composition, and its potency remain unknown." If a similar fraction of emissions from sewage
sludge incinerators has not been identified or quantified, calculations based on known emissions
might understate true exposure and risk. To adjust for this possible error, EPA assumed that the
average cancer potency of these unknown compounds was comparable to that for the pollutants
evaluated. The Agency therefore increased the estimated health risks from incineration of
sewage sludge by a factor of five to derive a conservative estimate of total risk.
A less conservative and perhaps more realistic "best estimate" of organic emissions was
derived using a slightly different methodology. As before, all compounds analyzed for at least
one POTW sampled in the monitoring studies were included in the analysis. Samples with
concentrations beneath the limits of detection were assigned values corresponding to the
appropriate detection limit. For this second estimate the Agency based emission estimates on
the arithmetic mean of values tor the multiple samples taken for each furnace type. EPA did not
attempt to account for unknown carcinogenic compounds in incinerator emissions.
Exposure Assessment
EPA combined estimates of emissions for metal and organic pollutants with estimates of
the transport and dispersion of pollutants in ambient air and with data describing the residential
locations of human populations to derive estimates of human exposure. As mentioned earlier,
EPA integrated data and results by mapping incinerators, human populations, and pollutant
concentrations onto a unified cartesian grid. Pollutant-plume overlap is indicated when
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significant contributions of pollutant concentrations from more than one incinerator are
predicted for a single grid cell.
After concentrations of pollutants were estimated for each grid cell, individual risks were
estimated with dose-response data for cancer and other noncarcinogenic diseases. EPA
aggregated estimates of health risks to individuals in each grid cell to estimate total health risks
for the human population residing within the grid cell. Next, the Agency aggregated risks across
all grid cells to derive an estimate of total risk from the 23 incinerating POTWs included the
analytic component of the NSSS. Sample weights from the NSSS were used to scale all results to
the national level. The Agency considered the overlap of pollutant plumes using dispersion
modeling with the full set of 172 known incinerators.
Uncertainties and Limitations
Data for calculating average organic emissions were categorized by type of furnace
(multiple-hearth or fluidized-bed) and emission controls (i.e., whether an afterburner was
operating). The rate of emissions for each pollutant was determined based on the sewage sludge
feed rate (g/s emitted per kg/s sludge). Although information detailing the furnace conditions,
sewage sludge moisture content, and other parameters affecting the emissions was recorded for
the test sites, much less is known about the remainder of the incinerators in the modeled data
set. The use of a relatively small sample to represent emissions for other incinerators might
over- or underestimate actual emissions.
6.3.3.2 Baseline Risks from Incineration
Under current conditions, the annual incineration of an estimated 0.7 million dry metric
tons of sewage sludge at secondary and advanced treatment works is responsible for an estimated
incremental risk of about 0.3 to 4 cases of cancer per year. The higher of these two estimates is
based on the worst-case estimate of organic emissions discussed above; the lower value is based
on the alternative method for estimating emissions. Risks from exposure to metals account for
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approximately 0.07 cases each year, while between 0.3 and 4 cases are expected to result from
emissions of organic pollutants.
Based on worst-case assumptions for emissions, the highest estimated risks from
individual chemicals are 0.08 cases/yr from aldrin, 0.07 cases/yr from dieldrin, 0.07 cases from
cadmium, 0.01 cases from 2,3,4,7,8-pcntachlorodibenzofuran, and 0.006 cases/yr from
acrylonitrile. Aldrin and dieldrin were never actually detected in stack emissions, although
emissions were tested for these pollutants. The detection limits at each test site were used as an
upper bound on the emissions. The lifetime incremental cancer risk for a highly exposed
individual detected through the mathematical modeling is estimated to be 6x10"4 based on the
best estimate of emissions, or 7x10"3 based on worst-case estimates.
Aggregate noncarcinogenic effects are expressed as the number of persons exceeding the
RfD for each pollutant, or the ratio of exposure to RfDs when these levels were not exceeded.
Where available, background intake of pollutants from sources other than those associated with
sewage sludge use or disposal is included in the calculations. Typical background intakes for
metals are generally two or more orders of magnitude higher than those resulting from the
incineration of sewage sludge. The most significant contribution from sewage sludge is for
mercury, for which the intake resulting from incineration is less than 1 percent of the background
level. In general, the contribution to ambient levels of these metals is negligible.
Exposure to lead from the incineration of sewage sludge causes an estimated 100 cases of
noncarcinogenic disease per year. Of these cases more than 95 percent consist of additional
cases of hypertension expected in adult males. The remainder is caused by other cardiovascular
effects in adults and neurological developmental effects in children.
6.3,3.3 Benefits of Controls Resulting in Reduced Emissions
EPA analyzed the POTWs' individual responses to the regulation only for those 23
POTWs included in the analytic subset of the NSSS. To estimate risk under the new regulations,
all exposure and risk calculations were repeated after adjusting emissions from, each of these
6-34
-------
modeled POTWs to reflect the expected installation of additional pollution controls. For
simplicity, only one additional control technology was considered. To reduce emissions for
metals, a wet electrostatic precipitator was assumed to be installed; organic emissions are
assumed unchanged. EPA has determined that the Part 503 THC requirement can be met using
current technologies and practices (see Section Four). EPA scaled the estimates of exposure and
risk after installation of controls the national level based on dispersion results from the full
inventory of known incinerators and on sample weights from the NSSS. The Agency then
derived expected reductions in risk by subtracting these results from comparable estimates of
exposure and risk under baseline conditions.
With the regulation in place, risks from organic pollutants are minimally reduced.
Additional pollution controls reduce the number of persons crossing the lead threshold from
about 700 to about 90 and the associated number of disease cases from about 100 to about 30.
6.4 ENVIRONMENTAL AND OTHER BENEFITS
As discussed earlier, the environmental (i.e., nonhealth) benefits of controlling sewage
siudge use or disposal disposal could not be quantified. A qualitative discussion of these benefits
is presented below.
The regulation of sewage sludge use or disposal is expected to result in certain
environmental benefits in addition to the benefits associated with reducing the incidence of
adverse human health effects. Such environmental effects are an outgrowth of the general
reduction of the amount and toxicity of sewage sludge that are used or disposed of, particularly
that disposed in environmentally sensitive areas. These environmental benefits consist mainly of
improved habitats for wildlife and other species in the areas where the disposal or use practices
occur..
For example, changes in incineration practices are likely to provide some marginal
environmental gain for wildlife. In addition, emissions reductions in the vicinities of the
incinerators may reduce particulate and other chemical deposition on buildings, automobiles, and
6-35
-------
structures, providing for a reduction in the extent to which these items are damaged by air
pollution. Finally, commercial farms and home gardens located in deposition areas for affected
sludge incinerators may experience some gain in crop vitality resulting from lower levels of
pollutants that are discharged.
In addition to environmental benefits, the regulation may account for some cost savings
as well. Based on information from the analytical portion of the National Sewage Sludge Survey
(NSSS), representing a universe of 10,939 POTWs, currently 4,328 PO'TWs beneficially land
apply sewage sludge and 4,268 POTWs dispose of their sewage sludge using various disposal
practices such as surface disposal, codisposal, incineration, etc. (some of the disposers use both
disposal and land application; the remainder, which are POTWs accumulating sewage sludge in
treatment lagoons, do not dispose of sewage sludge frequently and their ultimate disposal
method is not known). Surface disposers total 1,936 POTWs, or 45 percent of these disposers;
co-disposers total 2,335 POTWs, or 55 percent of these disposers; and POTWs that incinerate
sewage sludge total 380 POTWs, or 9 percent of these disposers. Of the 4,268 POTWs that
dispose of their sewage sludge, 2,689 generage sewage sludge that can meet pollutant
concentration limits.
Many people have a misapprehension about the quality of sewage sludge, and farmers
may be reluctant to accept sewage sludge as a fertilizer because they are concerned about public
perceptions. If the POTWs currently disposing of sewage sludge can meet the pollutant
concentration limits, the POTW might be able to use this information as a marketing and public
relations tool. In this way, some of the barriers to sewage sludge land application may be
overcome. The fact that these POTWs' sewage sludge meets pollutant concentration limits could
be just the tool they need to make the shift to land application.
These 2,689 POTWs dispose of 1,020,000 dmt of sewage sludge annually, 187,000 dmt
going to surface disposal, 452,000 dmt going to co-disposal, and 381,000 dmt going to
incineration. It is not possible to determine how many would shift to land application based on
the way the NSSS is written. However, costs for land application can be lower than those for
some disposal methods, particularly incineration. If POTWs can more easily, because of greater
public acceptability, shift away from disposal to land application, a cost savings could result.
6-36
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In addition to these direct costs savings, additional cost savings are also possible.
Commercial fertilizers are a significant portion of farmer's costs of growing crops. Sewage sludge
that meets the pollutant concentration limits will be able to be applied to meet the agronomic
need of crops for nitrogen, thus farmers might not have to purchase any commercial fertilizers,
or might be able to reduce the amount of fertilizer that they purchase. This will result in
substantial costs savings to farmers for fertilizing and conditioning their soils.
The average percent available nitrogen in land-applied sewage sludge is 4 percent,
according to the NSSS questionnaire survey. Based on the 1.0 million dmt of sewage sludge
disposed of annually, EPA estimates that 40,800 metric tons of available nitrogen is associated
with this high quality sewage sludge that is disposed. At current prices for nitrogen (as ammonia
or urea) of $231 per metric ton (personal communication between ERG and USDA, October,
1992), the value of this sewage sludge, if land applied, could be as much as $9.4 million. Even if
only 10 percent of this sewage sludge is land applied, the total cost savings could be nearly $1
million.
6-37
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REFERENCES TO SECTION SIX
Bowers, J.F. et al. 1980. Industrial Source Complex (ISC) Dispersion Model User's Guide
(Vol. 1). PB80-133044. U.S. EPA, Research Triangle Park, NC.
Environmental Science and Engineering. 1985. Exposure to Airborne Contaminants Released
from Land Disposal Facilities—A Proposed Methodology. Prepared for the U.S. EPA
Office of Solid Wastes, Washington, DC.
Hwang, S.T. 1982. Toxic Emissions from Land Disposal Facilities. Environmental Progress. 1:46-
52. February.
Hwang, S.T. and Falco. 1986. Estimation of Multimedia Exposures Related to Hazardous Waste
Facilities. In: Cohen, Y., ed. Pollutants in a Multimedia Environment. Plenum Publishing
Co. New York, NY.
National Academy of Sciences (NAS). 1983. Risk Assessment and Management: Framework for
Dccisionmaking. Washington, DC.
National Institute of Occupational Safety and Health (NIOSH). 1979. Registry of Toxic Effects
of Chemical Substances.
Pcnnington, J.A.T. 1983. Revision of the total diet study of food lists and diets. /. Am. Diet
Assoc. 82:166-173.
Thomann, R.J. and J.A. Mueller 1987. Principles of Surface Water Quality Modeling and
Control. Harper and Row. New York, NY.
USDA. 1972. Food Consumption: Households in the United States, Seasons and Year 1965-66.
Nationwide Food Consumption Survey 1965-66. Report No. 12.
USDA. 1982. Food Consumption: Households in the United States, Seasons and Year 1977-78.
Nationwide Food Consumption Survey 1977-78. Report No. H-6.
U.S. EPA. 1986a. Guidelines for Carcinogenic Assessment; Guidelines for Estimating Exposure;
Guidelines for Mutagenicity Risk Assessment; Guidelines for Health Assessment of
Suspect Developmental Toxicants; Guidelines for Health Risk Assessment of Chemical
Mixtures. Federal Register. Vol. 51, No. 185.
U.S. EPA. 1986b. Guidelines on Air Quality Models (Revised). EPA/OAQPS-450/2-78-027R.
U.S. EPA. 1986c. Research and Development: Development of Risk Assessment Methodology
for Municipal Sludge Landfilling. Prepared by Environmental Criteria and Assessment
Office, Cincinnati, OH, for the Office of Water Regulations and Standards. ECAO-CIN-
485.
6-38
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U.S. EPA. 1987. Municipal Waste Combustion Study. Office of Solid Waste and Emergency
Response, Office of Air and Radiation, and Office of Research and Development.
EPA/530-SW-87-021g. September.
U.S. EPA. 1988. Development of a Risk Assessment Methodology for Municipal Sludge
Landfilling. ECAO-CIN-485. Prepared by the Environmental Criteria and Assessment
Office, Cincinnati, OH.
U.S. EPA. 1989a. Training Materials for GEMS and PCGEMS. Office of Pesticides and Toxic
Substances. January.
U.S. EPA. 1989b. Graphical Exposure Modeling System User Guide. Office of Toxic
Substances. March.
U.S. EPA. 1989c. Development of Risk Assessment Methodology for Land Application and
Distribution and Marketing of Municipal Sludge. EPA/600/6-89/001.
U.S. EPA. 1989d. RUSTIC Risk of Unsaturated and Saturated Transport and Transformation of
Chemical Concentrations. Vol II Users Guide. EPA/6()0/3-89/048b. Office of Research
and Development. July.
U.S. EPA. 1990. Development of Risk Assessment Methodology for Surface Disposal of
Municipal Sludge. Prepared by the Environmental Criteria Assessment Office, Office of
Research and Development. March.
Yeh. G.T. 1981. AT123D: Analytical Transport One-, Two-, and Three-Dimensional Simulation
of Waste Transport in the Aquifer System. Oak Ridge National Laboratory,
Environmental Sciences Division, Publication No. 1439. March.
6-39
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-------
APPENDIX A
SUPPORTING DATA FOR LAND APPLICATION
-------
-------
APPENDIX A
SUPPORTING DATA FOR LAND APPLICATION
This appendix provides additional detail on analyses performed to support the pass/fail
and compliance cost analyses in Section Four, which covers economic impact of regulating the
land application of sewage sludge. It also provides supporting material and more detailed results
of the pass/fail analysis. Section A.1 discusses analyses used to determine annual application
rates, to ascertain the reasonableness of the rates, and to adjust rates, where warranted. Section
A.2 presents an analysis of the frequency with which POTWs use written agreements or contracts
with sewage sludge appliers when the POTW does not apply the sludge itself. Finally, Section
A.3 presents telephone call summaries outlining conversations with POTW operators to
determine application rates, compliance strategies, and other information.
A.1 PASS/FAIL SUPPORT ANALYSES
Four analyses are discussed in this section. Section A.1.1 summarizes EPA's approach to
determining annual application rates based primarily on NSSS data, adjusted in some instances
when data were believed to be in error because of unusual responses to a question on numbers
of applications per year per site. Section A.1.2 reviews the application rate data to determine
whether POTWs appear to be applying sludge at agronomic rates, i.e., rates based on the
nitrogen needs of crops. Section A.1.3 summarizes the approach used to impute missing data.
Finally, Section A. 1.4 discusses the impact of composting and blending on sewage sludge that
goes to lawns or home gardens, brokers or contractors, or is sold or given away in bags or other
containers. This section also presents a pass/fail analysis for these types of sewage sludge, using
pollutant concentration limits as the measure of pass/fail.
A-l
-------
A.I.I Adjustments to Annual Application Rates
The regulatory pass/fail analysis for land application uses annual whole sludge application
rates (AWSARs) to determine compliance with cumulative pollutant loading rate limits. These
AWSARs were computed based on answers to rwo questions in the NSSS: one covering the
application rate used by a POTW for a specific enduse and one covering the number of
applications at this rate made each year to one site. In theory, multiplying the application rate
times the number of applications to each site should produce the AWSAR. Unfortunately,
because the question on number of applications appears to have been misinterpreted in some
cases, many unusually high rates were produced when this procedure was followed.
This problem was primarily of concern for POTWs that did not meet pollutant
concentration limits, since they must meet cumulative limits based on ASWARs. Since the
unusually high rates that were calculated were causing many POTWs to fail the cumulative limits,
and since EPA did not want to estimate failures based on erroneous data, an analysis of the
validity of these data was undertaken. Table A-l presents application rate data for POTWs that
do not meet pollutant concentration limits and that indicated more than one application per site.
The reported application rate is from the NSSS, as is the reported number of applications. The
calculated annual application rate presents the annual application rate calculated using the
reported application rate times the reported number of applications. The column entitled
"adjustment" explains the type of adjustment made to the data, if any, and the "new rate" column
presents the rate used in the pass/fail analysis to generate the results presented in Section Four.
EPA's first step was to determine the "reasonableness" of the application rates. To do
this, EPA assumed that any rate under 55 dmt was not unreasonable (based on an analysis of
maximum reasonable agronomic rates to be discussed in Section A.1.2). If a POTW passed the
cumulative limits at a rate under 55 dmt, no further adjustments were made. As Table A-l
shows, application rates for POTWs 349, 334, 310, 252, and 336 (one enduse) were not adjusted
based on this criterion. If the POTW did not pass the cumulative limits or if the rate exceeded
55 dmt for an enduse because of multiple applications, additional work was undertaken to
determine a realistic application rate or to correct the questionnaire data.
A-2
-------
TABLE A-l
ADJUSTMENTS TO MULTIPLE APPLICATIONS AND/OR ANNUAL APPLICATION
RATES AMONG POTWs FAILING POLLUTANT CONCENTRATION LIMITS AND
REPORTING MORE THAN ONE APPLICATION PER YEAR
POTW
096
096
097
097
129
116
Re-
ported
Flow
Rate
Group
1
1
1
1
2
2
Volume
of
Sludge
(Dry
Metric
Tons)
,738
738
5,191
5,191
14.13
1,611
Report-
ed
Applic-
ation
Rate
246
62
230
58
4
5
Report-
ed
Number
of
Applica-
tions
13
2
13
2
23
155
.
Calculated
Annual
Applica-
tion Rate8
3,200
125
2,993
117
92
775
Adjustment
No adjustment-
fails criteria
even if one
application
assumed
No adjustment-
fails criteria
even if one
application
assumed
No adjustment-
fails criteria
even if one
application
assumed
No adjustment-
fails criteria
even if one
application
assumed
Call back to
POTW
indicated
numbers
misreport-edb
Call back to
POTW
indicated
numbers
misreport-ed
New
Rate
3,200
125
2,993
117
45
5
A-3
-------
TABLE A-l (cont.)
POTW
349
349
334
334
440
117
117
Re-
ported
Flow
Rate
Group
2
2
3
3
2
3
3
Volume
of
Sludge
(Dry
Metric
Tons)
549
499
698
233
93
557
62
Report-
ed
Applic-
ation
Rate
2
12
2
2
8
0.2
2
Report-
ed
Number
of
Applica-
tions
9
4
3
3
2
92
81
!
Calculated
Annual
Applica-
tion Rate"
21
49
5
5
16
21
163
Adjustment
Application
rate reasonable
Application
rate reasonable
Application
rate reasonable,
passes criteria
Appliction rate
reasonable,
passes criteria
Exceeds
volume of
sludge as-
suming one 19-
hectare average
reported site
Call back
indicated
maximum
number of
applica-tions to
any one site
was 2
See above
New '
Rate
21
49
5
5
8
(numb
er of
applic
a-
tions
set to
1)
0.4
(numb
er of
applic
a-
tions
set to
2)
4
(numb
er of
applic
a-
tions
set to
2)
A-4
-------
TABLE A-l (cont.)
POTW
034
310
252
141
336
336
Re-
ported
Flow
Rate
Group
3
3
4
4
4
4
Volume
of
Sludge
(Dry
Metric
Tons)
800
406
21
23
'
27
81
Report-
ed
Applic-
ation
Rate
0.4
1
0.4
0.5
0.3
1
Report-
ed
Number
of
Applica-
tions
250
10
24
246
52
52
Calculated
Annual
Applica-
tion Rate4
95
13
11
132
16
70
Adjustment
Application
rate correct
based on call
back
Application
rate reasonable,
passes criteria
Application
rate reasonable,
passes criteria
Exceeds
volume of
sludge
assuming one
17-hectare
reported
average site
Application
rate reasonable,
passes criteria
Exceeds
volume of
sludge based
on one 28-acre
reported
average site
New
Rate
95
13
11
1
-
16
10
"Application rates have been rounded thus reported application rate times number of
applications may not appear to equal annual application rate exactly.
bQuantity of sewage sludge was also misreported. Actual amount of sewage sludge disposed of in
1988 was 603 drat.
Source: ERG estimates based on 1988 National Sewage Sludge Survey, EPA.
A-5
-------
Next, EPA tried to determine a realistic ''maximum" rate. In the NSSS, the survey
respondents answered a question on average numbers of acres per application. Although most
POTWs probably had more than one site, we used the total quantity of sewage sludge disposed
annually that was associated with an enduse and the average acreage per application reported in
the NSSS for that enduse (using the worst-case assumption that the POTW applied all of its
sewage sludge to only one site in one application) to determine a "maximum" estimated
application rate. If the "maximum" estimated application rate was clearly much lower than the
highest application rate a POTW could use while meeting the cumulative limits over a 20-year
site life, EPA adjusted the rate to the "maximum" estimated rate and determined that the
POTWs sewage sludge would meet the cumulative limits when applied for the enduse in
question. As Table A-l shows, application rates for POTWs 440, 141, and 336 were adjusted
because their reported application rates did not appear to be consistent with their quantity of
sludge and their reported average acreage per application.
In some cases, however, the facilities either did not provide data on average acreage, or
the amount of sewage sludge disposed divided into the acreage reported still produced unusually
high application rates. Application rates for six POTWs—096, 097, 129, 116, 117, and
034—remained questionable after we attempted to calculate a maximum reasonable rate. Rates
for 096 and 097 were not adjusted, however, because, even if the sewage sludge were applied only
once to a site at the reported rate, the POTWs' sewage sludge failed the criteria. We contacted
the remaining four POTWs to provide us with better information (see Section A.4, Supporting
Material). As a result of these call backs, we discovered that one POTW had provided incorrect
data; one had misinterpreted the application rate question, thinking it referred to annual
application rate; and one had misinterpreted the multiple application question, thinking the
question asked for total applications to all sites. Only one, POTW 034, had answered the
questionnaire correctly. The application rates were adjusted for all but POTW 034 based on
annual application rates reported by the POTW representatives contacted during these call backs.
A-6
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A.1.2 Agronomic Rate Analysis
The Part 503 regulations require that all land-applying treatment works must not exceed
the nitrogen needs of the crops on which sewage sludge is spread (the agronomic application
rate) (reclamation can be undertaken using greater than agronomic rates, but this must be
approved by the permitting authority). Thus EPA analyzed the NSSS data to determine which, if
any, facilities may be exceeding the agronomic rate when applying sewage sludge other than for
reclamation. The NSSS questionnaire survey asks respondents if they used the nitrogen and/or
phosphorus needs of crops to determine application rates. Since nitrogen needs are usually the
primary concern in determining rates, EPA assumed that if respondents answered yes to this
question, the application rate used probably did not exceed the agronomic rate (see Table A-2).
The facilities that answered "no" to this question were not necessarily applying at higher-than-
agronomic rates; in most cases, they may have been applying at less than agronomic rates. EPA
surmises that application rates may appear to be less than agronomic rates for at least two
reasons: (1) state limits, Part 257 limits, or good-practice guidance on contaminants in sewage
sludge could constrain the application rate; or (2) the POTW generates a very low-solids sewage
sludge, which is applied in large quantities (but contains so few solids that the dry weight is
minimal) primarily for soil conditioning and moisture, and only secondarily for nitrogen.
There is some evidence to support the first two cases. POTW 117 (which fails the ceiling
concentrations for nickel and zinc), generates sewage sludge with a very high zinc concentration.
At typical agronomic rates, this POTW would fail Part 503 criteria as well as state limits (the
state in which this POTW is located limits zinc). Instead, the POTW applies sewage sludge at
0.4 dmt/ha in one case and 4 dmt/ha in another.
In the second case, EPA determined that most of the POTWs using low application rates
generate low-solids sludge. Table A-3 presents POTWs that apply sludge at rates less than 5
dmt/ha. The weighted mean percent solids in this group (excluding POTW 117) was 2.6 percent,
which would mean that on average/nearly 11,000 gallons of sewage sludge would have to be
applied to a hectare to equal 1 dmt/ha, or over twenty 2,000-gallon truckloads for a 4-hectare
(10-acre) site.
A-7
-------
TABLE A-2
COMPARISON OF APPLICATION RATES AMONG FACILITIES ANSWERING YES OR
NO TO QUESTION PERTAINING TO THE USE OF NITROGEN NEED IN DETERMINING
APPLICATION RATE
Facilities Responding Yes to Nitrogen
Question
Facility ID
050
399
033
201
201
429
189
371
370
454
029
431
029
349
454
026
204
454
472
242
242
198
371
Application Rate
(dmt/ha)
705a
290"
252"
179°
118a
75b
59b
55
55
55
53
51
49
49
45
38
37
34
33
32
32
31
29
Facilities Responding No to Nitrogen
Question
Facility ID
096
097
476
470
096
097
034
004
097
129
097
021
436
436
061
336
096
090
310
096
128
252
336
Application Rate
(dmt/ha)
3,201a
2,993a
l,200a
223a
1253
117a
95
94a
61
45
44
30
16
16
16
16
16
15
13
11
11
11
10°
A-8
-------
TABLE A-2 (cont.)
Facilities Responding Yes to Nitrogen
Question
370
349
454
189
261
347
012
044
044
227
047
452
369
356
349
060
111
209
440
440
219
209
204
116
219
245
128
29
21
19
17
17
17
16
16
14
13
12°
11
11
10
10
10
10
9
8C
8
7
7
6
5b
5
4
4
Facilities Responding No to Nitrogen
Question
422
417
108
221
334
334
120
439
061
117
393
426
090
475
329
117
348
124
9
9
7
7
5
5
5b>
4
4
4C
3
lc
1
1
0.4
0.4C
0.1
0.09
A-9
-------
TABLE A-2 (cent.)
Facilities Responding Yes to Nitrogen
Question
226
186
230
141
330
359
312
028
028
047
095
3
2
2
r
1
1
1
0.4
0.4
0.03
0.03
Facilities Responding No to Nitrogen
Question
'Application rate considered possibly in error due to unusually high number of applications.
bApplication rate might be in error, but number of applications was not considered excessive (6
applications in both cases).
These numbers were adjusted (sec Table A-l and Section A.1.2).
A-10
-------
TABLE A-3
APPLICATION RATES UNDER 5 DMT PER HECTARE
AND PERCENT SOLIDS ASSOCIATED WITH THESE RATES
POTW
095
124
348
329
117
028
028
359
475
090
426
330
141
230
186
393
226
128
117
061
245
Application
Rate
0.03
0.09
0.1
0.4
0.4
0.4
0.4
1
1
1
1
1
1
2
2
3
3
4
4
4
4
Solids
0.2%
2% -
2%
2%
10%
0.8%
0.8%
6%
6%
2%
NAa
2%
4%
4%
2%
4%
5%
13%
10%
5%
2%
Number of Enduses Represented
135
135
30
135
30
135
135
135
30
30
30
135
135
135
30
30
6
6
30
30
30
-
"Data missing.
Source: 1988 NSSS Analytical Survey, EPA.
A-ll
-------
EPA investigated in more depth the application rates reported by POTWs that answered
"no" to the nitrogen question. As Table A-2 indicates, nearly all application rates associated with
negative answers to the question on nitrogen were less than 10 dmt/ha, leading EPA to believe
that the agronomic rate was most likely not exceeded. Of the 22 enduses with application rates
equal to or greater than 10 dmt, many (10 enduses in the survey) had application rates that
ranged from 10 to 16 dmt, still a reasonable application rate for most types of vegetation. The
remaining enduses included three with application rates ranging from 30 to 55 dmt/ha (POTWs
021, 097, and 129). Based on the range of application rates associated with enduses in which the
nitrogen needs of the crops were considered (0.03 to 55 dmt/ha1, with 14 survey enduses
associated with application rates of 30 dmt or more), EPA does not believe that an application
rate of 30 dmt/ha clearly exceeds a reasonable agronomic rate. Thus, in EPA's judgment, POTW
021, which applies sludge at 30 dmt/ha is not necessarily exceeding an agronomic rate. As
application rates rise above 30 dmt/ha, the likelihood of exceeding nitrogen needs of crops may
increase, although it is still not certain. The two facilities applying sludge at rates greater than 30
dmt/ha but less than 55 dmt/ha fail criteria for metals and are assumed to shift disposal practices.
Thus the issue of whether POTWs 097 and 129 are applying sludge at greater-than-agronomic
rates is not critical to the pass/fail analysis.
We then looked more closely at the responses where nitrogen needs were not considered
by the facility and application rates exceeded 55 dmt/ha. EPA has assumed that unless a rate in
this range is identified as most likely erroneous, rates this high very likely exceed agronomic
rates. A total of nine enduses were associated with application rates in this range. The sewage
sludge used for six enduses (POTWs 096, 034, and 097) either fail the cumulative limits at these
application rates or fail ceiling limits. POTW 097 is expected to shift to codisposal, and POTW
096 is expected to reduce application rates to below 55 dmt/ha. POTW 034 has already shifted
to composting because of state requirements. Assuming its application rate has not changed,
agronomic rates might not be exceeded because composted sewage sludge tends to have less
available nitrogen. Three enduse application rates (for POTWs 476, 470, and 004) were
!The application rates shown in Table A-2 ranging from 117 to 102,001 dmt/ha are believed to
be erroneous due to responses indicating unusually high numbers of multiple application question.
The application rate of 55 dmt is associated with the highest application rate calculated using one
reported application per year.
A-12
-------
computed based on a number of multiple applications, which ranged from 149 to 446
applications. The annual application rates generated did not seem to be realistic, and given the
misinterpretations possible with either the multiple application question (where numbers of sites
could have been counted) or application rates (where annual rates might have been provided),
EPA concluded that these annual application rates were probably erroneous. Even if 10
applications per year were made at the application rates reported by these POTWs (the median
number of applications at all POTWs was 1.5), the application rates used by these POTWs would
be compatible with agronomic rates (5 to 26 dmt/ha). Additionally, these POTWs generate low
percent solid sewage sludges (two POTWs have 2-percent solid sewage sludge and one has a 4-
percent solid sewage sludge). As the analysis above indicated., sewage sludge with percent solids
averaging this low are often associated with application rates of less than 5 dmt/ha.
Based on the foregoing analysis, EPA estimates that only 3 POTWs (096,097, and 034),
practicing 6 enduses, are estimated to be exceeding agronomic rates. These 3 POTWs also fail
to meet either criteria as well and represent 32 POTWs and 35 enduses nationwide. All other
land-applying POTWs practicing secondary or advanced treatment are most likely not exceeding
agronomic application rates. This finding is consistent with the fact that many state regulations
limit sludge application based on nitrogen and is also consistent with general industry-proclaimed
good management practices.
A.1.3 Missing Data
A number of POTWs did not provide data on their application rates, their numbers of
applications per year, or both. EPA imputed rates for these POTWs in the following way. First,
POTWs were categorized by enduse. Groups of POTWs practicing agricultural land application,
public contact site application, reclamation, and silviculture were developed, and annual
application rates were computed. Since there was wide variability in application rates, and since
EPA did not feel it was possible to investigate all unusually high or low application rates (the
corrections based on analyses above were, however, incorporated), EPA chose to impute annual
application rates for each of the major enduses using a "weighted" median. Each POTW in the
analytical survey represents a certain number of similar POTWs, depending on survey design flow
A-13
-------
group designation. EPA thus assigned the annual application rate of the representative POTW
to "dummy" POTWs (i.e., those represented by each survey POTW). For example, if a POTW
had an application rate of 10 and it represented 6 POTWs, this POTW and 5 dummy POTWs
would appear to have an application rate of 10. This approach was needed because the survey
weights were assigned based on design flow, but EPA imputed the median based on reported
flow (see survey weight discussion in Section Two).
Once the "dummy" POTWs were assigned application rates, the median for the enduse
group was identified. The results of this procedure are shown in Table A-4. Where application
rates were missing, including some questionnaires with missing numbers of applications (13 out
of 120 enduses), the median for the appropriate enduse group was assigned to the enduse in
question. Where only the number of applications (6 out of 120 enduses) was missing, we set the
number of applications to one. This change was made based on the median numbers of
applications reported in the survey (1.5) and based on an assumption that the respondents may
have skipped the question because the POTWs made only one application, and thus the
respondents deemed the question irrelevant.
One POTW (128), which had an unknown enduse, failed the cumulative limits when any
nonagricultural enduse median application rate was used, thus EPA decided to call the POTW to
get the actual application rate. The sewage sludge is applied to government conservation land,
which might be considered either public contact site or silviculture. The sewage sludge, which is
13 percent solids, is applied at 13 wet tons per acre, or about 4 dry tons per hectare. With this
rate, the cumulative limits are met.
Data for one other POTW were corrected as well. In the NSSS, the application rate for
POTW 120 was listed as 0. We assumed that this occurred because the number was rounded at
some point in the data manipulation process. The application rate was thus set at 0.4 U.S. tons
per acre, and calculations to convert the number to dmt/ha were then performed.
A-14
-------
TABLE A-4
MEDIAN APPLICATION RATES BY TYPE OF ENDUSE
Type of Enduse
Agriculture
Silviculture
Public Contact Site
Reclamation
Undetermined
Median Application Rate
Reported Flow
Group 1
15.86
11.43
116.58
100.89
—
Reported Flow
Group 2
11.37
26.06
44.73
44.73
55.15
Reported Flow
Group 3
5.38
11.93
0.76a
—
47.53
Reported
Flow Group 4
2.24
5.38
0.58a
13.45
~
aVery low rates may be associated with uneven sewage sludge distribution (i.e., sewage sludge
may be placed around trees and shrubs and not applied evenly over a site—see discussion in
Section A.1.2).
A-15
-------
A.1.4 Composted and Blended Sewage Sludge
The analysis in Section 4.3.2.1 uses pollutant concentrations in composted sewage sludge
that have been adjusted downwards by 40 percent. EPA's data show an average of 40 percent
dilution is achieved during composting (personal communication between ERG and Alan Rubin,
EPA, May 16,1991). Using the 40 percent dilution factor, EPA calculated the pollutant
concentrations in the composted sewage sludge.
Additionally, three NSSS POTWs (former ocean disposers), which represent themselves
only, blend their sewage sludge. The blended sewage sludge is subsequently composted. Finally,
two NSSS POTWs (representing 135 POTWs) blend their sewage sludge. Because this sewage
sludge is solar/air dried, no dilution is assumed.
Table A-5 presents the listing of all NSSS POTWs that blend and/or compost their
sewage sludge. This table presents the original pollutant concentrations for all composters and
blenders. Table A-6 shows the effects of blending and/or composting on pollutant
concentrations. The last column in each table presents the pass/fail analysis.
The pass/fail results in both tables are based on pollutant concentration limits. As
discussed in Section Four, sewage sludge used for lawns or home gardens, going to brokers or
contractors, or sold or given away in bags or other enclosures will need to pass pollutant
concentration limits in order to maintain current market levels. EPA therefore assumes that
POTWs with these types of sewage failing to meet pollutant concentration limits will need to
reduce pollutant concentrations or find alternative markets for at least a portion of their sewage
sludge. Not all of the POTWs provide sewage sludge for these purposes, or in bags or other
containers. However, for the purposes of this analysis, only the pollutant concentration limits are
used. As Table A-5 and A-6 show, although some sewage sludge initially fails to meet pollutant
concentration limits, all the sewage sludge in this analysis meets the pollutant concentration
limits after composting or blending.
A-16
-------
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A-18
-------
A.2 ANALYSIS OF WRITTEN CONTRACTS
The Part 503 regulations require all POTWs that do not apply sludge themselves to
provide to the sewage sludge applier or subsequent preparers "notice and information." "Notice
and information" comprise a written agreement with the applier or subsequent preparer. It
might be strictly contractual and resemble the contract in Figure A-l, or it may be a less formal
agreement, as long as the applier agrees in writing that the required application rate (whether
limited by nitrogen or by metals content of the sludge) will be met and all management practices
dictated by Part 503 will be followed.
EPA used the NSSS to determine the number of POTWs that might not be meeting this
requirement currently. If a facility responded that the POTW or other municipal employees
applied the sewage sludge or if the POTW hired a contractor to apply the sludge (a contract is
assumed inherent to the contractor-POTW relationship), the POTW was judged to be in
compliance with Part 503 requirements. If the customer, farmer, or other unknown entity not
controlled directly by the POTW applied the sewage sludge, questions on whether the POTW
had written agreements with the sludge appliers were analyzed. If the POTW in question had an
interagency agreement, a written contract, or another type of written agreement that was judged
equivalent to a contract, the POTW was considered to be in compliance with Part 503
requirements. If written instructions were provided, if verbal agreements applied, or if EPA
could not determine whether the POTW was meeting the spirit of the Part 503 requirements, the
POTW was considered out of compliance.
Out of 92 land-applying POTWs in the analytical survey, only five do not appear to have
written agreements of the type specified. One POTW provides written instructions, one POTW
indicated it had state permits, and one indicates only "proof of insurance &." Since EPA could
riot determine whether the state permits and proof of insurance constituted notice and
information, the Agency assumed that these POTWs were out of compliance. An additional five
POTWs had no information. Based on the large number of POTWs that appear to be in
compliance, EPA assumed that these five POTWs also have some form of written agreement.
The five POTWs that are believed not to have written agreements represent 97 POTWs
nationwide.
A-l 9
-------
THIS CONTRACT, made this.
. day of,
CONTRACT
19 , by and between .
hereinafter referred to as Owner, and ! , hereinafter referred to as City, witnesseth that,
WHEREAS, Owner is the owner of a parcel of agricultural real property located in (PARCEL NO.) _ (TOWNSHIP) t (COUNTY)
Onto, which can bo reached as follows:
., and
WHEREAS, City operates a waste treatment or disposal plant which after processing produces a product known as sewage sludge, and
WHEREAS, Owner will allow sewage sludge from City to be placed on the above-mentioned real property only on the terms set out below,
NOW THEREFORE, Owner and City mutually agree as follows:
1, The "Ohio Guide for Land Application of Sewage Sludge,"
Bulletin 598 of the Cooperative Extension Service of the Ohio State
University, as revised in May, 1976, shall be used as a guideline for
responsible management practises. Hereinafter Bulletin 598 will be
referred to as "The 1976 Guide."
2. The City will deliver sewage sludge to the above-mentioned
property of Owner and will properly spread or otherwise deposit said
sewage sludge on said property without charge to the Owner. City shall
be responsible for all equipment used to deliver and spread such sewage
sludge.
3. The Owner and the City will mutually agree on the specific portion
of said property which is to receive sludge. In the absence of unusual
factors, they will abide by the site election criteria of the 1976 Guide.
4. The Owner or his representative may decline to receive sludge on
said property when, in Owners's or his representative's judgement, the
sludge application equipment would damage the soil structure because
of excessive soil moisture at the disposal site. When possible, the
Owner will give the City notice of poor field conditions 24 hours prior to
the appointed application time. However, the City does realize that this
is not always possible and that there will be some days when untimely
excessive rainfall will require termination of spreading activities at a
moment's notice on a given field.
5. The Owner will notify City in writing of the dates between which
City may deliver and spread sewage sludge The City may deliver said
sewage sludge only during the period thus described. The Owner will
make himself or his representative available to City or its employees
during such period to ensure said sewage sludge is deposited on the
proper location on said property.
6. Owner shall specify the access to be used by the City when
sewage sludge is applied to a specific portion of said property. The
Owner shall provide and maintain an access for use by the City without
charge to the City, and the City shall not be liable for any damages
thereto, except damage caused by City's negligence.
OWNER:
Address:
7. Using the criteria of the 1976 guide, the Owner and the City have
mutually agreed on the rates and amounts per acre said sewage sludge
is to be applied during the Contract period. For the term of this
Contract, Owner will adhere to mutually agreed upon application rates
listed in Attachment A which is included as a part of this Contract.
8. The City shall properly analyze its sewage sludge on a monthly
basis for the total nitrogen, ammonia and nitrate nitrogen, phosphate,
potassium, lead, zinc, nickel, copper, and cadmium content. The results
of such analysis will be provided to the Owner or his representative
upon request without charge before sludge is applied to said property.
9. City shall keep and maintain records of the following items, and
shall make such records available to Owner or his representative upon
request:
(a) All analyses of the composition of sewage sludge produced by the
City.
(b) All reports concerning the operation or production of sewage
sludge by the City.
(c) All applications to agricultural land of sewage sludge produced by
City including dates of application, amounts applied, specified
rates of application, specific parcels of land upon which sewage
sludge has been applied.
(d) All required governmental permits or approvals for the application
of sewage sludge on agricultural land.
10. City will deliver and apply sludge which is Well stabilized and
which does not present a severe odor nuisance to Owner or other rural
residents who live in the vicinity of the sludge disposal site. The Owner
may refuse to accept any sludge which is exceptionally odorous.
11. The Contract shall continue in effect for a period of three years
following the date first above written. The Parties hereto may renew this
Contract in writing. Either party may cancel this Contract by giving
written notice to the other party of the intention to do so. Cancellation
will be effective five days after receipt of such notice. Such notices shall
be delivered personally or by certified mail to the address(es) listed at
the end of this Contract.
CITY:
By_
Title
By_
Title
Address:
Source: EPA, 1984.
Figure A-l. Sample Contract.
A-20
-------
OTHER SUPPORTING MATERIAL
This section summarizes the pertinent information from telephone conversations with
POTW operators. These telephone calls were made to clarify answers to questions on the
survey. Most of these POTWs were contacted to verify their annual application rates (see
Section A.1.1). A few POTWs were called because data were missing or to verify compliance
strategies.
POTW 454
This POTW was contacted because one failing enduse was unspecified and because the
POTW failed the criteria for metals (although with minimal consequences). The NSSS, although
it asked about potential compliance strategies regarding shifting from land application to other
types of disposal, did not enquire about shifting from one enduse to another. Since POTW 454
practices a number of land application enduses, and since most of its enduse practices require
lower application rates than the failing enduses, it appeared that this POTW was a good
candidate for shifting sewage sludge to other enduses. To do so, the POTW would have to have
adequate land at its disposal. The POTW was thus contacted with these issues in mind.
The POTW representative indicated that the unspecified enduse was conservation land on
which sewage sludge is applied under a program initiated by the state to pay farmers for allowing
portions of their land to lay fallow for a number of years. The sewage sludge was applied to the
land to replace the natural wildlife habitat of the region. The land was formerly agricultural land
(it supported wheat) and will be out of agricultural use for 10 years.
The POTW representative stated that they could easily shift between land application
enduses. (The two failing enduses are a very small part of their operations; their largest
operations are major silviculture projects.) They have large amounts of additional land available
for silviculture purposes as well.
A-21
-------
POTW 117
This POTW was contacted because EPA considered the calculated annual application
rates to be potentially erroneous. The POTW representative indicated that the number of
applications did not refer to the same site; he thought that they may have made more than one
application to a site, but not more than two applications to a site.
POTW 116
POTW 116 was contacted because EPA considered the calculated annual application
rates to be potentially erroneous. The application rate was listed as 53 wet tons per acre applied
155 times per year. The POTW representative indicated that the number of applications
referred to the number of days they were able to apply sewage sludge, based on the weather, and
that they had applied sewage sludge to 20+ sites (ranging in size from 24 to 150 acres each). He
stated that the actual amount of sewage sludge applied annually was about 11,000 to 15,000
gallons per acre (subsurface injected), which corresponds with 44 to 66 wet tons. Thus the
original 53 wet tons per acre appears to be the correct annual application rate. The correct
application rate with 155 applications per year would be 0.34 wet tons per acre.
POTW 034
This POTW was contacted because EPA believed the calculated annual application rate
was potentially erroneous. The POTW representative confirmed the application rate, but
indicated that the POTW had shifted to in-vessel composting to comply with state requirements
(required prior to 1988).
A-22
-------
POTW 129
This POTW was contacted because EPA believed the calculated annual application rate
was potentially erroneous. The POTW representative looked up reports to the state and
discovered that the land application numbers reported in the survey did not match those on the
report to the state for that year. (The figures from the report to the state have been
incorporated into the pass/fail model.) In 1988, however, the facility was not in compliance with
state regulations. Since that time the POTW has expanded the amount of land on which it
applies sludge. It now appears to be applying sewage sludge at much lower rates (which are
much lower than their maximum allowable rate), if all 800 acres to which they now have access
are used. They noted that obtaining the additional acreage was very easy and was facilitated by
the state.
POTW 128
This POTW was contacted because it did not answer the question on application rate for
one of its enduses. The POTW representative indicated that the land was government
conservation land similar to that used by POTW 454. The application rate is 13 wet tons per
acre. Twelve applications of sludge were made, but to different sites, averaging 23 acres in size.
A-23
-------
REFERENCES TO APPENDIX A
EPA. 1985. Handbook: Estimating Sludge Management Costs. EPA/625/6-85/010.
EPA. 1984. Environmental Regulations and Technology. Use and Disposal of
Municipal Wastewater Sludge. EPA 625/10-84-003, September.
A-24
-------
APPENDIX B
SUPPORTING DATA FOR SURFACE DISPOSAL
-------
------- An error occurred while trying to OCR this image.
-------
TABLE B-l
DETERMINATION OF CURRENT COMPLIANCE WITH PATHOGEN AND
VECTOR ATTRACTION REDUCTION REQUIREMENTS
POTW
317
097
234
410
156
381
232
432
353
235
315
434
065
089
227
340
398
414
423
451
463
Complies with Requirements
NO
YES
NO
YES
NO
YES
NO
NO
NO
NO
YES
YES
YES
NO
YES
NO
YES
YES
YES
YES
YES
Reason
Other sewage sludge is land applied;
entire quantity expected to meet
requirements.
Daily cover used.
Daily cover and lime treatment used.
Wet air oxidation used as sewge
sludge treatment.
Daily cover used.
Daily cover used.
Other sewage sludge is land applied.
Drying beds used.
Drying beds used.
Drying beds used.
Drying beds used.
Drying beds used.
Source: ERG estimates from 1988 National Sewage Sludge Survey, EPA.
B-2
-------
TABLE B-2
COSTS OF OPTIONS
POTW
317
234
156
232
432
353
235
089
340
Lime Treatment Cost
(weighted)
$30,375
842,103
462,951
2,347,522
57,573
462,897
258,977
981,620
$1,903,430
Alternative Cost
N/A
N/A
$194,400a
N/A
N/A
N/Ab
N/A
$40,500C
N/A
aDaily cover—4 hours per day @ 30/hr x 270 days/yr. (Full costs assumed within this estimate.)
(1,190 dmt)
bCodisposes stored sludge more frequently (20 percent of sewage sludge disposed @ $313 per dmt).
°Daily cover—1 hour per day @ 30/hr x 10 days/yr (0.01 dmt).
Source: ERG estimates.
B-3
-------
were used, with one major change in assumption from those presented in the handbook. The
labor cost has been adjusted downwards to reflect the assumption that the lime mixing can be
monitored by a current employee with a small incremental portion of time. Five minutes of each
hour that the mixing machine is operated is assumed to be spent directly monitoring the mixing
or taking delivery of lime. The other assumptions and input variables can be seen in the notes to
Table B-3. Tables B-4 through B-6 present the calculations performed. Note that all final costs
are weighted by the analytical survey weights, and thus the final costs in Table B-6 represent
costs for all surface-disposing POTWs nationwide to meet pathogen and vector attraction
reduction requirements.
Table B-7 presents the final costs of lime treatment, including a factor for the additional
cost of disposing of a larger amount of sewage sludge. According to the algorithms in the EPA
handbook (EPA, 1985), lime addition increases the dry tonnage disposed by 34 percent. EPA
thus took the current cost of disposal and multiplied this cost by 0.34 times the current quantity
of sewage sludge disposed to represent the cost of disposing of the additional amount of sewage
sludge generated. As the table shows, the total cost of complying with the pathogen and vector
attraction reduction requirements is $9.6 million.
B-4
-------
Table B-3. Input Parameters to Lime Addition Cost Analysis
Input Symbol
sludge suspended solids concentration (%) SS
sludge solids specific gravity
sludge specific gravity SSG
daily operation period (hr/day) HPD
annual operation period (days/yr) DPY
sludge detention time in mixing tank (hr/batch) DT
lime dosage as a fraction of dry solids mass LD
hydrated lime content of lime product (%) LC
bulk density of hydrated lime in storage silo (lb/ft"3)
cost of lime ($/ton) LMCST
cost oflime storage silo(s) ($/fT3) LSCST
cost of mixing tanks ($/gal) MTCST
cost of lime feed system ($/lb/hr) LFCST
cost of labor ($/hr) . COSTL
cost of energy ($/kWh) COSTE
Value
3
. 1.42
1.01
8
'365
0.5
0.3
90
30
100
9.34
1.02
19.10
30
0.11
Plant
ref#
13-36-317
21-25-234
24-20-156
25-25-232
25-45-432
33-39-353
35-26-235
45-13-089
45-37-340
Annual Sludge ' Daily Sludge
Stored or S.Disposed Volume
(US tons/year) (gal/day)
SV
506.60
2,265.99
1,190.00
6,538.20
41.43
172.10
29.64
0.01
140.62
11,094.69
49,625.83
26,061.34
143,188.46
907.33
3,768.95
649.12
0.22
3,079.62
Assumptions:
1. POTWs that are included because they store their sludge are assumed to store 20 percent.
This affects POTW 33-39-353.
2. Annual Cost of Labor formula has been revised.
For all firms, 5 minutes of each hour are spent on the lime mixing machine.
The number of operating days has been estimated based on the following assumptions:
The small POTWs (235,089,340) operate the lime units 100 days per year.
The incinerator 33-39-353 operates its storage 20 percent of the time, or 73 days per year.
The incinerator 13-36-317 operates its lime units on the days when it does not incinerate,
which is proportional to the tons disposed and incinerated (6.2 % disposed): 23 days of surface disposal.
3. No lime storage silos are assumed to be installed if the lime required annually is less than 60,000 Ib. (ap
This affects POTWs 25-45-432, 35-26-235, and 45-13-089.
B-5
-------
Table B-4. Process Design Output Data
Plant
Kfff
Weight of Lime
Product Required
(Ib/yr)
ALR
Volume of Lime
Storage Silo
(ft"3)
VLS
Mixing Tank
Capacity
(gal)
MTC
Lime feed
system capacity
(Ih/hr)
LFC
13-36-317
21-25-234
24-20-156
25-25-232
25-45-432
33-39-353
35-26-235
45-13-089
45-37-340
340,756.95
1,524,184.45
800,435.79
4,397,822.94
27,867.27
115,757.81
19,936.90
6.73
94,585.95
946.55
4,233.85
2,223.43
12,216.17
77.41
321.55
55.38
0.02
262.74
1,386.84
6,203.23
3,257.67
17,898.56
113.42
471.12
81.14
0.03
384.95
1,397.58
6,251.27
3,282.90
18,037.17
114.29
474.77
81.77
0.03
387.93
B-6
-------
Table B-5. Quanities Calculatioas Output Data
Plant
refit
Annual Energy
Requirement
for Air Mixing
(kWh/yr)
BER
Total Annual
Energy
(kWh/yr)
Annual Labor
Requirement
(hr/yr)
L
13-36-317
21-25-234
24-20-156
25-25-232
25-45-432
33-39-353
35-26-235
45-13-089
45-37-340
539.53
2,413.29
1,267.35
6,963.21
44.12
183.28
31.57
0.01
149.76
701.39
3,137.27
1,647.56
9,052.17
57.36
238.27
41.04
0.01
194.69
257.26
1,300.18
797.88
3,294.57
261.70
257.77
246.15
242.36
260.34
B-7
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TABLE B-7
TOTAL COST OF MEETING PATHOGEN AND VECTOR ATTRACTION
REDUCTION REQUIREMENTS
POTW
317
234
156
232
432
353
235
089
340
Total
Number of
POTWs
Nationwide
Represented
1
6
6
6
6
30
30
135
135
355
Compliance
Cost (Lime
Treatment
or Other)
$30,375
842,103
194,400
2,347,522
57,573
l,616,019a
258,977
40,500
1,903,430
7,290,899
Cost per
Ton of
Additional
Sewage
Sludge
Disposal
$341
5.17
N/A
4.13
5,160
N/A
500b
N/A
245
-
Tons of
Sewage
Sludge
Disposed
per
POTW
507
2,266
1,190
6,538
8,741
172
30
0.01
6,141
25,585
Weighted
Total Cost
of
Additional
Sewage
Sludge
Disposal
$58,735
26,395
-
55,086
436,182
-
151,164
-'
1,581,342
2,308,904
Total Cost
$89,110
868,498
194,400
2,402,608
493,755
1,616,019
410,141
' 40,500
3,484,772
9,599,803
"Cost of lime treatment plus disposal costs for additional sewage sludge is not known since no data
are available on current costs of storage. To be conservative, we have selected the cost of lime
treatment plus additional costs to be equal to codisposal costs at $313/dmt, although we do not
assume the POTW shifts sewage sludge to this option.
"These POTWs did not provide the cost of disposal. These costs were taken from similar size
POTWs in the other surface disposal category.
Source: ERG estimates.
B-9
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REFERENCES TO APPENDIX B
EPA. 1985. Handbook: Estimating Sludge Management Costs. EPA/625/6-85/010.
B-10
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APPENDIX C
SUPPORT MATERIAL FOR
SEWAGE SLUDGE INCINERATION COSTS
-------
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APPENDIX C
SUPPORT MATERIAL FOR
SEWAGE SLUDGE INCINERATION COSTS
C.1 INTRODUCTION
This appendix estimates the economic impact of the Part 503 sewage sludge regulation on
publicly owned treatment works (POTWs) operating sewage sludge incinerators. Section Four of
this RIA presents a pass/fail analysis that used the analytical portion of the 1988 National
Sewage Sludge Survey (NSSS) to derive compliance strategies for the POTWs that fire sewage
sludge in sewage sludge incinerators. The section then used the pass/fail results and other
information discussed in this Appendix and in Section Four to determine potential compliance
strategies for all POTWs that were estimated to fail the Part 503 pollutant requirements for
sewage sludge incinerators. The pass/fail analysis was based on two underlying regulatory
requirements. A POTW seeking compliance must meet emission levels of certain metals such
that any health risk created will be no greater than one in 10,000 (10"*) to the Highly Exposed
Individual (HEI). It must-also meet limits on organics in the stack gases. Organic pollutants in
stack gases must not exceed a monthly average concentration of 100 parts per million by volume
(ppmv) on dry basis Total Hydrocarbons (THC), measured hot as propane and corrected to 0-
percent moisture and 7-percent oxygen. The assessment of health risks posed by sewage sludge
fired in a sewage sludge incinerator was based on the emission characteristics of specific
pollutants of concern (e.g., chromium and cadmium) and accounts for the concentration of these
pollutants in sewage sludge and/or in stack gases. (For further information, see EPA's Technical
Support Document for Sewage Sludge Incineration [EPA, 1992].)
C.1.1 Pass/Fail Analysis of POTWs Practicing Sewage Sludge Incineration
To comply with Part 503 requirements, some POTWs might need to install additional
pollution control devices on their sewage sludge incinerators and make operational
C-l
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improvements. This section summarizes the results of the pass/fail analysis which was discussed
in detail in Section Four, and presents the underlying assumptions used to identify what types of
equipment POTWs would add, the changes they might make to their operating procedures, and
the costs of both of these compliance strategies.
EPA conducted the NSSS to obtain reliable, current data on sewage sludge generated at
POTWs, and on use or disposal practices and associated costs. From August 1988 to September
1989, EPA collected sewage sludge samples at 208 POTWs and analyzed them for more than 400
pollutants. In addition, EPA obtained data through detailed questionnaires from 479 POTWs
with at least secondary wastewater treatment. EPA used the results of the survey to determine
the impacts of pollutant limits, presented in the Part 503 regulation, on current POTW use or
disposal practices. Twenty-six of the NSSS POTWs surveyed practiced sewage sludge
incineration. Of this number, 23 operated their own sewage sludge incinerators. The other 3
transferred their sewage sludge elsewhere for sewage sludge incineration. In addition, one of the
23 incinerated minor amounts of sewage sludge and, at the time of the survey, appeared to be
shifting from incineration to another use or disposal practice. For purposes of this analysis, EPA
assumed that this POTW disposes of sewage sludge at a codisposal site, and will not be
incinerating sewage sludge. Thus this appendix investigates the impacts on the 22 POTWs that
are expected to continue to operate sewage sludge incinerators and extrapolates these impacts to
the 179 POTWs estimated to operate sewage sludge incinerators nationwide.
To determine which POTWs will require additional pollution control equipment to meet
the requirements of Part 503, EPA performed two separate pass/fail analyses: one for metals
emissions and a simple analysis for THC.
In the pass/fail analysis for metals emissions, EPA assumed that each of the 22 survey
POTWs that operate incinerators was operating the sewage sludge incinerator under a
"reasonably worst-case scenario." To simulate this scenario, the Agency used data on actual stack
heights, sewage sludge feed rates, and concentrations of pollutants in sewage sludge from the
NSSS. Data on control efficiencies were not available from the NSSS, so the Agency set the
existing pollution control efficiencies for the removal of cadmium, chromium, arsenic, lead, and
nickel to a median value, based on data from several sewage sludge incinerator units EPA has
C-2
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tested over the years. The median is considered conservatively low because the data include
observations associated with poorly operated equipment for which control efficiencies could
easily be improved. Furthermore, the percentage of chromium emissions assumed to be in its
most toxic (hexavalent) form was derived from the 90th percentile value obtained from recent
tests of incinerator units. A 90th-percentile concentration represents the highest 10 percent
hexavalent-to-total-chromium ratio detected in stack emissions.
Using this reasonably worst-case scenario, EPA determined whether a POTW was likely
to pass the metal pollutant requirements with current pollution control technology or whether
additional controls would be necessary (see Section Four). This analysis showed that 4 of the 22
POTWs surveyed by EPA as part of the NSSS were likely to fail the metal emission limits with
current air pollution control technology. When it was assumed, however, that these 4 POTWs
would install state-of-the-art pollution control equipment (e.g., wet electrostatic precipitators),
only 1 POTW (POTW 317), using a multiple-hearth furnace, was identified as likely to continue
to fail. This one failing POTW will most likely require more extensive, and thus more expensive,
pollution control equipment, as well as more precise operating controls.
For THC emissions, EPA determined that all fluid-bed combustors and multiple-hearth
furnaces equipped with afterburners are expected to meet the THC emission limit. The survey
of POTWs includes three plants using fluid-bed combustors and six plants operating multiple-
hearth furnaces equipped with afterburners. Based on studies of multiple-hearth furnaces and
THC emissions (Baker, 1991, and Baturay, 1991), EPA believes that all sewage sludge
incinerators, with proper operation, should be able to meet the proposed THC emission limit of
100 ppmv as propane adjusted for 0 percent moisture and 7 percent oxygen, measured as a
monthly average.
As noted earlier, the 22 survey POTWs statistically represent 179 POTWs operating
sewage sludge incinerator units nationally. The 4 survey POTWs EPA identified as likely to fail
the metal emissions limits with existing technology are nationally representative of 14 POTWs
that EPA estimates could fail the metal emissions requirements of the Part 503 regulation with
heir existing pollution control equipment.
C-3
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C.1.2 Pollution Control Devices for Sewage Sludge Incinerator Units
Almost all existing pollution control equipment installed in sewage sludge incinerators
arc wet scrubbers. These wet scrubbers can be retrofitted with add-on fine-particulatc
scrubbers—wet electrostatic precipitators (WESPs), Electro Dynamic Venturis (EDVs), and
Ionizing Wet Scrubbers (IWSs). More is known about the capability of WESPs to remove
cadmium and chromium from scrubbed gases exiting Venturi scrubbers than about the other
technologies because of recent pilot test studies and full-scale installations of WESPs at various
POTWs.
The exclusive references in this appendix to upgrading existing scrubbers with WESPs
should not be construed to mean that they are the only choice for retrofitting existing sewage
sludge incinerators, but that no test data on other types of wet finc-partieulate scrubbers are
available from which to estimate the performances of these scrubbers or to size equipment for
eost estimation.
The WESPs available for this application have been of the tubular type up- or down-flow
configurations and different charging and collecting electrode designs. The performance of a
WESP is influenced by its gas characteristics, the precipitator configuration, applied voltage.
current density, and specific collection area.
C.1.3 Sewage Sludge Incinerator Emissions
EPA's pass/fail analysis showed that, among metal emissions, cadmium and chromium
are the most difficult to maintain within the standards (see Section Four). In fact, excess levels
of these two metals in sewage sludge were most likely to be the cause for failure in the pass/fail
analysis among the surveyed POTWs (Jones and Knight, 1991; Jones, personal communication,
October. 1992), EPA's research on THC emissions from sewage sludge incinerators indicated
that most multiple-hearth incinerators would be able to meet the THC emission standard with
some minor modifications to operations or equipment. To determine if it is theoretically
possible for those POTWs with the highest metal emissions to meet the regulation, EPA
C-4
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analyzed a variety of compliance strategies. These strategies represent options that those
POTWs could put into effect to address their high emission levels of cadmium and chromium.
EPA's research on metals emissions from sewage sludge incinerators indicated that
chromium emissions are a primary cause for concern because of the relatively high conversion
rate of trivalent chromium (Cr3) to the toxic hexavalent form (Cr*6) in the multiple-hearth
furnaces that were tested (Jones and Knight, 1991; Jacobs, 1991; DeWees et al., 1990). The data
further indicated that WESPs, which may increase the removal of metals, particulates, and
condensed organic matter, might not be very effective in removing hexavalent chromium from
stack gases (Segall et al., 1991a, 1991b). One emissions test conducted at a fluid-bed sewage
sludge incinerator unit indicated that the level of hexavalent chromium in scrubbed gases exiting
from the fluid-bed combustors might actually be low. However, the paucity of the data and the
low chromium concentration in the sewage sludge at these test incinerators did not strongly
support a conclusion that oxidation of chromium in the fluid-bed combustors is generally less
than the ratio obtained in the multiple-hearth furnaces (Segall et al., 1991a, 1991b, 1991c).
To control cadmium emissions, the survey analysis shows that emission limits can be met
fairly easily by installing WESPs. Although cadmium and hexavalent chromium from flue gases
might be removed by other add-on scrubbers, such as EDVs or IWSs, or by completely replacing
existing equipment with baghouses or fabric filters, no data on the removal of hexavalent
chromium by these systems have been collected.
For THC emissions, although the fluid-bed combustors that were tested consistently met
the 100 ppmv THC emission limit by improving operations, some of the multiple-hearth furnaces
were found to require operational improvements and minor equipment modifications to satisfy
the same criteria (Chehaske et al., 1991).
The following three sections (C.2, C.3, and C.4) describe in greater detail the compliance
problems that are presented by chromium and cadmium as well as metal emissions in general.
For each pollutant, the description includes the nature of the emission, emissions tests and the
conclusions drawn from them, and compliance strategies. Following these sections, Section C.5
C-5
-------
presents cost estimates for pollution control equipment options and then details the methodology
used to determine the costs.
C.2 EFFECTS OF POLLUTION CONTROL DEVICES ON CHROMIUM EMISSIONS
FROM SEWAGE SLUDGE INCINERATORS
The survey analysis indicates that a multiple-hearth furnace installed at one large
wastcwater treatment works located in an industrial city will have difficulty meeting the
chromium emission limit even with improved air pollution control equipment when firing sewage
sludge. To deteiTnine the cost of complying with the Part 503 regulation, it is necessary first to
develop a compliance strategy for this treatment works. Toward this end, EPA analyzed the
chromium emission and speciation data that the Agency and other researchers recently
developed, and evaluated the capability of WESPs to remove chromium escaping from Venturi
scrubbers. These results are discussed below.
C.2.1 Nature of Chromium Emissions
Chromium is not considered a volatile rnetal and is therefore not likely to be emitted in
gaseous form. However, the data suggest that the fly ash produced by sewage sludge incineration
can become slightly enriched with chromium during combustion or flue gas cleaning (ITC and
Carlson, 1991; Carroll et al., 1989). The data show that the emission factor for chromium in
sewage sludge incinerator units equipped with a combination Venturi and impingement plate
scrubber was between 0.07 percent and 2.60 percent for multiple-hearth furnaces and 0.09
percent to 0.66 percent for fluid-bed combustors (Baturay, 1992).
The chromium enrichment observed from the data might be attributable to one
phenomenon or a combination of phenomena. For example, tests sponsored by EPA indicate
that incinerator units installed with a combination Venturi and impingement scrubber might
collect chromium in the trivalent form more efficiently than in the hexavalent form (Segall et al.,
1991a), leaving elevated levels of hexavaient chromium in the fly ash. Other research conducted
C-6
-------
by EPA indicates that wet scrubbers are less efficient in collecting chromium in the presence of
chlorine (Carroll et al., 1989).
It is also possible that the degree of sewage sludge treatment might be another factor in
whether chromium enrichment of fly ash occurs. Sewage sludge undergoing biological treatment
tends to form into smaller particles than does primary-treated sludge. Smaller particles attract
the chromium more readily than larger ones because, by volume, they have a larger relative
surface area for adsorption. These smaller particles containing chromium can then become lifted
preferentially with the gas flow in the furnaces, causing enrichment in the uncontrolled fly ash
emissions (Lester, 1987). Another enrichment possibility is that some of the chromium in sewage
sludge can form volatile compounds (i.e., CrO2Cl2), which are preferentially adsorbed by smaller
particles, thus making their collection in the scrubber more difficult.
Although it appears that the Venturi scrubbers are effective in removing chromium, little
is known about the valency state of the chromium being emitted. The data base for the emission
of chromium in hexavalent form is very limited because the methodology for sampling and
analysis of this metal was only recently developed and validated (DeWees et al., 1990). This
limited data base includes information obtained from recent EPA-sponsored tests conducted at
three sewage sludge incinerators (Jacobs, 1991, and DeWees et al., 1990). Two of these tests
were conducted at multiple-hearth furnace installations (known by EPA as Site 6 and Site 9); the
third was at a fluid-bed incinerator unit (Site 8).
C.2.2 Chromium Emission Tests
Each of the three sewage sludge incinerators on which EPA performed emission tests
(Sites 6, 8, and 9) is outfitted with similar pollution control devices. The multiple-hearth furnace
at Site 6 is equipped with a Venturi scrubber and an impingement plate aftercooler. The sewage
sludge at this POTW is conditioned with lime and ferric chloride, which is expected to increase
the oxidation of chromium from the trivalent to hexavalent form (Barton et al., 1991).
C-7
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The multiple-hearth furnace at Site 9 is also equipped with a combination Venturi and
impingement scrubber but was retrofitted with a full-size up-flow WESP. This POTW incinerates
sewage sludge generated onsite, as well as sewage sludge transferred from other wastewater
treatment works. Although sewage sludge from Site 9 is conditioned with polymers, EPA
suspects that some of the transferred sewage sludge incinerated during the tests might have been
conditioned with lime before transfer.
The fluid-bed combustor at Site 8 is also equipped with a combination
Vcnturi/impingement plate scrubber. During emission tests, a pilot-scale down-flow WESP was
added to the existing scrubber to determine the effectiveness of the WESP in removing
additional pollutants. No lime was added to the sewage sludge incinerated at this location.
At the two multiple-hearth furnace installations, EPA sponsored a series of experiments
to improve combustion through operational improvements for lowering THC emissions (DeWees
ct al., 1990). These experiments were conducted during stack sampling for metal emissions and
testing for the valency of chromium in fly ash. The data obtained from these tests indicated that
the controlled emission rate of total chromium exiting a scrubber is highly dependent on the
chromium concentration in the sewage sludge and the performance of the Venturi scrubbers,
while the conversion of trivalent to hexavaient chromium was influenced most by the operating
temperature of the multiple-hearth furnaces. EPA also expects that the amount of lime added to
sewage sludge as a conditioner prior to incineration also increases the conversion of trivalent to
hexavaient chromium. Since lime was added at both Site 6 and Site 9, however, the tests could
not conclusively prove this hypothesis.
The variety of conditions existing at each POTW makes it imperative that each site be
analyzed individually. During the tests, the chromium removal efficiency at Site 6 was 99.5
percent, which is to be expected from most multiple-hearth furnaces equipped with similar air
pollution control equipment. By comparison, the chromium removal efficiency at Site 9 was only
89.0 percent without a WESP, which is considerably lower than the average efficiencies exhibited
by other multiple-hearth furnaces equipped with similar scrubbers. Since Site 6 and Site 9 both
have multiple-hearth furnaces and combination Venturi/impingement scrubbers; the variation in
chromium removal efficiency has been attributed to a number of factors, including the increased
-------
chromium concentration in the sewage sludge at Site 6. The chromium content of the sludge
incinerated at Site 6 (200 mg/kg, dry weight) was almost twice the concentration found at Site 9
(110 mg/kg, dry weight) (Segall et al., I991b and 1991c).
It has generally been accepted that as pollutant concentrations in the sewage sludge
increase, pollution control devices become more efficient in removing the pollutants. In addition,
there is also a theoretical threshold concentration level at which the pollutant concentration
becomes so low that any further reduction cannot be easily or economically attained. Even
though the chromium removal efficiency can be higher at a treatment works that incinerates
sewage sludge with a high chromium content as compared to another incinerating low-chromium
sludge, more total chromium will be emitted from the first, all other variables being equal.
Another condition that might have lowered the chromium removal efficiency at Site 9 is
the performance of its Venturi scrubber. The average controlled total chromium concentration
in the flue gas at Site 9 was measured at 15.06 /zg/dscm, which is considerably greater than the
3.95 /Ag/dscm measured at the discharge of the impingement plate scrubber at Site 6. These
results indicate that the Venturi scrubber at Site 6 was more efficient in removing chromium,
even though it had about twice the chromium concentration in the sewage sludge. The
chromium concentration at the discharge of the WESP added at Site 9, however, was 1.99
/ig/dscm, which is close to the Site 6 emissions data. To make up for an inefficient scrubber, Site
9 needed a WESP, which eventually brought its chromium emissions close to that observed at
Site 6 without a WESP.
Although the WESP installed at Site 9 removed 87.25 percent of the chromium from the
flue gases exiting the Venturi scrubber, it improved the overall system efficiency to only 98.60
percent, which is not representative of what is normally achieved with this type of pollution
control equipment. The data suggest that the lower chromium removal efficiency at Site 9, even
with the WESP, is also highly influenced by the effectiveness of combustion and not influenced
by the total concentration of chromium-in the scrubbed gases (as shown in Figure C-l). For
instance, the multiple-hearth furnace at Site 9 might have been operated at a higher temperature,
which would have increased the conversion of trivalent to hexavalent chromium. The data
C-9
-------
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C-10
-------
suggest that once hexavalent chromium is formed, as mentioned earlier, it is nearly impossible to
capture using a WESP.
The ratio of hexavalent to total chromium in the controlled emissions at Site 9 was one
whole order of magnitude greater than the ratio at Site 6. Because the conversion of trivalent to
hexavalent chromium is basically an oxidation reaction, the conversion is expected to have
increased with improved combustion. The tests conducted at Site 6 and Site 9 support this
hypothesis (Segall et al., 1991 c). During the tests, the multiple-hearth furnace at Site, 6i was
operated in two modes. In the first mode, the furnace used large quantities of auxiliary fuel with
high hearth temperatures to promote complete combustion, and thus lower the emission of
carbon monoxide (CO). In this "low CO" mode, THC emissions were lower and the oxidation ,
rate of chromium to the hexavalent form was higher than rates observed during the "normal"
operating mode (see Figure C-2). Although the multiple-hearth furnace at Site 9 was also tested
in both normal and low-CO modes, the hexavalent chromium emissions were determined only in
the low-CO mode because of problems encountered with sampling in the normal mode.
However, the tests indicated that, in the low-CO mode, the hexavalent-to-trivalent-chromium
ratio in the scrubbed gases was very similar to the results obtained at Site 6.
The results from the fluid-bed combustors contrast sharply with the emission data for the
multiple-hearth furnaces. The fluid-bed combustor at Site 8, which is also equipped with a
combination Vemuri and impingement plate scrubber, achieved a 99.976 percent chromium
removal efficiency. With the addition of the pilot-scale WESP, the overall chromium removal
efficiency increased to 99.99 percent, with an incremental removal rate of 62 percent at the
WESP. The chromium concentration registered 1.78 /ig/dscm in the flue gas at the discharge of
the Venturi/impingement plate scrubber and 0.97 /ig/dscm at the discharge of the WESP (Segall
et al., 1991a). These results indicate that the WESP was not effective in removing the chromium
remaining after the scrubber, which is probably the result of the very low chromium
concentration in the flue gas.
Although the fluid-bed combustors that EPA tested produced lower chromium emissions
than the multiple-hearth furnaces, the greater control efficiencies associated with these fluid-bed
incinerators might be a result of site-specific conditions rather than incinerator type. It is likely
C-ll
-------
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C-12
-------
that the greater removal efficiency at Site 8 is influenced by the following factors: the unit has
an efficient Venturi scrubber, the sewage sludge fired in this unit has not been conditioned by
lime, and the unit operates at a low temperature. To conclude, therefore, that fluid-bed
combustors are more efficient at removing chromium than multiple-hearth furnaces might be
erroneous. Furthermore, those conditions that greatly influence an incinerator's pollutant
removal efficiency and that determine whether that incinerator can meet the new emissions
requirements might be overlooked.
It appears that all POTWs could meet the emissions criteria in the Part 503 regulation
with the addition of a WESP, as long as several conditions were also met, including optimizing
the existing scrubber performance, minimizing hexavalent chromium formation by operating in
cool mode at lower temperature, and incinerating sewage sludge that has a low chromium
content and that has not been conditioned with lime.
C.2.3 Conclusions Drawn from Chromium Emission Test Data
The following conclusions have been drawn from the test data regarding the operating
parameters and equipment performance of POTWs operating sewage sludge incinerators:
The hexavalent-to-total chromium ratio (Cr+6/Total Cr) in the uncontrolled
emissions from fluid-bed combustors burning sewage sludges with low chromium
concentrations can be between 0.0001 and 0.0026. The Cr+6/Total Cr ratio in the
uncontrolled emissions from the multiple-hearth furnaces has not been tested.
Although high-energy Venturi scrubbers might be effective in removing both
trivalent and hexavalent chromium from flue gases, the removal efficiency for
chromium in trivalent form has been found to be higher than that for hexavalent
chromium.
The greater the concentration of hexavalent and trivalent chromium in the flue
gas, the more efficient a WESP will be in collecting them. If the concentration
of these metals is low, a WESP positioned downstream from even efficient air
pollution control equipment, such as a high-energy Venturi scrubber, might not
efficiently remove either species of chromium. On the other hand, a WESP can
be very effective if the concentration of these metals in scrubbed gases is high;
high concentrations might be associated with a poorly performing Venturi
scrubber or high chromium concentration in the sewage sludge being fired.
C-13
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The greater the combustion efficiency in multiple-hearth furnaces, the larger the
ratio of Cr+6/Total Cr will be in the emissions. In the normal mode of operation,
when the top hearth temperature is about 800°F, the Cr+6/Total Cr ratio in the
controlled emission can be between 0.01 to 0.03. If the furnaces were operated
with high amounts of auxiliary fuel, however, and the top hearth temperatures
reach above 1,000°F, the Cr+6/Total Cr ratio can reach to about 0.30.
C.2.4 General Compliance Strategies for Controlling Chromium Emissions
Based on the conclusions above, site-specific strategies were developed to reduce the risk
posed by hexavalent chromium emissions. In addition to sewage sludge pretreatment, these
strategies might comprise one or more of the following options:
• Optimize the existing Venturi scrubber performance so that it reaches its highest
chromium removal efficiency, or add Venturi scrubbers at those installations
equipped with only an impingement plate or cyclonic scrubber.
• Add fine particulate scrubbers, such as a WESP, to existing wet air pollution
control equipment to enhance system performance.
• Minimize chromium conversion from the trivalent to hexavalent state by operating
multiple-hearth furnaces in normal (cool) mode with top-hearth temperatures
about 800°F, and install external afterburners to control THC emissions, if
necessary.
• Minimize chromium conversion from the trivalent to hexavalent state by
minimizing the amount of lime added to the sewage sludge as a conditioner.
• Increase stack height to improve emission dispersion and reduce the maximum
ground level concentration for the HEI.
C.2.5 Site-Specific Compliance Strategies for Controlling Chromium Emissions Using
WESPs
As mentioned earlier, one NSSS POTW (317) was expected to have difficulty meeting the
health-risk criteria for chromium emissions. Additionally POTW 319, although passing the
chromium limit, needs close to the median control efficiency for a WESP to ensure that this limit
C-14
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is met. The responses of these two POTWs to the NSSS were analyzed to determine whether
the installation of WESP controls would bring chromium emissions into compliance with the final
regulation. The preliminary analysis indicated that POTW 317 would require a 99.15 percent
chromium removal efficiency to meet the regulation, while the control requirement on POTW
319 would be even higher, at 99.70 percent.
' £
The EPA data indicates that the total chromium removal efficiency of 99.15 percent is
achievable with a combination of a Venturi scrubber and a WESP for satisfying the requirement
of POTW 317. The addition of WESPs to the existing Venturi scrubbers at POTW 319 may not
suffice to meet the needed 99.70 percent chromium removal efficiency. However, it is possible to
" - • ••• \.
reduce the chromium efficiency requirement by minimizing the formation of hexavalent •.*,-
chromium by operating the furnaces in the normal (cool) mode. As data indicates, the -^
hexavalent-to-total chromium ratio can be reduced to about 0.03 by running in this mode of
operation. By limiting the hexavalent formation, a Venturi scrubber and WESP would be able to
provide sufficient efficiency for meeting the regulatory requirement. This strategy might require
that the THC reduction is accomplished with a post-scrubber afterburner (although EPA believes
that the removal needed would be achieved without an external afterburner).
C.3 EFFECTS OF POLLUTION CONTROL DEVICES ON CADMIUM EMISSIONS FROM
SEWAGE SLUDGE INCINERATORS I
C.3.1 Nature of Cadmium Emissions and Cadmium Emission Tests
Cadmium and most of its compounds are considered volatile. The boiling point of
cadmium is reported to be 1,409°F; cadmium oxide decomposes between 1,650°F and 1,830°F;
and cadmium chloride boils at 1,760°F. Researchers have demonstrated that both uncontrolled
and controlled emissions of cadmium increase with a rise in combustion temperature. In
addition, cadmium, like other volatile metals, might vaporize during combustion and, when
cooled, condense on fly ash particles. As mentioned earlier, smaller particles offer a larger
relative surface'area'for adsorbing condensing metals. Therefore, mosiTof the cadmium appears
to bind to smaller ash particles (see Figure C-3). Because the Venturi and impingement plate
C-15
-------
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scrubbers are not efficient in removing submicron-sized particles, the controlled cadmium
emissions from sewage sludge incinerators are relatively high. Up to 30 percent of cadmium
emitted from the combustors is not captured by conventional pollution control equipment.
The data indicate that, although the controlled cadmium emissions from both types of
incinerator units are sensitive to combustion temperatures, the problem is probably less prevalent
for fluid-bed combustors than for multiple-hearth furnaces. Because of better mixing
characteristics and uniform temperature profiles in fluid-bed combustors, these units could be
operated at lower temperatures (less than 1,600°F), which minimize vaporization of volatile
metals while still meeting the 100 ppmv THC emission limit. The data also show that, at
operating temperatures of about 1,700°F, the controlled emissions of cadmium from fluid-bed
combustors equipped with a combination Venturi/impingement scrubber can reach as high as 40
percent (White and Beluzo, 1980).
Cadmium emissions from multiple-hearth furnaces equipped with a combination
Venturi/impingement scrubber increase with increases in the hearth temperature. This effect is
clearly observed during tests of the multiple-hearth furnace at Site 6, where cadmium emissions
were measured while the furnace was operating in normal (cool) and low-CO (hot) modes
(Segall et al., 1991a). The cadmium emission data are presented in Figure C-4 as a function of
top-hearth temperature. Another factor that might also influence the cadmium concentration in
scrubbed gases is its initial concentration in the sewage sludges being incinerated.
C.3.2 General Compliance Strategies for Cadmium Emissions
The strategies presented for reducing the health risk from cadmium emissions are similar
to those described for chromium. In addition to lowering the cadmium concentration in sewage
sludge by pretreatment, these options are as follows:
Optimize the existing Venturi scrubber performance for the best cadmium
removal efficiency, or install a Venturi scrubber if the installation is equipped with
only an impingement plate or cyclonic-type scrubber.
C-17
-------
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C-18
-------
Supercool gases in the aftercooler (to 80° to 100°F) to maximize the condensation
of cadmium vapors, and add a wet fine particulate scrubber to collect the
condensed cadmium.
Minimize the volatilization of the cadmium by operating multiple-hearth furnaces
in normal (cool) mode with top-hearth temperatures about 800°F, and install
external afterburners for the control of THC emissions, if necessary.
Increase stack height to improve emission dispersion and reduce the maximum
ground level concentration for the Highly Exposed Individual (HEI).
C.3.3 Site-Specific Compliance Strategies for Controlling Cadmium Emissions
by WESPs
The feasibility of controlling cadmium emissions with WESPs at POTWs 317 and 319 has
been investigated, just as it was for chromium emissions. The results of this evaluation indicate
that, at both locations, WESPs will be capable of lowering cadmium emissions to the level
required by the final regulation.
C.4 OPERATIONAL, IMPROVEMENTS TO REDUCE METAL EMISSIONS
The emissions of metals from multiple-hearth furnaces and fluid-bed combustors can be
reduced using several operational approaches. These reductions can be made by changing the
operational methods or modifying hardware. Improvements made in one type of pollution
(metals), however, often increase emissions of another type of pollutants (organics). The
following five operational improvements could lead to significant reductions in emissions of
metals and organics.
C.4.1 Better Operator Skills
In spite of all the available modern control and instrumentation systems, the operation of
sewage sludge incinerators remains more of an art than a science. The quality of the operation
C-19
-------
of sewage sludge incinerators would be improved by instituting a certification program. The
certification and training program instituted by the State of Maryland is a good model for such a
program (State of Maryland, 1991).
C.4.2 Improvements in Sludge Feed Rate
Variation in the sewage sludge feed rate is the most common cause of high emission rates
of both metals and THC from sewage sludge incinerators. Multiple-hearth furnaces are more
sensitive to changes and interruptions in sewage sludge feed rates and variations in sewage sludge
characteristics than are fluid-bed combustors. Because the operation of multiple-hearth furnaces
is inherently unstable, because these furnaces are slow to react, and because the sewage sludge
inventory in these furnaces is large, changes in moisture content of the sewage sludge or the feed
rate cause the fire to move within the furnace and disturb the established burning pattern.
During these transient conditions, which may last for several hours, more than the usual
quantities of sewage sludge may be burning. Because the amount of air needed to combust large
quantities of sewage sludge cannot be satisfied, the furnace under these conditions may smoke,
causing the emission of large amounts of unburned organic matter in the form of THCs. During
these transitory conditions, high combustion temperatures can also cause emissions of the volatile
metals to increase.
Providing sewage sludge feed at a steady rate with reasonably constant characteristics
(moisture and heat content) would improve the multiple-hearth furnace performance. The ease
with which the sewage sludge feed rate and sludge characteristics can be kept constant, however,
depends on the dewatering equipment and the arrangement of the conveying equipment feeding
the sewage sludge cake. Surge hoppers and tanks are messy solutions, and sludge bunkers are
difficult and sloppy to operate. Recent advances in centrifugal dewatering offer improvements,
with quick-response controls and a direct sewage sludge feed system with positive displacement
pumps.
The operation of fluid-bed combustion systems is also affected by changes in the sewage
sludge feed rate,, but to a lesser degree than that for multiple-hearth furnaces. Because of the
C-20
-------
small inventory of sewage sludge in the combustor and the inherently quick-response capability of
the fluid-bed, the transitory conditions might last only a few minutes—not as long as upsets in
multiple-hearth furnaces.
C.4-3 Improvements in Combustion Characteristics
It has been observed in multiple-hearth furnaces that overbed firing of auxiliary fuel,
especially natural gas, stabilizes the burning zone and helps maintain a more uniform
temperature profile, resulting in lower THC emissions. The observations and the test data
indicate that THC emissions from multiple-hearth incinerators can be reduced to below 100 ppm
solely by operational means, at some installations. However, firing auxiliary fuel above the
burning zone requires a careful balance. Although overheating sewage sludge in the drying zone
would cause volatilization and the escape of volatile organic matter, increasing the temperature
in the burning zone can result in volatilization of metals and cause formation of clinkers.
C.4.4 Improvements in Air Distribution
Air is typically introduced into multiple-hearth furnaces by draft induction through air
ports or doors. The hot air then returns through the center shaft. Because many air leaks can
be present and because air ports are often poorly located for ventilation, the air supply for
combustion can be difficult to control. Air supply control can be improved, however, by limiting
or eliminating air leaks and by providing a forced-air system for better control.
C.4.5 Optimize Venturi Scrubber Performances
Venturi scrubbers usually perform best at a specific gas/water ratio. Usually, this ratio
represents the maximum design conditions. Most of the time, however, sewage sludge
incinerators operate at levels lower than the maximum design conditions. The efficiency of the
C-21
-------
Venturi scrubbers often can be improved by adjusting the gas/water ratio to the actual operating
conditions.
C.5 COST ESTIMATES FOR EMISSION CONTROL STRATEGIES
C.5.1 Pollution Control Equipment and Associated Costs
EPA estimates that all fluid-bed combustors would be able to meet the metal emission
requirements without requiring equipment modifications. EPA believes that 14 POTWs
operating multiple-hearth or other incinerators have to retrofit their existing wet scrubbers with
fine-particulate scrubbers (e.g., WESPs), and all POTWs are expected to meet the THC
requirements with no modifications to equipment or operations. Because the proposed standard
does not require lower emissions of THC than those currently experienced, the cost for
compliance with the THC standard, other than for monitoring and testing, is insignificant. A
summary of annualized compliance costs for adding WESPs and the cost for installing and
operating flame ionization detectors (FIDs) for continuous monitoring of the THC emissions is
presented in Table C-l.
C.5.2 Methodology Used to Determine Cost Estimates for Emission Control Strategies
C.5 2.1 Introduction
This section outlines the steps taken and the calculations performed to prepare the cost
estimates for the emission control strategy described in the previous section. The methodology
used to prepare the cost estimate includes eight steps, most of which refer the reader to tables
that summarize the computations for that step. After outlining the steps, this section describes
each table in detail.
Compliance costs were based on 23 POTWs that EPA surveyed as part of the 1988 NSSS
that operate sewage sludge incinerators (see Section C.I). EPA believes that all but one of these
C-22
-------
Table C-1
COST FOR COMPLIANCE FOR PROPOSED REGULATIONS
SEWAGE SLUDGE INCINERATORS
($1000)
COST OF COMPLIANCE WITH METAL EMISSIONS (1)
CAPITAL
OPERATING
MAINTENANCE
2377
767
425
SUBTOTAL
(1) FOR RISK LEVEL 1/10,000
3569
COST OF COMPLIANCE WITH THC MONITORING
CAPITAL
MAINTENANCE
3338
3586
SUBTOTAL
6924
TOTAL ANNUAL COST FOR COMPLIANCE: $10,493
C-23
-------
23 facilities will attempt to meet the criteria in the Part 503 regulation and not shift to another
use or disposal practice. One other surveyed facility incinerated a minor amount of sewage
sludge and, at the time of the survey, appeared to be shifting away from incineration to
codisposal. The costs associated with this shift are discussed in Section Four.
The 22 NSSS POTWs represent similar POTWs around the country that can be expected
to have similar compliance costs in adjusting to the Part 503 regulation. These 22 survey
POTWs include 19 multiple-hearth furnace installations nationally representative of 113 POTWs,
and 3 fluid-bed combustion systems representing 66 POTWs. Although some of these 179
POTWs operate single incinerators, most have multiple units. Of the 277 incinerator units
represented by this study, 181 are multiple-hearth units and 96 are fluid-bed combustors. The
annual aggregate quantity of sewage sludge incinerated by these units is about 1,279,000 dry tons
per year (DTPY) (based on annual throughput as reported in the NSSS and weighted using
analytical survey weights) of which 84 percent is incinerated in multiple-hearth furnaces, while
the remaining 16 percent is processed in fluid-bed combustors.
The NSSS indicated that fluid-bed combustors usually are installed at relatively small
wastewater treatment works with an average sewage sludge incineration throughput rate of 3,200
dry tons per day (DTPD), whereas the average rate for plants with multiple-hearth furnaces is
9,500 DTPD. The survey results indicate that with proper operation, the fluid-bed combustion
systems should be able to meet both the metals requirements and the THC emission limit of 100
ppmv dry, measured hot as propane and corrected to 7 percent oxygen and zero moisture.
Multiple-hearth furnaces (as well as electric and flash-drying furnaces), however, will encounter
greater compliance costs because of the need to develop more extensive metal emission control
strategies. This section on compliance cost methodology, therefore, focuses mainly on these
nonfluid-bed installations.
C.5.2.2 Methodology
The following steps were taken to determine the costs of modifying sewage sludge
incinerators to meet the Part 503 requirement.
C-24
-------
1. Determine the number (population) of incinerator units to be included in the
analysis.
2. Select models representative of the incinerator population.
3. Evaluate the need for improvements to meet the new regulatory requirements for
the model incinerator units.
4. Identify technologies for meeting the improvement needs.
5. Estimate capital costs for retrofitting different sizes of incinerator units with the
additional air pollution control equipment (WESPs) needed to meet the new
regulatory requirements.
6. Estimate capital cost for retrofitting the model and similar incinerator units with
the additional air pollution control equipment (WESPs) needed to meet the new
regulatory requirements.
7. Estimate labor and maintenance costs for the,operation of the additional air
pollution control equipment (WESPs) for the model and similar incinerator units.
8. Estimate capital and operational costs for outfitting the incinerator units with
FIDs to monitor THC emissions.
C.5.2.3 Determination of Costs
Capital Costs of WESPs
Tables C-2 and C-3 estimate the cost of adding WESPs to existing scrubbers. The cost of
adding a WESP is significantly influenced by the construction material chosen, in addition to the
pollutant removal efficiency requirements. Because WESPs also remove acid mist from flue
gases, the selection of material for construction depends on the amount of acidic compounds in
the flue gases exiting the existing scrubbers.
Equipment costs listed in Table C-2 are based on quotes obtained from an equipment
vendor (SES, 1991). The costs include necessary ducts and dampers, foundations, building
modifications to accommodate the WESP, piping, and wiring. The WESPs can be installed
either on the inlet or outlet side of the induced draft (ID) fans. Installation at the inlet side of
C-25
-------
Table C-2
WET ELECTROSTATIC PRECIPITATOR (WESP) COST ESTIMATE
GAS
1)
2)
A)
FLOW RATE TO WESP (ACFM)
DIRECT COSTS
EQUIPMENT PURCHASE (1)
AUXILIARIES (2)
DUCTS AND DAMPERS (3)
SUBTOTAL: PURCHASES
FOUNDATIONS
HOUSING
PIPING
WIRING
SUBTOTAL: INSTALLATION (4)
TOTAL DIRECT (1 + 2)
5000
181
18
36
235
7
18
5
5
36
272
8000
218
22
43.6
283
8.72
21.8
7
7
43.6
327
11000
($1000)
230
23
46
299
9.2
23
7
7
46
345
14000
256
26
51.2
333
10.24
25.6
8
8
51.2
384
17000
299
30
59.8
389
11.96
29.9
9
9
59.8
449
20000
308
31
61.6
400
12.32
30.8
9
9
61.6
462
23000
317
32
63.4
412
12.68
31.7
10
10
63.4
476
24000
337
34
67.4
438
13.48
33.7
10
10
67.4
506
INDIRECT COSTS
CONTRACTOR'S MARKUP (5)
ENGINEERING (6)
CONSTRUCTION SUPERVISION (7)
STARTUP (8)
TESTING (9)
41
27
14
20
75
49.05
32.7
16.35
20
75
51.75
34.5
17.25
20
75
57.6
38.4
19.2
20
75
67.275
44.85
22.425
20
75
69.3
46.2
23.1
20
75
71.325
47.55
23.775
20
75
75.825
50.55
25.275
20
75
B) TOTAL INDIRECT
TOTAL INSTALLED COST (A+B)
176
193.1
198.5
210.2 229.55
233.6 237.65 246.65
448
520.1
543.5
594.2 678.05
695.6 713.15 752.15
NOTES:
11) Includes transformer and controls
(2) Assumed 10% of purchase price
(3) Assumed 20% of purchase price
(4) Includes piping and wiring to WESP
(5) Assumed 15% of total direct cost
(6) Assumed 10% of total direct cost
(7) Assumed 5% of total direct cost
(8) Includes only WESP
(9) Includes only WESP
C-26
-------
Table C-3
CAPITAL COST FOR RETROFITTING MULTIPLE HEARTH FURNACES
WITH WET ELECTROSTATIC PRECIPITATORS
(SI 000)
PLANT FURNACES SIMILAR NUMBER OF HEARTH CAPITAL PER COST
NUMBER IN PLANT PLANTS FURNACES FURNACE COST PLANT ALL PLANTS
(number) (number) (number) (number) SIZE ($1000) ($1000) ($1000)
8
9
10
15
4
1
4
4
6
6
1
1
24
6
4
4
22'x8
14'x6
22'x9
22'X9
645
375
700
700
2580
375
2800
2800
15480
2250
2800
2800
TOTALS
14
38
23330
NOTE:
1) Annualized cost is calculated at 8% interest rate for 20 years
TOTAL ANNUALIZED COST:
$2,377,327
C-27
-------
the fan is desirable at those installations where the accumulation of ash at the ID fan is a
problem. The existing ID fans can easily accommodate the additional pressure drop
requirement accompanying the addition of a WESP because the pressure drop is relatively low
(1 to 2 inches of WC). If an additional couple of inches is not available, the pressure drop at
the Venturi scrubbers can be lowered to compensate for the WESP requirements. The estimate
includes the cost of startup and testing of the WESP. The testing costs include stack testing for
metals and particulates by an independent testing organization. The cost estimates for
operation and maintenance are presented in Tables C-4 and C-5, respectively.
Capital and Operating Costs for THC Analyzers
To estimate the cost of installing THC analyzers, budget estimates from vendors were
obtained (Rosemount, 1991). Because of the complexity and delicate nature of a THC analyzer,
EPA researchers estimated that the analyzer would require the attention of a maintenance
worker at 1 hour per day, at a rate of $20 per hour, plus a 15 percent supervision fee. The
material cost for maintenance was estimated to be $2,550 per year, and the calibration gases
were estimated to cost about $2,000 per year. The total installed equipment cost was estimated
to be $85,000 per unit, including a heated sample probe, filter, THC analyzer, oxygen analyzer,
tubing and valves for calibration gases, flow meter, programmable logic controller (PLC),
control cabinet for housing instruments, and a recorder. The installation was estimated to cost
about $7,000, while unit startup, manuals, and operator training were estimated to cost about
$5,000 per unit. Engineering and testing fees are estimated to be $29,800 per plant.
In summary, the cost to install a THC analyzer for each sewage sludge incinerator unit
was estimated at $128,800, with operation and maintenance costs estimated at about $13,000 per
unit per year (see Tables C-6 and C-7).
C-28
-------
Table C-4
OPERATING COST FOR MULTIPLE HEARTH FURNACES
RETROFITTED WITH WET ELECTROSTATIC PRECIPITATORS
($1000)
MODEL
PLANT
NUMBER
(number)
8
9
10
15
NUMBER OF
FURNACES
IN PLANT
(number)
4
1
4
4
NUMBER OF
SIMILAR
PLANTS
(number)
6
6
1
1
TOTAL
NUMBER OF
FURNACES
(number)
24
6
4
4
MULTIPLE
HEARTH
FURNACE
SIZE
22'x8
14'x6
22'x9
22'X9
UNIT
OPERATING
LABOR
COST (1)
19
19
19
19
PLANT ALL PLANTS
OPERATING
LABOR
COST (2)
37.78
18.89
37.78
37.78
OPERATING
LABOR
COST
227
113
38
38
SUBTOTAL
14
38
416
MODEL
PLANT
NUMBER
(number)
8
9
10
15
NUMBER OF
FURNACES
IN PLANT
(number)
4
1
4
4
NUMBER OF
SIMILAR
PLANTS
(number)
6
6
1
1
TOTAL
NUMBER OF
FURNACES
(number)
24
6
4
4
PLANT '
SLUDGE
RATE
(tpy dry)
16755
4085
49343
32218
TOTAL ASH
SLUDGE
RATE
(tpy dry)
100530
24510
49343
32218
DISPOSAL
RATE
(dty dry)
15.08
3.68
7.40
4.83
£LL PLANTS
ASH
DISPOSAL
COST (3)
3
1
1
SUBTOTAL
14
38
206601
30.99
62
MODEL
PLANT
NUMBER
(number)
8
9
10
15
NUMBER OF
FURNACES
IN PLANT
(number)
4
1
4
4
NUMBER OF TOTAL
SIMILAR NUMBER OF
PLANTS
(number)
6
6
1
1
FURNACES
(number)
24
6
4
4
PLANT
SLUDGE
RATE
(tpy dry)
16755
4085
49343
32218
TOTAL
SLUDGE
RATE
(tpy dry)
100530
24510
49343
32218
UNIT
POWER
COST (4)
($/dry ton)
1.40
1.40
1.40
1.40
. ALL PLANTS
WESP
POWER
COST
141
34
69
45
SUBTOTAL
14
38
206601
5.60
289
NOTES: 1) Assumed 1 hour per shift at cost of $15/hr + 15% supervision
2) Assumed single units operate 365 24-hr day and multiple units 5O% of time
3) Assumed $2000/dry ton ash disposal cost
4) Assumed $1.40 power cost per dry ton sludge incinerated at $0.06/kWh
TOTAL OPERATING COST:
$766,774
C-29
-------
Tub!* C-B
MAINTENANCE COST FOR MULTIPLE HEARTH FURNACES
RETROFITTED WITH WET aECTROSTATIC PRECIPITATORS
($1000)
MODEL NO OF NUMBER OF TOTAL MULTIPLE UNIT PLANT ALL PLANTS
PLANT FURNACES SIMILAR NUMBER OF HEARTH MAINTENANCE MAINTENANCE MAINTENANCE
NUMBER IN PLANT PLANTS FURNACES FURNACE LABOR LABOR LABOR
(number) (numtw) (number) (number) SIZE COST (1) COST (2) COST
8
9
10
15
4
1
4
4
6
6
1
1
24
6
4
4
22'x8
14'x6
22'x9
22'X9
8.40
8.40
8.4O
8.40
16.790
8.395
16.79O
16.790
101
SO
67
67
SUBTOTAL
14
38
286
MODEL NO OF NO OF TOTAL MULTIPLE ALL PLANTS UNIT ALL PLANTS
PLANT FURNACES SIMILAR NUMBER HEARTH WESP MAINTENANCE MAINTENANCE
NO IN PLANT PLANTS FURNACES FURNACE CAPITAL MATERIAL MATERIAL
(number) (number) (number) (number) SIZE COST COST (3) COST
8
9
10
15
4
1
4
4
6
6
1
1
24
6
4
4
22'x8
14'x6
22'x9
22'X9
15480
2250
28OO
28OO
0.006
0.006
O.O06
O.OO8
93
14
17
17
SUBTOTAL
14
38
23330
140
NOTES: 1) Assumed 1 hour per day at cost of $2O/hr +15% supervision
2) Assumed maintaining two units at a time for multiple units
3) Assumed maintenance material cost is 0.6% of installed cost
TOTAL MAINTENANCE COST:
$425,410
C-30
-------
Table C-6
CAPITAL COST FOR THC ANALYZERS
($1000)
MODEL
PLANT
NUMBER
(number)
1
2
3
4
5
6
7
8
9
10
11
12
13
15
16
17
18
19
20
23
22
24
TOTALS
NOTES:
NUMBER
FURNACE
IN PLANT
(number)
1
3
6
2
1
10
1
4
1
4
1
1
1
4
1
1
2
1
2
1
2
1
1 } Assumed
FURNACE
TYPE
(MHF/FB)
MHF
MHF
MHF
FBC
MHF
MHF
FBC
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
FBC
MHF
MHF
$99,000 per
NUMBER OF
SIMILAR
PLANTS
(number)
6
6
1
30
6
1
6
6
6
1
6
6
6
1
1
30
6
6
6
30
6
6
179
TOTAL
NUMBER OF
UNITS
(number)
6
18
6
60
6
10
6
24
6
4
6
6
6
4
1
30
12
6
12
30
12
6
277
DIRECT
COST
(2)
594
1782
594
5940
594
990
594
2376
594
396
594
594
594
396
99
2970
1188
594
1188
2970
1188
594
27423
INDIRECT
COST
(3)
179
179
30
894
179
30
179
179
179
30
179
179
179
30
30
894
179
179
179
894
179
179
5334
TOTAL
INSTALLED
COST
773
1961
624
6834
773
1020
773
2555
773
426
773-
773
773
426
129
3864
1367
773
1367
3864
1367
773
32757
incinerator including equipment and installation
2) Assumed $29,800 per plant including engineering, startup and testing
AMORTIZED CAPITAL COST:
3,337,959
C-31
-------
Tabla C-7
OPERATION AND MAINTENANCE COST FOR THC ANALYZERS
($1000)
MODEL
PLANT
NUMBER
(number)
1
2
3
4
5
6
7
8
9
10
11
12
13
15
16
17
18
19
20
23
22
24
TOTALS
NOTES:
NUMBER
FURNACE
IN PLANT
(number)
1
3
6
2
1
10
1
4
1
4
1
1
1
4
1
1
2
1
2
1
2
1
1 } Assumed
FURNACE
TYPE
IMHF/F8)
MHF
MHF
MHF
FBC
MHF
MHF
FBC
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
MHF
FBC
MHF
MHF
1 hour per
NUMBER OF
SIMILAR
PLANTS
(number)
6
6
1
30
6
1
6
6
6
1
6
6
6
1
1
30
6
6
6
30
6
6
179
TOTAL MAINTENANCE MAINTENANCE ALL PLANTS
NUMBER OF LABOR MATERIAL OPERATION &
UNITS
(number)
6
18
6
60
6
10
6
24
6
4
6
6
6
4
1
30
12
6
12
30
12
6
277
COST
(1)
50
151
50
504
50
84
50
201
50
34
50
50
50
34
8
252
101
50
101
252
101
50
2325
COST MAINTENANCE
(2)
27
82
27
273
27
46
27
109
27
18
27
27
27
18
5
137
55
27
55
137
55
27
1260
COST
78
233
78
777
78
129
78
311
78
52
78
78
78
52
13
388
155
78
155
388
155
78
3586
day at $20/hr + 15% supervision
2} Includes $2.550/unit parts and $2,OOO/unit supplies including calibration gases
ANNUAL MAINTENANCE COST:
$3,585,765
C-32
-------
REFERENCES TO APPENDIX C
Baker, Robert A. 1991. Review Comments on the. Regulation of Incinerator Emissions, 40 CFR
Part 503C Federal Register, November 19,1990. Letter to W. Diamond, EPA.
Association of Metropolitan Sewerage Agencies, Washington, DC. January 3.
Barton. R.G., W.R. Seeker, and H.E. Bostian. 1991. The Behavior of Metals in Municipal
Sludge Incinerators. Energy and Environmental Research Corporation and U.S.
Environmental Protection Agency. Publication No. EPA/600/J-91/130. U.S. EPA,
Cincinnati, OH.
Baturay, A. Carlson Associates. 1992. Data Base for Metal Emissions from Sewage Sludge
Incinerators. Carlson Associates, Catharpin, VA.
Baturay, A. 1991. Total Hydrocarbon Emissions from Multiple Hearth Furnaces. Proceedings
of the 84th Annual Meeting & Exhibition of Air & Waste Management Association,
Vancouver, British Columbia, June 16-21. Air & Waste Management Association.
Carroll, G.J., R.C. Thurnau, R.E. Mournighan, L.R. Waterland, J.W. Lee, and DJ. Fournier, Jr.
1989. The Partitioning of Metals in Rotary Kiln Incineration. For presentation at the
Third International Conference on New Frontiers in Hazardous Waste Management,
Pittsburgh, PA, September 10-13. U.S. Environmental Protection Agency and Acurex
Corp. Publication No. EPA/600/D-89/208. U.S. EPA Risk Reduction Engineering
Laboratory, Cincinnati, OH.
Chehaske, John T., W.G. DeWees, F.M. Lewis, and H.E. Bostian. 1991. Total Hydrocarbon
Emissions Testing of Sewage Sludge Incinerators. Draft Report. Contract No. 68-CO-
0027. Pacific Environmental Services, Inc., DEECO, Inc., and U. S. EPA Risk Reduction
Engineering Laboratory, U.S. Environmental Protection Agency, Cincinnati, OH.
DeWees, W.G, C.A. Davis, S.C. McClintock, A.L. Cone, H.E. Bostian, E.P. Grumpier, and S.C.
Steinsberger. 1990. Sampling and Analysis of Municipal Wastewater Sludge Incinerator
Emissions for Metals, Metal Species, and Organics. Proceedings of the 83rd Annual
Meeting and Exhibition of Air & Waste Management Association. Air & Waste
Management Association, Pittsburgh, PA.
EEMA. 1990. Contract Documents - Incinerator Air Pollution Control. Contract No. 89-53-
SH. Environmental Engineering & Management Associates, Inc., Upper Moreland-
Hatboro Joint Sewer Authority, Montgomery County, PA.
ITC and Carlson. 1991. Stack Emission and Capacity Test Report for Sewage Sludge
Incinerators—Foreign Sludge Facilities, Lower Potomac Pollution Control Plant.
International Technology Corporation and Carlson Associates. Department of Public
Works, Fairfax, VA.
Jacobs, H. 1991. Ratio of Hexavalent to Total Chromium Incineration Emission. Memorandum
' to A. Rubin. U.S. Environmental Protection Agency, Washington, DC June 28.
C-33
-------
Jones, A., and L. Knight. 1991. Preliminary Ideas for Compliance Strategies for Sewage Sludge
Incinerators. Memorandum to A. Baturay. Eastern Research Group, Arlington, MA.
September 17.
Knislcy, D.R... L.M. Lamb, and A.M. Smith. 1987. Site 1 Revised Draft Emission Test Report -
Sewage Test Program. Radian Corporation, Contract No. 68-02-6999. U.S.
Environmental Protection Agency, Water Engineering Research Laboratory, Cincinnati,
OH.
Lester, J.N. 1987. Heavy Metals in Wastewater and Sludge Treatment Processes. CRC Press,
Inc., Boca Raton, FL.
PEI and Carlson. 1989. Emission Test Report for Sludge Incinerator No. 1 at Site A. PEI
Associates and Carlson Associates, Catharpin, VA.
Rosemount. 1991. Budget Proposal to Carlson Associates. Rosemount Analytical, Inc., La
Habra, CA.
SEC. 1991. Budget Proposal to Carlson Associates. Smith Environmental Corporation,
Ontario, CA.
Scgall, R.R., W.G. DeWecs, and P.M. Lewis. 1991 a. Emission of Metals, Chromium, and
Nickel Species, and Organics from Municipal Wastewater Sludge Incinerators, Volume
VI: Site 8 Emission Test Report. Entropy Environmentalists, Inc. and DEECO, Inc.
EPA Contract No. 68-CO-0027. U.S. EPA Office of Research and Development, Risk
Reduction Engineering Laboratory, Cincinnati, OH.
Segall, R.R., W.G. DeWecs, and P.M. Lewis. 1991b. Emission of Metals, Chromium, and
Nickel Species, and Organics from Municipal Wastewater Sludge Incinerators, Volume
III: Site 6 Emission Test Report. Entropy Environmentalists, Inc. and DEECO, Inc.
EPA Contract No. 68-CO-0027. U.S. EPA Office of Research and Development, Risk
Reduction Engineering Laboratory, Cincinnati, OH.
Scgall, R.R., W.G. DeWees, and P.M. Lewis. 1991b. Emission of Metals, Chromium, and
Nickel Species, and Organics from Municipal Wastewater Sludge Incinerators, Volume
VIII: Site 9 Emission Test Report. Entropy Environmentalists, Inc. and DEECO, Inc.
1991c. EPA Contract No. 68-CO-0027. U.S. EPA Office of Research and Development,
Risk Reduction Engineering Laboratory, Cincinnati, OH.
SES. 1991. Budget Proposal to Carlson Associates. Sonic Environmental Systems, Parsippany,
NJ.
Shamat. N., E. Grumpier, and A. Roddan. 1990. Total Hydrocarbon (THC) Analyzer
Evaluation Study. Proceedings of the 63rd Annual Conference and Exposition of the
Water Pollution Control Federation, October 8. Water Pollution Control Federation,
Washington, DC.
State of Maryland. 1991. COMAR26.11.08.08D. Training Course for Operators of Municipal
Waste Combustors, Sewage Sludge Incinerators, and Hazardous Waste Incinerators.
C-34
-------
Weast, R.C., and MJ. Astle. 1981. CRC Handbook of Chemistry and Physics. CRC Press, Inc.,
Boca Raton, FL.
White, M. and G. Beluzo. 1980. Performance of Emissions Tests and Material Balance for a
' Fluidized-Bed Sludge Incinerator. GCA Corporation. Contract No. 68-01-4143. U.S.
Environmental Protection Agency, Division of Stationary Source Enforcement,
Washington, DC.
C-35
-------
-------
APPENDIX D
DOMESTIC SEPTAGE HAULER FINANCIAL PROFILE
-------
-------
APPENDIX D
DOMESTIC SEPTAGE HAULER FINANCIAL PROFILE
This appendix presents the financial profile of domestic septage haulers, as well as several
analyses that are summarized in Section Four of the RIA.
D.1 FINANCIAL PROFILE
As discussed in Section Four, EPA used information gathered and presented in ERG
(1990) to develop profiles of small, medium, and large domestic septage firms. This profile
provided information on amount of septage handled annually, revenues on a per-septic-tank
basis, etc. Additional information, however, was needed before a full financial profile of these
firms could be developed. EPA assumed that much of the operation of domestic septage
disposal would be similar to that for sewage sludge. Therefore, EPA used the EPA handbook on
sewage sludge disposal costs (EPA, 1985) to develop annualized capital and operating costs.
This handbook presents, in an appendix, algorithms for determining costs of disposal. The
assumptions in this handbook were modified somewhat to reflect some of the differences in
operation. For example, we have assumed that small and medium size domestic septage haulers
buy used trucks. The market for used trucks is larger than the size of this industry would
suggest, since the trucks used for domestic septage are the same as those used for spreading
sludge, manure, and liquid fertilizers. Thus used trucks are readily available.
There are three components to the financial analysis: the derivation of input values, the
calculation of various quantities (e.g., number of tankloads handled annually), and the cost
computations. These three components are discussed below.
Table D-l presents the input data used to develop total costs of operation. The
quantities of various parameters necessary to operate a domestic septage hauling firm are
developed in Table D-2, using the input values from Table D-l. Daily septage volume is
calculated on the basis of gallons per year handled by each model firm divided by the number of
days the firm operates. The number of tanks loaded per day is the daily septage volume divided
D-l
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D-3
-------
by the volume of the tank truck. The total load time per day is the truck loading time, a default
value from the EPA handbook (EPA, 1985) times the number of tanks serviced per day. The
daily haul time is the number of trucks operated times the daily truck mileage divided by truck
speed. The driver labor requirement is the total load time, plus the daily haul time, plus the
product of the number of trucks, the trips per day per truck, and the truck unloading time
(another default) all multiplied by the days per year (see equation in Table D-2). The annual
fuel requirement is calculated as the product of the number of trucks, daily truck mileage, and
days operated per year, divided by truck fuel consumption. The output of this series of
equations provides the estimate of the number of driver hours per day per truck (this variable
ranges from 1.86 to 5.61 for the smallest to the largest firm), and the annual fuel requirement
(ranging from 394 to 15,600 gallons per year).
Table D-3 presents the cost calculations. The first column presents the cost of labor,
including the overhead multiplier. This cost is calculated as the product of the number of trucks,
the days operated per year, the labor hours per day per truck (for small size firms this is
calculated as the driver hours per day plus 1/2 hour per day to attend to administrative functions;
the time for the medium and large firms to attend to administrative functions is taken into
account by allowing the number of hours per day per employee equal a full day (8 hours), even
though actual driving and disposal-related time is estimated at 5. 60 and 5.61 hours per day per
truck, respectively), the cost of labor, and the wage inflator.
The next cost calculated is the annual vehicle maintenance cost, which equals the product
of the number of trucks, the daily truck mileage, the days per year, and the maintenance cost per
mile. We used the default value from EPA (1985) for the maintenance cost per mile, which had
to be inflated to 1992 dollars (MSECI/751 represents this inflator, which is the Marshall and
Swift Equipment Cost Index). The annual cost of diesel fuel was calculated as the annual fuel
requirement times the cost of diesel fuel. The labor cost, vehicle maintenance cost, and the
annual cost of diesel fuel were summed to develop the annual O&M costs. For large firms, it is
assumed that 37.5 percent of the company's business is commercial (based on ERG, 1990),
therefore the annual O&M costs were multiplied by a factor of 0.625 to remove this portion
from the analysis. The cost of trucks reflects the values taken from The Pumper [1990], the
industry trade magazine that presents advertisements for new and used trucks of the sizes
D-4
-------
w
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aintenan
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D-5
-------
determined to be commonly used by domestic septage haulers. The cost of trucks was multiplied
by the number of trucks to derive the total cost of trucks as with O&M costs, for large firms the
total costs of trucks was multiplied by 0.625 to remove the commercial portion of the business
from the analysis. This figure was then annualized at 12 percent over 5 years to estimate the
annual cost of capital. Total annual costs were then estimated by adding total O&M to total
annual cost of capital.
The next portion of the table calculates the total cost per tank, the profit per year, the
profit plus owner's wage, assuming the owner pays himself a driver's wage of $11 per hour, and
profit, owner's wage, and overhead, both total and per hour. This figure for profit, owner's wage,
and overhead is used to calculate the total cost to the owner of his own time spent reading and
interpreting the regulation. Profit plus owner's wage is used to develop the net present value
analysis in Section Five.
D.2 OVERHEAD SENSITIVITY
Many factors involving the cost of operations at domestic septage haulers could not be
ascertained, including costs of benefits, infrastructure costs, etc., since data at this industry level
is not readily available. EPA thus took an approach using a factor to approximate these costs.
Since many of these costs are related to the number of employees (the more employees, the
greater the benefits costs, the more square feet needed in a building, and the more utilities
required), EPA assumed that overhead costs could be apportioned as a percentage of labor costs.
Because this overhead figure is not known, EPA ran a sensitivity analysis using three
overhead factors. In general, this industry should be characterized by fairly low overheads.
Many domestic septage haulers operate out of their own houses or farms, and most probably do
not provide many benefits to employees. Table D-4 presents the cost calculations as presented in
Table D-3. This table presents three groups of data. The three groups of data represent data
for three scenarios in which the overhead multiplier is 1.5 times labor costs, 1.75 times labor
costs (the selected scenario in Table D-3), and 2.0 times labor costs (i.e., benefits, cost of a
building or portion of a building, and other employee-related expenses total 50 percent, 75
percent, and 100 percent of labor costs). As the table shows, profits are substantial at an
D-6
-------
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ENSITIVITY A
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D-7
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overhead rate of 1 .5 (in the largest firms, the owner's total profit — wage plus profit — is estimated
at nearly $78,000. At the highest overhead rate of 2.0, profits shrink considerably, but: in the
small and medium firms, profits provide not much more than the $11 per hour that truck drivers
might be paid. EPA selected 1.75 based on the observation that at an overhead rate of 2.0, the
business might nol: offer a high enough return on investment. At 1.5, returns seem unrealistically
high.
D.3 TRANSPORTATION ANALYSIS
In Section Four, EPA estimated that small surface-disposing domestic septage haulers
might shift to land application, rather than remaining as surface disposers because of the cost of
installing ground-water monitoring wells. EPA assumed that in shifting to land application,
domestic septage haulers incur an additional transportation cost because of the need to purchase
additional land, which may take them further from their current base of operations. Tables D-5
through D-7 present the results of an analysis to determine the incremental cost of three
scenarios: that daily truck mileage increases by 10 percent, by 20 percent, or by 30 percent. The
first group of lines in these tables is the baseline with no mileage increase. As discussed in
Section D.3, all the. analyses use a wage inflator of 1.75. As Table D-6 shows, the cost per septic
tank pumped for small domestic septage haulers is $64 per tank in the baseline, $67 per tank in
the 10 percent additional mileage assumption, $70 in the 20 percent additional mileage
assumption, and $73 in the 30 percent additional mileage assumption. EPA chose the midpoint
assumption of 20 percent, or a $6 per septic tank increase in costs. This assumption was made
because only an additional 2.5 acres of land is estimated to be needed in order for a small
surface-disposing domestic septage hauler to meet annual application rate requirements in
Subpart B. Therefore, EPA believes that the mileage increase is not likely to be very large.
-------
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REFERENCES TO APPENDIX D
EPA. 1985. Handbook: Estimating Sludge Management Costs. EPA 1625/6-85-010.
Cole Publishing, 1990. The Pumper, June, 1990.
D-12
-------
APPENDIX E
PRETREATMENT SECTION FROM THE RIA FOR
THE PROPOSED PART 503 REGULATION
-------
-------
THE EFFECT O'F PRSTRSATMENT ON SLODGS QUALITY
The implementation of pretreatment can have a dramatic effect on pollutant
levels in POTW sludges. For some POTWs, one or two dischargers may be the
primary source of troublesome pollutants. Strict pretreatment controls on
these few sources can improve the overall sludge quality for the POTW. Other
POTWs may have numerous dischargers of varying sizes that are responsible for
high contaminant levels in the sludge. In this case, widespread
implementation cf pretreatment may be necessary to improve sludge quality.
The National Pretreatment Program requires certain POTWs to control the
level of contaminants in their influent through the implementation of four
types of federally enforceable pretreatment standards:
• National categorical pretreatment standards. These technology-based
standards require pretreatment controls according to the industry
category of the discharger.
• Prohibited'discharge standards (general). These standards apply to all
dischargers, and prohibit the discharge of pollutants that are a fire
or explosion hazard, corrosive, solid or viscous/ or in large enough
volumes or at high enough temperatures so as to cause interference with
POTW operations.
• Prohibited discharge standards (specific). These standards prohibit
the discharge of any pollutants into the sewage system if they pass
through the POTW untreated or interfere with POTW operations.
• Local discharge limits. These limits are developed and enforced by
local (POTW) pretreatment programs to implement the general and
specific prohibited discharge standards and, if necessary, prevent
localized pass-through and interference problems not controlled by the
categorical pretreatment standards.
Thus, POTWs can control pollutants in industrial influents through (a)
industry-specific standards (categorical standards); or (b) site-specific
standards that apply to all or selected industrial dischargers in their
service territory (prohibited discharge standards and local limits programs).
E-l
-------
EPA conducted several case studies to determine the effect of specific
control technologies on a POTW's ability to comply with the numerical
pollutant limits of the proposed sludge disposal regulations. The control
technologies used in these case studies, which vary by industry, are discussed
below in Section 5.1. The current categorical standards for an industry are
based on the best available technology (the technology, that achieves the
highest removal) that is economically achievable. Additional pollutant
removals may be possible through more stringent control technologies, but may
be more costly to the industrial discharger.
The case studies analyzed the effects of requiring the best available
technologies of all categorical dischargers. The current status of the POTW's
pretreatment program was used as the baseline in each case study. Thus, if
certain categorical dischargers were not in compliance with the current
standards, it was assumed that they would realize the full pollutant
reductions attainable by installing the best available technology. Those
industrial dischargers already.in compliance would realize the incremental
pollutant reductions attainable by upgrading to the best available technology.
The National Pretreatment Program (through the use of pretreatment
standards) will require POTWs to control their industrial discharges to meet
the new pollutant limits set for their sludges - unless the POTW can achieve
compliance through other means or switch to a less restrictive disposal
option. Therefore, additional pretreatment controls will be a way to achieve
compliance with the new sludge disposal regulations.
In this RIA, the pretreatment case studies are used to determine whether
compliance with the proposed regulations could be achieved through tighter
pretreatment controls on categorical dischargers raher than through changing
sludge disposal practices. The case study analysis has certain limitations
(see Section 5.4) that restrict the applicability of its conclusions. The
results have not, therefore, been incorporated into the compliance strategies
or the costs of the regulatory options discussed in this RIA. However,
pretreatment is an important mechanism available to POTWs to alleviate their
E-2
-------
sludge disposal problems. Further study In this area is warranted and may be
included in subsequent regulatory analyses.
5.1 Case Studies
Eight POTWs and their industrial contributors subject to categorical
standards were studied to determine the potential reduction in total loadings
of various pollutants through stricter pretreatment. For purposes of this
study, stricter pretreatment refers to the requirement for pollutant
reductions from industrial dischargers beyond those required by the
categorical pretreatment standards. The potential improvement was based on a
scenario that assumed categorical industrial contributors in the service area
of each case study POTW installed and operated the most stringent pretreatment
technology (the best available technology).
The treatment plants chosen for this study represent a cross-section of
sludge disposal options, POTW size, and industrial contribution in their
influent. Table 5-1 summarizes the relevant characteristics of each case
study POTW. Data regarding sludge quality and industrial influent from ,
individual dischargers were collected. Current pretreatment practices were
also investigated.
The pretreatment technologies currently specified in the existing
categorical standards are referred to as "pretreatment standards for existing
sources" (PSES). The most stringent technology for each categorical industry
is referred to as SPS. SPS technology options for the following categorical
industries were analyzed: inorganic and organic chemicals; leather tanning;
electrical and electronic components; metal finishing and electroplating;
plastics molding and forming; textiles; printing and publishing; pulp and
paper; metal molding and casting; nonferrous metals manufacturing; iron and
steel; auto and other laundries; battery manufacturing; and paint
formulating. These industries were chosen because they occurred frequently
among the case study POTWs and because they use toxic metals and organic
compounds of concern to this analysis.
E-3
-------
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E-4
-------
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E-5
-------
The basis for selecting the SPS technologies, the costs of each
technology, and the incremental pollutant removals were derived from EPA
development documents and .administrative records for the categorical
pretreatsnent standards. Representative model plants from these sources were
chosen to provide the basil for the costs and expected improvements as a
result of SPS technologies for each industry category. A description of each
industry model (and the PSES and SPS options assumed) is provided in
Appendix A.
For each case study POTW, the total loadings from known industrial
contributors for several metals and the chemical' BEHP were calculated. The
listings of industrial contributors were generally obtained from the
Industrial Waste Surveys conducted by each POTW. The annual loadings of
pollutants to the POTW from each contributor were calculated using influent
sampling results and the total yearly flow from each discharger. Where
influent sampling data were not available, pollutant levels in raw discharges
of the industry's model plants (from EPA development documents) were used.
The reduction in individual pollutants that can be achieved from
industry-specific SPS technology was applied to the total loadings of each
industrial discharger to determine the mass of pollutants that could
potentially be removed. Table 5-2 lists the estimated percent reduction in
pollutants for the industrial model plants switching from PSES to SPS, or no
pretreatmeni: to SPS. The percent reduction in pollutants assumed for each
industrial contributor in the case studies depended on whether or not'that
contributor was already in compliance with the categorical pretreatment
standards. This information was known for some of the case study POTWs; where
unknown, it was conservatively assumed that industrial contributors were
already in compliance with PSES. For those contributors already in compliance
with PSES, the reduction in pollutant loadings was based on switching from
PSES to SPS. The improvement for plants with no pretreatment systems was
based on the total percent reduction attainable from installing SPS systems.
Most industrial users subject to the categorical pretreatment standards
should already have installed PSES to be in compliance with the regulations.
E-6
-------
TABLE 5-2
ESTIMATED PERCENT REMOVAL OF SPS OPTIONS
INDUSTRY AND
PRETREATMENT SCENARIO
.Inorganic Chemicals
No Pretreatment to SPS
PSES to SPS
Leather Tanning
No Pretreatment to SPS
PSES to SPS
Metal Finishino and
Electroplating
No Pretreatment to SPS
PSES to SPS
Metal Molding and Casting,
Aluminum Subcategory
No Pretreatment to SPS
PSES to SPS
Metal Molding and Casting,
Copper Subcategorv
No Pretreatment to SPS
PSES to SPS
_Metal -Molding and Casting,
Ferrous Subcategory
No Pretreatment to SPS
PSES to SPS
Non-ferrous Metals
Manufacturing
No Pretreatment to SPS
PSES to SPS
' INCREMENTAL PERCENT OF POLLUTANT REMOVEpa
CADMIUM CHROMIUM COPPER LEAD MERCURY NICKEL ZINC
NA 99 97 99 NA 98 86
NA 96 30 86 NA 42 68
NA 100 0 88 NA 00
NA 98 0 88 NA 0 0
97 100 100 96 NA lo'fl 100
97 99 97 96 NA 98 97
NA NA 95 97 NA 95 100
NA NA 0 33 NA 0 32
98 NA 100 99 ....NA 98 100
0 NA 0 0 NA 0 0
96 96 98 100 NA 96 100
0 0 0 0 NA 00
96 100 100 99 NA 100 100
0 0 NA 0 NA 0 0
BEHP
NA
NA
NA
NA
NA
NA
100
0
98
0
96
0
NA
NA
E-7
-------
TABLE 5-2 (cont.)
INDUSTRY AND
PRETREATMSNT SCENARIO
Auto and Other Laundries f
Car Wash Subcatecorv
No Pretreatment to SPS
PSES to SPS
Auto and Other Laundries,
Industrial Laundrv
SubcategorvD
No Pretreatment to SPS
PSES to SPS
Battery Manufacturing
No Pretreatment to SPS
PSES to SPS
Electrical and Electronic
Components
No Pretreatment to SPS
PSES to SPS
Plastics Molding 'and Forming
No Pretreatment to SPS
PSES to SPS
Textiles0
No Pretreatment to SPS
PSES to SPS
Metal Molding and Casting,
Zinc Subcategory
No Pretreatment to SPS
PSES to SPS
INCREMENTAL PERCENT OF POLLUTANT REMOVED*
CADMIUM CHROMIUM COPPER LEAD MERCURY NICKEL ZINC
0 29 28 96 NA 0 85
0 29 28 96 NA 0 85
17 87 77 98 NA 0 93
17 87 77 98 NA 0 93
68 96 91 100 100 88 98
0 17 57 NA NA 71 33
V
96 89 24 99 NA NA 99
30 17 24 40 NA NA 0
NA NA NA NA NA NA 62
NA NA NA NA NA NA 62
NA 40 40 NA NA NA 39
NA 40 40 NA NA NA 39
95 95 99 96 NA 95 100
0 0 0 0 NA 0 0
E-8
-------
TABLE 5-2 (cont.)
INCREMENTAL PERCENT OP POLLUTANT REMOVEDa
INDUSTRY AND
PRETREATMENT SCENARIO
CADMIUM CHROMIUM COPPER LEAD MERCURY NICKEL ZINC BEH?
Printing and Publishing
No Pretreatment to SPS
PSES to SPS
Iron and Steel
No Pretreatment to SPS
PSES to SPS
Paint Formulating'3
No Pretreatment to SPS
PSES to SPS
Organic Chemicals
No Pretreatment to SPS
PSES to SPS
Pulp and Paper
No Pretreatment to SPS
PSES to SPS
NA
NA
NA
NA
100
100
NA
NA
NA
NA
100
92
NA
NA
100
100
44
0
0
0
87
23
NA
NA
100
100
96
0
0
0
100
96
NA
NA
100
100
99
0
NA
NA
NA
NA
NA
NA
100
100
NA
NA
NA
NA
0
0
NA
NA
100
100
-
7
0
0
0
96
96
0
0
100
100
87
0
0
0
NA
MA
NA
NA
100
100
98
0
0
0
aTwo figures expressing percent removal are provided. The first refers to the
incremental pollutant removal achieved when SPS is installed where there was previously no
Pretreatment. The second figure refers to the additional removal achieved by SPS over
that achieved by PSES.
^There are currently no PSES requirements for these industries.
NA =• Not applicable. Pollutants are not commonly associated with discharges from these
industries.
Source: Industrial Technology Division, EPA, Washington, DC.
1438S
E-9
-------
By the time the data were collected for these case studies; however, some had
not done so. Since the data received from individual case study FOTWs
reflected the current status of all industrial contributors, the current
status- was used as the baseline. Therefore, the case study results reflect
the improvement potential through stricter pretreatment and, in some cases,
through bringing all categorical industries into compliance.
The total annual mass of pollutants estimated to be removed from each
discharger as a result of stricter pretreatment was aggregated for each POTW.
This figure was compared to the POTW-wide total annual loadings of each
pollutant., Thus, an overall percent reduction in each pollutant was
calculated for each POTW.
The results of the case study analyses are presented in.Table 5-3. These
results are estimates of the percent reduction in total yearly pollutant
loadings to the POTW if categorical industrial dischargers install SPS
technologies. The estimated reductions for each pollutant vary widely across
POTHs. Six out of the eight case study POTWs attained additional reductions
of over 90 percent in at least one pollutant. On an average basis for all
plants, chromium and nickel levels show the greatest improvements.
Pollutant reductions as a result of stricter pretreatment will vary for
each POTW, based on che types and the sizes of industrial contributors in the
POTW system. The extent to which the categorical standards have already been
implemented will also be a strong factor. Although the most significant
improvements are attained with PSES, substantial additional reductions can be
achieved with SPS. When upgrading from PSES to SPS, over 90 percent
reductions can be achieved in at least one" pollutant for 9 of the 17
industries examined.
5.2 The Cost to Industry of Implementing Stricter Pretreatment Programs
The incremental capital and annual operating and maintenance costs for the
pretreatment options studied are presented in Table 5-4. Costs for upgrading
E-10
-------
TABLE 5-3
POTW
River Road
Newburyport
Muscatine
Goshen
Passaic Valley
Westerly
Trinity
Green Bay
Average
CADMIUM
1.0
1.75
0.9
97
10.1
49.9
17.4
0.5
22.3
CHROMIUM
4.4
0.92
98
99
100
95.4
97.5
11.4
63.3
COPPER
1.4
1.39
1.1
4.0
55
87.2
9.4
2.4
20.2
LEAD MERCURY
0.2
1.74
20.9
41.1
15,7
96
9.2
6.1 0
23.9 ID
NICKEL
98.5
6.9
13.1
11.1
100
94.3
65.9
6.9
49.6
ZINC
0.5
0.85
0,5
47.7
10.2
98.3
17.3
41.0
27.0
BEHP
-
-
-
-
-
-
-
-
••
ID » Insufficient -data.
Source: ERG analyses.
Note: Percent reductions apply to the current influent pollutant loadings.
1439S
E-ll
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TABLE 5-4
INCREMENTAL CAPITAL AND O&M COSTS FOR
SPS PRETREATMENT TECHNOLOGIES
($ 1987)
m
INDUSTRY
Inorganic Chemicals
Metal Finishing/Electroplating
Leather Tanning
Metal Molding & Casting, Aluminum
Metal Molding & Casting, Copper
Metal Molding & Casting, Ferrous
Metal Molding & Casting, Zinc
Printing & Publishing
Pulp & Paper
Iron & Steel
Paint Formulating3
Organic Chemicals
Auto & Other Laundries, Car Wash
INCREMENTAL COST
PER DISCHARGER ($000)
PSES - SPS
ANNUAL
CAPITAL OSM
153 84
111 .. 67
1,765 395
4 5
0 0
0 0
0 0
2 2
0 0
799 790
143 69
NA NA
242 115
Subcategory
Auto and Other Laundries, Industrial*
Laundries Subcategory
242
115
E-12
-------
TABLE 5-4 (cont.)
acurrently no PSES requirements.
NA = Not Available.
Source: EPA, ITD, March 1987.
INCREMENTAL COST
PER DISCHARGER ($000)
INDUSTRY
Battery Manufacturing
Electrical & Electronic Components
Plastics Molding & Forming
Textiles*
Non-Perrous Metals
PSES
CAPITAL
22
17
97
2,672
0
- SPS
ANNUAL
O&M
9
7
43
881
0
2098S
E-13
-------
from PSES to SPS are also presented. On an individual industrial plant basis,
upgrade costs from PSES to SPS are highest for the textile industry: $2.5 and
$0.84 million, for capital and O&M costs, respectively. (Note that in this
case upgrading is the same as going from no pretreatment to SPS since there
are currently no specific PSES limits for textiles.)
Only the incremental costs associated with upgrading from PSES to SPS were
included in these totals. Although certain dischargers were not in compliance
with PSES, they would have eventually made the expenditures required to
comply. For those dischargers, the costs of PSES were subtracted from total
costs of SPS.
The costs of pretreatment technologies were based on process flows and
other relevant characteristics of the model plants for each industry category
as described in Appendix A. These models were chosen to represent the most
common plants in each industry category. The incremental costs estimated for
the model plants were adjusted for each industrial discharger using a common
engineering scaling factor based on the flow volume.
Table 5-5 presents the total cost of stricter pretreatment on a per POTW
basis. These costs represent the total capital and O&M costs to all affected
industrial dischargers in the POTW's service area. These costs will not be
incurred by the POTW, but rather by the dischargers ordered by the POTW to
upgrade pretreatment systems.
The larger plants with many categorical industrial contributors have the
highest costs, as shown in Table 5-5. Passaic Valley receives influent from
33 textile mills, which account for a significant portion of the costs due to
the high capital and operating costs of SPS for this industry.
5.3 The Effect of Pretreatment on the Ability of the Case 5tudy_porws to
Comply With the Proposed Regulations '
The improvement in sludge quality resulting from implementing pretreatment
may be an important factor in a POTW's ability to comply with the proposed
E-14
-------
TABLE 5-5
TOTAL INCREMENTAL COSTS OF STRICTER PRETREATMENT
FOR THE CATEGORICAL INDUSTRIES OF EACH POTW
($ 1987)
Goshen
River Road
Muscatine
Westerly
Trinity River
Passaic Valley
Newburyport
Green Bay
CAPITAL
900
505
2,175
3,423
4,554
35,352
188
1,364
TOTAL INCREMENTAL
ANNUALIZED
CAPITAL3
118
66
286
450 1,
612 2,
4,648 13,
25
179
COSTS
O&H
504
281
569
896
492
079
114
765
($000)
TOTAL
ANNUAL
622
347
855
2,346
3,104
17,727
139
944
aAnnualized assuming 10 percent interest rate and 15-year
equipment life.
1449S
E-15
-------
sludge disposal regulations. This aspect of pretreatment was analyzed for the
case study POTWs. The percent reductions in pollutant loadings to the POTW
estimated in Section 5.1 were used as a proxy for the percent reduction
possible in sludge contaminant levels.
Table 5-6 shows the results of this analysis for each case study POTW.
The projected sludge quality, after SPS had been implemented, was determined
based on the existing sludge quality and the estimated improvement for
individual contaminants for each POTW (see Table 5-3). Table 5-6 also shows
the maximum sludge concentrations allowed for compliance with the proposed
regulations.
The maximum concentrations shown for each POTW reflect Option 3 criteria
relevant to the particular disposal method used. The two case study plants
using incineration are also numbers 7 and 8 of the 10 model incinerators used
in Section 4.1. Therefore, the maximum pollutant concentrations calculated
for those specific models were used in this analysis. ?or those case study
POTWs using land application, maximum pollutant concentrations corresponding
to Option 3 nonagricultural land application criteria were used. This set of
criteria were chosen since agricultural land application rules specify
application rates, not maximum pollutant concentrations, in sewage sludge.
The results associated with Option 3 are shown in Table 5-6. Although
significant improvements in sludge quality are obtained, only the Goshen plant
can effect compliance for all pollutants analyzed if additional pretreatment
by categorical industries to the level shown is achieved. For plants using
incineration and monofills, the criteria are stringent enough that even a
substantial improvement in certain contaminants is insufficient to attain
compliance.
Not all the regulated pollutants (pollutants covered by the proposed
sludge disposal regulations) were covered by the pretreatment case study
analysis and not all case study POTWs had sludge quality data for all
pollutants that were studied. Therefore, Table 5-6 does not include data for
all the regulated pollutants. The pass/fail decision was based only on those
contaminants shown.
E-16
-------
TABLE 5-6
PASS/FAIL ANALYSIS FOR CASE STUDY POTUS
POLLUTANT
CADMIUM
CHROMIUM
COPPER
LEAD
NICKEL
ZINC
EXISTING
SLUDGE
CHG/KG)
TRIMITY
31
228
550
141
61
570
PROJECTED
QUALITY
AFTER
(HG/KG)
RIVER--ONSITE
25.73
2.052
515.9
133.527
21.045
553.47
MAXIMUM
SLUDGE PASS/FAIL
(HG/KG) EXISTING
SLUDGE LANDFILL
, 9.44 FAIL
MA
NA
500 PASS
NA
NA
RESULTS
PROJECTED
FAIL
PASS
CLEVELAND WESTERLY—INCINERATION
CADMIUM
CHROMIUM
COPPER
LEAD
NICKEL
ZINC
108
802
NA
NA
389
NA
78.192
166.816
NA
NA
21.784
NA
0.55 FAIL
9.51 FAIL
NA
52.15
3.6 FAIL
NA
FAIL
FAIL
FAIL
PASSAIC VALLEY—OCEAN DISPOSAL
CADMIUM*
CHROMIUM
COPPER
LEAD
NICKEL
ZINC
2.7
110
110
170
12
150
2.5677
0.88
83
166.94
7.584
139.5
34072.25 PASS
NA
NA
NA
NA
NA
PASS
CITY OF GOSHEN--LAND APPLICATION
CADMIUM
CHROMIUM
COPPER
LEAD
NICKEL
ZINC
529.5
3242
1409
178.9
955
13704
15.885
32.42
1352.64
105.551
848.995
7167.192
384
3063
3300.3
1622.8
988
8622.4
FAIL
FAIL
PASS
PASS »
PASS
FAIL
PASS
PASS
PASS
PASS
PASS
PASS
E-17
-------
TABLE 5-6 (CONT'D)
POLLUTANT
EXISTING
SLUOGE
QUALITY
(HO/KG)
PROJECTED
QUALITY
AFTER
PRETREAT.
(MG/KG)
MAXIMUM
SLUOGE
PftUf*
(MG/ICG)
PASS/FAIL RESULTS
EXISTING
PROJECTED
RIVER ROAD-LAND APPLICATION
CADMIUM
CHROMIUM
COPPER
LI-AD
NUCKEL '
ZDIC
= ::S=====S = I
0.006
NA
0.024
0.056
NA
0.504
==========
0.00594
NA
0.023688
0.055888
NA
0.50148
============
384
3063
3300.3
1622.8
988
8622.4
333333333333
PASS
• PASS
PASS
PASS
PASS
33533X333
PASS
PASS
PASS
PASS
PASS
[33333333333
GREEN BAY— INCINERATION
cfDHiw
CHROMIUM
CCPPER
LEAD
NICKEL
ZIHC
18.065
572.6666
688.5
284.8333
264.5
1451.833
17.97467
507.3826
671.976
267.4585
246.2495
856.5816
2.47
42.77
NA
234.6
16.2
NA
FAIL
FAIL
FAIL
FAIL
FAIL
FAIL
FAIL
FAIL
Source: ERG estimates.
*Hsxiraj« sludge concentration was calculated for standard
discharge rate of 15,500 gallons per minute. If the actual
sludge concentration had exceeded this value, the sludge would
not have failed, but the discharge rate would have had to have
beisn reduced.
E-18
-------
5.4 Limitations to the Analysis
A major limitation to the methodology is that only potential improvements
in sludge quality among the categorical dischargers were analyzed. In
addition, categorical industries include only a portion of the industrial
dischargers that fall under the mandates of the pretreatment standards.
Although S?S provides additional pollutant reductions over PSSS, requiring
pretreatment for noncategorical industrial dischargers could realize greater
reductions in pollutants. This scenario would be more cost-effective since,
in general, reducing the pollutant discharge levels (the initial 90 percent)
using a PSES technology (such as lime and settle at a noncategorical industry)
is more efficient than adding an SPS technology (such as a polishing filter),
to increase pollutant removals from 90 to 99 percent at a categorical
industry. However, the data and the resources needed to perform an analysis
of the noncategorical dischargers were not available for these case studies.
Another limitation is the use of one model plant to represent the cost for
dischargers in each industry category. Although a scaling factor was used to
adjust these costs to the individual dischargers, actual costs may vary
significantly. -This methodology does, however, provide a rough approximation
of the associated incremental costs potentially faced by industry. Since the
main goal of the analysis was to evaluate the potential role of pretreatment
in complying with the proposed sludge disposal regulations, this method is
justifiable.
1445S
E-19
-------
PRKTRBATMBNT CASE STUDY ANALYSIS;
IKDOSTRY MODEL PLAMT CHARACTERISTICS
E-20
-------
PRBTRBATMENT CASE STUDY ANALYSIS:
INDUSTRY MODEL PLANT CHARACTERISTICS
Inorganic Chemicals - The model plant chosen for this industry is a median
production plant in .the chlorine-diaphragm cell subcategory. This
subcategory has the largest number of dischargers in the inorganic
chemicals category. The SPS option is assumed to be a well-designed and
operated lime, settle, and filter treatment system followed by
dechlorination, and elimination of lead cell construction. PSES for this
category is equalization, alkaline precipitation, and settling processes.
Leather Tanning - The model plant for this category is a median production
plant in the hair pulp/chrome tan/retan-wet finish subcategory, which is
the subcategory with the highest number of dischargers. PSES for this
category is catalytic oxidation of sulfides, flue gas carbonation,
activated sludge with extended aeration, and powdered activated carbon
addition. The S?S option is based on PSES plus well-designed and operated
lime, settle, and filter treatment.
Metal Finishing and Electroplating - The model plant for this category was
chosen to represent plants that have a diverse waste stream and a median
discharge flow rate. PSES for the category is chemical emulsion breaking,
cyanide oxidation, chromium reduction, lime and settle, and sludge
dewatering. The option considered as SPS is PSES plus 90 percent flow
reduction through countercurrent rinsing, and a well-designed and operated
lime and settle, cyanide precipitation and filtration system.
Printing and Publishing - A film,processing, non-metallic plate processing
plant using press room water-based ink was chosen as the model facility.
A well-designed and operated lime, settle, filtration, vacuum filtration
system was assumed to be the SPS technology. Pretreatment standards have
not been promulgated, but PSES was assumed to be lime, settle, and
filtration, which is the most common technology.
Pulp and Paper - A median production plant in the groundwood-fine papers
subcategory was used as a model. The PSES technology of chemical
substitution was assumed to achieve the highest reduction in metals for
this category. No other, more stringent technology was identified for an
SPS option.
Metal Molding and Casting - Model plants in each of the aluminum, copper,
2inc, and ferrous subcategories of metal molding and casting were
examined. SPS is equal to PSES in each subcategory except for aluminum. .
In the aluminum subcategory, treatable levels of toxic metals remain after
lime and settle systems. Therefore, SPS for the aluminum subcategory is
based on PSES plus filtration. PSES for copper, zinc, and ferrous
subcategories is recycle, lime and settle, and filtration. PSES for the
aluminum subcategory is recycle, lime and settle.
E-21
-------
Iron and Steel - The model plant for this category is based on a facility
of median production in the by-product coke-making subcategory. PSES is
recycle, oil skimming, ammonia stripping, and pH adjustment. SPS is based
on PSES plus cyanide precipitation with ferrous sulfate, followed by
filtration.
Organic Chemicals - The model plant was an organic chemicals plant that
discharges 104,000,000 liters/yr. Pretreatment standards have not been
promulgated for this category (as of 7/1/87). The PSES technology and
associated improvements for SPS were assumed identical to those used at
the model plant.
Auto and Other Laundries - Two model plants were chosen for this
category: (1) wand-type car wash with a flow of 128,000 liters/year; and
(2) industrial laundry with the same flow as the car wash. There are no
categorical pretreatment standards for this industry. The SPS technology
was assumed to be dissolved air flotation plus filtration for both model
plants.
Battery Manufacturing - The model plant is a lead battery manufacturer
discharging 2,700,000 liters/yr. The PSES technology is flow reduction,
oil skimming, lime precipitation, and settling. The SPS option includes
PSES plus polishing filtration.
Electrical and Electronic Components - The model plant discharges
42,500,000 liters/yr and produces semiconductors, electronic crystals,
color televisions, and t.v. phosphors. PSES for this category is solvent
management, in-process chemical treatment for lead and chromium reduction,
end-of-pipe neutralization, chemical precipitation/clarification, and
sludge dewatering. The SPS option is PSES plus multimedia filtration.
Plastics Molding and Forming - The model plant basis is a plant that
processes 2,480 KKG/year of plastic and discharges 7,270,000 liters/year
from the contact cooling and heating water subcategory and 4,540,000
liters/year from the cleaning water subcategory. The PSES option is to
comply with the General Pretreatment Regulations, which do not regulate
individual metals or organic chemicals. The SPS option includes
equalization, pH adjustment, package activated sludge plant for the
cleaning water subcategory and activated carbon for the contact cooling
and heating water subcategory.
Textiles •• The model plant is a woven fabric finishing (desizing) plant
discharging 2.1 billion liters/yr. The SPS technology is assumed to be
biological treatment. No PSES has been promulgated.
Non-Perrouis Metals Manufacturing - The model plant is in the precious
metals subcategory and discharges 4,800,000 liters/yr of treated water.
The PSES option for this subcategory is lime, settle, and filter with
ammonia steam stripping, cyanide precipitation, flow reduction, and ion
exchange end-of-pipe treatment. No more stringent technology was
identified for an SPS option.
1446S
E-22
-------
DETAILED CALCULATIONS FOR
BACH CASE STUDY POTW
E-23
-------
City of Goshen
Coehen, Indiana
Electroplating and He«:al Finishing
Avg flow In
Company (HGO) Compliance
Artco 0.007 1
Midland 0.08 1
Johnson 0.136 1
Company
Artco
Midland
Johnson
Total Poll Reraoved{kg/year)
Paint and Ink Formulating
Avg flow In
Company (HGD) Compliance
<*g/l>:
Anderson 0.0006 1
IvyTerrac 0.003 1
Company
Anderson
IvyTerrace
Total Poll Re»oved(k8/year>
Avg flow
CHI..UJ T**«._ I /urn^
CO
0.48
5.53
1052.97
CO
0.47
5.36
1021.38
1027.21
CO
0.524
0.43
2.17
CO
0.43
2.17
2.61
3333333JC3
CO
CR
992.00
807.42
902.55
CR
982.08
799.35
893.52
2674.95
CR
3.12
2.59
12.94
CR
2.59
12.94
15.53
CR
Company data supplied in me/ I. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Typical Raw Wastes (Kg/year)
CU PB HG NI AG ZN
22.26 61.94
14.38 22.12
20.68 75.21
0.00
0.00
0.00
Potential Improvement
CU PB HG
21.59 59.46
13.95 21.24
20.06 72.20
55.60 152.90
0.00
0.00
0.00
0.00
Typical Raw Wastes
CU PB HG
2.476 6.3
2.05 5.23
10.27 26.13
Potential
CU PB
2.05 5.23
10.27 26.13
12.32 31.36
CU PB
5.161
4.28
21.41
Improvement
HG
4.28
21.41
25.69
140.33
44.24
56.41
(kg/year
NI
137.52
43.36
55.28
236.16
(Kg/year)
NI
1.35
1.12
5.60
(kg/year
NI
1.12
5.60
6.72
0.00 164.53
0.00 3373.48
0.00 3440.95
reduction)
AG ZN
0.00 159.59
0.00 3272.28
0.00 3337.73
0.00 6769.60
AG ZH
0.015 74.746
0.01 62.01
0.06 310.03
reduction)
AG ZN
0.01 62.01
0.06 310.03
0.07 372.03
HG NI AG ZN
CN
0.00
0.00
0.00
CM
0.00
0.00
0.00
0.00
CM BEHP
0.079 0.418
0.07 0.35
0.33 1.73
CM BEHP
0.07 0.35
0.33 1.73
0.39 2.08
CN BEHP
Pollutant Removed 1029.82 2690.48 67.93 184.26 25.69 242.88 0.07 7141.63, 0.39 2.08
Ave Effluent Loadings
Total Plant Loadings
(Kg/year)
Percent Removed
0.11
0.6
0.38
0.1
3.24 1061.591 2717.496 1702.227 447.9545
97.0 99.0 4.0 41.1
0 0.49
0 2194.977
0.0 11.1
3.34
0.1
0 14961.68 447.9545
0.0 47.7 0.1
0
0.0
E-24
-------
GREEN BAY METRO SEWERAGE DISTRICT
GREEN BAY, UI
Conpany data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
GREEN BAY METRO SEWERAGE DISTRICT
GREEN BAY, WI
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
RAW DATA
Company
Val plat
Val Engrav
Astro Elec
Krueger
Norelkote
N. Engrav
NW Metal
Ultra Plat
Gr By Mill
Ft. Howard
PDQ Car
Univ Laund
G & K
Bay Towel
Medalcraft
TOTAL PLANT:
J. River
Rest
SIC
3471
3471
3471
3471
3471
3471
3471
3471
26
332
7542
721
721
721
nonfer
GALLONS
PER DAY
400
622
350
258500
68900
660
2500
6500
7659
7900
15075
12525
43758
89648
1500
CD
0.05
0.05
0.007
0.002
0.01
0.004
0.01
0.39
0.02
0.001
0.012
0.001
0
0.001
1.93
0.02
0.02
0.02
CR CU PB HG HI
(data for indinvidual contributors on
0.011
0.72
423
0.23
0.05
0.08
0.04
11
0.11
0.049
0.06
0.017
0.35
0.12
0.17
0.08
0.08
0.082
0.008
0.38
2.3
0.02
0.16
1.79
0,03
0.41
7.54
0.07
0.16
0.13
2.36
0.43
86.5
0.055
0.05
0.273
0.018
0.5
0.89
0.17
0.07
0.14
0.08
0.86
1
0.012
0.07
0.01
3.38
0.18
0.26
0.11
0.1
0.1
0.0002
0.0002
0.0002
0.0004
0.0002
0.012
0.0002
0.0004
0.002
0.0002
0.0002
0.003
0.0051
0.0005
0.0002
0.0005
0.0005
0.0005
0.03
1.04
0.06
0.91
0.07
0.12
0.04
0.33
0.8
0.31
0.1
0.009
0.16
0.13
1.8
—
0.1
0.08
0.113
AG ZN
Mg/l supplied)
0.001
0.13
0.05
0.005
0.02
0.07
0.02
0.005
0.04
0.001
0.002
0.29
0.02
0.02
0.02
0.48
3910
0.47
0.006
0.074
0.58
0.037
0~427
0.38
0.26
1.19
0.43
7.41
0.88
12.7
0.055
0.076
0.309
CN
0.02
3.12
0.02
0.03
0.15
0.18
0.32
0.02
0.02
0.02
0.02
0.02
0.15
E-25
-------
GREEN BAY METRO SEWERAGE DISTRICT
GREEN BAY, UI
Company data supplied in mg/t. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and H«tal Finishing
Avg flow In
Company (HGO) Compliance
Val plat 0.0004 1
Val Engrav 0.0006 1
Astro Elec 0.0004 1
Krueger 0.2585 1
Norelkote 0.0689 1
H. Engrav 0.0007 1
NW Metal 0.0025 1
Ultra Plat 0.0065 1
Typical Raw Wastes (Kg/year)
CO
0.03
0.04
0.00
0.71
0.95
0.00
0.03
3.50
CR
0.01
0.60
233.93
82.20
4.76
0.08
0.14
98.85
CU
0.00
0.32
1.27
7.15
15.24
1.73
0.10
3.68
PB
0.01
0.41
0.49
60.76
6.67
0.14
0.28
7.73
HG
0.00
0.00
0.00
0.14
0.02
0.01
0.00
0.00
NI
0.02
0.86
0.03
325.23
6.67
0.12
0.14
2.97
Potential Improvement (kg/year
Company
Val plat
Val Engrav
Astro Elec
Krueger
Horelkote
N. Engrav t, Much
NU Metal
Ultra Plat
CO
0.03
0.04
0.00
0.69
0.92
0.00
0.03
3.40
Total Poll Re*oved(kg/yr> 5.13
CR
0.01
0.59
231.59
81.38
4.72
0.08
0.14
97.87
416.36
CU
0.00
0.31
1.23
6.93
14.78
1.68
0.10
3.57
28.62
PB
0.01
0.40
0.47
58.33
6.40
0.13
0.27
7.42
73.42
HG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
NI
0.02
0.85
0.03
318.73
6.53
0.11
0.14
2.91
329.31
AG
0.00
0.11
0.03
1.79
1.91
0.07
0.07
0.04
ZN
0.27
3243.52
0.26
2.14
7.05
0.56
0.13
3.84
CN
0.01
2.59
0.01
10.72
0.00
0.15
0.00
1.62
reduction)
AG
0.00
0.10
0.03
1.70
1.81
0.06
0.07
0.04
3.81
ZN
0.26
3146.22
0.25
2.08
6.84
0.54
0.12
3.72
3160.04
CM
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Pulp and Paper
Avg flow In
Conpany (HGO) Compliance
Gr By Nil I 0.0077 1
J. River 4 1
Pta 14 1
CO
0.21
110.61
387.12
CR
1.17
442.42
1548.48
CU
80.27
304.17
967.80
Typical Raw
PB
10.65
608.33
1935.61
Wastes
HG
0.02
2.77
9.68
Potential Improvement
Conpany
Gr By Hill
J. River
Pig
CO
0.00
0.00
0.00
CR
0.00
0.00
0.00
CU
0.00
0.00
0.00
PB
0.00
0.00
0.00
HG
0.00
0.00
0.00
(Kg/year)
NI
8.52
553.03
1548.48
(kg/year
NI
0.00
0.00
0.00
AG
0.00
110.61
387.12
ZN
4.05
304.17
1471.06
CN
3.41
reduction)
AG
0.00
0.00
0.00
ZN
0.00
0.00
0.00
CN
0.00
0.00
0.00
Total Poll RemovedCkg/year)
E-26
-------
GREEN BAY METRO SEWERAGE DISTRICT
GREEN BAY, UI
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1383.575
Iron & Steel
Company
Avg flow In
(HGD) Compliance CO
Ft. Howard 0.0079 1 0.01
Company
CO
Ft. Howard 0.00.
Total Poll
Car Wash
Company
POO Car
Company
Removed< kg/year) 0
Avg flow In
(MGO) Compliance CD
0.0151 1 0.25
CO
PDQ Car Wash 0.00
Total Poll
Industrial
Company
Um'v Laund
G & 1C
Bay Towel
Company
University
G & K
Bay Towel
Total Poll
Removed
-------
GREEN BAY METRO SEWERAGE DISTRICT
GREEN BAY, UI
Cori^ainy data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Konferrous Metals Hfg.
Avg floti In
Company (HGDli Compliance
Hedalcraft 0.001!i 1
Cocpany
Hcdalcrnft Hint
Total Poll RemovedCkg/year)
Typical I
CO CR CD PB
4.00 0.35 179.39 0.54
Potential
CO CR CU PB
0.00 0.00 0.00 0.00
0000
Raw Wastes (
HG
0.00
Improvement
HG
0.00
0
Xg/year)
NI
3.73
(kg/year
NI
0.00
0
AC
0.60
reduction)
AG
0.00
0
1x35==:=:=::==
ZN CN
26.34 0.31
ZN CN
0.00 0.00
0 0
:== ====== =======
Total Plant Flow
Avg flow In
Ccopany Compliance CD
CR
Typical Raw Wastes (Kg/year)
CU PB HG NI AG ZN
CN
J. River
P*fl
Rest
Total
14
17
35
110.61 442.42 304.17 608.33 2.77 553.03 110.61 304.17
387.12 1548.48 967.80 1935.61 9.68 1548.48 387.12 1471.06
470.08 1927.31 6416.53 2350.38 11.75 2655.93 470.08 7262.67
967.30 3918.22 7688.50 4894.32 24.20 4757.44 967.80 9037.90
Grand Total
Pollutant Rcnoved
Plant Flow 35
Percent Rctnovtd
CO CR CU PB
5.15 448.35 182.35 297.43
967.8 3918.22 7688.5 4894.32
0.5 11.4 2.4 6.1
HG NI AG ZN CN
0.00 329.31 3.81 3706.77 0.22
24.2 4757.44 967.8 9037.9 0
0.0 6.9 0.4 41.0 0.0
E-28
-------
Muscatine STP
Muscatine, Iowa
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and Metal Finishing
Avg flow In
Company (HGD) Compliance
CO
CR
Typical Raw Wastes (Kg/year)
CU PB HG NI
AG
ZN
CM
-------
Passaie Valley Sewerage Commissioners
Newark, Hew Jersey
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Inorganic Chemicals
Company
«/i.
Fid
Heubach
Gen
Essex
Company
Fid
Heubach
Gen
Essex
Avg flow In
(HGO) Compl iance
0.001 1
0.387
0.109
0.086 1
Typical Raw Wastes (Kg/year)
CD
0.037
0.05
19.80
5.58
4.40
CR
1.9
2.63
1016.61
286.33
225.91
CU
17
23.50
9095.97
2561.91
2021.33
PB
21
29.03
11236.19
3164.72
2496.93
HG
0.003
0.00
1.61
0.45
0.36
NI
22
30.42
11771.25
3315.42
2615.83
Potential Improvement (kg/year
Total Poll ReroovedC kg/year)
«»«««*»i
>«*«».»«:,«,:«:,=,
CO
0.00
0.00
0.00
0.00
0
CR
2.52
1006.44
283.47
216.88
1509.308
CU
7.05
8823.09
2485.06
606.40
11921.59
PB
24.97
11123.83
3133.07
2147.36
16429.23
HG
0.00
0.00
0.00
0.00
0
NI
12.78
11535.83
3249.11
1098.65
15896.35 4
AG
0.018
0.02
9.63
2.71
2.14
ZN
3
4.15
1605.17
452.10
356.70
CN
reduction)
AG
0.01
2.70
0.76
0.60
.06245
ZN
2.82
1380.45
388.81
242.56
2014.634
CN
:==================s===============================:!=============:rs==:=====!======
Electroplating and Metal Finishing
Company
«/l:
Acme
Aircraft
Alcaro
Alfred
AmerBump
AnerElec
Andarn
Ancdiz
Aurf lyte
AutoElec
leamar
Best
CPatti
ChromeArt
CircuitHa
Coroet
Diamond
Double
Our its
Avg flow In
(HGO) Compliance
0.0096 1
0.006 1
0.023
0.003
0.008 1
0.008 1
0.0084 1
0.009 1
0.009 1
0.047
0.001 1
0.008 1
0.01 1
0.0069
0.004 1
0.0005 1
0.0005 1
0.011 1
0.004 1
CO
0.283
3.76
2.35
9.00
1.17
3.13
3.13
3.29
3.52
3.52
18.39
0.39
3.13
3.91
2.70
1.57
0.20
0.20
4.30
1.57
CR
27.46
364.47
227.79
873.21
113.90
303.72
303.72
318.91
341.69
341.69
1784.38
37.97
303.72
379.66
261.96
151.86
18.98
18.98
417.62
151.86
CU
12.63
167.63
104.77
401.62
52.39
139.70
139.70
146.68
157.16
157.16
820.71
17.46
139.70
174.62
120.49
69.85
8.73
8.73
192.08
69.85
Typical Raw
PB
0.331
4.39
2.75
10.53
1.37
3.66
3.66
3.84
4.12
4.12
21.51
0.46
3.66
4.58
3.16
1.83
0.23
0.23
5.03
1.83
Wastes
HG
0.001
0.01
0.01
0.03
0.00
0.01
0.01
0.01
0.01
0.01
0.06
0.00
0.01
0.01
0.01
0.01
0.00
0.00
0.02
0.01
(Kg/year)
NI
15.47
205.33
128.33
491.93
64.17
171.11
171.11
179.66
192.50
192.50
1005.26
21.39
171.11
213.88
147.58
85.55
10.69
10.69
235.27
85.55
AG
0.023
0.31
0.19
0.73
0.10
0.25
0.25
0.27
0.29
0.29
1.49
0.03
0.25
0.32
0.22
0.13
0.02
0.02
0.35
0.13
Zil
12.47
165.51
103. 44
396.54.
51.72
137.93
137.93
144.82
155.17
155.17
810.31
17.24
137.93
172.41
118.96
68.96
8.62
8.62
189.65
68.96
1.
24
15
59
7
20. __
CN
856
.63
.40
.02
.70
.53
20.53
21.55
23.09
23.09
120.60
2.57
20.53
25.66
17.71
10.
1.
1.
28.
10.
26
28
28
23
26
E-30
-------
Passaic Valley Sewerage Commissioners
Newark, Hew Jersey
Company data supplied in rog/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and Metal Finishing (Cont.)
Avg flow In
Company (MGO) Compliance
ECElec
ElCircuit
ElProc
GH Metal
GenMet
Highland
HyGrade
Ideal
Imperial
IndPlat
IndHard
JCMet
Keystone
Kohinoor
Loisel
Manco
Mara
Miller
Mottern
Mover
NJ Gal
NuTron
Ondecker
PNC
PanGraph
Para
PlatCity
Polaris
Precision
PrecProt
QualMet
Ranno
Redi
Remie
Reyoni
Suffern
SunHet
TAFar
Timco
Trb/alb
Trio
Arrow
ArtMet
CALau*
Conrad
0.015
0.004
0.007
0.009
0.0477
0.004
0.0016
0.024
0.026
0.069
0.002
0.007
0.008
0.019
0.01
0.0005
0.0018
0.038
0.003
0.008
0.011
0.013
0.0035
0.017
0.015
0.0095
0.0065
0.012
0.005
0.004
0.002
0.047
0.0069
0.004
0.0029
0.053
0.031
0.009
0.005
0.001
0.0023
0.133
0.029
0.001
0.029
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
CO
5.87
1.57
2.74
3.52
18.66
1.57
0.63
9.39
10.17
27.00
0.78
2.74
3.13
7.43
3.91
0.20
0.70
14.87
1.17
3.13
4.30
5.09
1.37
6.65
5.87
3.72
2.54
4.70
1.96
1.57
0.78
18.39
2.70
1.57
1.13
20.74
12.13
3.52
1.96
0.39
0.90
52.04
11.35
0.39
11.35
CR
569.48
151.86
265.76
341.69
1810.96
151.86
60.74
911.17
987.10
2619.62
75.93
265.76
303.72
721.35
379.66
18.98
68.34
1442.69
113.90
303.72
417.62
493.55
132.88
645.41
569.48
360.67
246.78
455.59
189.83
151.86
75.93
1784.38
261.96
151.86
110.10
2012.17
1176.93
341.69
189.83
37.97
87.32
5049.42
1101.00
37.97
1101.00
Typical Raw Wastes (Kg/year)
CU PB HG NI
261.93
69.85
122.23
157.16
832.93
69.85
27.94
419.09,
454.01
1204.87
34.92
122.23
139.70
331.78
174.62
8.73
31.43
663.55
52.39
139.70
192.08
227.01
61.12
296.85
261 .93
165.89
113.50
209.54
87.31
69.85
34.92
820.71
120.49
69.85
50.64
925.48
541 .32
157.16
87.31
17.46
40.16
2322.44
506.40
17.46
506.40
6.86
1.83
3.20
4.12
21.83
1.83
0.73
10.98
11.90
31.58
0.92
3.20
3.66
8.70
4.58
0.23
0.82
17.39
1.37
3.66
5.03
5.95
1.60
7.78
6.86
4.35
2.97
5.49
2.29
1.83
0.92
21.51
3.16
1.83
1.33
24.25
14.19
4.12
2.29
0.46
1.05
60.87
13.27
0.46
13.27
0.02
0.01
0.01
0.01
0.07
0.01
0.00
0.03
0.04
0.10
0.00
0.01
0.01
0.03
0.01
0.00
0.00
0.05
0.00
0.01
0.02
0.02
0.00
0.02
0.02
0.01
0.01
0.02
0.01
0.01
0.00
0.06
0.01
0.01
0.00
0.07
0.04
0.01
0.01
0.00
0.00
0.18
0.04
0.00
0.04
320.83
85.55
149.72
192.50
1020.23
85.55
34.22
513.32
556.10
1475.80
42.78
149.72
171.11
406.38
213.88
10.69
38.50
812.76
64.17
171.11
235.27
278.05
74.86
363.60
320.83
203.19
139.02
256.66
106.94
85.55
42.78
1005.26
147.58
85.55
62.03
1133.59
663.04
192.50
106.94
21.39
49.19
2844.66
620.26
21.39
620.26
AG
0.48
0.13
0.22
0.29
1.52
0.13
0.05
0.76
0.83
2.19
0.06
0.22
0.25
0.60
0.32
0.02
P. 06
1.21
0.10
0.25
0.35
0.41
0.11
0.54
0.48
0.30
0.21
0.38
0.16
0.13
0.06
1.49
0.22
0.13
0.09
1.69
0.99
0.29
0.16
0.03
0.07
4.23
0.92
0.03
0.92
ZN
258.61
68.96
120.69
155.17
822.38
68.96
27.59
413.78
448.26
1189.61
34.48
120.69
137.93
327.57
172.41
8*. 62
31.03
655.15
51.72
137.93
189.65
224.13
60.34
293.09
258.61
163.79
112.06
206.89
86.20
68.96
34.48
810.31
118.96
68.96
50.00
913.76
534.46
155.17
86.20
17.24
39.65
2293.02
499.98
17.24
499.98
CN
38.49
10.26
17.96
23.09
122.40
10.26
4.11
61.59
66.72
177.06
5.13
17.96
20.53
48.76
25.66
1.28
4.62
97.51
7.70
20.53
28.23
33.36
8.98
43.62
38.49
24.38
16.68
30.79
12.83
10.26
5.13
120.60
17.71
10.26
7.44
136.00
79.55
23.09
12.83
2.57
5.90
341.29
74.42
2.57
74.42
E-31
-------
Passaic Valley Sewerage Connissioners
Newark, New Jersey
Company data supplied in mg/t. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and Metal Finishing (Cont.)
Avg flow In
Cotcpany (HGD) Compliance
Daytona 0.012
Edmar 0.032
Gloube 0.004
Gordoi 0.008 1
ITT 0.176 1
JBHirsh 0.001 1
Hedin 0.0009 1
Presto 0.257
Philips 0.004
TEInd 0.012 1
Wallace*! 0.105
Wcston 0.018 1
Uestuood 0.063 1
Vibra 0.006
Typical Raw Wastes
CO
4.70
12.52
1.57
3.13
68.86
0.39
0.35
100.56
1.57
4.70
41.08
7.04
24.65
2.35
CR
455.59
1214.90
151.86
303.72
6681.93
37.97
34.17
9757.14
151.86
455.59
3986.38
683.38
2391.83
227.79
209.
558.
69.
139.
3073.
17.
15.
4487.
69.
209.
1833.
314.
1100.
104.
CD
54
78
85
70
30
46
72
72
85
54
50
31
10
77
PB
5.49
14.64
1.83
3.66
80.54
0.46
0.41
117.61
1.83
5.49
48.05
8.24
28.83
2.75
Potential
Company
Acme
Aircraft
A I car o
Alfred
AffierSurap
AmerElec
Andarn
Anodiz
Aurilyte
AutoElec
Beamar
Best
CPatti
ChroneArt
CircuitMan
Ccxnet
Diamond
Double
Durite
ECElec
ElCircuit
ElProc
GH K«tal
GenHet
Highland
HyGrad*
CO
3.64
2.28
8.73
1.14
3.04
3.04
3.19
3.42
3.42
17.84
0.38
3.04
3.80
2.62
1.52
0.19
0.19
4.17
1.52
5.69
1.52
2.66
3.42
18.10
1.52
0.61
CR
360.82
225.52
873.21
113.90
300.69
300.69
315.72
338.27
338.27
1784.38
37.59
300.69
375.86
261.96
150.34
18.79
18.79
413.44
150.34
563.79
151.86
263.10
338.27
1792.85
150.34
60.14
CU
162.61
101.
401.
52.
135.
135.
142.
152.
152.
820.
16.
135.
169.
120.
67.
8.
8.
186.
67.
254.
69.
118.
152.
807.
67.
27.
63
62
39
50
50
28
44
44
71
94
50
38
49
75
47
47
32
75
07
85
57
44
95
75
10
PB
4.22
2.64
10.10
1.32
3.51
3.51
3.69
3.95
3.95
20.65
0.44
3.51
4.39
3.03
1.76
0.22
0.22
4.83
1.76
6.59
1.76
3.08
3.95
20.96
1.76
0.70
HG
0.02
0.04
0.01
0.01
0.24
0.00
0.00
0.36
0.01
0.02
0.15
0.02
0.09
0.01
Improvement
HG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
-------
Passaic Valley Sewerage Commissioners
Newark, New Jersey
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and Metal Finishing (Cont.)
Company
Ideal
Imperial
IndPlat
IndHard
JCMet
Keystone
Kohinoor
Loisel
Manco
Mara
Miller
Mottern
Moyer
NJ Gal
MuTron
Ondecker
PNC
PanGraph
Para
PlatCity
Polaris
Precision
PrecProt
QualHet
Ranno
Redi
Remie
Reyom
Suffern
SunMet
TAFar
Timco
Trb/alb
Trio
Arrow
ArtHet
CALaus
Conrad
Oaytona
Edmar
Gloube
Gordos
ITT
JBHirsh
Medin
9
9
26
0
2
3
7
3
0
0
14
1
3
4
4
1
6
5
3
2
4
1
1
0
17
2
1
1
20
11
3
1
0
0
50
11
0
11
CO
.11
.87
.19
.76
.66
.04
.21
.80
.19
.68
.42
.14
.04
.17
.93
.33
.45
.69
.61
.47
.55
.90
.52
.76
.84
.62
.52
.10
.12
.77
.42
.90
.38
.87
.48
.01
.38
.01
4.55
12
1
3
66
0
0
.14
.52
.04
.80
.38
.34
CR
911.17
987.10
2619.62
75.17
263.10
300.69
714.13
375.86
18.79
67.65
1442.69
112.76
303.72
417.62
493.55
131.55
645.41
563.79
357.07
244,31
451.03
187.93
150.34
75.17
1784.38
259.34
150.34
109.00
2012.17
1176.93
338.27
187.93
37.59
86.45
5049.42
1101.00
37.59
1101.00
455.59
1214.90
151.86
300.69
6615.11
37.59
33.83
Potential Improvement (kg/year
CU PS HG NI
419.09
454.01
1204.
87
33.88
118.57
135.50
321.
169.
8.
30.
663.
50.
139.
192.
227.
59.
296.
254.
160.
110.
203.
84.
67.
33.
820.
116.
67.
49.
925.
541.
152.
84.
16.
38.
2322.
506.
16.
506.
209.
558.
69.
135.
2981.
16.
15.
82
38
47
49
55
81
70
08
01
28
85
07
91
10
26
69
75
88
71
87
75
12
48
32
44
69
94
96
44
40
94
40
54
78
85
50
10
94
24
10.54
11.42
30.31
0.88
3.08
3.51
8.35
4.39
0.22
0.79
16.69
1.32
3.51
4.83
5.71
1.54
7.47
6.59
4.17
2.86
5.27
2.20
1.76
0.88
20.65
3.03
1.76
1.27
23.28
13.62
3.95
2.20
0.44
1.01
58.43
12.74
0.44
12.74
5.27
14.06
1.76
3.51
77.32
0.44
0.40
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
513.32
556.10
1475.80
41.92
146.72
167.69
398.25
209.61
10.48
37.73
812.76
62.88
171.11
235.27
278.05
73.36
363.60
314.41
199.13
136.24
251.53
104.80
83.84
41.92
1005.26
144.63
83.84
60.79
1133.59
663.04
188.65
104.80
20.96
48.21
2844.66
620.26.
20.96
620.26
256.66
684.43
85.55
167.69
3689.08
20.96
18.86
reduction)
AG ZN
0.73
0.79
2.08
0.06
0.21
0.24
0.57
0.30
0.02
0.05
1.15
0.09
0.24
0.33
0.39
0.11
0.51
0.45
0.29
0.20
0.36
0.15
0.12
0.06
1.42
0.21
0.12
0.09
1.60
0.94
0.27
0.15
0.03
0.07
4.02
0.88
0.03
0.88
0.36
0.97
0.12
0.24
5.32
0.03
0.03
413.78
448.26
1189.61
33.45
117.06
133.79
317.75
167.23
8.36
30.10
655.15
50.17
137.93
189.65
- 224.13
58.53
293.09
250.85
158.87
108.70
200.68
83.62
66.89
33.45
810.31
115.39
66.89
48.50
913.76
534.46
150.51
83.62
16.72
38.46
2293.02
499.98
16.72
499.98
206.89
551.70
68.96
133.79
2943.34
16.72
15.05
CM
40.03
43.37
115.09
0.00
0.00
0.00
0.00
0.00
0.00
0.00
63.38
0.00
13.34
18.35
21.68
0.00
28.35
0.00
0.00
0.00
0.00
0.00
0.00
0.00
78.39
0.00
0.00
0.00
88.40
51.71
0.00
0.00
0.00
0.00
221.84
48.37
0.00
48.37
20.02
53.37
6.67
" 0.00
0.00
0.00
0.00
E-33
-------
Pissaic Valley Sewerage Commissioners
Newirk, Hew Jersey
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and Metal Finishing (Cont.)
Company
CO
Presto 97.54
Philips 1.52
TEInd 4.55
WallaceiT 39.85
Ueston 6.83
Uestwood 23.91
Vfbra 2.28
Electroplating and Metal Finishing
Total Poll Rerooved 619.77
Iron and Steel Manufacturing
Avg flow In
Cocpany (HGO) Compliance
«vu
HatStand 0.141
Company
HatStand
Leather Tanning
Avg flow In
Ccrpany (HGO) Compliance
no/I:
HJ Tan 0.027 1
Ocean 0.346
Seton 1.153
CO
0
0.00
CO
0.00
CO
0
0.00
0.00
0.00
CR
Potential Improvement (kg/year
CU PB HG NI
9757.14 4487.72
151.86 69.85
451.03 203.26
3986.38 1833.50
676.55 304.89
2367.91 1067.10
227.79 104.77
61769.50 28200.44
CR CU
0
0.00
CR
0.00
CR
160
5972.73
76539.39
255058
0
112.91
1.76
5.27
46.13
7.91
27.68
2.64
717.42
Typical Raw
PB
0
0.00 5496.83
0.00 85.55
0.00 251.53
0.00 2245.79
0.00 377.29
0.00 1320.52
0.00 128.33
0.00 34670.20
Wastes
HG
0
0.00 0.00 0.00
Potential Improvement
CU PB HG
0.00
CU
0.05
1.87
23.92
79.71
0.00
Typical Raw
PB
1.1
41.06
526.21
1753.52
0.00
Wastes
HG
0
0.00
0.00
0.00
(Kg/year)
NI
0
0.00
(kg/year
NI
0.00
(Kg/year)
NI
0.06
2.24
28.70
95.65
reduction)
AG ZN
7.76
0.12
0.36
3.17
0.54
1.90
0.18
49.33
AG
0
4430.86
68.96
200.63
1810.28
301.02
1053.58
103.44
27843.19
ZH
0.2
0.00 38.99
reduction)
AG ZN
0.00
AG
0
0.00
0.00
0.00
0.00
ZN
0.05
1.87
23.92
79.71
CN
428.66
6.67
0.00
175.13
0.00
0.00
10.01
1721.15
CN
50
9747.16
CN
9747.16
CH
0
0.00
0.00
0.00
E-34
-------
Passaic Valley Sewerage Commissioners
Newark, New Jersey
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Company
CO
CR
Potential Improvement (kg/year reduction)
CU PB HG NI AG ZN
CN
NJ Tan
Ocean
Seton
0.00 5853.27
0.00 76539.39
0.00 255058
Total Poll Removed(kg/year) 0 337450.2
0.00
0.00
0.00
0
36.14
463.06
1543.10
2042.296
0.00
0.00
0.00
0
0.00
0.00
0.00
0
0.00 0
0.00 0
0.00 0
0
.00
.00
.00
0
0.00
0.00
0.00
0
Pulp and Paper
Avg flow In
Company (MGO) Compliance
mg/l:
Chin Am 0.567 1
GardenSt 7.269 1
Harcal 3.073 . 1
Newark 0.138 1
CO CR
0 0.005
0.00 3.92
0.00 50.25
0.00 21.24
0.00 0.95
CU
0.028
21.95
281 .40
118.96
5.34
Typical Raw
PB
0.009
7.06
90.45
38.24
1.72
Wastes
HG
0
0.00
0.00
0.00
0.00
Potential Improvement
Company
Chin Am
GardenSt
Harcal
Newark
Total Poll Removed(kg/ye*r)
Aluminum Forming
Avg flow In
Company (HGO) Compliance
mg/l:
Warner 0.001 1
CD CR
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0 0
CO CR
0 0
0.00 0.00
CU
0.00
0.00
0.00
0.00
0
CU
0.132
0.18
PB
0.00
0.00
0.00
0.00
0
Typical Raw
PB
0.237
0.33
HG
0.00
0.00
0.00
0.00
0
Wastes
HG
0
0.00
Potential Improvement
Company
CD CR
CU
PB
HG
(Kg/year)
NI
0.005
3.92
50.25
21.24
0.95
(kg/year
NI
0.00
0.00
0.00
0.00
0
(Kg/year)
NI
0.028
0.04
< kg/year
NI
AG
0 0.
0.00 58
0.00 743
0.00 314
0.00 14
reduction)
AG
0.00 0
0.00 0
0.00 0
0.00 0
0
AG
ZN
074
.01
.70
.40
.12
ZN
.00
.00
.00
.00
0
ZN
0 1 .897
0.00 2
reduction)
AG
.62
ZN
CN
0
0.00
0.00
0.00
0.00
CN
0.00
0.00
0.00
0.00
0
CN
0
0.00
CN
BEHP
0.007
5.49
70.35
29.74
1.34
BEHP
0.00
0.00
0.00
0.00
0
BEHP
8.014
11.08
BEHP
Warner
0.00 0.00 0.00 0.11 0.00 0.00 0.00 0.84
E-35
0.00 0.00
-------
Patsaic Valley Sewerage Commissioners
Newark, New Jersey
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Copper Forming
Avg flow In
Company (HGO) Compliance
mg/l:
LittleFal 0.014
Otconite 0.029 1
CO
0.009
0.17
0.36
CR
0
0.00
0.00
cu
0.911
17.63
36.53
Typical
PB
0.235
4.55
9.42
Potential
Company
LittleFal
Okonite
Total Poll Removed(kg/year)
Plastics Holding t Forming
Avg flow In
Company (HGO) Compliance
mg/l:
VanMess 0.071 1
KleerKast 0.033 1
Hartz 0.051 1
Wallace 0.105 1
CO
0.17
0.00
0.17
CR
0.00
0.00
0.00
CU
17.63
0.00
17.63
PB
4.50
0.00
4.50
Raw Wastes
HG
0
0.00
0.00
Improvement
HG
0.00
0.00
0.00
Typical Raw Wastes
CO
0
0.00
0.00
0.00
0.00
CR
0
0.00
0.00
0.00
0.00
CU
0
0.00
0.00
0.00
0.00
PB
0
0.00
0.00
0.00
0.00
HG
0
0.00
0.00
0.00
0.00
Potential Improvement
Company
VanNess
KleerKast
Hartz
Wallace
CO
0.00
0.00
0.00
0.00
CR
0.00
0.00
0.00
0.00
CU
0.00
0.00
0.00
0.00
PB
0.00
0.00
0.00
0.00
HG
0.00
0.00
0.00
0.00
(Kg/year)
NI
0.007
0.14
0.28
< kg/year
NI
0.13
0.00
0.13
(Kg/year)
NI
0
0.00
0.00
0.00
0.00
(kg/year
NI
0.00
0.00
0.00
0.00
AG
0
0.00
0.00
ZH
1.27
24.58
50.92
CN
0
0.00
0.00
BEHP
0.007
0.14
0.28
reduction)
AG
0.00
0.00
0.00
AG
0
0.00
0.00
0.00
0.00
reduction)
AG
0.00
0.00
0.00
0.00
ZN
24.58
0.00
24.58
ZN
0.598
58.70
27.28
42.17
86.81
ZN
36.39
16.92
26.14
53.82
CN
0.00
0.00
0.00
CN
0
0.00
0.00
0.00
0.00
CN
0.00
0.00
0.00
0.00
BEHP
0.13
0.00
0.13
BEHP
0.098
9.62
4.47
6.91
14.23
BEHP
8.66
4.02
6.22
12.80
Total Poll Ren»ved(kg/year)
0.00
0.00
0.00
0.00
0.00
0.00
0.00 133.28
0.00 31.71
E-36
-------
Passaic Valley Sewerage Commissioners
Newark, Hew Jersey
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a wits
factor: 1383.575
Battery Manufacturing
Avg flow In
Company (HGD) Compliance
mg/l:
PowerBat 0.001 1
Company
PowerBat
Kon- Ferrous Metals
Avg flow In
Company (MO)) Compliance
mg/l:
Certified 0.011 0
Engelhard 0.038 0
OH I 0.06 0
Company
Certified
Engelhard
ONI
CO
0.0005
0.00
CO
0.00
CO
0.319
4.85
16.76
26.46
CO
4.75
16.42
25.93
CR
0.076
0.11
CR
0.02
CR
2.87
43.65
150.78
238.08
CR
43.65
150.78
238.08
CU
0.176
Typical Raw wastes
PB KG
206
0.24 284.81
Potential
CU PB
0.14
CU
1.68
0.00
0.008
0.01
Improvement
HG
(Kg/year)
NI
0.073
0.10
(kg/year
NI
0.00 0.07
Typical Raw Wastes (Kg/year)
PB KG HI
0.07
25.55 1.06
88.26 3.68
139.36 5.81
Potential
CU PB
25.04
86.50
136.58
0.95
3.27
5.17
0
0.00
0.00
0.00
Improvement
HG
0.00
0.00
0.00
32.3
498.83
1723.24
2720.91
(kg/year
HI
498.83
1723.24
2720.91
AG
0.0188
0.03
reduction)
AG
O.'X)
AG
0
0.00
0.00
0.00
reduction)
AG
0.00
0.00
0.00
' ZN
0.487
0.67
ZH
0.22
ZM
0.18
2.74
9.46
14.93
ZN
2.41
8.32
13.14
CN
0
0.00
CN
0.00
CN
0
0.00
0.00
0.00
CM
0.00
0.00
0.00
BEHP
0
0.00
BEHP
0.00
BEHP
0
0.00
0.00
0.00
BEHP
0.00
0.00
0.00
Total Poll Removed
-------
Passoic Valley Sewerage ConroEssioners
Newark, New Jersey
Company data supplied in ing/1. Converted
to Kg/yr based on avg flou and a units
factor: 1383.575
Textile Mills
Avg flow In
Conpsny (HGD) Compliance CO
rog/U
ALDyers
Apollo
Baltic
Boris
Champion
Columbia
COffiO
Coral
Craft
Dyetex
Ewpire
EUPiece
InterVeil
Interstat
Leader
Manner
Hissbrem
HJersey
Paragon
Paterson
Paul's
Perennial
Signature
Pooghkeep
Rainbow
Reneo
Stacy
Sunbrite
TextilePi
Thomas
Thorn
Trio
Zenith
0.011
0.017
0.07
0.104
0.067
0.559
0.135
0.164
0.318
0.467
0.024
0.023
0.063
0.045
0.381
0.094
0.41
0.033
0.03
0.043
0.026
0.096
0.135
0.247
0.066
0.09
0.047
0.102
0.176
0.008
0.113
1.359
0.162
0
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
1 0.00
CR
0.787
11.97
18.50
76.17
113.16
72.90
608.24
146.89
178.45
346.01
508.14
26.11
25.03
68.55
48.96
414.56
102.28
446.12
35.91
32.64
46.79
28.29
104.46
146.89
268.76
71.81
97.93
51.14
110.98
191.50
8.70
122.95
1478.71
176.27
Typical Raw Wastes (Kg/year)
CU PS KG NI
0.656
9.98
15.42
63.49
94.32
60.77
507.00
122.44
148.74
288.42
423.55
21.77
20.86
57.14
40.81
345.56
85.26
371.86
29.93
27.21
39.00
23.58
87.07
122.44
224.02
59.86
81.63
42.63
92.51
159.63
7.26
102.49
1232.57
146.93
0
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
AG
0
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
ZH
0.999
15.19
23.48
96.68
143.64
92.54
772.09
186.46
226.52
439.22
645.02
33.15
31.77
87.02
62.15
526.23
129.83
566.29
45.58
41.44
59.39
35.91
132.59
186.46
341.15
91.16
124.31
64.92
140.88
243.09
11.05
156.07
1877.04
223.75
CN
0.071
1.08
1.67
6.87
10.21
6.58
54.87
13.25
16.10
31.22
45.84
2.36
2.26
6.18
4.42
37.40
9.23
40.25
3.24
2.94
4.22
2.55
9.42
13.25
24.25
6.48
8.83
4.61
10.01
17.28
0.79
11.09
133.40
15.90
BEHP
0.21
3.19
4.94
20.32
30.20
19.45
162.30
39.20
47.62
92.33
135.59
6.97
6.68
18.29
13.07
110.62
27.29
119.04
9.58
8.71
12.48
7.55
27.87
39.20
71.71
19.16
26.13
13.65
29.61
51.10
2.32
32.81
394.57
47.04
E-38
-------
Passaic Valley Sewerage Cocmrissioners
Newark, New Jersey
Conpany data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Conpany
CO
CR
Potential Improvement (kg/year reduction)
CU PS HC NI AG ZN
CN
BEHP
ALDyers
Apollo
Baltic
Boris
Champion
Columbia
Como
Coral
Craft
Dyetex
Empire
EWPiece
InterVeil
Interstate
Leader
Manner
Hissbrenner
NJersey
Paragon
Paterson
Paul's
Perennial
Signature
Poughkeep
Rainbow
Renco
Stacy
Sunbrite
TextilePiece
Thomas
Thorn
Trio
Zeni th
Total Poll RemovedCkg/year)
/*___.J T*»*M|
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
CO
4.79
7.40
30.47
45.26
29.16
243.30
58.76
71.38
138.40
203.25
10.45
10.01
27.42
19.59
165.82
40.91
178.45
14.36
13.06
18.72
11.32
41.78
58.76
107.50
28.73
39.17
20.46
44.39
76.60
3.48
49.18
591.48
70.51
2474.31
CR
3.99
6.17
25.40
37.73
24.31
202.80
48.98
59.50
115.37
169.42
8.71
8.34
22.86
16.33
138.22
34.10
148.74
11.97
10.88
15.60
9.43
34.83
48.98
89.61
23.94
32.65
17.05
37.00
63.85
2.90
41.00
493.03
58.77
2062.45
CU
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
PB
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
. 0.00
0.00
0.00
0.00
0.00
0.00
0.00
HG NI
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
AG
5.93
9.16
37.71
56.02
36.09
301.11
72.72
88.34
171.30
251.56
12.93
12.39
33.94
24.24
205.23
50.63
"220.85
17.78
16.16
23.16
14.01
51.71
72.72
133.05
35.55
48.48
25.32
54.94
94.81
4.31
60.87
732.05
87.26
3062.31
ZN
1.08
1.67
6.87
10.21
6.58
54.87
13.25
16.10
31.22
45.84
2.36
2.26
6.18
4.42
37.40
9.23
40.25
3.24
2.94
4.22
2.55
9.42
13.25
24.25
6.48
8.83
4.61
10.01
17.28
0.79
11.09
133.40
15.90
558.06
CN
3.03
4.69
19.31
28.69
18.48
154.19
37.24
, 45.24
87.71
128.81
6.62
6.34
17.38
12.41
105.09
25.93
113.09
9.10
8.27
11.86
7.17
26.48
37.24
68.13
18.20
24.82
12.96
28.13
48.55
2.21
31.17
374.84
44.68
1568.06
BEHP
Pollutant Removed
Total Plant Loading
-------
River Road
Wichita Falls, TX
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and Metal Finishing
Avg flow In
Company (HGO) Compliance
Stanley 0.048 1
Tranter 0.01 1
Hnunet 0.027 1
HawnetRef 0.004 1
Typical Raw Wastes (Kg/year)
CO
1.26
0.11
0.22
0.00
CR
139.36
1.59
6.35
0.00
CU
24.55
0.00
1.31
0.25
PB
3.32
0.00
0.00
0.00
HG
0.00
0.00
0.00
0.00
Potential Improvement
Company
Stanley
Tranter
Haunet
HawaetRef
CO
1.22
0.11
0.22
0.00
Total Poll Removed(kg/year) 1.55
Battery Manufacturing
Avg flow In
Company (HGD) Compliancu
AC 0.04 1
CO
0.00
CR
137.97
1.57
6.28
0.00
CU
23.82
0.00
1.27
0.24
145.83 25.33
CR
0.00
CU
3.43
PB
3.19
0.00
0.00
0.00
3.19
Typical Raw
PB
6.19
HG
0.00
0.00
0.00
0.00
0.00
Wastes
HG
0.00
Potential Improvement
Company
AC
Avg flow CO
Grand Total (HGD)
Pollutant Removed
Averaoe Inf luent(mg/l)
CO
0.00
1.55
0.01
CR
0.00
CR
145.83
0.22
CU
1.95
CU
27.28
0.13
PB
0.00
PB HG
3.19
0.09
HG
0.00
NI
491.09
10.23
27.62
6.69
(kg/year
NI
481.27
10.03
27.07
6.56
524.92
(Kg/year)
NI
3.87
(kg/year
NI
2.75
AG
0.00
0.00
0.00
0.00
reduction)
AG
0.00
0.00
0.00
0.00
0.00
AG
0.00
reduction)
AG
0.00
NI AG ZN
0.00
0.01
527.67
0.01
0.00
ZN
19.91
3.00
0.00
2.77
ZN
19.31
2.91
0.00
2.68
24.90
=======:=:=
ZN
0.00
ZN
0.00
CN
24.90
0.33
CN
0.00
0.00
0.00
0.00
CM
0.00
0.00
0.00
0.00
0.00
!£====»
CN
0.00
CN
0.00
BEHP
0.00 0.00
Total Plant Loadin
CK8/year)
Percent Removable
11 152.08 3345.83 1977.08 1368.75 152.08 535.64 0.00 5018.75
1.0
4.4
1.4
0.2
0.0
98.5
0.0
0.5
0.00
0.0
0.00
0.0
E-40
-------
Trinity River Authority
Grand Prarie, TX
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electroplating and Metal Finishing
Avg flow In
Company
Gen Mag
Groff
LFC
Electro
Irving
Western
Texas
EDM
Atlas
NatHand
BMC
RediStrip
LTV
NatMet
HEB
Edd's
(MGO) Compliance
0.0243 1
0.0146 1
0.0025 1
0.016 1
0.004
0.008
0.004 1
0.02 1
0.01
0.093 1
0.044 1
0.0021 1
1.1525 1
0.0209 1
0.0035
0.02 1
CD
0.47
0.00
0.44
0,00
0.00
0.00
0.00
0.00
0.00
0.00
47.45
0.12
63.74
38.72
0.01
52.54
CR
2.24
0.10
0.15
0.00
0.55
191.35
3.32
12.44
276.52
280.30
220.22
2.93
5529.16
143.03
396.80
24.33
Typical Raw Wastes (Kg/year)
CU
0.00
0.46
34.77
0.00
0.00
0.00
0.00
0.00
0.00
6.43
141.74
1.92
207.14
17.92
0.01
161.76
PB
1.10
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.29
13.38
1.07
223.08
8.09
0.05
1.38
HG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Potential Improvement
Company
Gen Mag
Groff
LFC
Electro
Irving
Western
Texas
EDM
Atlas
NatHand
BMC
RediStrip
LTV
NatMet
HEB
Edd's
CD
0.45
0.00
0.42
0.00
0.00
0.00
0.00
0.00
0.00
0.00
46.03
0.11
61.82
37.56
0.01
50.96
CR
2.22
0.10
0.14
0.00
0.55
191 .35
3.29
12.32
276.52
277.50
218.01
2.90
5473.87
141.60
396.80
24.09
CU
0.00
0.45
33.73
0.00
0.00
0.00
0.00
0.00
0.00
6.24
137.49
1.86
200.93
17.38
0.01
156.91
PB
1.06
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
1.23
12.85
1.03
214.16
7.77
0.05
1.33
HG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
NI
2.54
0.20
0.00
0.00
0.00
0.00
0.00
165.91
0.00
119.58
338.84
0.52
414.29
95.07
343.57
65.53
(kg/year
NI
2.49
0.20
0.00
0.00
0.00
0.00
0.00
162.59
0.00
117.19
332.06
0.51
406.00
93.17
343.57
64.22
AG
0.01
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
79.67
1.44
0.00-
0.00
ZN
0.00
2.42
0.00
0.00
0.00
0.77
0.55
13.83
4.84
9.00
193.45
2.67
302.75
15.89
2.47
45.63
CM
167.29
1.01
0.17
0.00
0.00
0.00
0.00
0.00
0.00
0.00
114.37
0.90
1035.72
19.65
0.00
77.98
reduction)
AG
0.01
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
75.69
1.37
0.00
0.00
ZN
0.00
2.35
0.00
0.00
0.00
0.77
0.54
13.41
4.84
8.73
187.65
2.59
293.67
15.42
2.47
44.26
CN
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Total Poll Removed(kg/year) 197.37 7021.27 554.99 239.47 0.00 1522.01 77.07 576.69
0.00
E-41
-------
Trinity River Authority
Grind Prarie, TX
Company data supplied in rog/l. Converted
to Kg/yr based on avg flow and a in its
factor: 1382.575
Inorganic Chemicals
Typical Raw Wastes (Kg/year)
Company
Hohawk
(HGO)
0.03
Compliance
1
CO
0.00
CR
5.53
cu
16.59
PB
5.53
HG
0.00
NI
0.00
AG
1.11
ZN
0.00
CN
Potential Improvement (kg/year reduction)
Coapany
Mohawk
CO
0.00
CR
5.31
CU PB
4.98 4.76
HG NI
0.00 0.00
AG ZN
0.31 0.00
CN
Pulp and Paper
Avg flow In Typical Raw Wastes (Kg/year)
Company (HGO) Compliance CO CR CU PB HG NI AG ZN CN BEHP
Western
Internat
0.053
0.012
0.00
0.00
0.00
0.00
0.00
13.27
8.06
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
3.32
0.00
2.32
0.00
0.00
Company
CO
CR
Potential Improvement (kg/year reduction)
CU PB HG NI AG ZN
Total Poll RemovedCkg/year)
CN
BEHP
Western
Internal
0
0
.00
.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Printing and Publishing
Avg flow In
Company (HGO) Cc*pliancis , CO CR
Typical Raw Wastes (Kg/year)
CU PB HG NI
AG
ZN
CN
BEHP
Texas 0.032
HydroGrap 0.146
1
0.00
2.22
6.19
1.82
4.42
3.84
0.00
0.00
0.00
0.00
2.65
2.22
1.33
0.00
0.00
35.73
0.00
0.00
0.00
0.00
Company
CO
CR
Potential IiaproveBent (kg/year reduction)
CU PB HG NI AG ZN
CN
BEHP
Texas
HydroGraph
Total Poll Removed
0.
0.
0.
00
00
00
5.70
1.82
7.52
1.02
3.34
4.35
0.00
0.00
0.00
E-42
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
-------
Trinity River Authority
Grand Prarie, TX
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Battery
Avg flow In
Company (HGD) Compliance
GNB 0.032 1
Company
Total Poll Removed
Plastics Holding and Forming
Avg flow In
Company (HGD) Compliance
Americhem 0.019 ' 1
Vinyl ex 0.03
Surgikos 0.3735 1
Company
Americhem
Vinylex
Surgikos
CD CR
0.00 0.00
CO CR
0.00 0.00
CO CR
0.05 0.21
0.00 0.00
00
CO CR
0.00 0.00
0.00 0.00
0.00 0.00
CU
Typical Raw Wastes
PB HG
0.00 23.45
Potential
CU PB
0.00
CU
0.00
Typical
PB
0.79 0.26
0.00 0.00
0 0
Potential
CU PB
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Improvement
HG
0.00
Raw Wastes
HG
0.00
0.00
0
Improvement
HG
0.00
0.00
0.00
(Kg/year)
Ml
11.06
(kg/year
HI
7.85
(Kg/year)
MI
0.00
0.00
0
(kg/year
MI
0.00
0.00
0.00
AG
0.00 0
reduction)
AG
0.00 0
AG -
ZN
.00
ZH
.00
ZN
0.00 1.92
0.00 149.32
0 4440.971
reduction)
AG ZN
0.00 1
0.00 92
0.00 2753
.19
.58
.40
CN
0.00
CN
0.00
CN
0.00
0.00
0
CN
0.00
0.00
0.00
BEHP
0.00
BEHP
0.00
BEHP
0.00
0.00
0
BEHP
0.00
0.00
0.00
Total Poll Removed(kg/year>
0 2847.168
E-43
-------
Trinity River Authority
Grand Prarie, TX
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
Electrical and Electronic Coop
Avg flow In
Company
Thermal
Electro
TRU
Boeing
Hitachi
Irving
A-L
Circuitro
ElecOrill
Tel cor
PHCircuit
HTexas
(MOD) Compliance
0.068 1
0.014 1
0.003
0.0021
0.0018 1
0.0077
0.0045
0.015
0.0003
0.166 1
0.01
0.0445 1
CO
0.00
0.00
0.00
0.29
0.00
0.53
0.00
0.00
0.04
11.48
0.69
0.00
CR
122.22
0.00
0.00
0.00
0.00
1.28
0.00
0.00
0.00
22.95
3.46
0.00
CU
94.02
22.07
6.22
7.26
0.00
159.69
26.13
269.60
1.04
245.57
71.89
278.71
Typical
PB
0.00
1.94
1.66
5.81
0.12
11.71
90.84
16.59
0.83
34.43
40.65
7.63
Potential
Company
Thermal
Electro
TRU
Bc*ing
Hitachi
Irvina
AIL
Circuitron
ElecOrill
Telcor
PHCircuit-
NTexas
Total Poll
«_____MXM
r.r-m^A Tnf.l
Re«oved(kg/yea.-}
:_a_xj«__3x__at__-i__-==
Avg floM CD
tttn\\ ...
CD
0.00
0.00
0.00
0.28
0.00
0.51
0.00
0.00
0.04
3.44
0.66
0.00
4.94
._^ x.
CR
20.78
0.00
0.00
0.00
0.00
1.14
0.00
0.00
0.00
3.90
3.08
0.00
28.89
_=-£5_SXS3^-!
CR
CU
22.56
5.30
1.49
1.74
0.00
38.33
6.27
64.70
0.25
58.94
17.25
66.89
283.73
CU
PB
0.00
0.77
1.64
5.75
0.05
11.59
89.93
16.42
0.82
13.77
40.24
3.05
184.05
3;__=s.
PB
Raw Wastes (Kg/year)
HG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Improvement
HG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
=xxxxxxxxs==
HG HI
NI
65.81
0.00
3.32
0.00
0.00
6.17
27.38
1.45
0.00
59.67
0.00
1.29
(kg/year
NI
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
3XXXXXX==:
AG
AG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.21
0.00
0.00
0.00
0.00
reduction)
AG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
___________
ZN
ZN
47.01
0.00
0.00
0.00
0.00
1.38
0.00
0.00
0.00
11.48
0.00
0.00
ZN
0.00
0.00
0.00
0.00
0.00
1.37
0.00
0.00
0.00
0.00
0.00
0.00
1.37
==X3X===
CH
CN
0.00
0.00
0.00
0.00
0.00
0.53
116.97
0.00
0.00
0.23
0.69
0.00
CH
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
_______
BEHP
0.00
0.00
0.00
0.00
0.00
0.00
0.00
o.co
0.00
0.00
0.00
0.00
BEHP
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
_________
BEHP
Pollutant Removed
Ave Influent
Total Plant Poll
Loadings (kg/yr)
Percent Removed
202.31 7062.98 848.05 428.27 0.00 1529.86 77.38 3425.22 0.00 0.00
0.01 0.055 0.078 0.04 0.0004 0.02 0.17 0.281
B4 1161.36 7247.10 9058.64 4645.45 0.00 2322.73 0.00 19743.18 0.00 32634.32
17.4 97.5 9.4 9.2 0.0 65.9 0.0 17.3 0.0 0.0
E-44
-------
Westerly Treatment Plant
Northeast Ohio Regional Sewer District
Cleveland, OH
Assume Pretreatroent
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
MCF-MGO: 0.000020
Inorganic Chemicals
Avg flou In Typical Raw Wastes (Kg/year)
Company (MGD) Compliance CO CR CU PB HG MI AG ZM CM
(mg/l) 0.037 1.9 17 21 0.003 22 0.018 3
AirProd 0.012 1 0.6 31.7 283.7 350.5 0.1 367.1 0.3 50.1
Potential Potential Improvement (kg/year reduction)
Company CO CR CU PB HG NI AG ZH CN
AirProd 0.0 30.4 85.1 301.4 0.0 154.2 0.1 34.0
33S33s33S3333s3333333sss33333333333
Electroplating and Metal Finishing
Avg flow In Typical Raw Wastes (Kg/year)
Company (HGO) Compliance CO CR CU PB HG HI AG ZN CN
(mg/l) 0.283 27.46 12.63 0.331 0.001 15.47 0.023 12.47 1.856
Aircraft
AlumAnod
Arv
AutoTap
CTIndus
CleveMet
Ouray
Guarantee
H end S
KBPlat
Kelly
Koster
Kyron
Master
Haynard
ProdFin
SRC
SouthShor
Strassen
0.007
0.002
0.001
0.011
0.017
0.007
0.002
0.009
0.000
0.004
0.077
0.001
0.006
0.001
0.000
0.130
0.000
0.000
0.002
2.59
0.95
0.28
4.32
6.59
2.87
0.92
3.63
0.02
1.49
30.24
0.55
2.49
O.S4
0.10
51.01
0.02
0.08
0.87
251.30
91.81
27.23
419.36
639.54
278.54
89.47
352.45
2.33
144.71
2933.96
53.68
241.19
52.13
9.34
4949.85
2.33
7.78
84.81
115.59
42.23
12.52
192.88
294.15
128.11
41.15
162.11
1.07
66.56
1349.45
24.69
110.93
23.98
4.29
2276.64
1.07
3,58
39.01
3.03
1.11
0.33
5.05
7.71
3.36
1.08
4.25
0.03
1.74
35.37
0.65
2.91
0.63
0.11
59.66
0.03
0.09
1.02
0.01
0.00
0.00
0.02
0.02
0.01
0.00
0.01
0.00
0.01
0.11
0.00
0.01
0.00
0.00
0.18
0.00
0.00
0.00
141.58
51.72
15.34
236.25
360.30
156.92
50.41
198.56
1.31
81.53
1652.89
30.24
135.88
29.37
5.26
2788.57
1.31
4.38
47.78
0.21
0.08
0.02
0.35
0.54
0.23
0.07
0.30
0.00
0.12
2.46
0.04
0.20
0.04
0.01
4.15
0.00
0.01
0.07
114.12
41.69
12.37
190.44
290.43
126.49
40.63
160.05
1.06
65.72
1332.36
24.38
109.53
23.67
4.24
2247.80
1.06
3.53
38.51
16.99
6.21
1.84
28.34
43.23
18.83
6.05
23.82
0.16
9.78
198.30
3.63
16.30
3.52
0.63
334.56
0.16
0.53
5.73
E-45
-------
Westerly Treatment Plant
Hortheast Ohio Regional. Sewer District
Cleveland, OH
Assume Pretreatment
Ccopany
CO
Company data supplied in mg/l. Converted
to ICg/yr based on avg flow and a units
factor: 1382.575
MCF-HGD: 0.000020
Potential Improvement (kg/year reduction)
Aircraft
AluMnod
Arv
AutoTap
CT Indus
CleveHet
Ouray
Guaranteed
H and S
KBPlat
Kelly
Koster
Kyron
Master
Haynard
Prodffn
SRC
SouthShore
Strassen
WtS
2.51
0.92
0.27
4.19
6.39
2.78
0.89
3.52
0.02
1.45
29.33
0.54
2.41
0.52
0.09
49.48
0.02
0.08
0.85
\*K
248.79
90.89
26.96
415.17
633.15
275.75
88.58
348.92
2.31
143.27
2904.62
53.15
238.78
51.61
9.24
4900.35
2.31
7.70
83.96
LU
112.12
40.96
12.15
187.09
285.33
124.27
39.92
157.24
1.04
64.56
1308.97
23.95
107.61
23.26
4.17
2208.34
1.04
3.47
37.84
PB
2.91
1.06
0.32
4.85
7.40
3.22
1.04
4.08
0.03
1.67
33.95
0.62
2.79
0.60
0.11
57.28
0.03
0.09
0.98
HG
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
NI
138.74
50.69
15.03
231.53
353.09
153.78
49.40
194.59
1.29
79.90
1619.83
29.64
133.16
28.78
5.15
2732.80
1.29
4.30
46.82
AG
0.20
0.07
0.02
0.33
0.51
0.22
0.07
0.28
0.00
0.12
2.33
0.04
0.19
0.04
0.01
3.94
0.00
0.01
0.07
ZN
110.70
40.44
12.00
184.72
281.71
122.69
39.41
155.25
1.03
63.75
1292.39
23.65
106.24
22.96
4.11
2180.37
1.03
3.43
37.36
CN
16.82
6.14
1.82
28.06
42.79
18.64
5.99
23.58
0.16
9.68
196.32
3.59
16.14
3.49
0.62
331.21
0.16
0.52
5.67
Total Poll RemovedCkg/year) 106.28 10525.51 4743.32 123.03
0.00 5869.81 8.46 4683.23 711.41
Iron and Steel Manufacturing
Avg flow in
Ccxnpany (HGO) Conpliance CO CR
3====3===.=3==3=3====S=33=3===Z3==============__=.,___________
Typical Raw Wastes (Kg/year)
.C^!!
ForestCft 0.07
Company
oooo
1 0.00 0.00 0.00 0.00
Potential
CO CR CU PB
0.00 0.00 0.00 0.00
I HG
> 0
0.00
Improvement
HG
0.00
NI
0
0.00
(kg/year
NI
0.00
AG ZN CN
0 0.2 50
0.00 18.00 4499.33
reduction)
AG ZN CN
0.00 0.00 4499.33
E-46
-------
Westerly Treatment Plant
Northeast Ohio Regional Sewer District
Cleveland, OH
Assume Pretreatment
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
HCF-HGD: 0.000020
Aluminum Forming
Avg flow In
Company (HGD) Compliance
(mg/l)
Arrow 0.007 1
Hi Star 0.001 1
Typical Raw Wastes (Kg/year)
CO
0
0.00
0.00
CR
0
0.00
o.op
CU
0.132
1.36
0.10
PB
0.237
2.44
0.19
HG
0
0.00
0.00
Potential Improvement
Company
Arrow
Hi Star
Total Poll Removed(kg/yr)
Printing and Publishing
Avg flow In
Company (HGD) Compliance
(mg/l)
HetroPres 0.009 1
Schaefer 0.001 1
CentralLi 0.001 1
AmerCol 0.021 1
AmerGreet 0.045 1
CO
0.00
0.00
0
CR
0.00
0.00
0
CU
0.00
0.00
0
PB
0.80
0.06
0.866436
HG
0.00
0.00
0
Typical Ran Wastes
CO
0
0.00
0.00
0.00
0.00
0.00
CR
109
1300.19
185.30
126.62
3218.04
6856.10
CU
4.6
54.87
7.82
5.34
135.81
289.34
PB
482
5749.46
819.40
559.92
14230.25
30317.80
Potential
Company
HetroPress
Schaefer
CentralLith
AmerCol
AmerGreet
CO
0.00
0.00
0.00
0.00
0.00
CR
1196.17
170.48
116.49
2960.60
6307.61
CU
12.62
1.80
1.23
31.24
66.55
PB
5519.48
786.62
537.53
13661.04
29105.09
HG
0
0.00
0.00
0.00
0.00
0.00
Improvement
HG
0.00
0.00
0.00
0.00
0.00
NI
0.028
0.29
0.02
(kg/year
NI
0.00
0.00
0
(Kg/year)
NI
0.074
0.88
0.13
0.09
2.18
4.65
(kg/year
NI
0.00
0.00
0.00
0.00
0.00
0
0
AG
0
.00
.00
ZN
1.897
19.51
1.50
CN
0
0.00
0.00
BEHP
8.014
82.42
6.36
reduction)
0
0
0
0
0
0
0
AG
.00
.00
0
AG
0
.00
.00
.00
.00
.00
ZN
6.24
0.48
6.724991
ZN
10.7
127.63
18.19
12.43
315.90
673.03
CN
0.00
0.00
0
CN
0.43
5.13
0.73
0.50
12.70
27.05
BEHP
0.00
0.00
0
BEHP
0
0.00
0.00
0.00
0.00
0.00
reduction)
0
0
0
0
0
AG
.00
.00
.00
.00
.00
ZN
122.53
17.46
11.93
303.26
646.11
CN
0.00
0.00
0.00
0.00
0.00
BEHP
0.00
0.00
0.00
0.00
0.00
Total Poll Removed
0 10751.35 113.4317 49609.75
0 1101.295
E-47
-------
Westerly Treatment Plant
Hortheast Ohio Regional Sewer District
Cleveland, OH
Assume Pretreatment
Paint Formulating
Company data supplied in rag/I. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
HCF-HGD: 0.000020
Avg flow In
Cccpany (HGO) Compliance CO
0.524
Cook 0.1021 1 73.98
Schilling 0.0001 1 0.07
Ccapany CO
Cook 73.98
Schilling 0.07
Total Poll RemovedCKg/yr) 74.05517
Textiles
Avg flow In
Cwrpany (HGD) Compliance CO
0«/l> 0
Lion 0.0115 1 o.OO
Company CO
Total Poll Rea»ved(Kg/yr) 0.00
Organic Chemical*
Avg flow In
Ccapany (HGO) Compliance CO
(tag/I) 0
Hortheast 0.0018 1 0.00
Typical Raw Wastes (Kg/year)
CR CU PB HG NI
3.12 2.476 6.3 5.161 1.35
440.50 349.57 889.47 728.66 190.60
0.44 0.35 0.89 0.73 0.19
Potential Improvement (kg/year
CR CU PB HG NI
440.50 349.57 889.47 728.66 190.60
0.44 0.35 0.89 0.73 0.19
440.9392 349.9248 890.358 729.3869 190.791
===========33========== =========3====3===3S
Typical Raw Wastes (Kg/year)
CR CU PB HG NI
C.787 0.656 000
12.55 10.46 0.00 0.00 0.00
Potential Improvement (kg/year
CR CU PB HG NI
5.02 4.19 0.00 0.00 0.00
==3=«=3=================3==3==3*==.3I==33 ==«=
Typical Raw Wastes (Kg/year)
CR CU PB HG NI
0.228 4.78 1.95 0 0.339
0.57 11.92 4.86 0.00 0.85
AG ZN CM
0.015 74.746 0.079
2.12 10553.01 11.15
0.00 10.59 0.01
reduction)
AG ZN CN
2.12 10553.01 11.15
0.00 10.59 0.01
2.1199 10563.60 11.16480
==========================
AG ZN CN
0 0.999 0.071
0.00 15.94 1.13
reduction)
AG ZN CN
0.00 6.21 1.13
====«=============3===3=
AG ZN CN
0 1.36 0
0.00 3.39 0.00
BEHP
0.418
59.02
0.06
BEHP
59.02
0.06
59.07454
=========
BEHP
0.21
3.35
BEHP
3.18
BEHP
1.27
3.17
E-48
-------
Westerly Treatment Plant
Northeast Ohio Regional Sewer District
Cleveland, OH
Assume Pretreatment
Company data supplied in mg/l. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
HCF-MGD: 0.000020
Potential Improvement (kg/year reduction)
Company
Total Poll
Removed( Kg/yr)
CD
0.00
Plastics Holding and Forming
CR
CU
0.00 0.00
Avg flow In
Company
(mg/l)
.Robin'
Cosmo
(HGO) Compliance
0.0062 1
0.0036 1
CD
0
0.00
0.00
CR
0
0.00
0.00
cu
0
0.00
0.00
PB
0.00
Typical Raw
PB
0
0.00
0.00
HG
0.00
Wastes
HG
0
0.00
0.00
NI
0.00
(Kg/year)
NI
0
0.00
0.00
Potential Improvement (kg/year
Company
Robin
Cosmo
Total Poll
Industrial
Removed(ICg/yr)
Laundries
Avg flow In
Company
(mg/l)
Morgan
Rentus
West End 0.
Glove 0.
West SideO.
Merchant sO.
(HGD) Compliance
0.0305 1
0.0007 1
041047 1
010349 1
008074 1
034182 1
CD
0.00
0.00
CR
0.00
0.00
cu
0.00
0.00
PB
0.00
0.00
HG
0.00
0.00
00000
Typical Raw Wastes
CO
0.059
2.49
0.06
3.35
0.84
0.66
2.79
CR
0.56
23.61
0.57
31.78
8.01
6.25
26.47
cu
1.67
70.41
1.70
94.78
23.89
18.64
78.92
PB
5.1
215.02
5.20
289.43
72.97
56.93
241.03
HG
0
0.00
0.00
0.00
0.00
0.00
0.00
HI
0.00
0.00
0
(Kg/year)
NI
0.18
7.59
0.18
10.22
2.58
2.01
8.51
AG
0.00
AG
0
0.00
0.00
ZN
0.00
ZN
0.598
5.13
2.95
CN
0.00
CN
0
0.00
0.00
BEHP
0.00
BEHP
0.098
0.84
0.48
reduction)
AG
0.00
0.00
0
AG
0
0.00
0.00
0.00
0.00
. 0.00
0.00
ZN
3.18
1.83
5.01
ZN
3.2
134.91
3.26
181.61
45.79
35.72
151.23
CN
0.00
0.00
0.00
CM
0.13
5.48
0.13
7.38
1.86
1.45
6.14
BEHP
0.76
0.43
1.19
BEHP
0.65
27.40
0.66
36.89
9.30
7.26
30.72
E-49
-------
Westerly Treatment Plant
Northeast Ohio Regional Sewer District
Cleveland, OH
Assume Pretreatment
Company data supplied in ing/1. Converted
to Kg/yr based on avg flow and a units
factor: 1382.575
HCF-KGO: 0.000020
Company
CO
CR
Potential Improvement (kg/year reduction)
CU PB HG NI AG
ZM
BEHP
Morgan
Rentus
West End
Glove
Uest Side
Merchants
Total Poll RetnovedCKg/yr)
Car Wash Subcattjory
Avg flow In
Company (MGD) Compliance
(mg/l)
Standard 0.0009' 1
Uest Ohio 0.0007' 1
0.42
0.01
0.57
0.14
0.11
0.47
1.73
CO
0.043
0.05
0.04
20.54
0.50
27.65
6.97
5.44
23.03
84.12
CR
0.099
0.12
0.09
54.21
1.31
72.98
13.40
14.35
60.77
210.72
5.10
283.64
71.51
55.79
236.21
222.03 862.97
Typical Raw
CU
0.54
0.67
0.50
PB
2
2.49
1.87
0.00
0.00
0.00
0.00
0.00
0.00
0.00
Wastes
HG
0
0.00
0.00
Potential Improvement
Company
Standard
Uest Ohio
Total Poll Ren»ved
-------