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6. PLACEMENT OF SEWAGE SLUDGE IN A MUNICIPAL SOLID WASTE LANDFILL UNIT
Statement of Regulation
§258.21(a) Except as provided in paragraph (b) of this section, the owners or operators of all )V1SWLF
units must cover disposed solid waste with six inches of earthen material at the end of each
... ._.,„, operating day, or at more^freinient intervals if necessary, Jo control disease jr&t VvCiv*-> , \ \-* $ v
§2S8.21(c) The Director of an approved State may grant a temporary waiver from the requirement of
paragraph (a) and (b) of this section If the owner or operator demonstrates that there are
extreme seasonal climatic conditions that make meeting such requirements impractical.
6.2.2 PART 258 CRITERIA FOR LANDFILL UNIT
Part 258 establishes minimum national criteria for the location, operation, design, cleanup, and closure
of MSWLFs. If a MSWLF fails to satisfy these criteria, it will be deemed to be in violation of section
4005 of RCRA. Sections 309 and 405(e) of the CWA will also be violated in this situation.
The specific siting, operating, and design requirements for a MSWLF unit are contained in Part 258
Subpart B (Location Restrictions), Subpart C (Operating Criteria), Subpart D (Design Criteria), Subpart
E (Ground-Water Monitoring and Corrective Action), Subpart F (Closure and Post-Closure Care), and
Subpart G (Financial Assurance Criteria). (MSWLFs that dispose of less than 20 tons of municipal solid
waste daily are exempt from Subparts D and E under specific circumstances).
These requirements pertain to the MSWLF and/or the owner and operator of the MSWLF. Part 503 does
not impose these requirements on the generator or preparer of sewage sludge. However, § 503.4 makes
the preparer responsible for ensuring that the sewage sludge is disposed in a MSWLF that meets the Part
258 criteria. Thus, a permit writer can require the preparer to dispose of sewage sludge only at
MSWLFs that have been approved (as designated by a license or permit to operate) by the permitting
authority.
6.3 FREQUENCY OF MONITORING, RECORDKEEPING, AND
REPORTING REQUIREMENTS
Part 503 does not establish frequency of monitoring, recordkeeping or reporting requirements for sewage
sludge that is placed in a MSWLF. Part 258 pertains to the MSWLF and the 'owner/operator of the
MSWLF, and does not establish monitoring, recordkeeping, or reporting requirements for the user of the
MSWLF.
Under Part 258, the owner/operator of the MSWLF is not required to sample and analyze the sewage
sludge for hazardous characteristics (e.g., the toxicity characteristic leaching procedure [TCLP] test) or
free liquids (Paint Filter Liquids Test).
"The establishment of frequency of monitoring, recordkeeping, and reporting requirements for preparers
of sewage sludge disposed in a MSWLF will require the use of best professional judgment (BPJ) and a
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___ 6. PLACEMENT ,OF SEWAGE SLUDGE IN A MUNICIPAL SOLID WASTE LANDFILL UNIT
rationale for these requirements in the fact sheet. Several EPA Regions and States require the preparer
of sewage sludge to periodically (e.g., once a year) analyze the sewage sludge using the TCLP test to
confirm that it is nonhazardous. A requirement to perform a TCLP and free liquids test and report the
results is,the only reliable way to ensure that these requirements are met. In general, permitting
authorities that do not impose a TCLP monitoring condition have accepted published studies or in-house
.historical data that indicate sewage sludge is nDTdrazardoirs.
Vector attraction reduction treatment processes (such as lime addition and extended air drying) can
produce a sewage sludge that contains no free liquids.
Some EPA Regions and States request that the preparer report the amount and destination of sewage
sludge that is sent to a MSWLF. This reporting helps the permitting authority establish a sewage sludge
inventory.
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7. INCINERATION - PART 503 SUBPART E
QUICK REFERENCE INDEX
INTRODUCTION '
SPECIAL DEFINITIONS
GENERAL REQUIREMENTS - -
POLLUTANT LIMITS
SITE-SPECIFIC LIMITS
LEAD
ARSENIC, CADMIUM, CHROMIUM, AND NICKEL
BERYLLIUM .
MERCURY -
MANAGEMENT PRACTICES
TOTAL HYDROCARBONS MONITOR
OXYGEN MONITOR
( MOISTURE CONTENT ' . ......
COMBUSTION TEMPERATURE '
AIR POLLUTION CONTROL DEVICE OPERATING PARAMETERS
ENDANGERED SPECIES ACT ' '
OPERATIONAL STANDARDS -
TOTAL HYDROCARBON (THC) - ;
CARBON MONOXIDE (CO) - .
>•
FREQUENCY OF MONITORING REQUIREMENTS
SEWAGE SLUDGE
STACK GAS
INCINERATOR AND AIR POLLUTION CONTROL DEVICE
RECORDKEEPING REQUIREMENTS
INCINERATOR INFORMATION
DISPERSION MODELING
STACK GAS DATA
SEWAGE SLUDGE MONITORING INFORMATION
REPORTING REQUIREMENTS
SCENARIOS FOR THE INCINERATION STANDARD
SCENARIO 1 - FIRING OF SEWAGE SLUDGE IN A SEWAGE SLUDGE INCINERATOR
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7.6
7.7
7.8
7.9
7.10
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7.1 INTRODUCTION
This chapter provides guidance on the implementation of the Part 503, Subpart E regulations for
incineration of sewage sludge. Each section ,states and discusses, the corresponding Subpart E
requirements. The permit writer must decide if the sludge to be fired in the incinerator meets the
definition of sewage sludge as provided in Part 503, Subpart A. The definitions of sewage .sludge and
material derived from sewage sludge are included in Chapter 2 of this manual.
Next, the permit writer should examine pollutant concentrations in the sewage sludge to verify that the
concentration of PCBs in the sewage sludge is less than 50 milligrams per kilogram of total solids (oil
a dry weight basis), and that the sewage sludge does not meet any of the characteristics Of a hazardous
waste as identified in Part 261, Subpart C (i.e., ignitable, corrosive, reactive, and toxic).
The permit writer must then determine whether the incinerator is regulated under Part 503. Sewage
sludge mixed with other materials such as grit or screenings at the treatment works where the sewage
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7. INCINERATION - PART 503 SUBPART E
sludge is generated is still considered to be sewage sludge. Sewage sludge whose quality is changed by
either treatment or mixing with other material after the sewage sludge leaves the treatment works where
it was generated is a material derived from sewage sludge. In this case, Part 503 applies if the material
derived from sewage sludge is fired in an incinerator. Material fed separately to an incinerator in which
sewage sludge or a material derived from sewage sludge is fired is auxiliary fuel. Part 503 also applies
when sewage sludge and auxiliary fuel are fired together. .
The permit writer should examine the information provided by the person who fires sewage sludge
concerning the types and quantities of auxiliary fuel fired in the incinerator. Municipal solid wastes can
be used as auxiliary fuel to fire sewage sludge in a sewage sludge incinerator as long as the quantity of
the municipal solid waste is no more than 30 percent of the dry weight of the sewage sludge and auxiliary
fuel together For example, if 10 metric tons (dry weight) of sewage sludge and auxiliary fuel are fed
to the incinerator per day, the quantity of municipal solid waste that can be used as auxiliary fuel must
not exceed 3 metric tons (dry weight) per day. The use of additional auxiliary fuels such as fuel oil may
allow a total of more than 3 tons/day of total auxiliary fuel! Co-incineration of sewage sludge with more
than 30 percent municipal solid waste may be subject to the requirements of Part 60, Subparts C, E,
and/or O.
Emissions of arsenic, cadmium, chromium, lead, and nickel into the atmosphere during the operation of
a sewage sludge incinerator are regulated by limiting the concentration of these pollutants in the sewage
sludge fired in the sewage sludge incinerator. The emissions of organic compounds from a sewage sludge
incinerator are regulated by limiting the concentration of total hydrocarbons (THC) (dry weight basis and
corrected for oxygen content) in the exhaust gas from the sewage sludge incinerator. In addition, Part
503 requires that the firing of sewage sludge in a sewage sludge incinerator not violate the National
Emission Standards for Hazardous Air Pollutants (NESHAPs) for beryllium and mercury in Subparts C
and E, respectively, of Part 61.
On February 25, 1994, Part 503 was amended to allow TWTDS to monitor carbon monoxide (CO)
instead of THC if they meet the following conditions. The exit gas from a sewage sludge incinerator
must be monitored continuously and the monthly average concentration of CO, corrected for zero percent
moisture and to seven percent,oxygen, must not exceed 100 parts per million on,a volumetric basis.
Sewage sludge incinerators also may be subject to the Clean Air Act (CAA) requirements of the Standards
of Performance for Sewage Treatment Plants'in Subpart 0 of Part 60. It is important to remember that
these CAA regulations have separate applicability requirements (and separate permitting authority) from
those of Part 503. Therefore, a sewage sludge incinerator that is subject to the Part 503, Subpart E
requirements may not necessarily be subject to the Part 60, Subpart O regulations.
The permit to the person who fires sewage sludge in a sewage sludge incinerator should contain all of
the Part 503 Subpart E requirements. If the sewage sludge incinerator receives sewage sludge from
various sources, the person who fires the sewage sludge may have difficulty controlling the quality.
Nevertheless, the person who fires the sewage sludge must meet the Part 503 requirements.
While Subpart E mainly addresses requirements for the actual firing of sewage sludge, any person who
prepares sewage sludge is required to ensure that the applicable requirements of Subpart E are met when
the sewage sludge is fired (§503.7). Thus, a treatment works that sends sewage sludge to an incinerator
that it does not own or operate should be issued a permit. The permit should require the treatment works
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7. INCINERATION - PART 503 SUBPART E
to ensure that the sewage sludge is sent to an incinerator that is in compliance with the Subpart E
requirements.
7.2 SPECIALDEFINITIONS
Section 503.9 contains general definitions applicable to Part 503. In addition, terms and definitions
specifically applicable to the incineration of sewage sludge are set out in §503.41. This portion of the
guidance manual elaborates on each of the §503.41 definitions.
Air Pollution Control Device
Statement of Reulation
§S03.41(a)
Air pollution control device is one or more processes used to treat the exit gas from a sewage
sludge incinerator
Although the. Part 503 regulation does not require either the use or specific types of air pollution control
devices, in most cases they are needed for a sewage sludge incinerator to comply with the Part 503
requirements. Typically, air pollution control devices used with sewage sludge incinerators control
emissions of particulate matter (including metals) and organic compounds. Cyclones, wet scrubbers, dry
and wet electrostatic precipitators, and fabric filters control particulates. Afterburners provide more
complete combustion of organic compounds (EPA 1992a). Air pollution control devices are frequently
arranged in series to provide better removal efficiencies of different pollutants from incinerator emission
gases.
Auxiliary Fuel
Statement of Regulation
,Auxaiary fuel is fuel used to augment the fuel value of sewage sludge, This includes, &ut is not
limited to* natural gas, fuel oil, coal, gas generated during anaerobic digestion of sewage sludge,
and municipal solid waste (not to exceed 30 percent of the dry weight of sewage sludge and
auxiliary fuel together)* Hazardous wastes are not auxiliary fuel,
The heating value of sewage sludge is relatively high and the combustion of sewage sludge can be self
sustaining if sewage sludge is both high in volatile solids content and low in moisture content (i.e., less
than 70 percent). However, the high water content of most sewage sludges requires additional heat to
sustain combustion of sewage sludge in the furnace. This additional heat is generated by burning
auxiliary fuel in the combustion chamber. Auxiliary fuel is any fuel (or combination of different fuels)
that can be used to maintain combustion in the furnace. Some examples of auxiliary fuels are provided
in the regulatory definition of auxiliary fuel. 'Many other materials such as wood or waste oils are also
auxiliary fuels. Hazardous wastes are specifically excluded from the regulatory definition of auxiliary
fuel. Municipal solid waste can be used as the auxiliary fuel if the municipal solid waste constitutes no
more than 30 percent of the dry weight of sewage sludge and auxiliary fuel together. If 30 percent or
more of the material fired in an incinerator is municipal solid waste, the incinerator is not subject to the
Part 503 regulation. ,
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7. INCINERATION - PART 503 SUBPART E
Control Efficiency
Statement of Regulation
§503.41(c) Control efficiency is the mass of a pofiutattt in the sewage sludge ted to an incinerator minus the
mass of that poUutarit fa the esat gas from the inefaerator stack divided &y the mass of the
pollutant in the sewage sludge fed to the incinerator. " , ___
Control efficiency must be determined from a performance test of the sewage sludge incinerator.
Performance tests should be conducted under representative conditions at the highest expected sewage
sludge feed rate within design specifications. Operations during periods of startup, shutdown, and
malfunction do not constitute representative conditions.
During the performance test, the amount of the sewage sludge charged to the incinerator must be
determined accurately. Samples of sewage sludge must be collected and analyzed to determine the
pollutant content of the sewage sludge. Samples must be collected from the sewage sludge charged to
the incinerator at the beginning of each test run and at a minimum of 30-minute intervals thereafter until
the test run ends. The sewage sludge samples collected during each test run should be combined into a
single composite sample. A minimum of three composite samples, representing three test runs, should
be collected and analyzed to determine the pollutants and the mass of each pollutant that is fed to the
incinerator. A representative measurement of pollutant emissions and total volumetric flow rate of the
exit gas must also be obtained to determine the mass of each pollutant that exits from the incinerator
stack. Normally, an appropriate sampling location where the exit gas stream is flowing in a known
direction is selected, and the cross-section of the stack is divided into a number of equal areas. Exit gas
is then collected from points located within each of these equal areas and analyzed for pollutants of
interest. During a performance test, stack sampling is typically conducted at least 3 times, with a
sampling period of one to four hours each. If more than one sewage sludge incinerator is located at a
site, the control efficiency of each incinerator must be determined, unless they are identical in design and
operation. The pollutant limits for each incinerator must be calculated using only the control efficiency
determined for that incinerator (EPA 1989). If two or more identical sewage sludge incinerators are
located at a site, a performance test can be run on one unit and used to determine the control efficiency
for the all the identical units.
The permit writer should review performance test records to determine the conditions of the performance
test and the appropriateness of the methods used. The protocol entitled "Methodology for the
Determination of Metal Emissions hi Exhaust Gases from Hazardous Waste Incineration and Similar
Combustion Processes" in Appendix 9 of Part 266 should be used when control efficiency determinations
are to be made.
Dispersion Factor
Statement of Regulation ™, ,,
§S03.41(d) Dispersion factor te the ratio of the increase in the ground level ambient air concentration for
a pollutant at or beyond the property line of the site where the sewage sludge incinerator is
located to the mass emission rate for the pollutant from the incinerator stack.
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The/dispersion factor is used in equations presented in Part 503 to calculate the sewage sludge pollutant
limits for metals. The dispersion factor is determined by using an appropriate air dispersion model. A
dispersion model, is a detailed air dispersion analysis. The model predicts the downwind ambient air
concentration at a specified distance from the stack for a given set of site-specific meteorological
conditions, stack height, and stack gas emission rates. Once the relationship between stack gas emission
rates and the ambient ground-level concentration of a pollutant is established, through use of a dispersion
model, the dispersion factor can be calculated. For example, if the model predicts that at a specified
mass emission rate, the ground-level ambient air concentration will increase from X to Z, the dispersion
factor can be calculated using the equation:
where: DF = dispersion factor
X = ground-level ambient air concentration without mass emission
rate
Y . = mass emission rate from stack gas of sewage sludge incineratqr
Z = ground-level ambient air concentration with mass emission rate
ofY
The units of measurement used for the dispersion factor in Part 503 are micrograms per cubic meter per
gram per second.
Fluidized Bed Incinerator
Statement of Regulation , , -
|50?.41(e) Fluidized bed incinerator is an enclosed device ,in which organic matter and inorganic matter in
sewage sludge are combusted in a bed of particles suspended ia the combustion chamber gas.
A fluidized bed incinerator is a unique combustion device in which air, sewage sludge, and inert solid
particles (sand) are mixed so that the mixture behaves as a fluid. Fluidizing sewage sludge during
combustion provides excellent mixing of combustion air with the sewage sludge and sand particles. The
turbulent mixing action provides intimate contact between the sewage sludge, combustion air, and the hot
sand particles, resulting in improved heat transfer capabilities, lower excess air and auxiliary fuel
requirements, and lower sewage sludge residence tunes compared to other types of sewage sludge
incinerators. The improved mixing capability of fluidized bed incinerators also provides some protection
against fluctuations in sewage sludge feed rate and moisture content.
Hourly Average
Statement gif Regulation <
§5(&<4i(f) Hourly average Is the arithmetic meat* of all measurements taken during a hoar* At least two
' measurements must be taken during the hour. __
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7. INCINERATION - PART 503 SUBPART E
The hourly average concentration of total hydrocarbons must be calculated to derive the monthly average
concentration for total hydrocarbons. For example, if the THC instrument is operated to collect and
analyze the exit gas every 15 seconds, then 240 measurements would be made in one hour. The
individual values would be summed and then divided by 240 to obtain the hourly average.
Incineration \
Statement of Regulation ^ -,
§503.41(g) Incineration js the combustion of organic matter and inorganic matter in sewage sludge by high
temperatures In an enclosed device. ' s
Although sewage sludges contain large amounts of water, the dry solids in the sewage sludges are largely
organic and, on a dry basis, very combustible. For the purposes of this regulation, combustion is the
thermal oxidation of sewage sludge at relatively high temperatures resulting in ash, water, and carbon
dioxide as primary end products. The oxygen required for combustion is normally furnished from
ambient air (approximately 21 percent oxygen by volume). The exhaust gases from sewage sludge
incinerators are a mixture predominantly composed of nitrogen, carbon dioxide, water vapor, and oxygen.
Depending on the composition of the incinerated sewage sludge, the auxiliary fuel that is fired, and the
design and operation of the incinerator and any air pollution control device, small quantities of sulfur
dioxide, nitrogen oxides, carbon monoxide, organic compounds, and particulate matter may also be
present. The particulate matter will, in part, consist of various trace metals in the form of oxides,
carbonates, silicates, and/or as elemental metals. Some metals, particularly mercury, will volatilize
'during incineration and will be emitted from the incinerator largely in gaseous form. A wide variety of
organic compounds may exist in incinerator exhaust gases. These organic compound emissions may
result from the incomplete combustion of sewage sludge and/or auxiliary fuel. In some cases, these
products of incomplete combustion can recombine to form larger organic compounds as they are emitted
from the incinerator. Other components of sewage sludge, mostly inorganic materials, will be discharged
from the incinerator as a bottom ash.
Monthly Average
Statement of Regulation , ' ' ,V,<,;-., i
" • ff - y --\- * ^ ->-r.^/,j"-^'""::- - ••'••' 'V"
§503.41(h) Monthly average is the arithmetic mean of the hourly averages for the hours a sewage sludge
incinerator operates during the month. - "'"" ".'......^.
The total hydrocarbons operational standard and carbon monoxide limit of 100 parts per million are
expressed as a monthly average concentration. The monthly average concentration is determined by
dividing the sum of all hourly averages (see definition of hourly average) obtained during a month by the
hours the sewage sludge incinerator operated during that month.
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7. INCINERATION - PART 503 SUBPART E
Risk Specific Concentration
Statement of Regulation
§503,41{i) Risk Specific Concentration is the allowable increase in the average daily ground level ambient
air concentration for a pollutant from the incineration of sewage sludge at or Beyond the
property line of the site where the sewage sludge incinerator is located.
The Risk Specific Concentrations (RSCs) are used in the equation provided in §503.43(d)(l) to calculate
the pollutant limits for arsenic, cadmium, chromium, and nickel. The RSCs were derived by EPA during
a risk-based assessment during which a risk level of 1 chance in 10,000, a body weight of 70 kg, and
an inhalation rate of 20 mVday were used. RSC values are provided in §503.43 for arsenic, cadmium,
nickel, and chromium. Part 503 allows the RSC value for chromium to be determined in one of two
ways. The chromium RSC value can be selected from four RSC values listed in the regulation depending
on the type of sewage sludge incinerator and air pollution control device, or the RSC value for chromium
can be calculated using Equation (6) of the regulation.
Sewage Sludge Feed Rate v
Statement of Regulation
§5(&.41(j) Sewaae sludge feed rate is either the average daily amount of sewage sludge fired in all sewage
sludge incinerators within the property line of the site where the sewage sludge incinerators are
located for the number of days in a 363 day period that each sewage sludge incinerator operates,
or the average dally design capacity for all sewage sludge incinerators within thfe property line
of the site where the sewage sludge incinerators are located.
The sewage sludge feed rate can play a crucial role in optimizing the operation of the sewage sludge
incinerator. In general, the sewage sludge feed rate is kept constant as a rapid change in the amount of
sewage sludge fed to the incinerator can cause drastic changes in furnace operation. Sewage sludge feed
rate.changes can affect the quantity and temperature of the incinerator off-gases and therefore may
decrease the efficiency of air pollution control devices (EPA 1992a).
The sewage sludge feed rate is used to establish the allowable daily concentration of the metal pollutants
in sewage sludge to be incinerated. The average daily amount of sewage sludge that is actually fired in
the sewage sludge incinerator or the average daily design, capacity of the sludge incinerator can be used
as the sewage sludge feed rate. The actual average daily amount is determined by dividing the total
amount of sewage sludge fired in a 365-day period by the number of days the sewage sludge incinerator
operated in that same 365-day period. A treatment works may contain more than one sewage sludge
incinerator within me property lines of the treatment works. The operating capacities and schedules of
the individual incinerators may vary considerably. The following is an example of a multi-unit
calculation for sewage sludge feed rate:
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A site has three incinerators with the following design capacities.
Unit 1: 100 dry metric tons per day (dmt/day)
Unit 2: 100 dmt/day
Unit 3: 200 dmt/day
Part 503 allows the operator to choose one of two methods to calculate the sewage sludge feed rate, which is
used in the pollutant limit calculations:
Method 1—Design Capacity for All Incinerators
Calculate the total design capacity for all incinerators at the site: '
Total capacity = 100 dmt/day + 100 dmt/day + 200 dmt/day = 400 dmt/day
Method 2—Average Daily Feed Rate for AJII Incinerators
Case 1.
For the first 20 days of the year, unit 1 operated at 50 dmt/day (and shut down for the remaining 80
days); for the first 100 days of the year, unit 2 operated at 50 dmt/day and unit 3 operated at 100
dmt/day.
Calculate the total amount of sewage sludge fired in a 365-day period:
Unit 1: 50 dmt/day x 20 days = 1,000 dmt
Unit 2: 50 dmt/day X 100 days = 5,000 dmt .
Unit 3: 100 dmt/day x 100 days = 10,000 dmt
Total - 1,000 dmt + 5,000 dmt + 10,000 dmt = 16,000 dmt
Calculate the average daily amount of sewage sludge fired during the total number of days the
incinerators operated during a 365-day period:
Average = 16'000 dmt = 160 dmtfday (rounded).
100 days
Case 2.
If the incinerators in the above example did not operate at the same tune, but instead operated
sequentially, the average would be based on the total number of days any incinerator at the site was
operated, which is 220 days. In that case, the average daily feed rate would be:
16,000 dmt =
220 days
dmtlday(rounded).
For greater flexibility, the person who fires sewage sludge may want to consider using Method 1 to
calculate concentration limits for greater latitude in the amount of sewage sludge fed to the incinerator.
If the amount of sewage sludge fired in the incinerator significantly exceeds the amount fired during
the performance test, a new performance test should be conducted.
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7. INCINERATION - PART 503 SUBPART E
Sewage Sludge Incinerator
Statement of Regulation
Sewage sludge incinerator fe an enclosed device in whfch only sewage sludge and aiudliary fuel
are fired. ' , - '
The term "an enclosed device," used in the definition of sewage sludge incinerator, in general refers to
some type of furnace. The most common types of furnaces used for sewage sludge incineration are
multiple-hearth furnaces and fluidized-bed furnaces (EPA 1990c). Other less commonly used furnaces
include electric-infrared furnaces and rotary kilns. Sewage sludge drying and stabilization units are not
considered to be sewage sludge incinerators. • ...
Some incinerators are operated under conditions of starved-air combustion in a primary chamber,
followed by excess air combustion in a secondary chamber (sometimes referred to as an afterburner).
No Federal regulations specify which type of incinerator must be used to incinerate sewage sludge.
However, some States (e.g., Kansas and Rhode Island) or regional authorities may specify certain types
of incinerators for firing sewage sludge (EPA 1990b). References listed at the end of this chapter provide
more detailed information on the types and operation of sewage sludge incinerators.
Stack Height
Statement of Regulation
Stack height is &e difference between, the elevation of the top of a sewage sludge incinerator
stack and tire elevation of the ground at the base of the stack when, the difference is equal to or
less than 65 meters. When the difference is greater than
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7. INCINERATION - PART 503 SUBPART E
Numerous organic compounds'have the potential to be emitted from sewage sludge incinerators.
However, identifying and quantifying potential organic compound emissions from incinerators is
complicated and expensive. Identification and quantification of organics only can be done by analyzing
samples of incinerator exhaust gas obtained over discrete time periods.
EPA has determined that there is a significant, correlation between the concentration of several organic
compounds in sewage sludge incinerator exhaust gases and the total hydrocarbons (THC) concentration
(as measured by a flame ionization detector) in the same gases. Because of this correlation and because
THC data can provide incinerator operators with information necessary to make relatively quick
adjustments to incinerator operating parameters, EPA uses a THC operational standard to regulate organic
compound emissions from sewage sludge incinerators (EPA 1992a).
Wet Electrostatic Precipitator
Statement of Regulation , " -s...
§S03.41(n) Wet electrostatic pfecipitator is an air pollution control device that uses both electrical forces
and water to remove pollutants in the exit gas from a sewage sludge incinerator siacfc,
. wet electrostatic precipitator is a variation of the more widely used dry electrostatic precipitator.
rimarily, wet electrostatic precipitators are designed to remove particulate matter (including metals) from
A
Primarily, .
exhaust gases. Because wet electrostatic precipitators use water, some absorption of gaseous pollutants
can also occur. The use of water also makes the wet electrostatic precipitators more compatible for use
with wet scrubbers.
In wet electrostatic precipitator operation, water sprays are used to condition the incoming gas stream.
The water sprays cool the gas stream, help maintain more uniform particle size, and ease the application
of electrical charge to particulate matter. After particles are charged, they migrate to the charged surfaces
of collection plates. Collected particulate matter is removed from the plates by continuous flushing with
water.
5
Wet Scrubber
Statement of Regulation
§503.41(0) Wet scrubber is an air_ pollution control device, that uses Water to remove'poflutenfe m the
exit gas from a sewage sludge incinerator stack. , ' , /m-ll
i1 - ' . '•• ,
Wet scrubbers exist in numerous forms, ranging from relatively simple spray chambers and wet cyclones
to more complex and more efficient plate and tray and venturi scrubbers. Regardless of whether the
scrubber is used to control gaseous pollutants or particulate matter, the removal efficiency of the scrubber
depends largely on the scrubber's pressure drop during operation. Generally, the higher the operating
pressure drop of the scrubber, the higher the pollutant removal efficiency.
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7.3 GENERAL REQUIREMENTS
Statement of Regulation
§503.42
No person shall fire sewage sludge in a sewage sludge incinerator except in compliance with the
to this subpart. - , ' ' , V
The general requirement of § 503.42 enhances the direct enforceability of the requirements of Siibpart E.
The compliance period, established in §503.2, required compliance to be achieved as expeditiously as
practicable, but no later than February 19, 1994. If the person who fires sewage sludge must construct
new pollution control facilities to comply with the rule, compliance was to be achieved no later than
February 19, 1995. However, as noted below, these dates were suspended for THC pending specification
of certain requirements. The permit writer should ensure that construction of new pollution control
facilities is indeed necessary for compliance purposes (construction should not be used in lieu of other
management practices).
Frequency of monitoring, recordkeeping, and reporting requirements were effective on July 20, 1993.
Part 503 states that the compliance date for these requirements for total hydrocarbons in the exit gas from
a sewage sludge incinerator is February 19, 1994, or February 19, 1995 if construction of new pollution
control facilities is necessary to comply with the operational standard for total hydrocarbons. Section
503.45(a) requires monitoring of THC emissions using ah instrument that is installed, calibrated,
operated, and maintained "as specified by the permitting authority.".
On February 17, 1994, a memo was distributed that states that there is no compliance date for the THC
monitoring requirement until the above requirements are specified. The amendments to Part 503
proposed on October 25, 1995, address this issue. Compliance with the incineration requirements that
are revised in this proposal will be required no later than 90 days from the publication of the final
amendments. If new pollution control facilities must be constructed, compliance is required no later than
12 months from publication. Until these amendments are finalized, there are no enforceable requirements
for THC monitoring unless included in a permit with a compliance date. Permit writers can use the EPA
document THC Continuous Emission Monitoring. Guidance for Part 503 Sewage Sludge Incinerators to
help them prepare permits containing THC monitoring requirements.
7.4 POLLUTANT LIMITS
Subpart E of Part 503 regulates five pollutants in sewage sludge fired in a sewage sludge incinerator:
lead, arsenic, cadmium, chromium, and nickel. Part 503 contains equations for calculating pollutant
limits for these five metals based on site-specific conditions. This section provides procedures on how
to calculate the pollutant limits for the five metals using equations and site-specific factors. Emissions
of beryllium and mercury are regulated by the National Emission Standards for these pollutants in Subpart
C and Subpart E of Part 61, respectively. Total hydrocarbons emissions are limited by an operational
standard discussed in Section 7.5. .
Since publication of Part 503, EPA has realized that the pollutant concentration limits, determined as
prescribed in §503.43, are frequently considerably higher than the actual concentration of metals in the
sewage sludge being incinerated. This indicates that the incinerator operating conditions and site
conditions will permit safe incineration of sewage sludge with high pollutant concentrations. Given the
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7. INCINERATION - PART 503 SUBPART E
resulting ample margin of safety between the regulatory values and the actual concentrations of metals
in incinerated sewage sludge, EPA proposed to amend the applicability section of the incineration subpart
in the October 1995 amendments (60 FR 54771). Under the proposed approach, if the permitting
authority approves, the sewage sludge does not have to be monitored for a particular pollutant and records
of the concentration of a pollutant in sewage sludge do not have to be kept if the calculated pollutant limit
exceeds the highest average daily concentration for that pollutant in the sewage sludge for the months of
operation in the previous calendar year. EPA will consider all comments on this proposed change when
deciding if it should be adopted in the final amendments.
7.4.1 SITE-SPECIFIC LIMITS
The development of pollutant limits for a sewage sludge incinerator requires the use of site-specific
information supplied by the person who fires sewage sludge in a sewage sludge incinerator. Before
calculating the limits for the five metals, site-specific factors used in the Part 503 equations have to be
obtained. These site-specific factors should be reviewed by the permitting authority. They include the
dispersion factor, control efficiency, stack height, and sewage sludge feed rate. Each of these factors is
discussed in more detail below.
The determination of the appropriate values for these factors requires knowledge of air dispersion
modeling, emissions testing, and the design and operation of the incinerator. The permit writer should
work with EPA's Air Program to evaluate the, information supplied.
Dispersion Factor
I>i$pejrsi0n 'Factojo-cottelates^ emission tate
for a pollutant with the resulting increase ia ,
' atableot ground level pollutant coaceotratiotts in
<-t, t^*,*" » <- t'fffJ «_. ' , . •> , f '"""' " ' -
the air around the incinerator
' Dispersion Baciof » increase in ambient ground-
level pollutant concentration (#g/m3) divided by
emission rate (g/sec)
The dispersion factor is determined through the
use of air dispersion models. Air dispersion
models range from simple screening techniques to
more sophisticated models. Screening techniques
are relatively inexpensive and do not require a
great deal of modeling expertise, computer time,
or input data. However, screening techniques are
conservative in their design and tend to predict
higher ambient pollutant concentrations than do
more complex models. The use of screening
techniques to determine a dispersion factor is
acceptable; however, both the permit writer and the permit applicant should recognize and accept that the
calculated sewage sludge pollutant limits will be lower (more stringent) than those derived from more
refined dispersion models. For this reason, the person who fires sewage sludge may choose to perform
more detailed and refined dispersion modeling.
A knowledgeable air quality modeler with adequate computer resources and meteorological and source
parameter data for model input is needed to perform a detailed air dispersion modeling "analysis. For
refined modeling, three air dispersion models are most commonly used (see box below). Selection of
the appropriate model depends mainly on two factors:
• Terrain Type—A simple terrain model is used if all terrain hi the surrounding area is below the
facility's lowest stack elevation; a complex terrain model is used if terrain elevations exist above
the lowest stack elevation
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7. INCINERATION - PART 503 SUBPART E
Urban/Rural Classification—Urban plume dispersion coefficients are used if the incinerator is
located in an urban area; rural plume coefficients are used if the incinerator is located in a rural
area.
AIR DISPERSION MODEL
Industrial Source Complex Long-Term model a'b
(ISCLT)
LONGZ0 ,
COMPLEX Ic
WHEN USED
Simple terrain; both rural and urban areas
Complex urban terrain
i
Complex rural terrain '
Sources:
" Industrial Source Complex (ISC) Dispersion Model User's Guide -Second Edition
b Sludge Incineration Modeling (SIM) System User's Guide
c Guidelines on Air Quality Models (GAQM)
In addition,to terrain and land use classification considerations, source parameters, meteorological data,
receptor grids, and model control options need to be provided in most dispersion models. Two
parameters that are necessary to perform refined modeling are incinerator design and operation
considerations. A list of typical source parameters needed for dispersion modeling appears below.
Source Parameters for Input to the Air Dispersion/Models:
• Stack height above ground level
• Inside stack diameter
• Gas velocity at stack exit
• Gas flow rate
• Gas temperature at stack exit
• Stack-base elevation
• Building dimensions
• Stack coordinates (based on distance from grid origin)
• Emission rate
The meteorological data used in the dispersion model should be representative of the incinerator location.
The Guidelines on Air Quality Models state that, if possible, 1 year or more of on-site meteorological data
are preferred for use in the dispersion model. If such data are unavailable, 5 years of meteorological data
from the nearest or most representative National Weather Service station should be used. The data
needed vary depending on the specific model to be run but, in general, consist of hourly observations of
wind speed and direction, mixing heights, stability class, and atmospheric temperatures. Sources of
meteorological data are listed below.
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7. INCINERATION - PART 503 SUBPART E
Sources of Meteorological Data:
National Weather Service (NWS) .
Onsite meteorological measurement program
Federal Aviation Administration (FAA)
Local universities
Military stations
Pollution control agencies
National Climatic Data Center, Asheville, NC (NWS and military station data)
Support Center fof Regulatory Air Model's (SCRAM) Electronic Bulletin Board System
(BBS) (NWS)
Onsite Meteorological Program Guidance for Regulatory Modeling Applications, GAQM,
EPA 1987
Ambient Monitoring Guidelines for Prevention of Significant Deterioration (PSD), GAQM,
EPA 1987
Quality Assurance Handbook for Air Pollution Measurements Systems, Volume IV:
Meteorological Measurements, EPA 1983 - ;
Control Efficiency
As discussed earlier, sewage sludge incinerator control efficiencies for the five regulated metals must be
determined from a performance test. Control efficiency is crucial in that it indicates the extent to which
pollutants remain in the incinerator exhaust and, therefore, the potential ambient air impacts of emissions
from the incinerator.
Under Part 503, control efficiency determinations should include three elements:
• Sampling .and analysis of sewage sludge for the regulated metals
• Sampling and analysis of incinerator air emissions for the regulated metals
• Monitoring and documentation of incinerator and control equipment operating parameters during
sampling. Parameters of interest include sewage sludge feed rate, incinerator exhaust flowrate,
incinerator combustion temperature, auxiliary fuel type and feed rate, and specific air pollution
control device parameters.
Permitting authorities may refer to the following recommended procedures for guidance in reviewing
control efficiency test procedures:
. For Sewage Sludge Sampling and Analvsis-POZW Sludge Sampling and Analysis Guidance
Document.
. For Stack Sampling and Analysis for Metals-"Methodology for the Determination of Metal
Emissions in Exhaust Gases from Hazardous Waste Incineration and Similar Combustion
Processes," Appendix 9 of Part 266.
. For Stack Sampling and Analysis for Hexavalent Chromium-"Determination of Hexavalent
Chromium Emissions from Stationary Sources," Appendix 9 of Part 266.
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7. INCINERATION - PART 503 SUBPART E
The recording of operating parameters during any performance test is important because this information
establishes "baseline" operating conditions of the incinerator and its control equipment when control
efficiencies were determined. If, at a later, time, the monitored operating parameters change significantly
from the baseline levels established during the performance test, the control efficiencies for regulated
pollutants also may have changed. If this situation were to occur, another performance test may need
to be conducted to confirm control efficiencies for each regulated pollutant.
Permit writers- should carefully review any performance test results and reports that support control
efficiency determinations. The person who fires sewage sludge must submit a test protocol to.the
permitting authority for review before any testing is conducted. Please refer to Section 7.8,
Recordkeeping Requirements, for a more detailed discussion of performance test considerations.
In some instances, data may be available from a performance test conducted to meet the requirements of
Part 60, Subpart O. These data, although useful, may not accurately represent the pollutant control
efficiencies for the sewage sludge incinerator and may result in higher sewage sludge pollutant limits than
would be calculated using more accurate control efficiencies.
Stack Height
Stack height plays an important role in Part 503, Subpart E for calculating pollutant limits in sewage
sludge. Stack height is used in the dispersion model to derive the site-specific dispersion factor.
Stack height can generally be obtained from engineering and/or construction drawings or plans specific
to each sewage sludge incinerator. If these drawings are unavailable or do not indicate stack height, the
permit writer should request that the owner/operator measure or approximate the stack height using
methods approved by the permitting authority. One recommended method is the use of transit in land
surveying techniques to determine inclination angle and, ultimately, stack height.
To determine stack height for use in the air dispersion model, do the following:
A.
B.
If the actual stack height, measured from the ground-level elevation at the base of the stack,
is less than or equal to 65 meters, the actual stack height is used in the air dispersion model
to determine the dispersion.factor (DP). .
If the actual stack height, measured from the ground-level elevation at the base of the stack,
exceeds 65 meters, determine a creditable stack height based on good engineering practice
(GEP). The creditable stack height is the largest stack height determined using the following
guidelines (in accordance with §51.100 (ii) as referenced in Part 503):
(1) 65 meters, measured from the ground-level elevation at the base of the stack.
(2) For stacks in existence on January 12,, 1979, for which the owner/operator has obtained
all applicable permits or approvals required under 40, CFR Parts 51 and 52, the creditable
stack height should be calculated using the following equation:
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7. INCINERATION - PART 503 SUBPART E
Creditable Stack Height = 2.5 x H
Where:
H is the height of nearby structure(s) measured from the ground-level elevation at the
base of the stack.
For example, consider a sewage sludge incinerator that has been in existence since
January 1976 and has a stack that measures 66 meters from the ground-level elevation
at the base of the stack and where a structure measuring 30 meters high, 20 meters
wide and 50 meters long exist within 60 meters of the stack. Using the above
equation the "creditable stack height is calculated as:
Creditable Stack Height =*2.5 x 30 = 75 meters
(3) For all other stacks, the stack height should be calculated based on good engineering
practice using the following equation:
Hg = H + 1.5L
Where:
Hg = good engineering practice stack height, measured from the ground-level
elevation at the base of the stack.
H = height of nearby structure® measured from the ground-level elevation at
the base of the stack.
L = lesser dimension, height or projected width, of nearby structure(s).
In this part, "nearby" is defined as that distance up to five times the lesser of the height
or the width dimension of a structure, but not greater than 0.8 kilometers (1/2 mile).
Modeling or field studies can be used to determine effective stack heights, but these
should first be approved by the EPA, State or local control agency. Specific requirements
are identified in §51.100(ii)(3).
For example, consider a sewage sludge incinerator having a stack that measures 66 meters
from the ground-level elevation at the base of the stack and is located within 60 meters
of a structure measuring 30 meters high, 20 meters wideband 50 meters long. The GEP
stack height for this incinerator is calculated as:
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7. INCINERATION - PART 503 SUBPART E
Hg = 30 + 1.5 x 20 = 6Q meters
The creditable stack height for this incinerator is therefore 65 meters because this number
is larger than the GEP stack height.
Sewage Sludge Feed Rate
The sewage sludge feed rate is.used directly in the pollutant limit equations. Any changes in sewage
sludge feed rate will therefore cause a direct, proportional change in pollutant limits. In addition, as
mentioned earlier, sewage sludge incinerator operating parameters (including sewage sludge feed rate)
can influence pollutant control efficiencies. The specific control efficiency achieved by the sewage sludge
incinerator at one sewage sludge feed rate may not be achieved at a different sewage sludge feed rate.
In addition, changes in sewage sludge feed rate may not result in proportional changes in control
efficiency. Therefore, a significant change in sewage sludge feed rate necessitates a new performance
test to determine the control efficiency to be used to calculate sewage sludge pollutant limits. To avoid
these additional performance tests and future permit changes, it is important to conduct performance tests
and calculate sewage sludge pollutant limits using design capacity sewage sludge feed rates.
A variety of methods can be used to measure sewage sludge feed rate to a sewage sludge incinerator.
The most commonly used methods are conveyor weighing systems and volumetric methods. Conveyor
weighing systems rely on weight sensors (load cells) mounted beneath conveyor belts or screw augers to
measure sewage sludge feed rates. Volumetric methods rely on the measurement of rotational speed on
the sewage sludge feeding equipment, generally using a tachometer calibrated to a known feed rate, to
measure sewage sludge feed rates. Volumetric methods include calibrated augers, pumps, rotary feeders,
and belt conveyors (EPA 1992a). Other methods that have been used successfully include a liquid sewage
sludge volumetric mass balance method and a stoichiometric method.
7.4.2 LEAD
The Part 503 regulation controls the emission of lead into the atmosphere by limiting the allowable daily
concentration of lead in the sewage sludge fed to the incinerator. Part 503 includes an equation to
calculate a site-specific limit for lead.
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7. INCINERATION - PART 503 SUBPART E
Statement of Regulation
§S03.43(c) Pollutant limit - lead,
,""•'•' •>•"***.» sufrttiujMglf,^; " ' - , ' f
§S03,43(C)(i) Thfeaverage daily concentration pf leadinSewage sludge fed to a sewage sludge incinerator shaH
not exceed the concentration; calculated using Equation (4)*
0,1 X NAAQS X 86,400
* DF X (1 - CE) x SF
'•
- *
«= Average daily concentration of lead in sewage sludge in milligrams per kilogram of
total solids (dry weight basis) for the days in the month ttiat the sewage sludge
incinerator operates.
Where:
C
NAAQS >= National Ambient Air Quality {Standard for lead in microgranis per cubic meter.
,,,.., > ..<• - ~. v,;v - . , __ ^HVK-HJ is
DF - Dispersion factor m micrograms per cubic meter per gram per second.
OS = Sewage sludge incinerator control efficiency for lead" in' hundredths,
SF =s Sewage sludge feed rate in metric tons her day (dry weigh't basis)! ^
(2) The dispersion factor (DF> in ecfuatioa (4) shall oe'termked from*an"affSispWsiott model.
(i) When the sewage sludge stack height is 65 meters"or lessTlbe'acttiaf'sewage sludge'
HiCfaerator stack height shall be used in the air dispersion model to determine the dispersion
factor (DF} for ittuation (4), ^ , ^' ,'
JAJ#4fe**$!&
(ii) When the sewage sludge incinerator stack" height exSsedS 6$ me&rs> tie cVed^itable stack
height shall be determined to accordance with 40 CFE 51,100 (ii) and the creditable stack
heieht shall be used in the air dfapersion model to determine the dispersion factor (DF) for
a «, •• ^ „ v-, % — - « J -a
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7. INCINERATION - PART 503 SUBPART E
Step 3: Verify that the NAAQS for lead provided in the permit application is the current correct
number. This information is listed in 50.12. The current NAAQS for lead is 1.5>g/m3.
Step 4: From the information provided in the permit application, obtain the value for sewage sludge
feed rate (SF) in metric tons per day (dry weight basis). If this is not provided in the permit
application, request this value. The permit writer also should request and carefully review any
documentation of how the SF value was determined. Calculations of average sewage sludge
feed rates should be verified and compared with historical data and design capacity SF values
before being used to set permit limits.
Step 5: Incorporate all necessary variables determined in the previous steps into equation (4) to verify
the pollutant limit for lead.
7.4.3 ARSENIC, CADMIUM, CHROMIUM, AND NICKEL
Like lead emissions, Part 503 controls the emission of arsenic, cadmium, chromium, and nickel by
limiting the allowable daily concentration of these pollutants in the sewage sludge charged to the
incinerator.. Part 503,contains an equation to calculate the pollutant limits for the above pollutants.
Whereas the NAAQS was used in equation (4) for lead, equation (5), which is used for arsenic, cadmium,
chromium, and nickel, employs a risk specific concentration (RSC) factor that reflects the risk associated
with incineration of sewage sludge and release of these pollutant into the atmosphere.
Statement of Regulation
§503.43(d) Pollutant limit » arsenic, cadmium, chromium, and nickel.
f503.43(d)(l} The average daily concentration for arsenic, cadmium, chromium, and nickel-in sewage sludge
Fed to a sewage sludge incinerator each; shall not exceed the concentration calculated' using
Equation (5). * ,/ ."'**.
Where:
SSC X 86.400
DJF x <1 - CE) X SF
CE
= Average daily concentration of arsenic, cadmium, chromium, or nickel in sewage
sludge in milligrams per kilogram of total solids (dry weight basis) for the days m the
> month that the sewage sludge incinerator operates.
- Sewage sludge incinerator control efficiency for arsenic, cadmium, chromium, or nickel
in hundredfhs.
DF =. Dispersion factor in micrograms per cubic meter per gram per second.
RSC — Risk specific concentration in micrograms per cubic meter.
SF = Sewage sludge feed rate in metric tons per day {dry- weight basis)*
(2) The risk specific concentrations for arsenic* cadmium, and nickel used in equation (5) shall be
obtained from Table 1 of §503,43.
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7. INCINERATION - PART 503 SUBPART E
Statement of Regulation
TABLE 1 OF $03.43 • RISK SPECIFIC CONCENTRATION »
Pollutant
Arsenic
Cadmium
Nickel
!, CADMEUM, AND NICKEL
', «**•- "«'
Concentration
'vet 'cubic meter)'
0.057
'
(3) The risk specific Concentration for chromium used in equation (5) shall be obtained from Table
2 Of §503.43 or shall be calculated using equation (6).
TABLE 2 OF 503,43 - RISK SPECIFIC CONCENTRATION -
Type of Incinerator
Fluidlzed be'd with wet scrubber
Fluidized bed with wet scrubber
and wet electrostatic precipitator
Other types with wet scrubber
Other types with wet scrubber
and wet electrostatic precipitator
Where:
*\ ffifek Specific Concentration
(micrograms per cubic meter1)
0.23
- 0.0085
— ———
Eq. (6)
RSC = risk specific concentration for chromium in micrograms per cubic meter used in
equation (5). ' _
•, , 1,I1<1'1'S ' *
r >= decimal fraction of the hexavalent chromium concentration in the to'tal chromium
concentration measured in the exit gas from the sewage sludge incinerator stack in
hundredths.
(4) The dispersion factor (DF) in equation (5) shall be determined from an air dispersion model,
, •> f ' ^ ^ "[ !^
(i) \Vhen the sewage sludge incinerator stack height is equal to or less than 65 meters, the
actual sewage sludge incinerator stack height shall be used in the air dispersion model to
determine the dispersion factor (DF) for Equation (5).
v%£X -X s-. f f / V •*
(ii) When the sewage sludge incinerator stack height is greater than 65 meters, the creditable
stack height shall be determined in accordance with 40 CFR 51.100 (ii) and the creditable
stack height shall be used in the air dispersion model to determine the dispersion factor
(DF) for equation (5), i "-•"-"
/ / I « 11 % :• -,
(5) The control efficiency (CE) in equation (5) shall be determined from a performance test of the
sewage sludge incinerator, ,, , , , „ „ „ «.<..>...'! '.*.l
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7. INCINERATION - PART 503 SUBPART E
The permitting authority can use the following five step procedure to determine the appropriate values
for the variables in equation (5) and calculate the allowable daily concentrations of arsenic, cadmium,
chromium, and nickel in sewage sludge charged into the sewage sludge incinerator.
Step 1: The DP used in this equation is the same numerical value used in equation (4) to calculate the
pollutant limit fpr lead. Refer to Section 7.4.2 for instructions on how to obtain the value of
the dispersion factor.
Step 2: Ensure that numerical values for CE for arsenic, cadmium, chromium, and nickel are based
on results of a performance test(s) conducted in accordance with Part 503. If the values are
not available or have been obtained using inappropriate performance test methods, request that
a performance test protocol be prepared and submitted for approval. Review the protocol and
make any necessary changes to it. After approval of the protocol, review the performance test
report and the values for control efficiency.
Step 3: The risk specific concentrations (RSC) for the pollutants arsenic, cadmium, and nickel are as
follows: '
RSC(arsenic) = 0.023
RSC(cadmium) = 0.057
RSC(nickel) = 2.0
The RSC for chromium should be obtained using either of the following two methods:
; f •'
A. Determine the type of incinerator and the air pollution control devices installed. The
numerical value of RSC for chromium for each type of incinerator and air pollution
control devices is as follows:
If incinerator is fluidized bed with wet scrubber, RSC(chromium) = 0.65
If incinerator is fluidized bed with wet scrubber and wet electrostatic precipitator,
RSC(chromium) = 0.23 /xg/m3 ,
If incinerator is another type with wet scrubber, RSC(chromium) = 0.064 /*g/m3
If incinerator is another type with wet scrubber and wet electrostatic precipitator,
RSC(chromium) = 0.016 /ig/m3
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7. INCINERATION - PART 503 SUBPART E
B. The following equation can also be used to calculate the RSC for chromium:
RSC(chromium) = °-0085
Where:
RSC = risk specific concentration for chromium in micrograms per cubic meter (also
see the definition provided for RSC hi Section 7.2).
r = decimal fraction of the hexavalent chromium concentration in the total chromium
concentration measured in the exit gas from the sewage sludge incinerator stack in
hundredths. Please note that a specific stack test method for the determination of
hexavalent chromium hi stack gases should be used. The permit writer should use
best professional judgment to determine the acceptable number of samples for
identifying the hexavalent chromium concentration.
The RSC for chromium can easily be determined by substituting the value of the variable
r in this equation. . ,
For example, if 15 percent of the total chromium concentration measured in the exit gas
of a sewage sludge incinerator requested by April 6, 1973, and is hexavalent chromium,
the decimal fraction of the hexavalent chromium would be 0.15 and the value for RSC is
calculated as:
RSC(chromium) =
= 0.057
If the permittee uses Method B, the permit writer should compare the RSC for chromium
with those in Table 2 of §503.43 to ensure that the calculated value is reasonable.
Step 4: From the information provided, obtain the value for sewage sludge feed rate (SF) in metric tons
per day (dry weight basis). This is the same value used to calculate the pollutant limit for lead.
Step 5: Incorporate all necessary variables determined in the previous steps into equation (5) to verify
the pollutant limits for arsenic, cadmium, chromium, and nickel.
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7. INCINERATION - PART 503 STJBPART E
7.4.4 BERYLLIUM
Statement of Regulation . ,
"" i
§503.43 (a) Firing of sewage sludge tit a sewage sludge incinerator shall not violate the requirements in the
. National Emission Standard for Beryllium in subpart C of 40 CFR Part 61.
§6l.32{a) Emissions to the atmosphere from stationary sources Subject to the provisions of this subpart
shall not exceed 10 grams of beryllium over a 24-hour period, except as provided in paragraph
(b) of this section.
§(>1.32{b) • Rather than meet the requirement of paragraph (a) of this section, an owner or operator may
request approval from the Administrator to meet an ambient concentration limit on beryllium
in the vicinity of the stationary source of 0.01 flg/m3, averaged over a 3ft-tlay period.
Beryllium emissions from a sewage sludge incinerator are regulated by the National Emission Standards •
for Hazardous Air Pollutants (NESHAPs) in Subpart C of Part 61. Part 503 requires that the NESHAP
for beryllium be met when sewage sludge is fired in a sewage sludge incinerator. The NESHAP for
beryllium is applicable to sewage sludge incinerators that process beryllium-containing waste. If a sewage
sludge incinerator demonstrates that it does not burn any beryllium-containing waste, it is in compliance
with §503.43(a). If a sewage sludge incinerator does burn beryllium-containing waste, the emission of
beryllium can be regulated in one of two ways:
• In the exit gas from the sewage sludge incinerator stack
• In the ambient air around the incinerator.
The conditions placed in the permit will depend '
on the method chosen by the applicant to
demonstrate compliance with the beryllium
requirements.
The NESHAP for beryllium that applies to all
sewage sludge incinerators covered under Part
503 is 10 grams of beryllium over a 24-hour
period. This standard applies to all regulated
incinerators, except when the owner/operator of
a sewage sludge incinerator requested by April 6,
1973, and has been granted a written approval
from the Administrator to meet an ambient
concentration limit for beryllium in the vicinity of
the sewage sludge incinerator of 0.01 jug/m3.
averaged over a 30-day period. The first limit
stated above requires that, when sewage sludge is
fired in a sewage sludge incinerator, the total
quantity of beryllium emitted must not exceed 10
grams during any 24-hour period. This limit is
for each site (e.g., if three incinerators are on
site, the total quantity of beryllium that is emitted
from all incinerators must not exceed 10 grams per
The NESHAP for beryllium in Subpart C of Part'61
includes a provision that allows an. owner or
operator to request approval from the Administrator
to meet an ambient concentration limit on beryllium
to the vicinity of the stationary, source of OvOt
/tg/m* (averaged over a 30-day period) to replace
the limit of 10 grams .of beryllium over a 24-hour
period* , Because &e deadline for seektag such
request was April 6, 1973, a sewage sludge
incinerator covered .under the Part 503 role can only
, be subject to this alternative ambient concentration
limit if the owner/operator of the incinerator, has
already been 'granted a. written approval to comply
with this provision,
•y f -v
The teim "in the vicinity of the stationary source"'
refers to the distance from the sewage sludge
incinerator stack to the point of maximum impact or
concentration of the beryllium * emissions, as
determined by use of a proper air dispersion model.
24-hour period). The alternative limit requires that
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7. INCINERATION - PART 503 SUBPART E
the ambient concentration of beryllium in the proximity of the sewage sludge incinerator not exceed 0.01
ftg/m3 when averaged over any 30-day period. The radius of the area that is considered within proximity
or vicinity of the plant is generally described in the written approval from the Administrator for this
alternative limit. "
The permit writer can utilize the following two step procedure to determine and incorporate the
appropriate emission standard for beryllium:
Step 1: From the information provided, determine whether a written approval has been granted to the
owner/operator by the Administrator to meet the alternative ambient concentration limit of 0.01
/tg/m3, averaged over a 30-day period in the vicinity of the incinerator facility. If written
approval was granted, first obtain a copy of the original written approval, then include this
alternative limit in the permit. If written approval was not granted, go to Step 2.
Step 2: If there is not a written approval from the Administrator granting the alternative ambient
concentration limit, incorporate the NESHAP of 10 grams of beryllium over a 24-hour period
into the permit.
7.4.5 MERCURY
Statement of Regulation
§503.43(b) Firing of sewage sludge In a sewage sludge incinerator shall not violate the requirements ia the
National Emission Standard for Mercury in subpart B of 40 CFR Fart fa*
§6L52(b) Emissions to the atmosphere from sludge incineration 'plants, sludge drying plants, or &
combination of these that process wastewater treatment plant sludge shaBnot exceed 3200 grams
of mercury per 24-hour period.
,».,*
The air emissions of mercury from a sewage sludge incinerator are regulated by the National Emission
Standards for Hazardous Air Pollutants (NESHAPs) in Subpart E of Part 61. Part 503 requires that the
NESHAP for mercury be met when sewage sludge is fired in a sewage sludge incinerator. The emission
of mercury can be regulated in one of two ways:
• In the exit gas from the sewage sludge incinerator stack
• In the sewage sludge fed to the incinerator.
The conditions placed in the permit will depend on the method chosen by the applicant to demonstrate
compliance with the mercury requirements.
The NESHAP for mercury that applies to all sewage sludge incinerators covered under Part 503 is 3200
grams of mercury over a 24-hour period. This means the total quantity of mercury that is emitted into
the atmosphere from all incinerators at a given site must not exceed 3200 grams during any 24-hour
period (e.g., if three incinerators are on site, the three incinerators could emit a total of 3200 grams per
24-hour period). The permit writer can incorporate this pollutant limit requirement verbatim from the
regulations.
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7. INCINERATION - PART 503 SCBPART E
7.5 MANAGEMENT PRACTICES
Part 503 contains several management practices related to the firing of sewage sludge in a sewage sludge
incinerator. These management practices require that certain instruments be installed, calibrated,
operated, and maintained for each sewage sludge incinerator. ^They also require that requirements be
established for incinerator combustion temperature and air pollution control device operating parameters,
based on values obtained during performance testing. The following technical guidance provides a more
detailed discussion of the purpose and need of such instrumentation. These management practices apply
to all incinerators subject to Part 503.
7.5.1 TOTAL HYDROCARBONS MONITOR
Statement of Regulation - ^
<> s f
§50J.45(a)(l} An instrument that continuously measures and records the total hydrocarbons concentration in
the sewage sludge incinerator stack exit gas shall be installed, calibrated, operated, and
maintained- for «aeh sewage sludge incinerator. , ., , ,
(2> "the total hydrocarbons instrument shall employ a flame ionization detector; shall have a heated
, Sampling line maintained at a.temperature of ISO degrees Celsius or higher at all times; and shall
be calibrated at least once every 24-hoar operating period using propane.
Part 503 requires installation of an instrument that continuously measures and records the to'tal
hydrocarbons concentration in the sewage sludge incinerator stack exit gas, unless CO is continuously
monitored, as described in the February 25, 1994, amendments to Part 503. The THC instrument must
have a flame ionization detector and a heated sampling line that can maintain a temperature of 150°C or
higher at all times. The flame ionization detector (FID) measures hydrocarbon emissions in the stack of
an incinerator. The instrument reports the stack monitoring results as a concentration of hydrocarbons
(in parts per million of THC by volume). The FID is a hydrogen-oxygen flame into which a small
sample of incinerator exhaust gases is introduced. The flame burns any gases present in the sample.
The Part 503 regulation also requires that this instrument be calibrated at least once every 24-hour period
using propane gas. When carbon-carbon (C-C) or carbon-hydrogen (C^H) bonds are broken and oxidized
in the flame, an ion is released and an electrical detector senses the release of the ion. Thus, the number
of C-C and C-H bonds being oxidized in the flame can be measured directly by the strength of the
electrical signal produced. The direct readout of this electrical signal can be calibrated to indicate the
concentration of hydrocarbons in the sample stream. Calibration is achieved by periodically introducing
a series of calibration gases of known hydrocarbon concentration into the sample flame and marking or
adjusting the readout to the actual concentration of calibration gases. EPA has selected propane as the
reference gas for calibration of THC instruments. The Agency also believes that 24 hours is the
maximum amount of time that this type of instrument can maintain its accuracy without calibration.
In addition to daily calibration, other issues related to THC monitor installation and performance need
to be addressed. To ensure that the THC standard can be enforced continuously, the permit writer needs
to establish specific criteria for judging whether THC continuous emission monitoring (CEM) data are
accurate. Section 7.7 of this document presents a more detailed discussion of criteria for continuing
emission monitors. A permit writer, however, will need to specify these criteria and acceptable
mechanisms that operators can use to achieve them as permit conditions. Because of the potential
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7. INCINERATION - PART 503 SUBPART E
complexity in outlining CEM performance criteria and test procedures, the permit writer may want to
refer to EPA's guidance document called THC Continuous Emission Monitoring Guidance for Part 503
Sewage Sludge Incinerators (EPA 1994).
7.5.2 OXYGEN MONITOR
Statement of Regulation -• ,., _,/ »W:
* °"v s >
§S03.4S(b) An. instrument that continuously measures and records the oxygen concentration to the sewage
Sludge incinerator stack exit gas shall be Installed, calibrated, Operated, and maintained for each
• * * * . "" ^£""v fy '& x? t ^ "•
sewage sludge incinerator. < / s~?~ ^
Part 503 requires installation of an instrument that continuously measures and records the oxygen
concentration in the sewage sludge incinerator stack exit gas. As discussed in Section 7.5, this
management practice is needed to obtain information to correct the THC concentration to 7 percent
oxygen. ,
Oxygen monitors use one of several possible analytical techniques and sampling mechanisms to measure
oxygen concentrations. Oxygen monitors can be either in situ or extractive. In situ monitors are in direct
contact with the gas stream and measure the oxygen concentration at that specific location. Extractive
monitors use a sampling system that continuously withdraws gas samples from the gas stream and directs
it to an analyzer that may be up to several hundred feet away. Extractive systems are almost always
equipped with sample conditioning systems that remove dust and moisture from the gas stream. The most
important difference to note is that in situ monitors measure oxygen on a wet basis and extractive
monitors generally measure oxygen on a dry basis. This difference is important because an oxygen
concentration on a wet basis can differ significantly from one measured on a dry basis, depending on the
moisture content of the gas sample. Wet and dry oxygen CEM measurements also can be used to
calculate stack gas moisture content continuously.
Three types of analytical techniques are generally used with oxygen monitors. These techniques include
electrocatalytic, polarographic, and paramagnetic. Detailed descriptions of each type of analyzer can be
found in EPA's Handbook of Continuous Air Pollution Source Monitoring Systems (June 1979). As with
the THC CEM, permit writers need to specify performance criteria and test procedures to ensure accurate
data that can be used to enforce the THC operational standard. The permit writer can refer to the CEM
specification established in Appendix B of Part 60, Subpart O for continuous oxygen monitors for sewage
sludge incinerators.
7.5.3 MOISTURE CONTENT
Statement of Regulation , ,, /
§503.45(c) An instrument that continuously measures and records information used to determine the
moisture content in the sewage sludge incinerator stack exit gas shall be' installed, calibrated,
operated, and maintained for each sewage sludge incinerator.
Part 503 requires installation of an instrument that continuously measures and records information that
can be used to determine the moisture content in the sewage sludge incinerator stack exit gas. As
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7. INCINERATION - PART 503 SUBPART E
discussed in Section 7,5, this information is necessary to correct the THC concentration for 0 percent
moisture. As mentioned earlier, one method used to measure the moisture content of a stack gas sample
is to measure wet and dry oxygen concentrations simultaneously and calculate moisture content from the
differences in these measurements. Another method involves determining the moisture from a
psychometric chart based on the temperature and pressure at 100 percent saturation of wet scrubber
exhaust gases. If proprietary monitors that measure stack gas moisture content directly are available, they
can also be used. Because moisture content is essential to the calculation of THC, the instruments used
to measure moisture content need to meet performance specifications as described for THC and oxygen
monitors.
7.5.4 COMBUSTION TEMPERATURE
Statement of Regulation
§50&45{d) An instrument that continuously measures and records combustion temperatures shall be
installed, calibrated,, operated and maintained for each'sewage sludge Incinerator.
§503«4S(e) Operation of the sewage sludge incinerator shall not cause a significant exceedencfc of the
maximum combustiontemperatwre forthe sewagesludgemewerafor, Tbemaximwmwmbflstion
temperature for the sewagesiudge incinerator shaft be based on information obtained dur-Jtagthe
performance test of the sewage sludge incinerator to determine pollutant control efficiencies.
Part 503 requires the installation, maintenance, operation and calibration of a device that continuously
measures and records incinerator combustion temperatures. The regulation also requires that the
maximum combustion temperature be established for each incinerator based on information obtained
during the control efficiency performance test of the incinerator. The permit writer should consider the
performance test conditions when setting the maximum temperature. The maximum temperature should
be set at no more than 100-150°F higher than the maximum temperature recorded during the test. The
maximum temperature should be established as a 'daily average unless the permit writer believes a
different averaging period is more appropriate. Combustion temperature can affect both organic and
inorganic emissions. Low combustion temperatures can result in poor combustion of sewage sludge and
increased organic emission rates. High combustion temperatures ,can increase the volatilization of metals
in the sewage sludge being incinerated and the potential for higher metal emission rates. High
combustion temperatures can also result in high flue gas temperatures that could possibly damage air
pollution control devices. ^ • •. , , .
Because of the THC operational standard, a minimum combustion temperature is not needed. To achieve
the THC operational standard, the incinerator will have to be operated at a certain temperature. By
relating the combustion temperature limit to the temperature observed during performance testing, the
potential rate of metals volatilization is theoretically maintained at the same level achieved during the
performance test. This condition, therefore, limits the metals loading applied to the incinerator's air
pollution control device. .
Combustion temperatures are typically measured using thermocouples. They offer a relatively
inexpensive, reliable and accurate means of measuring fairly high temperatures. Thermocouples are
almost always enclosed ina'thermowell that protects the thermocouple from the hostile environment of
the incinerator combustion areas. Because of the potential for frequent damage, thermocouples are
located downstream of the combustion zone near the exit of the combustion chamber. Thermowells that
extend away from the incinerator wall improve the accuracy and response of the thermocouple, but are
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7. INCINERATION -. PART 503 SUBPART E
subject to slag buildup or abrasion (EPA 1990a). Periodic inspection and replacement of thermocouples
is recommended; periodic calibration of thermocouples that are in place is impractical. If possible, the
use of two thermocouples in separate wells is recommended to provide a cross-check pf the operation of
each thermocouple.
7.5.5 AIR POLLUTION CONTROL DEVICE OPERATING PARAMETERS
Statement of Regulation "' " v^'^-4*^*^1- ^ • - ^ r ^ ••
|S03,4S(0 Appropriate air pollution control devices shall be installed for the sewage sludg* incinerator.
Operating parameters for the air pollution control devices shall be selected that indicate
adequate performance of the device. The values for the operating parameters for the air
pollution control devices shall be based on information obtained: during the performance test of
the sewage sludge incinerator to determine pollutant control efficiencies. Operation of the
sewage sludge incinerator shall not cause a significant exceedence of the values for the Selected
operating parameters for the air pollution control device.
Part 503 requires the values for the operating parameters for an incinerator's air pollution control device
(APCD) be based on information obtained during the incinerator's performance test. By recording key
APCD operating parameters during control efficiency performance testing, one can establish baseline
values for these parameters at known control efficiencies. By operating the incinerator and its control
equipment at these baseline values in the future, the control efficiencies can be expected to remain
relatively unchanged from performance test values. Continuously monitoring these operating parameters
is theoretically an indirect means of monitoring pollutant control efficiencies.
As for the maximum temperature determination, it is important to know how the performance test
conditions relate to normal operating conditions. Permit limits should be set based on the manufacturer's
recommendations and the operating conditions during the performance test. To allow for operating
flexibility, the values for the APCD operating parameters should be a range around the values
demonstrated during the performance test.
Because each incinerator and APCD combination is site-specific, APCD operating parameter values also
will be site-specific. Table 7-1 presents several APCD operating parameters that can be indicators of
performance. Section 7.7 of this chapter discusses the establishment of incinerator and APCD operating
parameters in permit conditions in greater detail.
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7. INCINERATION - PART 503 SUBPART E
TABLE 7-1 PERFORMANCE INDICATOR PARAMETERS
FOR AIR POLLUTION CONTROL DEVICES
APCD
Parameters
Example Measuring Devices
Venturi scrubber
Pressure drop
Liquid flow rate
Gas temperature (inlet and/or outlet)
Gas flow rate '
Differential pressure (AP) gauge/
transmitter
Orifice plate with AP gauge/transmitter
Thermocouple/transmitter
Arinubar or induced (ID) fan
parameters
Impingement scrubber
Pressure drop
Liquid flow rate
Gas temperature (inlet and/or outlet)
Gas flow rate
AP gauge/transmitter
Orifice plate with AP gauge/transmitter
Thermocouple/transmitter
Annubar or ID fan parameters
Mist eliminator (types
include a wet cyclone, .
vane demister, chevron
demister, mesh pad, etc.)
Pressure drop
Liquid flow
Differential pressure gauge/transmitter
Orifice plate with AP gauge/transmitter
Dry scrubber (spray dryer
absorber)
Liquid/reagent flow rate to atomizer
pH of liquid/reagent to atomizer
For rotary atomizer: Atomizer mptor
power
For dual fluid flow: Compressed air
pressure -
Compressed airflow rate ,
Gas temperature (inlet and/or outlet)
Magnetic flowmeter
pH meter/transmitter
Wattmeter
Pressure gauge
Orifice plate with AP gauge/transmitter
Thermocouple/transmitter
Fabric filter
Pressure drop (for each compartment)
Broken bags
Opacity
Gas temperature (inlet and/or outlet)
Gas flow rate
AP gauges/transmitters
Proprietary monitors
Transmissometer
Thermocouple®
Annubar or ID fan parameters
Wet electrostatic
precipitator.
Secondary voltage (for each
transformer/rectifier)
Secondary currents (for each
transformer/rectifier)
Liquid floW(s) (for separate liquid
feeds)
Gas temperature (inlet and/or outlet)
Gas flow rate
Kilovolt meters/transmitter
Milliammeters/transmitter '
Orifice piate(s) with AP gauge/
transmitter
Thermocouple(s)
Annubar or ID fan parameters
Source: EPA 1990a
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7. INCINERATION - PART 503 SUBPART E
7.5.6 ENDANGERED SPECIES ACT
Statement of Regulation
§S03.4S(g) Sewage sludge shall not be fired in a sewage sludge incinerator if it is likely to adversely affect
a threatened or endangered species listed uri'der Section 4 of the Endangered Suedes Act or its
designated critical habitat. """ ""^ "' f t , " " < ^TrTx ' '
In addition to meeting the requirements of Subpart E of the Part 503 regulations, additional management
practices that would prevent likely adverse effects on threatened or endangered species or their critical
habitats may need to be developed on a site-specific basis. First, a determination should be made as to
whether there are any threatened or endangered species or their critical habitats present in the areas
affected by the air emissions from the sewage sludge incinerator. In general, this determination should
be done by the person who fires sewage sludge. Results of the air dispersion modeling will help in
delineating the area of impact.
This provision is not of concern if no threatened or endangered species or critical habitats are present.
However, the permit writer may want to include this provision in the permit as it appears in Part 503.
If threatened or endangered species or their designated critical habitats are present, the permit writer will
need to determine whether the firing of sewage sludge will be likely to cause an adverse effect upon the
species or their habitats. Again, this determination may need to be done by the person who fires sewage
sludge. An assessment of potential adverse impacts may be expensive and the causal link between the
air emissions from the sewage sludge incinerator and the degree of impact to the species or habitat may
be difficult to substantiate. The field office of the U.S. Department of Interior, Fish and Wildlife Service
(FWS) may have information on any studies of the area's threatened and endangered species or critical
habitats. If there is any available information indicating potential adverse impacts due to the firing of
sewage sludge, then a site-specific assessment may be needed. The permit writer should document in the
fact sheet the presence of threatened or endangered species or their critical habitats and any information
indicating adverse impacts. The permit writer should include a permit condition that incorporates the
management practice that firing of sewage sludge shall not cause adverse effects upon the species or
habitats present in the area.
If adverse effects are likely, the permit writer will need to follow EPA policies or use best professional
judgment in constructing site-specific management practices to prevent these likely adverse impacts. It
will be necessary for the permit writer to work with the owner/operator in identifying these specific
management practices.
7,6 OPERATIONAL STANDARDS
Subpart E does not contain numerical limits for specific toxic organic compounds in sewage sludge or
in the exit gases from sewage sludge incinerators. However, to protect human health and the
environment from organic pollutants when sewage sludge is incinerated, the regulation contains an
operational standard for total hydrocarbons (THC). This operational standard applies to all incinerators
subject to Part 503 except where CO is monitored in accordance with §503.40(c). The following
guidance provides the necessary information and direction to incorporate this operational standard into
the permit.
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7. INCINERATION - PART 503 SUBPART E
Statement of Regulation
The total hydrocarbons concentration in the exit gas from a sewage sludge incinerator shall be
corrected for zero percent moisture by multiplying the measured total hydrocarbons
concentration by the correction factor calculated using equation (7).
Correction factor (percent moisture)
Where?
§50J.44(b)
X — Decimal fraction of the percent moisture in the sewage sludge incinerator "exit gas in
' hnndredths, , ' • ,
The total hydrocarbons: concentration in the exit gas from a sewage sludge incinerator shall be
corr ectedjto seven percent oxygen by multiplying the measured total hydrocarbonsconeentration
by the correction factor calculated using Equation (8).
Correction factor (oxygen) - 3
. (8)
Where*
T — Percent oxygen concentration in the sewage sludge incinerator stack exit gas {dry
volume/dry volume},
The monthly average concentration for total hydrocarbons in the exit gas from a sewage sludge
incinerator stack, corrected for zero percent moisture using the correction factor from equation
f7) and to seven percent oxygen using the correction factor from equation (8), shall not exceed
100 parts per million on a volumetric basis when measured using the instrument required by
7.6.1 TOTAL HYDROCARBON (THC)
THC is a measure of the carbon-carbon (C-C) or carbon-hydrogen (C-H) bonds of the organic material
present in the exhaust gas of an incinerator. THC provides an indirect measurement of the total organic
'pollutants in the exit gases of an incinerator. Therefore, limiting the THC levels in the exhaust gas of
an incinerator provides an indirect control over the total quantities of organic pollutants released from
that incinerator. Part 503 contains an operational standard for THC in the stack emissions to ensure that
excessive amounts of organic pollutants are not released into the atmosphere. This requirement is a
.technology-based operational standard based on operating data from a study of four sewage sludge
incinerators (EPA 1992a).
The corrected THC level in the exhaust gases must not exceed a monthly average of 100 parts per million
on a volumetric basis. This operational standard requires that the THC concentration in the stack exit
gas be measured continuously and corrected to 7 percent oxygen (from 21 percent oxygen in air) and for
0 percent moisture using adequation provided in the regulation. The THC concentration is corrected to
7,percent oxygen to account for the excess air used in the combustion of sewage sludge.
Excess air refers to the amount of air that is present in the combustion chamber of the incinerator in
excess of the minimum amount required for the combustion process to take place. The presence of excess
air in the combustion chamber enhances the combustion process and provides a safety measure against
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7. INCINERATION - PART 503 SUBPART E
variations hi the system, such as changes in sewage sludge feed rate and sewage sludge moisture content,
that could lead to incomplete combustion of the organic matter. A sewage sludge incinerator operated
with very little excess air could easily exceed the operational standard of 100 ppm THC. On the other
hand, the THC concentration could be lowered without reducing the actual emission rate simply by
adding higher rates of air to the incinerator. High excess air rates "dilute" the THC concentration
detected by the flame ionization detector (FID). This could allow an incinerator to appear to be meeting
the THC standard, when the actual THC emissions are in excess of those set by the regulations taking
dilution into account (EPA 1989, 1992b). This is why the measured THC concentration has to be
corrected to seven percent oxygen.
The presence of moisture in the exit gas can dilute the THC measurement and create artificially low
readings. Because most sewage sludges contain substantial amounts of water, the exit gas contains
moisture and the THC must be cprrected for this moisture content. Conventionally, the THC is measured
in terms of dry-volumetric basis (0 percent moisture) and therefore correction for moisture is based on
0 percent moisture content. The THC concentration in the exit gas must be corrected for 0 percent
moisture by multiplying the measured THC concentration by the following correction factor:
Correction factor (percent moisture) = /^ _ ^
Where:
X = decimal fraction of the percent moisture in the exit gas in hundredths.
Further correction of the measured THC concentration to 7 percent oxygen must be performed by
multiplying the measured THC concentration by a dimensionless correction factor specified in the
regulation [§503.44(b)]. That correction factor is as follows:
Correction factor (oxygen) = /^x — y>
Where:
Y = percent oxygen concentration in the exit gas (dry volume/dry volume).
For example, if the measured THC is 30 ppm, the measured oxygen content is 9 percent, and the
measured moisture content is 30 percent, the THC value corrected to 7 percent oxygen and no moisture
is calculated as the following:
THC (dry, 7 percent oxygen) =
30 ppm x 14
(1 - .3) (21 - 9)
42.9 ppm x 1.1667
= 50 ppm . ,
The monthly average THC limit of 100 ppm is based on continuous measurements while sewage sludge
is being incinerated. Thus, the regulation requires installation of instruments for continuous monitoring
of THC, oxygen, and information needed to determine the moisture content in the exit gas of a sewage
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7. INCINERATION - PART 503 SUBPART E
sludge incinerator (detailed discussion of these continuous monitoring requirements are provided in
Section 7.6 of this chapter). . , ,
The permit should clarify that the THC operational standard is based on continuous measurement with
the specified instrumentation, oxygen concentration, and moisture content in the sewage sludge incinerator
stack exit gas (see Section 7.6 for the monitoring,instruments required). Furthermore, the permit writer
should include in the permit the specific equations that must be used to correct for excess air and moisture
content. The permit should also specify that the limit of 100 ppm must be on a volumetric basis and that
hourly averages of THC measurements after correction to 7 percent oxygen and for 0 percent moisture
should be recorded continuously. The raw monitoring data used to derive the values of corrected, dry
THC also should be collected, maintained, and made available to the permitting authority on request.
7.6.2 CARBON MONOXIDE (CO)
Statement of Regulation
§505>40(c) The management practice in §503«4£(a}, the frapency of monitoring requirement for tote! i
hydrocarbon concentration in §503.46(b) and the recordkeeping requirements for total |
hydrocarbon concentration in §503,47(c) and (w) do not apply if the following conditions are i
mefc , ' i
(1) The exit gas front a sewage sludge incinerator stack is monitored continuously for carbon i
monoxide. , ' i
(2) The monthly average concentration of carbon monoxide in the exit gas from a sewage sludge i
incinerator stack, corrected for izero percent mofetore and to seven percent oxygen, does not i
exceed 100 parts per million on a volumetric basis. . . i
(3) The person who tires sewage sludge in a sewage sludge incinerator retains the following " j
information for five years: i
' (i) The carbon monoxide concentrations in the exit gas; and . :
(ii) A calibration and maintenance log for the instrument used to measure the carbon monoxide
concentration. , „" - »* % i
f < •* :
(4) Class I sludge management faculties, POTWs (as defined m 40 CFR SOJU2) wth a design flow i
- rate equal to or greater than one million gallons per day, and POTWs that serve a population i
; of 10,000 people or greater submit the monthly average carbon monoxide concentrations in ;
the exit gas to the permitting authority oa February 19 of cash yean \
As mentioned earlier, on February 25, 1994, Part 503 was amended to allow carbon monoxide to be
monitored instead of THC if the following conditions are met. The exit gas from a sewage sludge
incinerator must be^monitored continuously and the monthly average concentration of CO, corrected for
zero percent moisture and to seven percent oxygen, must not exceed 100 parts per million on a
volumetric basis.
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7. INCINERATION - PART 503 SUBPART E
7.7 FREQUENCY OF MONITORING REQUIREMENTS
The monitoring requirements presented in §503.46 apply to sewage sludge fired in a sewage sludge
incinerator, to the exit gas from a sewage sludge incinerator while sewage sludge is being fired, and to
air pollution control device operating parameters.
7.7.1 SEWAGE SLUDGE
Statement of Regulation
§503.46(a) Sewage sludge , - "•,-<•. „ ' ', , "
V , ,, " ""'" , " ' '" x,
§S03.46(a)(l) The frequency of monitoring for beryllium shatt tieas required under subpart C of 40 CFK Part
W a»d for mercury a$ required undersuljpartE of 4¥CFR Part 61-
(2) The frequency of monitoring for arsenic, cadmium, chromium, lead, and ni<&el in sewage sludge
fed to a sewage sludge incinerator shall be the frequency to Table 1 of §503,46. ,
Part 61 requires only a one-time start-up stack sampling or, alternatively, continuous air sampling, for
beryllium. For mercury, Part 61 requires a one-time start-up stack or sludge sampling, with annual
monitoring for those sources for which mercury emissions exceed 1600 grams per 24-hour period, as
specified hi §§61.53-.55. Permit writers may want to require periodic monitoring to ensure that the
NESHAPs are being met. The preamble to the October 25, 1995, amendments to Part 503 (60 FR
54781) suggests various monitoring alternatives that may be appropriate for sewage sludge incinerators.
Section 503.46 requires that sewage sludge fired in a sewage sludge incinerator be monitored for arsenic,
cadmium, chromium, lead, and nickel at the frequencies presented in Table 1 of §503.46. The frequency
of monitoring for these pollutants depends on the amount of sewage sludge fired in an incinerator in a
365-day period.
TABIJS 1 OF 503-4fi « FBEQlS
Amount of Sewage Sludge*
•(metric tons per 365 day period)
Greater than zero but
less than 290
^
Equal to or greater than ,
290 but less than 1,500
*• -.
Equal to or greater than
1,500 but less than 15,000
Equal to or greater than
15,000
.,
* Amount of sewage sludge fired
S*, ™ v.v ' •" *• < /X '*%
$NCy OF MQJWTORfi'Kr » iNCINSRATIOIs
""'',„
Frequency
^/ ^ f '/ '/*/ * & tf*™ '-. w * / * ss,"
-, •• / once per year
fi f ff ••• f
, -! ~,^ ,™^vKv^*.r'
ortc4 per qpiarter
(4 times per year)
f j ^ i ^
,f r ' ,t W ^ s , ,
^ - once pef 60 days
'(6 tunes per year)
'';''^tJ,,™-,"\ ' > '
once per month
,;«. ', ' (12 times per year)
^f f /4^v^"^f^^fi' *' 1 * ^ ^ ** "Jvi i-&fJvA v s
in a sewage sludge incinerator (dry weight basis).
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7. INCINERATION - PART 503 SUBPART E
|503.46(a)(3} After the sewage sludge has been monitored for 2 years at the frequency in Table 1 of
§503.46, the permitting authority may reduce the frequency of monitoring for arsenic,
cadmium, chronw'um, lead, and nickel. ' " ••
The regulation allows the permitting authority to modify the frequency of monitoring after sewage sludge
has been monitored at the frequencies in Table 1 of §503.46 for 1 years. Some important factors that
a permit writer should consider in establishing permit conditions for sewage sludge monitoring
frequencies include: ,
History of compliance with the pollutant limits
Variability of pollutant concentrations in the sewage sludge
Trends in pollutant concentrations in the sewage sludge
, Magnitude of typical pollutant concentrations ,
Magnitude of the pollutant limits.
Permit writers also may wish to specify either by permit or by referencing appropriate guidance
documents how sewage sludge monitoring is to be conducted. Specifically:
• Sewage Sludge Sampling Methods—Discussions should include the entity responsible for
sampling; sample splitting; equipment to be used; sample techniques, locations/times, amounts,
and types (grab or composite); sample handling and preservation; sampling records to be kept;
and conditions when sampling should occur.
• Analytical Methods—Discussions should include the numbers of analyses, acceptable techniques,
quality assurance and quality control procedures, analytical records to be kept, and calculations
to be made.
Grab—A single grab sample can be a representative sample if every part of the sewage sludge has an
equal chance to be sampled and the sewage sludge is fairly homogenous in pollutants and solids content.
Because the sample collection point is fixed and cannot be randomly selected, the time at which a sample
is collected should be randomly chosen. For example, a number from 1 to 24 can be randomly selected
to determine the tune at which a grab sample should be collected from an incinerator sewage sludge feed
line during a 24-hour continuous operation period.
Composite—Another method of obtaining a representative sample is to collect single grab samples at
predetermined intervals during a continuous operation period and combine them into a single composite
sample. A composite sample is more representative of the sewage sludge than a single grab sample.
The frequency of monitoring in Table 1 of §503.46 assumes that sewage sludge is fired in a sewage
sludge incinerator throughout the 365 day period. The frequency of monitoring could be affected if the
sewage sludge is stored before it is fired in the incinerator. -
Two approaches that can be used when sewage sludge is stored before it is used or disposed to show
compliance with pollutant concentration limits are discussed in section 4.7.2. An important aspect of both
approaches is that representative samples of the sewage sludge must be collected and analyzed.
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7. INCINERATION - PART 503 SUBPART E
7.7.2 STACK GAS
Statement of Regulation
§S03.46(b)
Total hydrocarbons, oxygen concentration, information to determine moisture content, .and
combustion temperatures. ' ,
The total hydrocarbons concentration and oxygen concentration in the exit gas from a sewage
sludge incinerator stack, the information wsed io measure moisture content in the exit gas, and
the combustion temperatures for die sewage sludge incinerator shall be monitored continuously
unless otherwise specified fey the permitting authority»
Section 503.46 requires that the exit stack gas from a sewage sludge incinerator be monitored
continuously for total hydrocarbons, oxygen, and moisture concentrations unless otherwise specified by
the permitting authority. The primary purpose of the CEM is to provide data to verify an incinerator's
compliance with the operational standard of §503.44. To ensure that the monitoring data can be used
to show compliance with Part 503, the permit writer should address the folio whig important issues in each
permit. Guidance on addressing these issues is available in EPA's THC Continuous Emission Monitoring
Guidance for Part 503 Sewage Sludge Incinerators (EPA 1994).
• CEM quality assurance and quality control procedures should be required and the criteria used
to judge these procedures should be specified. Besides the daily calibration and maintenance
requirements of §503.45, quarterly calibration error checks of the CEMs are recommended.
Written calibration, testing, and maintenance procedures for CEMs should also be required from
incinerator operators.
• CEMs should be required to meet certain performance specifications. These performance
specifications should establish the criteria used to judge the acceptability of the CEMs at the time
of installation. Important elements of performance specifications include performance test
procedures, monitor range and resolution, calibration gas requirements, response time, and
conditioning and operational test period requirements.
• Data availability requirements should be required and defined. Is monitor downtime allowed for
monitor calibration, maintenance, and malfunctions? If so, how much and how frequently?
• Data reduction and averaging procedures and calculations should be detailed. .Specific procedures
for the calculation of THC exceedence incidents, for the percentage of THC exceedence tune and
for correction of total hydrocarbons for oxygen and moisture should be defined.
• Acceptable locations of CEM sample points and calibration gas injection points should be
specified. The chief consideration in CEM sample point location is that the measurement
obtained is representative of incinerator exit gases. The CEM sampling point should be located
such that the potential for gas stratification and air in-leakage are minimized and that manual
stack sampling and maintenance accessibility is provided. The quality and concentrations of
calibration gases also need to be specified.
• Criteria should be defined for judging the validity of CEM data and determining when corrective
actions need to be taken.
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If an incinerator monitors CO instead of THC, the permit writer should specify the CO CEM
requirements in the same manner as she would specify THC CEM requirements.
. , • - . . • •, ..•''../ • . .-..-.-
The Agency has, received requests for a variance from, the CEM requirement from incinerators that
operate infrequently. In the proposed amendments to Part 503 (60 PR 54771, October 1995), EPA
proposed to amend §503.46(b) to allow the permitting authority to specify an alternative to continuous
monitoring of the exit gas from a sewage sludge incinerator. EPA requested comments on whether small
incinerators should be allowed to monitor less than continuously, how the monitoring should be
performed, and how to decide which incinerators should be allowed to monitor less than continuously.
The Agency will consider all comments received on the proposed amendments when deciding if the
permitting authority should be able to exempt certain small incinerators from continuous THC or CO
monitoring. ; .
7.7.3 INCINERATOR AND AIR POLLUTION CONTROL DEVICE
Statement of Regulation.
§503.46(c) Air-pollution control device operating parameters.
j j . <• ' |>
• The frequency of monitoring for the sewage sludge incinerator air pollution control device
operating parameters shall be at least daily.
The requirements at §503.46 require the incinerator combustion temperature to be monitored
continuously. Air pollution control device operating parameters are to be mqnitored at least daily. The
values of these parameters should be consistent with the values pbserved during the performance test to
determine pollutant control efficiencies.
The regulations at Part 61, Subparts C and E do hot specify operating parameters to be monitored. They"
do require that no change in the operation be made which would potentially increase beryllium or
mercury emission rates above those estimated by the most recent stack test, until new emission rates are
calculated1 and the results are reported, to the Administrator, To satisfy this requirement, operating
parameters that impact beryllium and mercury emission rates should be established and monitored.
Part 503 provides flexibility in establishing permit conditions for incinerator and APCD operating
parameters. This flexibility is necessary so that appropriate conditions can be applied, based on
incinerator and APCD designs and operating procedures; it also burdens the permit writer with the
responsibility of identifying important operating parameters and establishing limits for them. When
writing permits, the permit writer should consider the following:
• Specific averaging times ensure enforceability
• Ranges allow for some operational flexibility.
• Pollutant limits must be tied to the values of the operating parameters observed during any
performance tests. It is important to understand that the conditions that exist during a
performance test can restrict the future operations of the incinerator and its APCD.
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7. INCINERATION - PART 503 SUBPART E
Some key parameters for which permit writers should consider establishing permit conditions include:
• Auxiliary fuel type and feed rates—in some cases, an increase in auxiliary fuel(s) feed rate may
increase pollutant emission rates. Permit writers should consider limiting the type(s) and feed
" rates of auxiliary fuels. .
• Incinerator combustion temperature—low combustion temperatures for even short time periods
can result in poor combustion efficiencies, and short-term increases in organic and odor-causing
emissions. Higher combustion temperatures can result in increased metals volatilization and
metals loading on the APCD. Because it may be difficult to reliably measure the combustion
zone temperature in many incinerators, another sampling location within or near the combustion
chamber can be used as an indicator of combustion zone temperature. The location should be
away from any quench water or air injection points.
• Temperature of flue gas entering the APCD—increased temperature at the inlet to the APCD
increases the volatility of metals that may be present. Metals that remain in the vapor form in
the APCD will be less efficiently captured.
• Venturi scrubber pressure drop—particulate and metals removals decrease with reduced pressure
drop.
• Fabric filter pressure drop—a low pressure drop can be indicative of torn or missing filters that
can lead to increased particulate and metals emissions. A high pressure drop can be indicative
of plugged or "blinded" filters that could potentially fail.
• Electrical power applied to an electrostatic precipitator or ionizing wet scrubber—reduced
electrical power or the number of fields in operation decreases the rate of particle charging thus
decreasing collection efficiencies. The unit of power applied and where the applied power is
measured also should be specified.
Permit writers should also remember that sewage sludge incinerators and their control equipment are
complex systems and that many of the parameters outlined earlier are related. Permit writers should be
aware of operating parameters and potential permit conditions that may conflict. Conflict also may occur
when parameters used to gauge compliance cannot be simultaneously operated at their worst-case
conditions. One example might be incinerator combustion temperature conditions established to maximize
organic destruction and to minimize metal volatilization. Permit writers should also be alert to parameter
limits that could violate permit conditions for reasons that may not be related to emissions. For example,
a low APCD pressure drop may result from reduced air flow rate or lower sewage sludge charging rates
and not from APCD problems.
7.8 RECORDKEEPING REQUIREMENTS
The permit should contain requirements for maintaining records that demonstrate compliance with the
operational standard, pollutant limits, and management practices. Specific records that must be
maintained by the person who fires sewage sludge in a sewage sludge incinerator are listed in §503.47.
In general, the recordkeeping requirements in §503.47 pertain to the monitoring requirements in
§503.46. The records are required to be developed and retained for at least 5 years by any person who
fires sewage sludge in a sewage sludge incinerator. These records will be largely based on other pieces
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7. INCINERATION - PART 503 SUBPART E
of information and documents such as air dispersion models, testing procedures, calculations, and
incinerator design and operating manuals. Without this documentation, the incinerator operator will not
be able to support reports made to.the permitting authority. Similarly, the permitting authority will not
have enough information to make complete evaluations of compliance or to judge the adequacy of the
information used to show compliance.
Because the Part 503 rule does not detail documentation requirements, the permit writer needs to be
specific enough so that the person who fires sewage sludge knows what is expected. Depending on the
specific requirement, the permit writer may require documentation to be submitted in the permit
application, during the review of the application, and after the permit has been issued (as an ongoing
permit condition). Some of the recordkeeping requirements in § 503.47 are very specific and some must
be developed by the permit writer based on site-specific conditions. This document provides general
recommendations for recordkeeping and documentation. The recordkeeping requirements and
recommended documentation to be discussed in this section has been divided into the following four
categories, each to be discussed individually in greater detail:
• Incinerator information
• Dispersion modeling
• Stack gas data
• Sewage sludge monitoring information.
7.8.1 INCINERATOR INFORMATION
Statement of Regulation , , , '
§5
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7. INCINERATION - PART 503 SUBPART E
Certain incinerator exhaust stack parameters also need to be determined arid documented so that a
dispersion factor can be obtained. Important stack parameters to document are:
• Stack height (the distance from ground level to the top of the stack discharge point)
• Stack diameter (if round) or stack opening length and width (if rectangular or square)
• Stack gas discharge velocity at or near the top' of the stack
• Stack gas discharge temperature at or near the top of the stack.
Because this information is unlikely to change very often, if at all, it would be appropriate for this general
information to be submitted as part of the permit application. The permit writer should include a permit •
condition requiring the notification of the permitting authority of any changes in the information submitted
in the application as soon as the person who fires the sewage sludge is aware of the change (preferably
before the change occurs).
7.8.2 DISPERSION MODELING
Statement of Regulation
§503.47(a)
§503.470)
§S03.47(k)
The person who fires sewage sludge in a sewage sludge incinerator shall develop the information
in §503,47{fa> through §503.47Cri) and shall retain that information Bff i«ve years.
The stack height for the sewage sludge incinerator,
The dispersion factor for the site where the sewage sludge incinerator is located*
Part 503 requires the use of a Dispersion Factor (DF) to calculate limits for lead, arsenic, cadmium,
chromium, and nickel in sewage sludge fed to a sewage sludge incinerator. Because the pollutants subject
to dispersion modeling requirements can be assumed to behave similarly (all act as particles and do not
undergo atmospheric reactions), one DF can be used to calculate pollutant limits for all five regulated
metals.
The increase in the ground level ambient air pollutant concentration at or beyond the property line can
be determined by using an air dispersion model. Models provide differing levels of sophistication and
suitability depending on the modeling application. Because of the variety of models available and the
potential complexities in their use, a modeling protocol should be reviewed by the permitting authority
prior to conducting any sophisticated dispersion modeling. A modeling protocol establishes procedures,
data requirements and acceptable assumptions. A protocol can help to avoid misunderstandings and the
need to conduct additional modeling runs.
The regulations do not specify acceptable methods of dispersion modeling to be applied to development
of a DF; methodologies acceptable to both the person who fires the sewage sludge and the permitting
authority should be developed on an individual basis. Many technical issues'need to be considered when
discussing the application of air dispersion models, such as:
• The mathematical algorithm of the model .
• Meteorological data requirements
• Averaging times for emission rates and predicted ambient air impacts
• Topographic and land use considerations.
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7. INCINERATION - PART 503 SUBPART E
• Receptor site locations
• Downwash "considerations.
The permit writer and incinerator operator may wish to refer to Guidelines on Air Quality Models
(Revised) and Screening Procedures for Estimating the Air Quality Impact of Stationary Sources, (both
published by EPA) for more detailed discussions on the application of dispersion models. The permit
writer and incinerator operator should also get help from personnel trainedvand experienced in dispersion
modeling whenever possible, to conduct and review dispersion modeling runs.
Regardless of the model chosen, the permit writer should require complete modeling documentation and
should thoroughly review this documentation after modeling is conducted. Sewage sludge incinerators
should be required to maintain the fpllowing documentation:
• Modeling protocols.
• Complete modeling reports that follow the approved protocols and include the model used, who
performed the modeling, all model input data, and the output of the model.
• The pollutant emission rates used.
• A scale diagram that shows the location of the incinerator stack(s), property lines, buildings and
other significant structures. The diagram should indicate building dimensions and distances
between buildings, property lines and the incinerator stack(s). >
• ! • - - ' , / . • • ' .
• A map of the area that shows its topography and land use.
• The value of the dispersion factor used to calculated pollutant limits and how it was calculated.
7.8.3 STACK GAS DATA
Statement of Regulation ,
§503,47(a) The person who fires sewage sludge fet a sewage sludge incinerator shall develop thfc information "
j» §50&47
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7. INCINERATION - PART 503 SUBPART E
Stack Test Data
The sewage sludge incinerator operator is required to conduct incinerator emissions stack testing by the
following regulations: . .
• Part 503, Subpart E—Determine control efficiencies for lead, arsenic, cadmium, chromium, and
nickel
• Part 61, Subpart C—Determine beryllium emission rate
• Part 61, Subpart E—Determine mercury emission rate.
Before discussing the specific documentation requirements of the testing outlined above, it may be helpful
to discuss some general stack testing documentation needs. As with dispersion modeling, a protocol must
be prepared for review by the permitting authority before any stack testing is performed. A stack test
protocol can prevent misunderstandings and the need for frustrating and costly re-tests. A stack test
protocol should establish approved sampling and analytical methods, sample point locations), and
incinerator and air pollution control device operating conditions. The final stack test report should follow
the established protocol and should explain deviations from agreed-upon procedures and operating
conditions. The test report should document the following:
• Sampling methods including the amount of sample, the duration of sampling, the number of
samples, tune and date of samples, person who conducted sampling, and sample point locations.
• Analytical methods including the number, time, date, and analyst for each analysis.
• Raw sampling and laboratory sheets.
• Calculation sheets.
• Quality assurance and quality control procedures such as sample train leak tests and sampling and
laboratory equipment calibrations and checks.
• Chain-of-custody sheets.
• Incinerator operating parameters during testing such as sewage sludge feed rate, auxiliary fuel
feed rate, oxygen concentrations, and incinerator temperatures. The,locations of oxygen and
temperature monitors should be specified.
• Applicable air pollution control device parameters during testing, such as stack gas opacity,
pressure drop across the pollution control device, scrubber liquid flow rates and solids
concentrations, stack gas flow rates, temperatures and pressures, and electrostatic precipitator
field power, voltage, and amperage being applied during testing.
Part 503, Subpart E requires that both the mass of a pollutant hi the sewage sludge fed to a incinerator
and the mass of that pollutant in the incinerator exhaust stack gas be determined in a performance test.
The mass of pollutants in the incinerator exhaust can be determined by stack testing and documented as
described in the earlier paragraph. The mass of pollutants in the sewage sludge fed to the incinerator can
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7. INCINERATION - PART 503 SUBPART E
be determined by sewage sludge sampling and analysis. Sewage sludge sampling should precede stack
sampling by the time it takes a metal molecule to move through the incinerator so that the same sludge
is compared at both ends. Sewage sludge sampling documentation that should be maintained from the
performance test includes: . ,
Sampling and analytical methods
Sample point(s)
Sample times, amounts, and frequencies
Sample compositing techniques
Raw sampling and laboratory sheets
Calculation sheets used in sampling and analysis •
Chain-of-custody sheets
Quality assurance and quality control data.
Part 61, Subpart C and Subpart E require initial performance testing to verify compliance with beryllium
and mercury emission standards. The documentation requirements,for stack gas and sewage sludge
sampling described earlier also would apply to these emission standards. Because both the beryllium and
mercury emission standards are expressed as grams emitted in a 24-hour period, documentation is needed
to show that incinerator operating conditions do not deviate from those conditions used to demonstrate
worst-case beryllium and mercury emissions in a 24-hour period. Subpart E also requires that
incinerators with mercury emissions greater than 1,600 grams per 24-hour period must monitor and
document mercury emissions by either stack testing or sewage sludge sampling and analysis annually.
Recommendations for stack gas sampling methods to be used are as follows:
• Beryllium—EPA Method 104 found in Part 61, Appendix B
• Mercury—EPA Method 101A found in Part 61. Appendix B
• Other metals-^-EPA protocol entitled "Methodology for the Determination of Metal Emissions
in Exhaust Gases from Hazardous Waste Incineration and Similar Combustion Processes."
Continuous Emissions Monitoring Data
Statement of Regulation
§S03.4?(e)
§503.47(f) ,
§503 -47 (h)
•§S03.47(ri)
The person who fire's sewage sludge fat a sewage sludge incinerator shall develop the information
in §503,47(6} through $503,47(n) and shall retain thai mformaflon for five years,
The total hydrocarbons concentration In die exit gast front the sewage sludge Incinerator stack,
The combustion temperatures, including the maximum combustion temperature, for the sewage
sludge incinerator.
The oxygen concentration and information used to measure moisture content in the exit gas from
the sewage sludge Incinerator stack. ' , '
A calibration and maintenance log for tht instruments used to measure: ths total hydrocarbons
concentration and oxygen concentration hi the exit gas from the sewage sludge incinerator stack,
the information needed to determine moisture content In the exit gas, and the combustion
temperatures,
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7. INCINERATION - PART 503 SUBPART E
Statement of Regulation
|S03,40
(c)
The management practice in §503*45(a), the frequency of monitoring requirement for total
hydrocarbon concentration to §503.4*>(b) and the recordkeepaig requirements for total
hydrocarbon concentration in §£03*47(c} and (n) do not apply if the following conditions are
met: - ' -
(J) The: exit gas from a sewage sludge incinerator stack is monitored continuously for carbon
monoxide. , ' " ' , t^' -
(2} The monthly average concentration of carbon monoxide in the exit gas from a
sewage sludge incinerator stack, corrected for zero percent moisture and to seven
percent oxygen} does not exceed 100 partesper million on a volumetric basis.
(3) The person who fires sewage sludge in a sewage sludge incinerator retains the following
information for five years:
(i) The carbon monoxide concentrations in the exit gas; and
(ii) A calibration and maintenance log for the instrument used to measure the carbon
monoxide concentration. _ * .
(4) Class I sludge management facilities,, POTWs (as defined in 40 CFR 501.2) with a design
flow rate equal to or greater than one million gallons per day, and POTWs that serve a
population of 10,000 people or greater submit the monthly average carbon monoxide
concentrations m (he exit gas to the permitting authority on February 1? of each year. -
The use of continuous emissions monitors at sewage sludge incinerators is required by Part 503, Subpart
E. This subpart requires the use, calibration, and maintenance of GEMs to determine total hydrocarbon,
oxygen, and moisture concentrations in the incinerator stack gases. A CEM for CO can be used as an
alternative to a CEM for THC.
As indicated earlier in Section 7.7, the Part 503 regulation does not specify CEM performance and
recordkeeping requirements. The CEM data issues identified in this section also need to be considered
and resolved before establishing recordkeeping requirements. Generic recommendations for CEM
documentation that should be maintained by the sewage sludge incinerator operator include:
• Daily calibration records, including a description of calibration procedures, the time and date of
each calibration, the calibration gas values, the GEM calibration results, any automatic calibration
correction factors used, and any corrective actions taken.
• Daily maintenance .records, including a description of any maintenance and corrective actions and
the amount of monitor downtime.
• Other records of quality assurance and quality control procedures, including quarterly calibration
error determinations.
• The criteria used to specify invalid CEM data. The operator should be required to document
what CEM data are excluded and why they were excluded from the calculation of the monthly
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7. INCINERATION - PART 503 SUBPART E
average for total hydrocarbons or for carbon monoxide. The operator should be required to
calculate monitor downtime on a monthly basis._ .
• , A description of data reduction and averaging procedures and calculations approved by the
permitting authority.
• The criteria used to specify when corrective actions must be taken and preventative maintenance
schedules and procedures.
• The locations of the CEM sample points, stack gas sample ports, and calibration gas injection
points. . x •.
• The initial certification plan and final test report for the CEM system.
As previously indicated, the permit writer may want to refer to EPA's THC Continuous Emission
Monitoring Guidance for Pan 503 Sewage Sludge Incinerators (EPA 1994).
The permit writer also may require calibration and maintenance records for sewage sludge feed monitors,
auxiliary fuel feed monitors, monitors for pressure drop across wet scrubbers, incinerator combustion
temperature monitors, and any monitors for other operating parameters specific to a particular incinerator
be kept. The permit writer may consider requiring that records of any deviations of operating parameter
values be kept.
7.8.4 SEWAGE SLUDGE MONITORING INFORMATION
Statement of Regulation
§503.47(a)„ The person who fires sewage stodge in a sewage sludge incinerator slrajl develop the information
ia §S03.470>) through $$03<47(n) and shall retain that information for 5 years*
J '~ '
§S03.47(b) The concentration of lead, arsenic, cadmium, chromium, and nickel in the sewagesludge fed to
the sewage sludge Incinerator, "
' •. h ^ •>
§503.47(1), The sewage sludge feed rate, ' •
Sewage sludge incinerator operators are required by Part 503, Subpart E to record the sewage sludge feed
rate for a sewage sludge incinerator and the concentrations of lead, arsenic, cadmium, chromium, and
nickel in the sewage sludge that is incinerated. The frequency of monitoring of metals concentrations in
the sewage sludge to be burned depends on the amount of sewage sludge fired in an incinerator. Table
1 of §503.46 outlines the monitoring frequency requirements.
Sewage sludge incinerators are generally designed and built to operate continuously, but a sudden change
in the quantity of sewage sludge fed to the incinerator can develop dramatic changes in operation. As
a result, the combustion process can be upset and THG concentrations can increase. Feed rate changes
also affect air pollution control devices, which operate within specific design parameters. When the
sewage sludge feed rate varies, the incinerator off-gases also will vary in quantity and temperature. This
variability can decrease the efficiency of the air pollution control devices and result in excess emissions
for particulate matter and metals.
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7. INCINERATION - PART 503 SUBPART E
Under steady-state conditions, the firing of sewage sludge provides enough heat both to evaporate the
large quantities of water that enter with the sewage sludge and to initiate combustion of the new sewage
sludge. Keeping constant the volume of the sewage sludge incinerated optimizes the required rate of
excess air and therefore reduces 'heat lost in excess air. In the case of multiple-hearth incinerators, ash
is not removed from the incinerator until it has cooled and given up its heat to entering combustion air.
It is almost impossible to achieve these optimum conditions unless the sewage sludge feed is consistent
(Perking 1974; EPA 1981, 1979/1987; WPCF 1988).
The sewage sludge feed rate should be monitored to provide information to the operator on the amount
of sewage sludge fed to the incinerator(s). Monitoring the sewage sludge feed rate ensures that it does
not exceed the feed rate used to establish the concentration limits for the metal pollutants.
The most widely used instruments to measure the incinerator sewage sludge feed rate are load cell
conveyor belt scales. The weight of sewage sludge on the belt is measured by strain gauges. As the
weight on the belt increases, the stress on the load cell increases, which causes a corresponding change
in the electrical resistance of the strain gauge. The electrical resistance, combined with the speed of the
belt, is fed to a microprocessor that calculates the mass per unit time of sewage sludge on the belt. These
scales, like any other instrument, often need calibration, require maintenance, and must be replaced when
beyond repair (EPA 1992a). Based on the requirements of Part 60, Subpart O, The sewage sludge feed
rate monitor should be certified by the manufacturer to have an accuracy of plus or minus 5 percent over
its operating range. The monitor should be calibrated and adjusted at a frequency necessary to maintain
this accuracy. The recommended frequency of sewage sludge feed rate monitor calibration should be
based on the manufacturer's recommendation. The calibration frequency can be adjusted by the
permitting authority, if warranted by a review of calibration records obtained from the incinerator
operator.
Important sewage sludge monitoring documentation and records that should be maintained by sewage
sludge incinerator operators include:
• Sewage sludge feed rates (on a dry basis) expressed as hourly, daily, and annual averages
• The operating range of the sewage sludge feed rate monitor and a certification of the monitor's
accuracy over that range
• Calibration and maintenance records of the sewage sludge feed rate monitor
• Records of sewage sludge feed rate monitor malfunctions, corrective actions, and downtime
• Sewage sludge sampling records including the methods used, sample amounts, compositing
techniques, tunes and dates, sample point locations, person(s) who obtained samples, and chain
of custody sheets
• Sewage sludge analytical results including the methods used, times and dates of analysis,
laboratory data and calculation sheets, person(s) performing the analysis, and laboratory quality
assurance and quality control procedures that were followed.
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Permit writers need to stipulate the acceptable sewage sludge sampling and analytical methods to be used.
Permit writers can refer to the following EPA documents for detailed guidance on sewage sludge
sampling and analysis:
* SW-846, Test Methods for Evaluating Solid Wastes .
• POTW Sludge Sampling and Analysis Guidance Document
• Hazardous Waste Incineration Measurement Guidance Manual
• Handbook on Quality Assurance/Quality Control Procedures for Hazardous Waste Incineration.
7.9 REPORTING REQUIREMENTS
of
§S03.48(a) Class I sludge management facilities, POTWs (as defined in 40 CFR501.2) with a design flow
rate equal to or greater than one millipn gallons per day, and POTWs that serve a population
of 10,000 people or gr eater shaB submit the information to §503.47{h) through g503.47(h) to the
permitting authority on February 19 of each year. /
The reporting requirements of Part 503 provide a regulatory mechanism that allpws permitting authorities
to gather information from sewage sludge incinerators to assess compliance. Because all sewage sludge
incinerators are classified as Class I sludge management facilities, all sewage sludge incinerators as
defined in §503.41 are subject to the reporting requirements of §503.48.
'"*-•-' - , ' . . •••'"*
These reporting requirements establish a minimum for reporting sewage sludge incinerator emission and
operating records. The person who fires the sewage sludge is required to submit the information in
§§ 503.47(b)-(h) to the permitting authority each year, provided sewage sludge was fired to the incinerator
in that particular year! ~
The information specified in §§503.47(b)-(h) is more complex than it may appear to be. As discussed
in Sections 7.7 and 7.8, the information required in §503,47 is largely based on other pieces of
information. Without detailed information, the permitting authority may not be able to verify the validity
of the §503.47 information and draw accurate and complete conclusions on the compliance status of the
sewage sludge incinerators. Therefore, the imposition of more detailed recordkeeping and reporting
permit conditions may be necessary.
The permit writer may want to establish reporting formats so that the information is meaningful and
useful for evaluating compliance and enforcing standards and limits. Examples include specifying
averaging times for CEM and APCD operating parameter data, and combustion temperature. The permit
writer also may want to specify the more frequent reporting of certain data. For example, by reviewing
CEM data submitted by an incinerator operator every quarter, the permitting authority can identify
patterns of nbncompliance earlier than would be possible using the §503.48 requirements. Once these
emission exceedences are identified, actions can be taken to correct these violations and prevent future
ones.
When permit writers specify permit conditions that require the detailed record keeping and monitoring
described earlier, they may also want to include requirements to report or make available to the
permitting authority these records and data.
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7.10 SCENARIO FOR THE INCINERATION STANDARD
0 . •
This section discusses a scenario for a sewage sludge incineration standard. The scenario contains the
requirements for the seven elements of a Part 503 standard (i.e., general requirements, pollutant limits,
management practices, operational standards, and frequency of monitoring, recordkeeping, and reporting
requirements).
The standard hi this scenario protects public health from reasonably anticipated adverse effects of
pollutants hi sewage sludge. This is the only scenario for a sewage sludge incineration standard under
Part 503.
7.10.1 SCENARIO 1 - FIRING OF SEWAGE SLUDGE IN A SEWAGE SLUDGE
INCINERATOR
In this scenario, the National Emission Standard for beryllium and mercury and site-specific pollutant
limits for arsenic, cadmium, chromium, lead, and nickel have to be met. In addition, requirements for
the concentration of total hydrocarbons (THC) in the stack exit gas have to be met.
Note that §503.40(c) indicates that the management practice in §503.45(a) concerning a continuous
emissions monitor for THC and the frequency of monitoring requirement for THC in §§503.47(c) and
(n) do not apply if the following conditions are met:
(1) The exit gas from a sewage sludge incinerator stack is monitored continuously for carbon
monoxide (CO).
(2) The monthly average concentrating of CO in the exit gas, corrected for zero percent moisture
and to seven percent oxygen, does not exceed 100 parts per million on a volumetric basis.
(3) The person who fires sewage sludge hi a sewage sludge incinerator retains the following
information for 5 years:
(i) The CO concentrations in the exit gas; and
(ii) A calibration and maintenance log for the instrument used to measure the CO
concentration.
(4) Class I sludge management facilities, POTWs (as defined in §501.2) with a design flow rate
equal to or greater than one million gallons per day, and POTWs that serve a population of
10,000 people or greater submit the monthly average .CO concentration in the exit gas to the
permitting authority on February 19 of each year.
The elements of a Part 503 standard for this scenario are presented below.
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ELEMENTS OF A PART 503 STANDARD - SCENARIO 1
General requirements: Requirements in §503.42
Pollutant limits:
NESHAPS for beryllium and mercury (see §§503.43(a) and (b))
Site-specific for arsenic* cadmium, chromium, lead and nickel (see
§§503.43(c)and(d))
Management practices: Requirements in §503.45
Operational standard
(total hydrocarbons): Requirements in §503.44
Frequency of monitoring: Requirements in §503.46
Recordkeeping: , Requirements in §503.47
Reporting: Requirements in §503.48
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REFERENCES
Perking, H. C. 1974. Mr Pollution. McGraw-Hill, Inc. New York, NY.
U.S. EPA. 1972. Sewage Sludge Incineration. August 1972. R2-72-040.
U.S. EPA. 1978a. Sludge Handling and Conditioning. Washington, DC. September 1978. 430/9-78-
002.
U.S. EPA. 1978b. Sewage Sludge Treatment and Disposal, Volume 2. Washington, DC. April 1978.
625/4-78-012. .
U.S. EPA. 1981. Engineering Handbook for Hazardous Waste Incineration. Washington, DC.
September 1981. SW-889. , .
U.S. EPA. 1979. Process Design Manual for Sludge Treatment and Disposal. U.S. Environmental
Protection Agency 625/1-79-001, January 1987.
U.S. EPA. 1983. Guidance Manual for Hazardous Waste Incineration Permits. Washington, DC. July
1983. SW-966.
U.S. EPA. 1985. Guidelines for Determining Good Engineering Practice Stack Height.
U.S. EPA. 1989. Technical Support Document: Incineration of Sewage Sludge. Draft. Washington:
Office of Water. ,
U.S. EPA. 1990a. Guidance Document for Testing and Permitting Sewage Sludge Incinerators. Draft
Report. Midwest Research Institute. September 1990.
U.S. EPA. 1990b. Guidance for Writing Case-by-Case Permit Requirements for Municipal Sewage
Sludge. Office of Water. May 1990. 505/8-90-001. ,
U.S. EPA. 1990c. Locating and Estimating Air Toxics Emissions from Sewage Sludge Incinerators.
May 1990 EPA-450/2-90-009.
U.S. EPA. 1992. Technical Implementation Document for EPA's Boiler and Industrial Furnace
Regulations. March 1992. EPA-530-R-92-011.
U.S. EPA. 1992a. Sewage Sludge Incinerator Total Hydrocarbon Analyzer Evaluation. Cincinnati, OH:
Office of Research and Development, Wastewater Research Division.
U.S. EPA. 1993. The Preamble to 40 CFR Part 503 Standard for the Use and Disposal of Sewage
Sludge. February 1993. 58 FR 9248.
U.S. EPA. Technical Support Document for Proposed Publicly Owned Treatment Works Sludge
Incineration Regulation. Washington, DC. July 1992.
7-50
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7. INCINERATION - PART 503 SUBPART E
U.S: EPA. THC Continuous Emission Monitoring Guidance far Part 503 Sewage Sludge Incinerators.
June 1994. EPA 833-B-94-003. .
Water Pollution Control Federation. 1988. Incineration, Manual of Practice. No. OM-11. Alexandria,
VA. • ' ' .. ' ,'•"••. '•
7-51
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8. PATHOGEN AND VECTOR ATTRACTION
REDUCTION - PART 503 SUBPART D
QUICK REFERENCE INDEX
. . Section
INTRODUCTION -..,".. • ' , 8.1
WHAT ARE PATHOGENS AND VECTOR ATTRACTION? 8.2
PATHOGENS
VECTOR ATTRACTION
WHEN DOES PATHOGEN AND VECTOR ATTRACTION REDUCTION HAVE TO OCCUR? 8.3
PATHOGEN REDUCTION ,
VECTOR ATTRACTION REDUCTION
FREQUENCY OF MONITORING 8.4
SPECIAL DEFINITIONS , _ , , , 8.5
CLASS A PATHOGEN ALTERNATIVES 8.6 .
ORDER IN WHICH PATHOGEN AND VECTOR ATTRACTION REDUCTION IS ACHIEVED
REGROWTH REQUIREMENT . ,
CLASS A ALTERNATIVE 1 ~
CLASS A ALTERNATIVE 2
CLASS A ALTERNATIVE 3
CLASS A ALTERNATIVE 4 - .
CLASS A ALTERNATIVE 5
CLASS A ALTERNATIVE 6
CLASS B PATHOGEN ALTERNATIVES 8.7
ORDER OF PATHOGEN AND VECTOR ATTRACTION REDUCTION
CLASS B ALTERNATIVE 1 ,
CLASS B ALTERNATIVE 2
CLASS B ALTERNATIVE 3
CLASS B SITE RESTRICTIONS .
VECTOR ATTRACTION REDUCTION OPTIONS • 8.8
VECTOR ATTRACTION REDUCTION OPTION 1
VECTOR ATTRACTION REDUCTION OPTION 2
VECTOR ATTRACTION REDUCTION OPTION 3 , .
VECTOR ATTRACTION REDUCTION OPTION 4
VECTOR ATTRACTION REDUCTION OPTION 5
VECTOR ATTRACTION REDUCTION OPTION 6
VECTOR ATTRACTION REDUCTION OPTION 7
VECTOR ATTRACTION REDUCTION OPTION 8 ,
VECTOR ATTRACTION REDUCTION OPTION 9 .
, VECTOR ATTRACTION REDUCTION OPTION 10 .
VECTOR ATTRACTION REDUCTION OPTION 11
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8.1 INTRODUCTION
This chapter provides guidance on the requirements for pathogen and vector attraction reduction in Part
503, Subpart D. The requirements in this Subpart apply to sewage sludge that is land applied or placed
on a surface disposal site" and to a land application site or surface disposal site under certain situations.
This chapter assumes that the sewage sludge is regulated under Part 503 (see Chapter 2) and the use or
disposal practice is either land application or surface disposal (see Chapters 4 and 5). .
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.2 WHAT ARE PATHOGENS
AND VECTOR ATTRACTION?
For the purpose of this regulation, "pathogens"
and "vector attraction" are defined as follows;
Pathogenic organisms are disease-causing
organisms. These include, but are not limited to,
certain bacteria, protozoa, viruses, and viable
helminth ova. §503.31(f).
Vector attraction is the characteristic of sewage
sludge that attracts rodents, flies, mosquitos, or
other organisms capable of transporting infectious
agents. '|503.31(k).
8.2.1 PATHOGENS
Pathogens are organisms capable of causing
diseases. These include certain bacteria, fungi,
viruses, protozoa (and their,cysts) and intestinal
parasites (and their ova). These organisms
produce disease by entering the body, and then
interfering with one or more metabolic functions.
The diseases produced are communicable because
the organisms are transferred from infected hosts
to potential hosts through either direct or indirect ^™"^^^™
physical contact.
Pathogens are found in the following wastewater:
• Residential wastewater, including that related to personal hygiene, toilet use, clothes washing and
food preparations
• Commercial food processing and preparation wastewater
• Street run-off (hi systems with combined sewers).
These organisms enter the treatment works in both active and inactive states (see the discussion below
of individual organism types). Regardless of type, pathogenic organisms are removed by sedimentation
and entrainment in biological floes hi secondary treatment. Their removal rates in, a treatment works can
be well in excess of 90 percent. Nevertheless, this still leaves sufficient levels of organisms in the
treatment works effluent to pose a health threat - hence the inclusion of disinfection requirements in most
permits to treatment works that treat domestic sewage. Pathogens removed from the wastewater can
concentrate in the sewage sludge.
The different types of pathogens include:
• Bacteria—Bacteria are single celled organisms. In general, bacteria are the only pathogens that
can carry out their entire life cycle outside of a "host," or infected organism. Pathogenic bacteria
are heterotrophic; that is, they use organic materials as both carbon and energy sources. Because
pathogenic bacteria can complete their life cycles outside man (or another host), sewage sludge
that has been treated to reduce pathogens can be reinfected. or may exhibit an increase in
bacterial concentration under conditions favorable to the bacteria.
• Viruses—Viruses are wholly parasitic in nature. They are capable of reproducing only through
the invasion of the host organism's own cells. Viruses that cause disease in man are typically
present hi the gut, and thus are routinely present in domestic sewage. Viruses have been found
to be removed effectively by sedimentation (presumably through entrainment in sewage sludge
floe particles) and are thereby concentrated in sewage sludge.
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
• Parasites—Parasites include protozoa, and a variety of multi-cellular animals, all of which utilize
the resources of their host's body to complete their life cycle. Protozoa are single-celled
organisms that form cysts. Cysts remain dormant until ingested by a host. In the host's gut the
cyst is changed into an active protozoan, which in turn releases cysts to be expelled with the
feces. '.'•'..-••
Most of the multicellular parasites are worms of various types. These infect their host through
the irtgestion of parasite ova. The ova changes to an active worm in the gut. Some types then
remain in the gut, while others invade other body tissues. For example, helminth are flatworms
associated with meat-animals (such as cattle and sheep) and with rodents. Disease is caused by
the development of one or more worms in the gut. In the case of some helminths, the worm will
migrate to other tissues, such as the heart or nervous system. This results in conditions
potentially fatal to the infected host. '
• Fungi—Fungi are non-photosynthetic plants that reproduce by generating spores. The pathogenic
nature of certain fungi is exhibited when the spores are inhaled by humans. In general, the
pathogenic effect exhibited is the result of the growth of the fungi in the nasal passages, throat,
mouth or lungs of the individual.
The pathogens for which requirements are established in Part 503 are Salmonella sp. bacteria, enteric
viruses; and viable helminth ova. In some cases, fecal coliform density is used as an indicator of the
density of these microorganisms. EPA concluded that if the requirements for these three microorganisms
are met, other pathogens in sewage sludge also are reduced.
8.2.2 VECTOR ATTRACTION
Vector attraction is any characteristic that attracts disease vectors. Disease vectors are animals that, as
a result of some aspect of their life cycle, are capable of transporting and transmitting infectious agents.
Their interaction with humans provides a pathway for the transmission of disease. Vectors are themselves
not pathogenic. Vectors fall into two broad categories: _
Insects—These include fleas, flies and mosquitos. They typically transmit disease through their
feeding habits; in the case of mosquitos and fleas, pathogens are picked up and spread by biting
and feeding on infected animals or humans, and subsequently feeding on an uninfected animal
pr human. Flies and certain other insects typically transmit disease through the contamination
of exposed food on which they are feeding.
Mammals—Rodents are the most well known mammalian vectors but other mammals, including
feral domestic animals, can act as disease vectors. In general, mammals act as disease vectors
by acting as hosts for infected insects (such as fleas) and transporting the infected insects to
places where they may come into contact with humans.
In general, unprocessed sewage sludge contains an organic component that is an attractive food source
to certain vectors. Specific components of raw sewage sludge that act as attractants include feces and'
food wastes.
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
The Part 503 requirements for vector attraction reduction are designed either to reduce the food source
in sewage sludge or to place a barrier between the sewage sludge and the vector. The barrier prevents
access to the food source in the sewage sludge.
8.3 WHEN DOES PATHOGEN AND VECTOR ATTRACTION REDUCTION
HAVE TO OCCUR?
8.3.1 PATHOGEN REDUCTION
The reduction of the pathogen content of any sewage sludge requires the following:
-"" • ,
• Exposure of the sewage sludge to conditions that are disadvantageous physiologically for the
pathogenic organisms
• Alteration of the characteristics of the sewage sludge such that if any exposure to pathogenic
organisms occurs after sewage sludge processing, the likelihood of re-infection is minimized
• Handling of the sewage sludge in a manner so as to minimize the chance for reintroduction of
pathogenic organisms.
The reduction of pathogenic organism is not the primary goal of most of the sewage sludge stabilization
processes even though those processes generally are effective at reducing pathogens. Commonly used
sewage sludge stabilization processes that also reduce pathogens include:
• Anaerobic digestion
• Aerobic digestion
• Chemical stabilization
• Heat treatment.
Because of the potential for certain pathogens to regrow after they have been reduced, several of the Part
503 pathogen requirements are time-related (i.e., they have to be met either at the time the sewage sludge
is used or disposed or at the time control over the sewage sludge is lost). The Part 503 pathogen
requirements subject to this time-related requirement include:
(1) Measurement of either fecal coliform or Salmonella, sp. bacteria for all of the Class A pathogen
alternatives; and
(2) Measurement of enteric viruses and viable helminth ova densities in Class A Alternative 4.
The purpose of the time-related pathogen requirements is to ensure that the requirements for the density
of certain pathogens are met as close as possible to when the sewage sludge is either used or disposed
or when control over the sewage sludge is lost. The three situations for which the time-related pathogen
requirements apply are discussed below.
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION-PART 503 SUBPART D
The first situation is "at the time of use or disposal." This means as close as possible to when the sewage
sludge is used or disposed. This may be, for example, 3 days before it is used or disposed depending
pn the time to collect and analyze a sample of sewage sludge and receive the results.
If the sewage sludge is used or disposed before the analytical results are received, the sample should be
collected when the sewage sludge is actually used or disposed (e.g., when the sewage sludge is applied
to the land). Of course, the risk with this approach is that the analytical results may indicate that a Part
503 pathogen requirement is not met. In this case, there would be a violation of that requirement because
the sewage sludge already has been used or disposed.
The last two situations for the time-related pathogen requirements are situations where control over the
sewage sludge is lost. In the case of sewage sludge sold or given away in a bag or other container, the
sewage sludge is first treated to meet the Part 503 requirements for pollutants, pathogens, and vector
attraction reduction. After those requirements are met, the sewage sludge usually is placed in a bag or
other container for sale or give away for application to the land. When and where the sewage sludge is
land applied is unknown in this case. The last opportunity for the time-related pathogen requirements
to be met is when the sewage sludge is prepared for sale or give away in a bag or other container for
application to the land. '.
The other situation is when sewage sludge is prepared to meet the EQ requirements. Because there is
no control over the actual application of an, EQ sewage sludge (i.e., ah EQ sewage sludge is not subject
to the land application general requirements and management practices), the last opportunity that the time-
related pathogen requirements can be met in this situation is when the sewage sludge is prepared to meet
the three quality requirements for an EQ sewage sludge. ••' '
The Part 503 requirements that are not time-related can be met any time before the sewage sludge is used
or disposed. For example, the time-temperature requirements for Class A, Alternative 1 can be met. any
time. The sewage sludge then could be stored before it is used or disposed and the enteric viruses and
viable helminth ova, which are the two organisms the time-temperature requirements are designed to
reduce, will not regrow during the storage period.
The Part 503 pathogen requirements that are not subject to the above time-related requirements include:
(1) The time-temperature requirements in Class A Alternative 1;
(2) The pH-temperature-percent solids requirements in Glass A Alternative 2;
(3) The demonstration requirements for the reduction of enteric viruses and viable helminth ova in
Class A Alternative 3; ,
(4) Treatment of the sewage sludge in a Process to Further Reduce Pathogens (PFRP) or an
equivalent PFRP in Class A Alternative 5 and 6, respectively; '
(5) Measurement of fecal coliform in Glass B Alternative 1; and
(6) Treatment of the sewage sludge in a Process to Significantly Redupe Pathogens (PSRP) or an
equivalent PSRP in Class B Alternatives 2 and 3, respectively. ,
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.3.2 VECTOR ATTRACTION REDUCTION
One of the goals of most sewage sludge stabilization processes is to reduce putrescibility, which directly
affects the tendency for sewage sludge to attract disease vectors. In general, efforts to reduce the
attraction of disease vectors to sewage sludge require some or all of the following:
• Reduction in the sewage sludge's organic content
• Modification of the sewage sludge's chemical characteristics to make it unattractive to vectors
• Placement of a barrier between the sewage sludge and vectors (e.g., inject sewage sludge beneath
the surface of the soil).
Three of the treatment-related vector attraction reduction options (Options 6, 7, and 8) and the options
that require that a barrier be placed between the sewage sludge and vectors (i.e., Options 9 through 11)
must be met when the sewage sludge is used or disposed.
The treatment-related option that has a limited storage period is pH adjustment (i.e., Option 6). The
technical support document for the Part 503 pathogen and vector attraction reduction requirements
indicates pH adjustment "does not significantly change the nature of the substances in the sewage sludge,
but instead causes stasis in biological activity." If the pH of the sewage sludge drops, the organic
material in the sewage sludge could begin to decompose, which could cause vectors to be attracted to the
sewage sludge.
The pH target conditions in Option 6 are designed to ensure that the sewage sludge can be stored for
several days before it is actually used or disposed. When quicklime or slaked lime is used to adjust the
pH, the storage period is from 12 to 25 days. After that period, vectors could be attracted to the sewage
sludge as the pH falls. If a different material (e.g., cement kiln dust or wood ash) is used to adjust the
pH, the period before which the pH drops may be different because other alkali materials are more
soluble than lime. Thus, less undissolved material is available to maintain the pH as it starts to drop.
. i
In cases where sewage sludge is stored for longer than 15 days, the pH of the sewage sludge should be
monitored just prior to when the sewage sludge is used or disposed (e.g., within one or 2 days). If the
pH of a representative sample of the stored sewage sludge is 11.5 of higher, the vector attraction
reduction requirement is met. If the pH is below 11.5, the pH has to be adjusted again to reach the target
conditions or another vector attraction reduction option has to be met.
Vector attraction reduction options 7 and 8 require that the percent solids in the sewage sludge be above
a certain value. If the moisture content of the sewage sludge increases after the percent solids
requirement is met, the sewage sludge could attract vectors. For this reason, options 7 and 8 must be
met at the tune the sewage sludge is used or disposed.
Vector attraction reduction option 10 requires incorporation of sewage sludge into the soil within six
hours after it is land applied or surfaced disposed, unless otherwise specified by the permitting authority.
This reduces the attraction of vectors to the sewage sludge by placing a barrier between the sewage sludge
and the vectors. In some cases, it may not be feasible to incorporate the sewage sludge into the soil
within six hours after it is land applied or surface disposed. Site-specific conditions (e.g., the remoteness
of a land application site) that may affect the time period during which sewage sludge can be incorporated
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
into the soil, should be considered by the permitting authority When deciding if a different time period
is appropriate. , '
8.4 FREQUENCY OF MONITORING
For those requirements that establish pathogen performance levels and vector attraction reduction
performance levels, the monitoring frequency is the frequency in Table 8-1.
TABLE 8-1 MONITORING FREQUENCY FOR PATHOGEN DENSITY LEVELS AND
VECTOR ATTRACTION REDUCTION OPTIONS 1-4, 6-8
Amount of sewagfe sludge*
(metric tons per 365-day period)
Greater than zero but less than 290
Equal to or greater than 290 but less than 1,500
Equal to or greater than 1,500 but less than 15,000
Equal to or greater than 15,000
Frequency
once per year ..
once per quarter (four times per year)
once per 60 days (six times per year)
once per month (12 times per year)
* , Either the amount of bulk sewage sludge applied to the land, the amount of sewage sludge received by a
person who prepares the sewage sludge for sale or give away in a bag or other container for application
to the land, or the amount of sewage sludge placed on an active sewage sludge unit (on a dry weight
basis). . ' , ;
The permit writer has the authority and discretion to specify more frequent monitoring. Reasons for
doing so may include: ,
• Very high potential for contact by the public with the use or disposal site
• A history of poor sewage sludge management on the part of the permittee.
In specifying monitoring frequency, the permit writer should: ,
• Make clear the minimum frequency required for each parameter
• Include language noting the need to submit all data, if monitoring is carried out more frequently
than specified.
When specifying monitoring frequency for operational parameters, the permit writer should consider:
• Good practice in the operation of sewage sludge treatment processes
• The size and complexity of the treatment works and the sewage sludge treatment processes
involved.
For more insight into what constitutes appropriate operational monitoring, the permit writer is referred
to: . • -
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
• Operation of Wastewater Treatment Plants, MOP11, WEF ,
• Sludge Handling and Conditioning, EPA 430/9-78-002
• Control of Pathogens and Vector Attraction in Sewage Sludge, EPA 625/R-92/013.
Specific monitoring parameters, their required or suggested monitoring frequency, and suggested
documentation are discussed after each specific pathogen or vector attraction reduction alternative.
When sewage sludge is stored for several months before being land applied or placed on an active sewage
sludge unit, the approach to frequency of monitoring for pathogen densities and vector attraction
reduction depends on which requirements are met. For the purpose of the following discussion, assume
that sewage sludge is generated continuously during a 365-day period and stored for 11 months before
it is used or disposed. Also assume that the frequency of monitoring required by Part 503 is once per
month. Note that the frequency of monitoring requirements do not apply for pathogen alternatives or
parts of pathogen alternatives that require that "operational conditions" be met (e.g., raise the temperature
of the sewage sludge for a specific tune). Those conditions should be met at all times.
The different approaches for sewage sludge that has been stored may result in a different number of
samples that are analyzed. The important thing to remember is that the samples that are analyzed have
to be representative of the sewage sludge that is used or disposed, which is the objective of the Part 503
frequency of monitoring requirements.
The only pathogen density requirement that could be affected by storing the sewage sludge before use or
disposal is the "regrowth requirement" for the Class A alternatives. (See Section 8.6.2 for a discussion
of regrowth.) To meet this requirement, either the density of fecal coliform or the density of Salmonella
sp. bacteria hi the sewage sludge has to be below a specific value at the tune the sewage sludge is used
or disposed. In the above example, a representative sample of the sewage sludge that is stored for 11
months would have to be analyzed at the time the sewage sludge is.land applied to show compliance with
the "regrowth requirement." It is not appropriate to collect and analyze a sample of the sewage sludge
that is placed on the storage pile each month and use the analytical results for those samples to show
compliance with the "regrowth requirement."
The approach in the above example for frequency of monitoring for vector attraction reduction also varies
depending on which vector attraction reduction option is met. The frequency of monitoring requirements
do not apply to vector attraction reduction options §§503.33(b)(5), (b)(9), and (b)(10). The conditions
in those options should be met at all times.
Two approaches can be used in the above example for the frequency of monitoring for vector attraction
reduction option in §503.33(b)(l). In the first approach, the required percent volatile solids reductions
can be demonstrated each month prior to when the sewage sludge is placed on the storage pile.
In the second approach, the volatile solids in the influent to the pathogen reduction process could be
measured each month. The volatile solids hi a representative sample of the stored sewage sludge could
be measured at the tune the sewage sludge is land applied. Those two measurements could then be used
to calculate the percent volatile solids reduction in the sewage sludge. Note that other parameters (e.g.,
fixed solids) also may have to be measured in the sewage sludge depending on which equation is used
to calculate percent volatile solids reduction.
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
There also are two approaches for the frequency of monitoring for the vector attraction reduction option
in §503.33(b)(2). In the first approach, compliance with this option could be demonstrated each month
by anaerobically digesting a sample of the sewage sludge in the laboratory prior to when it is dewatered
and placed on the storage pile.
The second approach only is applicable when the sewage sludge is stored in an environment that is clearly
anaerobic. In this case, a representative sample of the stored sewage sludge could be digested
anaerobically in the laboratory to demonstrate compliance with the percent volatile solids reduction
requirement in this option. This approach does not appear to be appropriate for sewage sludge that is
dewatered and stored in windrows'or piles because these are not totally anaerobic conditions.
There also are two approaches for the frequency of monitoring for-the vector reduction option in
§503.33(b)(3). In the first approach, a representative sample of the sewage sludge would be collected
and digested aerobically in the laboratory each month prior to when the sewage sludge is placed on the
storage pile. ' - • -
In the second approach, a representative sample of the stored sewage sludge could be digested in the
laboratory to shown compliance with the percent volatile solids reduction requirement in this option. This
approach only is appropriate if the sewage sludge is stored under aerobic conditions, which is highly
unlikely in most cases, - .
The vector attraction reduction option in §503.33(b)(4) only is applicable to liquid sewage sludges with
a percent solids content of two percent or less that have not been deprived of oxygen for more than two
hours. For this reason, there is only one approach for the frequency of monitoring for this option.
To comply with this option, a representative sample of the sewage sludge has to be collected each month
(assuming the sewage sludge is treated in an aerobic process) and the specific oxygen update rate (SOUR)
,for the sewage sludge has to be determined. Of course, the results of the test have to meet the,
requirements for this option. The sewage sludge could then be dewatered and stored for 11 months or
the liquid sewage sludge could be stored in a lagoon for the 11 months.
As mentioned above, the operating conditions in the vector attraction reduction option in §503.33(b)(5)
should be met at all times. The reduction in the characteristics of the sewage sludge that attract vectors
achieved during the option (5) process should not be affected if the sewage sludge is stored before it is
used or disposed.
\ - . ; . •• '
Option (6) could be affected if the sewage sludge is stored after the pH adjustment requirements are met.
When lime is used to adjust the pH, the sewage sludge can be stored for up to 25 days before the pH
starts to drop. When other materials are used to adjust the pH, the storage time before the pH starts to
drop is shorter. Thus, the pH of the sewage sludge (all of the sewage sludge, not just a representative
sample) should be adjusted at the time the stored sewage sludge is land applied (up to 25 days prior to
land application if lime is used for pH adjustment) to prevent the pH from dropping before the sewage
sludge is land applied. If the pH does drop, vectors could be attracted to the s6wage sludge as it
putrefies. _
There are two approaches for the frequency of monitoring for the vector attraction reduction options in
§§ 503.33(b)(7) and (b)(8). In the first approach, the percent spjids requirement in the appropriate option
could be met each month in a representative sample of the sewage sludge. The option continues> to be
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
met when the sewage sludge is stored as long as the percent solids does not decrease during the storage
period. If the moisture content of the sewage sludge increases (i.e., the percent solids decreases) before
the sewage sludge is used or disposed, vectors could be attracted to the sewage sludge. Thus, this
approach is applicable to the above example if the percent solids of the sewage sludge does not decrease
during the 11-month storage period.
The other approach for this option is to determine the percent solids of a representative sample of the
stored sewage sludge just prior to when it is land applied. If the percent solids meets the requirement
in the appropriate option, vector attraction reduction is achieved.
8.5 SPECIAL DEFINITIONS
Statement of Regulation ,",, X. „ ' s '
§S03.31(a) Aerobic digestion is the biochemical decomposition of organic matter in sewage sludge into
carbon dioxide and water by microorganisms in the presence of air,
§S03.31(b) Anaerobic digestion is ttie biochemical decomposition of organic matter in sewage sfadge into
methane gas and carbon dioxide by microorganisms in the absence of air.
n'\, _•" " >fc ' t ^J,'-,', " « f S , vvi wrf—Tv ~ m ,
§503.31(c) Density of microorganisms is the number or microorganisms per unit mass of total solids (dry
Weight) in the sewage sludge. " " " ,' ™;," ™^,,i5">, rjt"
§503.31(d) Land with a high potential for public, exposure is land that the public uses frequently, This
includes, but is not limited to, a public contact site and a reclamation site located in a populated
area (e.g>, a construction site located in a city),
§S03.31(e) Land with a law potential for public exposure is land that the public uses infrequently. This
includes, but is not limited to, agricultural land, forest, and a reclamation site located in an
unpopulated area (e.g., a strip mine located in a rural area), , " „*
^^ ^ ^ ** ** t"" ftfff?ff fsf /• 'f f fyf &t,fy f '* VsM-WS jffff -5v y
§503,31(0 Pathogenic Organisms are g%ea$e*causiiu» organisms. These include, but are not limifed to,
certain bacteria, protozoa, viruses, and viable helminth ova.
' ,f« ^'i'i,^,f^,Kxff'my,-" f
§503.31(g) pH means the logarithm of the reciprocal of the hydrogen ion concentration measured at 25flC
or measured at another temperature and then converted to an equivalent value at 25°C.
§503.31(h) Specific oxygen uptake rate (SOtflti is the mass of oxygen consumed per unit time per unit mass
of total solids (dry weight basis) in the sewage sludge*
§503.310) Total solids are the materials in sewage sludge that remain as residue when the sewage sludge
IS dried at 103 to J.05 degrees Celsius. ',",'"'
? ••••'• •• / ^ * >
§503.31(j) Unstabilized solids are organic materials in sewage sludge that have not been treated'in either
an aerobic or anaerobic treatment process.
§503.31(k) yector attraction^ is the characteristic of sewage stodge that attracts rodents, flies, mosquitos, or
other organisms capable of transporting infectious agents.
§503.31(0 -Volatile solids fe the amount of the total solids in sewage sludge lost whenthe sewage sludge is
combusted at 550 degrees Celsius te the presence of excess air. ____________
Colony Forming Unit - The density of microorganisms expressed as a count of colonies on an agar plate or filter
disk. Because a colony might have originated from a clump of bacteria (instead of an individual), the count is not
a count of individual bacteria. This unit of measurement can not be used when the Class A pathogen
requirements are met because of the inaccuracy of the method at low microorganism densities.
8-10
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Indicator Organism 7 is an organism that is itself not pathogenic, but whose presence or absence is indicative of
the respective presence or absence of pathogenic organisms.
Most Probable Number (MPN) - is determined using a test based on the fermentation of a fixed number of
replicates of a number of dilutions of the test sample. The number of replicable tubes in each dilution exhibiting a
certain behavior (e.g., gas production for coliform) is used to probablistically estimate the organism density in the
original sample. . •
Plaque-forming Units - Virus densities are determined by inoculation of several standard types of host cells. The
inoculated host cells are placed in a growth medium; after an incubation period, zones of no growth (i.e., plaques)
will form as a result of the viral action on the host cells. Counting of these zones provides the numerical value
expressed as Plaque-forming Units. . '
Mean Cell Residence Tune (MCRT) - is defined as: -
.'''__ mass of solids in the digester
c ~~ mass of solids removed per day ,
The resulting number, in days, is related to the average time a cell remains in the digester. Exact determination
of an actual average cell residence time is complicated by the fact that due to digestion, mass of cells into a
* digester does not equal mass of cells out. For more information, see Appendix E in Control of Pathogens and
Vector Attraction in Sewage Sludge. (EPA, 1992)
: Wet Bulb Temperature - is measured using a thermometer that has its bulb encased in a water-saturated wick; the
thermometer and wick are allowed to reach evaporative equilibrium with the gas whose temperature is being
measured. ,
The megarad - is a measure of the energy dose received per unit mass of the material being irradiated. One
megarad is equivalent to 10 joules of energy per grain (a joule is about 1/100 btu). ,
8.6 CLASS A PATHOGEN ALTERNATIVES
8.6.1 ORDER IN WHICH PATHOGEN AND VECTOR ATTRACTION REDUCTION IS
ACHIEVED
The order in which pathogen and vector attraction reduction occurs is important when the Class A
pathogen requirements and certain vector attraction reduction options are met. Section 503.32(a)(2)
requires that Class A pathogen, reduction be accomplished before or at the same time as vector attraction
reduction except when vector attraction reduction is achieved by alkali addition (Option 6) or drying
(Options 1 and 8). This requirement does not apply when the Class B pathogen requirements are met.
The need to specify the order in which pathogen and vector attraction Occurs is based on evidence that
regrowth of pathogens can occur, in some cases, if pathogen reduction follows vector attraction reduction.
In the early 1980s, both Germany and Switzerland required disinfection of digested sewage sludge before
it could be applied to pasture in the summer. After receiving reports of the presence1 of Salmonella sp.
bacteria in disinfected sewage sludge (usually disinfection was achieved through pasteurization), an
investigation was conducted that-revealed that the pasteurized sewage sludges were contaminated with
pathogenic bacteria. This was attributed to the absence of competitive bacteria in the sewage sludge due
8-11
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
to disinfection. Pathogenic bacteria regrew rapidly to dangerous levels even though the sewage sludge'
had been well digested.
The discovery that pathogenic bacteria can regrow to high levels when competitive bacteria (i.e.,
vegetative bacteria) are absent demonstrated that it "is unwise to have pathogen reduction as the final
processing step before the sewage sludge is used or disposed unless there is some kind of a deterrent to
regrowth of pathogenic bacteria in the sewage sludge. Such deterrents include the rionpathogenic bacterial
population that remains in the sewage sludge when pathogen reduction occurs either prior to or at the
same time as vector attraction reduction; the presence of a chemical that causes stasis in biological
activity, such as would occur when vector attraction reduction option 6 is met; a high percent solids in
the sewage sludge, such as would occur when either vector attraction reduction option 7 or 8 is met; and
the nonpathogenic bacterial population in a sewage sludge that meets the Part 503 Class B pathogen
requirements.
Results of several studies indicated that a much lower rate of regrowth of pathogenic bacteria occurs in
sewage sludge in which the bacteria have been reduced to low levels (e.g., when the Class A pathogen
requirements are met) if vector attraction reduction follows pathogen reduction. This is the reason why
Part 503 requires that pathogen reduction occur prior to or at the same time as vector attraction reduction,
except when the Class B pathogen requirements are met or when the requirements in vector attraction
options 6, 7, or 8 are met. As mentioned above, when the Class B pathogen requirements are met or
when the requirements in vector attraction reduction options 6, 7, or 8 are met, the sewage 'sludge
contains deterrents that limit the regrowth of pathogenic bacteria.
8.6.2 REGROWTH REQUIREMENT
The objective of the Class A pathogen alternatives is to reduce the density of Salmonella sp. bacteria,
enteric viruses, and viable helminth ova in the sewage sludge to below detectable levels. After the
density of enteric viruses and viable helminth ova are reduced^ they will not regrow over time,
Salmonella sp. bacteria may regrow, however. This is the reason for the regrowth requirement discussed
below.
Each of the six Class A pathogen alternatives requires that the sewage sludge meet either the following
fecal coliform density level or Salmonella sp. bacteria density level at the time the sewage sludge is used
or disposed^ at the tune the sewage sludge is prepared for sale or give away in a bag or other container
for application to the land, or at the time the sewage sludge is prepared to meet the EQ requirements (see
section 8.3 for discussion of at the time of use or disposal):
• Fecal Coliform—Less than 1,000 Most Probable Number (MPN) per gram total dry solids, or;
• Salmonella sp.—Less than 3 MPN per 4 grams total dry solids.
The purpose of the above requirement is to ensure that Salmonella sp. bacteria do not regrow between
the time pathogen reduction occurs and the time that the sewage sludge is used or disposed. For
example, the temperature of the sewage sludge may be raised to the required level and kept at that level
for the required time and then the sewage sludge may be stored for 6 months prior to use or disposal.
To ensure that Salmonella sp. bacteria do not regrow during the 6-month storage period, a sample of the
sewage sludge has to be tested for either fecal coliform or Salmonella sp. bacteria at the time of use or
disposal. If either the fecal coliform density or Salmonella sp. bacteria density in the sample is equal to
8-12
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
"or less than the above values, regrowth has not Occurred and the sewage sludge remains Class A with
respect to pathogens.
Fecal coliform density is used to demonstrate that the sewage sludge contains a low level of pathogenic
bacteria (i.e., it is an indicator organism). In some cases, the fecal coliform density in the sewage sludge
may exceed the allowable density even though the density of pathogenic bacteria in the sewage sludge
is low. In this case, the level of Salmonella, sp. bacteria can be measured in the sewage sludge in lieu
of measuring the fecal coliform. The Part 503 regrowth requirement for Class A sewage sludge is met
if the density of Salmonella sp. bacteria is below the allowable density in Part 503 even if the fecal
coliform density in the sewage sludge exceeds the allowable Part 503 fecal coliform density.
8.6.3 CLASS A ALTERNATIVE 1
Statement of Regulation
Class A - Alternative 1 (Not applicable for composting)
(j) Miner the density of fecal coliform in the sewage sludge shaft be less than 100ft Most
Probable Number per grant of total solids {dry weight basis), or the density of Salmonella
sp* bacteria in the sewage sludge" shall be less than three Most Probable Mutnber per four
grams of total solids (dry weight basis) at the time ifae sewage sludge is used or disposed;
at the time the sewage sludge is prepared for sale or give away in a bag or other container
, for application to the land; or attbe flme tine sewagesludgeormaterial derived from, sewage
s sludge is prepared to meet the requirements in 503uiO(b)» S03,iO(c), £03.10(s}>
The temperature of the sewage sludge that is used or disposed shall be maintained at a
specific value for a period of tune,
(A) When the percent solids of me sewage sludge is seven percent or higher, the
temperature of the sewage sludge shall be 50 degrees Celsius or higher; the time period
shall be 20 mmutes or longer; and the temperature and time period shall be determined
% using equation (2), except when, small particles of sewage sludge are heated by either
Avarmed gases or an immiscible liquid.
131.7b(KflO(>
Eq* (2)
Where,
D *= time: m days.
t = temperature in degrees Celsius.
(B) When the percent solids of the sewage sludge is seven percent or higher and small
particles of sewage sludge are heated by either warmed gases or an immiscible liquid,
the temperature of the sewage sludge shall be 50 degrees Celsius or higher; the time
period shall be -15 seconds or longer; and the temperature and time period shall be
determined using equation (2>.
(C) When the percent solids of the sewage sludge is less than seven percent and the tune
per iod is at least 15 seconds, but less than 30 minutes, the temperature and time period
shall be determined using'equation (2). - -
8-13
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Statement of Regulation
(D) When the percent solids of the sewage sludge is less than seven percent; the
temperature of the sewage sludge is 50 degrees Celsius or higher? and the time period
is 30 minutes or longer, the temperature and time period shall be determine^ using
equation (3).
50.070.000
JQ0.14001
Eq, (3)
•}••&, <
Where,
- ,v' ,*'D SP time in days. ' -<'
t B? temperature'inDegreesCelsius. '* ' ^ '
Alternative 1 applies to processes that reduce pathogens by thermal means (elevated temperatures) such
as heat treatment, thermophilic digestion, pasteurization, and heat drying. This alternative requires both
the demonstration that certain pathogen density levels are not exceeded and adherence to specified
operating parameters. There is an inverse relationship between the temperature and the time of contact
needed to reduce pathogenic organisms to below detectable levels. The above equations are mathematical
expressions of the relationship between temperature and time. The time that sewage sludge must be held
at a given temperature is determined using the equations.
When the time/temperature conditions are met, Salmonella sp. bacteria, enteric viruses, and viable
helminth ova hi the sewage sludge are reduced to below detectable levels. Enteric viruses and viable
helminth ova do not regrow after they are reduced. Thus, there is no need to test the sewage sludge for
those microorganisms at the tune of use or disposal. Because Salmonella sp. bacteria may regrow, the
above regrowth requirement has to be met when the sewage sludge is used or disposed.
Appropriate parameters to be monitored and a monitoring frequency are presented below. The permit
writer also may want to specify the records or documentation that should be kept. Suggested
documentation to demonstrate compliance with this alternative is provided below.
FREQUENCY OF MONITORING
Pathogen Parameters
Salmonella or fecal coliform
Frequency
Once per year, quarterly, bimonthly, or monthly (see
Table 8-1)
Operating Parameters
Sewage sludge temperature/time
maintained
Percent solids
Frequency
At least 1 reading per shift, preferably continuous
Once per year, quarterly, bimonthly, or monthly (see
Table 8-1)
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Salmonella or Fecal Coliform and Percent Solids
Date and time of sample collection, sampling location, sample type, sample volume, name of
sampler, type of sample container, and methods of preservation, including cooling
Date and time of sample analysis, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless
a contract lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures
Analytical results expressed as dry weight.
Records of Operating Parameters
Date and time temperature checked
Record or documentation of detention time of the sewage sludge in the treatment unit
- Daily volumes of sewage sludge to the treatment unit(s) and daily volume of supernatant and
, processed sewage sludge withdrawn
- Size (gallons) of the treatment unit(s).
8.6.4 CLASS A ALTERNATIVE 2
Statement of Regulation
§S03«32(a)(4) Class A - Alternative 2
(i) Either; the density of fecal coliforra in the sewage stodge shall be less than MOO Most
Probable Mumper per gram of total solids {dry weight basis), or the density of Salmonella
,sp. bacteria in the sewage sludge shaft be less than three Most I*robable Number per four
grams of total solids'(dry weight basis) at the time the sewage sludge is used or disposed;
at the time the sewage sludge is prepared for sale or give away,in a bag or other container
for application to the land; or at the time the sewage sludge or material derived from
sewage sludge 4s prepared to meet the requirements in50340
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
• The pH of the sewage sludge must be raised to over 12, and maintained above 12 for at least 72
continuous hours;
• For at least one 12-hour period during the 72 hours, the temperature of the sewage sludge must
be raised (and maintained) to over 52 °C; and
• Following the 72 hours, the sewage sludge must be air dried to over 50 percent solids.
The pH should be measured at 25°C (77°F) or at the existing temperature and corrected to 25°C by use
of the following:
pH correction =
_ -0.03 pH units
1.0° C
x (25°C-T°Q
For example, sewage sludge measured at 15°C would have to be above 12.3 so that it would be above
12 after the .3 pH correction (Smith and Farrell 1994).
When the above conditions are met, Salmonella sp. bacteria, enteric viruses, and viable helminth ova in
the sewage sludge are reduced to below detectable levels. The entpric viruses and viable helminth ova
will not regrow after being reduced. Because. Salmonella sp. bacteria may regrow, the sewage sludge
has to be tested for either fecal coliform or Salmonella sp. bacteria at the time of use or disposal.
, r ,
Parameters to be monitored, a suggested frequency of monitoring, and records to be kept are provided
below.
FREQUENCY OF MONITORING
Pathogen parameters
Salmonella or fecal coliform
Operating parameters
pH of sewage sludge/time maintained
Temperature of sewage sludge/time maintained
Percent solids
Frequency
Once per year, quarterly, bimonthly, or monthly
(see Table 8-1)
Frequency
Beginning, middle, and end of treatment
Beginning, middle, and end of treatment
Once at end of air drying (batch mode)
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Salmonella or Fecal Coliform
Date and time of sample collection, sampling location, sample type, sample volume, name of
sampler, type of sample container, and methods of preservation, including cooling
Date and time of sample analysis, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless
a contract lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures
Analytical results expressed as dry weight.
Records of Operating Parameters
Time (hours) pH maintained above 12
Time (hours) temperature maintained greater than 52 °C
Percent solids of sewage sludge after air drying
8-16
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.6.5 CLASS A ALTERNATIVE 3
Statement of Regulation \
§503.32(a}(5) Class A - Alternative 3
dD Either the density of fecal coliform in the sewage sludge shall he less than 1000 Most
IProbable Number per gram vf total solids (dry weight hasis), or the density of
Salmonella sp« bacteria at sewage sludge shall be less than three Most Probable
Number per four grams of total solids (dry weight basis) at the time the sewage sludge
is used or disposed; at the tune the sewage sludge is prepared for sale or give away in
a hag or other container for application to the land; or at the time the sewage sludge
or material derived from sewage sludge is prepared to meet the requirements in
S03.10(b), 503.10(0, 503L10(e), or 503.10(f): , ' -
(ii) (A) The sewage sludge shall be analyzed prior to pathogen treatment to determine whether
the sewage sludge contains enteric viruses, ,
(B) When'the density of enteric viruses in the sewage sludge prior to pathogen treatment
is less than one Plaque-forming Unit per four grams of total solids (dry weight basts),
the sewage sludge is Class A with respect to enteric viruses until the'next monitoring
episode for the sewage sludge. - "*
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
The purpose of this alternative is to demonstrate that the sewage sludge treatment processes reduce enteric
viruses and viable helminth ova in the sewage sludge to below detectable levels. After that demonstration
is made, the sewage sludge does not have to be monitored for enteric viruses and viable helminth ova.
Instead, values for the process operating parameters have to be consistent at all times with the values for
the parameters determined during the demonstration. The values for enteric viruses and viable helminth
ova that have to be achieved during the demonstration are:
• Enteric Viruses—Less than 1 Plaque-forming Unit per 4 grams total solids (dry weight basis)
• Helminth Ova—Less than 1 viable ovum per 4 grams total solids (dry weight basis).
If the sewage sludge meets these values before treatment, it is Class A with respect to either enteric virus,
viable helminth ova, or both until the next sampling episode at which time another sample of the sewage
sludge has to be tested for those microorganisms. When either the enteric virus density, viable helminth
ova density, or both are above the level of detection; the above demonstration has to be made.
Once enteric viruses and viable helminth ova are reduced in the sewage sludge they will not regrow.
Thus, there is no requirement to test the sewage sludge for those microorganisms at the time of use or
disposal. The sewage sludge does have to be tested for either fecal coliform or Salmonella sp. bacteria
at the time of use or disposal because Salmonella sp. bacteria may regrow after being reduced if the
sewage sludge is stored before it is used or disposed.
FREQUENCY OF MONITORING
Parameters
Salmonella or fecal coliform
Enteric viruses
viable Helminth ova
Operating parameters
Frequency
Once per year, quarterly, bimonthly, or monthly (see
Table 8-1)
Once per year, quarterly, bimonthly, or monthly
until demonstration is made
Once per year, quarterly, bimonthly, or monthly
until demonstration is made
Specific to process after the reduction for either
enteric viruses or viable helminth ova is shown
'
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Salmonella or Fecal Coliform
• Date and time of sample collection, sampling location, sample type, sample volume, name of
sampler, type of sample container, and methods of preservation, including cooling
• Date and time of sample analysis, name of analyst, and analytical methods used
* Laboratory bench sheets indicating all raw data used in calculation of results (unless a contract
lab performed analysis for the permittee)
• Sampling and analytical QA/QC procedures.
Records of Operating Parameters
• Specific to the process.
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.6.6 CLASS A ALTERNATIVE 4 -
Statement of Regulation
§$03.32(a)«») Class A - Alternative 4
(i)
Either the density of fecal conform in the sewage ,sludge shafl-be Jess than 100U Most
Probable lumber per gram to total solids (dry weignt basis), or til* density otSatmonetta
sp, bacteria Da the sewage sludge shall be less than three Most Probable Number per four
grams of total solids (dry weight basis) at the time the sewage sludge is used or disposed;
at the time the sewage stodge is prepared for sale or give away in a bag or, other container
for application to the land; or at the time the sewage sludge at material derived from sewage
sludge is prepared to meet the requirements in 503,lCe}, or 503,10(0, unless otherwise specified by the permitting authority.
(iii) The density of viable helminth ova In the, sewage sludge shall be less than one per four
grains of total soBds {dry weight basis) at the time the sewage stodge is used or disposed
at the tune the sewage sludge is prepared for sale or give away in a bag or other container
for application to the land? or at the time the sewage sludgeor material derived from sewage
sludge is prepared to meet die requirements in S03,10(b), 5G3.iO(£)» 5fl3*l>
unless otherwise specified fey the permitting authority,
Alternative 4 is ideally suited for the following situations:
• Sewage sludge has been treated using a newly developed or innovative treatment processes) that
has process operating parameters different from those specified for the other Class A alternatives.
• Sewage sludge has been treated using a treatment processes) for which a correlation between
values for operating parameters and pathogen reduction has not been derived;
• There is no history of treatment of the sewage sludge for pathogen reduction. ( -
• Sewage sludge is stored for long periods of time!
This alternative requires demonstration that the sewage sludge meets the following pathogen density levels
at the time of use or disposal:
. • Fecal Coliforrn—Less than 1,000 MPN per gram total dry solids, or •
' • Salmonella sp.—Less than 3 MPN per 4 grams total dry solids, and
• Enteric Viruses—Less than 1 Plaque-forming Unit per 4 grams total solids (dry weight basis),
: and -..'••'•
•• Viable Helminth Ova—Less than 1 viable ovum per 4 grams total solids (dry weight basis).
8-19
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
If the sewage sludge meets the above requirements at the time of use or disposal, it is Class A with
respect to pathogens. To continue to be Class A, the above requirements have to be met in every sample
of sewage sludge that is collected and analyzed. '
FREQUENCY OF MONITORING
Parameters
Salmonella or fecal colifonn
Enteric viruses
Viable Helminth ova
Frequency
Once per year, quarterly, bimonthly, or
monthly (see Table 8-1)
Once per year, quarterly, bimonthly, or
monthly
Once per year, quarterly, bimonthly, or
monthly
RECORDS OR DOCUMENTATION
• Date and time of sample collection, sampling location, sample type, sample volume, name
of sampler, type of sample container, and methods of preservation, including cooling
• Date and time of sample analysis, name of analyst, and analytical methods used
• Laboratory bench sheets indicating all raw data used in calculation of results (unless a
contract lab performed analysis for the permittee)
• Sampling and analytical QA/QC procedures.
8.6.7 CLASS A ALTERNATIVE 5
Statement of Regulation
§S03.32(a)(7) Class A - Alternative 5
(i) Either the density of fecal coIKbrm in the sewage sludge shall be Jess than 1000 Most
Probable Number per gram of total solids (dry weight basts), or the density of $ Sewage sludge that is used or disposed shall be treated m one pf the Processes to Further
Reduce Pathogens described in Appendix B of this part.
8-20
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART, 503 SUBPART D
Statement of Regulation
APPENDIX B - PATHOGJEI* TTREATMENT PROCESSES
B, Processes to Further ..Reduce Pathogens (PFRJPK , ,
I, Composting ' -
Using either the within-vessel composting method or the static aerated pile composting •>
method, the temperature of the sewage sludge is maintained at 55 degrees Celsius Or
higher For three days.
Using the windrow composting method,, the; temperature of the sewage sludge is
maintained at 55'degrees Celsius or higher for IS days or longer. During the period
when the compost is maintained at 55,degrees Celsius or higher, there must be 8
minimum of five turnings; of the windrow,
2,; Heat drytog - v
Sewage stodge is dried by direct or indirect; contact mfh hot gases to reduce '
the moisture content of the' sewage sludge to 16 percent or tower. Either the
temperature of the sewage sludge particles exceeds 80 degrees Celsius or the
wet bulb temperature of the gas in contact with the sewage sludge as the
sewage sludge leaves the dryer exceeds 80 degrees Celsius.
3. Heat treatment
Liquid sewage sludge is heated to a temperature of 180 degrees Celsius or greater for
30 minutes, , , , ,
4. Thermophilic aerobic digestion
Liquid sewage sludge Is agitated with air or oxygen to maintain, aerobic conditions and
the mean cell residence time of the sewage sludge is 10 days at 55 to 60 degrees Celsius.
5, Beta ray irradiation
Sewage sludge is irradiated with beta rays from an accelerator at dosages of at least 1.0
megarad at room temperature (ca. 20 degrees Celsius).
6. Gamma ray irradiation ' ' •• ,
Sewage sludge is irradiated with gamma rays from certain isotopes, such as Cobalt 60
and Cesium 137, at dosages of at least 1.0 megarad at room temperature (ca* 20
degrees Celsius).
7. Pasteurization
The temperature of the sewage sludge is maintained at 70 degrees Celsius or higher for
3D minutes or longer.
This alternative requires the sewage sludge be treated in one of the PFRPs and that the PFRP be operated
in accordance with the above description at all times. These processes are those originally defined in Part
257 as Processes to Further Reduce Pathogens (PFRPs) with the vector attraction reduction requirements
(e.g., volatile solids reduction) deleted from the description. In addition to being treated in a PFRP, the
density of either fecal coliform or Salmonella sp. bacteria has to be equal to or less than the value
presented above at the time the sewage is used or disposed. Suggested monitoring and record-keeping
requirements are provided below.
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
FREQUENCY OF MONITORING
Pathogen Parameters
Salmonella or fecal coliform
Frequency
Once per year, quarterly, bimonthly, or monthly
(see Table 8-1)
Operating Parameters
Composting
- Temperature of sewage sludge during
composting process
Heat drying
- Moisture content of dried sewage sludge
- Temperature of sewage sludge particles or
wet bulb temperature of exit gas
Heat treatment
- Temperature of sewage sludge during
treatment
Thermophilic aerobic digestion
- Temperature of sewage sludge in digester
Beta ray irradiation
- Dosage
Gamma ray irradiation
- Dosage
Pasteurization
- Temperature of sewage sludge during
treatment
Frequency
Continuous or periodic during treatment
Once at end of treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Salmonella or Fecal Coliform
Date and time of sample collection, sampling location, sample type, sample volume, name of
sampler, type of sample container, and methods of preservation, including cooling
Date and time of sample analysis, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless
a contract lab performed the analyses for the preparer) .
Sampling and analytical QA/QC procedures '
8-22
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
RECORDS OR DOCUMENTATION
Records of Operating Parameters
Composting
- Description of composting method
- Logs documenting time temperature
maintained above 55°C (at least 2 readings
per day 7 or more hours apart)
- Logs documenting compost pile turned at
least 5 times during period temperature
remains above 55°C, if windrow compost
method
Heat drying ,
- Moisture content of dried sewage sludge
- Logs documenting temperature of sewage
sludge particles, or wet bulb temperature
of exit gas exceeds 80°C (either continuous
chart or a minimum of 2 readings per day
7 or more hours apart)
Heat treatment ;
- Logs documenting sewage sludge heated to
temperatures greater than 180 °C for 30
minutes (either continuous chart or 3
readings at 10 minute intervals)
Thermophilic aerobic digestion
- Logs documenting temperature maintained
at 55-60° C for 10 days (at least 2 readings
per day 7 or more hours apart)
Beta ray irradiation
- Beta ray dosage
- Ambient room temperature log (either
continuous chart or a minimum of 2
readings per day 7 or more hours apart)
Gamma ray irradiation
- Gamma ray isotope used
- Ambient room temperature log (either
continuous chart or a minimum of 2
readings per day 7 or iriore hours apart)
Pasteurization
- Time temperature maintained above
70°C
(either continuous chart or a minimum of
2 readings per day 7 or more hours
apart)
8-23
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.6.8 CLASS A ALTERNATIVE 6
State of Regulation
|503.32(a)(8) Class A « Alternative «
(i)
Either the density of fecal coliform in the sewage sludge shall he less than 1000 Most
Probable Number per gram of total solids (dry weight basis), or the'density of Salmonella,
sp. bacteria in the sewage sludge shall be less than three Most Probable Number per four
grams of total solids,{dry weight basis) at the time the sewage sludge is used or disposed;
at the time the sewage sludge is prepared for sale or give away in a bag or other container
for application to the land; or at the time the sewage sludge or material derived from
sewage sludge fe prepared to meet the requirements in 503«iO(b), S03.1^0(c), S03,10(e), or,
" " *' '
(ii) Sewage sludge that is used or disposed shall be treated in a process that is equivalent to a
Process to Further Reduce Pathogens, as determined by the permitting authority.
This alternative requires that the sewage sludge be treated in a process that is equivalent to a PFRP. The
permitting authority will determine whether a process is equivalent to a PFRP based on information
submitted by the person requesting such a designation. In deciding whether a process is a PFRP, the
permitting authority may request assistance from EPA's Pathogen Equivalency Committee (PEC). The
PEC, which includes representatives from the Office of Research and Development and the Office of
Water, was established in 1985 to provide technical assistance on pathogen and vector attraction reduction
issues. . ,
PFRP equivalency determinations only will be made with respect to the reduction of enteric viruses and
viable helminth ova in the sewage sludge. Equivalency determinations will not be made for the reduction
of Salmonella sp. bacteria because of the regrowth requirement for a Class A sewage sludge. To prevent
regrowth, the density of fecal coliform or Salmonella sp. bacteria in the sewage sludge has to be 1000
MPN per gram of total solids or three MPN per four grams of total solids, respectively, at the time the
sewage sludge is used or disposed.
For additional information on PFRP equivalency, see Environmental Regulations and Technology, Control
of Pathogens and Vector Attraction in Sewage Sludge, (EPA, 1992).
FREQUENCY OF MONITORING
Parameters
Salmonella or fecal coliform
Operating parameters
Frequency
Once per year, quarterly, bimonthly,
(see Table 8-1)
Specific to process
or monthly
RECORDS OR DOCUMENTATION
Records of Operating Procedures
• Specific to the process
8-24
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\,
8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Salmonella or Fecal Coliform
Date and time of sample collection, sampling location, sample type, sample volume, name of
sampler, type of sample container, and methods of preservation, including cooling
Date and time of sample analysis, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless
a contract lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures ,
8.7 CLASS B PATHOGEN ALTERNATIVES
For sewage sludge to be classified Class B with respect to pathogens, the requirements in one of the
following three alternatives must be met. The objective of these alternatives is to reduce Salmonella
bacteria, enteric viruses, and viable helminth ova in the sewage sludge.
Table 8-2 summarizes the Class B alternatives applicable to land application and surface disposal of
sewage sludge.
TABLE 8-2 CLASS B PATHOGEN ALTERNATIVES
X ""
" Use or Disposal Practice
Bulk sewage sludge applied to agricultural land/forest/
public contact sites/reclamation sites
Bulk sewage sludge applied to lawns and home
' gardens
Sewage sludge sold or. given away in a bag or other
container for application to1 the land
Surface disposal v
Class B Alternatives
i \ ,
, X
**
**
x***
s 2
X
**
**
x***
3
X
**
**
x***
Site Re$trietion
-Met
X*
-.
J ,
- ' '..
*The site restrictions in §503.32(b)(5) have to be met if one of the Class B pathogen alternatives is met.
**Not allowable for these types of land; the Class A pathogen alternatives must be met when bulk sewage
sludge is applied to lawns or home gardens or sewage sludge is sold or given away in a bag or other container
for application to the land.
***Either the Class A or Class B pathogen requirements have to be met when sewage sludge is placed on an
active sewage sludge unit unless the vector attraction requirement in §503.33(b)(ll) (i.e., the sewage sludge
is covered with soil or other material at the end of each-operating day) is met.
The Class B alternatives rely on a combination of treatment of the sewage sludge and prevention of
exposure to the sewage sludge after it is use or disposed to protect public health and the environment
from pathogens in the sewage sludge. In the case of land application, exposure is prevented through
restrictions on the land application site (e.g., do not harvest root crops for 38 months after application
8-25
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
of the sewage sludge). For surface disposal, exposure is prevented through the Part 503 surface disposal
management practices (e.g., do not graze animals). ,
A summary of each Class B pathogen alternative is presented below.
8.7.1 ORDER OF PATHOGEN AND VECTOR ATTRACTION REDUCTION
There is no requirement that pathogen reduction occur either prior to or at the same time as vector
attraction reduction for a Class B sewage sludge. When the Class B requirements are met, there are
enough competitive bacteria remaining in the sewage sludge to prevent rapid regrowth of Salmonella sp.
bacteria. In addition, both the site restrictions that have to be met when a Class B sewage sludge is land
applied and the management practices for surface disposal of sewage sludge .prevent exposure to the
sewage sludge after it is used or disposed. This provides time for the environment to further reduce
pathogens remaining in the sewage sludge.
8.7.2 CLASS B ALTERNATIVE 1
Statement of Regulation -;
-. ^v^* wrt ^ ^ •• •>
§503,32(b)C2) Class &« Alternative X
^ -j *, -.* f fffff f ft : "" v v[ * ""
I ,! 'l it f<<: tv> ^y
(i) Seven representative samples of the «ewdge sludge that is used pr disposed shall be
collected, ' , ,. ,,
(ii) The geometric mean of the density of fecal colifornn in the samples collected! m paragraph
(b)(2)(i) of this section shall be less than either 2/ Most Probable Number pe* grant
of total solidg (dry M-eight basis) or 2,000,000 Colony *Wmmg Units per grsqn of total solids
(dry weight basis}* ' '" " '"^ * ' "
This alternative requires that the geometric mean of
the fecal coliform densities of seven samples be
less than:
• 2,000,000 MPN per gram total solids (dry
weight basis), or
• 2,000,000 Colony Forming Units per gram
of total solids
(dry weight basis).
^ Qf
- of n numbers. fnthiscasei
V -ffft f % ttrr**? f
x
* ^ * *' *
. ,
**** **
*'
For this alternative, seven samples of the sewage
sludge have to be taken during each monitoring episode and each sample has to be tested for fecal
coliform. The geometric mean of the fecal coliform densities for those seven samples has to be below
the above values for the sewage sludge to be Class B with respect to pathogens.
The geometric mean of seven samples is used in this alternative to reduce the standard error of the mean
fecal coliform density. This accounts for variability in the fecal coliform density in the sewage sludge.
8-26
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
The above fecal coliform density is the value that typically is achieved when sewage sludge is treated in
an anaerobic digester. Pathogens in a Class B sewage sludge are further reduced by the environment
when the sewage sludge is used or disposed.
FREQUENCY OF MONITORING
Pathogen Parameters
Fecal coliform
Frequency
Once per year, twice per year, quarterly, or
monthly (see Table 8-1)
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Fecal Coliform '. .
Date and time of sample collection, sampling location, sample type, sample volume, name of
sampler, type of sample container, and methods of preservation, including cooling
Date and time of sample analysis, name of analyst, and analytical methods used ,
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless
a contract lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures
8.7.3 CLASS B ALTERNATIVE 2
Statement of Regulation
, §503.32
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Statement of Regulation
3, Anaerobic digestion
"* "
Sewage sludge is treated lit the absence of ait fat a specific mean cell residence time
' at & specific temperature. Values for the mean cell residence time and temperature
shall Be between 15 days at 35 degrees Ce&ius and 55 degrees Celsius and 60 days at
20 degrees Celsius* f
* r ' v '
4, Composting v '
>, % •'•'*• '
Using either the^within-vesSfcl, static aerated pile;, OrMrodroWcomposting methods, the
temperature of the sewage sludge is raised to 40 degrees Celsius or higher and remains
at 40 degrees Celsius or higher for five days. For four hours during the five days, the
temperature in the compost pile exceeds 55 degrees Celsius.^
~ ' "
5, Lime stabilization
•V V
Sufficient lime is added to the sewage sludge to raise the pH of the sewage sludge to
?^>-->A \.*™- X/* -. > ^ 4' A Xt ^ < X
12 after two hours of contact.
This alternative requires that the sewage sludge be treated in one of the PSRPs and that the PSRP be
operated in accordance with the above description at all times. These processes are those originally
defined in Part 257 as Processes to Significantly Reduce Pathogens with the vector attraction reduction
requirements (e.g., reduce volatile solids) deleted from the description. Treatment can occur any time
prior to use or disposal. . ,
FREQUENCY OF MONITORING
Operating Parameters
Aerobic digestion
- Temperature of sewage sludge during
treatment
Air drying
- Daily average ambient temperature
Anaerobic digestion
- Temperature of sewage sludge during
treatment
Composting
- Temperature of sewage sludge during
treatment
Lime stabilization
- pH of sewage sludge
Frequency
Continuous or periodic during treatment
At least once per day during drying period
Continuous or periodic during treatment
Continuous or periodic during treatment
At least twice, once upon addition of lime and
once 2 hours after addition
8-28
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, 8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
RECORDS OR DOCUMENTATION
Records of Operating Parameters
Aerobic digestion
- Mean residence time of sewage sludge in
digester
- Logs showing temperature was
maintained for sufficient period of time
(ranging from 60 days at 15°C to 40 days
at 20°C) (continuous charts or 2 readings
per day at least 7 hours apart)
Air drying
- Description of drying bed design
- Depth of sewage sludge on drying bed ,
- Drying time in days
- Daily average ambient temperature
Anaerobic digestion
- Mean residence time of. sewage sludge in
digester5
- Logs showing temperature was ,
maintained for sufficient period of time
(ranging from 60 days at 20°C to 15 days
at 35 °C) (continuous charts or 2 readings
per day at least 7 hours apart)
Composting
- Description of composting method
- Daily temperature logs documenting
sewage sludge maintained at 40°C for 5
days (at least 2 readings per day 7 or
more hours apart)
- Hourly readings showing temperature
exceeded -55 °C for 4 consecutive hours
Lime stabilization
- pH of sewage sludge immediately and
then 2 hours after lime addition
8.7.4 CLASS B ALTERNATIVE 3
Statement of Regulation
§S03,32(b)(4) Class B - Alternative 3
'Sewage sludge that is used or disposed shall be treated in a process that is equivalent to a
Process to Significantly Reduce Pathogens, as determined by the permitting authority.
This alternative requires that the sewage sludge be treated in a process that is equivalent to a PSRP. The
permitting authority will determine whether a process is equivalent to a PSRP based on information
submitted by the person requesting such a designation. In deciding whether a process is a PSRP, the
permitting authority may request assistance from EPA's Pathogen Equivalency Committee. For more
information on PSRP equivalency, see Environmental Regulations and Technology, Control of Pathogens
and Vector Attraction in Sewage Sludge, (EPA, 1992).
FREQUENCY OF MONITORING/RECORDS OR DOCUMENTATION
Frequency of Monitoring Records of Operating Parameters
Specific to the process. • ;
-------
8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.7.5 CLASS B SITE RESTRICTIONS
Statement of Regulation
§S03.32(b)(5) Site Restrictions
(i)
m.
(iv)
(vi)
Food crops with harvested parts that touch the sewage sludge/soil mixture and are
totally above the land surface shall not be harvested for 14 months after application of" "
sewage sludge, '.',,",,' ', , ~ ""
Food crops with harvested parts below the surface of the land shall not be harvested for
20 months after application of sewage sludge when the sewage sludge remains on the
land surface for 4 months or longer prior to'incorporation into the soil.
•• ,.•*!•
Pood crops with harvested parts below the surface of the land shall not beKiafvested for
38 months after application of sewage sludge when the sewage sludge remains on the
land surface for less than 4 months prior to incorporation into the soil.
(Viil)
Food crops, feed crops, and fiber crops shall not be'harvested^o* 30 days after
application of sewage sludge.
Animals shall not be grazed on the land for 30 days after application of sewage sludge,
Turf grown on land where sewage sludge is applied shall not be harvested for 1 year
after application of the sewage sludge when the harvested turf is placed on either land
with a high potential for public exposure or a lawn/'u'nfess otherwise specified by thfc
permitting authority.
•- ^ •* * v^ ' >> * / «&*"•>
public access to land with a high potential for public exposure shall be restricted for 1
year after application of sewage sludge. <• <. * <",
/ •f s ' £ % ^
Public access to land with a low potential for puTblic exposure shall be restricted for 30
days after application of sewage sludge.
Because of the likelihood that pathogenic organism remain in a Class B sewage sludge, the site restriction
presented above have to be met when a Class B sewage sludge is applied to the land. These restrictions
prevent exposure to the sewage sludge and provide time for the environment to reduce the pathogens in
the sewage sludge to below detectable levels.
The site restrictions.for crops require that crops not be harvested for a period after application of the
sewage sludge. These restrictions assume a 2-month growing period before a crop is harvested. For
example, the 14-month restriction on harvesting a food crop whose harvested parts touch the sewage
sludge/soil mixture assume a crop will not be grown for 12 months and a 2-month, growing period before
harvest. ,
The site restriction for crops with harvested parts below the land surface addresses die-off of viable
helminth ova. There is evidence that viable helminth ova can survive below the land surface for 36
months if the sewage sludge is incorporated into the soil within 4 months after being land applied. For
this reason, the site restriction requires that a crop such as potatoes, radishes, or carrots not be-harvested
within 38 months (36-month restriction plus 2-month growing period) after the sewage sludge is applied
to the land.
8-30
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
If the sewage sludge remains on the surface of the land for 4 months ,or longer before it is incorporated
into the soil, the period before harvest of crop with harvested parts below the land surface is reduced to
20 months (18-month restriction plus 2-month growing period). During the 4-mpnth period,
environmental conditions reduce the viable helminth ova in the sewage sludge.
Table 8-3 lists examples of food crops subject to the Class B harvesting restrictions.
TABLE 8-3 EXAMPLES OF CROPS AFFECTED BY THE CLASS B HARVESTING
RESTRICTIONS
Crops with Harvested Parts That Towcli the
Ground
Crops with Harvested Parts Below the Ground
Melons
Eggplant
Squash
Tomatoes
Cucumbers
Celery
Strawberries
Cabbage
Lettuce
Potatoes
Yams
Sweet Potatoes
Mushrooms
Onions
Leeks
Radishes
Turnips
Rutabaga
Beets .
The Class B site restrictions also require that no crop, whether it has harvested parts that touch the
sewage sludge/soil mixture, are below the ground, or are above the ground, be harvested within 30 days ,
after application of the sewage sludge. This 30-day period is part of the above periods before crops^that
touch the sewage sludge/soil mixture and crops that are below the land surface can be harvested. The
30-day period allows the environment to reduce pathogens in the Class B sewage sludge before crops with
parts above the ground are harvested.
There also is a 30-day restriction on grazing of animals after a Class B sewage sludge is land applied
because sewage sludge can adhere to animals that walk on the application site and then contact humans.
Thus, this is a potential pathway of exposure for humans to pathogens in the sewage sludge. Note that
the intent of this site restriction is to not allow managed grazing of animals (e.g., milk cows and riding
horses) on the application site. This is different from transient grazing of the application site by wildlife.
The other site restrictions for a Class B sewage sludge restrict access to the sewage sludge by the public.
When turf grown on the application site is harvested for placement on land with high potential for public
exposure or a lawn, the harvesting restriction is 1 year after application of the sewage sludge. This,is
the same as the restriction for land with a high potential for public exposure on which a Class B sewage
sludge is applied. In both cases, there is a high potential that the public could contact the sewage sludge
after it is land applied and be exposed to the pathogens in the sewage sludge.
In the case where a Class B sewage sludge is applied to turf that is placed on land with a high potential
for public exposure or a lawn, the permitting authority may reduce the 1 year restriction oh harvesting
of the turf. An example when this may be appropriate is where turf is placed on land around a building
that will not be ready for occupancy within a year after sewage sludge is applied to the land on which
the turf is grown. In this situation, public access to both the land on which; the turf is grown and to the
8-31
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
land on which the turf is placed could be restricted for 1 year. This would prevent exposure to the
sewage sludge and allow the environment to reduce pathogens in the sewage sludge.
The public access restriction for land with a low potential for public exposure (e.g., a farm) is 30 days.
Thirty days is the minimum period needed for the environment to reduce pathogens in a Class B sewage
sludge. The 1-year access restriction is not needed in this case because it is unlikely that the public will
be exposed to the sewage sludge.
8.8 VECTOR ATTRACTION REDUCTION OPTIONS
One of 11 vector attraction reduction options in Part 503 has to be met when sewage sludge is land
applied or placed on a surface disposal site. Vector attraction reduction is achieved in the first eight
options through treatment of the sewage sludge. For the last three options, vector attraction reduction
is achieved by placing a barrier between the sewage sludge and the vector (e.g., injecting the sewage
sludge below the land surface). The applicability of the vector attraction reduction options is presented
in Table 8-4.
x TABLE 8-4 VECTOR ATTRACTION REDUCTION OPTIONS
FOR EACH USE OR DISPOSAL PRACTICE
Vector Attraction Reduction Option
Use or Disposal Practice
Bulk sewage sludge applied to
agricultural land/forest/public contact
sites/reclamation sites
Bulk sewage sludge applied to lawns
or home gardens
Sewage sludge sold or given away in
a bag or other container for
application to the land
Surface disposal
1
X
X
X
X
2
X
X
X
X
3
X
X
X
X-(
4
X
X
X
X
5
X
X
X
X
6
X
X
X
X
7
X
X
X
X
8
X
X
X
X
9
X
X
10
X
X
11
X
Each of the vector attraction reduction options is discussed below.
8.8.1 VECTOR ATTRACTION REDUCTION OPTION 1
Statement of Regulation
§50333(b)(l) The mass of volatile solids in the sewage stodge sliatt be reduced fay a minimum of 38 percent.
Option 1 requires that the mass of volatile solids in the sewage sludge be reduced by a minimum of 38
percent. This is achieved typically by treating the sewage sludge in an aerobic or anaerobic digester.
During treatment, most of the biodegradable material in the sewage sludge is degraded, thus reducing the
attractiveness of the sewage sludge to vectors.
5-32
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
To calculate percent volatile solids reduction, the mass of volatile solids in the sewage sludge prior to
entering the stabilization process and the mass of volatile solids in the sewage sludge that is used or
disposed is determined. Percent volatile solids reduction is then calculated using those data and other
appropriate data^ in an equation. The equations that can be used include the full mass balance equation,
the approximate mass balance equation, the constant ash equation, and the Van Kleeck equation. For
more information on these equations, see Appendix C in Environmental Regulations and Technology,
Control of Pathogens and Vector Attraction Reduction, (EPA, 1992).
In calculating percent volatile solids reduction, credit can be/given for any volatile solids reduction that
occurs from the influent to the sewage sludge stabilization process through other treatment processes
before the sewage sludge leaves the treatment works. For example, if the sewage sludge is treated in an
anaerobic digester and then dewatered in sand drying beds, percent volatile solids reduction can be
calculated from the influent to the digester to the dewatered sewage sludge that leaves the treatment
'works. Credit can not be given, however, for volatile solids reduction achieved in any wastewater
treatment process.
FREQUENCY OF MONITORING
Parameter
Volatile solids
Once per year,
(see Table 8-1)
Frequency ,
quarterly, bimonthly,
or monthly
RECORDKEEPING ;
• Volatile solids concentration
disposed
• Information on method- used
of in influent sewage sludge and in sewage sludge that is
to determine volatile solids .
used or
8.8.2 VECTOR ATTRACTION REDUCTION OPTION 2
Statement of Regulation • v
—"' '"'t f f
§5(B.33(h)(2) When the 38 percent volatile solids reduction requirement in 503.33(b)(l) cannot be met for an
anaerobically digested sewage stodge, vector attraction reduction can be demonstrated by
digesting A portion of the previously digested sewage sludge aiiaeroblcally id the laboratory in
a bench-scale unit for 40 additional days at a temperature between 30 and 37 degrees Celsius,
• When at the end of the 40 days, the volatile solids in the sewage sludge at the beginning df that
period is reduced by less than 17 percent, vector attraction reduction is achieved.
Often, a sewage sludge is well-stabilized (i.e., has a low mass of volatile solids) when it enters either an
aerobic or anaerobic digester. As a-resultj the volatile solids content of the sewage sludge can not be
reduced an additional 38 percent through digestion. In cases like this, vector attraction reduction cai^bfe
demonstrated by shpwing that the percent volatile solids is reduced by less than a certain percentage after
further treatment in a bench-scale unit. This is the approach taken hi this option and in Option 3.
Option 2 applies to a sewage sludge that has been treated in an anaerobic process. If a sample of the
sewage sludge is treated further hi an anaerobic bench-scale unit and if the percent volatile solids
reduction during this period is less than 17 percent, vector attraction reduction is achieved. The
following conditions have to be met during the bench-scale test:
8-33
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
1. A sample of the anaerobically digested sewage sludge has to be digested anaerobically in the
laboratory in a bench-scale unit at a temperature between 30°C and 37°C for 40 days.
2. After 40 days, the mass of volatile solids in the sewage sludge at the beginning of the test has
to be reduced by less than 17 percent.
In developing this option, EPA relied on percent volatile solids reduction calculated using the Van Kleeck
equation. A sewage sludge that meets this option when the Van Kleeck equation in used to calculate
percent volatile solids reduction may fail this option if a different equation is used (e.g., the mass balance
equation). Therefore, EPA recommends that the Van Kleeck equation be used if this option is met.
FREQUENCY OF MONITORING
Volatile solids
Parameter
Once per year,
(see Table 8-1)
Frequency
quarterly, bimonthly, or monthly
RECORDKEEPING
• One-time description of bench-scale digestion
• Time (days) that sewage sludge was further digested in bench-scale digester
• Temperature (degrees Celsius) maintained while sewage sludge was in digester (at least
per day)
2 readings
8.8.3 VECTOR ATTRACTION REDUCTION OPTION 3
Statement of Regulation , / ;, -„ „„,, ,
\ "" ^ ^ ff ^ •* ^ *• w •> y
§503.33(fa)(3) When the 38 percent volatile solids reduction requirement to 503,33(b)(D cannot be met for an
aerobically digested sewage sludge, vector attraction reduction can be demonstrated by digesting
a portion of the previously digested sewage sludge that has a percent solids of two percent or less
aerobicaily in the laboratory in a bench-scale unit for 30 additional days at 20 degrees Celsius.
When at the end of the 30 days, the volatile solids in the sewage sludge at the beginning of that
period is reduced by less than IS percent, vector attracting reduciibn is achieved.
This option is similar to Option 2 except in this case the sewage sludge has been digested aerobicaily.
If a sample of the aerobicaily digested sewage sludge that has a percent solids of two percent or less is
treated further hi an aerobic bench-scale unit for 30 days and if the mass of volatile solids in the sewage
sludge at the beginning of the test is reduced by less than 15 percent, vector attraction reduction is
achieved. The following conditions have to be met during the bench-scale test:
1. A sample of aerobicaily digested sewage sludge having less than two percent solids has to be
digested aerobicaily in a bench-scale unit for 30 days at a temperature of 20°C.
2. After 30 days, the mass of volatile solids in the sewage sludge at the beginning of the test has
to be reduced by less than 15 percent.
8-34
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
The 15 percent volatile solids reduction requirement in this option also is based on information obtained
using the Van Kleeck equation. For the reasons mention above in Option 2, EPA recommends that the
Van Kleeck equation be used to calculate volatile solids reduction when this option is met.
FREQUENCY OF MONITORING
Parameter Frequency
Once per year, quarterly, bimonthly, or monthly
Volatile solids (see Table 8-1)
RECORDKEEPING
• One-time description of bench-scale digestion ,
• Time (days) that sewage sludge was further digested in bench-scale digester
• Temperature (degrees Celsius) maintained while sewage sludge was in digester (at least
per day) ,
2 readings
8.8.4 VECTOR ATTRACTION REDUCTION OPTION 4
Statement of Regulation ^ • "
-|S03.33(b)(4) The Specific oxygen uptake rate (SOXJR) for sewage stodge treated in an aerobic process shall
be equal fo or less than 1.S milligrams of oxygen per hour per gram of total solids (dry weight
basis) at a temperature of 20 degrees Celsius, , -
Option 4 provides another way to demonstrate vector attraction reduction for sewage sludge treated in
an aerobic process. As indicated above, 38 percent volatile solid reduction may not be achieved because
the sewage sludge entering an aerobic digester already is partially stabilized. This is frequently the case
for sewage sludges held or circulated in wastewater treatment processes for longer than 30 days.
Vector attraction reduction is achieved for an •
aerobically digested sewage sludge if the specific
oxygen uptake rate (SOUR) for the sewage sludge
is equal to or less than 1.5. milligrams of oxygen
per hour per gram of total solids (dry weight
basis) at 20°C. Note that the unit of
measurement for the sewage sludge is total solids
on a dry weight basis, not volatile solids.
The SOUR test is applicable only to aerobic liquid
sewage sludges with two percent solids or less i
that have not been deprived of oxygen for more
than two hours. Thus, this test is not appropriate
anaerobic sewage sludge (e.g., sewage sludge in an
Specific Oxygen Uptake Safe (SOUR) -
SOUS, is a measure of the rate of oxygen
utilization'of a wastewater mixed liquor or
sludge. In general, SOUR is the oxygen
uptake rate, in milligrams of dissolved
oxygen per hour per gram of volatile solids.
Oxygen uptake rate is measured using a
device known as a respirometef.
for dewatered sewage sludge, compost, and liquid
anaerobic lagoon).
8-35
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
FREQUENCY OF MONITORING
SOUR
Parameter
Frequency
Once per year, quarterly, bimonthly, or monthly
(see Table 8-1)
RECORDKEEPING
• Dissolved oxygen readings for sewage sludge sample over 15-minute period (mg/L)
• Calibration records for the DO meter
• Temperature (degrees Celsius) at beginning and end of DO readings
• Total solids for sewage sludge sample (g/L)
• SOUR calculations (mg/h/g)
8.8.5 VECTOR ATTRACTION
Statement of
§S03.33(b){5)
Regulation
REDUCTION
OPTIONS
<• t ., j
J ' •* S JSf- s J
Sewage sludge shall be treated ui an aerobic process for J4 days or longer. Paring that time,
the temperature of the sewage sludge shall be higher than 40 degrees Celsius and the average
temperature of the sewage sludge shall be higher than 45 degrees Celsius.
For some sewage sludge aerobic processes, such as composting, it is not possible to determine the percent
of volatile solids reduction. This option provides a way to demonstrate vector attraction reduction for
those processes.
For this option, specific process operating parameters have to be met. They are:
• The sewage sludge has to be treated aerobically for a minimum of 14 days; and
• The temperature of the sewage sludge has to remain above 40 °C at all times during the 14 day-
period; and
• The average temperature of the sewage sludge over the 14-day period has to be higher than
45°C.
The most common sewage sludge process for which Option 5 applies is composting. This option also
could be used, however, to demonstrate vector attraction reduction for other sewage sludge aerobic
processes such as aerobic digestion. '
FREQUENCY OF MONITORING
Parameter
Sewage sludge temperature/time maintained
Continuous or
Frequency
periodic during treatment
RECORDKEEPING
• Description of treatment process
• Log documenting time temperature was above 40°C (at least 2
apart)
• Log documenting average temperature of sewage sludge
readings per day 7 or more hours
8-36
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.8.6 VECTOR ATTRACTION REDUCTION OPTION 6
Statement of Regulation
§503,33
In this option, vector attraction reduction is achieved by adding alkali to the sewage sludge. Alkali does
not change the composition of the sewage sludge, but instead causes a stasis in biological activity. When
this occurs, vectors are not attracted to the sewage sludge because it no longer contains putrefying
material. Vector, attraction reduction is achieved in this option by:
• Raising the pH of the sewage sludge to 12 or higher by adding alkali to the sewage sludge; and
• Maintaining the pH of the sewage sludge at 12 or higher for at least two hours without the
addition of more alkali; and
» Maintaining the pH of the sewag6 sludge at 11.5 or higher for another 22 hours without the
addition of more alkali.
As mentioned above, alkali addition only causes a stasis, in the biological activity in the sewage sludge.
If the pH should drop, the surviving bacterial spores could become active biologically, which could cause
the sewage sludge to putrefy and attract vectors. This could happen, for example, if the sewage sludge
is stored for long periods after the pH of the sewage sludge is adjusted (see discussion in section 8.3). ,
Information used to develop this option is based on pH measured at 25°C, thus, the pH either should be
measured at 25°C or the measured pH value should be corrected to 25°C. See ^Section 8.6.4 for the
correction equation.
FREQUENCY OF MONITORING
pH of sewage
Parameter
sludge/time maintained
Frequency
Beginning, middle, and end of treatment
RECORDKEEPING
• pH 'of sewage sludge/alkali mixture measured at 25° C
• Hours pH was maintained .
* Amount of alkali added to sewage sludge (Ibs or gal)
• Amount of sewage sludge treated ' . - ' • ' < •
8-37
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
8.8.7 VECTOR ATTRACTION REDUCTION OPTION 7
Statement of Regulation I , >
§503.33(b)C7) The percent solids of sewage sludge that does not contain uiistabilized solids generated in a
primary wastewater treatment process shall be equal to or greater than 75 percent based on the
moisture content and total soiids prior to mixing with other materials at the time the sewage
sludge is used or disposed, at the time the sewage sludge is prepared for sale or given away in
a bag or other container for application to the land, or at the time the sewage sludge is prepared
to meet the requirements in §503.IO(b), (c), (e), or (f).
This option applies to sewage sludge that does not contain unstabilized solids generated in a primary
wastewater treatment process. Sewage sludge included in this category include secondary, tertiary,
stabilized primary, and other stabilized sewage sludges. The sewage sludge cannot contain unstabilized
solids because organic material, such as partially degraded food scraps, in the sewage sludge can attract
vectors even though the solids content is 75 percent or higher.
Under this option, sewage sludge must be dried to a percent solids of 75 percent or higher before mixing
with other materials. Thus, the percent solids requirement must be met by removing water from the
sewage sludge rather than by adding inert material to the sewage sludge. Materials that reduce moisture
by reaction (e.g., lime), by adsorption, or as water of crystallization can be used to raise the percent
solids content of the sewage sludge.
When this option is used to reduce the attractiveness of the sewage sludge to vectors, the dried sewage
sludge should be handled in such a way to ensure that the moisture content of the sewage sludge does not
increase before use or disposal. If the dried sewage sludge becomes wet before it used or disposed,
vectors could be attracted to the sewage sludge.
FREQUENCY OF MONITORING
Parameter
Percent solids
FreQoency
Once per year, quarterly, bimonthly,
(see Table 8-1)
or monthly
RECORDKEEPING
• Percent solids
• Absence of unstabilized solids generated during primary treatment
8.8.8 VECTOR ATTRACTION REDUCTION OPTION 8
Statement of Regulation , ' ' ,,
', " ..
§S03.33(b)(8) The percent solids of sewage sludge that contains trastaoiliasd solids generated 'in a primary
Wastewater treatment process shall be equal to or greater'than $0 percent based'onthe moisture
content and total solids prior to mixing with other materials at the time the sewage sludge is used
or disposed,, at the time the: sewage sludge is prepared for sale or given away in a bag or other
container for application to the land, or at the time the sewage sludge is prepared to meet the
requirements in §S03.100>)> (c),, (e), OP (f)* " *'"
8-38
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
This option is applicable to sewage sludge that contains unstabilized, solids generated in a primary
wastewater process. Even though the sewage sludge contains unstabilized solids, a solids content of 90
percent or greater is sufficient to reduce the attractiveness of the sewage sludge to vectors. As with
Option 7, the percent solids must be achieved by removing water, not by adding inert materials.
In addition, the percent solids of the sewage sludge should not be reduced1 prior to when the sewage
sludge is used or disposed. If the sewage sludge becomes wet, vectors could be attracted to the sewage
sludge. For this reason, the sewage sludge should be handled in a such a way to ensure that the moisture
content of the sewage sludge is not increased after the percent solids requirement in this option is met
and before the sewage sludge is used or disposed.
FREQUENCY OF MONITORING
Parameter
Percent solids
Frequency
Once per year, quarterly, bimonthly,
(see Table 8-1)
or monthly
RECORDKEEPING
• Percent solids , .
• Absence of unstabilized solids generated during primary treatment
8.8.9 VECTOR ATTRACTION REDUCTION OPTION 9
Statement of Regulation
§503.33{b)(9)
-------
8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Special restrictions are included in this option for a Class A sewage sludge because of the concern for
regrowth of Salmonella sp. bacteria. During the first eight hours after the sewage sludge is discharged
from the pathogen reduction process, levels of pathogenic bacteria in a Class A sewage sludge remain
low. After eight hours, pathogenic bacteria may regrow rapidly.
FREQUENCY OF MONITORING
Parameter
Time between end of Class A pathogen treatment
process and injection
Frequency , ,
Each time sewage sludge is injected below the
land surface < -
RECORDKEEPEVG
• Description of application site '
• Log indicating sewage sludge was injected below the land surface
• Log indicating no significant amount of sewage sludge remains on the land surface within one
hour after application
8.8.10 VECTOR ATTRACTION REDUCTION OPTION 10
Statement of Regulation , , ; ! v ,
"-"""- "-"'— ' ----------- *- ^ ------------------ > ^ 5
,, f -, ' ^ •"" i X > 1.4. •& ff
§503.33(b)(lO) (I) Sewage sludge applied to the land surface V placed on a surface disposal site shafl be
incorporated into the soil within six hours after application to or placement on the land,
unless Otherwise specified by the permitting authority.
(ii> When sewage stodge that is incorporated Ifito' ike soil is Class A with respecF
the sewage sludge shall be applied to or placed on the fend within eight hours after being
discharged from the pathogen treatment process. "*' •.
This is the second of the barrier options for vector attraction reduction. It only applies to bulk sewage
sludge applied to agricultural land, forest, a public contact site, or a reclamation site and to sewage sludge
placed on a surface disposal site.
Vector attraction reduction is achieved in this option by incorporating sewage sludge that is applied to
the land surface into the soil within 6 hours after it is land applied. Incorporation is done by "turning
over" or plowing the land on which the sewage sludge is applied. This results in the mixing of the
sewage sludge with the upper 6-12 inches of the soil. The 6 hours provide, a reasonable time for the
sewage sludge to be incorporated into the soil. In certain situations it may not be feasible to incorporate
the sewage sludge within 6 hours. The permitting authority can allow a longer time period if necessary.
When the sewage sludge that is incorporated into the soil is Class A with respect to pathogens, it has to
be applied to the land within 8 hours after discharge from the pathogen reduction to prevent regrowth of
Salmonella sp. bacteria. The Class A sewage sludge then has to be incorporated into the soil within 6
hours after it is land applied. These additional 6 hours are not expected to result in regrowth of
Salmonella sp. bacteria because:
8-40
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8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART.D
• Regrqwth is inhibited by the desiccation that starts when the sewage sludge is applied to the land
surface ,
The soil bacteria that invade the sewage sludge when it is surface applied inhibit rapid regrowth
of Salmonella sp. bacteria.
FREQUENCY OF MONITORING
Parameter
Time between application/placement and
incorporation into soils
Time between end of Class A pathogen treatment
process and application/placement on the land
Frequency
Each time sewage sludge is applied to the land
surface '
-. ' . . • • ' - • '
RECORDKEEPEVG
• Description of application site
• Log indicating sewage sludge was incorporated into the soil
8.8.11 VECTOR ATTRACTION REDUCTION OPTION 11
Statement of Regulation " " -
§503.33(b)(11) Sewage sludge placed on an active sewage sludge unit shall be covered with soil or other material
at the end of each operating day.
Option 11, which is the third option that achieves vector attraction reduction by placing a barrier between
the sewage sludge and vectors, applies to sewage sludge placed on active sewage sludge units at a surface
disposal site. When sewage sludge placed on an active sewage sludge unit is covered daily, vectors can
not contact the sewage sludge. For this reason, they are not attracted to the sewage sludge.
FREQUENCY OF MONITORING '•-"'.'
• Daily
RECORDKEEPESTG
• Log indicating cover
was placed on the active sewage sludge unit
daily
8-41
-------
8. PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
REFERENCES
Smith, I.E. and J.B. Farrell. 1994. Vector Attraction Reduction Issues Associated with the Part 503
Regulations and Supplemental Guidance. In The Management of Water and Wastewater Solids for the
21" Century: A Global Perspective. Water Environmental Federation.. Alexandria, VA.
U.S. EPA. 1992. Control of Pathogens and Vector Attraction in Sewage Sludge. December 1992.
EPA/675/R-92/013. •
U.S. EPA. 1992. Technical Support Document for Reduction of Pathogens and Vector Attraction in
Sewage Sludge. November 1992. EPA/822/R-93/004.
8-42
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'APPENDIX A
CONVERSION FACTORS - ENGLISH SYSTEM UNITS TO
METRIC SYSTEM UNITS
-------
-------
TABLE A-l. CONVERSION FACTORS - ENGLISH SYSTEM UNITS TO METRIC
• ' - " • SYSTEM UNITS, . ' ' . • '
English System international System of Units (SI)
Name
• -
Inch
Foot
Mile
Abbreviation
-
- in
ft
mi
Multiplier
Length
2.54
0.3048
,. 1.609
Symbol
/
cm
m
km
Kame
'
Centimeter
1 Meter
Kilometer
Area • ', '
Square Inch
Square Foot
"Square Mile
Square Mile
Acre
in2
ft2
mi2
mi2
acre
6.4516
9.29 x 10-2
2.59
259
0.4047
cm2
m2
, km2
ha
ha
Square Centimeter
Square Meter .
Square Kilometer
Hectare
Hectare .
- Volume
Cubic Foot
Cubic Foot
Gallon
Million Gallons
Acre Foot
ft3
ft3
gal
Mgal
acre-ft
28.32
2.832 x lO'2
3.785
3.7854 x 103
1233
L ,
m3
. L
m3
m3
Liter
Cubic Meter
Liter
Cubic- Meter
Cubic Meter
, Pressure ;
Pounds per Square
Inch
lbs/in2
7.031 x 10*
kg/cm2
Kilograms per Square
Centimeter
Mass
Pound
Pound
Ton (short)
Ib
lb
T
4.539 x 102
0.4536
0.9072
gm
kg
mt
Gram
Kilogram
Metric Tonne
Density
Pounds per Cubic
Foot
Tons per Acre
Tons per Acre
Ibs/ft3
T/acre
T/acre
16.02
2242.15
2.2421
kg/m3
kg/ha
mt/ha
Kilograms per Cubic
Meter
Kilograms per
Hectare
Metric Tonnes per
Hectare
"A-l
-------
TABLE A-l. CONVERSION FACTORS - ENGLISH SYSTEM UNITS TO METRIC
SYSTEM UNITS (Continued)
English System ^'""Ir^riiational System <>jf tMts (SI)
Name
Abbreviation '
Multiplier
Symbol
Name
Discharge (flow rate, volume/time)
Cubic Feet per
Second
Gallons per Minute
Gallons per Day
Million Gallons per
Day
Million Gallons per
Day
fWsec
gal/min
gal/day
Mgal/day
Mgal/day
28.32
6.39 x 10-2
4.3813 x 10-5
43.8126
3.7854 x 103
L/sec
L/sec
L/sec
L/sec
m3/day
Liters per Second
Liters per Second
Liters per Second
Liters per Second
Cubic Meters per Day
Bower s ,-"-'-'' - -- ;
Horsepower
Degrees Fahrenheit
hp
0.7457
kW -
Kilowatt
s ,v,i •> *. w*. S** & -,W ^1 vX»-*XO.X f i f j s f **>
Temperature
°F
0.555(°F-32)
°C
Degrees Celsius
*- ' -'Miscellaneous t
Parts per Million
Parts per Billion
Million Gallons per.
Acre
ppm
ppb
Mgal/acre
1.0
1.0
9354.537
mg/L
ug/L
m3/ha ,
Milligrams per Liter
Micrograms per Liter
Cubic Meters per
Hectare
A-2
-------
TABLE A-2. CONVERSION FACTORS - METRIC SYSTEM UNITS TO ENGLISH SYSTEM
•. • ' .. UNITS.' ' . " ' -
International System of Units (SI) English System
Name
»
Centimeter
Meter
Kilometer
Abbreviation
'
cm
m
km
Multiplier
Length
0,3937
3.2808
0.6214
Symbol
"•
in
ft
mi
Name
Inch
Foot
Mile
- , - Area
Square Centimeter
Square Meter
Square Kilometer
Hectare
Hectare '
cm2
m2
km2
ha
ha
0.155
10.763
.3861
3.861 x 10-3
2.471
in2 .
ft2
mi2
mi2 •
ac ••
Square Inch
Square Foot
Square Mile
Square Mile
Acre
Volume
Liter
Liter i
Cubic Meter
Cubic Meter
Cubic Meter
L
L
m3
m3
m3
3.531 x 10-2
, 0.2642
35.3147.
2.641 x 10-4
8.1071 x 10-4
Pressure
Kilograms per Square
Centimeter
kg/cm2
14.22
ft3
, gal
ft3
Mgal
acre-ft
Cubic Foot
Gallon
Cubic Foot
Million Gallons
Acre^foot
- •
lbs/in2
Pounds per Square
Inch
Mass , ,
Gram
Kilogram
Metric Tonne
gm
kg
mt
2.20 xlO'3
2.205
1.103
Ib
Ib
T
Pound
Pound
Ton (short)
, Density
Kilograms per Cubic
Meter
Kilograms per
Hectare
kg/m3
kg/ha
0.0624
4.46 x 10-4
lbs/ft3
T/acre
Pounds per Cubic
Foot
Tons per Acre
A-3
-------
TABLE A-2. CONVERSION FACTORS - METRIC SYSTEM UNITS TO ENGLISH SYSTEM
UNITS (Continued)
International System of Unite (SI) English System
Name
Metric Tonnes per
Hectare
Abbreviation
mt/ha
Multiplier
0.446
Symbol
T/acre
JSame
Tons per Acre
Discharge (flow rate, volume/time)
Liters per Second
Liters per Second
Liters per Second
Liters per Second
Cubic Meters per
Day
L/sec
L/sec
L/sec -
L/sec
m3/day
3.531 x 10-2
15.85
22,824.5
2.28 x lO'2
2.6417 x 10-4
ftVsec
gal/min
gal/day
Mgal/day
Mgal/day
Cubic Feet per
Second
Gallons per Minute
Gallons per Day
Million Gallons per
Day
Million Gallons per
Day ,
Power '
Kilowatt
kW
1.341
hp
Horsepower
Temperature
Degrees Celsius
°C
1.8°C + 32
op
Degrees Fahrenheit
Miscellaneous
Milligrams per Liter
Micrograms per Liter
Cubic Meters per
Hectare
mg/L
ug/L
m3/ha
1.0
1.0
1.069 x -104
ppm
ppb
Mgal/acre
Parts per Million
Parts per Billion
Million Gallons per
Acre
A-4
-------
APPENDIX B
SURFACE DISPOSAL SITE LINERS
-------
-------
SURFACE DISPOSAL SITE LINERS
A liner is defined in §503.21(j) as soil or synthetic material that has a hydraulic conductivity of 1 x 10~7
centimeters per second or less. Three types of liners and their properties are discussed in detail below.
Soil Liners (Compacted Clay)
The permeability and performance of soil liners are most affected by the following factors: soil
properties; liner thickness; lift thickness, placement, and bonding; arid hydraulic conductivity. Although
the soil may contain all the correct properties for successful construction of the liner, the soil liner may
still not meet the hydraulic conductivity criterion if the qonstruction practices are not properly controlled.
Thus, construction information is needed to verify the integrity of the liner.
Soil Properties ..-'..'.
The permeability and performance of a soil liner
depends upon the properties of the soil. The
compacted clay component of a soil liner defines
the liner's hydraulic conductivity. There are two
systems of soil classification used in the United
States to determine whether a soil is considered a
clay or a silt. These two classification systems
are difficult to compare. Therefore, rather than
define the soils by one or the other of the
classifications, soils for clay liners can be defined
based upon their specific characteristics. To
determine whether a soil will meet the hydraulic
conductivity requirement, the following
characteristics of the soil should be present: "
• At least 20 percent fines (fine, silt an4
clay sized particles); however, some soils
- The United States, Department of Agriculture's
(USDA) soil classification system is based on
grain size and uses, a three-part diagram to
classify all soils. The American Society of
Testing . and Materials' (ASTM) soil
classification system does not use grain size as
a criteria but instead bases the classification of
clays on plasticity criteria. The ASTM system
uses a plasticity diagram and the slope of line
flA" to distinguish between clays and silts,
(those soils that fall lit the area above the n A"
line are considered to be clays, those below
silts) (EPA 1989C),
with less fines may meet the hydraulic conductivity of 10"7 cm/sec (EPA 1989c)
• A plasticity index (PI) of the soil between 10 and 30 percent (soils with a PI greater than 30
percent are sticky and difficult to work with) (EPA 1989c)
• No more than 10 percent gravel-sized particles (coarse fragments can cause zones with higher
' conductivity) (EPA 1989c) . •
• No soil particles or chunks of rock greater than 1 to 2 inches in diameter (large particles can
form permeable "windows" through a layer) (EPA-1989c).
B-l
-------
SURFACE DISPOSAL SITE LINERS (Continued)
The most common additive used for soil'
amendment is sodium bentonite. This clay
mineral, generally in the form of a dry
powder, when mixed with water expands by
absorbing the water into the mineral matrix.
The addition of a relatively small amount (5 to
10 percent) of this mineral to a noncohesive
soil makes the soil more cohesive.
Generally, natural soil materials are recommended
for surface disposal sites; however, soils amended
or blended with different additives (e.g., lime,
cement, bentonite clays, and borrow clays) may
also meet the criteria for hydraulic conductivity.
Thickness of Liner
A thickness of two feet is generally considered the
minimum thickness needed to obtain adequate
compaction Of the soil and meet the hydraulic •••••••^•••MBMHHHHHBHMMIMBMMMMMHMM
conductivity requirement (EPA 1992a). .;
Lift Thickness, Placement, and Bonding
Soil liners are most often constructed in a series of lifts, each compacted separately. The lift thickness
(generally 5-9 inches) is dependent upon soil properties, compaction equipment, and the compaction
needed to meet the hydraulic conductivity requirement. At smaller sites, the soil liner may be constructed
over the entire site at one time. At larger sites with multi-unit designs the liners may be constructed in
segments over the life of the site. In the case of multi-unit designs, the design should address how the
old and new liner segments will be bonded together to maintain the hydraulic conductivity requirement
(EPA 1992a). .
Hydraulic Conductivity
The hydraulic conductivity of a liner is the most important design parameter when evaluating a
constructed soil liner. The hydraulic conductivity determines the ease with which water passes through
the liner material. The hydraulic conductivity depends upon the degree of compaction, compaction
method, soil moisture content, and density of the soil during liner construction. Hydraulic conductivity
is also dependent upon the viscosity and density of the leachate and on the shape, size, and area of the
conduits though which the liquid flows. Leachates from surface disposal sites have physical properties
similar to those of water so water is appropriate for testing the compacted soil liner and source'materials.
The hydraulic conductivity of a partially saturated soil is less than the hydraulic conductivity of the same
soil when saturated, due to a reduction of flow area from air entrapment. Hydraulic conductivity testing
should be conducted on samples that are fully saturated (EPA 1992a).
The lowest hydraulic conductivity of compacted clay soil usually occurs when the soil is compacted-at
a moisture content slightly higher than the optimum moisture content, generally in the range of 1 to 7
percent (EPA 1989c). When compacting clay, water content and compactive effort are the two factors
that should be controlled to meet the maximum hydraulic conductivity criterion. Since it is impractical
to specify and construct a clay liner to a specific moisture content and to a specific compaction, and
because moisture content is difficult to control in the field during construction, the design plan usually
specifies a range of moisture contents and corresponding soil densities (percent compaction) to achieve
the required hydraulic conductivity. During construction of the liner, soil testing is conducted to ensure
that the design specifications are being met. The amount of soil testing to define these construction
parameters is dependent on the degree of natural variability of the source material (EPA 1992a).
B-2
-------
SURFACE DISPOSAL SITE LINERS (Continued)
Laboratory and field testing are performed to determine compaction requirements and moisture contents
of material delivered to the site. Laboratory testing is usually conducted on field samples for
determination of hydraulic conductivity of the in-place liner. In laboratory testing, soil samples can be
fully saturated and the effects of a large overburden stress on the soil, which is not easily performed in
the field, can be simulated (EPA 1989c). '
Differences between laboratory and field conditions (e.g., uniformity of material, control of water
content, compactive effort, and compaction equipment) may make it unlikely that minimum hydraulic
conductivity values measured in the laboratory on remolded, pre-construction borrow source samples are
the same as the values achieved during actual liner construction. Laboratory testing also does not account
for operational problems that may occur in the field. Methods that can be used to measure hydraulic
conductivity in the lab are provided below.
Laboratory Methods To Measure Hydraulic Conductivity
EPA Method 9100 for measuring hydraulic conductivity of soil samples in publication SW-846, Test
Methods for Evaluating Solid Waste — Physical/Chemical Methods (EPA '1986).
U.S. Army Corps of Engineers Engineering Manual 1110-2-1906 (1970) (4) and the newly
published Measurement of Hydraulic Conductivity of Saturated Porous Materials (
American Standards and Testing Methods (ASTM) D-5084 Measurement of Hydraulic Conductivity
of Saturated Porous Materials Using a Flexible Wall Permeameter [To verify full saturatipn of the
sample, this method may be performed with back pressure saturation and electronic pore pressure
measurement (EPA 1992a)]. , « -
Field tests provide an opportunity to check representative, areas of the liner for conformance with
compaction specifications (including density and moisture content). Field tests are the most accurate
method of determining hydraulic conductivity because laboratory values generally are lower than those
measured in test fills or actual liners (EPA 1992a). Therefore, the results of both field tests and
laboratory tests should be evaluated when determining the compliance of soil liners with the hydraulic
conductivity requirement.
There are four kinds of field hydraulic conductivity tests, as described below:
• Borehole test — A hole is drilled into the soil and filled with water. The rate at which water
percolates into the borehole is measured.
• Porous probe test — A porous probe is driven into the soil and water is poured into the probe.
The amount of water that is released from the probe into the soil is measured. :
j ' ' • ' ' •
• Infiltrometer test — An infiltrometer is embedded into the surface of the soil liner so that the rate
of flow of a liquid into the liner can be measured. There are two types of infiltrometers — open
and sealed. Open rings are less desirable than popular sealed rings because they make it difficult
to account for evaporative basis when measuring the drop in water levels. Also, double-ringed
B-3
-------
SURFACE DISPOSAL SITE LINERS (Continued)
infiltrometers are preferred to single rings because double-ringed infiltrometers are less
susceptible to the effects of temperature.
• Underdrain test — Underdrains, which are installed during construction of the liner, are the most
accurate in-situ permeability testing device because they measure the exact amount of leachate
that migrates from the bottom of the liner (EPA 1989c).
Flexible Membrane Liners (Geomembranes)
Flexible membrane liners (FMLs), also called geomembranes, are generally polymeric materials,
particularly plastics and synthetic rubbers, mixed with a variety of other ingredients, such as carbon
black, pigments, fillers, plasticizers, processing aids, crosslinking chemicals, anti-degradants, and
biocides. There are several types of polymeric materials that are used in the manufacture of the FML
sheeting, including (EPA 1992a):
• Thermoplastics, such as polyvinyl chloride (PVC)
• Crystalline thermoplastics, such as high density polyethylene (HDPE), very low density
polyethylene (VLDPE), and linear low density polyethylene (LLDPE)
• Thermoplastic elastomers, such as chlorinated polyethylene (CPE) and chlorosulfonated
polyethylene (CSPE).
In assessing whether a FML will meet the hydraulic conductivity requirement, the following important
information should be examined:
• Thickness — The thickness of an FML affects permeability and can range anywhere from 20 to
120 mils. However, the recommended minimum thickness for all FMLs is 30 mils [with the
exception of high density polyethylene (HDPE) which should be at least 60 mils for proper
seaming] (EPA 1992a).
• Chemical compatibility with the contained waste — Plastics and rubber exhibit various degrees
of compatibility with different leachates. Materials' used in an FML should be selected based on
exposure to the leachate during its intended life. Compatibility testing is often performed prior
to installation. The most common test is the EPA Method 9090 Compatibility Test found in the
EPA document entitled, Test Methods for Evaluating Solid Waste, SW-846. This test simulates
the conditions to which the FML may be exposed during operation of the disposal site and what
effects, if any, the leachate and wastes will have on the liner.
' . /
Composite Liners
Composite liners are combinations of flexible membrane liners and compacted soil liners often used to
reduce the impact of penetrations of the FML. The use of a flexible membrane liner, in addition to the
soil, increases the leachate collection efficiency of the liner and provides a more effective hydraulic
barrier. The ability of a composite liner to meet the hydraulic conductivity requirement should be
assessed in a manner similar to that described above for each of the liner components: the soil liner and
the FML. ' ' - '
B-4
-------
APPENDIX C
INFORMATION SOURCES
-------
-------
INFORMATION SOURCES
Many EPA, State, Federal, and other organizations distribute technical publications that can provide
valuable information on various issues that may arise during the permitting process. The following
list of information sources, arranged alphabetically, provides a brief description of the types of
information these sources can provide. Following the list of sources is a list of documents published
by EPA to aid in the implementation of Part 503. The last information source is a list of EPA
Regional sludge (biosolids) coordinators. The Regional coordinators can provide Region-specific
guidance and provide the names of appropriate State personnel.
Building Seismic Safety Council - - ~
: 1201 LSt., NW
Suite 400
Washington, DC 2005 \
(202) 289-7800 '
The Building Seismic Safety Council (BSSC) is dedicated to wide distribution of technology for,
designing seismic safety into buildings. FEMA stocks all BSSC publications and will send the
requestor copies at no charge by calling FEMA publications at (202) 646-3484.
U.S. Federal Emergency Management Agency (FEMA) , '
Flood Map Distribution Center
6930 (A-F) San Thomas Rd.
Baltimore, MD 21227-6227 , , ,
U.S. Federal Emergency Management Agency (FEMA)
.(800)638-6620 . Continental U.S. only, except Maryland
• (800)492-6605 Maryland only
(800) 638-6831 Continental U.S., Hawaii, Alaska, Puerto Rico, Guam, and the Virgin
' Islands
The U.S. Federal Emergency Management Agency (FEMA) can provide assistance and information
on flooding and floodplains. The National Flood Insurance Program Community Status Book is
published bimonthly and can be obtained by calling the toll-free numbers listed above. Flood
insurance rate maps and other flood maps, including those delineating 100-year floodplains, may be
obtained from the map distribution center.
C-l
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INFORMATION SOURCES (Continued)
National Climatic Data Center -
Federal Building
Asheville, NC 28801
(704)259-0682
The National Climatic Data Center stocks various weather publications for the United States.
National Weather Service meteorological data older than one year is available from the center. A „'
useful guide for determining rainfall hi the western U.S., on a state by state basis is Precipitation
Frequency Atlas of the Western United States - NOAA Atlas 2. A publication for the eastern and
central U.S. entitled 5 to 60 Minute Precipitation Frequency for Eastern and Central United States is
available from NTIS (see above). The order number is PB 272112/AS. The center is open Monday
through Friday from 8:00 a.m. to 4:00 p.m. EST.
National Earthquake Information Center
P.O. Box 25046
Denver Federal Center MS 967
Denver, CO 80225 '
(303)273-8500 :
The National Earthquake Center (NEIC) is the national data'center and archive for earthquake
information. NEIC maintains a data base that has cataloged earthquake data that covers a time period
from 2100 BC to approximately four weeks behind the current date. There is a charge for this data
base service. To obtain further information the permit writer should call (303) 273-8406.
National Information Service for Earthquake Engineering
University of California, Berkeley
404A Davis Hall
Berkeley, CA
(510)231-9401
The National Information Service for Earthquake Engineering provides information for earthquake
engineering through a series of research reports, computer software programs, databases and library
services. The center is open from 8:00 a.m. to 12:00 p.m. and from 1:00 p.m. to 5:00 p.m. Monday
through Friday. There is a charge for publications and software. The permit writer should call the
service for the specific information required.
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INFORMATION SOURCES (Continued)
National technical Information Service (NTIS)
5285 Port Royal Rd. '
Springfield, VA 22151 J ,
(703)487-4650
(800)553-6847 ,
The National Technical Information Service provides information about technical reports published by
various sources, including EPA. NTIS has a large inventory of technical publications which are
available for a charge. The hours of operation are from 8:30 a.m. to 5:00 p.m. Monday through
Friday. Information on NTIS services and ordering information can be accessed by calling one of the
numbers listed above.
RCRA/Superfund'Industrial Assistance Hotline
(800)424-9346
The RCRA/Superfund Hotline provides information to the public and the regulated community in
understanding EPA regulations and policy on Resource Conservation and Recovery Act (RCRA)
which includes regulation of municipal solid waste landfills. Although the hotline does not deal with
the subject of sewage sludge disposal, they can provide state and local contacts for a variety of
agencies. The hotline also can be a source of information for the latest publications from the U. S.
EPA, in particular, solid waste .disposal, methane gas control, covers, liners, and leachate collection
systems., The phone call is toll free and the hours of operation are from 8:30 a.m. to 7:30 p.m. EST,
Monday through Friday. ,:
U.S. Army Corps of Engineers .
Publication Depot -
2803 52nd Ave.
Hyattsville, MD 20781-1102
(301)4362063
The Corps of Engineers Publication Depot has many documents pertaining to flooding and
floodplains. The Federal Manual for Identifying and Delineating Jurisdictional Wetlands is available
from the Depot. All publications are free,, however, they must be ordered in writing, no phone
orders are accepted: The Depot is open from 7:30 a.m. to 4:00 p.m. EST Monday through,Friday.
The Corps of Engineers Hydrologic Engineering Center can supply the HEC models. The Center
will distribute the models to Federal Agencies only from this location. The software is available to
the public from NTIS. The center can be contacted at:
Hydrologic Engineering Center
609 2nd St. .
Davis, CA 95616
(916)756-1104
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INFORMATION SOURCES (Continued)
U. S. Department of Agriculture
Soil Conservation Service (SCS) .
P.O. Box 2890
Washington, DC 20013
Publication Distribution Office
Room0054E
South Building • - .
Washington, DC 20250
(202) 720-5157
The Soil Conservation Service (SCS) of the United States Department of Agriculture can provide
technical assistance hi determining the nitrogen requirements of crops or vegetation, and calculating
the agronomic'rate. 'SCS has a nationwide network of nearly 3,000 offices and focuses its assistance
on non-Federal land. SCS district offices can provide on-site assistance in determining the
acceptability of sites to receive sewage sludge for land application. SCS can proyide publications to
assist the permit writer on subjects including wetlands delineation, floodplains and erosion control.
For SCS programs and assistance, the permit writer should find the local office in the phone book
which is listed under the United States Government, Department of Agriculture. If the permit writer
needs specific documents that are not available at the local office, the Publication Distribution Office
should be contacted.
U.S. Department of Interior
Fish and Wildlife Service
Publications Unit
4401 N. Fairfax St. ' •
130 Webb Building
Arlington, VA 22203
(703) 358-1711
(703) 358-2283 (FAX)
The Publication Unit of the Fish and Wildlife Department distributes free publications that may be
helpful for determining the presence of endangered species and delineating wetlands. The Publication
Unit is open from 7:45 a.m. to 4:30 p.m. EST Monday through Friday. Publications are free to the
public and may be ordered by phone, fax, or written request.
U.S. Geological Survey (USGS)
Earth Science Information Center
12201 Sunrise Valley Drive
Reston, VA 22092
(800) USA-MAPS (872-6277) .
The USGS Earth Science Information Center stocks an extensive supply of maps covering the entire
United States. The Center is open from 8:00 a.m. to 4:00 p.m. EST, Monday through Friday. The
toll-free telephone number allows the caller a variety of options for obtaining information.
C-4
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INFORMATION SOURCES (Continued)
The types of maps available from the Center that are mentioned in this manual as very useful to the
permit writer are: • ' :
1) Algermissen S.T., et. al. 1990. Probabalistic Earthquake Acceleration and Velocity Maps for the .
United States and Puerto Rico. -Map MF 2120. (Maps of horizontal acceleration useful for
determining whether a sewage sludge disposal unit lies within a seismic impact zone.)
2) USGS. 1978. Preliminary Young Fault Maps. Map MF 916. (Delineates Hplocene faults in the
United States.) • ,
Other maps available include topographic maps, state geologic maps, .and various specialized maps
that may be useful in determining the suitability of a location for a sewage sludge disposal unit.
State seismicity maps can be obtained from USGS Map Sales offices. .Mail orders can be addressed
to: . ' . -' • • _ •.' - '•' • .-. '''*'.;'
U.S. Geological Survey >,
Map Distribution
Denver Federal Center, Box 25286
Denver, CO 80225
... (303)236-7477 ' , ,
The EROS Data Center distributes aerial photographs that may be useful for delineating fault traces
and structural lineaments. The center carries the National Aerial Photographic Program/National
High Altitude Program (NAPP/NHAP) stereo photos, landsat photos, and other aerial photographs.
The center is open from 7:30 a.m. to 4:00 p.m. Monday through Friday. The center can be
contacted at: .
U.S. Geological Survey
EROS Data Center
Sioux Falls. SD 57198
(605) 594-6151
*********#**##*****#*****#*****************^
U.S. Environmental Protection Agency -; •
Center for Environmental Research Information (CERI)
26 West Martin Luther King Drive ,
Cincinnati, OH'45268
(513)569-7562 ;
The Office of Research and Development (ORD) has centralized most of its information distribution
and technology transfer activities at CERI. ,CERI serves as the distribution center for ORD reports
and research results. The permit writer can contact CERI to request information for summary reports
and technical documents on a wide range of topics including landfill covers, liners, construction
techniques, etc. ,
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INFORMATION SOURCES (Continued)
U.S. Environmental Protection Agency
Office of Air Quality and Standards
Research Triangle Park .
(919) 541-5381 (Joe Tuma)
Information on the availability and cost of the air dispersion models can be obtained by calling Joe
Tuma at the number given above.
************************************************************************************
U.S. Environmental Protection Agency
Office of Water Resource Center
RC-4100
401 M Street, S.W. ,
Washington, DC 20460
The Office of Water Resource Center distributes all available Office of Water documents. All the
implementation guidance documents listed below are currently available. Many of these documents
and other listed references are also available from NTIS.
*******************************************************
U.S. Environmental Protection Agency
. Reduction Risk Engineering Laboratory (RREL)
Cincinnati, OH .
(513)569-7834
The Geotechnical Analysis for Review of Dike Stability (CARDS) software package was developed to
assist in evaluating earth dike stability. GARDS may be obtained from RREL. There is no charge
for the program, however, the program must be copied onto discs which the user must supply.
************************************************************************************
C-6
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INFORMATION SOURCES (Continued)
PART 503 IMPLEMENTATION GUIDANCE DOCUMENTS
' ' t " • ' %
Environmental Regulations and Technology: Control of Pathogens and Vector Attraction in Sewage
Sludge (EPA 625-R-92-013), December 1992. ,
Preparing Sewage Sludge For Land Application or Surface Disposal: A Guide for Preparers of
Sewage Sludge on the Monitoring, Recordkeeping, and Reporting Requirements of the Federal
Standards for the Use, or Disposal of Sewage Sludge, 40 CFR Pan 503 (EPA 831-B-93-002a), August
1993.
Domestic Septage Regulatory Guidance: A Guide to the EPA 503 Rule (EPA 832-B-92-005),
September 1993.
Surface Disposal of Sewage Sludge: A Guide for Owners/Operators of Surface Disposal Facilities on
the Monitoring, Recordkeeping, and Reporting Requirements of the Federal Standards for the Use or
Disposal of Sewage Sludge, 40 CFR Part 503 (EPA 831-B-93-002c), May, 1994. '
THC Continuous Emission Monitoring Guidance for Part 503 Sewage Sludge Incinerators (EPA 833-
B-94-003), June 1994.
A Plain English Guide to the EPA Part 503 Biosolids Rule (EPA 832-R-93-003), September 1994.
Land Application of Sewage Sludge: A Guide for Land Appliers on the Requirements of the Federal
Standards for the Use or Disposal of Sewage Sludge, 40 CFR Part 503 (EPA 831-B-93-002b),
December 1994. .
C-7
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INFORMATION SOURCES (Continued)
EPA REGIONAL SLUDGE COORDINATORS
Region 1
Thelma Hamilton
JFK Federal Building
Boston, MA 02203
(617) 565-3569
Region 6
Stephanie Kordzi
1445 Ross Ave., Suite 1200
Dallas, TX 75202-2733
(214) 665-7520
Region 2
Alia.Roufaeal
290 Broadway
New York, NY 10007-1866
(212) 637-3864
1 Region 7
John Dunn
726 Minnesota Avenue
Kansas City, KS 66101
(913)515-7594
Region 3
Ann Carkhuff
841 Chestnut Street
Philadelphia, PA 19107-4431
(215) 597-9406
Region 8 - . -
Bob Brobst
999 18th Street, Suite 500
Denver, .CO 80202-2405
(303) 293-1627
Region 4
Vince Miller
345 Courtland Street
Atlanta, GA 30365
(404) 347-30.12 x2953
Region 9
Lauren Fqndahl
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1909
Region 5
John Colletti
77 W. Jackson Blvd.
Chicago, IL 60604-3590-
(312) 886-6106
Region 10
Dick Hetherington
1200 Sixth Avenue
Seattle, WA 98101-9797
(206) 553-1941
C-8
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APPENDIX D
DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E
The pollutant limits for metals presented in Section 503.43 are calculated, in part, from sewage sludge
incinerator control efficiencies (CE) for each of these metal pollutants. Section 503.43 states that CE
shall be determined from a performance test of a sewage sludge incinerator. The regulatory definition
of control efficiency can be expressed by the following formula:
CE = [Pollutant(in) - Pollutant(om)]/ Pollutant(in) ,
where: '
Pollutant(ih) = the mass of a pollutant in the sewage sludge fed to an incinerator,
Pollutant(out) = the mass of the same pollutant in the exit gas from the incinerator stack.
Without CE determinations sewage sludge limits cannot be established. Part-503 does not establish
specific procedures to be followed to determine CE. The following discussion is intended,to guide permit
writers, and incinerator operators to appropriate test procedures that can be used to determine and
document values for CE. ;
Control efficiency performance testing involves three elements: determining the mass of a pollutant in
the exit gas from the sewage sludge incinerator stack; determining the mass of that pollutant in the sewage
sludge fed to a sewage sludge incinerator; and determining the operating parameters of the incinerator's
air pollution control device during the performance test of the incinerator. The first two elements are
components of the regulatory definition of CE. The third element is not part of the definition of CE,
however, it is important since it can be used for on-going documentation of CE values after performance
testing has been completed. Each of these elements will be discussed individually in greater detail.
.Determining pollutant mass in the incinerator exit gas '"-...•
In order to accurately determine the mass of a pollutant in an incinerator's exit gas, sampling and
subsequent analysis of the incinerator exit gas stream must be conducted in discrete tune periods. It is
important to understand that these procedures, known as stack tests in air pollution control-jargon, only
provide data about the incinerator exit gas when gas sampling took place. Stack tests, therefore, only
provide a "snap-shot" of an incinerator's exit gas.
Appendix A of Part 60 contains test methods that are used to determine emission rates for various
pollutants from stationary sources. Although these methods are used primarily to determine compliance
with EPA's New Source Performance Standards (NSPS) and in some cases, National Emission Standards
for Hazardous Air Pollutants (NESHAP), they have also been applied widely to other situations. For
example, these methods have been used extensively to determine emission rates from sources subject to
state air quality regulations.1 Some of the Part 60 Appendix A stack test methods can also be applied
to. determine, in part, the mass of metal pollutants emitted from sewage sludge incinerator stacks.
1 It should be noted that some State agencies have developed their own test methods that sources must
follow in order to demonstrate compliance with state specific requirements.
. • . • ..-, • D-i- . • '•' ' ,. •••:•..
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E (Continued)
The mass emission rate of a particular metal pollutant from an incinerator stack can determined from the
concentration of the pollutant in the incinerator exit gas and the exit gas flow rate as expressed by the
following formula:
emission rate = (pollutant concentration) x (gas flow rate)
Although not included in Part 60 Appendix A, the test procedure entitled, Methodology for the
Determination of Metal Emissions in Exhaust Gases from Hazardous Waste Incineration and Similar
Combustion Processes, is recommended for determining metals concentrations in sewage sludge
incinerator exit gases. This test method, commonly called the multi-metals method, has been used
extensively to measure metals emissions from municipal solid waste, hazardous waste, and sewage sludge
incinerators. The multi-metals method has been incorporated into EPA's regulations governing the
burning of hazardous waste in boilers and industrial furnaces (the BIF Rule, Part 266, Subpart H).
The multi-metals method collects both volatile and non-volatile fractions of metals in stack gases and can
be applied to the following metals: total chromium, cadmium, arsenic, nickel, manganese, beryllium,
copper, zinc, lead, selenium, phosphorus, thallium, silver, .antimony, barium, and mercury. In this
method, the stack gas sample is withdrawn isokinetically from the emission source, with particulate
emissions collected in the probe-and on a heated filter, and gaseous emissions collected in a series of
chilled impingers containing solutions of nitric acid in hydrogen peroxide and of acidic potassium
permanganate. After sampling is completed, sample train components are recovered and digested in
separate front- and back-half fractions. Materials collected in the sampling train are acid-digested to
dissolve inorganics and to remove organics that may create analytical interferences. After digestion, both
fractions are brought up to their required volumes for metals analyses. Depending on the metals of
interest and necessary analytical sensitivities, the fractions are analyzed by atomic absorption spectroscopy
(AAS), graphite furnace AAS, inductively coupled argon plasma emission spectroscopy, and/or cold
vapor AAS. The analytical results from both fractions can be combined to yield metals values for the
entire train. The multi-metals method specifies a normal sampling run of one hour in duration, collecting
a stack gas sample volume of 1.25 m3. In many situations, greater sensitivity is needed to quantify metal
emission rates, therefore the method allows the sampling duration and sample volume to be increased to
4 hours and 5 m3, respectively to increase method detection limits. The multi-metals method expresses
resulting metals concentrations as milligrams per dry standard cubic meter. .
The flow rate of an incinerator's exit gas can be determined by using EPA Methods 1,2, and 4 from Part
60, Appendix A. The following table briefly describes each of these methods.
TABLE D-l. EPA REFERENCE METHODS TO DETERMINE GAS FLOW RATES
Method
EPA Method 1
EPA Method 2
EPA Method 4
Method Description
Sample and velocity traverses for stationary sources
Determination of stack gas velocity and volumetric flow rate (type S
pitot tube)
Determination of moisture content in stack gases
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E (Continued)
Determining pollutant mass in the feed to the incinerator
• Determined by multiplying the average metal concentrations in the sludge fed to the incinerator
while stack gas sampling took place by the amount of sludge fed to the incinerator while stack
gas sampling took place. , .
• Metal concentrations in sludge is determined by sampling and analysis of the sludge before it is
fed to the incinerator.
- Grab samples should be taken at various times during the test run and later combined to form
a composite sample for the run.
- The composite sample should be representative of the sludge that is actually fed ,to the
incinerator. One grab sample should be taken every 15 minutes unless data is available to
indicate that less frequent sampling is adequate. The size of the composite sample must be
established so that "representativeness" is-ensured.
- Sludge sampling should be conducted simultaneously with stack gas sampling. Since sludge
residence times and gas residence times of the incinerator can differ significantly, sludge
sampling should begin and end before stack gas sampling begins and ends; the "off-set" should
be equal to the difference between sludge and stack gas residence times.
- - The resulting composite sample should be "flow-weighted"- on a dry sludge basis. If the sludge
feed rate (dry basis) and the metal concentrations in the sludge both vary over the duration of
the performance test, the resulting composite sample will not be indicative of the metals
introduced to the incinerator if sampling is not flow-weighted.
- Flow-weighted samples require that the sludge feed rate to the incinerator be measured and
recorded and that the moisture content of the sludge be measured. ,
' - Previous discussions of sludge sampling and compositing apply to all feed streams into the
incinerator (sludge and scum).
- Sampling, sample handling and preparation, and analyses procedures should primarily follow
EPA's "Test Methods for Evaluating Solid Waste - Physical/Chemical Methods, SW-846" and
the ASTM Annual Book of ASTM Standards. (OTHER METHODS MAY ALSO BE
APPLICABLE)
• The amount of sludge fed to the incinerator during a test can be determined by obtaining an
average of the sewage sludge feed rate during the performance test run and multiplying by the
duration of the test run. -
- This method requires the use of a sludge feed rate monitor; precautions must be taken to
evaluate and ensure the accuracy of the monitor The monitor must be certified for accuracy
and maintained and calibrated properly.
- In some cases, the amount of sludge fed to an incinerator could be determined by measuring
the difference in sludge feed tank levels before and after each test run. This method requires
D-3
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E (Continued)
i
that the feed tank be sized such that accurate and precise level measurements could be taken
and that sludge was not added to the tank during the test run.
Documenting operating parameters of air pollution control devices (APCD) during CE performance
testing
• Not directly related to the determination of CE.
• Regulations require that permit conditions for APCD operating parameters be based on CE
performance testing.
• The operating parameter values observed during the performance test establish "baseline"
conditions that can be used to compare with future operations. If these parameters deviate from
the values observed during the performance test, a difference in the measured CE value could
be indicated.
• Operating parameter values should be monitored and recorded as continuously as possible to
provide an indication of the actual parameter values, as well as the variability of these values
during sampling.
• The incinerator operator should clearly understand the importance of documenting APCD
parameter values during testing to future incinerator operations. The operator may want to
perform testing at unusual conditions to establish worst-case operating parameters that could
provide flexibility of future operations.
• Operating parameters depend on the type of APCD. See guidance in Chapter 7 of text.
D-4
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APPENDIX E
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C
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DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C
In accordance with Section 503.23(b), "the owner/operator of a surface disposal site may request site-
specific pollutant limits for an active sewage sludge unit without a liner and leachate collection system
when the existing values for site parameters specified by the, permitting authority are different from the
values for those parameters used to develop the pollutant limits in Table 1 of Section 503.23." The
concentration of each regulated pollutant "shall not exceed either the concentration for the pollutant
determined during a site-specific assessment, as specified by the permitting authority, or the existing
concentration of the pollutant in the sewage sludge, whichever is lower."
The final rule for surface disposal sites (Table 1 of Section 503.23), includes regulations for only three
pollutants: arsenic, chromium and nickel. The groundwater pathway (Pathway 14) is the only one of
concern for site-specific modeling, since the regulated pollutants are metals, and therefore do not
volatilize. In addition, the national EPA pollutant concentration limits were based on either the lowest
risk-based criteria value or the pollutant concentration representing the 99th.percentile of sewage sludge
samples analyzed for the National Sewage Sludge Survey (NSSS) (U.S. EPA, 1992). In particular, the
national pollutant limit for nickel was'based on the NSSS 99th percentile value of 420 mg/kg, rather than
the risk-rbased limit of 690 mg/kg.
When a permittee requests site-specific pollutant limits, the permit writer will have to.make several
decisions. First, she must decide if the reasons for the request are appropriate, e.g. is a high
groundwater recharge rate a reason to approve site-specific limits. If the parameter is appropriate, she
must know what value was used to determine the pollutant limits in Part 503, and what is an appropriate
pollutant limit-based on the permittee's values. The models used to develop the surface disposal pollutant
limits include numerous parameters. The tables at the end of this section were developed to allow permit
writers to look up values for the three pollutants when certain parameter values are changed. If a permit
writer chooses to allow site-specific pollutant limits based on other parameters, he will have to make
decisions based on his own BPJ.
The following list includes some of the different parameters that could be considered for the development
of site-specific pollutant tables:
• Sewage sludge condition,
• Site geometry,
• Soil type,
• Depth to groundwater,
• Distance from edge of active sewage sludge unit to property boundary,
• Groundwater recharge,
• Soil-water partition coefficients,
• Hydraulic gradient, and
• Aquifer thickness. • • ,
Criteria for Identifying Candidate Parameters for Site-Specific Pollutant Limit Tables
The definition of "surface disposal" includes a range of disposal facilities, including sludge-only
monofills, lagoons, waste piles, dedicated sites for land application and others. The physical
characteristics of these types of facilities vary significantly, and specific modeling of each of the
different types of facilities was not considered practical for the final rule. Instead, two
"prototype" facilities (a monofill and a surface impoundment with continuous inflow) were
E-l
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DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
selected to represent the broader universe of facility types. For each pollutant and exposure
pathway, the more limiting of criteria calculated for these two prototype facilities was used for
the final regulation. ,
The use of prototypes presents some complications for site-specific modeling of individual
facilities. If the site under consideration is a waste pile, for example, how should the pile's
slope or height be represented with input parameters used in two models designed respectively
for a surface impoundment filled with liquid or a monofill with a cover layer of soil? If the
facility is a surface impoundment receiving only occasional deposits of sludge, what parameters
are appropriate to describe these deposits for a model that assumes continuous inflow?
In order to avoid the need to develop new models for additional facility prototypes, parameters
that describe the actual surface disposal unit such as sewage sludge condition and site geometry
were not considered in the tables. Another important factor to consider when, selecting
parameters is the ease with which the parameter can be measured or estimated. Parameters that
are likely to have substantial variability for a single site were not used in developing the tables
because data based on a limited number of samples does not adequately represent an entire site.
The following section explains why four possible parameters were not used in the development
of the site-specific look-up tables.
Groundwater recharge was found to have a significant impact upon estimated pollutant limits.
However, because of the difficulty in measuring local recharge, it was not considered as a
variable for the site-specific tables. This issue is complicated by the differences in recharge
below different surface disposal facility types. For example, a surface impoundment, which is
assumed to have a standing head of water, is modelled differently than a monofill, which has a
temporary cover soil and eventually a permanent cover.
Soil-water partition coefficients (Kd) for metals can be estimated from numerous site-specific
variables including temperature, pH, total dissolved solids, presence of iron oxides, clay, and
organic matter. Because of the potential spatial variability, however, it can be difficult to
estimate Kd values which are representative of the entire site. As a result, laboratory-derived Kd
values often do not correspond to field values that have been calibrated over large areas.
Accurately estimating site-specific Kd values requires substantial sampling effort. For this reason,
soil-water partition coefficients were not used as a site-specific parameter.
The hydraulic gradient can fluctuate due to weather and the potential effects of surrounding
pumping wells. In addition, model results (and hence pollutant limits) are relatively insensitive
to the values chosen for hydraulic gradient. For these reasons, hydraulic gradient was not used
as a site-specific parameter.
Aquifer thickness affects criteria, although not as significantly as the other site-specific parameters
discussed here (i.e., depth to groundwater, distance, and soil type). For example, an order of
magnitude change in the aquifer thickness (from"5m to 50m) only produces a five-fold increase
in the allowable concentration, with little or no change occurring for greater thicknesses. By
comparison, a difference of a factor of two in the depth to groundwater or change in soil type
E-2 • ' ' ' '
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DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
may lead to as> much as an order of magnitude or more change in the criteria. Due to the
relatively insignificant effect on criteria and the additional computational burden of including four
independent variables, aquifer thickness was not included for the site-specific tables.
Site-Specific Parameters . ' •
The site-specific pollutant tables were derived using the assumptions, models and methodology
used to derive the national limits, (U.S. EPA, 1992). The three parameters used in developing
the site-specific pollutant tables are:
• Soil type, x
• Depth to groundwater, and ^
•• Distance from edge of active sewage sludge unit to property boundary.
Below is a description of each of the site-specific parameters.
Soil Type
Soil type refers to the uppermost portion of the vadose zone, which is characterized by significant
biological activity. The soil type can impact the transport of pollutants through such processes
as filtration, biodegradation, sorption, and volatilization. For metals, filtration and sorption are
the only relevant processes. Consistent with the methodology used to determine the national
pollutant limits, the site-specific model assumes that the soil is homogeneous throughout the soil
column and that one soil type is being modeled. In the site-specific modelling, soil type is
represented by the following set of parameters:
• Hydraulic conductivity, -
• Bulk density,
• Porosity,
• Water retention parameters, and
• Residual water content.
Soil types are based on a soil group classification system developed, by the Soil Conservatipn
Service (USDA, 1972). The SCS classification consists of four groups (A, B, C and D), that are
in order of decreasing percolation potential. For each SCS .soil group, the site-specific model
assumes fixed values for the soil type parameters listed above. The four SCS groups are
associated with soil characteristics as follows (USDA, 1972; McCuen, 1982):
Group A: Soils having a high infiltration rate when thoroughly wet. These consist mainly
of deep, well drained to excessively drained sands or gravelly sands: deep sand,
deep loess, aggregated silts.
. E-3
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
Group B: Soils having a moderate infiltration rate when thoroughly wet. These consist
chiefly of moderately deep or deep, moderately well drained or well drained
soils that have moderately fine texture to moderately coarse texture: shallow
loess, sandy loam.
Group C: Soils having a slow infiltration rate when thoroughly wet. These consist chiefly
of soils having a layer that impedes the downward movement of water or soils
of moderately fine texture or fine texture:, clay loams, shallow sandy loam,
soils low in organic content, and soils usually high in clay.
Group D: Soils having a very slow infiltration rate when thoroughly wet. These consist.
chiefly of clays that have high shrink-swell potential: soils that swell
significantly when wet, heavy plastic clays, and certain saline soils.
For a particular site, the SCS soil group can be identified using any of the following:
• Soil characteristics, .
• Saturated hydraulic conductivity, or >
• County soil surveys.
The soil characteristics associated with each group are listed above. Site-specific soil
characteristics are best obtained by doing site-specific soil analysis. A soil analysis can also be
used to estimate the hydraulic conductivity (a measure of the soils ability to transmit water),
which can be correlated with the SCS soil groups. The following table shows the correlation
between saturated hydraulic conductivity and soil group (Brakensiek and Rawls, 1983).
Group Saturated Hydraulic Conductivity (cm/hf)
Al . 10.0 - 61 '
A
B
C
D
1.0 - 10.0
0.60 - 1.0
0.20 - 0.60
0.005 - 0.20
SCS county soil surveys, where available, can give a detailed description of soils at locations
within a county, and can be used to identify the soil group. Additionally, the SCS (U.S.D.A.,
1972) has assigned hydrolo'gic soil groups to over four thousand soils in the U.S. and Puerto
Rico. Other sources for identifying the soil group include:
• U.S. Geological Survey,
• State Geological Survey,
• State Department of Natural/Water Resources,
• U.S. Department of Agriculture Soil Conservation Service, or
• Private Consulting Firms
E-4
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
If the soil group has been identified as being Group A using either the soil characteristics, or
county surveys, then the hydraulic conductivity should be measured to distinguish which range
within Group A is appropriate. Alternately, permeability values can be obtained from such
sources as
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
Bulk Density
The bulk density of soil is defined as the mass of dry soil divided-by its total (or bulk) volume.
Bulk density directly influences the retardation of solutes and is related to soil structure. In
general, as soils become more compact, their bulk density increases. Values for bulk density
were derived from Carsel et al. (1988), that provided descriptive statistics for bulk density
according to Hie four SCS soil groups.
Porosity
• t • *»*•.,,,
Porosity is the ratio of the void volume of a given soil or rock mass to the total volume of that
mass. If the total volume is represented by Vt and the volume of the voids by Vv; the porosity
can be defined as ®t=VyVt. Porosity is usually reported as a decimal fraction or percentage, and
ranges from 0 (no pore spaces) to 1 (no solids). Porosity values were calculated from the bulk
density:
where:
BD
P50
=bulk density of soil (kg/m3)
=particle density of soil (kg/m3), and
=porosity of soil (dimensionless).
A value of 2650 was used as a typical particle density for mineral soils (Freeze and Cherry,
1979).
Water Retention Parameters
The water-retention characteristic of the soil describes the soil's ability to store and release water
and is defined as the relationship between the soil water content and the soil suction or matric
potential (Maidment, 1993). The unsaturated hydraulic conductivity is a non-linear function of
volumetric soil water content, and varies with soil texture. The van Genuchten (1980) water.
retention parameters were used to determine the soil water content and the unsaturated hydraulic
conductivity.
In order to select values for the soil-retention parameters it is necessary to relate a soil type to
each soil group. Carsel and Parish (1988) provide descriptive statistics for the van Genuchten
parameters for twelve soil types: clay, clay loam, loam, loamy sand, silt, silty loam, silty clay,
silty clay loam, sand, sandy clay, sandy clay loam, and sandy loam. The following assignments
were made to each soil group, based on relative permeability:
• Group A: Sand
• Group B: Sandy Loam
E-6
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
• Group C: Clay Loam
• Group D: Silty Clay Loam.
Residual Water Content ,
Values for the residual water content were taken from Carsel and Parrish (1988), using sand for
Group A, sandy loam for Group B, clay loam for Group C, and silty clay loam for Group D.
Depth to Groundwater
The depth to groundwater is defined as the distance from the lowest point of the active sewage
sludge unit to the water table. The water table is itself defined as the subsurface boundary
between the unsaturated zone (where the pore spaces contain both water and air) and the saturated
zone (where the pore spaces contain water only). For the purposes of site-specific modeling, the
water table is defined as being the high water table, or the "highest level of a saturated zone in
the soil in most years" (USDA, 1989). The depth to groundwater determines the distance a
contaminant must travel before reaching the aquifer, and affects the attenuation of contaminant
concentration during vertical transport. As this depth increases, attenuation also tends to increase,
thus reducing potential pollution of the groundwater.
Seven depths are used to represent the depth to groundwater at an active sewage sludge unit.
Table E-2 shows the depth along with the applicable ranges. Where a site-specific value falls
between two values in Table E-2, the smaller value should be used (e.g., a site-specific value of
6 feet or roughly 1.8 meters would correspond to one meter). SCS county soil surveys can be
useful sources for depths to groundwater, although site-specific measurements are preferred.
Other sources for the depth to groundwater include:
• U.S. Geological Survey,
• State Geological Survey, .','-.
« State Department of Natural/Water Resources, '.'• •
• U.S. Department of Agriculture Soil Conservation Service, or
• Private Consulting Firms.
Distance from Edge of Active Sewage Sludge Unit to Property Boundary
"' • . ' \
Consistent with the methodology for the national pollutant criteria, the site-specific model
assumes that a drinking water well is located at the site's property boundary, directly down-
gradient of the site. Thirteen distances are used to represent the distance from the edge of the
unit to the property boundary. Table E-3 shows the distances along with the applicable ranges.
When site-specific values fall between two values in Table E-3, the smaller (closer) value should
be used (e.g., a site-specific value of 175 meters corresponds to 150 meters).
E-7
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
Table E-2. Depth to Groundwater (m)
Depth to Groundwater(m)
1
5
10
15
20
30
50
Range (m)
< 5
5 < x < 10
10 < x < 15
15 < x < 20
20 < x < 30
30 < x < 50
> 50
Table E-3. Distance to Property Boundary
Distance (m)
0
25
50
75
100
125
150
200
250
300
400
500
1000 .
Range (m)
< 25
25 < x < 50
50 < x < 75
75 ^ x < 100
100 < x < 125
125 < x < 150
150 1000
Site-Specific Pollutant Limit Look-Up Tables
The site-specific pollutant limits are presented in Tables E-4 to E-6 for arsenic, chromium, and
nickel, respectively. To determine the site-specific pollutant limit for an individual active sewage
sludge unit, the permit writer should locate the matrix which corresponds to the appropriate soil
group, and find the column representing the distance to the edge of the site and the row
representing the depth to groundwater. If the site-specific value estimated for either the depth
to groundwater or the distance to the edge of the site falls between two values in the table, then
the lower value should be used. The national pollutant limits for each pollutant are in bold, and
correspond to: Soil Group Al, a one meter depth to groundwater, and a 150 meter distance from
the edge of the active sewage sludge unit to the boundary property (U.S. EPA, 1993).
E-8
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
Table E-4. Risk-Based Site-Specific Pollutant Criteria for Arsenic (in mg/kg)
Soil group Al
Depth »
GWto)
Km)
5(m)
10 (m)
15 (m)
20 (m)
30 (m)
50 (m)
Distance to Edge of Site (m)
0
30
36
48
61
75
120
650
25
34
40
53
66
81
140
890
50
39
46
59
73
88
170
1,200
75
46
53
66
80
98
210
1,700
- 100
53
61
74
90
110
260
2,400
as
62
70
84
100
130
340
3,400
, WO
73
80
95
110
160
440
4,900
200
.97
100
110
150
240
.750
10,000
' 250
120
130
150
210
370
. 1,300
20,000
300
150
160
200
, 310
580
2,200
41,000
400
230
250
380
720
1,400
7,000
Unlimited
500
340
430
780
1,700
3,800
21,000
Unlimited
1,000
4,800
11,000
38,000 „
Unlimited
Unlimited
Unlimited
Unlimited
Soil group A2
Depth to
GW
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
Table E-5. Risk-Based Site-Specific Pollutant Criteria for Chromium (in mg/kg)
Soil group Al
Depth to
GW(m)
Km)
5(m)
10 (m)
15 (m)
20 (m)
30 (m)
50 (m)
Distance to Edge of Site , .
0
330
400
990
3,600
15,000
Unlimited
Unlimited
25
390
680
2,800
14,000
85,000
Unlimited
Unlimited
50
550
1,300
8,400
59,000
Unlimited
Unlimited
Unlimited
75
880
3,200
27,000
Unlimited
Unlimited
Unlimited
Unlimited
100
1,500
8,200
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
125
3,000
22,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
150
6,300
64,000
Unlimited
Unlimited
, Unlimited
Unlimited
Unlimited
200
31,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
250
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
300
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
400
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Soil group C
Depth to
GW(m)
Km)
5fm)
10(m)
15(m)
20 (m)
30 (m)
50 (m)
Distance to Edge of Site (m)
0
340
420
1,100
4,300
19,000
Unlimited
Unlimited
25
410
740
3,300
19,000
Unlimited
Unlimited
Unlimited
50
590
1,500
10,000
81,000
Unlimited
Unlimited
Unlimited
'75
960
3,800
36,000
Unlimited
Unlimited
Unlimited
Unlimited
100
1,700
10,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
125
3,400
29,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
150
6,300
64,000
"Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
200
31,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
i 250
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
300
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited-
400
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Soil group D
Depth to
GW (m)
Km)
5(m)
10 (m)
15 (m)
20 (m)
30 (m)
50 (m)
Distance to Edge of Site (m)
0
350
420
1,100
4,300
19,000
Unlimited
Unlimited
25
420
740
3,300
19,000
Unlimited
Unlimited
Unlimited
50
590
1,500
10,000
81,000
Unlimited
Unlimited
Unlimited
75
960
3,800
36,000
Unlimited
Unlimited
Unlimited
Unlimited
100
1,700
10,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
125
3,400
29,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
ISO
6,300
64,000
Unlimited,
Unlimited
Unlimited
Unlimited
Unlimited
200
31,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
25p
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
300
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
400
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
E-10
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
Table E-6. Risk-Based Site-Specific Pollutant Criteria for Nickel (in mg/kg)
Soil group Al •
Depth
•to GW (m)
Km),
S(ra) ^
KKm) '
55 fm)
20 (m)
30 (m)
50
i5
0
350
440 -
1,200
5,100
24,000
Unlimited
Unlimited
25 '
430
810
3,900
24,000
Unlimited
Unlimited
Unlimited
, 50
620
1,700
13,000
Unlimited
Unlimited
Unlimited
Unlimited
75
1,000 '
4,500
47,000
Unlimited
Unlimited
Unlimited
Unlimited
100
1,900
12,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
125
4,000
37,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
150 >
4,500
48,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
" 200 ^
19,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
250
Unlimited
Unlimited
Unlimited
- Unlimited
Unlimited
Unlimited,
Unlimited
?00
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
400
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Soil group C
^ Depth
' to GW Cm)
Um>
S(m) .
10 (m)
,15 (m)
" 20 (m)
30
0
370
460
1,300
6,100
30,000
Unlimited
Unlimited
25
450
890
4,600
31,000
Unlimited
Unlimited
; Unlimited
50
660
2,000
16,000
Unlimited
Unlimited
Unlimited
Unlimited
' 75
1,100
5,300
63,000
Unlimited
Unlimited
Unlimited
Unlimited
100
2,100
15,000 .
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
125
4,600
49,000
Unlimited
Unlimited
• Unlimited
Unlimited
Unlimited
150
8,800
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
200
50,000
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
250
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
300'
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
400
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
Unlimited
'National Pollutant limits for nickel were based on 99th percentile value for the NSSS (420 mg/kg).
E-ll
-------
DETERMINING SITE-SPECIFIC POLLUTANT
LIMITS FOR PART 503, SUBPART C (Continued)
REFERENCES
Brackensiek, D.L., and WJ. Rawls. 1983. "Green-Ampt Infiltration Model Parameters for
Hydrologic Classification of Soils." In Proceedings of Special Conference on Advances in
Irrigation and Drainage, ASCE, Jackson, Wyoming.
Freeze, R.A. and J.A. Cherry. 1979. Groundwater. Englewood Cliffs, NJ: Prentice-Hall.
Carsel, R.F., and R.S. Parrish. 1988. "Developing Joint Probability Distributions of Soil-Water
Retention Characteristics." Water Resources Research. Vol. 24(5), 755-769.
Carsel, R.F., R.S. Parrish, R.L. Jones, J.L. Hansen, and R.L. Lamb. 1988. "Characterizing the
Uncertainty of Pesticide Leaching in Agricultural Soils." Journal ofContam. Hydrology. Vol.
25, 111-124. '
McCuen, Richard H. 1982. A Guide to Hydrologic Analysis using SCS Methods. Prentice Hall,
P-12.
Maidment, David R. 1993. Handbook of Hydrology. McGraw-Hill, Inc., Chapter 5, Infiltration
and Soil Water Movement.
U.S.D.A. SCS. 1989. Soil Survey of Norfolk and Suffolk Counties, Massachusetts.
U.S.D.A. SCS. 1972. SCS National Engineering Handbook, Section 4, Hydrology, Chapter 7 ~
Hydrologic Soil Group, pp.7.1-7.28.
U.S. EPA, 1992. Technical Support Document for the Surface Disposal of Sewage Sludge. EPA
822/R-93-002.
U.S. EPA. 1993. Standards for the Use or Disposal of Sewage Sludge; Final Rules. Federal
Register. Vol. 58, No.32.
Van Genuchten, M. Th. 1980. "A Closed-Form Equation for Predicting the Hydraulic
Conductivity of Unsarurated Soils," Soil Sci. Soc. Am. J., vol. 32,pp. 892-898.
E-12
-------
APPENDIX F
INTERIM APPLICATION FORM
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APPENDIX G
SAMPLE PERMIT
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Permit No.:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
. REGION VIII
DENVER PLACE
999 18TH STREET, SUITE 500
DENVER, COLORADO 80202-2466-
AUTHORIZATION TQ LAND APPLY/LANDFILL SLUDGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Clean Water Act, as
amended, (33 U.S-.C. §1251 et seq; the "Act"),
the
is authorized to Land Apply/Landfill Treated Sewage Sludge,
in accordance with application sites, specific limitations, monitoring
requirements, management practices and other conditions set forth
herein. Authorization to land apply sewage sludge is limited to the
outfall specifically listed in the permit.
This permit, shall become effective July 1, 1994.
This permit and the authorization to Land. Apply/Landfill Treated
Sewage Sludge shall expire at midnight, March, 31, 1999.
Signed this 6th
y of May 1994.
Permitting Official
ix HT. Dodson
/ Director
Water Management Division
Title
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PART I
Page 2 of 42
Permit No. :
TABLE OF CONTENTS
I. Specific Limitations and Monitoring Requirements
A. Definitions • , .' - •
B. Description of Sludge Generating Facilities ' /
C. Specific Limitations and Self-Monitoring Requirements
> D. Management Practices for Land Application and Landfilliiig
E. Special Conditions on Sludge Storage
F. Recordkeeping
II. Monitoring, Recording and Reporting Requirements . •
A. Representative Sampling
B. Monitoring Procedures
C. Penalties for'Tampering . ^
D. Reporting of Monitoring Results .
E. Additional, Monitoring by the Permittee
F. Twenty-four Hour Notice of Noncompliance Reporting
G. Other Noncompliance Reporting '
H. Inspection and Entry
III. Compliance Responsibilities .:
A. Duty to Comply ~ ,
B. Penalties for Violations of Permit Conditions 7
•C. Need to Halt or Reduce-Activity not a Defense ,
D. Duty to Mitigate
E. Proper Operation and Maintenance
IV-. General Requirements
A. Planned Changes
B. Anticipated Noncompliance
C, Permit Actions
D. Duty to Reapply , , •
E. 'Duty to Provide Information -:
F. Other Information ...
G. Signatory Requirements
H. Penalties for Falsification of Reports .
I. Availability of Reports . •
J. Oil and Hazardous Substance Liability
K. Property Right's • ;
L.' Severability , . , :
M. Transfers ' ' " .'
N. State and Federal Laws . •
O. Reopener Provision ,
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PART I • . .
Page 3 of 42
Permit No.:
I. SPECIFIC LIMITATIONS AND MONITORING REQUIREMENTS
A. Definitions. •
1.
2.
6'.
"Animals" for the purposes of this permit are domestic
livestock. _....-. ,
"Annual Whole Sludge Application Rate" is the amount of
sewage sludge (dry-weight basis) that can be applied to a
unit area of,land during a cropping cycle.
"Agronomic Rate" is the whole sludge application rate
(dry-weight basis) designed to: (1.) provide the amount of
nitrogen needed by the crop or vegetation grown on the
land; and (2) minimize the amount of nitrogen in the
sewage sludge that passes below the root zone of the crop
or vegetation grown on the land to the ground water.
"Annual Pollutant Loading Rate" is the maximum amount of a
pollutant (dry-weight basis) that can be applied to a unit
areel of land during a 365-day period.
"Application Site or Land Application Site" means all
contiguous areas of a users' property intended for sludge
application.
"Batch" is when a pile of sludge is created, allowed to
sit for a specific period of time and then removed from
the site. A batch of sludge could be compost piles or
long-term treatment piles.
"Biosolids" means any sludge or material derived from
sludge that can be beneficially used. Beneficial use
includes, but is not limited to, land application to
agricultural land, forest land, a. reclamation site or sale
or give away to the public for home lawn and garden use.
"Bulk Sewage Sludge" is sewage sludge that is not sold or
given away in a bag .or other container for application to
the. land.
"Composite Sludge Sample" is a sample taken either in a
wastewater treatment process, dewatering facility,or
application device consisting of a series of individual
grab samples. For liquid sludges, a minimum of three,grab
/samples of 500 milliliters taken during the first one-
third, second one-third and final one-third of a pumping
cycle and combined in equal volumetric amounts. For semi-
dewatered, dewatered or dried sludge, a composite sample
consisting of a minimum of three.grab samples of%0.5
pounds taken over a period of 24 hours not less than two
hours apart or another representative sample as defined or
approved by the permitting authority. .
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PART I
Page 4 of 42
Permit No.:
A. Definitions. (Continued)
10. "Cumulative Pollutant.Loading Rate" is the maximum amount
of an inorganic pollutant (dry-weight basis) that can be
applied to a unit area of land. " .
11
"CWA" means the Clean Water Act (formerly referred to as
either the Federal Water Pollution Act or the Federal
Water Pollution Control Act Amendments of 1972), Pub. L.
92-500, as amended by Pub. L. 95-217, Pub. L. 95-576, Pub.
L. 96-483, Pub. L. 97-117, and Pub. L. 100-4.
12. "Daily Maximum" ("Daily Max.") is the maximum value
allowable in any single sample or instantaneous
measurement. '. ,
13. "Director" means Director, of the United States
Environmental Protection Agency, Water Management
Division.
14. "Dry Weight-basis".means 100 percent solids (i.e., zero
percent moisture). • ..
15. "EPA" means the United States Environmental Protection
Agency.
16. A "grab" sample, for monitoring requirements, is defined
as a single "dip and take" sample collected at a
representative point anywhere in wastewater treatment or
sludge land application processes.
17. "Grit and Screenings" are sand, gravel, cinders, other
materials with a high specific gravity and relatively
large materials such as rags generated during preliminary
treatment of domestic sewage at a treatment works and
shall be disposed of .according to 40 CFR 258.
18. "Ha" means hectare. One hectare is equal to 2.47 acres.
19. "High Potential for Public Contact Site" is land with a
high potential for contact by the public. This includes,
but is not limited to, public parks, ball fields,
cemeteries, plant nurseries, turf farms, and golf courses.
20. An "instantaneous" measurement, for monitoring
requirements, is defined as a single reading, observation,
or measurement. ,-.'".
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PART I
Page 5 of 42
Permit No.:
Definitions. (Continued)
21.'"Land Application" is, the spraying or spreading.of sewage
sludge onto the land surface; the injection of sewage
sludge below the land surface; or-the incorporation of
sewage sludge into the land so that the sewage sludge can
either condition the soil or fertilize crops or vegetation
"grown" in the soil. Land application includes distribution
. and marketing (i.e. the selling or giving away, of the
sludge). '
22. '!Low Potential for Public Contact Site" is land with a low
potential for contact by the public. This includes, but
is not limited to, farms, ranches, reclamation areas, and
other lands which.are private lands, restricted, public
lands, or lands which are not generally accessible to or
used by the; public. ,
23. "Monthly Average" is the arithmetic mean of all
measurements taken.during the month.
\
24. "Paint Filter Test" is a test (SW 9095) where a
predetermined amount of sludge is placed in a paint
filter. If any portion of the material passes through the
filter in a five minute test period, the material is
deemed to contain free liquids. . •
25. "Pathogen" means an organism that is capable of producing
an infection or disease in a susceptible host.
26. "PFRP" means Processes to Further Reduce Pathogens, as
described in detail in 40 CFR Part 257, Appendix II and
consists of composting, heat drying, heat treatment,
thermophilic aerobic 'digestion, irradiation or
pasteurization. ' ' .
27. "Pollutant" for the purposes of this permit is an organic
substance, an inorganic substance, ^a combination of
organic and inorganic substances, or pathogenic.organisms
that, after discharge and upon exposure, ingestions,
inhalation,' or assimilation into an organism either
directly from the environment or indirectly by ingestion
through the food-chain, could, on the basis of information
available to the Administrator of EPA, cause death,
disease, behavioral abnormalities, cancer, genetic
mutations, physiological malfunctions (including
malfunction iii .reproduction) , or physical deformations' in
either organisms or offspring of the organisms. -
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PART I
Page 6 of 42
.Permit No.:
A. Definitions. (Continued)
28. "Pollutant Limit" is a numerical value that describes the
maximum amount of a pollutant allowed per unit amount of
sewage sludge (e.g., milligrams per kilogram of total
solids); the maximum amount of a pollutant that can be
applied to a unit area of land (e.g., pounds per acre);
the maximum density of a microorganism per unit amount of
sewage sludge (e.g., Most Probable Number per gram of
total solids); the maximum volume of a material that can
be applied to a unit area of land (e.g., gallons per
acre); or the maximum amount of pollutant allowed in plant
tissue (e.g., parts per million).
29. "PSRP" means Processes to Significantly Reduce Pathogens,
as described in detail in 40 CFR Part 257, Appendix II and
consists of aerobic digestion, air drying, anaerobic'
digestion, composting, or lime stabilization.
30. "Runoff" is rainwater, leachate, or other liquid that
drains overland on any part of a land surface and runs•off
of the land surface.
31. "Sewage Sludge" means solid, semi-solid, or liquid residue
generated during the treatment of. domestic sewage and/or a
combination of domestic sewage and industrial waste of a
liquid nature in a Treatment Works. Sewage sludge
includes, but is not limited to, domestic septage; scum or
solids removed in primary, secondary, or advanced
wastewater treatment processes; and a material derived
from sewage sludge. Sewage sludge does not include ash
generated during the incineration of sewage sludge or grit
and screenings generated during preliminary treatment of
domestic sewage in a Treatment Works. These must be
disposed of in accordance with 40 CFR 258..
32. "Similar Container" is either an open or closed
receptacle. This includes, but is not limited to, a :
bucket, a box, a carton, and a vehicle or trailer with a
load capacity of one metric ton or less.
33. "Specific Oxygen Uptake Rate (SOUR)" is the mass of oxygen
consumed per unit time per unit mass of total solids (dry
weight basis) in the sewage sludge.
34. "Total Solids" are the materials in the sewage sludge that
remain as residue if the sludge is dried at 103 to 105
degrees Celsius.
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PART I
Page 7 of 42
Permit No.:
A. Definitions. (Continued)
3,5. "Toxicity Characteristic Leaching Procedure" is test
method (Method 1311) used to determine the mobility of
both organic and inorganic pollutants present in liquid,
solid and multiphasic wastes.
3.6,. "Treatment Works" are either Federally owned, publicly-
, owned, or privately owned devices or systems used to treat
(including recycling and reclamation) either'domestic
sewage or a combination of domestic sewage and industrial
waste of. a liquid nature.
37. "Unstabilized Solids" are organic materials in sewage
sludge that have not been treated in either an aerobic or
anaerobic treatment process.
38. "Vector Attraction" is the characteristic of sewage sludge
that attracts rodents, flies, mosquitos or other organisms
capable of transporting infectious agents.
39. "Volatile Solids" is the amount of the total solids in
sewage sludge lost when the sludge is combusted at 550
degrees Celsius for.15-20 minutes in the presence of
excess air. , ' ' '.
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PART I
Page 8 of 42.
Permit No. :
B. Description of Sludge Generation. Treatment and Use/Disposal
The authorization to land apply treated sewage sludge provided
under this permit is limited to those sludges produced from
the treatment works owned and operated by the City of
and specifically designated below. «
1. Description of Sludge Generating Facilities
Outfall
Serial Number(s)
201
202
Description of Sludge Source
Sludge produced at the City of
treatment works is,
.gravity thiqkened, anaerobically
digested and land applied to
agricultural land during most of
the year.
In the winter the sludge is
anaerobically digested, dewatered
with a belt filter press and
landfilled.
2. Change in Treatment System or Use/Disposal Practice
The permittee must inform the EPA and the
Department of Environment and Natural Resources at least
180 days prior to any significant change'in the sludge
generation and handling processes at the plant and any
major change in use/disposal practices. This includes',
but is not limited to, the addition or removal of sludge
treatment units (e.g.'," digesters, drying beds, etc.) .
and/or any other change.which would require a major
modification of the permit (e.g., changing from land
application to surface disposal).
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. PART I
, . Page 9 of 42
• ' Permit No.:
C. Specific Limitations and Self-Monitoring' Requirements
1. Outfall:201
All sludge generated by this facility to be used for land
application shall meet the requirements of Part I.C.I.a, b and
c listed below. These limits are effective immediately.
However, if significant construction is necessary to meet
these limits, then they must be achieved by February 19, 1995.
a. Chemical Pollutant Limitations
1) If the sludge is to be land applied to agricultural
land, forest land, a public contact site or a . • ,
reclamation site it must meet at all times:
a) The maximum pollutant concentrations listed in
Table 1 and the cumulative pollutant loadings in
Table 2; or
b) The maximum pollutant concentrations in Table 1
and the .monthly average pollutant concentrations
in Table 3. .
If the sludge does not meet these requirements it
cannot be land applied. '
. If .the sludge ,is to be sold or .given away in a bag or
similar enclosure for application to the land for
other than lawn or home garden use it shall meet:
a) The maximum pollutant concentrations in Table 1
and the annual pollutant loading rates in Table 4;
or . . •
b) The maximum pollutant concentrations in Table 1 .
. and the monthly average pollutant .concentrations
"' in Table 3. . • - ' '
,If. the sludge does not meet these requirements it
cannot be sold or given away for land application.
If the sludge is to be applied to a lawn or home
-garden it shall meet:'
a) The monthly average pollutant concentrations in
Table 3. ' "•
If the sludge does, not meet these requirements it
cannot be sold or given away for .application to a lawn
or home garden,.
2)
3)
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PART I
Page 10 of .42
Permit No.:
Specific Limitations and Self-Monitoring Requirements
(Continued) . .
1. Outfall 201 (Continued)
a. Chemical Pollutant Limitations (Continued) c./
-
Total Arsenic
Total Cadmium
Total Chromium
Total Copper
Total Lead
Total Mercury
Total Molybdenum
Total Nickel
Total Selenium
Total Zinc
Table 1
Daily
Maximum
mg/Kg
a/b/ ,
75
85
3000
4300
840 .
57
75
420
100
.7500
Table 2
Cumulative
Loading
Kg/Ha
41
39 .
3000
1500
300
17
N/A
420
100
2800 .
Table 3
, Monthly
Average
mg/Kg
a/d/
41
39
1200
1500
300
17
N/A
420
36
2800
Table 4
Annual
Loading
'Kg/Ha/365
Day
' Period
2.0
' . . 1-9
150
75
15
0.85
N/A
21
5.0
140
a./ See Part I.A. for definition of terms.
b./ The limitations represent maximum allowable levels of pollutants
in any sludge generated at Outfall 201 intended for land
application.
c./ Dry-weight Basis. . .,
d./ These limitations represent the maximum allowable levels, of
pollutants based on an average of all samples taken during a 30-
day period in any sludge generated at Outfall 201 intended for
land application.
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PART I
; '' Page 11 of 42 ,
Permit No.:
Specific Limitations and Self-Monitoring Requirements
(Continued) .
1. Outfall 201 (Continued)
b. Pathogen Limitations
,If the sludge is to be land applied to agricultural
land, forest land, a public contact site or a
.reclamation site it shall be either Class A or Class B
(including,the site restrictions) as described below.
If the sludge does not meet Class B it cannot be land'
i applied. '
If the sludge is to be sold or given away in a bag or
similar enclosure for application to land or for,use
on a lawn or home garden it shall be Class A as
described below.
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PART I
Page 12 of 42
Permit No.:
C. Specific Limitations and Self-Monitoring Requirements
(Continued) ,
1. Outfall 201 (Continued)
b. Pathogen Limitations (Continued)
1) Class A Pathogen Requirements a/
Fecal Coliform
and Salmonella
Limits
Process Requirements (One of the following):
Fecal Coliforms
shall be < 1000
MPN/gram of
total solids b/
OR
Salmonella
shall be < 3
MPN/4 grams of
total solids b/
AND
Composting using either the within-vessel
or static aerated pile composting method,
the temperature of the sludge while in the
composting process is maintained at 55°C or
higher for .three days.
Composting using the windrow method, the
temperature of the windrowed sludge shall
be maintained at 55°C or higher for 15 days
or longer, with a minimum of 5 turnings of
the pile during those 15 days.
a./ There are additional pathogen reduction and vector attraction
reduction alternatives available in 40 CFR 503.32 and 40 CFR
503.33. If the permittee intends to use one of these
alternatives the EPA and the State of must be
informed at least 30 days prior to its use.'This change may be
made without additional public notice.
b/ Based on a geometric mean of a minimum of seven (7) samples of
sludge collected over a two week period (or as approved by the
permitting authority in your sampling and analysis plan, if you
were required to have one).
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PART I
( . , ' , Page 13 of 42
Permit No.:
C. Specific Limitations and Self-Monitoring Requirements
(Continued)
1. Outfall 201 (Continued)
* - '
b. Pathogen Limitations (Continued)
2) Class B Pathogen Requirements a/
Fecal Coliform
Limit ' ' -
Process Requirements (One of the following):
Fecal Coliforms
shall be
< 2,000/000 MPN
or CFU/gram of
total solids b/
OR
The sludge is anaerobically digested
between these times specified: 15 days at
35-55°C and 60 days at 20°C.
Composting, using the within-vessel, static
pile or windrow methods, the temperature
while in the composting process shall be
maintained at 40°C or higher for 5 days.
During those 5 days the'temperature in the
pile shall.exceed 55°C for 4' hours.
a/ There are additional pathogen reduction and vector attraction
reduction alternatives available in 40 CFR 503.32 and 40 CFR
503.33. If the permittee intends to use one of these
alternatives the EPA and the State of must be
informed at least 30. days prior to its use. This change may be
made without additional public notice.
b/ Based on a geometric mean of a minimum of'seven (7) samples of
sludge collected over a two week period (or as approved by the
permitting authority in your sampling and analysis plan, if, you
were required to have one). •
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PART I
Page 14 of 42
Permit No.:
C. Specific Limitations and Self-Monitoring Requirements
(Continued)
1. Outfall 201 (Continued) ,
i . 4
b. Pathogen Limitations (Continued)
3) Site Restrictions
If the sludge is Class B with respect to pathogens, the
permittee shall comply with all of the site restrictions
listed below: ' .-
a) Pood crops with harvested parts that touch the sludge/soil
mixture and are totally above the land surface shall not
be harvested for 14 months after application.
b) Food crops with harvested parts below the land surface
shall not be harvested for 20 months after application if
the sludge remains on the land surface for four months or
more prior to incorporation into the soil.
c) Food crops with harvested parts below the land surface
shall not be harvested for 38 months after application if
' the sludge remains on the land surface for less than four
months prior to incorporation into the soil.
d) Other food crops and feed crops shall not be harvested
from the land for 30 days after application.
e) Animals shall not be allowed to graze on the land for 30
days after application.
f) Turf grown on land where sludge is applied shall not be
harvested for one year after application if the harvested
turf is placed on either land with a high potential for
public exposure or a lawn.
g) Public access to land, with a high potential for public
exposure shall be restricted for one year after
application.
h) Public access to land with a low potential /for public
exposure shall be restricted for 30 days after .
application.
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• . PART I
• ' ' Page 15 of 42
..'•'". Permit No. :
Specific Limitations and Self-Monitoring Requirements
(Continued) . ,
1. Outfall 201 (Continued) ;
c. Vector Attraction Reduction Limitations ' •
If the sludge is to be land applied to agricultural
land, forest land, a public contact site or a
reclamation site it shall meet one of the alternatives
listed below. • ••-.•'"
If the sludge is to be sold 6r given away in a bag or
similar enclosure for application to land or for use
on a lawn or .home garden it shall meet one of the
first. 4, alternatives listed below.
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PART I
Page 16 of 42
Permit No.:
C. Specific Limitations and Self-Monitoring Requirements
(Continued) • , :
1. Outfall 201 (Continued)
c. Vector Attraction Reduction Limitations (Continued) a./
1) The mass of volatile solids in the sludge shall be
reduced by a minimum of-38 percent prior to land
application.
2) If an anaerobically digested sludge cannot meet the 38
percent volatile solids reduction requirement, a
portion of the previously digested sludge shall be
digested anaerobically in the laboratory in a bench-
scale unit for an additional 40 days at 30°C or
higher. At the end of the 40 days, the volatile
solids content shall have been reduced by no more than
17 additional percent. . .. .
3) The sludge shall be treated in an aerobic process for
14 days or longer with a temperature remaining above
40°C. The average temperature shall be greater than
45°C.
4) The pH of the sludge shall be raised to a minimum of
12 by alkali addition, but without the addition of
more alkali, the pH shall remain at 12 or above for 2
hours and remain at a minimum of 11.5 for an
additional 22 hours.
5) The sludge shall be injected below the surface of the
land and ho significant amount of sludge shall be
present on the land surface within one hour after the
sludge is injected. If the sludge meets the Class A
pathogen requirements '(JPart I.C.l.b.l)), the sludge
shall be injected below the land surface within 8
hours after the sludge is discharged from the pathogen
reduction process.
a./ There are additional pathogen reduction and vector
attraction reduction alternatives available in 40 CFR
503.32 and 40 CFR 503.33. If the permittee intends to use
one of these alternatives the EPA and the State of
must be informed at least 30 days prior to its use.
This change may be made without additional public notice.
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PART I
•. . " . . Page 17 of 42 •
. Permit No. :
C. Specific Limitations and Self-Monitoring Requirements
(Continued) f
1. Outfall 201 (Continued) '
c. Vector Attraction Reduction Limitations (Continued) a/
, • 6) Sludge applied to the land surface shall be
incorporated into the soil within 6 hours after
application to the land. Sewage sludge that is
incorporated into the soil and meets the Class A
'pathogen requirements (Part I.C.l.b.l)) shall be
applied to or placed on the land within 8 hours after
being discharged from the pathogen treatment process.
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PART I
Page 18 of 42
Permit No.:
Specific Limitations and Self-Monitoring Requirements • >
(Continued) ...
1. Outfall 201 (Continued)
d. Self-Monitoring Requirements
1) At a minimum, upon.the effective date of this permit,
all chemical pollutants, pathogens and applicable
vector attraction reduction requirements shall be
monitored on a bimonthly basis. Samples or
measurements shall be representative of the nature of
the sludge.. •
2) If this facility does not collect samples on a regular
basis because sampling occurs from long-term treatment
piles, compost piles, drying beds, etc. a sampling and
analysis plan is to be prepared and submitted to the
EPA and the State of , . • ' within 90 days of
issuance of this permit. If, when the permit was
issued the.permittee was not sampling in this manner
but a change in process necessitated this form of
sampling, then the plan must be submitted 30 days
before the change occurs. This plan is to detail how
representative samples are to be obtained and should
include elements presented in Section 2.13 of the
latest version of the Region VIII Biosolids Management
Handbook. The number of samples collected will be at
least as many as those that would be collected
annually as required from the amount of sludge
produced (i.e. six for this facility).
3) Deep soil monitoring for nitrate-nitrogen is required
for all land application sites (does not apply to
sludge that is sold or given away in bags or similar
containers). A minimum of six samples per 320 (or
less) acre area are to be collected. These samples
are to be collected .down to either 5 feet or to the
confining layer, whichever is shallower. Each one
foot increment is to' be composited 'with the other
samples from the site and one analysis for nitrate is
to be done for each increment. Samples are required
to be taken once every five years for non-irrigated
sites or annually for irrigated sites.
4) Soil monitoring for phosphorus (reported as P) is
required for all land application sites (does not
apply to sludge that is sold or given away).. Six
samples of one foot depth each are to be 'collected for
each 320 acre area and composited. Samples'are
required to be taken once every five years for non-
irrigated sites or annually for irrigated sites.
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PART I
Page 19 of 42
Permit No. :
-Specific Limitations and Self-Monitoring Requirements
(Continued)
1. Outfall 201 (Continued) ;
d. Self-Monitoring Requirements .
5) Sample collection, preservation and analysis shall be
, • performed in a manner consistent with the•requirements
of .4.0: CFR Part 503 and/or other criteria specified in
this permit. Metals analysis is to be performed using
method SW 846 with method 3050 used for digestion.
For the digestion procedure, an amount of sludge
equivalent to one .gram dry weight shall be used-. The
methods are also described in the latest version of
the Region VIII Biosolids Management Handbook.
Monitoring for soil nitrate and phosphorus is to be
performed using the methods in Methods of Soil
( Analysis, Part 2. Chemical and Microbiological
Properties. Page, A.. L., Ed., American Society of
. Agronomy and Soil Science Society of America, Madison,
WI, 1982. .
6) Material derived from a sludge that meets the chemical
limitations in Table 3 (Part I.C.I.a.), the pathogen
. requirements in Part L.C.l.b. and one of the first 4--
vector attraction reduction requirements in Part
I.C.I.e. is not required to be monitored unless -
otherwise required by the permitting authority. The
sludge itself is required to be monitored as stated
above. The permitting authority may request
additional monitoring for material derived from sludge
if the data shows a potential for concern.
7) After two years of monitoring at - the frequency
specified, the permittee may request that the
permitting authority reduce the sampling frequency for
the chemical pollutants in Part I.C.I.a. The
,, frequency cannot be reduced to less than once per year
for land applied sludge for any parameter. The
frequency 'also cannot be reduced for any of the
pathogen or vector attraction reduction requirements
listed in this permit. . _ .
8) .If pollutant concentrations in the sludge no longer
meet the limitations in Table 3, the limitations in
Table 2 and/or Table 4 must be used. The permittee
shall determine cumulative pollutant loadings and/or
annual pollutant loadings for each land application
site or for sludge that: is sold or given away.
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PART I :
Page 20 of 42 -
Permit No.:
!
Specific Limitations and Self-Monitoring Requirements
(Continued)
1. Outfall 201 (Continued)
d. Self-Monitoring Requirements
9) The permittee must provide written notification to the
EPA and the State of within 90 days of
the effective date of the permit of the location of
any present land application site where sludge subject
to the cumulative pollutant loading rates has been
applied. This same notification must be given for new
sites as soon as possible, but in no case later than
30 days after the sludge sample was collected.
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. . PART I
•':••. . Page 21 of 42
, Permit No. :
Specific Limitations and Self-Monitoring Requirements
2. Outfall 202 - . .
a. Chemical Pollutant Limitations , .
1) Sludge that is to be landfilled shall be in strict
compliance with 40 CFR 258. It is the responsibility
of the permittee to demonstrate that sludge disposal,
'-. into the landfill is in accordance with 40 CFR. 258 by
submitting routine "Paint Filter Test" and "Toxicity
Characteristic. Leaching Procedure" results to the EPA.
2} The permittee shall report to the EPA the annual
amount and percent solids.of sludge transferred to the
landfill.
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PART I
Page 22 of 42
Permit No.: ;
C. Specific Limitations and Self-Monitoring Requirements
(Continued)
2. Outfall 202 (Continued) ,' ,
b. Vector Attraction Reduction Limitations
Sludge to be landfilled shall meet one of the alternatives
listed in Part I.e.I.e. with this additional alternative:
Sludge placed in a landfill shall be covered with soil or ,
other material at, the end of each operating day.
There are additional vector attraction reduction
alternatives available in 40 CFR 503.33. If the permittee
intends to use one of these alternatives the,EPA must be
informed at least 30 days prior to its use. These limits
are effective,immediately. However, if construction is
necessary to meet these limits, then they must be achieved
by February 19, 1995.
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.'.•.•• PART, I
• ' , Page 23 of 42
Permit No.:
C. Specific Limitations.and Self-Monitoring Requirements
(Continued)
2. Outfall 202 (Continued)
c. Self-Monitoring Requirements
1) At a minimum, upon the effective date, of this permit,
the'paint filter test, determination of percent solids
and applicable vector attraction reduction
'. requirements shall be monitored on a bimonthly basis.
The toxicity characteristic leaching procedure shall
be monitored once during the life of the permit.
Samples or measurements shall be representative of the,
nature of the sludge; • ' '
2) Sample collection and preservation shall be performed
in a manner consistent with the requirements of 40 CFR
. Part 503,. 40 CFR 261 and/or other criteria specified
in this permit. "
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PART I
Page 24,of 42
Permit No.:
D. Management Practices
1. Land, Application Management.Practices
if the sludge or material derived from sludge meets the metals
limits in Table 3 (Part I.G.1.a.), the Class A pathogen
reduction limits in Part I.C.l.b.l) and one of .the first 4
vector attraction reduction alternatives in Part I.C.I.c., the
following .management practices are not required unless
requested by the permitting authority through permit
modification procedures under Part IV.0. of this permit.
The permittee'shall-operate and maintain the land application
site operations in accordance with the following requirements:
a. The permittee shall provide to the EPA and the State of
within 90 days of the effective date of this
permit a land application plan. At a minimum, the plan is
to include the components listed in section 2.3 of the
latest version of the Region VIII Biosolids Management
Handbook. .
b. Application of sludge shall be conducted in a manner that.'
will not contaminate the groundwater or impair the use
classification for that water (if the State has classified
it) underlying the sites. The permittee must, submit
information to the EPA indicating the State's
classification for this groundwater.
c. Application of' sludge shall be conducted in a manner that
will not cause a violation of any receiving water quality
standard from discharges of surface runoff from the land
application sites. Sludge shall not be applied to land iO
meters .or less from waters of the United States (as • '
defined in 40 CFR 122.2).
• • ' .'•'•' '
.d. Application of sludge shall be conducted in a manner that
does not exceed the agronomic rate for available nitrogen
of,the crops grown on the site. At a minimum, the
permittee is.required to follow the methods for
calculating agronomic rate outlined in the latest version
of the Region VIII Biosolids Management Handbook (other
methods may be approved by the permitting authority). The
treatment plant shall provide written notification to the
applier of the sludge of the concentration of total
nitrogen (as N on a dry weight basis) in the sludge.
Written permission from the permitting authority is
required to exceed the agronomic rate.
e. Application of sludge to frozen, ice-covered, or snow
covered sites where the slope of the site exceeds six
percent is prohibited.
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PART I
Page 25 of 42
Permit No.:
Management Practices (Continued) . , •
1. Land Application Management Practices (Continued)
f. No person shall apply sludge for beneficial use to frozen,
ice-covered, or snow-covered land where the slope of such
land is greater than three percent and is less than or equal
to six percent unless one of the following requirements is,
met:
' •",'''' •
1) there is 80 percent vegetative ground cover; or,
• ' - , / .
2) approval has been obtained based upon a plan
demonstrating adequate runoff containment measures.
g. Sludge shall not .be applied to sites where the available
phosphorous content of the soil exceeds the following:
1) for sodium bicarbonate extraction, 100 ppm;
2) for AB-DPfA extraction, 50 ppm;
t
3) for Bray PI extraction, 170 ppm;
4) available phosphorus levels shall be determined.based
upon the Bray PI extraction when the soil pH is 6.5 or
less. , '
The permittee may request these limits be modified if
different limits would be justified based on local
conditions. The limits are required to be developed in
cooperation with the local agricultural extension office or
university.
h. Sludge shall not be applied to any site area with standing
surface water. If the annual high groundwater level is
known or suspected to be within five, feet of the. surface,
additional deep soil monitoring for nitrate-nitrogen as
described in Part I.C.l.d.3) is to be performed. At a
minimum, this additional monitoring will involve a
collection of more samples in the affected area and possibly
more frequent sampling.' The exact number of samples to be
collected will be outlined in a deep soil monitoring plan to
be submitted to the EPA and the State of ' within
90 days of the effective date of this permit. The plan is
subject to approval by the permitting authority.
i. The specified cover crop shall be planted during the next
available planting season. If this does not occur, the
permittee shall notify .the Director in writing. Additional
restrictions may be placed on the application of the sludge
on that site on a case-by-case basis to control nitrate
movement. Deep soil monitoring may be increased, under the
discretion of the permitting authority.
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PART I
Page,26 of 42
Permit No.:
Management Practices (Continued)
l. Land Application Management Practices (Continued).
1 • if
j. The sludge or the application of the sludge shall not
-cause or contribute to the harm of a.threatened or
endangered species or result in the destruction or adverse
modification of critical habitat of a threatened or
endangered species after application. •
v ' ~ ,
k. When weather and or soil conditions prevent adherence to
the sewage sludge application procedure, sewage sludge
shall not be applied on the site.
1. For sludge that is sold or given away, either a label
shall be affixed to the bag or similar enclosure or an
information sheet shall be provided to the person who
. receives the sludge. The label or information sheet shall
contain:
1) The name and address of the person who prepared the *
sludge for sale or give away for application to the
. land. ' ••'.'. '•-..•-''
2) A statement that prohibits the application of the
sludge to the land except in accordance with the
instructions on the label or information sheet. ,
3) The annual whole sludge application rate for the
sludge that does not cause the annual pollutant
loading rates in Table 4 (Part I.C.I.a.) to be
exceeded.
m. Sludge subject to the cumulative pollutant loading rates
in Table 2 (Part I.C.I.a.) shall not be applied to
agricultural land, forest, a public contact site, or a .
reclamation site if any of the cumulative pollutant
loading rates in Table 2 have been reached.
n. If the treatment plant applies the sludge, it shall .
provide the owner or lease holder of the land on which the
sludge is applied notice and necessary information to
comply with the requirements in this permit. ,
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PART I .
Page 27 of 42
Permit No.:
D. Management Practices (Continued)
1. Land Application Management Practices (Continued)
o. Before sludge subject to the cumulative pollutant loading
rates in Table 2 (Part I.C.I.a.) is applied to the land,
the person who proposes to apply the sludge shall contact
the permitting authority to determine whether sludge
subject to the cumulative pollutant loading rates in Table
2 has been applied to the site since July 19, 1993.
1) If sludge subject to the cumulative loading limits in
Table 2 has not been applied since July 19, 1993, the
cumulative amount for each pollutant listed in Table 2
may be applied to the site in accordance with Table 2.
2) If sludge subject to the cumulative loading limits in
Table 2 has been applied since July 19, 1993, and the
cumulative amount of each pollutant applied to the
site in the sludge ,since that date is known,, the
cumulative amount of each pollutant applied to the
site shall be used to determine the additional amount
of each pollutant that can be applied to the site in
accordance with Table 2.
3) If sludge subject to the cumulative loading limits in
Table 2 has been applied since July 19, 1993, and the
cumulative amount of each pollutant applied to the
site in the bulk sewage sludge since that date is not
known, an additional amount of each pollutant shall
not be applied to the site.
p. For sludge or material derived from sludge that is stored
in piles for one year or longer, measures shall be taken
to ensure that erosion (whether by wind or water) does not
occur. However, best management practices -should also be
used for piles used for sludge treatment. If a treatment
pile is considered to have caused a problem, best
management practices-could be added as a requirement in
the next permit renewal.
g. The permittee shall inspect the application of the sludge
to active sites to prevent malfunctions and deterioration,
operator errors and discharges which may cause or lead to
the release of sludge to the environment or a .threat to
human health. The permittee must conduct these
inspections often'enough to identify problems in time to
correct them before they harm human health or the
environment. The permittee shall keep an inspection log
or summary including at least the date and time of
inspection, the printed name and the handwritten signature
of the inspector, a notation of observations made and the
date and nature of any repairs or corrective action.
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• . PART I
Page 28 of 42 .
• . , Permit No. :
D. Management Practices (Continued) :-'
2. Landfilling Management Practices
The permittee shall follow these management practices:
••- a., Landf illing of sludge shall be conducted in a manner that
will not contaminate the groundwater underlying the site.
b. Landfilling of sludge shall be conducted in a manner that
will not cause a violation of any'receiving water quality
standard from discharges of surface runoff.
c. The landfilling of sludge shall not cause or contribute to
the harm of a threatened or endangered species or result
'in the destruction or adverse modification of critical-
habitat of a threatened or endangered species.
d. •. Landf illing of sludge shall not restrict the flow of a
100-year flood.
e. Public access to the site shall "be restricted so that the
public is not exposed to potential health and safety ' •
hazards. ' • • . '
f. Explosive gases generated by the facility shall not exceed
25 percent" of the lower explosive limit for the gases in
the facility structures and 100 percent of the lower
explosive limit at the property line. .
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PART I
Page 29 of 42
Permit No.:
Special Conditions on Sludcre Storage
Permanent storage of sewage sludge is prohibited. Sludge
shall not be temporarily stored for more than two years.
Written permission to store sludge for more than two years
must be obtained from.the permitting authority. Storage of
sludge for more than.two years will be allowed only if it is
determined that significant treatment is occurring.
Recordkeeping
1. Recordkeeping for Land Application • .
a. If the permittee prepared' material derived from sludge
that meets the limits in Table 3 (Part I.C.I.a.), the
Class A pathogen requirements in Part I.C.l.b.l) and one
of the first 4 vector attraction reduction alternatives in
Part I.C.I.e., the permittee is not required to keep
'. records on that material unless otherwise required by the
permitting authority. :
b. The permittee is required to keep the following
information for at least 5 years: . ~
1) Concentration of each pollutant in Table 1 .(Part
I.C.I.a.).
2) A description of how the pathogen reduction •
requirements in Part I.C.l.b. were met.
3) A description of how the vector attraction reduction
requirements in Part I.C.I.e. were met.
4) A description of how the management practices, in Part
I.D. were met (if necessary). • .. . ,
- 5) A description of how the site restrictions in Part
I.C.l.b.3) were met (if necessary).
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PART I
Page 30 of 42
Permit No.:
F. Recordkeeping (Continued)
Recordkeeping for Land Application (Continued)
7) The following certification statement:
"I certify under the penalty of law, that the pathogen
requirements in Part I.C.l.b., one of the vector
attraction reduction alternatives in Part I.e.I.e.,
the management practices in Part I.D. (if necessary)
and the site restrictions in Part I.C.l.b.3) (if
necessary) have been met. This determination has been
made under my direction and supervision in accordance
with the system designed to assure that qualified
personnel properly gather and evaluate the information
used to determine that the pathogen requirements, the
vector attraction reduction requirements, the
management practices and the site restrictions have
been met. I am aware that there are significant
penalties for false certification including the
possibility of imprisonment."
Landfill Recordkeeping
a. The permittee is required to keep the following
information for at least 5 years:
1) Results of the paint filter tests, determination of
percent solids and toxicity characteristic leaching
procedure tests (Part I.C.2.a.).
2) A description of how the vector attraction reduction
requirements in Part I.C.2'.b. were met.
3) A description of how the management practices in Part
I.D. were met.
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PART I - .
"... '•'. . . • . . Page 31 of 42 . . .
. . Permit No.:
E. Recordkeeping (Continued) , '
2. Landfill Recordkeeping (Continued)
4) The following certification.statement:
. . "I certify under the penalty of law, that the paint
filter tes.ts and toxicity characteristic leaching
procedure tests Part I.C.2.a., one of the vector
attraction reduction alternatives in Part I.C.2.b. and
the management practices in Part I.D. have been met.
••-.'..' .. ' This determination has been made under my direction >
and supervision in accordance with the system designed
. to assure that qualified personnel properly gather and
•."•: evaluate the: information used to determine that the
pathogen .requirements, the vector attraction reduction
requirements, the management practices and the'site
restrictions have been met. , I am aware that there
.-..,. . are significant penalties for false certification
including the possibility of imprisonment."
3. Records of monitoring information shall include:
a. The date> exact place, and time of sampling or
measurements;
'b. The initials or name(s) of the individual(s) who
performed the sampling or measurements;
c. The date(s) analyses were performed; .
d. The time(s) analyses were initiated; • ;
e. The initials or hame(s) of .individual(s) who performed
the analyses;
f. References and written procedures, when available, for
the analytical techniques or methods used; and,
g. The results of such analyses, including the bench
sheets, instrument readouts, computer disks or tapes,
etc., used to determine these results.
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PART I
Page 32 of 42
Permit No.:
E. Recordkeeping (Continued)
The permittee shall retain records of all monitoring
information, including all calibration and maintenance
records and all original strip chart recordings for
continuous monitoring instrumentation, • copies of all
reports required by this permit and records of all data
used to complete the application for this permit for the
life of the permit. Data collected on site, copies of
Sludge Report forms, and a copy of this NPDES sludge-only
permit must be maintaine'd on site during the duration of
activity at the permitted location.
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, PART II v -.'•.-•'.
' - -. '--'.•• .,.•'• page 33 of 42
Permit No.:
' • ,•' ' • -'
II. MONITORING, RECORDING AND REPORTING REQUIREMENTS - -
A. Representative Sampling. Sludge samples used to measure .
compliance with Part I of 'this Permit shall be collected at
locations representative of the quality.of sludge generated
'at the treatment'works and immediately prior to land >
application. -.:'••
B. Monitoring Procedures. Monitoring must be conducted
according to test procedures approved under.40 CFR Part 503
unless other test procedures, have been specified in this
permit. See Part I.e. for any applicable sludge monitoring
: procedures.
C. Penalties for Tampering. The Act provides .that any person
who falsifies, tampers with, or knowingly renders
inaccurate, any monitoring device or method required to be .
, .maintained under this permit shall, upon conviction, be
punished by a fine of not more than '$10,000 per violation,
or by imprisonment for not more than two years per
violation, or by both. Second conviction is punishable by a
fine of not more than $20,000 per day of violation, or by
imprisonment of not more than four years, or both.
D. Reporting of Monitoring Results. ,
/ '".'.•'.
The permittee shall provide the results of all monitoring
performed in accordance with Part I.C., and information on
management practices, land application sites, site
restrictions and certifications shall be provided no later
than February 19 of each year. Each report is for the
previous calendar year. If no sludge was applied to the
land during the reporting period, "no sludge was applied"
shall be reported. Until further notice, sludge monitoring
, results may be reported in the testing laboratory's normal
format (there is no EPA standard form at this time), but
should be on letter size pages. Legible copies of these,
and all other reports, required herein, shall" be signed and
.certified in accordance with the Signatory Requirements (see
Part IV), and submitted to the Director, Water Management
Division and the Department ,of Environment and
Natural Resources at the following addresses:, ,
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PART II
Page 34 of' 42
Permit No.:
Reporting of Monitoring Results (Continued)
original to:
United States Environmental
Protection Agency
Region VIII
Denver Place
999 18th Street, Suite 500
Denver, Colorado 80202-2466
Attention:
Water Management Division
Regional Sludge Program,
NPDES Branch (8WM-C)
copy to:
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PART II
• Page 35 of 42 .
Permit No.:
' • , . i- •
Additional Monitoring by the Permittee. If the permittee monitors
any pollutant more frequently than required by this permit, using
test procedures approved under 40 CFR 503 or as specified in this
permit, the results of this monitoring shall be included in the
calculation and reporting of the data submitted on the Sludge
Report form. Such increased frequency shall -also be indicated.
Twenty-four Hour Notice-of Noncompliance Reporting
1. The permittee shall report any noncompliance including
transportation accidents, 'spills, and uncontrolled runoff from
sludge transfer or land application sites which may seriously
endanger health or .the environment.as soon as possible, but no
later than 24 hours from the time the permittee first became
aware of the circumstances. The report shall be made to the
EPA, Region VIII, Emergency Response Branch at (303) 293-1788
and"the State of
2. The following occurrences of noncompliance shall be reported
by telephone to the EPA, Region VIII, Compliance Branch at
(303) 293-1628 by the first workday (8:00.-a.m. - 4:30 p.m.
Mountain Time), and the State of
by the first workday (8:00 a.m. - 4:30' p.m. Central Time)
following the day the permittee became aware of the
circumstances: ' - .
a. Violation of any of the Table 1 metals limits, the
pathogen limits, the vector attraction reduction limits, or
the management practices for sludge that has been land
applied.
3. A written submission shall also be provided within five days
of the time that the permittee becomes aware of the
circumstances. The written submission shall contain:
a. A description of the noncompliance and its cause;
b. The period of noncompliance, including exact,dates and
times; ,--,'..
c. The estimated time noncompliance is expected to .continue
if it. has not been corrected; and, .
d. Steps taken or planned to reduce, eliminate, and prevent
• reoccurrence of the noncompliance.
4. The Director may waive the written report on a case-by-case
basis if the oral report has been received within 24 hours by
the Compliance Branch, Water Management Division, Denver,
Colorado, by phone, (303) 293-1628.
5. Reports shall be submitted to the addresses in Part II.P..
Reporting of Monitoring Results. •''.••-
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PART II
Page 36 of 42
Permit No.:
G. Other Noncompliance Reporting. Instances of noncbm.pliance not
required to be reported within 24 hours shall be reported at the
time that monitoring reports for Part II.D. are submitted. The
reports shall contain the information listed in Part II.F.3.
H. Inspection and Entry. The permittee shall allow the Director,
or authorized representative thereof, upon the
presentation of credentials and other documents as may be required
by law, to:
1. Enter upon the permittee's premises where a regulated facility
or activity is located or conducted, or where records must be
kept under the conditions of this permit;
2. Have access to and copy, at reasonable times, any records that
must be kept under the conditions of this permit;
3. Inspect at reasonable times any facilities, equipment
(including monitoring and contrql equipment), practices, or
operations regulated or required under this'permit, including,
but not limited to, sludge treatment, collection, storage
facilities or area, transport vehicles and containers, and
land application sites; and, •
4. Sample or monitor at reasonable times, 'for the purpose of
assuring permit compliance or as otherwise authorized by the
Act, any substances or parameters at any location, including,
but not limited to, digested sludge before dewatering,
dewatered sludge, sludge transfer or staging ar.eas, any ground
or surface waters at the land application sites, or sludges,
soils, or vegetation on the land application sites.
5. The permittee shall make the necessary arrangements with the
landowner or leaseholder to obtain permission or clearance, so
that the Director,
or authorized
representative thereof, upon the presentation of credentials
and other documents as may be required by law, will be
permitted to enter without delay for the purposes of
performing their responsibilities.
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PART III
Page 37 of,42
Permit No.:
il:
COMPLIANCE RESPONSIBILITIES
A. Duty to Comply. The permittee must comply with all
conditions of this permit. Any permit noncompliance
constitutes a violation of the Act and is grounds for,
enforcement action; for permit termination, .revocation and
reissuance, modification, or for denial of a permit renewal.
The permittee shall give the Director advance notice of any.
planned changes at the permitted facility or of any activity
which may result in permit noncompliance. .
B. Penalties for Violations of Permit Conditions.
1. The Act provides that any person who violates ,a permit
. condition implementing Sections 301, 30'2, 306, 307, 308,
318, 402, or 405 of the Act is subject to a civil
. -penalty not to exceed $25,000 per day for each
violation^ Any person who negligently violates permit
conditions implementing Sections 301, 302, 306,, 307,
308, 318, 402 or 405 of the Act is subject to a fine of
$2,, 500 to $25,000 per day of violation, or imprisonment
for not more that 1 year, or both. Any person who
knowingly violates such sections or such conditions is
subject to a fine of $5,000 to $50,000 per day of
violation, or imprisonment for not more than 3 years, or
both. Any person who violates Sections 301 302, 303, .
306, 307, 308, 318, 402, or 405 of the Act and who .knows
at that time that he thereby places another person'in
imminent danger of death or serious bodily injury,
shall, upon conviction, be subject to a fine of not more
than $250,000 or imprisonment of not more than 15 years,
or both. •'. ' -.. -
• 2. Any person who violates permit conditions implementing
Sections 301, 302, ,306, 307, 308, 318, 402, or 405 of
the Act may be assessed an administrative penalty by the
Administrator. Administrative penalties are not to
exceed $10,000 per day for each day during which the
violation continues, wit,h the maximum amount of any
penalty not to exceed $125,000. •
C. Need to Halt or Reduce Activity not a Defense. It shall not
be a defense for a permittee in an enforcement action that
it would have been necessary to halt, or reduce the permitted
activity in order to maintain compliance with the conditions
of this permit.
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PART III
Page 38 of 42
Permit No.:
D. Duty to Mitigate. The permittee shall take all reasonable steps
to minimize or prevent any land application in violation of this
permit. ' • .
E. Proper Operation and Maintenance. The permittee shall at all
times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances), including but
not limited to, all treatment, transportation, and application
equipment which are installed or used by the permittee to achieve
compliance with the conditions of this permit. Proper operation
and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures. This provision requires
the operation of back-up or auxiliary facilities or similar
systems which are installed by a permittee only when the operation
is necessary to achieve compliance with the conditions of the
permit. • • .
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PART IV
Page 39 Of 42
Permit No. :
IV. GENERAL REQUIREMENTS
A. Planned Changes. The permittee shall, give notice to the
Director as soon as possible of any planned physical
alterations or additions to the permitted facility. Notice
is required only when: , '
1. 'The alteration or addition could significantly change
• the nature or increase the quantity of pollutant land
applied. This notification applies to pollutants which
are not subject to limitations in the permit; or,
2. The alteration or addition to a permitted facility may
meet one of. the .criteria for determining whether a
facility is a new source.
B. Anticipated Noncompliance. The permittee shall give advance
notice to the Director of any planned changes in the :
permitted facility or activity which may result in'
noncompliance with permit requirements.
C.'' Permit Actions. This permit may be modified, revoked and
reissued, or terminated for cause. The filing of a request .
by the permittee for a permit modification, revocation and '-
' reissuance, or termination, or a notification of planned
changes or anticipated noncompliance, does not stay any"
permit condition. :
D. Duty to yReapply. If. the permittee wishes to continue an
activity regulated by this permit after the expiration date
of this permit, the permittee must apply1 for and obtain a
new permit. The application should be submitted at least
180 days before the expiration date of this permit.
E. Duty to Provide Information. The permittee shall furnish to
the Director, within a reasonable. time,, any information .
•which the Director may request to determine whether cause
exists for modifying, revoking and reissuing, or terminating
this.permit, or to determine compliance with this permit.
The permittee shall also furnish to the Director, upon -;
request, copies of records required to be kept by this
. permit. •
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- _ PART IV;
• - ' • Page 40 of.42: .
' :• ' •> .. Permit No. :
Qther Information. When the permittee becomes aware that it-
failed -to submit any relevant•facts in a permit application, or
submitted .incorrect information in a permit application or any
report to the Director, it shall promptly submit such facts or
information. . ,' ,
Signatory Requirements. All ,applications, reports or information
submitted to the Director shall be signed and certified.
1. All permit applications shall be signed by either a principal
executive officer or ranking elected official.
2. All reports required by the permit .and other information
requested by the Director shall be signed by a person
described above or by a duly authorized representative of that
person. A person is a duly authorized representative only if:
a. The authorization is made in writing by a person described
• , above and submitted to the Director; and,
b. The authorization specifies either an individual or a
position having.responsibility for the overall.operation
of the regulated facility, such as the position of plant
',. manager, superintendent,. position of equivalent
responsibility, or an .individual or position having
.. overall responsibility for environmental matters. (A duly
authorized representative may thus be either a named
individual or any individual occupying a named position.)
3. Changes to authorization. If an authorization under Part
IV.G.2. is no longer accurate because a-different individual
or position has responsibility for the overall operation of:
the facility, a new authorization satisfying the requirements
'of Part IV.G.2. must be" submitted to the Director prior to or
together with any reports, information,' or applications to be
signed by an authorized representative.
• 4. Certification. Any person signing a document, under this ,•
,. section shall make the • following certification: , "
"I certify under penalty of law that this document and all,
attachments were prepared under my direction' or"supervision in
accordance with a system designed to assure that qualified
personnel properly gather and evaluate the,information
submitted. Based on my inquiry of the person or persons who
manage the system, or those persons directly responsible for
gathering the information, the information submitted is, to
the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for
submitting false information, including the possibility of
fine and imprisonment for knowing violations."
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PART IV
Page 41 of 42
Permit No.:
H. Penalties for'Falsification of Reports. The Act provides that any
person who knowingly makes any false statement, representation, or
certification in any record or other document submitted.or
required to be maintained under this permit, including monitoring
reports or reports of compliance or noncompliance shall, upon
conviction be punished by a fine of not more than $10/000 per
violation, or by imprisonment for not more than six months per
violation, or by both. ...'.• • '
I. Availability of Reports. Except for data determined to be
confidential under 40 CFR Part 2, all reports prepared in
accordance with the terms of this permit -shall be available for
public inspection at the offices of the ' Department of
Environment and Natural Resources and the Director. As required
by the Act, permit applications, permits and all data necessary to
determine compliance with the permit conditions or applicable
Federal or State sludge regulations shall not be considered
confidential. . ,
J. Oil and Hazardous Substance Liability. Nothing in this permit
shall be construed to preclude the institution of any legal action
or relieve the permittee from any responsibilities, liabilities,
or penalties to which the permittee is or may be subject under
Section 311 of the Act. .
K. Property Rights. The issuance of this permit does not convey any
property- rights of any sort, or any exclusive privileges, nor does*
it authorize any injury to private property or any invasion of
personal rights, nor any infringement of federal, state or local
laws or regulations. ,
L. Severability. The provisions of this permit are severable, and if
any provision of this permit,, or the application of any provision
of this permit to any circumstance, is held invalid, the
application of such provision to other circumstances, and the
remainder of this permit, shall not be affected thereby.
M. Transfers. This permit may be automatically transferred to a new
permittee if: ., '
1. The current permittee notifies the Director at least 30 days
in advance of the proposed transfer date;
2. The notice includes a written agreement between the existing
and new permittees containing a specific date for transfer of
permit responsibility, coverage, and liability between them;
and, • "
3. The Director does not notify the existing permittee and the
proposed new permittee of his or her.intent to modify, or
revoke and reissue the permit.1 If this notice is not
received, the transfer is effective on the date specified in
the agreement mentioned in paragraph 2. above.
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PART.IV - ' -
Page 42 of 42
.':'• . •< . Permit No. : - : •-- . •
N. State or Federal Laws. Nothing in this permit, shall be construed
to preclude the institution of any legal action or relieve the
.. permittee from any responsibilities, liabilities, or penalties
established pursuant to any applicable state law or regulation
under authority preserved by Section 510 of the Act or any
applicable Federal or State transportation regulations, such as
but not limited to the Department of Transportation regulations.
0. Reopener Provision'. This permit may be reopened and modified-
(following proper administrative procedures)- to include the
appropriate sewage sludge limitations (and compliance schedule, if
necessary), management practices, other appropriate requirements
:to protect public health and the environment, or if there have „..
been substantial changes (or such changes are planned): in'sludge
use or disposal practices; applicable management practices or
numerical limitations for pollutants in sludge have been
promulgated which are more stringent than the requirements in this
. permit; and/or it has been determined that the permittee's sludge
use or land application practices do not comply with existing
applicable state or federal regulations. ,_
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APPENDIX H
NUTRIENT MANAGEMENT PLANNING
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NUTRIENT MANAGEMENT PLANNING
Nutrient Management Planning
Many factors can affect the likelihood of nitrate leaching from land-applied sewage sludge to ground
water. These range from physical factors, such as soil type and climatic conditions, to management
techniques used during the application of sewage sludge. Table H-l describes the major physical factors
influencing the transport of land-applied nitrogen to ground water. Many of the factors that affect "the
off-site transport of nutrients to surface water are described in Table H-2. This table focuses on physical
factors, although management techniques used in the application of sewage sludge can also affect off-site
transport.
Nutrient management represents the most effective way to reduce offsite nitrogen transport, as it
incorporates principles that lower nitrogen losses to all environmental media — surface water, ground
water, air, and soil. Simply put, the most effective way to reduce the loss of fertilizer-derived nitrate
to ground water is to reduce the quantity of nitrogen applied. Comprehensive nutrient management
planning incorporates a variety of measures that minimize the edge-of-field delivery of nutrients and
minimize the leaching of nutrients from the root zone by eliminating the application of excess nutrients,
improving the timing of nutrient application^ and using agronomic crop production technology to increase
nutrient use efficiency. Many localities and States require nutrient management planning for an array of
land use types, especially agricultural lands. The principal components of nutrient management planning
are summarized in Table H-3. Additional sources of information on nutrient management planning
include county extension agents, soil conservation service district . conservationists, and agricultural
consultants Some of the recommendations included in Table H-3, especially these associated with the
consideration of environmentally high risk areas, need an assessment of site-specific conditions (e.g.,
depth to ground water and soil type).
Nutrient management planning is particularly important to understand when sewage sludge or any nutrient
source is land applied to more environmentally sensitive areas, such as:
• Lands near surface water or wetlands ,
•, Soils with high leaching indices
• Irrigated land in humid regions
• Highly erodible soils .
• Shallow aquifers
• Karst topography containing sink holes and shallow soils over fractured bedrock.
In some instances, it may be better to avoid the application of sewage sludge altogether. Such locations
include:
• Areas having a shallow depth to ground, water, or seasonal high water table, especially if soils
are coarse-textured. ,
• Soils with very high (sands) or very low (clay) permeability, and poorly drained soils.
• Steep slopes. If impossible to avoid application, use erosion and sediment controls.
• Areas where the soil cover is limited (e.g., less than approximately 4 feet thick in the humid east
coast) over bedrock, sink holes, and water table.
H-l
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NUTRIENT MANAGEMENT PLANNING (Continued)
Nutrient management planning, as described in the previous section, is the most effective way of reducing
the quantity of land-applied nutrients available to contaminate surface and ground water. In addition to
nutrient management planning to reduce the quantity of nutrients applied and increase nutrient uptake
efficiency, sediment-bound nutrients (e.g, orthophosphate) should be managed using erosion and sediment
controls. ,
Nutrient runoff from the land is a function of the nutrient quantity and concentration in its carrier (water
or sediment), the mass of the carrier, and the ease, at which delivery to receiving waters can occur.
Nutrient management planning serves to reduce nutrient quantities and concentrations. A variety of best
management practices (BMPs) to control erosion and sediment can be used to reduce the carrier mass and
reduce pollutant delivery. Table H-4 briefly defines these BMPs. The choice of BMPs and their
effectiveness depends on complex site-specific factors such as soil type, slope, local climatic conditions,
crop type and farming technique, and farmer diligence. It is impossible to describe in this document all
of the considerations that must be taken into account when identifying BMPs to be used on a particular
site. Most State and local agricultural agencies have done extensive research on the effectiveness and
suitability of BMPs for their jurisdictions. For example, the USDA - Soil Conservation Service sponsors
a series of Field Office Technical Guides (FOTGs) that contain a variety of information on soil
conservation practices and resource management, including standards and specifications for BMPs. These
guides are prepared for specific geographic areas.
When evaluating BMPs to reduce erosion and sediment run-off, it is criticalto recognize that some
techniques, depending on site-specific conditions, can actually have the potential to increase nitrogen
leaching by reducing and/or storing the carrier mass. .Techniques that reduce the carrier mass (e.g.,
conservation tillage, terracing) may increase the concentration of nutrients, while techniques to contain
sediments (e.g., sediment detention basins) may increase the amount of time available for leaching. The
potential for enhanced ground-water contamination from these practices is extremely site-specific. Table
H-5 provides general information on the effectiveness of certain BMPs on protecting'ground and surface
water bodies. It is interesting to note that only nutrient management planning and the use of cover crops
definitively protect both surface and ground water resources.
Hr2
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NUTRIENT MANAGEMENT PLANNING (Continued)
TABLE H-l MAJOR FACTORS INFLUENCING TRANSPORT OF LAND-APPLIED
NITROGEN TO GROUND WATER
Factor
Climate
Precipitation . - - .
)
Evapotranspiration
Temperature
Soil Properties
Water Content
Bulk Density ,
Hydraulic Conductivity
Texture
Soil Structure
Depth to Ground Water
Impact QH Ground Water
Precipitation and/or irrigation has a dominant effect on the leaching of nitrate
to ground water. The extent of nitrate leaching is directly related to the
amount of water infiltrating the soil. Nitrate is most likely to leach below the
i;oot zone when Soil is at or near saturation (enables maximum hydraulic
conductivity). Heavy precipitation immediately after application also
increases nitrate losses to ground water, especially if soil is permeable. '
Evapotranspiration rates in excess of precipitation and/or irrigation will
reduce the potential for nitrate leaching as there is usually insufficient water
to transport nitrate past the root zone. Conversely, if evapotranspiration rates
are low, water and dissolved materials (e.g. , nitrates) can move downward
below the root zone.
Temperature affects all nitrogen transformation processes (e.g,
immobilization, mineralization, nitrification, and denitrification). However,
temperature impacts on the movement of water and solutes in soils are poorly
understood and are likely to be only a small factor in nitrate leaching.
Soluble nitrate is transported by soil water. Increased soil water levels
increase the movement of water and nitrate within and below the root zone.
Decreasing porosity or increasing bulk density (the two are inversely related)
decreases the leaching potential of nitrogen by decreasing the cross-sectional
area available for mass flow and increasing path lengths of w,ater flow.
Soils with high hydraulic conductivity in relation to the initial infiltration of
water (e.g. , sands) have a greater potential for the mass transport of water
and dissolved solutes below the root zone. '
Particle size distribution affects water retention, porosity, hydraulic
conductivity^ and adsorption capability. In general, coarser soils (e.g., sands)
have greater capacity for mass transport and fewer opportunities for
adsorption of nitrogen. Finer soils (e.g., silts and clays) have a greater
capacity for adsorption, which reduces the leaching potential of nitrate. Soils
with extremely high or extremely low permeability should be avoided.
Highly permeable soils are too susceptible to leaching, while soils with low
permeability may have internal drainage problems that restrict sludge
decomposition. ^
Highly structured soils haye preferential pathways allowing the mass transport
of water and solutes below the root zone.
Shallow ground water has a greater potentialfor contamination with nitrates
because the distance and resulting travel time for materials leached below the
root zone is lessened.
Source: Adapted from Spectrum Research, Inc.
H-3
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NUTRIENT MANAGEMENT PLANNING (Continued)
TABLE H-2 MAJOR FACTORS INFLUENCING TRANSPORT OF LAND-APPLIED
NUTRIENTS TO SURFACE WATER
Factor
Impact on Surface Water
Nitrogen
Phosphorus
Climate
Rainfall/run-off
Highest concentration of N in run-off
occurs with first significant
rainfall/run-off event after
application. Because of high
solubility/mobility of N, the
concentration and availability of N at
the soil surface dissipates with time.
Highest concentration and loss of P in
run-off occurs with first significant
rainfall/run-off event after application.
The availability of soluble P in run-off
dissipates rapidly with time, because P
has a propensity to adsorb to soil
particles. Since mass loss of P is
related to sediment transport, peak run-
off loading of P corresponds to peak
sediment loads.
Rainfall Intensity
Run-off occurs when precipitation
exceeds Infiltration. As rainfall
intensity increases, infiltration
decreases and run-off rate increases.
Increased amount and velocity of
run-off increases the energy available
for nitrogen extraction and transport.
Run-off occurs when precipitation
exceeds infiltration. As rainfall
intensity increases, infiltration decreases
and run-off rate increases. Increased
amount and velocity of run-off increases
the energy available for sediment
transport, and therefore, phosphorous
Ipss.
Rainfall
Duration/Amount
As rainfall duration/amount increase,
conditions for subsurface leaching of
nitrogen also increase. Nitrogen may
leach below the zone of surface run-
off leach extraction and transport,
thus decreasing'nitrogen
concentration hi run-off.
Increased rainfall duration/amount may
affect depth of surface interaction with
soil-adsorbed phosphorus. Since
phosphorus is much less soluble and
mobile than nitrogen, the concentration
of phosphorus in run-off is altered less
than that of nitrogen.
Time to Run-off After
Application
Nitrogen concentration in run-off and
time to run-off are inversely related;
run-off concentrations of nitrogen
increase as time to run-off decreases.
As the time from application to run-
off event increases, a greater
proportion of the nitrogen is
immobilized or leached below the
zone of surface run^off extraction.
Phosphorus concentration in run-off and
time to run-off are inversely related;
run-off concentrations of phosphorus
increase as time to run-off decreases.
As the time from application to run-off
event increases, a greater proportion of
the phosphorus is immobilized or
adsorbed/precipitated on soil surfaces
and not available in soluble form for
run-off.
H-4
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i NUTRIENT MANAGEMENT PLANNING (Continued)
TABLE H-2 MAJOR FACTORS INFLUENCING TRANSPORT OF LAND-APPLIED
i NUTRIENTS TO SURFACE WATER (Continued)
Factor
Impact on Surface Water
Nitrogen
Phosphorus
Soil
Soil Texture
Soil texture affects -infiltration rates,
soil credibility, particle transport
potential. Run-off typically increases
on fine-grained soils, while
infiltration increases on coarse-
grained soils (e.g., sand). Time to
run-off is longer on coarse-grained
soils, possibly reducing initial run-off
losses of soluble nitrogen.
Conversely, time to run-off typically
decreases with fine-grained soils.
Run-off velocity also increases with
fine-grained soils. '
Soil texture affects infiltration rates, soil
credibility, particle transport potential.
Soil texture also affects phosphorus
adsorption sites.. Run-off typically
increases on fine-grained soils, while>~-
infiltration increases on coarse-grained
soils (e.g., sand). Time to ran-pff is
longer on coarse-grained soils', possibly
reducing initial run-off losses of soluble
phosphorus.
Surface
Crusting/Compaction
Decreases infiltration rates, reduces
time to run-off, and increases initial
concentrations of soluble-nitrogen.
Decreases infiltration rates, reduces
time to run-off, and increases initial
concentrations of soluble-phosphorus.
Water Content
As the water content of soil
increases, especially if soils are wet.
at the time of application, the run-off
potential may be increased, time to
run-off may be reduced, and the
amount of subsurface leaching
reduced.
As the water content of soil increases,
especially if soils are wet at the time of
application, the run-off potential may be
increased, time to run-off may be
reduced. ••'••,
Slope
Increasing slope may increase rim-off
rate and soil detachment/transport.
In general, slopes of less than 6
percent are considered suitable for
land application; less than 4 percent
is ideal. Steeper slopes can be used
if careful crop and soil management
is employed.
Increasing slope may increase run-off
rate and soil detachment/transport. In.
general, slopes of less than 6 percent
are considered suitable for land
application; less than 4 percent is ideal.
Steeper slopes can be used if careful
crop and soil management is employed.
Degree of Aggregation
and Stability
Affects infiltration rates, crusting
potential, effective depth for
entrainment, sediment transport
potential, and adsorbed nitrogen
enrichment in sediments.
Affects infiltration rates, crusting
potential, effective depth for
entrainment, sediment transport
potential, and adsorbed phosphorus
enrichment in sediments. • '
Source: Adapted from Spectrum Research, Inc.
H-5
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NUTRIENT MANAGEMENT PLANNING (Continued)
TABLE H-3 PRINCIPAL COMPONENTS OF NUTRIENT MANAGEMENT PLANNING
Application Rate: Avoid applying excess fertilizer by using rates recommended as a result of soil testing,
consideration of all possible available sources of nitrogen (e.g., nitrogen available in the soil, nitrogen
contributions to the soil from legumes grown in rotation or other residual crops, carryover nitrogen from
previous years of fertilization, other significant .sources of nutrients (e.g., irrigation water, commercial
fertilizers)), and an understanding of the growth requirements of the crop. Use the minimum amount of
fertilizer necessary to meet the plant needs. Ensure that crop yield estimates are realistic, based on producer-
documented yield history and other relevant information. Appropriate methods include averaging the three
highest yields in five consecutive crop years for the planning site, or other methods based upon criteria used
in developing a State Land Grant University's nutrient recommendations. In lieu of producer yield histories,
university recommendations based on interpretation of soils data may be used.
Timing of Application: Apply sludge and fertilizer as close as possible to the time required for maximum
plant uptake. Avoid fall and whiter applications for spring-planted crops. Time application to minimize
leaching losses from rainfall or irrigation (i.e., apply after these events). Also time application to avoid
periods of heavy rainfall and critical erosion periods. Use seasonally split nitrogen applications on most soils
to improve efficiency of nitrogen use and reduce total site loading. Avoid application to frozen soils.
Appropriate Method of Nutrient Application. Use application methods that promote efficient nutrient use.
Incorporate or inject sludge beneath the soil surface when possible. Avoid application methods that contribute
to soil erosion.
c
Ensure Application Equipment (e.g., sprayer, spreader) Works Properly: Calibrate equipment frequently.
Calibrate on similar terrain and at speeds similar to actual spraying condition. Check distribution pattern of
sprayer/spreader. Ensure uniform distribution. , .
Practice Water Conservation: Avoid .excess irrigation. Use sensors to determine the need and timing of
irrigation. ' • .
Keep Detailed Records: Record information on nutrient management procedures. Include such information
as brand used, formulation, date and time of application, amount of application, climatic conditions during .
application, irrigation schedule, and annual quantities of fertilizers used.
Leave Vegetated Buffers Around Water Bodies: Maintain and repair unfertilized vegetative buffer strips
around water bodies.
Use Cover Crops: Use small grain cover crops to scavenge nutrients remaining in the soil after harvest of
the principal crop, particularly on highly leachable soils.
Control Phosphorus Losses: Minimize loss of phosphorous from fields through a combination of erosion and
sediment controls. ,
H-6
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NUTRIENT MANAGEMENT PLANNING (Continued)
TABLE H-4 BMPs SUITABLE FOR EROSION AMD SEDIMENT CONTROL
BMP Type
Reduces Carrier Mass
Conservation Tillage
Contouring
Terraces ;
. Cover Crops
Vegetative Filter Strips
Reduces Pollutant Delivery
Terraces
Vegetative Filter Strips
Sediment Detention
Basins and Ponds
Infiltration Trenches
Description
Any tillage or planting system that leaves at least 30 percent of the soil
surface covered with crop residue after planting. Primary techniques include
no-till, ridge-till, and other minimum till practices. Conservation tillage
decreases soil erosion and surface runoff and increases infiltration.
A system where agricultural field preparation and tilling is conducted in the
direction of the land's contour instead of cutting across contour lines.
Contouring is effective at reducing soil loss associated with agricultural
activities. Contouring is most effective on permeable soils with mild slopes
If heavy, intense rainfalls occur, contouring loses effectiveness because the
furrows may overtop and fail.
Terraces are constructed, flattened areas suitable for planting, that cut across
the natural slope of a site. By reducing slope length, terraces reduce runoff
velocity and can reduce soil loss upwards of 90 percent. Terraces serve to
store water temporarily, allowing sediment to deposit and water to infiltrate.'
If terraces are overtopped by intense precipitation, severe erosion can occur.
The planting of crops (e.g., grains or grasses) to reduce the amount of time
an area is left fallow. Cover crops decrease nutrient losses to ground water
through plant uptake of nutrients. Legume cover crops will tie up soil
nitrogen during the winter and will provide nitrogen for subsequent crops.
The residual nitrogen from legumes must be considered when determining
nutrient requirements for future crops.
Bands of natural or planted vegetation situated between pollutant source
areas and receiving waters. Filter strips remove soil particles and soil-bound
nutrients from runoff as it passes through. Filter strips work best in flatter
areas, as they can lose their sediment-trapping efficiencies if inundated with
high volumes of fast moving runoff. The needed widths for vegetative filter
strips will vary depending on site specific conditions.
See above description. . ' •' .
See above description. . ' , ' v ,'
Large 'structures designed to reduce peak run-off rates and to remove a
certain percentage of sediment and sediment-bound nutrients in; run-off.
There are three basic types of detention ponds: dry ponds, wet ponds, and
extended wet ponds. Each type operates slightly differently and the
appropriate one should be selected based on site-specific conditions and local
requirements. . ,
Subsurface trenches typically filled with coarse material that serves to slow
and store run-off so that it can infiltrate into the soil.
Source: Adapted from Dillaha 1990.
H-7
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NUTRIENT MANAGEMENT PLANNING (Continued)
TABLE H-5 EFFECTS OF CERTAIN BMPs ON SURFACE AND GROUND WATER
BMP-Type
Conservation Tillage
Contouring
Terraces
Cover Crops
Vegetative Filter Strips
Sediment Detention Basins and Ponds
Infiltration Trenches
Nutrient Management
,' Effect oti Vf
Surface Water
Positive (P)
P
P
P
P
P
P
P
Ground Water
No Effect (NE) or Adverse (A)
NE/A
NE/A
P
NE/A
A
NE/A
P
Source: Adapted from Dillaha 1990; Logan 1990; and Camacho 1990.
H-8
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