PREFACE
Section 405(d) of the Clean Water Act (CWA) directs the U.S. Environmental Protection Agency (EPA)
to develop regulations containing guidelines for the use or disposal of sewage sludge.  This section also
requires EPA to establish standards that protect public health and the environment from any reasonably
anticipated adverse effects of.toxic pollutants in sewage sludge that  is used or disposed.  On February
19th, 1993  (58 Federal Register 9248), EPA published a final regulation at 40 Code of Federal
Regulations (CFR) Part 503 that contains the standards addressed in  section 405(d). This  regulation
contains requirements for four sewage sludge use or disposal practices:  application of sewage sludge to
the land,  placement  of sewage sludge on a surface disposal  site,  placement  of sewage sludge in a
municipal solid waste landfill (MSWLF) unit, and firing of sewage sludge'in a sewage sludge incinerator.

A key element in EPA's implementation of the Part 503 regulation  is to educate Agency and  State
personnel about these requirements,  The regulation is directly applicable to persons who use  or dispose
of sewage sludge through one of the Part 503 use or disposal practices, and permitting authorities can
directly enforce the provisions of the rule. It also will be implemented through Federal permits and will
be implemented through State permits once States  become authorized to manage the Federal sewage
sludge program. When work on this document was initiated, the primary focus was to educate permit
writers about the Part 503 requirements and to serve as an update to  the Guidance for Writing Case-by-
Case Permit Conditions for Municipal Sewage Sludge. (EPA 1990). Therefore, throughout the document,
reference is made to  the permit writer'and the permitting authority.

However, it is  now clear that the information interpreting Part 503  serves not only State and Federal
permits writers, but also direct regulators and the regulated community.  Readers should be aware that
the term  "permit writer" or "permitting authority" is intended to mean the State or Federal  regulator,
whether or not a permit is issued. A permit writer may use the information in the document to establish
appropriate permit requirements for the use or disposal of sewage sludge. An example of an EPA-issued
permit is included in Appendix G.  This document may also be used as a reference manual by anyone
involved in the use or disposal of sewage sludge. It is the responsibility of the sewage sludge  regulators-
to use this document to help protect  public health and the .environment.

This document is a guidance manual.  It is intended  to provide information  that  may be  needed to
properly implement Part 503.  It does notestablish a binding norm. Decisions in any particular case will
be made applying the law and regulation on the basis of specific facts.

Note that this document does not address the Part 503 requirements for the use  or-disposal of domestic
septage.  These requirements  are addressed in a separate guidance document called Domestic Septage
Regulatory Guidance - A Guide to the EPA 503 Rule (EPA 1993).  Several other guidance documents
have been published  to help in the implementation of Part 503.' These are listed in Appendix C along
with sources to obtain these and other EPA documents.           .

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                     TABLE OF CONTENTS
     ','          ,  •   -     . '•   '   '    ,-'""'.''   .'' ! '.-'...-   ''•'  Page

LIST OF ACRONYMS . ....	, .	... ...... ... . . . . . . .'. ....... x

1.    INTRODUCTION	. : . . , . .	  1-1

     1.1    BACKGROUND  . . . . ......:...........	 1-1
' • ••  1.2    HISTORY OF EPA'S SEWAGE SLUDGE REGULATIONS  . . . ; . .	  1-1
     1.3    SUMMARY STATISTICS FOR SEWAGE SLUDGE USE OR DISPOSAL
           PRACTICES	 . . . ... .. . .	, .	 :_	'.' . .  . ,1-2

2.    WHAT IS PART 503? . .  . . . ... ,. . . . . . . . .... . .".,... ..... .". ....... .  .  2-1

     2.1    INTRODUCTION	  i	,'".'	.2-1
     2.2   'GENERAL DEFINITIONS	 , . ."	  2-2
     2.3    WHAT DOES PART 503 REGULATE? .... .  . . .	 ........  2-6

           2.3.1   POLLUTANTS:	! .....'-.  :.....:....;........  2-6
           2.3.2'' PATHOGENS	  2-7
           2.3.3   VECTOR ATTRACTION REDUCTION	.;..... 2-10
           2.3.4   EXIT GAS FROM A SEWAGE SLUDGE INCINERATOR STACK  . 2-10
           2.3.5   PART 258 QUALITY REQUIREMENTS	 2-11
           2.3.6   OTHER REQUIREMENTS ............ .... ... r	2-11

     2.4    WHO DOES PART 503 REGULATE?  . , .:..,:.............,..... 2-12

           2.4.1   PERSON WHO PREPARES SEWAGE  SLUDGE	 2-12
           2.4.2   PERSON"WHO APPLIES .SEWAGE SLUDGE TO THE LAND  ..  . 2-13
           2.4.3   OWNER/OPERATOR OF A SURFACE DISPOSAL SITE ....... 2-13
           2.4.4   PERSON WHO FIRES SEWAGRSLUDGE IN A SEWAGE
       ,          SLUDGE INCINERATOR ..	2-13
           2.4.5   CLASS I SLUDGE MANAGEMENT FACILITIES, POTWs WITH
                 A  FLOW RATE EQUAL TO OR .GREATER THAN 1 MGD, AND
                 POTWS THAT SERVE 10,000 PEOPLE OR MORE	 2-13

     2.5    HOW IS PART 503 IMPLEMENTED? ............... ... ...... .  . 2-14
          -• ,             '       '-'-->            -             '     '
           2.5.1   SELF-IMPLEMENTING . . . .............. . . . . ........ 2-14
           2.5.2   PERMITS	 2-14

     2.6    WHAT IS NOT REGULATED BY PART 503?	•/ . . , ....-.'	, .2-16

           2.6.1   TREATMENT PROCESSES  .......................... 2-16
           2.6.2   SELECTION OF A USE OR DISPOSAL PRACTICE	2-16
           2.6.3   CO-FIRING OF SEWAGE SLUDGE .  . . . .	'. 2-16
           2.6.4   SLUDGE GENERATED AT AN INDUSTRIAL FACILITY ......  .. 2-16
           ,2.6.5   SEWAGE SLUDGE GENERATED AT AN INDUSTRIAL
                 FACILITY'	 .."......... 2-17
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                       TABLE OF CONTENTS (CONTINUED)
3.
      2.6.6   HAZARDOUS SEWAGE SLUDGE	.	2-17
      2.6.7   SEWAGE SLUDGE WITH HIGH PCB CONCENTRATION	2-17
      2.6.8   INCINERATOR ASH	 2-17
      2.6.9   GRIT AND SCREENINGS	:..,....	 2-17
      2.6.10  DRINKING WATER TREATMENT SLUDGE	  . 2-18
      2.6.11  COMMERCIAL AND INDUSTRIAL SEPT AGE	  . 2-18

2.7    ELEMENTS OF A PART 503 STANDARD	,	.2-18

      2.7.1   GENERAL REQUIREMENTS	 2-18
      2.7.2   POLLUTANT LIMITS	,	 2-19
      2.7.3   MANAGEMENT PRACTICES	  . . .	2-19
      2.7.4   OPERATIONAL STANDARDS . . ,	 2-19
      2.7.5   FREQUENCY OF MONITORING	2-19
      2.7.6  ' RECORDKEEPING . .  . .,	2-20
      2.7.7   REPORTING	;	 .	••••••• 2~2Q

2.8    PROTECTION OF PUBLIC HEALTH AND THE ENVIRONMENT	2-20

      2.8.1   POLLUTANT LIMITS AND MANAGEMENT PRACTICES -
             LAND APPLICATION AND SURFACE DISPOSAL	2-20
      2.8.2   POLLUTANT LIMITS AND MANAGEMENT-PRACTICES -
             INCINERATION	 '.	2-20
      2.8.3   OPERATIONAL STANDARDS . .	2-21

2.9    REQUIREMENTS MORE STRINGENT THAN OR IN ADDITION TO
      PART 503	................:	 2-21

      2.9.1   PERMITTING AUTHORITY	2-21
      2.9.2   STATE, POLITICAL SUBDIVISION, OR INTERSTATE AGENCY  . 2-21

PART 503 AND THE PERMITTING PROCESS	 3-1

3.1    PERMIT APPLICATION	'.  . 3-1

      3.1.1   REVIEWING THE APPLICATION '....'	 3-2
      3.1.2   COLLECTING ADDITIONAL INFORMATION .  .	 3-3

3.2    OVERVIEW OF THE PERMITTING  PROCESS	, ,	 3-6

      3.2.1   CORE PERMIT CONDITIONS	 . . :  . 3-6
      3.2.2   FACT SHEET	!.'.		 3-7
                                   - u -

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                       TABLE OF CONTENTS (CONTINUED)
4.    LAND APPLICATION - PART 503 SUBPART B

     4.1    INTRODUCTION  .'..'.-,-	

     4.2    SPECIAL DEFINITIONS	 ; . . .

     4.3'   GENERAL REQUIREMENTS  .......
     4.4
     4:6
           4.3.1
           4.3.2
           4.3.3

           4,3.4
       BULK SEWAGE SLUDGE -PREPARER .	
       BULK SEWAGE SLUDGE - APPLIER	 .
       SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR
       OTHER CONTAINER - PREPARER ..................
       SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR
       OTHER CONTAINER - APPLIER  ..................
POLLUTANT LIMITS ........................ .....

4.4.1   CEILING CONCENTRATION LIMITS - ALL LAND APPLIED
       SEWAGE SLUDGES .	., .  ...,..:
4.4.2  : BULK SEWAGE SLUDGE ... .......,..,;.........
4.4.3   SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR
       OTHER CONTAINER	
     4.5    MANAGEMENT PRACTICES
           4.5.1   BULK SEWAGE SLUDGE .......................
           4.5.2   SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR
                  OTHER CONTAINER	
OPERATIONAL STANDARDS  .
           4.6.1   PATHOGENS -.,,..•	
           4.6.2   VECTOR ATTRACTION REDUCTION
 4-1

 4-2

 4-3

 4-7

 4-8
4-10

4-14

4-15

4-16


4-17
.4-18

4-23

4-26

4-26

4-41

4-41

4-41
4-44
     4.7    FREQUENCY OF MONITORING REQUIREMENTS  . .	 . . . .,4-44
           4.7.1   PARAMETERS TO BE MONITORED .	;	
           4.7.2   MONITORING FREQUENCY	
           4.7.3   MONITORING POINTS . ...		 .  .'.-: ..'...
           4.7.4   SAMPLE COLLECTION AND PRESERVATION PROTOCOL
           4.7.5   ANALYTICAL METHODS . . . .		
           4.7.6   QUALITY ASSURANCE/QUALITY CONTROL(QA/QC)
     4.8   RECORDKEEPING REQUIREMENTS
           4.8.1   DOCUMENTATION FOR POLLUTANT CONCENTRATIONS
           4.8.2   DOCUMENTATION FOR PATHOGEN AND VECTOR
            -     ATTRACTION REDUCTION	
                                                        4-45
                                                        4-45
                                                        4-48
                                                        4-49
                                                        4-50,
                                                        4-50

                                                        4-57

                                                        4-62

                                                        4-62

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                                                                  Page

           4.8.3    DOCUMENTATION TO SHOW COMPLIANCE WITH
                  MANAGEMENT PRACTICES	4-62

     4.9    REPORTING REQUIREMENTS	 4-65
                                                    V      I  J
     4.10   SCENARIOS FOR A LAND APPLICATION STANDARD ... ..!...,.... 4-67

           4.10.1   SCENARIO 1 - EXCEPTIONAL QUALITY (EQ) SEWAGE
                  SLUDGE		 4-69
           4.10.2   SCENARIO 2 - BULK SEWAGE SLUDGE THAT IS NON-EQ
                  BECAUSE OF VECTOR ATTRACTION REDUCTION	4-70
           4.10.3   SCENARIO 3 - BULK SEWAGE SLUDGE THAT IS NON-EQ
                  BECAUSE OF PATHOGEN REDUCTION	 4-71
           4.10.4   SCENARIO 4 - BULK SEWAGE SLUDGE THAT IS NON-EQ
                  BECAUSE OF POLLUTANT CONCENTRATIONS	4-72
           4.10.5   SCENARIO 5 - BULK SEWAGE SLUDGE THAT IS NON-EQ
                  BECAUSE OF VECTOR ATTRACTION REDUCTION AND
                  PATHOGEN REDUCTION	4-73
           4.10.6   SCENARIO 6 - BULK SEWAGE SLUDGE THAT IS NON-EQ
                  BECAUSE OF VECTOR ATTRACTION REDUCTION AND
                  POLLUTANT CONCENTRATIONS	4-74
           4.10.7   SCENARIO 7 - BULK SEWAGE^SLUDGE THAT IS NON-EQ
                  FOR PATHOGEN REDUCTION AND POLLUTANT
                  CONCENTRATIONS	4-75
           4.10.8   SCENARIO 8 - BULK SEWAGE SLUDGE THAT IS NON-EQ .
                  FOR VECTOR ATTRACTION REDUCTION, PATHOGEN
                  REDUCTION, AND POLLUTANT CONCENTRATIONS  ....... 4-76,
           4.10.9   SCENARIO 9 - SEWAGE SLUDGE SOLD OR GIVEN AWAY IN
                  A BAG OR OTHER CONTAINER FOR APPLICATION TO THE
                  LAND THAT IS NON-EQ BECAUSE OF POLLUTANT
                  CONCENTRATIONS		4-77

5.    SURFACE DISPOSAL - PART 503 SUBPART C	  5-1

     5.1    INTRODUCTION  .	  5-2

     5.2    SPECIAL DEFINITIONS .		  5-4

     5.3    GENERAL REQUIREMENTS	  5-8

           5.3.1    COMPLY WITH THE PART 503 SURFACE DISPOSAL
                  REQUIREMENTS .	  5-8
           5.3.2    LOCATION OF ACTIVE SEWAGE SLUDGE UNIT WITHIN 60
                  METERS OF A FAULT, IN AN UNSTABLE AREA, OR IN A
                  WETLAND	  5-8
           5.3.3    WRITTEN CLOSURE AND POST-CLOSURE PLAN	  5-9
           5.3.4    NOTIFICATION TO SUBSEQUENT OWNER	5-14

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                  TABLE OF CONTENTS (CONTINUED)
5.4
POLLUTANT LIMITS . ,' '... . .	•'.".'	 5-15
      5.4.1    AN ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER !
             AND LEACHATE COLLECTION SYSTEM WITH A UNIT
             BOUNDARY TO SITE PROPERTY LINE DISTANCE OF 150
             METERS OR MORE  ........	 5-16
      5.4.2    AN ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER
          -   AND LEACHATE COLLECTION SYSTEM WITH A UNIT
             BOUNDARY TO SITE PROPERTY LINE DISTANCE OF LESS
             THAN 150 METERS  . . . . . ... .... ....	5-17
      5.4.3    SITE-SPECIFIC POLLUTANT LIMITS ....... .-. . .  . . ..... . 5-18

5.5    MANAGEMENT PRACTICES  . .... ...... ... .......;..... ..... 5-20

      5.5.1    ENDANGERED SPECIES OR CRITICAL HABITAT
             PROTECTION	 . .	 . .	'.. .... .5-20
      5.5.2    BASE FLOOD FLOW RESTRICTIONS ................... 5-2-1
     "5.5.3    REQUIREMENTS IN A SEISMIC IMPACT ZONE  .... , , . . . . . 5-23
      5.5.4    REQUIREMENT OF 60 METERS OR MORE FROM A FAULT .... 5-25
      5.5.5    UNSTABLE AREAS		 . 5-27
      5.5.6    WETLAND PROTECTION . . . .	 . .	 5-30
      5.5.7    STORM WATER RUN-OFF MANAGEMENT . . . .... . .  .'. ., .... 5-32
      5.5.8    LEACHATE COLLECTION AND DISPOSAL  .\ ............ 5-34
      5.5.9    METHANE GAS CONTROL ........	... . . . . . ... 5-43
      5.5.10   FOOD, FEED, AND FIBER CROPS AND GRAZING
             RESTRICTIONS . ..-. ......... ...	.......; 5-47
    ,  5.5.11   PUBLIC ACCESS CONTROL	 . '. ..... 5-48
      5,5.12   GROUND-WATER PROTECTION	 5-49

5.6    OPERATIONAL STANDARDS  . .	 . . : .	 .,5-60

      5.6.1    PATHOGENS	 ...	 . .... 5-60
      5.6.2    VECTOR ATTRACTION REDUCTION ................... 5^61

5.7    FREQUENCY OF MONITORING REQUIREMENTS  ........... . . . /. 5-62

      5.7.1    PARAMETERS TO BE MONITORED . . . . . . .... . .... . ... . 5-62
      5.7.2    MONITORING FREQUENCY .	 5-62
      5.7.3    MONITORING POINTS	 5,64
     ' 5.7.4    SAMPLE COLLECTION AND PRESERVATION PROTOCOL ..'..' 5-65
   .   5.7.5    ANALYTICAL METHODS ........:....	 .5-66
  :    5.7.6    QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) . . . . . . . 5-69

5.8    RECORDKEEPING REQlUIREMENTS . . . .... . . . . . . ,  . . ;  . ... : . . . 5-69

      5.8.1   "DOCUMENTATION FOR POLLUTANT CONCENTRATIONS  . . . 5-70
      5.8.2    DOCUMENTATION FOR PATHOGEN AND VECTOR
             ATTRACTION REDUCTION	 . 5-71
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                       TABLE OF CONTENTS (CONTINUED)
           5.8.3   DOCUMENTATION TO SHOW COMPLIANCE WITH
                  MANAGEMENT PRACTICES	'...„..	5-71

     5.9    REPORTING REQUIREMENTS	 .	5-77

     5.10   SCENARIOS FOR A SURFACE DISPOSAL STANDARD	5-79

           5.10.1   SCENARIO 1 - ACTIVE SEWAGE SLUDGE UNIT WITHOUT A
                  LINER AND LEACHATE COLLECTION SYSTEM WITH A
                  UNIT BOUNDARY TO SITE PROPERTY LINE DISTANCE OF
                  150 METERS OR GREATER	 . .	 . 5-80
           5.10.2   SCENARIO 2 - ACTIVE SEWAGE SLUDGE UNIT WITHOUT A
                  LINER AND -LEACHATE COLLECTION SYSTEM WITH A
                  UNIT BOUNDARY TO SITE PROPERTY LINE DISTANCE LESS
                  THAN 150 METERS	5-81
           5.10.3   SCENARIO 3 - ACTIVE SEWAGE SLUDGE UNIT WITHOUT A
                  LINER AND LEACHATE COLLECTION SYSTEM FOR WHICH
                  SITE-SPECIFIC POLLUTANT LIMITS ARE DEVELOPED .'	5-82
           5.10.4   SCENARIO 4 - ACTIVE SEWAGE SLUDGE UNIT WITH A
                  LINER AND LEACHATE COLLECTION SYSTEM . .......... 5-83

6.    PLACEMENT OF SEWAGE SLUDGE IN A MUNICIPAL SOLID WASTE
     LANDFILL UNIT	 .'."	 6-1

     6.1    INTRODUCTION	 6-1

     6.2    PART 503 REQUIREMENTS	 '.	,	 6-1

           6.2.1   REQUIREMENTS FOR QUALITY OF MATERIALS PLACED IN
                  A MUNICIPAL SOLID WASTE LANDFILL UNIT	 6-2
           6.2.2   PART 258 CRITERIA FOR LANDFILL UNIT	 . 6-4

     6.3    FREQUENCY OF MONITORING, RECORDKEEPING, AND REPORTING
           REQUIREMENTS	 6-4

7.    INCINERATION - PART 503 SUBPART E	 7-1

     7.1    INTRODUCTION	 7-1

     7.2    SPECIAL DEFINITIONS	 7-3

     7.3    GENERAL REQUIREMENTS  . .	 .	 7-11

     7.4    POLLUTANT LIMITS		7-11

           7.4.1   SITE-SPECIFIC LIMITS	 ,	, . 7-12
           7.4.2   LEAD .  .	"	'. . . .7-17
           7.4.3   ARSENIC, CADMIUM, CHROMIUM, AND NICKEL  	7-19
                                  - vi -

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                       TABLE OF CONTENTS (CONTINUED)
           7.4.4    BERYLLIUM ........... . .		7-23
:           7.4.5    MERCURY	 . . \ . 7-24

 •%.   7.5    MANAGEMENT PRACTICES ...... . ...'....,............... . 7-25

           7.5.1    TOTAL HYDROCARBONS MONITOR ... ...... . . . .  . .... . . .7-25
           7.5.2  '  OXYGEN MONITOR  ...!.. .';..	  . . , . . 7-26
           7.5.3    MOISTURE CONTENT . .	.........;..	7-26
           7.5.4    COMBUSTION TEMPERATURE	 .  . ., . . 7-27
           7.5.5    AIR POLLUTION CONTROL DEVICE OPERATING
           ;       PARAMETERS	:. ... .V. ...... 7-28
           7.5:6    ENDANGERED SPECIES ACT ....................... .7-30

     7.6    OPERATIONAL STANDARDS  .... .............. . . .	. . 7-30

           7.6.1    TOTAL HYDROCARBON (THC)	..,.....:...	7-31
           7.6.2    CARBON MONOXIDE (CO) . . .	 . . ...  ...... . 7-33

     7.7    FREQUENCY OF MONITORING REQUIREMENTS  .........  . .  ..... 7-34

           7.7.1    SEWAGE SLUDGE . .	 . .	 7-34
           7.7.2    STACK GAS	 . \ ....'........,.., ..• ... 7-36
           7.7.3    INCINERATOR AND AIR POLLUTION CONTROL DEVICE .... 7-37

     7.8    RECORDKEEPING REQUIREMENTS	/	  . .  . , - ; . 7-38
                                                      '''-'•.'
           7.8.1    INCINERATOR INFORMATION . . . . ...... . . ,	 . . 7-39
           7.8.2    DISPERSION MODELING	.-	 7-40
           7.8.3    STACK GAS DATA .............. ... .... ....... . . . 7-41
           7.8.4    SEWAGE SLUDGE MONITORING INFORMATION	.-. 7-45

    •' 7.9    REPORTING REQUIREMENTS  .............................. 7-47

     7.10   SCENARIO .FOR THE INCINERATION STANDARD ................ 7-48

           7.10.1 .  SCENARIO 1  FIRING OF SEWAGE SLUDGE IN A SEWAGE
                  SLUDGE INCINERATOR ........ . :........	 7-48

8.    PATHOGEN AND VECTOR ATTRACTION REDUCTION - PART 503
    / SUBPART D. .	,	;.......,....	  8-1

     8.1    INTRODUCTION  .... ..... ........ .... ... . .\ . . . . ... .... . . . .-.  8-1

     8.2    WHAT ARE PATHOGENS. AND VECTOR ATTRACTION? ............  8-2

           -8.2.1    PATHOGENS	 ...	 . ...	- - ....  8-2
           8.2.2    VECTOR ATTRACTION	...'.....	 8-3
                                 - yii -

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TABLE OF CONTENTS (CONTINUED)

8.3



8.4
8.5
8.6









8.7






8.8












WHEN DOES PATHOGEN AND VECTOR ATTRACTION REDUCTION
HAVE TO OCCUR? 	 	
8.3.1 PATHOGEN REDUCTION 	 	 	 .
8.3.2 VECTOR ATTRACTION REDUCTION .'...; 	 	
FREQUENCY OF MONITORING 	 	 . 	 	 	
SPECIAL DEFINITIONS 	 	 	 	
CLASS A PATHOGEN ALTERNATIVES 	 	
8.6. 1 ORDER IN WHICH PATHOGEN AND VECTOR ATTRACTION
REDUCTION IS ACHIEVED 	
8.6.2 REGROWTH REQUIREMENT 	 	
8.6.3 CLASS A ALTERNATIVE 1 	 	 	
8.6.4 CLASS A ALTERNATIVE 2 . 	
8.6.5 CLASS A ALTERNATIVE 3 	 	 	
8.6.6 CLASS A ALTERNATIVE 4 	 	
8.6.7 CLASS A ALTERNATIVE 5 	 .-...-, 	 	
8.6.8 CLASS A ALTERNATIVE 6 	
CLASS B PATHOGEN ALTERNATIVES . . .' 	 	 	 	
*
8.7.1 ORDER OF PATHOGEN AND VECTOR ATTRACTION
REDUCTION 	 	
8.7.2 CLASS B ALTERNATIVE 1 	
8.7.3 CLASS B ALTERNATIVE 2 . 	 	 	 	
8.7.4 CLASS B ALTERNATIVE 3 . . 	 	 	 	
8.7.5 CLASS B SITE RESTRICTIONS . . . . 	 	 	
VECTOR ATTRACTION REDUCTION OPTIONS 	 	 	
8.8.1 VECTOR ATTRACTION REDUCTION OPTION 1 	
8.8.2 VECTOR ATTRACTION REDUCTION OPTION 2 	
8.8.3 VECTOR ATTRACTION REDUCTION OPTION 3 	
8.8.4 VECTOR ATTRACTION REDUCTION OPTION 4 	 	
8.8.5 VECTOR ATTRACTION REDUCTION OPTION 5 	
8.8.6 VECTOR ATTRACTION REDUCTION OPTION 6 ..........
8.8.7 VECTOR ATTRACTION REDUCTION OPTION 7 	 	
8.8.8 VECTOR ATTRACTION REDUCTION OPTION 8 	
8.8.9 VECTOR ATTRACTION REDUCTION OPTION 9 	 	
8.8.10 VECTOR ATTRACTION REDUCTION OPTION 10 	 	
8.8.11 VECTOR ATTRACTION REDUCTION OPTION 11 . . . 	 	
Page

8-4
. 8-4
. 8-6
8-7
8-10
8-11

. 8-11
. 8-12
. 8-13
. 8-15
. 8-17
. 8-19
. 8-20
8-24
8-25

. 8-26
. 8-26
. 8-27
. 8-29
8-30
8-32
. 8-32'
. 8-33
. 8-34
. 8-35
.8-36.
. 8-37
. 8-38
. 8-38
. 8-39
. 8-40
. 8-41
            - VI11 -

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                       TABLE OF CONTENTS (CONTINUED)
                  >        LIST OF APPENDICES


APPENDIX A CONVERSION FACTORS - ENGLISH SYSTEM UNITS TO METRIC
           SYSTEM UNITS

APPENDIX B SURFACE DISPOSAL SITE LINERS

APPENDIX C INFORMATION SOURCES

APPENDIX D DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E

APPENDIX E DETERMINING SITE-SPECIFIC POLLUTANT LIMITS FOR PART sos,
           SUBPART c                               .       ,

APPENDIX F INTERIM APPLICATION FORM
   '.                  .'•          •"    '  "            -  )   •
APPENDIX G SAMPLE PERMIT

APPENDIX H NUTRIENT MANAGEMENT PLANNING  •
                                 - ix -

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                             LIST OF ACRONYMS
 APCD         Air Pollution Control Device
 APLR         Annual Pollutant Loading Rate ;
 AWSAR       Annual Whole Sludge Application Rate
 BMP          Best Management Practice
 BPJ           Best Professional Judgment
 CE           Control Efficiency
 CEM  - •      Continuous Emission Monitoring
 CFR          Code of Federal Regulations
 CO           Carbon Monoxide
 COE          U.S. Army Corps of Engineers
 CPLR         Cumulative Pollutant Loading Rate:
 CWA         Clean Water Act
 DF     ,      Dispersion Factor
 EPA     •     U.S. Environmental Protection Agency
 EQ           Exceptional Quality
 FEMA        U.S. Federal Emergency Management Agency
 PR           Federal Register
 FWS        ,  U.S. Fish and Wildlife Service                 '
 GEP          Good Engineering Practice
 LCRS         Leachate Collection,and Removal System •'
' LEL          Lower Explosive Limit
 MCL          Maximum Contaminant  Level
 MSWLF       Municipal Solid Waste Landfill
 NAAQS       National Ambient Air Quality Standard
 NESHAPS     National Emission Standards for Hazardous Air Pollutants
 NPDES       National Pollutant Discharge Elimination System
 NSPS         New Source Performance Standard
 NSSS         National Sewage Sludge Survey
 PCB          Polychlorinated Biphenyl
 PEC          Pathogen Equivalency Committee
 PFRP         Process to Further Reduce Pathogens
 POTW        Publicly  Owned Treatment Works
 PSRP         Process to Significantly  Reduce Pathogens
 QA/QC       Quality Assurance/Quality Control
 RCRA        Resource Conservation and Recovery Act
 RSC          Risk Specific Concentrations
 SCS          Soil Conservation Services
 SDWA        Safe Drinking Water Act
 SOUR        Specific Oxygen Uptake Rate
 TCLP         Toxicity Characteristic Leaching Procedure             .
 THC          Total Hydrocarbon
 TKN          Total Kjedahl Nitrogen     •
 TWTDS       Treatment Works Treating Domestic Sewage
 USGS         U.S.  Geological Survey
                                            - x -

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                                1.  INTRODUCTION
                                QUICK REFERENCE INDEX
 BACKGROUND       '
 HISTORY OF EPA'S SEWAGE SLUDGE REGULATIONS "'
 SUMMARY STATISTICS FOR SEWAGE SLUDGE USE'OR DISPOSAL PRACTICES
Section

 1.1
 1.2
 1.3
                                                                                         Pag
1-1
1-1
1-2
 1.1    BACKGROUND

' The primary goals of the Clean Water Act (CWA) are to protect and improve the quality of the Nation's
 water.  To prevent contamination and deterioration of water quality, wastewater from households and
 commercial and industrial activities is treated at wastewater treatment plants  before it is discharged to
 surface water or ground water.  There are approximately 15,000 publicly owned treatment works
 (P0TWs)  in the United States  that process almost 34 billion gallons, of domestic sewage and other
 wastewater each day (EPA 1991). Sewage sludge is generated by POTWs and by privately owned and
 Federally owned treatment works during the treatment of domestic sewage.  The annual amount of
 sewage sludge generated during the treatment of domestic sewage is estimated  at about 47 pounds for
 every individual in the United States (58 FR 9249,  February 19, 1993).

 1.2    HISTORY OF EPA'S SEWAGE SLUDGE REGULATIONS

 The use or disposal of sewage sludge has been regulated under various environmental statutes. In the
 past, it was regulated principally under the solid waste disposal regulations at 40 Code of Regulations
 (CFR) Part 257, jointly promulgated under the Resource Conservation and Recovery Act (RCRA) and
 the CWA. In addition, the Marine Protection, Research, and  Sanctuaries Act (MPRSA) regulated the
 dumping of sewage sludge to oceans and estuaries, until the Ocean Dumping Ban Act of 1988 prohibited
 this disposal  practice.  Finally,  the Clean Air Act (CAA)  regulates the  air emissions (primarily
 particulates) from sewage sludge incinerators.           .                •         .

 The 1977 amendments to the CWA directed the U.S. Environmental Protection Agency (EPA) to develop
 regulations containing guidelines for the use or disposal of sewage sludge.  In  1984, EPA's  Office of
 Water convened a Sludge Task Force that made recommendations for the development of a sewage sludge
 management program and published guidance on the metals content of sewage sludge applied to land used .
' for growing food crops. In 1987, Section 405(d) of the CWA was amended ^o require EPA to establish
 standards that adequately protect public health  and the environment from any reasonably anticipated
 adverse effects of pollutants in sewage sludge that is" used or disposed. In response, EPA developed and
 published technical standards and requirements on February 19,  1993 (58 FR 9248), codified in 40 CFR
 Part 503.  Part 503 was amended on  February 25, 1994 (59 FR 9095), and October 25, 1995 (60 FR
 54764).  Additional amendments were proposed on October 25,  1995 (60 FR 54771).  Discussions in this
 document assume that these changes will be finalized.

 The  1987 revisions to  the CWA also require that  any  Section 402 (National  Pollutant Discharge
 Elimination System [NPDES]) permit include sewage sludge use or  disposal  standards unless these
 requirements are included in another permit. The amendments also expanded the regulated universe to
 include all treatment works treating dbmestic sewage (TWTDS), even those not needing an NPDES
 permit. TWTDS"include all sewage sludge or wastewater treatment systems used to store, treat, recycle,
                                             1-1

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and reclaim municipal or domestic sewage. On May 2, 1989 (54 PR 18716), EPA revised 40 CFR Parts
122 and 124 to establish the procedures and requirements for addressing sewage sludge management in
NPDES permits. At the same time, 40 CFR Part 123 was revised and 40 CFR Part 501 was promulgated
'to establish State program requirements and approval procedures.  On February 19, 1993 (58 FR.9404),
Parts 122 and 501 were amended to establish a tiered permit application schedule.

1.3     SUMMARY STATISTICS FOR SEWAGE SLUDGE USE OR DISPOSAL
        PRACTICES

In 1988, EPA collected information on the use or disposal of sewage sludge through a two-part National
Sewage Sludge Survey (NSSS).  A questionnaire survey was used to obtain both technical and financial
information on the sewage sludge use or disposal practices employed by POTWs.  Information on the
quality of sewage sludge used or disposed in 1988 was obtained through an  analytical survey during
which samples of sewage sludge were collected at several POTWs and analyzed for several pollutants.
Results of the NSSS were used to develop the Part 503 regulation and to  evaluate the impact of the Part
503 regulation on POTWs.  The summary statistics in this section are from the NSSS.
                                                                  /      ;         •  '
The NSSS focused on POTWs with either primary, secondary or advanced treatment of wastewater.  The
survey results  show that the frequency of particular use or disposal practices  varies widely by POTW
size, except for land application, which is used frequently by all sizes of POTWs.  For example, many
small POTWs  use surface disposal, while this practice is uncommon among large POTWs.  Similarly,
incineration and  ocean disposal have been used  by many large  POTWs, but hardly  at all by small
POTWs. The tables on the following pages provide more information on POTW sewage sludge use or
disposal practices obtained through the NSSS.                              ,

Table 1-1 shows national estimates of the number and percentage of POTWs that use a particular use or
disposal practice and the amount of sewage sludge used or disposed through each practice.  The most
prevalent practice is land application (34.6 percent)', followed by placement in co-disposal landfills (i.e.,
a municipal solid waste landfill unit)  (22.2 percent) and surface disposal (10 percent).

Table 1-2 reports national estimates of the total amount and percentage of sewage sludge used or disposed
annually for various use or disposal practices and for certain POTW size categories. As can be seen in
the table, POTWs  with a design flow rate over 100 million gallons per day (mgd) account for 28.7
percent  of the  sewage sludge used or disposed by POTWs.  POTWs with a flow rate between 10 mgd
and 100 mgd use or dispose of 39.5 percent of the annual amount of sewage sludge; and POTWs with
a flow rate between one mgd and 10 mgd use or dispose of 24.1 percent of the amount of sewage sludge
that is used or disposed annually by POTWs.  In contrast, POTWs with a flow rate less than one mgd
account for only 7.6 percent of the amount of sewage sludge used or disposed annually.

The largest amount of sewage sludge is used or disposed through co-disposal landfills (33.7 percent), land
application (33.5 percent),  and incineration (16.1). Only 10.4 percent of the amount of sewage sludge
used or disposed annually is placed on a surface disposal site.
                                            1-2

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     TABLE 1-1  NUMBER OF POTWS AND THE AMOUNT OF SEWAGE SLUDGE
           USED/DISPOSED ANNUALLY BY USE OR DISPOSAL PRACTICE
Use/Disposal
Practice
Incineration
Land
Application
Co-Disposal:
Landfill -
Surface
Disposal
Ocean Disposal*5
Unknown:
Other
Unknown:
Transfer
All POTWs
PQTWs Using a Use/Disposal
Practice
Number
381
4,657 .
2,991
1,351
133
'3,920
25
13,458°
percent of
Total
2.8
34.6
22.2 • •; '
10.0
1.0 '"
29.1
0.2 .
ioo.od
Amount of Sewage Sludge
Used/Disposed
s
Amounta .
864.7
1,787.8 :
1,798.6'
553.6
335.4
0
N/A '
5,340.1
Percent of
Total
1.6.1
33.5
33.7'
10.4
6.3
0.0
N/A
iop.od
aThousands of dry metric tons. . ' :. •
bThe National Sewage Sludge Survey was conducted before the Ocean Dumping Ban Act of 1988 prohibited
the dumping of sewage sludge into the ocean. Ocean dumping of sewage sludge ended in June 1992. ,
cThe total number of POTWs does not equal the number in the text because some POTWs utilize more than
one use or disposal practice, and are counted twice in this table. .
dNumbers do not add up to 100 percent because of rounding. •
Source:  1988 National Sewage Sludge Survey and 1988 Needs Survey.  Extracted from 58 PR 9248, February
       19, 1993.    .                    ,       -
                                     1-3

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    TABLE 1-2 ESTIMATED AMOUNT OF SEWAGE SLUDGE USED OR DISPOSED
         ANNUALLY BY SIZE OF POTW AND USE OR DISPOSAL PRACTICE
Use or Disposal
Practice
Incineration
Land Application:
Agricultural
Land Application:
Compost
Land Application:
Forests
Land Application:
Public Contact Sites
Land Application:
Reclamation Site
Land Application:
Sale or Give Away
in a Bag or Other
Container
Land Application:
Undefined
Co-Disposal:
Landfill
Surface Disposal:
Dedicated Site
Surface Disposal:
Monofill
Surface Disposal:
Other
Ocean Disposal3
Unknown: Other
Unknown: Transfer
Total
(% of Total)
Amount of Sewage Sludge Used or Disposed by POTW Size
(in thousands of dry metric tons)
>100 mgd
382.9
203.0
22.4
4.5
62.1
52.6
30.6
12.7
518.6
34.2
13.8
31.5
166.1
0
N/A
1,535.0 .
(28.7)
> JO to 100 mgd
346.5
400.8
65.3
24.5
60.5
9.8
27.8
76.4
674.0
124.9
79.8
60.0
157.9
0
N/A
2,108.2
(39.5)
>1 to 10 mgd
124.8
423,.9
-31.7
1.0
40.3
2.4
11.9
27.2 •
495.6
63.2
41.6
17.4 '
8.0
0
N/A
1,289.0
(24.1)
<, 1 mgd
10.5
143.2
30.8
"1.3 '
6.3
1.0
0.8 ,
13.0
110.4
36.5
22.2
28.5
3.4
0
N/A
407.9
(7.6)
Total
<% or Total)
864.7
(16.1)
1,170.9
(21.9)
150.2
(2.8)
31.3
(0.6)
169.2
(3.2)
65.8
(1-2)
71. 11
(1.3)
129.3
(2.4)
1,798.6
(33.7)
258.8
(4.9)
157.4
(3.0)
137.4
(2.6)
335.4
(6.3)
0
N/A
5,340.1
(100.0)
aThis survey was conducted before the Ocean Dumping Ban Act of 1988 prohibited the dumping of sewage
sludge into the ocean. Ocean dumping of sewage sludge ended in June 1992.
Source:  1988 National Sewage Sludge Survey and 1988 Needs Survey. Extracted from 58 FR 9248, February
       19, 1993.                                   '   ..   "
                                      1-4

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                            2.   WHAT IS PART 503?
                                QUICK REFERENCE INDEX
INTRODUCTION

GENERAL DEFINITIONS

WHAT DOES PART 503 REGULATE?'                    •           ,       .
     POLLUTANTS                    -      ;
     PATHOGENS
     VECTOR ATTRACTION REDUCTION            •   •.    -            .
     EXIT GAS FROM'A SEWAGE SLUDGE INCINERATOR STACK
     PART 258 QUALITY REQUIREMENTS
     OTHER REQUIREMENTS

WHO DOES PART 503 REGULATE?
     PERSON WHO PREPARES SEWAGE SLUDGE
     PERSON WHO APPLIES SEWAGE SLUDGE TO THE LAND
     OWNER/OPERATOR OF A SURFACE DISPOSAL SITE
     PERSON WHO FIRES SEWAGE SLUDGE IN A SEWAGE SLUDGE INCINERATOR
     CLASS I SLUDGE MANAGEMENT FACILITIES, POTWS WITH A FLOW RATE EQUAL
     TO OR GREATER THAN 1 MGD, AND POTWS THAT SERVE 10,000 PEOPLE OR MORE

HOW IS PART 503 IMPLEMENTED?        '-
     SELF-IMPLEMENTING
    I PERMITS                      ,                               .

WHAT IS NOT REGULATED BY PART 503?        "
     TREATMENT PROCESSES.       .  '  ,
     SELECTION OF A USE OR DISPOSAL PRACTICE
     CO-FIRING OF SEWAGE SLUDGE    .     ' . .                     '
     SLUDGE GENERATED'AT AN INDUSTRIAL FACILITY
     SEWAGE SLUDGE GENERATED AT AN INDUSTRIAL FACILITY
     HAZARDOUS SEWAGE SLUDGE  '     .
     SEWAGE SLUDGE" WITH HIGH PCB CONCENTRATION         •
     INCINERATOR ASH
     GRIT AND SCREENINGS
     DRINKING WATER TREATMENT SLUDGE
    • COMMERCIAL AND INDUSTRIAL SEPTAGE

ELEMENTS OF A PART 503 STANDARD
     GENERAL REQUIREMENTS
     POLLUTANT LIMITS .         '
     MANAGEMENT PRACTICES                            -
     OPERATIONAL STANDARDS         '    .  ,
     FREQUENCY OF MONITORING
     RECORDKEEPING  •    .
     REPORTING                                                   ,

PROTECTION OF PUBLIC HEALTH AND THE ENVIRONMENT
     POLLUTANT LIMITS ANP MANAGEMENT PRACTICES - LAND APPLICATION
     AND SURFACE DISPOSAL
     POLLUTANT LIMITS AND MANAGEMENT PRACTICES - INCINERATION
     OPERATIONAL STANDARDS              ..              !

REQUIREMENTS MORE STRINGENT THAN OR IN ADDITION TO PART 503
     PERMITTING AUTHORITY
     STATE, POLITICAL SUBDIVISION, OR INTERSTATE AGENCY
                                                                       Section
                                                                        2.1
 2.2'
 2.3
2.4
2.5
2.6
2.7
2.8
2.9
 2-1

 2-2

 2-6
 2-6
 2-7
2-10
2^10
2-11
2-11

2-12
2-12
2-13
2-13
2-13

2-13

2-14
2-14
2-14

2-16
2-16
2-16
2-16
2-16
2-17
2-17
2-17
2-17
2-17
2-18
2-18,

2-18
2-18
2-19
2-19
2-19
2-19
2-20
2-20

'2-20

2-20
2-20
2-21 '

2-21
2-21
2-21
2.1    INTRODUCTION
              /                  .•              "  .      • '             '••'••
EPA published the Standards for the Use or Disposal of Sewage Sludge, Part 503, in the Federal Register
on February 19, 1993. This chapter discusses what is regulated by Part 503, who is regulated by Part
503, how Part 503 is implemented, and what is not regulated by Part 503.
                                             2-1

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                                     2.  WHAT is PART 503?
This chapter also discusses the seven elements  of a Part 503 standard and why a Part 503 standard
protects public health and the environment. The last discussion in this chapter concerns requirements that
are more stringent than or in  addition to  the  Part 503 requirements and who  can establish these
requirements.

2.2    GENERAL DEFINITIONS

Part 503 Subpart A contains definitions of terms used in more than one subpart in Part 503. This section
provides additional information on several  of the definitions in §503.9.  It  also discusses two key
definitions in Parts 122 and, 501.

CLASS I SLUDGE MANAGEMENT FACILITY
  Statement of Regulation                               --"                "     '
        ~UJ  J-'*~ --!-«-••«—I  ^ «J     •-• -                          ^        ^     |

    §122.2       Class I sludge management facility means any publicly owned treatment works (POTW),
                identified under 40 CER 403.8(a) as being required to have an approved pretreatroent
                program (including any POTW located in a State that has elected to assume local program
                responsibilities pursuant to 40 CFR 403.10(e)) and any other treatment works treating
                domestic sewage classified as a Class I sludge management facility by the Regional
                Administrator, or, in the case of approved State programs, ihe Regional Administrator in
                conjunction with the State Director, because of the potential for Its sludge use or disposal
                practices to adversely affect public health and the environment.
This is an important definition because the reporting requirements in Part 503 only apply to Class I sludge
management facilities and other selected POTWs, generally known as majors.

DOMESTIC SEWAGE
  Statement of Regulation                            -  ^               *

    §503.9(g)     Domestic sewage is waste and wastewater from humans or household operations that is
                discharged to or otherwise enters a treatment works.
There are two important aspects of this definition.  First, the definition is explicit that the waste and
wastewater from humans or household operations must be discharged to or otherwise enter a treatment
works for those wastes and wastewater to be domestic sewage.  Wastes and wastewater from humans or
household operations (e.g., solid waste) that does not enter a treatment works is not domestic sewage.
Second, it defines the type of wastewater that must be in the influent to a treatment works for the solids
that are removed from the wastewater to be sewage sludge.  This is  discussed further below in the
definition of sewage sludge.
                                              2-2

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                                     2. WHAT is PART 503?
PERSON
  Statement of Regulation                                              r     -        ..    '

    §503.9(q)     Person, is an individual,' association, partnership, corporation, municipality, State or Federal '
                agency, or an agent or employee thereof.         •      '                         "
The important aspect of this definition is that a person is not just an individual. A person includes, but
is not limited to, the generator of sewage sludge (e.g., a-privately owned treatment works), a land applier
of sewage sludge (e.g., an independent contractor who  receives sewage sludge from the generator and
then applies the  sewage sludge to the land),  the owner/operator of a  surface disposal site (e.g.,  a
municipality), the owner/operator of a municipal solid waste  landfill unit, and the person who  fires,,
sewage sludge in a sewage sludge incinerator.      ,

PERSON WHO PREPARES SEWAGE SLUDGE
  Statement of Regulation                                          _
        ^               *                       * *          .         f
    §503.9(r)   ,  Person Who prepares sewage sludge is either the person who generates sewage sludge during
                the treatment of domestic sewage in a treatment works or the person who derives a material
          ,  "    from sewage sludge.
There are several ways to derive a material from sewage sludge.   These are discussed below in the
definition of sewage sludge. In all cases, however, the person who derives a material from sewage sludge
is a person who prepares sewage sludge.  This term is used in Part 503 to indicate the person responsible
for certain Part 503 requirements.

SEWAGE SLUDGE AND MATERIAL DERIVED FROM SEWAGE SLUDGE
  Statement of Regulation                 "             -     '  -  '

    §503.9(w) -    Sewage sludge is solid, semi-solid, or liquid residue generated during the treatment of
                domestic sewage in a treatment works. Sewage sludge^ncludes, but fe aot 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, firing of sewage sludge in a sewage sludge incinerator or grit and
                screenings generated Swing preliminary treatment of domestic sewage in a treatment works.
Sewage sludge and a material  derived from sewage sludge are discussed separately below.   Grit and
screenings and ash are not included in the definition because they have characteristics that are different
from the characteristics of sewage sludge.                           <

As indicated above, sewage sludge is generated during the treatment of domestic sewage in a treatment
works.  If domestic sewage is in the influent to the treatment works, either by itself or mixed with other
wastewaters (e.g., industrial wastewater), solids removed during the treatment of the domestic sewage
are sewage sludge. If domestic sewage is not in the influent, the solids generated during the treatment
of the wastewater are not sewage sludge.
                                               2-3

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                                    2.  WHAT is PART 503?
Sewage sludge retains its identity as sewage sludge as long as it remains within the property lines of the
treatment works where it is generated. While within the treatment works, sewage sludge may be stored,
treated (e.g., composted with other materials),  or mixed with other materials and still retain its identity
as sewage sludge.

Sewage sludge also retains its identity as sewage sludge after it leaves the property line of the treatment
works if the quality of the sewage sludge is riot changed after it leaves.  When the quality of the sewage
sludge is changed, a material is derived from sewage sludge.                  /

There are two ways in which the quality of sewage sludge that leaves the property line of the treatment
works can be changed.  This can be done either by treatment (e.g., composting with  another sewage
sludge)  or by mixing with another material (e.g, mixing with  water treatment plant sludge or with grit
and screenings). In both cases, the resulting material is a material derived from sewage sludge.  If the
derived material is applied to the land, placed on a surface disposal site, placed in a municipal solid waste
landfill (MSWLF)  unit, or fired in a sewage sludge incinerator, the appropriate requirements in Part 503
have  to  be  met.  In these  cases, the derived material  itself has to  meet the appropriate Part 503
requirements (e.g., the pathogen requirements have to be  met  for the derived material).

Sewage sludge 'can be placed in a MSWLF unit in which household wastes already have been placed or
household wastes can be placed in the landfill unit after sewage sludge is placed in the unit.  In both
cases, the area  of land on which the sewage sludge  is placed  is  a MSWLF unit; the  appropriate
requirements for the landfill unit (i.e., 40  CFR Part 258) have to be met; and the sewage sludge must
meet  the Part 258  quality requirements for materials placed  in a MSWLF unit.

Part 503 defines a sewage sludge incinerator as an  enclosed device  in which only sewage sludge and
auxiliary fuel are fired.  Either sewage sludge or a material  derived from sewage  sludge may be fed to
a sewage sludge incinerator.  In other cases, sewage sludge or a material derived from sewage sludge and
another material may be fed to the incinerator separately (i.e.,  the sewage sludge and other material are
mixed in the incinerator itself).  In these cases,  Part 503  still applies because the other material is
considered auxiliary fuel.

STORE OR STORAGE OF SEWAGE SLUDGE
  Statement of Regulation

    §503.9(y)     Store or storage of sewage sludge is the placement of sewage sludge on land on which the
                sewage sludge remains for 2 years or less. This does not include placement of sewage sludge
                on land for treatment,                              . *
If the sewage sludge remains on the land for longer than 2 years, the area of land is an active sewage
sludge unit and the Part 503 surface disposal requirements have to be met unless the person who prepares
the sewage sludge demonstrates that the land is not an active sewage sludge unit.  This demonstration is
explained in Chapter 5.

One question related to this definition is how to determine whether the sewage sludge remains on the land
for longer than 2 years.  This can be done either by determining the age of the sewage sludge on the land
or the time that the land is used to store sewage sludge.  In most cases, determining the age of the sewage
                                              2-4

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                                     2.  WHAT is PART 503?
sludge is more appropriate because land may be used for short-term storage over a long period (e.g.,
sewage sludge may be stored on the same area of land for only 6 months out of the year).

TREAT OR TREATMENT OF SEWAGE SLUDGE
  Statement of Regulation                                '     ,

    §503.9(z)      Treat or treatment of sewage sludge is the preparation of sewage sludge for finalise or
                 disposal. This includes, T>ut is not limited to? thickening, stabilization, and dewatering of,
                 sewage sludge. This does not include storage of sewage sludge,    	
This definition  is important because, with the exception of certain pathogen alternatives and vector,
attraction reduction options, Part 503 does not establish requirements for the treatment of sewage sludge:
Instead, it establishes requirements for the use or disposal of sewage sludge.

TREATMENT WORKS TREATING DOMESTIC SEWAGE
  Statement of Regulation

    §122,2        Treatment works treating domestic sewage (TWTDS) means a POTW or say other sewage
                 sludge or wastewater treatment device or systems, regardless of ownership (including federal
                 facilities) used in the storage, treatment, recycling, and reclamation of municipal or domestic
                . sewage, including land dedicated for the disposal of sewage sludge. This definition does not
                 include septic tanks or similar devices.  For purposes of this definition, "domestic sewage"
                 includes waste and'wastewater from humans or household operations that'are discharged^ to
                 or otherwise enter a treatment works. In States where there is no approved State sludge
                 management program, under section 405(0 of the CWA, the Regional Administrator .may ,
                 designate any person subject to the standards for sewage sludge use and disposal in 40 CER
                rpart 503 as a "treatment works treating domestic sewage," where he or-she finds that there is
                 a potential for adverse effects on public health and the environment from poor sludge quality
                 or poor sludge handling, use or disposal practices, or where he or she finds that such ,
                 designation is necessary to ensure that such person is in compliance with 40 CFR part S03l
Note that the preamble to Part 501 indicates that  "lands dedicated to the disposal of sewage sludge"
includes land used for final disposal of sewage sludge such as monofills and surface disposal sites (54 PR
18726). It does not include land on which sewage sludge is applied to condition the soil or fertilize crops
grown  in the soil.

The above definition explains the situations when the Regional Administrator may designate someone as
a TWTDS.' States with approved State sewage sludge management programs can develop any appropriate
program ,to regulate non-TWTDS users or disposers of sewage shidg'e to ensure compliance with Part
503.                                       ':     -     .
                                                                             ,                    /

The definition of a TWTDS is used in the sewage sludge permitting program to identify entities subject
to a permit under section 405(f) of the CWA. As  indicated below, this definition is different from the'
definition of treatment works in Part 503.
                                                 2-5  •

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                                     2.  WHAT is PART 503?
TREATMENT WORKS
  Statement of Regulation

    §503.9 (aa)    Treatment works is either a federally owned, publicly owned, or privately owned device or
                system used to treat (including recycle and reclaim) either domestic sewage or a combination
                of domestic sewage and industrial waste of a liquid nature.
This definition indicates the ownership of the devices or systems in which domestic sewage is treated.
Note that a treatment works can treat only domestic sewage or a combination of domestic sewage and
industrial waste of a liquid nature.  In both cases, .the solid, semi-solid, and liquid residues generated are
sewage sludge.                                        .
                                                                                     1 •
Septic tanks or similar devices are included in the definition of a treatment works because domestic
sewage is treated in those devices. For the solid, semi-solid, arid liquid residues from those devices to
be sewage sludge, the devices must be treatment works.

Septic tanks or similar devices are not included in the above definition of a TWTDS because the owner/
operator of those devices will not receive a permit  for the use or disposal of the solid, semi-solid, or
liquid  residues generated in the devices.   However, because the residues are  sewage  sludge, the
appropriate Part 503 requirements have to be met if the residues are used or disposed through one of the
Part 503 use or disposal practices even in the absence of a permit.

2.3    WHAT DOES PART 503  REGULATE?

As  mentioned previously, Part 503 contains the requirements that have to be met when sewage sludge
is applied to the land, placed on a surface disposal site, placed on a municipal solid waste landfill unit,
or fired in a sewage sludge incinerator. Requirements are included in Part 503 for pollutants in sewage
sludge, the reduction of pathogens in sewage sludge,  the reduction of the  characteristics in sewage sludge
that attract vectors, the quality of the exit gas from a sewage sludge incinerator stack, the quality of
sewage sludge that is  placed in a MSWLF unit, the  sites where sewage  sludge is either land applied or
placed for final disposal, and for a sewage sludge incinerator.     ,

2.3.1   POLLUTANTS

In developing the pollutant limits in Part 503, EPA first identified pollutants most likely to interfere with
the  use or disposal of sewage sludge.  Using the information available  on the toxic effects of these
pollutants, the Agency then developed a list of pollutants for which an initial exposure risk assessment
was conducted. Because the use or disposal of sewage sludge affects air, soil, and water, all media were
considered in the risk assessment.

Based on the results of the initial exposure risk assessment, a final list of pollutants was developed for
Part 503.  A more detailed exposure risk assessment was then conducted to develop the limits for the
pollutants in Part 503.   The risk assessments  conducted to  develop the Part 503 pollutant limits are
discussed below.
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                                    2.  WHAT is PART 503?
For land application, 14 pathways of exposure were considered in the detailed exposure risk assessment.
The movement of a pollutant into arid through the environment was simulated using models to determine
the concentrations of pollutants reaching art individual, plant, or animal (see Figure 2-1).  These models
used human health and environmental criteria (i.e., art allowable dose) already published by EPA and an
estimate of the exposure to a highly exposed individual (human, plant, or animal) to develop the amount
of a pollutant (i.e., cumulative pollutant loading rate) that could be applied to the land in sewage sludge.
The most stringent cumulative pollutant loading rate from the risk assessment is the loading rate for each
pollutant in Table 2 of § 503.13.  Note that not every pathway was evaluated for every pollutant. In some
cases, a pathway was not applicable for a pollutant (e.g., .vapor pathway for an inorganic pollutant)'and
in other cases data needed to evaluate a pathway for a pollutant were not available.  The pollutants for
which limits are included  in the  land application subpart are listed in Table 2-1.

For surface disposal, two pathways were evaluated in the detailed exposure risk assessment.   These were
the ground-water pathway and the air or vapor pathway.  These pathways are different from the ground-
water and vapor pathways for land application because different assumptions were used in the pathway
models  for  each practice.  The  most stringent of the pollutant limits for these two pathways are the
pollutant limits  for surface disposal in Part 503.  The pollutants for  which limits are included in the
surface  disposal subpart also  are listed in Table 2-1.

One pathway was evaluated during the  exposure risk assessment for firing of sewage sludge  in a. sewage
sludge  incinerator.  This was the inhalation pathway.  A risk specific concentration (i.e., allowable
ambient air concentration)  was developed  for  each  pollutant  during  the risk  assessment.    That
concentration is used in an equation in Part 503 along with site-specific values for certain parameters to
calculate the allowable concentration of the pollutant in  sewage sludge. In the case of lead, an existing
standard (i.e., National Ambient Air Quality Standard) is used in an equation in Part 503 with site-
specific values for other parameters to calculate the allowable concentration of lead in the sewage sludge.
In addition, the National  Emission Standards  for beryllium and mercury have to be met when sewage
sludge is fired in a sewage sludge incinerator.  Table 2-1 also contains the pollutants for which limits or
equations used to calculate limits are included in the Part 503 incineration subpart.

As shown in Table.2-1, Part 503 contains limits for 11 metals for one or more use or disposal practice,
although not every pollutant  is regulated under each practice.  Part 503 also contains requirements for
total hydrocarbons in the emissions from a sewage sludge incinerator stack.  This is discussed further
below.      "                                                 •
                                           These include,  but  are not  lirhited to,  certain bacteria,
2.3.2   PATHOGENS

Pathogens  are  disease-causing organisms.
protozoa, viruses, and helminth ova.

The pathogens for which requirements are included in Part 503 are Salmonella sp. bacteria, enteric
viruses, and viable helminth ova.  In some cases, the level of fecal coliform in the sewage sludge can be
used to show that certain pathogens have been reduced in sewage sludge.' The Part 503 requirements for
the reduction of pathogenic organisms  in sewage sludge are technology-based operational standards.
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                            2. WHAT is PART 503?
                                      Human
                           Animal
Human
                  •!=;•:•:;;•!•:!;•;•!•;•!.!•!•!•:•
               Ground Water
                                       Animal
                                   OW11
                               \t
                                 Sewage
                                 Sludge
    Human
                        Contaminated
                          Water
        Human
                                                      Soil Biota
                                                            v
                                                Soil Biota
                                                            Predator of Soil Biota
                                 Human
                    FIGURE 2-1 EXPOSURE PATHWAYS
                                     2-8

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                                    2.  WHAT is PART 503?
          TABLE 2-1 POLLUTANTS REGULATED BY PART 503 REGULATION
Pollutant
Arsenic
Beryllium . -
Cadmium
Chromium ,
Copper .
Lead
Mercury • • " "
Molybdenum / .
Nickel -
Selenium
J Zinc
Land
Application
X

X

X
X
- • X '
X '
X
X
X
Surface
Disposal
X

- ' .
x




X


Incineration
X
X
X
X

x
X

X


Part 503  contains requirements  for  two classes  of  pathogen reduction.   The  Class  A  pathogen
requirements, which are met by treating the sewage sludge, are designed to ensure that the density of
Salmonella sp. bacteria, enteric viruses, and viable helminth ova in the sewage sludge are reduced to
below detectable levels.  Because the density of pathogens in the sewage sludge is reduced to below
detectable,levels by  treating the sewage sludge  before, it used or disposed, there can be immediate
exposure to the sewage sludge after it is used or  disposed.  For a sewage sludge to be classified Class
A with respect to pathogens, one of the six Class A pathogen alternatives in Part 503 has to be met. -

The Class B pathogen requirements rely on a  combination of treatment of the sewage sludge to reduce
the density of Salmonella sp. bacteria, enteric viruses, and viable,helminth ova in the sewage sludge and
prevention of exposure to the sewage sludge after it is used or disposed.  Under this approach, restrictions
are placed on the site where the sewage sludge is used or disposed to prevent exposure to the sewage
sludge.  This allows time for the environment to further reduce pathogens in the sewage sludge to below
detectable limits.  For example, when Class  B sewage sludge  is applied to the land, site restrictions
concerning harvesting of certain crops, grazing  of animals, and public access have to be met.  For a
sewage  sludge to be classified Class B with respect to pathogens, one of the three Class B pathogen
alternatives in Part 503 has to be met.           ,                    ,

Note that some of the pathogen requirements  have to be met "at the time the sewage sludge is used or
disposed" while others apply to sewage sludge "that,is used or  disposed."  The requirements that have
to be met at the time of use or disposal are  designed to ensure the requirements  are met as close as
possible to when the sewage sludge is actually used or disposed.

There are two cases" related to  the  "at the time of use or disposal" requirement.  In one ease, a sample
of the sewage sludge may be collected and analyzed far enough in advance to receive the analytical results
before the sewage sludge is actually used or disposed.  This may be 3 days or some  other period
depending, on how long it takes to receive the analytical results.   In the other case,  a  sample  may be
collected  at the,time of use or disposal, but  the analytical results are not  received prior to when the
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                                    2. WHAT is PART 503?
sewage sludge is actually used or disposed.  In this second case, nothing  can be done to correct a
violation of Part 503 because the sewage sludge already has been used or disposed.  In both cases, the
pathogen requirement is met at the "time of use or disposal."               -           .

Pathogen requirements that apply to sewage sludge "that is used or disposed" can be met any time before
the sewage sludge is actually used or disposed. For example, the Class A time/temperature requirements
can be met any time  before the sewage sludge is used or disposed as long as there is a record that
indicates the temperature of the sewage sludge was maintained at a certain value for a certain period.

The Part 503 pathogen reduction requirements apply to sewage sludge that is applied to the land or placed
on a surface disposal site. There are no pathogen reduction requirements for sewage sludge placed  on
a MSWLF unit because Part 503 relies on the criteria in Part 258 to achieve this reduction. In addition,
there are no pathogen reduction requirements for incineration because pathogens  do  not  survive the
incineration process.

2.3.3   VECTOR ATTRACTION REDUCTION              ,

Vector attraction is the characteristic of sewage sludge that attracts rodents, flies, mosquitos, or other
organisms capable of transporting infectious agents (i.e., pathogens). The purpose of the Part 503 vector
attraction reduction operational standards is to reduce the attraction of sewage sludge to vectors.

There are two approaches to vector attraction reduction. -Vector attraction can be reduced by treating the
sewage sludge or by placing a barrier between the sewage sludge and the vectors. Eight of the 11 vector
attraction reduction options in Part 503 are based on treating the sewage sludge. . The other three (i.e.,
injection, incorporation, and daily cover) require that a barrier be placed between the sewage sludge and
vectors.

One  of the vector attraction reduction options in Part 503 has to be met when  sewage sludge is either
applied to the land or placed on a surface disposal site. Part 503 relies on the Part 258 criteria to reduce
vector attraction when sewage sludge is placed on a MSWLF unit.  There are no vectqr attraction
reduction  requirements  for sewage sludge that is fired in a  sewage sludge incinerator because the
characteristics of sewage sludge that attract vectors are reduced during incineration.

2.3.4  EXIT GAS FROM A SEWAGE SLUDGE INCINERATOR STACK

Part 503 contains a requirement .that limits the concentration of either total hydrocarbons (THC) or carbon
monoxide (CO) in the exit gas from a sewage sludge incinerator stack. Both requirements are operational
standards because they are technology-based (see Section 2.7),

THC is a measure of the organic compounds in the exit gas. Because organic compounds are  formed
during the combustion process, EPA concluded that those compounds should be controlled by limiting
the concentration of THC in the exit gas instead of establishing an allowable concentration  for  certain
organic pollutants in the sewage sludge fed to the incinerator.  The THC operational standard of 100 parts
per million (ppm) is a measure of all organic compounds in the exit  gas (i.e., those in the sewage sludge
and those formed during incineration) and is based on the performance of a certain type of incinerator.
In addition, economic impact was considered  when establishing  the  allowable value for the THC
operational standard.
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                                    2.  WHAT is PART 503?
GO can be measured in the exit gas of a sewage sludge incinerator in lieu of measuring THC.  EPA
concluded that if the monthly average concentration of CO in the exit gas is equal to or less than 100
ppm, the monthly average concentration of THC in the exit gas also is equal to or less than 100 ppm.

2.3.5  PART 258 QUALITY REQUIREMENTS

Part 503 requires that sewage sludge  placed  in  a MSWLF unit meet the requirements in Part 258
concerning the quality of materials placed in a MSWLF unit. Those requirements are found in Subpart
C - Operating Criteria - of Part 258.              :

The first requirement is in §258.20 - Procedures for excluding the receipt of hazardous waste.  This
subsection indicates that hazardous materials and polychlorinated biphenyls wastes can not be placed in
a MSWLF  unit.  Thus,  if sewage sludge is hazardous,  as  defined in 40 CFR Part 261, or  is a
polychlorinated biphenyls waste, as defined in 40 CFR Part 761, it can not be placed in a MSWLF unit.

The second  requirement is in §258.28 - Liquid restrictions. This subsection indicates that liquid waste
may not be placed in a MSWLF unit. Liquid waste is any waste determined to contain "free liquids" as
defined by Method 9095 (i.e., Paint Filter Liquids Test), in EPA Publication No. SW-846.  Thus, if the
sewage sludge does not pass the Paint Filter Liquids Test, it can not be placed in a MSWLF unit.

2.3.6  OTHER REQUIREMENTS

In addition to establishing requirements for the quality of sewage  sludge that is used or disposed,  Part
503,contains management practices and other restrictions that apply to a use or disposal site under certain
situations.  Part 503  also contains management practices that apply to a sewage sludge incinerator.

Requirements are included in Part 503  for a use or disposal site because those requirements are needed
to protect public health and the environment.  To,meet those requirements, control of the site must be
maintained.

For example, information about a land application site has to be known to ensure that the land application
agronomic rate management practice is  met.  Control over a land application site also is needed to ensure
that the Class B site restrictions for harvesting crops and turf, .for grazing of animals, and for public
contact are met. In all cases, records of how the requirements  pertaining to the site are met have to be
kept and certifications that certain requirements are met have to be made.

For surface  disposal, several of the management practices are related to locating the surface disposal site.
Other management practices require that certain activities be conducted at a surface disposal site (e.g.,
monitor the air for methane gas).  In most cases, the owner/operator of the surface disposal site is
responsible  to .ensure that requirements related to the surface disposal site itself are met.

Part 503 also contains management practices that pertain to the operation of a sewage sludge incinerator.
These  management  practices  address  the • different  types  of  instruments  that  have to  be installed,
calibrated,  operated, and maintained.
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                                    2.  WHAT is PART 503?
2.4   WHO DOES PART 503 REGULATE?

In addition to establishing requirements for the quality of sewage sludge that is used or disposed and for
sites on  which sewage sludge  is used or disposed,  Part 503  indicates  who has  to ensure that the
requirements are met.  These include the person who prepares  sewage sludge, the person who land
applies sewage sludge, the owner/operator of a surface disposal site, the person who fires sewage sludge
in a sewage sludge incinerator, Class I sludge management facilities, POTWs with a flow rate equal to
or greater than one mgd, and POTWs that serve a population of 10,000 people or more.

2.4.1  PERSON WHO PREPARES SEWAGE SLUDGE

Part 503 contains several requirements that the person  who prepares  sewage sludge is responsible to
ensure are met.  Note that a person who prepares sewage sludge is either the generator of the sewage
sludge or a person who derives a material from sewage sludge (i.e., changes the quality of sewage sludge
received  from the generator of the sewage sludge).  The first of these requirements is in §503.7.

As indicated in §503.7, the person who prepares sewage sludge must ensure that the applicable Part 503
requirements are met when sewage sludge is applied to the land, placed on a surface disposal site, or fired
in a sewage sludge incinerator. The person who prepares sewage sludge also is responsible to ensure the
sewage sludge meets the Part 258 quality requirements when sewage sludge is placed in a MSWLF unit.

Section 503.7 places the ultimate responsibility to ensure that the Part 503 requirements are met on the
person who prepares sewage sludge even when the preparer is  not the  person who actually uses or
disposes  of the sewage sludge.  For example, if the person who prepares sewage sludge provides the
sewage sludge to another person who applies the sewage sludge to the land, the preparer must ensure that
the Part 503 requirements for the applier are met. In this case, the preparer is responsible even if there
is an agreement or contract with the applier and the preparer provides the  applier the appropriate notice
and necessary information about the Part 503 requirements.

Because of § 503.7, preparers now have to know how and where their sewage sludge is used or disposed.
This is different  from the past when, in many cases, the preparer did not  know what happened to their
sewage sludge after it was either given or sold to another person.

In addition to overall responsibility to ensure that the Part 503 requirements are met, the preparer also
is responsible for several specific Part 503 requirements. In some cases, the preparer must ensure that
the pollutant limits, pathogen requirements, vector attraction reduction requirements, and management
practices are met. The preparer also must provide notice and necessary, information to certain persons,
must keep records, and must report information to the permitting authority in certain cases.

As mentioned above, a preparer of sewage sludge  is both the generator arid, a person who derives a
material  from sewage sludge.  When the preparer is  the person who  derives a material from sewage
sludge, the generator's responsibilities under Part 503 are reduced.  In  this case, the generator provides
the person who derives a material "a raw product" from which the material is  derived. The person who
derives the material  is responsible to ensure that the derived material meets the appropriate Part 503
requirements (e.g., pollutant limits, pathogen requirements, and vector attraction reduction requirements)
and is responsible for the ultimate use or disposal of the derived material.
                                             2-12

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                                    2.  WHAT is PART 503?
 2.4.2   PERSON WHO APPLIES SEWAGE SLUDGE TO THE LAND

 The Part 503 requirements for .which the person who applies sewage sludge to the land is responsible vary '
 depending on which of the Part 503 requirements are applicable.  For example,  if bulk sewage sludge,
 is applied to the land under the cumulative pollutant loading rate concept, the applier must keep records
 of the amount of each of the Part 503 pollutants applied to the land in sewage sludge.,             ,

 Another example of a Part 503 requirement for which the land applier is responsible is the Class B site
 restrictions.  When bulk sewage sludge meets the Class B pathogen requirements, the land applier must
 ensure that the restrictions on the site are met (e.g., do not harvest root crops for 3& months after the
 sewage sludge is applied).                                          .                    «

 Other Part 503 requirements for which the land applier is responsible when bulk sewage sludge is applied
 to the land include the requirement to provide the owner or lease holder of the application site notice and
 necessary information, the land application management practices, the vector attraction reduction options
 concerning injection of sewage sludge below the land surface and incorporation of the sewage sludge into
 the soil, and certain recordkeeping requirements.                           f

 In the case of sewage sludge that is sold or given away in a bag or other container for application to the
 land, the person who applies the sewage sludge is responsible for reading and following the instructions
 on a label or information sheet.  For example, the applier should not apply the sewage sludge at a rate
 that is greater than the rate specified on the bag or information sheet. ..•'••

 2.4.3   OWNER/OPERATOR OF A SURFACE DISPOSAL SITE

 The owner/operator of a surface disposal site is responsible to ensure that several  of the Part 503 surface
 disposal requirements are met. These include pollutant limits under certain situations, the surface disposal
 management,practices, and certain vector attraction reduction options (i.e., those options in which a
 barrier is placed between the sewage sludge and the vectors).

 2.4.4  PERSON WHO FIRES SEWAGE SLUDGE IN A SEWAGE SLUDGE INCINERATOR

 Part 503 requires that no person shall  fire sewage sludge in a  sewage sludge incinerator except in
 compliance with the requirements in subpart E of Part 503. Thus, that person must ensure that the Part
 503 incineration requirements are met.

 2.4.5   CLASS  I  SLUDGE MANAGEMENT  FACILITIES,  POTWS WITH A FLOW RATE
        EQUAL TO OR GREATER THAN 1MGD, AND POTWS THAT SERVE  10,000 PEOPLE
         OR MORE

 The reporting requirements in subparts B, C, and E of Part 503 require that class I sludge management
 facilities, POTWs with a flow rate equal to or greater than 1 mgd, and POTWs that serve 10,000 people
• or more report certain information annually.
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                                    2.  WHAT is PART 503?
2.5    HOW IS PART 503 IMPLEMENTED?

2.5.1  SELF-IMPLEMENTING

EPA designed Part 503 so that the standards are directly enforceable against most users or disposers of
sewage sludge, whether or not they obtain a permit.  This means  that publication of Part 503  in the
Federal Register serves as notice to the regulated community of its duty to comply with the requirements
of the rule, except those requirements that indicate that the permitting authority shall specify what has
to be done. Thus, even without the terms and conditions of a sewage sludge permit, regulated users and
disposers of sewage sludge are required to meet the requirements promulgated in the rule.  The proposed •
amendments to Part 503 delete the requirements  for permit authority specification and will make the
entire rule self-implementing,  once they are finalized.

As required by Section 405(d) of the CWA, compliance with the Part 503 standards must be achieved
as expeditiously as possible, but no later than February 19, 1994, or no later than February 19,  1995,
if construction of new pollution control  facilities is required to comply with the regulation.   The
frequency of monitoring,  recordkeeping, and reporting requirements (except those  for THC) were
effective  on July  20,  1993.  Compliance with the incineration requirements that are revised in the
amendments mentioned above is required no later than 90 days from publication of the final amendments.
If new pollution control facilities must be constructed, compliance is required no later than 12 months
from publication.

2.5.2  PERMITS

Even though Part 503 is largely self-implementing, Section 405(f) of the CWA requires the inclusion of
sewage sludge use or disposal requirements in any Section 402 permit issued to a TWTDS.  On May 2,
1989 (54 FR 18716), EPA revised Part 122 to expand its authority to issue NPDES permits with these
requirements.

The sewage sludge permitting regulations (Part 122) apply to all TWTDS.   This includes all sewage
sludge generators, sewage sludge treaters and blenders,  surface disposal sites,  and sewage  sludge
incinerators.  Persons regulated by Part 503 but not considered TWTDS,  such as land  appliers who do
not change the quality of the  sewage sludge,  may be designated as  a TWTDS by the  Regional
Administrator to protect public health or the environment or to ensure compliance with Part 503. The
reasons for designating a sewage sludge user  or disposer as a TWTDS  should be stated in the permit's
fact sheet or statement of basis.
                          ' *               -               ,.                f        .
When a State is authorized to run the Federal sewage sludge management program under Part 123 or Part
501 they must at a minimum have authority to issue permits for all TWTDS. If they wish to require
permits from land appliers or other  persons that are not considered TWTDS, they can do so without
designating them as TWTDS.  This is because States can regulate non-TWTDS sewage sludge users or
disposers as they wish, as long as they ensure compliance with Part 503.

Some TWTDS are not currently required  to apply for a permit because they  are not regulated by Part
503. The best example of this group is industrial treatment works that generate sewage sludge from the
combined treatment of industrial wastewater and domestic sewage.  The treatment of domestic sewage
causes them to be considered a TWTDS, but they are not presently regulated  by Part 503.  If Part 503
is amended to include these treatment works, they will be required to apply for a permit.
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                                    2.  WHAT is PART 503?
There are also numerous users and disposers of sewage sludge that are not TWTDS.  These include
sewage sludge baggers who do not change the quality of the sewage sludge, land appliers, and domestic
septage haulers.  These are the persons that can be designated as TWTDS by the Regional Administrator
if it is necessary to issue them a permit.

When one preparer sends sewage sludge to another preparer, the permit requirements may- be split
between the preparers.  Because the second preparer is, changing the sewage, sludge quality, most of the
permit requirements should be in the permit for that person.   The exact division of the requirements
depends on who is doing what to the sewage sludge. In some situations the permit writer might designate
two preparers co-permittees.

The following permits issued under Sections 402 and 405 of the CWA will be the principal vehicles for
implementing Part 503:

     • NPDES permits issued by EPA under Part 122

     • State permits issued under an approved sewage sludge program that can be part of the State
       NPDES (Part 123) program or a non-NDPES (Part 501) sewage sludge permit program.   .

The Part 503 standards and requirements also may be included in permits issued under the appropriate
provisions of:

     * Subtitle C of the Solid Waste Disposal Act                                            ,
  .   • Part C of the Safe Drinking Water Act
     • The Marine Protection, Research;  and Sanctuaries Act of 1972                    .  ...    .
     • The Clean Air Act [see CWA Section 405(f)(2)].                     -

This guidance document is also intended for use by regulators  in these programs.

Initially, EPA Regions are responsible for including conditions to implement Part 503 in NPDES permits
issued to treatment works in all States because, currently, no State has received EPA approval of its State
sludge management program.1  Where a  State  has an  approved  NPDES program,  EPA will issue  a
separate NPDES permit to implement the sewage sludge standards and requirements or negptiate with the
State on joint issuance of NPDES permits containing the Part 503 technical standards and requirements.
Rather than issue individual permits, the  EPA  Regions (and the States that become authorized) may
choose to develop and issue general permits for different categories of TWTDS or sewage sludge use or
disposal practices.
    'EPA's sewage sludge permitting program will not displace existing State sewage sludge management
programs. States are encouraged to seek program approval as soon as possible, however, and the Agency
has published the State Sludge Management Program Guidance Manual (EPA 1990) to assist their efforts.
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                                   2. WHAT is PART 503?
2.6    WHAT IS NOT REGULATED BY PART 503?

Part 503 contains the requirements that have to be met when sewage sludge is used or disposed through
various use or disposal practices. This section discusses activities and materials that are not subject to
Part 503 requirements.                                      •

2.6.1   TREATMENT PROCESSES
                a         j

Part 503 does not establish requirements for processes used to treat domestic sewage or for processes
used to treat sewage sludge prior to final use or disposal with two exceptions. The exceptions pertain
to the processes used to reduce pathogens and vector attraction.

Some of the  Part 503 pathogen alternatives and vector attraction  reduction options are performance
standards (e.g., raise the pH of the sewage sludge and reduce the volatile solids of the sewage sludge).
Part 503 does not specify, however, how to meet the performance standards. They can be met through
treatment of the sewage sludge or through any  other approach.

2.6.2   SELECTION OF A USE OR DISPOSAL PRACTICE

Part 503 does not require that sewage sludge be used or disposed through a particular use or disposal
practice.   The determination of the manner  in  which sewage sludge  is used or disposed is the
responsibility of the local authority.  However, if the local authority decides to apply sewage sludge to
the land, place sewage sludge on a surface disposal site, place sewage sludge in a MSWLF unit, or fire
sewage sludge in a sewage sludge incinerator, the appropriate requirements in Part 503 have to be met.

2.6.3   CO-FIRING OF SEWAGE SLUDGE

Part 503 does not establish requirements for sewage sludge co-fired in an incinerator with other wastes
or for the incinerator in which sewage sludge and other wastes are co-fired. Other wastes do not include
auxiliary fuel. Most materials fired with sewage sludge are considered auxiliary fuel.

If the auxiliary fuel is municipal solid waste, it can not exceed 30 percent of the dry weight of the sewage
sludge or material derived from  sewage sludge and auxiliary fuel.  The requirements in 40 CFR Parts
60 and 61 apply in cases where the total mass fired contains more than 30 percent municipal solid waste.
In all other cases, Part 503 applies when either  sewage sludge or a material derived from sewage sludge
and auxiliary  fuel are fired in an incinerator.                                                    ,

2.6.4   SLUDGE GENERATED AT AN INDUSTRIAL FACILITY

Sludge generated at an industrial  facility during the treatment of only industrial wastewater is not subject
to Part 503 when it used or disposed. Because domestic sewage is not in the influent to the  treatment
works, solids removed from the industrial wastewater  during treatment are not, by definition, sewage
sludge.  For this reason, the Part 503 requirements do  not apply when the sludge is used or disposed.

If the sludge  is applied to or placed on the land, the requirements  in Part 257 have to be met.  If the
sludge is placed  in a municipal solid waste landfill, the requirements in Part 258 have to be met.
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                                   2.  WHAT is PART 503?
2.6.5  SEWAGE SLUDGE GENERATED AT AN INDUSTRIAL FACILITY

Sewage sludge generated at an industrial facility during the treatment of industrial wastewater combined
with domestic sewage is not subject to Part 503 when it used or disposed. In this case, solids generated
during treatment of the combined wastewaters are sewage sludge because domestic; sewage is in the
influent to the treatment works.

The most important aspect of this exclusion is that the sewage sludge has to be generated at an industrial
facility during the  treatment of industrial wastewater combined with domestic sewage.  If the sewage
sludge is not generated at an industrial facility, the Part 503 .requirements have to be met if the sewage
sludge is used or disposed through one of the Part 503 practices.:

EPA decided not to regulate this type of sewage sludge under Part 503 because the Agency did not have
the information needed to evaluate the impact of the Part 503 regulation on industries.  Instead, EPA
decided' to' continue to subject this sewage sludge to the requirements in Part 257 if the  sewage sludge
is, applied to or placed on the land (these are the requirements that applied to all sewage sludges .applied
to or placed on the land prior to Part 503).  Note that Part 503 does apply to. the use  or disposal of
sewage sludge generated at an industrial facility if domestic sewage is treated by itself at the industrial
facility. '...     .  '    .           '                 '                 •            •  •  .'

2.6.6  HAZARDOUS SEWAGE SLUDGE

Part  503 does not  establish  requirements for the use or  disposal of sewage sludge determined to be
hazardous in accordance with Part 261. .Hazardous sewage sludge-is subject to the requirements in 40
CFR Parts 261-268 when it is used or disposed.                 ,

2.6.7  SEWAGE SLUDGE WITH HIGH PCB CONCENTRATION

Part  503 does not establish requirements for the use or disposal of sewage sludge with a concentration
of polychlorinated  biphenyls (PCB) equal to or-greater than 50 milligrams per Jcilogram of total solids
(dry  weight  basis).  The requirements in Part 761 have to be met when those sewage sludges are used
or disposed.

2.6.8  INCINERATOR ASH

Part  503 also does  not establish requirements for the use or disposal of ash generated during the firing
of sewage sludge in a sewage sludge incinerator.  Because the characteristics of ash are  different from
the characteristics of sewage sludge,  the pollutant limits developed during the exppsure risk assessments
do, not apply to the ash.  For this reason, Part 503 also does not apply to the  ash  when it,is  used or
disposed.                                                 •   .                            ,

2.6.9  GRIT AND  SCREENINGS

Part  503 does not  establish requirements for the use or disposal of grit (e.g., sand, cinders, or other
materials with a high  specific gravity)  or  screenings (e.g., relatively large materials  such as rags)
generated during preliminary treatment of domestic sewage, or a combination of domestic sewage and
industrial waste of a liquid nature in  a treatment works. These materials usually are generated when the
wastewater passes  through bar screens and a grit chamber at the beginning of the treatment works.
                                             2-17'

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                                    2. WHAT is PART 503?
Because grit and screenings have characteristics that are different from the characteristics of sewage
sludge, the pollutant limits .developed during the  exposure risk assessments do not apply to those
materials.  For this reason, Part 503 does not apply when grit ,and screenings are used or disposed.

2.6.10 DRINKING WATER TREATMENT SLUDGE

Part 503 does not establish requirements for the use or disposal of sludge generated during the treatment
of either surface water or ground water used for drinking water. Because domestic sewage is not in the
influent to the processes in which surface water or ground water is treated, the solids removed in those
processes  are not sewage sludge. Thus, Part 503 does not apply to the use or disposal of those solids.

2.6.11 COMMERCIAL AND INDUSTRIAL SEPTAGE

Part 503 also does not establish requirements  for the use or  disposal of commercial septage, industrial
septage, a mixture of domestic septage and commercial  septage, or a mixture of domestic septage and
industrial  septage. Part 503 only applies if the device in which the septage is generated (e.g., a  septic
tank) only receives domestic sewage.  If the device receives any material other than domestic sewage,
the solids  removed from the device are not domestic septage.  In this case, Part 503 does not apply when
the septage is used or disposed.

Part 503 also does not apply if domestic septage is mixed with either commercial septage (e.g.,  grease
from a grease trap at a restaurant) or industrial septage prior to use or disposal.   In this case, the
requirements in Part 257 have to be met if the mixture is applied to or placed on the land. Part 257 also
applies if either commercial septage or industrial septage or a mixture of commercial and industrial
septage is applied to or placed on the land.

2.7    ELEMENTS OF A  PART 503 STANDARD

The Part 503 regulation is a complex, yet flexible regulation.  For example, different pollutant limits can
be met when sewage sludge is applied to the land depending on the type of sewage sludge (e.g., bulk)
and the type of land on which the sewage sludge is  applied. In addition, Part 503  contains several
pathogen alternatives and vector attraction reduction options that can be met. This allows the person who
prepares sewage sludge to "tailor" a Part 503 standard for their particular situation.

As with any standard (e.g., a water quality standard or a drinking water standard), the elements of a Part
503 standard must be understood to comply with the Part 503 regulation.  This section discusses those
elements,  which include general requirements,  pollutant limits, management  practices, operational
standards,  frequency  of  monitoring requirements,  recordkeeping  requirements,  and  reporting
requirements.

2.7.1  GENERAL REQUIREMENTS

The general requirements in Part 503 vary by use or disposal practice.  The first general requirement for
each use or disposal practice is that sewage sludge shall not be used or disposed unless the applicable Part
503 requirements are met.                                                                  ,

The main purpose of the other general requirements is to ensure the transfer of information about the Part
503  requirements between  different parties (e.g., a person "who prepares sewage sltfdge and a land
                                             2-18

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                                     2.  WHAT is PART 503?
 applier).  These, general requirements address such things as providing notice and necessary information
 about the Part 503 requirements to different persons, determining the .amounts of different pollutants
 applied to the land previously in' sewage sludge, notifying the permit authority about the interstate transfer
 of sewage sludge, and closing a surface disposal site.                                          '

 The general requirements are an important element of a Part 503 standard. All persons involved in the
 use or disposal of sewage sludge must understand and follow the appropriate Part 503 general
 requirements.                                  \                            '

 2.7.2  POLLUTANT LIMITS

 The pollutant limits in Part 503 describe the amount of a pollutant allowed per unit of amount of sewage
 sludge or the amount of a pollutant that can be applied  to a unit area of land.  The pollutant limits are
 based on the results of an exposure risk assessment and are on a dry weight basis.

 Although the Part 503 pollutant limits are important, they are not the only element in a Part 503 standard.
 All elements of a Part 503 standard should be considered equally when determining the Part 503
- requirements that have to be met.                    ,                 - .  .    .

 2.7.3  MANAGEMENT PRACTICES

 The Part 5Q3  management practices contain .requirements  that help protect public health and the
 environment from  the reasonably adverse effects of  pollutants in the sewage sludge.   Often, the
 management practices address situations.not addressed in the exposure risk assessment (e.g., sewage
 sludge entering a water of the United States after being applied to frozen or snow-covered land). In other
 cases, the management practices address operational requirements (e.g., install an instrument).

 2.7.4   OPERATIONAL STANDARDS

 The CWA  indicates that in cases where a risk-based  limit can hot be developed  for a pollutant,  an
 operational standard can be developed that in the judgment of the EPA Administrator protects public
 health and the environment from the reasonably anticipated adverse effects of the pollutant. EPA chose
 to control pathogens in sewage sludge, the attraction of vectors to sewage sludge, and the concentration
 , of total hydrocarbons  in the exit gas from a sewage sludge incinerator stack through  an operational
 standard because either a risk assessment methodology for those parameters was not available or data
 needed to conduct a risk assessment were not available.

 An operational standard is a separate element in a Part 503 standard to distinguish it from a pollutant
 limit. As  indicated previously, pollutant limits are risk-based whereas the operational standards are
 technology-based.                                                          ,'.''..'

 2.7.5  FREQUENCY OF MONITORING

  This element of a Part  503 standard indicates the frequency  at which tests have  to be conducted to
  determine whether a Part 503  requirement is met.  The Part 503 frequency of monitoring requirements
  are based on the amount of sewage sludge that is used or disposed annually. The greater the amount used
  or disposed, the more frequent tests have to be conducted.  In cases where nO  sewage sludge is used or
  disposed during a year, no tests have to be conducted.             ,
                                               2-19

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                                    2.  WHAT is PART 503?
The Part 503 frequency of monitoring requirements address pollutants, pathogen densities, and certain
vector attraction reduction options.  In cases where a value for a sewage sludge operating parameter has
to be met (e.g., time/temperature requirements for pathogen reduction), the specified value should be met
at all times.

2.7.6   RECORDKEEPING

A Part 503 standard contains a recordkeeping element to ensure that a record is kept that shows whether
the appropriate Part 503 requirements have been met.  The recordkeeping requirements in Part 503
indicate who has to keep a record, what records to keep, and for how long the record has to be kept.

2.7.7   REPORTING

The final element in a Part 503 standard is reporting. The Part 503 reporting requirements indicate who
has to report information to the permitting authority, the information that has to be reported, and  when
that information has to be submitted.

2.8    PROTECTION OF PUBLIC HEALTH AND THE ENVIRONMENT

The Part 503 regulation contains requirements designed to protect public health and the environment  when
sewage sludge is used or disposed.   This section discusses the  elements of a Part 503 standard that
provide this protection.                                                            .

2.8.1   POLLUTANT LIMITS AND MANAGEMENT PRACTICES - LAND APPLICATION  AND
        SURFACE DISPOSAL

The pollutant limits and management practices for  land application and surface disposal are designed to
protect public health and the environment from the reasonably anticipated adverse effects of pollutants
in sewage sludge.  The pollutant limits, which are pollutant concentrations or loads, are based on the
results of exposure risk assessments in which available information was used to determine a limit for
different pathways of exposure. The most stringent limit from the pathways evaluated for each pollutant
is the limit for the pollutant in Part 503.  Thus, the Part 503 limit is protective of all of the pathways
evaluated for a pollutant.

The management practices also protect public health and the environment by establishing requirements
for either a land application site or a surface disposal site.  In many cases, the management practices
establish requirements for situations not addressed in the exposure risk assessment (e.g., causing  harm
to threatened or endangered species). In other cases, they establish site requirements (e.g., do not locate
an active sewage sludge unit in an unstable area)  that address the integrity of land on which  sewage
sludge is applied or placed.                                   i

2.8.2  POLLUTANT LIMITS AND MANAGEMENT PRACTICES - INCINERATION

The Part 503 incineration pollutant limits and management practices are designed to protect public health
from the reasonable anticipated adverse effects of pollutants  in sewage sludge that is incinerated.   The
pollutant limits are based on the results of an exposure risk assessment in which the inhalation pathway
was evaluated. Results of the risk assessment (e.g., a risk specific concentration for each pollutant) are
used in an equation along with certain site-specific data to calculate the allowable concentration of an
                                            2-20

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                                    2. WHAT is PART 503?
 inorganic pollutant in sewage sludge that is incinerated. In the case of lead, an existing air standard is
. used in lieu of a risk specific concentration to calculate the limit for lead.  ,

 The Part 503 incineration management practices contain requirements for the operation of a sewage
 sludge1 incinerator and for instruments used to measure values for certain operational parameters.  The
 management practices  ensure that the incinerator is operated in a similar manner as it was  during the
 performance test to determine the site-specific values used to calculate the pollutant limits.    v

 2.8.3  OPERATIONAL STANDARDS                                         ,

 In cases where risk-based numerical limits and management practices can not be developed, the CWA
 indicates that alternative standards can be developed.  These include a design standard, an equipment
 standard, a management practice, an operational standard, or. a combination thereof, that in the judgment
 of the EPA Administrator protects  public health and the environment from the reasonably  anticipated
 adverse effects of "a pollutant in sewage sludge.

 Part 503 contains operational standards for pathogens, vector attraction reduction, and the concentration
 of total hydrocarbons in the exit gas from a sewage sludge incinerator.  In EPA's judgment, the
 operational standards  for pathogens  and  vector attraction  reduction protect public health  and the
 environment from pathogens and the attraction of vectors to sewage sludge when sewage sludge is land
 applied or placed on  a surface  disposal site.  In the judgment of the EPA Administrator, the total
 hydrocarbons operational standard protects public health from the reasonably anticipated adverse effects
 of organic pollutants1 in the exit gas from a sewage sludge incinerator stack.

 2.9    REQUIREMENTS MORE STRINGENT THAN OR IN ADDITION TO
         PART 503

 2.9.1   PERMITTING AUTHORITY

 The Part 503 requirements are National standards. When writing a permit, the permitting authority can
 impose more stringent or additional requirements as  long as he can show that they are necessary to
 protect public health and the environment from any adverse effect of a pollutant in the sewage sludge.
 The permitting authority can use best professional judgment (BPJ) to develop more stringent conditions
 or to add limits for pollutants that are not regulated by Part 503.  The justification for more stringent or
 additional requirements must be included  in the permit's fact sheet.                          ,

 2.9.2   STATE, POLITICAL  SUBDIVISION, OR INTERSTATE AGENCY

 A State, political subdivision, or interstate agency can, impose more stringent or additional requirements
 without any justification.  However, when a State assumes  authorization of the Federal sewage sludge
 management program, the additional or more stringent requirements would not be considered part of .the
 approved State program and would not  be Federally .enforceable,  unless the State shows the  more
 stringent or additional requirements are needed to protect public health and the environment.
                                              2-21

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                                  2.  WHAT is PART 503?
                                     REFERENCES
U.S. Environmental Protection Agency (EPA). 1984. Policy on Municipal Sludge Management.

U.S. EPA. 1990. National Sewage Sludge Survey; Availability of Information and Data, and Anticipated
Impacts on Proposed Regulations. Proposed Rule. 40 CFR Part 503. 55 FR 47210, November 9, 1990.

U.S. EPA.  1991.  National Pretreatment Program Report to Congress.  21W-4004 Washington, DC:
Office of Water.

U.S. EPA. 1993. Standards for the Use or Disposal of Sewage Sludge.  Final Rule.  40 CFR Part 503.
58 FR 9248, February 19,  1993.
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         3.  PART 503 AND THE PERMITTING PROCESS
                                QUICK REFERENCE INDEX
PERMIT APPLICATION
     REVIEWING THE APPLICATION
     COLLECTING ADDITIONAL INFORMATION

OVERVIEW OF THE PERMITTING PROCESS
     CORE PERMIT CONDITIONS'
r     FACT SHEET
                      Section

                      3.1



                      3.2
 Page

 3-1
 3-2
 3-3

 3-6
' 3-6
 3-7
3.1    PERMIT APPLICATION

An estimated 16,000 POTWs and an additional 3,000 to 5,000 other treatment works treating domestic
sewage are subject 'to the requirements of Part 503. Table 3-1 identifies the types of persons'required
to apply for a sewage sludge permit. Because of the large number of persons anticipated to be permitted,
EPA has developed a phased approach to incorporate the Part 503 requirements into permits.  This
approach is outlined in EPA's February 19, 1993, amendments to the sewage sludge permit program
regulations (58 FR 9404).          .,

               TABLE 3-1 PERSONS REQUIRED TO APPLY FOR A PERMIT
      Persons Required To Apply For a Permit
Persons Not Required To Automatically Apply
              For A Permit
    All generators of a sewage sludge that is
    ultimately regulated by Part 503

    Industrial facilities that separately treat domestic
    sewage and generate a sewage sludge that is
    ultimately regulated by Part 503

    All surface disposal site owners/operators

    All sewage sludge incinerator owner's/operators

    Any person who changes the quality of a sewage
    sludge that is ultimately regulated under Part 503
    (e.g., sewage sludge blenders or composters)
 Industrial facilities that treat a combination of
 industrial wastewater and domestic sewage and
 generate sewage sludge*            ,

 Sewage sludge land appliers/haulers/transporters
 (who do not change the quality of the sewage
 sludge)*             ..      ,

 Sewage sludge packagers/baggers (who do. not
 change the quality of sewage sludge)*

 Owners of property on which sewage sludge is
 land applied*

 Domestic septage haulers/land appliers*
 *EPA maintains the ability to request permit applications from these persons Where necessary to protect public
 health and-the environment                               .                                    .
                               >  • •        •,                                   *-'.'--
 The first phase of permitting is focused on persons required to have or requesting site-specific pollutant
 limits (i.e., incinerators and some surface disposal sites).  These persons had to submit sewage sludge
 application information:within 180 days of publication of Part 503.  For all other TWTDS that already
 have NPDES, permits, the Part 503 requirements, will be incorporated into their  permits as they are
                                              3-1

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                          3.  PART 503 AND THE PERMITTING PROCESS
site-specific limits and that do not have NPDES permits had to submit limited baseline data within 1 year
after Part 503 was published, and then a complete permit application when requested by the permitting
authority.  EPA may develop other permitting priorities and  maintains the ability to require permit
applications from any person sooner than under the phased approach.

Parts  122 and 501 require that the following information be obtained in the' application: general facility
information,  annual sewage  sludge volume, other  permits held  or  requested, a  topographical  map
extending 1 mile beyond the TWTDS boundary, a narrative description of use or disposal practices/any
sewage sludge monitoring data the applicant may have, and any other information requested by the permit
writer.  The permit applicant must identify its chosen use or disposal practices and submit information
to enable the permitting authority to determine compliance with the standards or to verify site-specific
pollutant limits where the applicant requests or is required to have them.
     «»                                   '              . •                                '
EPA has developed an interim application form to be used by all TWTDS. The form lists the information
that is required for the different categories of sewage sludge users or disposers.  It should be used  until
the promulgation of the new municipal application forms 2A and 2S. The interim application form is in
Appendix F and additional copies can be obtained from EPA Regional sludge coordinators. '

All sewage sludge permit applications  must be sent to the EPA Regional office until an applicant's State
sewage sludge management program has been approved by EPA. When renewing an NPDES application
in an NPDES approved State,  the effluent information must go  to the State and  the sewage sludge
information must be sent to the EPA Region.

3.1.1  REVIEWING THE APPLICATION

The better the information received at  the time of application, the easier it is to assemble an appropriate
and accurate permit for a particular use or disposal practice. Therefore, the most important step of the
permitting process is the review of the  application information by the permit writer for completeness and
accuracy.  Experience in NPDES permit writing has shown that considerable correspondence is often
required before an application is considered to be "complete" and "accurate" by the permit writer. Some
offices employ checklists for  the review of application  forms to facilitate  this process.  As the permit
writer gains experience in writing permits, she will be able to better detect omissions and errors in the
application information.

At  a  minimum,  the application  information should address  each ,of the requirements  specified at
§§ 122.21(c) and (d). When an information item is not applicable, "NA" should be used to show that the
item has been considered.  However, if information is missing for an item, the permit writer must contact
the applicant to obtain a written response.  Because an administrative record  must be maintained in
processing a permit application and hearings are possible, only  minor items  should be handled by
telephone, and even these must be documented in writing.  The preferred method is to return the
application to the applicant for completion, or to, request a new application after the applicant has been
advised of the problem items.  If changes or corrections to any application are .extensive, the  applicant
may be required to submit a new application. An application is considered complete when the permitting
authority is satisfied that all required materials have been submitted.

The permit writer also  should  review the application to ensure,  to the best of his ability,  that  it is
accurate.  While it can be difficult to detect many inaccuracies from the application alone, a number of
common mistakes can be readily detected. The permit writer  should follow the same procedures for
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                          3.  PART 503 AND THE PERMITTING PROCESS
correcting inaccurate information as are used for obtaining rnissing information.  The following are
examples of, accuracy reviews the permit writer may conduct for pollutant characterization data.

     • Do the reported values correspond to any existing permit, previous application, or monitoring
       data?                                 ,                            :

     * Do concentration values correspond with analytical detection levels?  Were the correct analytical
       methods used?                                           , .

The permit writer should examine a number of data elements to verify that the data submitted are accurate
and representative of the quality of the sewage sludge.  These include evaluations to ensure ihat:

     • Samples of sewage sludge were collected so as to ensure a representative sample
     • Samples were collected and transported using appropriate procedures                    -
     • All regulated parameters were analyzed             -             •'••',
     • Analytical methods specified in Part 503  Were used
     • Appropriate detection levels were documented
     • Results were reported on a dry weight basis                "  ..                       ,
     V Chain of custody was documented from sample collection through analysis      ,    ,
     • Appropriate QA/QC procedures were followed.                            .

3.1.2  COLLECTING ADDITIONAL INFORMATION

The permit writer may use additional sources of information to develop the draft permit.  For example,
a review of any records existing on the TWTDS can provide information that may be used by the permit
writer.   Performing a site  visit, and reviewing supplemental  information sources can also provide
additional information  and insight into operations at a TWTDS.

Background: information on the TWTDS may be available in the existing NPDES permit file or in other
permit program office  files, such as Resource Conservation and Recovery Act (RCRA) and Clean Air
Act files. Information  that may be available includes any current permits at the Federal, State, and local
levels; the fact sheets for the current permits; any existing pollutant monitoring or discharge monitoring
reports (DMRs); compliance  inspection reports;  correspondence  concerning compliance problems;
information on changes in plant conditions; and communications with other agencies.  Some of this
information may be stored ,in various automated data tracking systems, such as  the NPDES Permit
Compliance System.  The permit writer should use this information where available. The information
found may be  used to  verify  information provided in the  application,  to  gain a more detailed
understanding of the TWTDS's operations, or to determine the compliance status of the TWTDS for other
programs, which may  indicate whether enforceable special conditions in the sewage sludge permit  are
appropriate.

For a permit writer to gain a  thorough understanding of complex TWTDS, an inspection visit can be
-invaluable.   A  site  visit is  important in cases where  significant  pollution  control or treatment
improvements are required or where frequent compliance problems have occurred.  The site visit should
include a review of sewage sludge treatment processes, including  performance of the sewage sludge
treatment units, and operation and maintenance practices.  A  site  visit supports an evaluation of the
adequacy of existing treatment practices and performance data and an assessment of the feasibility of
improvements.  Monitoring points, sampling methods, and analytical techniques should be evaluated to
                                              3-3

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                          3. PART 503 AND THE PERMITTING PROCESS
determine changes to monitoring requirements'and to evaluate the quality of the data. In addition, raw
material and product storage and loading areas, sewage sludge storage and disposal areas, land application
sites, storm water management controls, and all process areas should be observed to determine the need
for controls and for specific best management practices.

Aerial photographs are an excellent aid for conducting a site visit and may provide much of the needed
information on the potential  for contamination of surface runoff.  Aerial photographs are useful in
determining the effects on the surrounding environment. For example, changes in vegetation in areas that
should be uniform may indicate a pollution problem and a change in the  coloration of bodies of water
may indicate the TWTDS's effects on the surface waters.  Aerial photographs may be obtained from a
variety of sources as identified in Table 3-2.                                           :

A great deal of information may be required to be submitted by the permit applicant.  To ensure the
completeness and accuracy of the data received, the permit writer may use a Variety of other sources.
Table 3-2 lists government agencies  and organizations that may be contacted to obtain information
including  topographic maps,  flood rate and boundary  maps, storm water management facility design
requirements,  and  air quality  models that may support permit development efforts and can be used to
verify or supplement the permit applicant's  responses.

As mentioned  above, additional sources of information that may be  useful to the permit writer include
other environmental permits,  such as air or solid waste permits, and other sewage sludge management
permits written for similar TWTDS.  Supplemental data may be requested,  as needed, from various State
agencies or from the applicant.  References  used in developing this guidance document, as listed at the
end of each chapter, are also good sources of information.

Finally, the permit writer may use secondary sources of information to obtain background data on sewage
sludge use or disposal practices and their potential effects on public health and the environment. Use of
these other sources may supplement information received from the applicant. The following is a list of
information sources for sewage sludge.

     •  EPA's National Sewage Sludge Survey—More than 400  PpTWs were surveyed for information
       on sewage sludge use or disposal practices and 200 were  sampled for actual sewage sludge
       quality data. Copies  of the analytical database and questionnaire database of this survey are
       available through the  National Technical Information Service (NTIS) in Springfield,  Virginia.
       Information on ordering these and  other technical support documents  is  in Part XIV of the
       preamble to Part 503  (58 FR 9377).
                                                                             w*
     •  State solid waste management plans, individual solid waste/sludge management plans, and State
       application forms—This information can be obtained through the State  NPDES permit office,
       solid waste program office, or health department.
              s                                                            '
     •  EPA Construction Grant Program information—This includes the NEEDS data base that describes
       all treatment processes  used at  POTWs  and other  basic information  about  their  design  and
       operation.  The NEEDS data base  is administered by the Municipal Support Division of the
       Office of Wastewater  Management at EPA Headquarters.                               '
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            3. PART 503 AND THE PERMITTING PROCESS
TABLE 3-2 LIST OF GOVERNMENT AGENCIES AND ORGANIZATIONS
    THAT MAY.BE CONTACTED FOR CERTAIN INFORMATION
Type of Information
1 . Topographical maps of the area being reviewed
2. Information on types bf habitat, endangered species of
plant, fish, and wildlife in the area being reviewed
3. Flood insurance rate maps (FIRMS) and flood boundary
and flood way maps in the area being reviewed -. • _
4. Information on 100-year flood and information to
; determine the potential of flooding in the area being
reviewed . . -
5. Information on the numerical models to aid in the
prediction of flood' hydrographs, flow parameters, the
effect of obstructions on flow/ levels, the simulation of
flood control structures, and sediment transport
6. • Site-specific storm water management facility design
requirements in the area being reviewed
• Storm water permits. . ' -
7. Location of wetlands in the area being reviewed '
8. Seismic impact zones, fault zones, and seismic hazards in
the area being reviewed
9. Copies of the Computer software package, Geotechnical
Analysis for Review of Dikes Stability, which details the
basic, technical concepts and operational procedures for
the analysis of site hydraulic conditions, dike slope,-
foundation stability, dike settlement, and liquefaction
potential of dike and foundation soils .
10. EPA's approved air quality models
[
11. Aerial photographs of a site to aid in identifying the
potential for surface runoff :
A ,
Source
U.S. Geological Survey (USGS).
Regional U.S. Fish and Wildlife Service (FWS).
U.S. Federal Emergency. Management Agency (FEMA)
Distribution Center, the U.S. Army Corps of Engineers,
USGS, the U.S. Soil Conservation Service, the Bureau of
Land Management, the Tennessee Valley Authority, or State
and local agencies. "
U.S. Water Resources Council, .U.S. Army Corps of
Engineers.
Local U.S. Army Corps of Engineers District Office'.
• Local planning agencies, civil works departments, or local
zoning boards (name and address of such local agencies
can be found in the local directories) . ' -
• NPDES permitting authority.
Local U.S. Army Corps of Engineers District Office and local
planning and zoning commissions or agencies.
USGS, the Building Seismic Safety Council, the Colorado
School of Mines, State Geological Surveys, Earthquake
Information Center, the National Information Service for
Earthquake Engineering, the National Institute of Science and
Technology, the American Institute of Architects.
EPA's Risk.Reduction Engineering Laboratory,
EPA's Office of Air Quality and Standards in Research
Triangle Park, NC. - .

Environmental Services Division (in some EPA Regions), the
National Enforcement Investigation Center, EPA's
Environmental Monitoring and Support Laboratory in Las
Vegas, NV, the Environmental Photo Interpretation
Laboratory in Vint Hill, VA, and private contractors.
                           3-5

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                          3.  PART 503 AND THE PERMTITING PROCESS
     •  Pretreatment program information—This includes information on types and amount of industrial
        loadings to a POTW and past or present sewage sludge quality problems and can be found in the
        POTW's pretreatment program application, annual reports, and environmental audit reports. This
        information can be found in the State or EPA Regional NPDES permitting office.

     •  Basin plans and water quality management plans—These sources may be useful in identifying
        sensitive areas such as wetlands or drinking water aquifers.

     •  Local and State health extension agencies and university agricultural research departments—These
        sources may be useful for consultation on specific characteristics or problems having to do with
        sewage sludge management and potential impacts.                  .

3.2    OVERVIEW OF THE PERMITTING PROCESS

An NPDES permit and the permit issuance process (including  development  of a fact sheet and public
notice requirements), must follow the NPDES permitting regulations in Parts 122 and 124.   Permits
issued by States under Part 501 must contain similar conditions to those in NPDES permits.  This section
reviews appropriate conditions for a sewage sludge permit and highlights fact sheet requirements.

3.2.1   CORE PERMIT CONDITIONS

Generally, each permit issued to a TWTDS should contain:

     •   Specific pollutant limits applicable to sewage sludge quality

     •   General requirements, operational standards,  and management practices

     •   Compliance monitoring requirements      .                           '     •

     •   Reporting and recordkeeping requirements

     •   Standard permit conditions required by Part 122 or Part 501
                                                                               t
     •   Any other conditions related to any aspect of sewage sludge management developed on a case-by-
        case basis where such conditions are necessary to protect public health and the environment.

As indicated above, each NPDES permit must contain the standard conditions  included in every NPDES
effluent permit.  Previously,  EPA modified some of these standard  conditions  to specifically include
sewage sludge activities. For a sewage sludge-only permit, some of the NPDES standard conditions from
§122.41, which focus on discharges to waters of the United States, do not apply (e.g., upset and bypass).
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                          3. PART 503 AND THE PERMITTING PROCESS
3.2.2  FACT SHEET

The permit writer must develop a fact sheet for each Class I sludge management facility and for each
permit that includes a land application plan, in accordance with the requirements in Parts 124 and 501.
When a fact sheet is not required, a statement of basis must be prepared.  A fact sheet must include:

     • Any calculations or other necessary explanation of the derivation of specific standards for sewage
       sludge use or disposal, including a citation to the standard for sewage sludge use or disposal and
       reasons why they are applicable.             .
                   - . **      '          ' .   •                     - '            "            '
     • A brief description of the TWTDS and when appropriate, a sketch or detailed description of the
       location of the regulated activity described in the application.  ,      .   . -s   •

     • For permits that include a sewage sludge land application plan under §501.15(a)(2)(ix), a brief
       description of how each of the required elements of the land application plan are addressed in the
       permit.             '    ,                                                   ,-  '  .,
                                            f    .   '
     • The name and telephone number  of a contact person.

     • A description of the procedures for reaching a final decision on the draft permit.
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        4.   LAND APPLICATION'- PART 503 SUBPART B
                               QUICK REFERENCE INDEX
INTRODUCTION

SPECIAL DEFINITIONS
GENERAL REQUIREMENTS .
    . BULK SEWAGE SLUDGE - PREPARER
    BULK SEWAGE SLUDGE - APPLIER
    - SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR OTHER CONTAINER - PREPARER
    SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR OTHER CONTAINER - APPLIER
Section

4.1

4.2

'4V3
POLLUTANT LIMITS
     CEILING CONCENTRATION LIMITS - ALL LAND APPLIED SEWAGE SLUDGES
     BULK SEWAGE SLUDGE
     SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR OTHER CONTAINER

MANAGEMENT PRACTICES                                    '.   .
     BULK SEWAGE SLUDGE
     SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR OTHER CONTAINER

OPERATIONAL STANDARDS
     PATHOGENS             '     .
  •  , VECTOR ATTRACTION REDUCTION   ,        _.-.•.""

FREQUENCY OF MONITORING REQUIREMENTS   '          '.
     PARAMETERS TO BE MONITORED
     MONITORING FREQUENCY
     MONITORING POINTS
     SAMPLE COLLECTION AND PRESERVATION PROTOCOL
     ANALYTICAL METHODS
     QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)

RECORDKEEPING REQUIREMENTS
     DOCUMENTATION FOR POLLUTANT CONCENTRATIONS
     DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION REDUCTION
     DOCUMENTATION TO SHOW COMPLIANCE WITH MANAGEMENT PRACTICES

REPORTING REQUIREMENTS
                                                                    -4.4
4.5
4.6
14.7
 Page

  4-2

  4-3

  4-7
  4-8
 4-10
 4-14
 4-15

 4-16
 4-17
 4-18
 4-23

 4-26
 4-26
4.8
4.9
                                                                    4.10
SCENARIOS FOR A LAND APPLICATION STANDARD
     SCENARIO 1 - EXCEPTIONAL QUALITY (EQ) SEWAGE SLUDGE
     SCENARIO 2 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF VECTOR ATTRACTION REDUCTION
     SCENARIO 3 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF PATHOGEN REDUCTION
     SCENARIO 4 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF POLLUTANT CONCENTRATIONS
     SCENARIO 5 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF VECTOR ATTRACTION
     REDUCTION AND PATHOGEN REDUCTION          .
     SCENARIO 6 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF VECTOR ATTRACTION
     REDUCTION AND POLLUTANT CONCENTRATIONS                      ,
     SCENARIO 7 - BULK SEWAGE SLUDGE THAT IS NON-EQ FOR PATHOGEN REDUCTION AND
     POLLUTANT CONCENTRATIONS
     SCENARIO 8 - BULK SEWAGE SLUDGE THAT IS NON-EQ FOR VECTOR ATTRACTION REDUCTION,
     PATHOGEN REDUCTION, AND POLLUTANT CONCENTRATIONS
     SCENARIO 9 - SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR OTHER CONTAINER FOR
     APPLICATION TO THE LAND THAT IS NON-EQ BECAUSE OF POLLUTANT CONCENTRATIONS
 4-41
' 4-41
 4-44

 4-44
 4-45
 4-45
 4-48
 4-49
 4-50
 4-50

 4-57,
 4.62
 4-62
 4-62

 4-65

 4-67
 4-69
 4-70
 4-71
 4-72

 4-73

 4-74

 4-75

 4-76

 4-77
                                           4-1

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                          4.  LAND APPLICATION - PART 503 SUBPART B
4.1    MTRODUCTION
This chapter provides guidance on implementation of the requirements for Part 503, Subpart B, which
applies to the land application of sewage sludge.  The permit writer should work with the permittee to
determine which of the land application requirements apply to a particular situation.  Chapter 2 defines
sewage sludge and provides a detailed description of materials that are not regulated under Part 503.

The first step is to determine whether the use or disposal practice qualifies as land application.  For
purposes of Part 503, "land application" is the spreading or spraying of sewage sludge onto the surface
of the land or the injection of sewage sludge beneath the surface of the land to condition the soil or to
fertilize crops grown in the soil.

Sewage sludge may be applied to agricultural land (including pasture and range land), forests, and public
contact sites, such as parks and golf courses. In these situations, the rate at which the sewage sludge is
applied usually is based on the nitrogen requirements of the vegetation or crop grown in the soil.

Sewage sludge also may be applied to disturbed land in an effort to reclaim and  vegetate the land. A
reclamation site is an area that has been disturbed by activities such as strip mining, clear-cutting, severe
erosion, or construction.  The land is so disturbed that it no longer supports vegetation.  Sewage sludge
is applied to restore organic material in the soil and to provide nutrients for vegetation grown in the soil.
In some cases, sewage sludge may be applied to a reclamation site at  a rate  that is,higher than the rate
needed to provide the nitrogen for the vegetation.

Other types of land on which sewage sludge may be applied are lawns and home garden.  Sewage sludge
usually is applied to lawns or home gardens in small  amounts and is  usually sold or given away in a bag
or other container (i.e., receptacle that holds up to one  metric ton of  sewage sludge) for application to
those types of land.                                                ,

The permit writer also should determine whether bulk sewage sludge will be applied to the  land or
whether sewage sludge will be sold or given away in a bag or other container for land application. This
will help the permit writer determine which of the  Part 503 land application requirements  apply to a
particular situation.
           Exception^ Quality' Criteria
Sewage sludge that meets certain requirements is
frequently referred to as "exceptional quality" (see
definition) although this term is not found in Part
503.  If a generator or other preparer is  able to
demonstrate that a sewage sludge  or a material
derived from sewage sludge meets the criteria for
"exceptional quality" sewage sludge, the  sewage
sludge is not subject to the general requirements
and management practices in the land application
subpart.  In addition, whenever an exceptional
quality  sewage sludge  is used to  produce  a
material derived from the sewage sludge,  the
resulting material  is not subject to the Part 503	
requirements.   The preparer  of this  resulting                                .  •
material does not have to independently demonstrate that the material meets the exceptional quality
criteria as long as all of the sewage sludge from which the material was derived meets the exceptional
Sewage  sludge or" material  derived  frQfli sewage
sludge, that achieves the ceiling concentratioiis in
§503, 13(^X1),  the  pollutant  concentrations  in
§503. 13(b)(3X one of the Class A pathogen reduction
alternatives in §5Q3,32(a),  and one of the vector
attraction reduction alternatives in §§503.33(b)(l)
through $>)($) of a vector attraction reduction method
determined by  the permitting  authority to  be
'equivalent,  is referred  to  us  exceptional quality
sewage sludge.
                                               4-2

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                         4.  LAND APPLICATION - PART 503 SUBPART B
quality  criteria.  Exceptional quality  bulk sewage  sludge  is not  subject to the Subpart B general
requirements and management practices unless.the permit .writer can show that these requirements are
necessary to protect public health and the environment.  When the sewage sludge does not  meet the
exceptional  quality criteria, the sewage sludge is  subject Jo the Subpart  B  general requirements and
management practices.                                         '

The treatment works generating the sewage sludge may not always be the person ultimately responsible
for the land application of the sewage sludge. The sewage sludge may be transferred to another person
who changes the quality or land applies the sewage sludge.   When the generator provides the sewage
sludge to another preparer, the permit writer must decide whether the generator or other preparer is
responsible for the different requirements. 'This decision should be based on a thorough understanding
of the type of sewage sludge treatment that occurs  at each TWTDS.  The permit writer may choose.to
put some, requirements in both permits.  Another option is  to issue one permit to both entities as co-
permittees.                                .

Appliers who do not change sewage sludge quality will usually not be required to obtain a permit. When
the applier is  not the preparer,  the permit writer  may want to put the applier's requirements in the
preparer's permit,  to  ensure  compliance  by the applier.   Table 4-1 lists  the  spepific  Subpart B
requirements that apply to a generator, another preparer, and an applier.      .       ;

The remainder of this chapter discusses the Part 503 requirements for land application.of bulk sewage
sludge and for sewage sludge that is sold or given away in a bag or other container for application to the
land.   This  chapter also discusses various scenarios for a land application standard.  The alternative
requirements for each of the seven elements of a Part 503  standard are combined  in the scenarios to
illustrate how those requirements are implemented.                                      ,

4.2    SPECIAL DEFINITIONS

Section 503.9 contains general definitions applicable to more than one subpart in Part 503. In  addition,
§503.11 provides several definitions specifically applicable to land application. This section discusses
some of the definitions in §503.11 and lists the remainder of the definitions in that section and some
selected definitions from §503.9 for reference purposes.

Agronomic Rate
  Statement of Regulation                                                 -'       *

    §503.11 (b)    Agronomic rate is the whole sewage sludge application rate (dry weight basis) designed:  (1) to
                provide the amount of nitrogen needed by the food crop» feed crop, fiber crop, cover crop, or
                vegetation grown on the land and (2) to minimize the amount of nitrogen in the sewage sludge
                that passes below the root zone of the crop w vegetation grown on the land to the ground water.
The important aspect of this definition is that the agronomic rate is a rate that is designed to achieve
certain results at a particular application site.  For this reason, site-specific factors (e.g., soil type) must
be considered when designing .the agronomic rate.                  .                      '

Many pieces of information are used to design, an agronomic rate.  These include, among other things,
the nitrogen concentration in the sewage sludge, estimates of available nitrogen from previous sewage
                                               4-3

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              4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-1  SUBPART B REQUIREMENTS APPLICABLE TO GENERATORS,
                   PREPARERS, OR APPLIERS
Generator or Preparer
General requirements
503.12(6)
503.12(f)
503.12(g)
503.12(i)
Pollutant limits
503.13(b)(l), (b)(3), or (b)(4)
Management practice
503.14(e)
Operational standards
503.15(a) pathogens
503.33(b)(l-8) vector attraction reduction
Monitoring
503.16(a) '
Recordkeeping
503.17(a)(l) exceptional quality sewage sludge
503.17(a){2) exceptional quality sewage sludge
derived material
503.17(a)(3)(i) sewage sludge subject to pollutant
concentration limits, Class A, and
vector attraction reduction in
§503.33(b)(9) or §503.33(b)(10)
503.17(a)(4)(i) sewage sludge subject to pollutant
concentration limits and Class B
503.17(a)(5)(i) sewage sludge subject to
cumulative pollutant loading rates
503.17(a)(6) sewage sludge subject to annual
pollutant loading rates
Reporting
503.18
Applter
General requirements
503.12(a)
503.12(b) '
503.12(e)
503.12(h)
503.12(j) •
Pollutant limits
503.13(b)(2)
•Management practices
503.14(a)
503.14(b)
503.14(c)
503.14(d) '
Operational standards
503.32(b)(5) site restrictions for Class B sewage
sludge
503.33(b)(9) vector attraction reduction
503.33(b)(10) vector attraction reduction
. . '
Recordkeeping
503.17(a)(3)(ii) sewage sludge subject to pollutant
concentration limits, Class 'A, and
vector attraction reduction in
§503.33(b)(9) or §503.33(b)(10)
503.17(a)(4)(ii) sewage sludge subject to pollutant
concentration limits and Class B
503.17(a)(5)(ii) sewage sludge subject to
cumulative loading rates
Reporting ,
503.18
                             4-4

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                         4. LAND APPLICATION - PART 503 SUBPART B
sludge applications and/or legume residues, the realistic yield of the crop or vegetation grown in the soil,
and the nitrogen requirement for the crop or .vegetation.

Annual Pollutant Loading Rate
  Statement of Regulation

    §503,ll(c)
Annual pollutant loading rate is the maximum amount of a pollutant that can be applied to a unit
area of land during a 3(S5 day period.                    	•
An annual pollutant loading rate (APLR) limits the amount of a pollutant that can be applied to the land
in sewage sludge each year.  It does not limit the concentration of a pollutant in the sewage sludge. "To
ensure that none of the annual pollutant loading rates are exceeded, the annual whole sludge application
rate that does not .cause any of those rates to be exceeded must be determined using the procedure in
Appendix A of Part 503.  The APLR only applies to sewage sludge that does  not meet the pollutant
concentrations and is sold or given away in a bag or other container for application to:the land.

Annual Whole Sludge Application Rate
  Statement of Regulation

    §503.11(d)
Annual whole sludge application rate is the maximum amount of sewage sludge {dry weight basis)
that can be applied to a unit area ojfland during a 365 day period,       	'
The annual whole sludge application rate (AWSAR) is the amount of sewage sludge (i.e., tons per acre)
applied to a hectare of the land in a year.  In most cases, the AWSAR for bulk sewage sludge is limited
to the agronomic rate for the application site.  For sewage sludge sold or given away in a bag or other
container, the AWSAR is the rate determined using the procedure in Appendix A of Part 503.

Bulk Sewage Sludge
  Statement of Regulation                               ,       ,

    §503.11
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                          4. LAND APPLICATION - PART 503 SUBPART B
Cumulative Pollutant Loading Rate
  Statement of Regulation
                                                            V         f  J     to

    §503.11(0     Cumulative pollutant loading rate is the maximum amount of an inorganic pollutant that can be
                 applied to ah area of land.                       .
This type of pollutant limit regulates the amount of a pollutant in sewage sludge that can be applied to
a unit area of land rather than the concentration of the pollutant  in the sewage sludge.  This amount is
not an annual  amount, but the cumulative amount that can be applied to the land (i.e., for the life of the
application site). Cumulative pollutant loading rates (CPLRs) only apply to bulk sewage sludge that is
land applied because records  have to be kept of the amount of each pollutant applied to a site in sewage
sludge.  It is impracticable to keep records of the amount of pollutants in sewage sludge sold or given
away in a bag or other container that is applied to the land.  CPLRs do not apply to sewage sludge that
meets the pollutant concentrations.

Land Application
  Statement of Regulation

    §503.11(h)    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
                soil so that the sewage sludge can either condition the soil or fertilize crops or vegetation grown
                in the soil.
Land application refers to the application of sewage sludge to an area of land to take advantage of the soil
conditioning properties or fertilizer value of the sewage sludge. Placement of sewage sludge on the land
for other purposes is considered surface disposal of sewage sludge in Part 503.

Other Container
  Statement of Regulation

    §503.11(j)     Other 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.
The definition of other container limits the amount of sewage sludge that can be sold or given away in
a bag or other container to one metric ton or less.  This definition is used because the assumptions made
to develop some of the Part 503 requirements (e.g., annual pollutant loading rates) only are applicable
to small amounts of sewage sludge applied to certain types of land (e.g., lawns and home gardens).
Usually only sewage sludge that is sold or given away in a bag or other container is applied to those types
of land.   Note that amounts of  sewage sludge less that one metric ton also can be classified as bulk
sewage sludge as discussed above.
                                               4-6

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                           4.  LAND APPLICATION - PART 503 SUBPAKT B
The remaining definitions  from  §503.11 and  selected definitions from §503.9 are shown below  for.
reference purposes.     ~                                   ,    ,
  Statement of Regulation
    §503,ll(a)     Agricultural land is land on which a food crop, a feed crop, or a fiber crop is grown.  This
                  includes range land and land used as pasture.
                       •j    f         '                     *            '         *        -  >     *
    §503.9(a)     'Apply Sewage sludge or sewage sludge applied to land means land application X>f sewage,
                  sludge.                                 ,              '

    §503.9{d).     Cover crop is a small grain crop, such as oats, wheat, or barley, not grown for harvest.

    §503.9(g)      Domestic sewage is waste and wastewater from humans or household operations that is
                  discharged to or otherwise enters a'treatment works.
     !                               •>                              -1              •>              -. '
    §503,9(h)      Pry weight basis means calculated on the basis of having been dried at 105 degrees Celsius
                  until reaching a constant mass (Le., essentially 100 percent solids content).

    §503,9)tj)     ' Feed crops are crops produces primarily for consumption by animals.           >         't

    §503.9(k)      Fiber crops are crops such as flax and cotton,                      ,               •  ,;.
                                                      '             '                  '    •.   •      i
    §503.9(1)      Food crops are crops consumed by humans. This includes, but is not limited-to, fruits,
                  vegetables, and tobacco.        /             ,.                               ••  ,    -

    §503.11(g)     Forest is a tract of land thick with trees and underbrush.

    §503.11©     Monthly average is the arithmetic mean of all measurements taken during the month.
                                \   •fJ *         •>              •*
    §503,1100'    Pasture is land on which animals feed directly OB feed crops such-as legumes, grasses, grain
                  stubble, or stover.

    §503.11(1)     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,                        ,                 '   .                      ,
                       f>                          ~      '          '                    •         •
    §503»ll(m)    Range land is open land with indigenous vegetation.

     §503.11(n)    Reclamation site is drastically disturbed land that is reclaimed using sewage sludge. This
                  includes, but is not limited to, strip'mines and construction sites.

     §503.9(bb)    Wetlands means those areas that are inundated or saturated by Surface wafer Or ground
                  water at a frequency and duration to support, and that under normal circumstances do
                  support,,a prevalence of vegetation (typieally adapted for life hi saturated soil conditions.
                  Wetlands generally include swamps, marshes, hogs, and similar areas.	
 4.3    GENERAL REQUIREMENTS

 The application of sewage sludge to the land may involve several persons." Not all of these persons need
 to receive a. permit, but all of them  must comply with the appropriate Subpart B  requirements.  This
 section discusses the general requirements in the Part 503 land application subpart. They require persons
 preparing and applying sewage  sludge to obtain  information  about  the  Part 503 land  application
                                                    4-7

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                          4.  LAND APPLICATION - PART 503 SUBPART B
requirements, to comply with the requirements, and to provide such information as necessary for other
persons involved in preparing and land applying sewage sludge to comply with the requirements.  The
general requirements that apply to land application of bulk sewage sludge and to sewage sludge sold or
given away in a bag or other container for application to the land are both discussed in this section.
These general requirements do not normally apply to exceptional quality sewage sludge.  However, the
permit writer may  apply any or all of these general requirements to bulk exceptional quality sewage
sludge, if she can show that these requirements are necessary to protect public health and the environment
from any reasonably anticipated adverse effect that may occur from any pollutant in the bulk sewage
sludge.

4.3.1   BULK SEWAGE SLUDGE - PREPARER

Several of the Part 503 general requirements for land application apply to the person who prepares bulk
sewage sludge.  They are discussed below.  Note that the person who prepares bulk sewage sludge is
either the generator of the sewage sludge (e.g., a Federally owned treatment works) or  a person who
derives, a material  from sewage sludge (i.e., changes the  quality of  sewage sludge received from a
generator).

Provide Concentration of Total Nitrogen in Sewage Sludge
  Statement of Regulation

    §503.12(d)    The person who prepares bulk sewage sludge that is applied to agricultural land, forest, a public
                contact site, or a reclamation site shall provide the person Who applies the bulk sewage sludge
                written notification of the concentration of total nitrogen (as N on a dry weight oasis) in the bulk
                sewage sludge.
This general requirement requires that the person who prepares the sewage sludge (i.e., the generator of
the sewage sludge or the person who derives a material from sewage sludge) provide the person who
applies bulk sewage sludge to agricultural land, forest, a public contact site, or a reclamation site written
notification of the total nitrogen concentration in the sewage sludge. The purpose of this requirement is
to provide the land  applier information needed by the applier to design the  agronomic rate for the
application site.

In addition to'the total nitrogen concentration, the preparer should provide the applier the total Kjeldahl
nitrogen, ammonia nitrogen,  and nitrate nitrogen concentrations in the bulk sewage sludge.  With that
information and information about the application site (e.g., soil type and nitrogen in previous application
of bulk sewage sludge), the  applier can design the agronomic rate  for the application site.   This is
discussed further hi the section on land application management practices for bulk sewage sludge.

Note that this general requirement does not apply to sewage sludge that is  sold or given away in a bag
or other container for application to the land.   In this situation, the guaranteed whole percentage of
nitrogen in the sewage sludge is usually printed on a label or information sheet along with an application
rate based on the nitrogen content of the sewage sludge.  This provides the applier with information
needed to ensure that the sewage sludge in not over-applied with  respect to nitrogen.
                                              4-8

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                         4.  LAND APPLICATION - PAkT 503 SUBPART B
Provide Information to the Person Who Applies Bulk Sewage Sludge
  Statement of Regulation
                                                  - r
    §503,12(0    When a person who prepares bulk sewage sludge provides the bulk sewage sludge to a person
                who applies the bulk sewage sludge to the land,, the person who prepares the bulk sewage sludge
              ~"~ shall provide the person who applies the sewage sludge notice and necessary information to
                comply with the requirements in this subpart* "       	'	
Under this general requirement, the person who prepares bulk sewage sludge is required to provide the
person who applies the bulk sewage sludge to the land information needed to comply with the Part 503
requirements. This includes the nitrogen content of the sewage sludge, the concentration of the Part 503
pollutants in the sewage sludge, the class of pathogen reduction, whether vector attraction reduction is
achieved through treatment, and the requirements for whfch the applier is responsible (e.g., management
practices,  vector attraction reduction if  the  sewage sludge is  injected below the  land  surface or
incorporated into the soil, and the Class B site restrictio'ns).   ,                -:' •'. > .
                                                    !"'""'
The preparer also should notify the applier whether a rdcord of the amount of each pollutant applied to
the site in sewage sludge has to be kept because the sewage sludge is subject to the CPLR and whether
the permitting authority in the state where the sewage sludge will be applied has been notified if that state
is other than the state in which the sewage sludge is generated. In addition, the applier should be notified
about the applicable Part 503 general requirements and irecordkeeping requirements.

Provide Information to Another Person Who Prepares Sewage Sludge
  Statement of Regulation                          !

    §5(»<12
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                           4.  LAND APPLICATION - PART 503 SUBPART B
 derived material is applied to the land,  including the requirement for a person who prepares sewage
 sludge in §503.7.

 Interstate Transfer Notification Requirement
  Statement of Regulation
                                                                                          ^ 1 A-v v^
    §503.12(5)     Any person who prepares bulk sewage sludge'that is applied to land in a State other than the
                 State in which the bulk sewage sludge is prepared shall provide written noti^, prior io the initial
                 application of bulk sewage sludge to the land application site by the applier,, to the permitting
                 authority for the State in which the bulk sewage sludge is proposed to be applied. The notice
                 shall include:                                      ,            ,     x       ,  „ ,*,
                                                        %  ,.   ^  f ' y "*•    •>* ^      r*.   < f  5-  IM
            (I)   The location, by either street address or latitude and longitude, of each land" application sitet

            (2)   The approximate time period bulk sewage sludge wifl be applied to the site.
                                            5        ' JJJ J,f, '  •.  , >           , i.'S (.'W'Avt ^
                                                      > * •" ,Uiix j*> ,.        jii'"' *i% [ «* *v
            (3)   The name, address, telephone number, and National Pollutant Discharge'Elimination System
                 permit number (if appropriate) for the person who prepares the bulk sewage sludge.  ^

            (4)   The name, address, telephone number, and National Poliutant Dfecharge Elimination System
   	permit number (if appropriate) for the person who will apply the bulk sewage sludge.
^^v\
The purpose of this general requirement is to alert the permitting authority that bulk sewage sludge that
is generated in one state will be land applied in another state. The permitting authority can then decide
what action to take, if any.

This general  requirement requires the person who prepares the bulk sewage  sludge to notify  the
permitting authority in the state where the sewage sludge will be land applied if that state is different from
the state in which the sewage sludge is generated.  As part of the notification, the preparer must provide
the location of the application site, the approximate time period bulk sewage sludge will be applied to the
site, and the name and address of both the preparer and the applier.

4.3.2   BULK SEWAGE SLUDGE - APPLIER
                                                                                                 i»
In general, the permit writer will not  issue a permit to persons involved in applying sewage sludge if
these persons are not generating or preparing the sewage sludge.  However, the permitting authority may
designate the applier as a TWTDS if a permit is necessary to protect public health and the environment
or to ensure compliance with Part 503. In some situations, such as when sewage sludge comes  from
another State, the permit writer might want to specify the information that the applier must obtain.  The
applier may be required to obtain all sampling data on pollutant concentrations in the sewage sludge and
all data on pathogen and vector attraction reduction requirements from the preparer.  Alternatively,  the
permit writer may require the applier to sample the sewage sludge received from the preparer to obtain
the sewage sludge quality data. The following Part 503 general requirements must be met by the applier
whether or not they are included in a permit.
                                               4-10

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                          4.  LAND APPLICATION - PART 503 SUBPART B
Comply With the Part 503 Land Application Requirements
  Statement of Regulation

    §503,12(a)    No person shall apply sewage sludge to the land except to accordance with the requirements in
                this Snbpart.                                          •'   -     -
The first general requirement for the applier of bulk sewage sludge is that no person shall apply sewage
sludge to the land except in accordance .with the requirements in the land application subpart.   This
general requirement places the responsibility on the land applier to ensure that the requirements related
to the land application site are met when the sewage sludge is actually land applied.  These requirements
include, but are not limited to, management practices, certain vector attraction reduction options, and the
Class B site restrictions.                                                   *

The land applier also should request information from the preparer that indicates that the treatment-related
Part 503 land application requirements  have been  met,  as appropriate.   This  includes  pollutant
concentrations in the. sewage sludge, the class of pathogen reduction, and whether vector attraction
reduction is  achieved through treatment.   The land applier needs this information to determine the
requirements that he has to meet.

The person who applies bulk sewage sludge is also responsible for keeping certain records. These include
the cumulative load of each inorganic pollutant applied to the land in sewage sludge if the CPLRs are
applicable, whether the management practices are met, whether the sewage sludge is either injected below
the land surface or incorporated into the soil for vector attraction reduction (as appropriate), whether the
Class B site restrictions are met (as appropriate), and whether the requirement  in-§ 503.12(e) to obtain
information has been met.

Do Not Exceed  Any  of the Cumulative  Pollutant  Loading  Rates at  a Land
Application Site
  Statement of Regulation                                                        -

    §503.12(h)    No person shall apply sewage sMdge subject to the cumulative pollutant loading rates irt
                §503«13(b)(2) to agricultural land, forest, a public contact site, or a reclamation site if any of the>
                cumulative, pollutant loading rates in §503.13(b)(2) has been reached.
 This general requirement addresses land application of bulk sewage sludge when the CPLRs are met.
 It does not apply if the pollutant concentration limits in Table 3 of § 503.13 are met when sewage sludge
 is land applied.                                                                     .            .
                                                                                         /
 Under this general requirement, no additional amount of bulk sewage sludge subject to the CPLRs can
,be applied to agricultural land, forest, a public contact site, or a reclamation site if any CPLRs have been
 reached at the application site.  Records of the amount of each pollutant applied to a site since July 20,
 1993, have to be kept to ensure that none of the CPLRs have been exceeded.   If the amount of each
 pollutant applied to a site in bulk sewage sludge prior to July 20, 1993, is known,  that amount qan be
 subtracted from the CPLR for a pollutant to determine the additional amount of the pollutant that can be
 applied in sewage sludge. Note that bulk sewage sludge which meets the pollutant concentration limits
                                              4-11

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                           4.  LAND APPLICATION - PART 503 SUBPART B
can be applied to agricultural land, forest, a public contact site, or a reclamation site after a CPLR has
been reached at the application site.

Under this general  requirement,  the land applier must keep a record of the amount of each Part 503
pollutant applied to  an application site in bulk sewage sludge subject to the CPLRs.  Those records must
be kept indefinitely and must be made available to other persons who apply bulk sewage sludge to the
same site. In this case, the records of the  amount of each pollutant  applied to the site are considered
effluent data and cannot be withheld from other appliers.                            .

Obtain Information Needed to Comply
  Statement of Regulation
    §503.12(e)(l)  The person who applies sewage sludge to the land shall obtain information needed to comply with
                 the requirements in this subpart.

    §503.12(e){2)  (5)  Before bulk sewagesludge subject to the cumulative pollutant loading rates in §503.13(b)(2)
                     is applied to the land, the person who proposes to apply the bulk, sewage sludge shall contact
                     the permitting authority for the State in which the bulk sewage sludge will be applied to
                     determine whether bulk sewage sludge subject to the cumulative pollutant loading rates in
                     §503il3
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                          4.  LAND APPLICATION - PART 503 SUBPART B
When the records 6f the amounts of each pollutant applied previously to the land in bulk sewage sludge
can not be found, additional amounts of sewage sludge can not be applied to that site under the CPLR
concept. However, sewage sludge that meets the pollutant concentration limits can be applied to that site,
assuming that all other applicable Part 503 requirements are met.

Provide Notice  to the Owner or Leaseholder  of the Land on Which Bulk Sewage
Sludge Is Applied
  Statement of Regulation   s           ,

    §503.12(h)    The person who applies hulk sewage sludge to the land shall provide the owner or lease holder
                of the land on which the bulk sewage sludge is applied notice and necessary information to
                comply with the requirements in this subpart.	  -	'
This general requirement, requires the person who applies bulk sewage sludge to provide the owner or
leaseholder of the land on which the bulk sewage sludge is applied notice and necessary" information to
comply with the Part 503 land application requirements,  the purpose of this general requirement is to
ensure the transfer of information about the Part 503 requirements to the appropriate persons.

The Part 503 land application requirements that may apply to the owner  or  lease holder of the land
include the site restrictions for a Class B sewage sludge.  These include  a prohibition on harvesting
certain types of crops and grazing animals for certain periods, and restricting  public access for certain
.periods.  This general  requirement  ensures that the owner or  lease holder is notified  about these
restrictions. The land applier knows about the restrictions because the preparer of the sewage sludge
provides the information to the applier.

In addition to the site restrictions for a Class B sewage sludge, the owner or lease holder of the land
should know that sewage sludge  is being applied to the land and that the appropriate Part 503 land'
application requirements have been met.   This information also should be provided by the land applier.

Notify the Permitting Authority When the Cumulative Pollutant Loading Rates Are
Met          ,                              ,    :' '                    ",              •-'.-'•'
  Statement of Regulation           s                                               •    "'

    §S03.12(j)     Any person who applies bulk sewage sludge subject to the cumulative pollutant loading rates hi
                 §503.13(b)(2) to the land shafl provide written notice, prior to the initial application of bulk
                 sewage sludge to a land application site by the applier, to the permitting authority for the State
                 in which the bulk sewage sludge will be applied and the permitting authority Shall retain and
                 provide access to  the notice. The notice shall include:

             (1)  The location, by either street address or latitude and longitude, of the. land application site,

             (2)  >The name, address, telephone number, and,National Pollutant Discharge Elimination System
                 permit number (if appropriate) of the person who will apply the buflc sewage sludge, 	
                                               4-13

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                         4. LAND APPLICATION - PART 503 SUBPART B
This general requirement addresses the situation where more than one person applies bulk sewage sludge
to a site under the CPLR concept.   Without knowing who all the appliers are,  there is no way to
determine when any of the CPLRs are reached at a site.     .

Under this general requirement, the person who applies bulk sewage sludge to the land under the CPLRs
must notify the permitting authority prior to the initial application of the bulk sewage sludge. The applier
provides the permitting authority the location of the application site, the appropriate time bulk sewage
sludge will be applied to the site, and the name and address of the land applier.  Note that the preparer
does not provide the permitting authority the amounts of the Part 503 pollutants applied to the site in bulk
sewage sludge.  This information is kept by the land applier. However, because the .permit writer will
normally issue  a  permit to the preparer but  not to the applier, this notification requirement may be
addressed in the preparer's permit.

This general  requirement applies any time bulk sewage  sludge is applied under  the CPLR concept,
whether the application site is within the state  where the bulk sewage sludge is generated or out-of-state.
Thus, the permitting authority should have a  record of all persons who apply bulk sewage sludge to a
particular site.

The permitting authority provides the names of previous appliers to a new applier when the new applier
notifies  the permitting authority prior to the initial application by the new applier.  The new applier has
to contact the previous appliers to obtain the amount of each of the Part 503 pollutants applied to the site
in bulk  sewage sludge by the previous  appliers.  The new applier  uses that  information  to adjust the
amount  of each pollutant the new applier can apply to the site in bulk sewage sludge  without causing any
of the CPLRs to be exceeded.

This general  requirement is very important to the implementation of the CPLR concept.  As iridicated
above, without knowing the amount of each of the Part 503 pollutants applied previously in bulk sewage
sludge, there is no way to know when any of the CPLRs are reached at a particular site.

4.3.3'   SEWAGE SLUDGE SOLD OR GIVEN  AWAY IN A BAG OR OTHER CONTAINER -
        PREPARER

Only one of the land application general requirements applies to a person who prepares sewage sludge
that is sold or given away in a bag or other container for application to the land.   It addresses the
situation where the preparer of the sewage sludge provides the sewage to another person who prepares
the sewage sludge (i.e., changes the quality of the sewage  sludge).

Provide Sewage Sludge to Another Person Who Prepares the  Sewage Sludge
  Statement of Regulation                               _  .              '  '          ,

    §503.12(g)    When a person who prepares sewage sludge provides the sewage sludge to another person who
                prepares the sewage sludge, the person who provides the sewage sludge shall provide the person
                who receives the sewage sludge notice and necessary information to comply with the requirements
                in this subpart.                       ; -                                "  '" '
In this situation, the person who provides sewage sludge to another preparer must provide the person who
prepares the sewage sludge notice and necessary information about the Part 503 requirements for sewage
                                             4-14

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                         4.  LAND APPLICATION - PART 503 SUBPART B
 sludge that is sold or given away in a bag or other container.  This includes information on the general
 provisions in subpart A of Part 503 (e.g., the provision in §503.7 for a preparer of sewage sludge) and
 the appropriate requirements in the land application subpart 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 original preparer's (i.e., most likely the generator of the sewage sludge) responsibilities under Part
 503 are reduced in this situation.  The original preparer only is required to provide notice and necessary
 information to the other person about the Part 503 land application requirements.  The person who
 prepares the sewage sludge is responsible to ensure the applicable Part 503 land application requirements
, are met.                               '                        , .

 4.3.4  SEWAGE SLUDGE  SOLD OR GIVEN AWAY IN A BAG OR OTHER CONTAINER -
        APPLIER

 When sewage sludge is sold or given away in a bag or other container for application to the land, there
 are two general requirements that the applier has to meet.  They include the requirements to apply the
 sewage sludge in accordance with Part 503  and to obtain information needed to comply with Part 503.
 Because it is unlikely that an applier of this type of sewage sludge would be designated as a TWTDS,
 these conditions would probably be placed in the preparer's permit.

 These general requirements only apply when the APLRs in Table 4 of §503.13 are met. If the pollutant
 concentration limits hi Table 3 of §503.13 are met when sewage sludge is sold or given away in a bag
 or other container, the general requirements do'not apply.                                      ,

 Comply with the Part 503  Land Application Requirements
   Statement of Regulation ,
                 No person shall apply sewage sludge to the land except in accordance with the requirements in
                 this subpart.       s  ,
 This general requirement requires the person who applies the sewage sludge to the land to comply with
 the appropriate Part 503 land application requirements.  In most cases, the applier in this situation is a
 home owner.
                                                                              \         '  '
 The Part 503 requirements that have to be met are the instructions on a label or information sheet, which
 is required when the APLRs are met.  The label or information sheet includes the AWSAR (e.g., pounds
 of sewage sludge per 1,000 square feet) for the sewage sludge and a statement that the AWSAR can not
 be exceeded.  The applier must follow the instructions on the label or information sheet.

 Obtain Information Needed to Comply With Part 503
   Statement of Regulation
                             <•'                    s
     f 503.12{e)(l)  The person who applies sewage sludgetothe land shaaootain information needed to comply with
                 the requirements in this swbpart.      ,	
                                              4-15

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                            4.  LAND APPLICATION - PART 503 SUBPART B
Under this general requirement, the person who applies sewage sludge that is sold or given away in a bag
or other container to the land is required to obtain information to comply with the Part 503 requirements.
This  is  done by reading  the  instructions on the label or information sheet related  to the Part 503
requirements and following those instructions.

4.4    POLLUTANT LIMITS

Subpart B of Part 503 contains pollutant limits for  sewage sludge that is land applied.   These limits,
which include ceiling concentration limits, cumulative pollutant loading  rates, pollutant concentration
limits, and annual pollutant loading rates, are discussed in this section.
  Statement of Regulation.
    §503.13

    §503,13(a)
Pollutant limits

Sewage sludge
    §503.13(a)(l)  Bulk sewage sludge or sewage sludge sold or given away in a bag or other container shall not be
                 applied to the land if the concentration of any pollutant in the sewage sludge exceeds the ceiling
                 concentration for the pollutant in Table 1 of §503.13.

    §503.13(a)(2)  If hulk sewage sludge is applied to agricultural land, forest, and public contact site, or a
                 reclamation site, either?                   "           ,

                 (i)  the cumulative loading rate for each pollutant shall not exceed the cumulative loading rate
                     for the pollutant in Table 2 of §503.13; or

                 (ii) the concentration of each pollutant in the sewage sludge shall not exceed the concentration
                     for the pollutant in Table 3 of §503.13.

    §503.13(a)(3)  If bulk sewage sludge is applied to a lawn or a home garden, the concentration of each pollutant
                 in the sewage sludge shall not exceed the concentration for the pollutant in Table 3 of §503.13,

    §503.13(a)(4)  If sewage sludge is sold or given away in a hag or other container for application to the land,
                 cithers                       -              ~ -  ' -

                 (i)  the concentration of each pollutant in the sewage sludge shall not exceed the concentration
                     for the pollutant in Table 3 of §503.13; or

                 (ii) the product of the concentration of each pollutant in the sewage sludge and the annual whole
                     sludge application rate for the sewage sludge shall not cause the annual pollutant  loading
                     rate  for the pollutant Sn Table 4 of §503.13 to be exceeded.  The  procedure used' to
                     determine the annual whole sludge application rate Is presented in Appendix A of this part.
                                                 4-16

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                         4. LAND APPLICATION - PART 503 SUBPART B
4.4.1   CEILING CONCENTRATION LIMITS - ALL LAND APPLIED SEWAGE SLUDGES
  Statement of Regulations
    §503,13
Pollutant limits
                        TABtE I OF §503,13 - CEILIN& CONCENTRATIONS
                  Pollutant
                                           Ceiling Concentration
                                         (milligrams per kilogram)*
                   Arsenic
                  Cadmium
                   Copper  ,
                1  • -Lead
                  Mercury
                Molybdenum
                 ' Nickel
                .  Selenium
                    Zinc

              *Dry weight basts
                                                   75
                                                   85 ;
                                                 4,300
                                                  840
                                                   5?
                                                   75;
                                                  420
                                                  100
                                                 7,500
The ceiling concentration limits for sewage sludge that is land applied are presented above.  They are
expressed in milligrams of pollutant per kilogram of sewage sludge on a dry weight basis.

All sewage sludge that is land applied, both bulk sewage sludge and sewage sludge sold or given away
in a bag or other container, has to meet the ceiling concentration limits. These limits are instantaneous
values, which means that all samples of sewage sludge analyzed for the Part 503 pollutants have to meet
the limits.

The ceiling concentration limits are the least stringent  of the concentration value calculated using the
CPLRs and assumed values for site life and AWSAR (see discussion below for the pollutant concentration
limits), and the 99th percentile value for the pollutant from EPA's 1988 National Sewage Sludge Survey
(NSSS). ,They prevent sewage sludges with high pollutant concentrations from being land applied.

After the ceiling concentration limits are met, one of two other groups of pollutant limits also have to be
met when sewage sludge is land applied.  These groups of limits are discussed below.
                                             4-17

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                         4.  LAND APPLICATION - PART 503 SUBPART B
4.4.2  BULK SEWAGE SLUDGE

Cumulative Pollutant Loading Rates
Statement of Regulations
§503,13 Pollutant limits
•• „
TABLED OP §503.13
Pollutant
Arsenic
Cadmium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Cumulative Pollutant Loading Rate (kg/ha)
41
39
1,500
300 '
*7
•#
420
100
2,800
*The molybdenum limit was deleted on February 25, 1994 (59 FederaiRegister 9095), EPA plans to propose a
new molybdenum limit in a subsequent amendment to Part 503.
The Part 503 CPLRs are presented above.  They limit the amount of a pollutant that can be applied to
an area of land in bulk sewage sludge.  The CPLRs are expressed in kilograms of pollutant per hectare
of land for the life of the application site.                             "

The CPLRs are based  on the results of an exposure risk assessment during which 14 pathways of
exposure were evaluated. The number of pathways evaluated for a pollutant varied depending on whether
the pathway was appropriate for a pollutant (e.g., the vapor pathway was not evaluated for inorganic
pollutants) and on the availability of information.

The result of a pathway analysis was either a CPLR 'or a pollutant concentration that was converted to
a CPLR.  The most stringent CPLR for all of the pathways evaluated is the CPLR for the pollutant in
Table 2 of §503.13.  Thus, a Part 503 CPLR protects public health and the environment from  the
reasonably anticipated adverse effect of the pollutant for all of the exposure pathways evaluated for a
pollutant.                                                          ,..     .

The other pollutant limits  in subpart B (i.e., ceiling concentration limits, pollutant concentration limits,
and annual pollutant loading rates) were developed using the CPLRs and some conservative'assumptions.
Because the CPLRs were used to develop  the other limits,  EPA concluded that the  other limits also
protect public health and the  environment when sewage sludge is land applied.

When bulk sewage sludge that is applied to  the land is subject to the CPLRs, records have to be kept of
the amount of each pollutant applied to the land in the bulk'sewage sludge.  When any  of the 10 CPLRs
is reached at a land  application site,  an additional amount of bulk sewage sludge subject to the CPLRs
can not be applied to the site. In most cases, not all of the CPLRs will be reached at a site at the same
time.   This provides an additional measure of  protectiveness for the pollutants for which the CPLR is
never reached at an  application site.
                                             4-18

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                         4. LAND APPLICATION - PART 503 SUBPART B
A permit writer can estimate the amount of time that a specific site will be able to receive sewage sludge
without exceeding the CPLRs if the AWSAR remains the same. Figure 4-1 shows the procedure to use
to estimate site life and Figure 4-2 provides an example calculation.              . ,,       .

Pollutant Concentration Limits                                              .
    §503,13 (b){3)  Pollutant concentrations             '       ,
                       TABLES OF §50343 - POLLUTANT CONCENTRATIONS
                        Pollutant
                       ^        >
                           i
                        Arsenic '
                        Cadmium
                        Copper
                        Lead
                        Mercury
                        Molybdenum
                        Nickel
                        Selenium
                       'Zanc
                                       Monthly Average Concentration
                                       (milligrams per kilograml1

                                                  41
                                                  39
                                                1,500
                                                 300
                                              '  -  17 :
                                                  *
                                                 420
                                                  100
                                                " 2,$00
  *Dry weight basis
  *The Molybdenum limit was deleted oh February 2§> 1994 (59 Fedefat Register 9095). EPA plans to propose a new
  molybdenum limit in a subsequent amendment to Part 503,    •                      -        '
The second group of pollutant limits that can be met when bulk sewage 'sludge is land applied is the
pollutant concentration limits  shown above.  They limit the  concentration of a pollutant in the bulk
sewage sludge and are expressed in milligrams  of pollutant per kilogram of sewage sludge on a dry
weight basis.                                                                              .  •

The pollutant  concentration  limits  were  developed using  the  following  approach.   A  pollutant
concentration was calculated using an assumed site of 100 years and an assumed annual whole sludge
application rate of 10 metric tons per hectare in equation (1) below.
                                 CPLR =  C
                                   100
                                 x  10  x  0.001
(1)
where:
    CPLR
      100
        C

        10
    0.001
cumulative pollutant loading rate from Table 2 of §503.13 in kilograms per hectare
assumed site life in years
pollutant concentration in milligrams-pollutant per kilogram-sewage sludge (dry weight
basis)
assumed annual whole sludge application rate in metric tons per hectare per 365-day period
a conversion factor
                                              4-19

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                      4.  LAND APPLICATION - PART 503 SUBPART B
Given: Steps 1  and 2 show the information  to be  obtained from the  applicant for use in
       calculating the site life

Step 1:  The concentration of arsenic, cadmium, copper, lead, mercury,  nickel, selenium, and
         zinc in the sewage sludge.

Step 2:  The whole sludge application rate (SR).

Calculations: Steps 3 through 5 show the procedures, using the information gathered in Steps
             1 and 2, to calculate the number of years sewage sludge could be applied to a site
             if the pollutant concentrations and SR remain the same.

Step 3:  Calculate a yearly pollutant loading rate (PL) for each inorganic pollutant using the
         equation below.                            '                   •  ,
Where:

PL
SR
0.001
         PL = C x 0.001 x SR
= Yearly pollutant loading rate for an inorganic pollutant in kilograms per hectare
   per 365-day period.        .

= Measured pollutant concentration in the sewage sludge in milligrams per kilograms
   of total solids (dry weight  basis).

= Whole sludge application rate in metric tons per hectare per 365-day period (dry
   weight basis).

= Conversion factor.
Step 4:  Calculate the years an inorganic pollutant can be applied to the land by dividing the
         cumulative pollutant loading rate in Table 2 of §503.13 by the PL calculated hi Step 3
         of this procedure.

Step 5:  Determine the lowest number of years calculated in Step 4 of this procedure.  This is the
         period that sewage sludge can be applied to the land assuming no change in sludge
         quality or application rates, without causing any of the cumulative pollutant loading rates
         in Table 2 of §503.13 to be exceeded.
              FIGURE 4-1  PROCEDURES TO CALCULATE SITE LIFE
                                          4-20

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4.  LAND APPLICATION - PART 503 SUBPART B
Given:
'
Stepl:
-. f
Step 2:
Calcula
Step 3:
F
Steps 1 and 2 show the information obtained from the treatment works for use in
calculating site life
The pollutant concentrations in sewage sludge (dry weight basis) follow:
Pollutant
Arsenic
Cadmium
Copper
Lead .
Mercury
Nickel' :
Selenium .
Zinc .
Measured Concentration (mg/hg)
10
7 .
741 , ;
- 134
5 ' •
42
5 .." ,
1,201

Whole sludge application rate is 10 metric tons per hectare per 365-day period.
tions: Steps 3 through 5 show the calculations, using the information gathered in Steps
1 and 2.
Determine the yearly pollutant loading rates (PL) for the pollutants using the equation
provided in Step 3 of Figure 4-1.
Pollutant JVfeasu
Arsenic
Cadmium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
red Concentration (mg/kg)
10
7
741
134
5
42
5
1,201'
PL (kg/ha/yr)
0.10
0.07
7.41
1.34
0.05
0.42
0.05
12.01









'./•'. • • . ' . -. ' ' • '
\ • • •-,-••
IGURE 4-2 EXAMPLE CALCULATIONS FOR DETERMINING SITE LIFE
                  4-21

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                     4. LAND APPLICATION - PART 503 SUBPART B
Step 4:   Calculate the years an inorganic pollutant can be applied to the land by dividing the
         CPLR by PL.              -'...'
Pollutant
Arsenic ,
Cadmium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
CPLR*
(kg/ha)
41
39
1,500
300
17 ,
420
100
2,800
PL**
(kg/ha/yr)
0.10
0.07
7.41
1.34
0.05
0.42
0.05
12.01
Years
(CPLR/PL)
410
, 557
202
224
340
1,000
2,000
233
       *From Table 2 of §503.13
       **From Step 3

Step 5:   Determine the lowest number of years calculated in Step 4.

         For this example, the lowest number of years is 202 for copper. Sewage sludge with
         the inorganic pollutant concentrations given in Step 1 of this procedure can be applied
         to the land each year at a whole sludge application rate of 10 metric tons per hectare
         for a period of 202 years.
     FIGURE 4-2  EXAMPLE CALCULATIONS FOR DETERMINING SITE LIFE
                                    (Continued)
                                        4-22

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                         4.  LAND APPLICATION - PART 503 SUBPART B
Because the pollutant concentration limits were determined using the CPLRs, EPA concluded that those
limits protect public health and the environment from the reasonably anticipated adverse effects of a
pollutant When bulk sewage sludge is land applied. ,                            '

The. pollutant concentration limits are monthly averages.  A monthly average is the arithmetic average
of all measurements taken during the month.  Thus, if two measurements are taken during the  month
(i.e.,  two representative samples are  collected and analyzed during the month), the monthly average
concentration for a pollutant is the sum of the two measurements divided by two.  A monthly average
concentration is not an instantaneous value if more than one measurement is taken during the month (i.e.,
it is the arithmetic average of all measurements taken during the month). Each measurement taken during
the month must meet the ceiling concentration limit for a pollutant whereas the arithmetic average of the
measurements taken during the month must meet the pollutant concentration limit for a pollutant.

When the pollutant concentration limits are met, records of the amount of each pollutant applied to a site
in bulk sewage  sludge do not have to be kept.  Records of the concentration of the pollutant in sewage
sludge do have  to be kept, however.

4.4.3  SEWAGE SLUDGE SOLD OR  GIVEN AWAY IN A BAG OR OTHER CONTAINER

Annual Pollutant Loading Rates
    §S03.J3(b)(4)  Annual pollutant loading rates                       \  -
                   TABLE 4 OF §503.13 - AISIMJAL POLLOTANT LOADING BATES
                       Pollutant

                       Arsenic
                       Cadmium
                       Copper
                       Lead
                       Mercury
                       Molybdenum
                       Nickel
                       Selenium
                       Zinc
    Annual Pollutant Loading Rate
(kilograms per hectare per 365-day period)1

          2.0
          1.0
           75
     •    ' 'IS
          0,85
           *
           n   "'   •
        ~ 5.0
 .     '   s 140
  'Dry weight basis
  *The molybdenum limit was deleted on February 25> 1994 (59 Federal Register 9005).  EPA plans to propose a new
  molybdenum limit in a subsequent amendment to Part 503.
 One group of pollutant limits for sewage sludge sold, or given away in a bag or other container is the
 APLRs shown above.  The APLRs limit the amount of sewage sludge that can be applied to an area of
 land and are expressed in kilograms of pollutant per hectare of land per 365-day period.

 The APLRs were developed using the  CPLRs in Table 2 of §503.13  and an assumed life  for the
 application site. Sewage sludge that is sold or given away in a bag or other container is usually applied
 to a public contact site, a lawn, or a home garden. To calculate the APLRs, EPA assumed a site life of
 20 years for those types of land.  The Agency concluded that a 20-year site life is reasonable for a public
 contact site, a lawn, or a home garden.
                                              4-23

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                          4.  LAND APPLICATION - PART 503 SUBPART B
 The APLRs were calculated by dividing the CPLRs in Table 2 of §503.13 by 20.  Because the CPLRs
 and a reasonable value for site life were used to calculate the APLRs, EPA concluded that the APLRs
 protect public health and the environment from the reasonably anticipated adverse effects of pollutants
 in sewage sludge when the sewage sludge is sold or given away in a bag or other container for application
 to the land.

 The following equation is used to determine the annual whole sludge application rate (AWSAR) for a
 sewage sludge that does not cause any of the APLRs to be exceeded at the application site.  An annual
 whole  sludge application rate is calculated for each pollutant using the measured concentration for the
 pollutant in the sewage sludge and the APLR for the pollutant in Table 4 of §503.13.
                                      AWSAR =
                                    APLR
                                   C x .001
 Where:

  AWSAR  =

    APLR  =
         /"»  —
      .001  =
annual whole sludge application rate in metric tons per hectare per 365-day period (dry
weight basis)
annual pollutant loading rate from §503.13(b)(4) in kilograms per hectare per 365 days
concentration of pollutant in sewage sludge in milligrams per kilogram (dry weight basis)
conversion factor
 The most stringent of the above annual whole sludge application rates is the rate that has to be included
 on a label or information sheet.  The person who land applies the sewage sludge is expected to apply the
 sewage sludge at a rate that is equal to or less than the rate on the label or information sheet.  Figure 4-3
 provides an example calculation.

' If the pollutant concentration increases for any particular pollutant, the permittee must recalculate and
 comply with a new AWSAR. The permittee should notify the permitting authority any time a change in
 pollutant concentrations causes a change in the AWSAR.  To avoid frequent changes in the AWSAR, the
 permittee should use the maximum expected pollutant concentrations when determining the AWSAR.

 Pollutant Concentration Limits

 The second group of pollutant limits that can be met when sewage sludge is sold or given away in a bag
 or other container for application to the land are the pollutant concentration limits in Table 3 of § 503.13/
 These limits are monthly average values and are expressed in milligrams  of pollutant per kilogram of
 sewage sludge on a dry weight basis.                                                       !

 The pollutant concentration limits for sewage sludge sold or given away in a bag or other container for
 application to the land are the same as the pollutant concentration limits for bulk sewage  sludge that is
 land applied.   Thus, sewage  sludge  that meets  the ceiling  concentration limits and  the pollutant
 concentration limits can be applied to the land in bulk or can be sold or given away in a bag or other
 container for application to the land if the other appropriate requirements are met.
                                              4-24

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                            4.  LAND APPLICATION - PART 503 SUBPART B
Given:    Step 1 shows the information to be gathered from the applicant and the annual pollutant loading rates
Step 1: Measure the concentration of arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, and zinc in the sewage
       sludge.      -':.-'..                                 :   .
       Annual pollutant loading rates from Table 4 in §503.13(b)(4) for land application and measured pollutant concentrations in
Pollutant
Arsenic
Gadmium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
Annual Pollutant Loading Rate* (kg/ha)
2:0
1.9
75
, 15
0.85 ' '. -
21
5
140
Concentration** (mg/kg)
10
7
741
134
- 5
42
5
1,201
*From Table 4 of §503.13.
**Measured in the sewage sludge. "
Calculations:   Steps 2 and 3 show the procedures, using the information gathered in Step I, to calculate the annual whole sludge
              application rate(AWSAR) that ensures annual pollutant loading .rates are not exceeded.

Step 2: 'Using the pollutant concentrations from Step 1 and the APLRs from Table 4 of the land application regulations, calculate the
       AWSAR using the equation below..
               AWSAR =
            APLR
           C x 0.001
Where,
AWSAR
APLR
C     ':
0.001
Annual whole sludge application rate in metric tons (mt) per hectare'per 365-day period (dry weight basis).  .
Annual pollutant loading rate in kilograms per hectare per 365-day period.
Measured pollutant concentration in the sewage sludge in milligrams per kilograms of total solids (dry weight basis).
Conversion factor.                                                         	
                            ANNUAL WHOLE SLUDGE APPLICATION RATE (AWSAR)
                            ,  Pollutant
              Arsenic
              Cadmium
              Copper
              Lead
              Mercury
              Nickel.
              Selenium
              Zinc
                                                    (mt/ba/365-aay periofi*
                                                                           200
                                                                           271
                                                                           101
                                                                            112
                                                                            170
                                                                           500
                                                                           1,000
                                                                            117
              *Dry weight basis.

 Step 3: Determine the AWSAR for the sewage sludge by selecting the lowest AWSAR from those calculated in Step 2.

        The lowest Annual Whole Sludge Application Rate for the sewage sludge in this example is 101.  If the sewage sludge is
        applied to land at a rate greater than 101 metric tons per hectare per 365-day period, the APLR for copper will be exceeded.
      FIGURE 4-3 EXAMPLE CALCULATIONS FOR DETERMINING THE AWSAR
                                                      4-25

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                          4. LAND APPLICATION - PART 503 SUBPART B
 4.5    MANAGEMENT PRACTICES

 4.5.1   BULK SEWAGE SLUDGE

 Section 503.14 specifies four management practices for bulk sewage sludge that is applied to the land.
 These management practices provide an  additional measure of protection, not considered in the  risk
 assessment models used to develop the pollutant limits, for endangered species or critical habitat, surface
 water, wetlands, and ground water.  The management practices do not normally apply to exceptional
 quality sewage sludge.  However, the permit writer may apply any or all of the management practices
 to bulk exceptional quality sewage sludge  if he can show that these requirements are necessary to protect
 public health and the environment from any reasonably anticipated adverse effect that may occur from
 any pollutant in the bulk sewage sludge.

 Endangered Species  or Critical Habitat Protection
  Statement of Regulation
    §S03.14(a)    Bulk sewage sludge shall not be applied to the land if it is likely io adversely affect a threatened
                or endangered species listed under Section 4 of the Endangered Species Act or its designated
                critical habitat.                 j         '  '       s,,,     '' ^  '      '
Permitting Factors

Land application sites are often located in rural areas that either contain or are surrounded by a wide
variety of plant, fish, and wildlife species,  some of which may be  endangered or threatened.  The
designated critical habitat is any place where a threatened or  endangered species lives and grows during
any stage in its life cycle.  All threatened or endangered species of plants,  fish, and wildlife are listed
in 50 CFR §17.11 and § 17.12. A copy of the lists with references to the original Federal Register listing
notice can be obtained from the U.S. Department of Interior, Fish and Wildlife Service (FWS).

The permit writer may need to verify if any endangered or threatened  species of plant, fish, or wildlife
exist on or near the application site.  In addition, an application site may be located in the migratory route
of an endangered or threatened species of fish or wildlife and may become a temporary but critical habitat
for such species.  The permit writer can obtain such information or verify the information provided in
the permit application by contacting the field office of the FWS.  To provide the permit writer with the
requested information, the FWS biologist may need specific  data, such as the exact location (preferably
in terms of latitude and longitude),  the size of the site, location and size of any nearby body of water,
and type and extent of vegetative cover.

If threatened or endangered species or their designated critical habitats  are present in the areas proposed
to receive the sewage sludge, the permit writer will need to determine whether  the application of the
sewage sludge to  the land will likely cause an adverse effect upon the species or their habitats.  An
adverse effect would be the destruction or adverse modification of the critical habitat to the extent that
the likelihood of survival and recovery of the species  is diminished.  Unfortunately, it  may  not be
possible to predict the effects of the land application of sewage sludge  on the spebies or habitat without
site specific field studies. In some cases, it may be necessary to prohibit the application of sewage sludge
on sites where threatened or endangered species or their critical habitats are present.  However, it may
                                              4-26

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                          4. LAND APPLICATION - PART 503 SUBPART B
be possible to allow the application of sewage sludge concurrent with field studies designed to measure
the effects of this application on the species and their habitats. Best professional judgment should be used
if specific management practices are necessary to protect the species and their habitat.

Permit Conditions                   '                                                            .

Section 503.14(a) only applies  if endangered species of plant,  fish, or wildlife are identified at an
application site  or if it is determined that the application site is located  in the migratory path of any
endangered or threatened species of wildlife.  However, as  a precautionary measure, the permit writer
may include this management practice in the permit as it appears in Part 503,

If it is determined that the  application site supports or is part of a critical .habitat for a threatened or
endangered species pf plant, fish,  or wildlife, the permit writer should consult with FWS personnel or
other informed State or local agency personnel to determine and  develop  necessary permit conditions,1
For  example,  if the application  site  is located within the migratory path of an endangered species, the
permit writer  could develop a permit condition prohibiting the application of bulk sewage sludge during
the migration period!
                /           -          .                  •'*,'.'"'        "
Other conditions that the permit writer may include are the  following:              '

   ,   •  Buffer zones that provide an adequate distance from  the critical habitat of the endangered species

      •  Requirements for increased frequency of monitoring and reporting in certain areas

      •  Requirements to conduct special studies to determine the impact on the endangered species or its
        critical  habitat.       .

Application of Bulk Sewage Sludge to Flooded Land2
  Statement of Regulation
§503.14(5)
                 Bulk sewage sludge shall not be applied to agricultural land, forest, a public contact site, Or a
                 reclamation site that is flooded, frozen or snow-covered so that the bulk sewage sludge enters a
                 wetland or other waters of the United States, as defined in 40 CJPR 122,2, except as provided in
                 a permit issued pursuant to section' 402 or 404 of the
Permitting Factors

Generally, land is considered flooded when the soil at the surface of the land is saturated with water,
regardless of whether water is visible on the ground.  Such flooding conditions may be produced by
heavy precipitation that occurs locally or at some distance from the site, the rise Of any nearby surface
           and EPA are in the process of developing consultation guidance for such permitting activities.

    2Although §503.14(b) addresses application of sewage sludge to both flooded land and frozen or
 snow-covered land together, this manual discusses sewage sludge application under these two situations
 separately for ease of understanding.                    .           .
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                          4.  LAND APPLICATION - PART 503 SUBPART B
water levels, the rise of the ground-water table to the surface of the land, the melting of snow and ice
on the ground, or irrigation.  Soil that is not well drained or not covered with grass or dense vegetation
can easily become saturated during heavy rainfalls and can remain saturated for an extended period during
rainy seasons.  On the other hand, soil that is well drained and covered with thick vegetation can become
saturated but generally does not remain saturated for more than a few days after a major rain shower.

The permit application (particularly the required topographic map) may provide information enabling the
permit writer to determine if a designated site has potential to flood.  In addition, the permit writer may
wish to identify flood plains by contacting the local offices of the Army Corp of Engineers and the United
States Geological Survey. Typically, these offices maintain data concerning lands that may be flooded
in the event of precipitation.  Particular attention should be paid to sites located adjacent to large water
bodies because these have the greatest potential to flood.

Lands located in flood plains are obviously more likely to become completely or partially flooded and
to remain flooded for an extended period.  River fioodplains are readily identifiable as  the flat areas
adjacent to the river's normal channel. Fioodplains are also identified in the flood insurance rate maps
(FIRMS); flood boundary and floodway maps are published by the U.S. Federal Emergency Management
Agency (FEMA).  Guidance in using FIRMS is provided in How to Read a Flood Insurance Rate Map,
published by FEMA. FEMA also publishes The National Flood Insurance Program Community Status
Book,  which lists  communities in the Emergency or Regular Flood Insurance Programs, including
communities that may not be involved in the National Flood Insurance Program but that have FIRMS or
floodway  maps published.  Maps and other FEMA publications may be obtained from the FEMA
distribution center.                                                              •

Areas riot covered by FIRMS or floodway maps may be included in  flbodplain maps available through
the U.S. Army Corps of Engineers, the U.S. Geological Survey, the U.S. Soil Conservation Service, the
Bureau of Land Management, the Tennessee Valley  Authority, and State and local agencies.  Many of
the river channels  covered by these maps may have  undergone modification for hydropower or flood
control projects, and the floodplain boundaries represented may not  be accurate or representative.  To
identify current river channel modifications  and land use watersheds that could affect floodplain
designation, it may be necessary to compare the floodplain map series to recent aerial photographs.

The rise of the ground-water table to the surface of the ground due to  hydrogeological activities can also
cause flooding of the land.  Such flooding  conditions are most likely to occur in the lands where the
ground-water table is at the ground surface.  Information on the seasonal changes of the water table in
an area can be obtained from the U.S. Geological Survey. If the land regularly experiences upsurges of
ground water and remains saturated for an extended period of time, it may be necessary to identify the
approximate period(s) of the year that such upsurges occur.

Irrigation  is a controlled way of saturating the soil.  The application of bulk sewage sludge to an irrigated
land may  not be a concern when irrigation is occurring during dry weather.  In some cases, however,
land is flooded for an extended period  to  facilitate the crop or vegetation growth (e.g., rice  fields,
artificial reedbeds, or artificial wetlands).

The permit writer should evaluate a land application site for all of the above factors that could cause the
land to become flooded and determine if  there are conditions necessary to address in the permit.
Different permit conditions may'be needed depending on the/location of the land and the extent of time
during which the land generally remains flooded. For example, land located in a flood plain that is often
                                             4-28

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                         4.  LAND APPLICATION - PART 503 SUBPART B
flooded may require more specific permit conditions than land that is well drained and becomes saturated
for only a short period during local or seasonal precipitations.                   -

Permit Conditions          '            .

Where no potential for floods is noted, the permit writer may incorporate the management practice as it
appears in Part 503.  However,  if the permit writer finds that potential  for flooding exists, the permit
writer may address those land application sites with specific management  practices to ensure that sewage
sludge does not enter waters of the United States.  Some possible conditions include:

   .  •  Restricting the application of bulk sewage sludge to floodplains during periods that such land has
        the potential to flood.                                      ,

 .  '  •  Restricting application of bulk sewage sludge during period(s) when the land is saturated.

     •  Prohibiting the application of bulk sewage sludge during period(s) when the land is flooded for
        irrigation.                                                                 •

     •  Require incorporation within a specific time period.          .    :,   .            ;

Application  of Bulk Sewage Sludge to Frozen or Snow-Covered Land
  Statement of Regulation                                         ,         .

    §503,14(1))    Bulk sewage sludge shall not be applied to agricultural land, forest, a public contact site, or a
                reclamation site that is flooded, frozen or snow-covered so that the bulk sewage*sludge enters a
                wetland or other waters of the United States, as defined in 40 CFR 122.2, except as'provided in
                a permit issued pursuant to Section 402 or 404 of the CWA.	            :	
Permitting Factors               '

Many factors must be considered to determine if bulk sewage sludge applied to frozen or snow-covered
land could enter surface waters or wetlands. When bulk sewage sludge is properly applied to land that
is not frozen, it gradually loses its water content by seepage into the ground and evaporation.  However,
it retains most of its nutrients and inorganic pollutants.  During precipitation, moist of dewatered sewage
sludge incorporated into the soil increases the soil's ability to  absorb moisture and, therefore, reduces
runoff (Huddleston and Ronayne 1990).  On the other hand, when sewage sludge is applied to frozen
land, it lies frozen on the surface of the ground with little or no chance for its moisture content to seep
into the ground.  When sewage sludge freezes and thaws repeatedly, it loses most of its water content
in a short period of time during thawing (EPA 1987, JMartel }991).  For this reason and because sewage
sludge will thaw before the frozen ground beneath it, there is a greater chance that the sewage sludge will
be washed off by any significant rainfall into a nearby stream,  rivers lake,  or wetland.
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                          4.  LAND APPLICATION - PART 503 SUBPART B
The application of bulk sewage sludge on snow-covered land has certain consequences. Generally, in flat
areas with little rainfall during the thawing season, the snow melt occurs from bottom to top, leaving any
sewage sludge applied to the surface of the snow intact (assuming that the sewage sludge was applied on
the top of the  last snow cover of the  season).  However, if the melting season is intermixed  with
precipitation, sewage sludge exposed on the surface of the snow can wash away and enter any nearby
surface water or wetland. .

This management practice is not a blanket  prohibition of the application of bulk sewage sludge to frozen
or snow-covered land. Rather, it is intended to restrict such application only if the bulk sewage sludge
could enter surface waters or wetlands.  For obvious reasons, the permit writer should not be concerned
with this management practice  in areas where the ambient air temperature is rarely below freezing or
which seldom receive any significant  snow precipitation.   The permit writer should first determine
whether the conditions for frozen or snow-covered land exist in the area where sewage sludge is applied
(such information is available from the National Oceanic and Atmospheric Administration).  If  such
conditions do exist, the permit writer should then determine whether thawing snow or water runoff might
carry sewage sludge into nearby surface waters and should develop permit  conditions to address this
eventuality.

The permit writer should consider the following four factors when developing permit conditions for a land
application practice that could involve frozen and snow-covered land: (1) the distance to surface waters
or wetlands, (2)  the topography of the land,  (3) the average precipitation in the area of the  land
application site, and (4)  the average length of time that land remains frozen.  First, because runoff is
sometimes  unavoidable,  even over well-drained soils, it is reasonable to assume that the closer a land
application site is to surface waters or wetlands, the greater the chance is for sewage sludge to enter those
water bodies.  As a general rule, more care must be taken to develop or determine the necessary permit
conditions where, the site is close to water bodies than where a site  is one half mile or more from any
surface body of water.  The permit writer will need data on the location of any surface waters or wetlands
on or near the application site.  The permit application and topographic map submitted as part of the
permit application may provide this information. The U.S. Geological Survey quadrangle maps can also
be used to determine the distance from the application site to water bodies.

The second factor that plays an Important  role in determining the potential for runoff to surface waters
is topography.  The slope of the land affects the amount and velocity of runoff. Hilly and steep terrains
(slope of 6  percent or above) produce  more  runoff having the capability to transport larger particles
(including sewage sludge) farther and faster (EPA 1983).  Flat-terrains (slope of less than 6 percent)
generate less runoff and at lower velocity, with little or no capacity  to carry larger particles a  long
distance (EPA 1983). Snow and ice deposited or accumulated on very hilly or steep terrain are not stable
and often move and break apart during rainfall or thawing.  Of special concern is frozen or snow-covered
land that has a fairly steep uninterrupted slope (greater than 6 percent) leading to the edge of a body of
water and that lacks adequate controls to protect the surface water from the avalanching effect of the snow
and ice.

Third, information on average precipitation and general weather patterns is necessary to determine if the
application of sewage sludge to land should be restricted under  certain conditions.  Generally, heavy
snowfalls and freezing conditions followed by torrential rains of short  duration produce large amounts
of runoff that will increase the potential for the sewage sludge to be washed off the land and into nearby
surface waters or wetlands. The information on average precipitation rates and weather patterns needed
to determine the occurrence and duration  (months of the year) of such  conditions is available for  most
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                         4. LAND APPLICATION - PART 503 SUBPART B
major  cities from the  following  three  publications of the National  Oceanic and Atmospheric
Administration:                                                   ,

     •  Climatic Summary of United States                                                       ,

     •  Monthly Sumniary of Climatic Data, which provides basic information on total precipitation,
        maximum and minimum temperatures, and relative humidity for each day of the month and for
        every weather station located in a given area

     •  Local Climatological Data, which provides an annual summary data for a relatively small number
        of major, weather stations.

Analyzing meteorological data is important to determine if there may be conditions that could produce
excessive surface runoff.     /,              ,

Fourth, the average length of time that land remains frozen in a 365-day period depends on the climatic
conditions and weather patterns of the area, If the land remains frozen for most of a given year and only
briefly thaws, the application of bulk sewage sludge becomes highly questionable.  On the other harid,
if the land stays frozen for only few days during a year or briefly freezes at night and thaws during the
day in cold  seasons, there may be little  or no additional risk of sewage sludge entering nearby surface •>
waters or wetlands. ,  •     .

Permit Conditions
                            i                                   .               t
Considering the above factors, the permit  writer should use best professional judgment in determining
the potential for sewage sludge  to enter surface waters or wetlands when applied to frozen or  snow-
covered land. Where the risk is  high, the permit writer should develop permit conditions or require the
permittee to develop and implement specific management practices to minimize this possibility.  If the
permit writer determines that bulk sewage sludge has no potential to enter surface waters or wetlands
from snow-covered or frozen land application areas,.additional management requirements should  not be
necessary.  As a  general rule, there is little or no chance for sewage sludge, to enter surface waters or
wetlands  when the land is flat and located in .a  temperate zone with moderate snow and freezing
conditions and when the application site  is very far from  any  surface  waters  or  wetlands.  As a
precautionary measure, the permit writer  may  want to incorporate  the related management practice
verbatim from the Part 503  rale into the permit.

In locations where the Jand is not very flat:(rolling hills with slopes of 6 to 12 percent), receives moderate
amounts of snow and ice, and is fairly distant from any surface waters or wetlands, the permit writer may
consider allowing the application of sewage sludge under certain conditions while the land is covered,with
snow (EPA 1983). As part of such permit conditions, the permit writer may require that the sewage
sludge be applied only once to an area and at ho time during or immediately  before or after any rain
event or that runoff controls, such as buffer zones or any other measure necessary, be required to prevent
sewage sludge from entering surface waters.              ,          •      -'•'.:..-•

In the areas where land is fairly steep (slope of greater than 12 but less than 15 percent) or where there
is high probability that the sewage sludge applied on top of the frozen or snow-covered land will be
washed off by rain and  into the nearby surface waters or wetlands, the application of sewage  sludge
should generally be allowed only during the time when  the ground is not snow-covered,  frozen, or
                                              4-31

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                          4.  LAND APPLICATION - PART 503 SUBPART B
thawing (saturated) (EPA 1983). Alternatively, the perniit writer may allow limited application of sewage
sludge to such snow-covered ground as long as adequate runoff controls are employed to ensure no
sewage sludge can enter surface waters.

Lands with uninterrupted steep slopes are normally close to either permanent or intermittent bodies of
water. The application of sewage sludge to any land with a slope greater than  15 percent should be
prohibited when covered with snow (EPA 1983). In addition, the application of sewage sludge to land
that remains  frozen for most of the year and only briefly thaws should be prohibited in most  cases.
Finally, if the permit writer determines that additional management practices may be appropriate fof sites
on or near wetlands, he or she may include conditions that limit sewage sludge application to times when
lands are not frozen or snow-covered, prohibit sewage sludge application to sites with  significant
wetlands, create buffer  zones around wetlands, or require diking around wetlands areas.
Distance to Surface Waters
  Statement of Regulation                                           ,      •",*•*      •   ; '   *

    §503.14(c)    Bulb sewage sludge shall not be applied to agricultural land, forest, or a reclamation site that
                is 10 meters or less from waters of the United States^ as defined in 40 CFR 122.2,  unless
                otherwise specified by the permitting authority.
Permitting Factors

While a properly constructed and maintained 10-meter setback provides adequate protection to water
bodies in most cases, under certain conditions a wider buffer zone may be necessary. There are also
situations where a smaller setback provides  adequate  protection but this must be approved by the
permitting  authority.  The major factors in determining the appropriate size of the buffer zone or setback
are:  (1) slope of the land, (2) type of surface water being protected, (3) condition of the ground surface
of the buffer, (4) rate of bulk sewage sludge application, (5) water content of the bulk sewage sludge,
and (6) soil permeability.

Generally,  steeper slopes produce more runoff with faster velocities thereby increasing the potential for
surface water contamination. As a general rule, the 10-meter setback should be adequate  if the slope is
6 percent or  less.  Land with slopes greater than 6 percent but less than 12 percent may  require wider
buffer zones, incorporation or injection of the biosolids, soil conservation methods (e.g., crop residue,
vegetative  cover), and/or other runoff controls.  The application of sewage sludge to lands with  slopes
greater than  12 percent but less than 15 percent may require  much wider buffer zones,  in addition  to
runoff controls. The application of sewage sludge to lands located near surface waters with slopes greater
than 15 percent should be prohibited except where the soil has very good permeability  and the slope
length is short and is only a small part of the entire  application site (EPA 1983, Huddleston and Ronayne
1990).  Sites which do not meet these criteria (e.g., reclamation sites) should be examined on a case-by-
case basis.  In addition, slope restrictions should not be imposed if flow patterns and proximity to surface
water would preclude migration to such waters.

The type of surface water to be protected from sewage sludge contamination is the second major factor
in determining if a wider buffer zone is necessary. For example,  a setback wider than 10 meters may
be necessary to protect a body of water used as a source of drinking water or a trout stream extremely
                                              4-32

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                          4.  LAND APPLICATION - PART 503 SUBPART B
sensitive to particulate matter and pollutants. Agricultural drainage ditches are examples of water bodies
that may not require a full 10 meter setback.                            ,

The condition of the ground surface of the buffer is the third important factor in determining the size of
the buffer zone. A buffer zone that is bare and has very low permeability provides almost no filtering,
while a surface with thick vegetation provides filtration and slows down the runoff.

Liquid sewage sludge is more  likely to be washed into the nearby waters than is dried or dewatered
sewage sludge.  In addition, if large quantities of sewage sludge are applied on slopes greater than 6
percent,  it may be necessary for the permit writer to require injection of liquid sewage sludge into the
soil or incorporation of dried  or dewatered sewage sludge into  the soil as  soon as practicable after
application, in addition to requiring other runoff controls and a setback wider than 10 meters.  However,
if the land is fairly steep (12 to 15 percent slope), the 10-meter setback is generally adequate for small
quantities of liquid sewage sludge or dried or dewatered sewage sludge applied to the land as long as the
sludge is immediately incorporated into the.soil (EPA 1983, Huddleston and Ronayne 1990).

Permit Conditions

If the permit writer finds that adequate management practices are not in place to prevent sewage sludge
from  entering U.S. waters, additional management practices may be appropriate.  Such practices may
include developing buffer zones greater than 10 meters and marking the boundaries of these zones using
flags, fences,  or lines. Where the permit writer determines that bulk sewage sludge has no potential to
enter  waters of the United States, he should incorporate the 10-meter setback with no additional special
conditions stipulated or a lesser setback if the permittee has submitted adequate information to verify, that
the smaller  setback will provide adequate protection.

The permit  writer may need to identify and specify, in the permit, the line from which the buffer zone
distance must be measured.  Generally, the setback should be measured from the top confining bank of
the stream,  river, creek, pond, or lake. If no bank is present it should be measured form the edge of the
water body  or any readily visible high water mark at the time the biosolids are applied.  -

Agronomic Application Rate
  Statement of Regulation                                      '  •                    .     '

    §503<14(d)    Bulk sewage sludge shall be applied to agricultural land, forest, or a public contact site* or a
                reclamation site at a whole sludge application rate that is equal to or less than the agronomic rate
                for the bulk sewage sludge unless,, in the ease of a reclamation site, otherwise specified by the
                permitting authority.                      -      '             '
Sewage sludges typically contain plant nutrients (nitrogen, phosphorus, and potassium),. although the
amount of nutrients available from sewage .sludge are normally lower than the amounts from most
commercial fertilizers (Huddleston and Ronayne 1990, EPA 1976, EPA 1978). Nitrogen and phosphorus
are the most prevalent nutrients found in sewage sludge, and are the nutrients most needed by plants.
                                              4-33

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                         4.  LAND APPLICATION - PART 503 SUBPART B
Nitrate Contamination

Nitrogen exists in the soils and sewage sludge in
three basic forms:

     •  Organic   (C-NH2)—Carbon   based
        compounds such as proteins, amino acids.
        This form is not available to plants and
        must be converted to inorganic nitrogen
        by soil microorganisms.  Mineralization
        is  the  conversion of organic  N  to
        inorganic N in the form of ammonium.
        Mineralization rates  vary for  different
        types of sludge but most of the organic
        nitrogen is mineralized  to inorganic N in
        the first year. All of the organic nitrogen
        is expected to have mineralized by  the
        end of the third year after application.

     •  Inorganic (ammonium NH,,"1", nitrite NO2~,
        nitrate NO3")—Plants use the nitrate and
        ammonium  ions.  The soil microbes and
        plants  compete for this  inorganic  N.
        Rapidly  growing  soil microbes  can
        immobilize  or "tie up" the  ammonium
        and nitrate in the soil by converting it to
        the  organic form, and  may temporarily
        deplete  the available N hi the soil  for
        plant uptake.   The positively charged
              ,    .        _   j   _ _   _    ^        — -s-i- ~i-~~i	k	n	s—i-i	err- f -n	  -       - -           . .  ..
        ammonium  ions are adsorbed by the clay  ^^^^^^^^^^^^MMMMHMHMI^M^H^^^
        and organic matter so  that little of this
        form is leached. Nitrification is the process whereby soil microbes convert ammonium to nitrate.
        Nitrate  is very mobile and readily  leached.   Nitrite  is  usually not present  in significant
        concentrations.

     •  Gas (nitrogen,  N2, ammonia NH3)—Nitrogen gas is present in the soil atmosphere (air) and a
        source of nitrogen for legumes that can convert this to ammonium (NH4+) which is then used by
        the plant.   In anaerobic conditions, microorganisms can convert nitrate to  nitrogen gas and
        nitrous oxide (N2O); this process is called denitrification!  Under alkaline conditions, ammonium
        ions lose a hydrogen ion and become ammonia which readily volatilizes (producing ammonia gas
        NH3).

Plants  can use  only a  portion  of the total nitrogen in the sewage sludge.   Some of the nitrate and
ammonium is lost to the atmosphere by denitrification and volatilization, some of the organic nitrogen
becomes available over time as the mineralization process converts the organic forms to ammonium and
nitrate. Some of the nitrate is  lost through leaching.  The goal is  to supply the necessary amount of
nitrogen needed for the crops or vegetation to produce the desired harvest yield with no leaching of the
, The nitrogen content of  sewage  sludge  is
 usually reported  as inorganic - ammonium-
 nitrogen, inorganic nitrate-nitrogen, and either
 total Kjeldahf nitrogen (TKN) or total nitrogen.
 TKN   represents   the organic  nitrogen  and
 inorganic  ammonium-nitrogen  only.   Total
 nitrogen, on, the other hand, represents organic
, nitrogen and inorganic ammonium-nitrogen as
 vyell^as, nitpte-nitrogen.   Because it  is not
 possible to analytically  test for  total  organic
 nitrogen, an  estimate of the total amount  of
 organic nitrogen  in  the sludge can be made
 based on, the analytical results for TKN or total
 nitrogen.  To determine the organic nitrogen,
 subtract  the ammonium-nitrogen from the
' TKN, or subtract the sum of ammonium plus
 nitrate-nitrogen from the total  nitrogen.  The
 nutrient contents of sewage sludge are normally
 expressed either as percent of dry weight or as
,mg/kg dry weight. Specifically, the, estimates
 may be made as follows:

     Organic N = TKN - ammonium, or

 Organic N — Total N - (ammonium ,-t- nitrate)
                                             4-34

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                         4.  LAND APPLICATION - PART 503 SUBPART B:
nitrogen below the root zone. The rates of mineralization, plant uptake, volatilization and denitrification
are dependent on many factors and will vary from site to site-arid at the same site.

Recognizing that sewage sludge,  if applied at excessive rates, could deteriorate ground water through
nitrate leaching, Part 503 requires that bulk sewage sludge be land applied at a rate that is equal to or
less than the agronomic rate for the application site. The agronomic rate is the whole sludge, application
rate (dry weight basis) designed: (1) to provide the amount of nitrogen needed by the crop or. vegetation
grown on the land and (2) to 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. : EPA  requires that the
agronomic rate not be exceeded when bulk sewage sludge is applied to agricultural  or forest land,  or a
public contact site.  If bulk sewage sludge is applied to a reclamation site, the permit writer may allow
exceedances of the  agronomic rate.                      ,   ;  .   ','.  .

The agronomic rate is the ratio of the sewage sludge nitrogen used for the crop (dry weight per unit area)
divided by the available nitrogen in the sludge (dry weight of nitrogen per dry weight of sludge):

                     .              Sludge N needed for crop
                                      Available N in sludge


Factors Affecting Nitrogen Availability

Predicting how much sewage sludge can be applied to meet crop yield goals and minimize leaching below
the root zone requires consideration of numerous factors.  Some  factors  that  influence the amount of
sewage sludge that can be applied are:                                       '

      • Total, nitrogen content in sewage sludge, and the concentrations (or  percentage  of the  total
    .    nitrogen) of the  various forms in the sewage sludge  are influenced by the  types of processing
        operations.  Anaerobic digestion (30 days or longer) produces sewage sludge with high levels of
        ammonium but little nitrate (oxygen is required to proceed from ammonia to nitrate) and converts
        most  of the readily available  organic nitrogen to  ammonium nitrogen.  Aerobically digested
        sewage sludge has higher levels of nitrate than anaerobically digested sewage  sludge.  Dewatering
        reduces the levels of both nitrate and ammonium nitrogen.       •

      • The mineralization rate is  affected by how well the sewage sludge was stabilized.   Poor
        stabilization results in more organic nitrogen for mineralization.  Good  stabilization converts
  !      organic nitrogen into readily available inorganic N leaving only that which is relatively inert and
        resistant to further mineralization (this sewage sludge may have a low mineralization rate).

      • The mineralization rate is also influenced by soil temperature and moisture.  Temperature affects
        the metabolic rate of microorganisms, thus mineralization rates are typically higher in the summer
        .months than in the winter months.              ,                     '.'",--
                                               4-35

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                           4.  LAND APPLICATION - PART 503 SUBPART B
      •  The amount of ammonium lost through volatilization to  the atmosphere is affected by pH,
         application method, application rate, and soil moisture.

         - Soil/sewage sludge pH—Alkaline sewage sludges have greater volatilization losses than more
          acidic sewage sludges.  The high concentration of hydrogen ions in an acid sewage sludge
          increases the level of ammonium ions in the liquid phase of the sewage sludge and consequently
          diminishes losses of ammonia.

         - Application method—The more thoroughly sewage sludge is mixed with soil after application,
          the lower the volatilization  loss.  Increasing the interaction of the ammonium ion with the
          cation exchange complex of the soil reduces the amount subject to volatilization.  Volatilization
          loss is minimal with subsurface injection of sewage sludge. If sewage sludge is left on the soil
          surface,  volatilization occurs rapidly with the greatest loss occurring within the first week.
          Incorporation of sewage sludge immediately after application can greatly reduce the loss.

         - Application rate—Greater amounts of sewage  sludge applied increase the percentage of
          ammonium ions lost by volatilization, possibly because of the decrease in the number of
          ammonium ions in direct contact with the soil.                                      -

        - Soil moisture—If the soil is  saturated before surface application of liquid sewage sludge, the
          volatilization rate will be greater due to the decrease in the rate of infiltration.  Slowing or
          impeding infiltration increases the  length of time the aqueous ammonium ion solution is
          exposed to drying conditions on the soil surface, thus increasing the volatilization losses from
          surface applied alkaline sewage sludges.

     •  The amount  of nitrate lost to the atmosphere by denitrification is  affected  by factors  that
        contribute to anaerobic conditions and by  the metabolic rate of the denitrifying microorganisms.
        The factors are:

        - Soil moisture—Saturated soils have fewer pore spaces  occupied by  oxygen;  thus  creating
          anaerobic conditions that favor the growth of denitrifying microorganisms.

        - Soil type—The texture of soil,.coarse (sandy) to fine (clay), affects  porosity and capacity to
          store water and oxygen; thus  influencing the prevalence of anaerobic conditions even when soil
          is not  saturated.

        - Carbon  source—An abundant  source of  readily  oxidizable  carbon  will  increase  the
          denitrification rate.

        - Nitrate levels-Denitrification will occur rapidly where nitrate levels provide sufficient source
          of nitrogen for the microorganisms.

Procedures for Determining the Agronomic Rate

The site-specific variability of the above factors means that determining the agronomic rate .should be
done on a  site-specific  basis.  Many State sewage sludge  management programs have developed
procedures based on the knowledge and experience gained in regulating sewage sludge land application.
These procedures account for the local conditions that affect the agronomic rate.  Permit writers who need
                                              4-36

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                          4.  LAND APPLICATION - PART 503 SUBPART B
assistance in reviewing agronomic rate calculations can contact the Cooperative Extension Service, the
Soil Conservation Service, or independent agronomists  specializing in soil evaluation and nutrient
management.  These agencies and individuals can provide information on crop nitrogen needs, soil
nitrogen testing, mineralization rates, and volatilization and denitrification losses. Permit writers should
rely on procedures developed by state sludge management programs to determine agronomic rates, unless
they have reason to believe that those procedures are not accurate.

The worksheet in Figure 4-4 illustrates one approach for calculating the agronomic rate. This worksheet
is provided as an example and  is not intended to replace the procedures currently being  used by
regulatory, authorities or agricultural extension services.  Many of the factors included in this example
are common to most procedures for calculating agronomic rate.  Some of the less common factors are
noted as optional on the worksheet.

At a minimum, all of these procedures consider the nitrogen requirement of the crop, and the nitrogen
content of the sewage sludge.  Most procedures address residual nitrogen eitheV through site-specific soil
nitrogen data^from soil monitoring) or estimates of the amount of residual nitrogen from previous sewage
sludge applications.  If appropriate, nitrogen losses and nitrogen"available from sources other than the
sewage sludge can be factored into the procedures for deriving the whole sewage sludge application rate.

The nitrogen requirements for specific crops also differ by region and are best obtained from either actual
soil test recommendations or from the Cooperative Extension Service's fertilizer recommendations and
guides available from  the County's Cooperative Extension Service Agent, Land Grant University, the
U.S.  Department of Agriculture, or  the  State sewage sludge regulatory agency.  Note that nitrogen
fertilizer recommendations are not typically given for legumes because they fix their  own nitrogen, so
purchasing commercial fertilizer  is not economical.  Therefore, for these crops, nitrogen requirements
should be obtained from crop nitrogen removal information.         ,

Although EPA chose to focus  on nitrate contamination of ground water when establishing the agronomic
rate as a requirement  in Subpart B, the nutrients from sewage sludge can also degrade surface  water
quality. Nutrient overenrichment of surface water bodies is a common problem. EPA's National Water
Quality Inventory showed that nutrients were the leading cause of water quality declines in lakes,
reservoirs, and estuaries and the  second leading pollutant in rivers and streams (EPA 1990).  Nitrogen
and phosphorus pose  serious  threats  to surface water quality.  This is especially'true of phosphorus,
because phosphate ions have low  solubility in most soils, so leaching losses! are rare. Instead, phosphate
availability for leaching decreases exponentially over time through precipitation reactions, adsorption on
mineral surfaces, and retention  by soil constituents.  As a result, most of the off-site transport,.of
phosphorus is associated with sediment erosion and becomes a surface water quality problem.

Appendix H includes information on nutrient planning that can help permit writers understand the many
factors involve in nutrient  management.  While this information is not necessary for writing permits, it
is useful in understanding  all  the factors involved in nutrient planning.
                                               4-37

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                           4.  LAND-APPLICATION - PART 503 SUBPART B
                        Example Design Worksheet 1—for the Agronomic Rate
                                      Key to Symbols and Abbreviations
            NH4 + - N=  Ammonium nitrogen co'ntent of the sewage sludge obtained from analytical
                          testing of the sewage sludge, kg/mt (dry weight basis).
            Kv        =  Volatilization factor estimating ammonium nitrogen remaining after
                          atmospheric losses.
            Org-N     =  Organic nitrogen content of the sewage sludge obtained from analytical
                          testing or determined by subtracting NH4-N from TKN; kg/mt (dry weight
                          basis). •
            NO3-N     =  Nitrate nitrogen content of the sewage sludge obtained from analytical
                          testing, kg/mt (dry weight basis)      "                        •
            FQ.,        =  Mineralization rate for the sewage sludge .during the first year of
                          application, in percent of organic nitrogen expressed as a fraction (e.g.,
                          20% = 0.2).
                                             Helpful Conversions
            mg/kg     =  Ib/ton X  500
            kg/ha      =  Ibs/acre X  1.12
            kg/ha      =  tons/acre X 2242  ~                   •
            mt/ha      =  tons/acre X 2.24
4.

5.

6.

7.

8.

9.
Total available nitrogen from sewage sludge.
a. Ammonium nitrogen.                     >•
   Calculated with the foltmving formula: analytical result for NHS - N (kg/mt) x Kv (Kv obtained
   front Table W-l)
b. Mineralized organic nitrogen for first year of application.
   Calculated with the following formula: Org-N X F^, (?„., obtained from Table W-2)
c. Nitrate nitrogen.                                           ,
'  Use analytical result for NO3-N
d. Total
Available nitrogen in the soil.
(Use whichever is greater aorb)
a. Soil test results of background nitrogen in soil
b. Estimate of available nitrogen from previous sewage sludge applications (From
   Worksheet2)      '                                       '          •     '
Nitrogen supplied from other sources (optional, but recommended):
a. Nitrogen from supplemental fertilizers (if appropriate)
b. Nitrogen from irrigation water (if appropriate)
c. Nitrogen from previous crop (unless #2 is based on soil testing)
d. Other (if appropriate) (specify):  	_^	
e. Total (add a, b, c, d, if available).
Total nitrogen available from existing sources.
Add 2 and 3e

Available nitrogen loss to -denitrification (optional) (check with regulatory authority
btforc using this site-specific factor)
Adjusted nitrogen available
Subtracts from 4

Total nitrogen requirement Of crop (obtain informationfrom agricultural extension
agents or other agronomy professionals)
Supplemental nitrogen needed from sewage sludge.
Subtract 4 or 6 from 7

Agronomic loading rate.
Divide 8 by 1
                                                                                                  kg/mt,

                                                                                                  kg/mt

                                                                                                  kg/mt

                                                                                                  kg/mt
                                                                                                  kg/ha
 kg/ha
 kg/ha
 kg/ha
 kg/ha
 kg/ha
 kg/ha

 kg/ha

 kg/ha

 kg/ha

 kg/ha

• mt/ha
        FIGURE 4-4  WORKSHEETS FOR DETERMINING AGRONOMIC RATE
                                                   4-38

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                          4.  LAND APPLICATION - PART 503 SUBPART B
          Worksheet 2.  Example Calculation for Available Mineralized Organic Nitrogen
The organic nitrogen in sewage sludge continues to decompose and release mineral nitrogen through the
mineralization process for several years following its initial application. This residual nitrogen from the previously
applied sewage sludge must be accounted for as part .of the overall nutrient budget when determining the agronomic.
rate for sewage sludge.  Residual nitrogen can be determined through soil analysis or calculated using  the following
procedure. These calculations must be done for each yearly sewage sludge application unless soil analysis is
performed prior to land application (see example calculations).     .   , '.
      Instructions:  Complete a separate table for each year sewage sludge was land applied. Note that most do not
      calculate beyond the 3rd year because the values  become negligible.  Sum the values of mineralized Org-N
      (Column d) from .each table for the particular calendar year you're trying to determine Org-N available. (See
      example below)
a. Year1
0-1 (year sewage sludge was
applied)
1-2 (1st year after)
2-3 (2nd year after)
b. Starting Org-Nz
(kg/ha)


-
c. Mineralization
Rate* {Exhibit W-2)



tL Mineralized Org-N4

1


e. Org-N
Remaining5 (kg/ha)



'Begin with year sewage sludge is applied and continue for 2 more years.
2In the first year, this equals the amount of Org-N initially applied..  In subsequent years, it represents the amount of  .
org-N remaining from the previous year (i.e., column e).               .
3The org-N content of the initially applied sewage sludge continues to be mineralized, at decreasing rates, for years
after initial application.  See Table W-2 for mineralization values.        .
4Multiply. column b and column c.
Subtract column d from column b.

                                                Example                                ,
Assume anaerobically digested sewage sludge with a 3% org-N content (dry weight basis) was applied to {he site at a
rate of 5 mt/ha in  1986.  The following year, 1987, 3 mt/ha of sewage sludge (same prg-N content a  1986)'was
applied to the same site.  It is now 1988 and you want to calculate the available nitrogen from previous sewage
sludge applications.
    In 1986,. the org-N in the sewage sludge applied = (0^03) (5-mt/ha) (1,000 kg/hit) =  150 kg/ha.
    In 1987, the org-N in the sewage sludge applied = (0.03) (3 mt/ha) (1,0.00 kg/mi) =  90  kg/ha.
Calculate the available nitrogen from 1986.and 1987 in the  following manner (assume anaerobically digested sewage
sludge).
, a. Year*

0-1 (first application-1986)
1-2 (1987)
2-3 (1988)

0-1 (first application-1987)
1-2 (1988)
2-3 (1989)
b. Starting Otg-N
(kg/ha)
c, MiaeralwatiOtt
Rate (Exhibit W-2}
• 1986 Sewage Sludge
ISO
120
108
0.2
0.1
0.05
4. Mineralised Org-N
 Ol-g-N
Remaining (kg/ha)

120
108
102.60 .
1987 Sfewage Stodge
90
72
64.8
0.2
0.1
0.05
18
7.2
3.24
72
64.80
• 61.56
 To determine the total mineralized organic nitrogen available in 1988 from the sewage sludge applied in 1986 and 1987,
 add the mineralized Org-N value in the 1988 row of column d of the table for the 1986 sewage sludge to the mineralized
 Org-N value in the  1988 row of column d of the table for the 1987 sewage sludge (i.e., 5.40.+ 7.2 .= 12.6 kg/ha).
 Total mineralized Org-N available in 1988 from previous sewage sludge 12.6 kg/ha.


  FIGURE 4-4  WORKSHEETS FOR  DETERMINING AGRONOMIC  RATE (Continued)
                                                    4-39

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                           4.  LAND APPLICATION - PART 503 SUBPART B
Table W-l



*
- Example Volatilization Factors (Kv)
If Sewage sludge Is:
Liquid and surface applied
Liquid and injected into the soil
Dewatered and surface
applied
Factor Kv J®
.50
1.0
.50* ,






*Use value obtained from State regulatory agencies if available.
Table W-2 - Example Mineralization Rates*
Time after
sewage
sludge
application
(Year)
0-1
1-2
2-3
Fraction of Org-N
Mineralized from
Unstabilized
Primary and Waste
Activated Sewage
Sludge
.40
.20-
.10
Fraction of Org-N
Mineralized .from _
Aerofefcally
Digested Sewage
Studge
.30 .
.15
.08
feraction of Org-N
Mineralized from F
Anaerobicatty R
Digested Sewage
Sludge '
.20
.10
.05
raction of Org-N
Mineralized from
Composted
Sewage Sludge
.10
.05
.03

*Fraction of Org-N present mineralized during the time interval shown. •
Note: The volatilization factors and mineralization rate were obtained from the Process Design Manual
for the Land Application of Sewage Sludge (EPA, 1983a). Many States have developed different values
for volatilization and mineralization based on local research. Check with the State authority or local
agricultural extension agent for additional guidance. If available, the permit writer should use state or
locally derived values.
FIGURE 4-4 WORKSHEETS FOR DETERMINING AGRONOMIC RATE (Continued)
Permit Conditions

To incorporate the agronomic rate management practice in a permit the permit writer should require the
permittee to determine the agronomic rate for his site at the time the sludge is to be applied and then
calculate the appropriate whole sludge application rate.   The permit writer should also specify how
frequently these calculations should be done (e.g., annually or for each sewage sludge application).

Part 503 only dictates application of sewage sludge at or below the agronomic rate.  If a permit writer
believes nutrient management practices are necessary in certain situations to protect public health or the
environment, she can incorporate other conditions into the permit. Nutrient management planning is the
best way to protect water resources, regardless of land use; it is especially necessary in areas with a high
potential for transport and in environmentally sensitive areas.
                                              4-40

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                         4.  LAND APPLICATION - PART 503 SUBPART B
4.5.2   SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR OTHER CONTAINER

There is only one management practice that is applicable to sewage sludge that is sold or given away in
a bag or other container for application to the land.  It is the requirement for a label or information sheet
to accompany the sewage sludge. As for bulk sewage sludge, the management practice does not apply
to exceptional quality sewage sludge.

Label or Information Sheet Requirements
  Statement of Regulation

    §5
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                          4.  LAND APPLICATION - PART 503 SUBPART B
verify that the permittee is using an appropriate alternative, the permit writer should consider the
following:

     •  Final Use of Sewage Sludge—The permit writer must be certain what type of land is to be used
        by the permittee.                                                                      ~

     •  Sewage Sludge  Treatment Processes—The  permit writer should identify which treatment
        processes the permittee employs.  The permit writer should review any submitted sewage sludge
        quality data and evaluate any information regarding existing or proposed sewage sludge treatment
        processes to verify that the permittee is capable of meeting the pathogen requirements for the land
        application practice proposed.  The permit writer should then identify which specific pathogen
        alternatives are:

        :  Required by Part 503 for the type of land on which sewage sludge is applied
        - Possible given the permittee's sewage sludge treatment processes
Bulk sewage sludge applied to lawns or gardens or sewage sludge that is sold or given away in a bag or
other container must be treated to reduce the risk  of disease transmission to the public using the
substance.  Because it is not feasible to impose site restrictions in these situations, the sewage sludge used
in this manner must meet the Class A pathogen reduction requirements.  Because of the lower potential
for public exposure and the  ability to control public access once the sewage sludge is applied,  bulk
sewage sludge that is applied  to agricultural land, forest, public contact sites, and reclamation sites  does
not have to be treated to  achieve the highest reductions.  In these cases, either Class A or Class B
pathogen reduction requirements must be met. If the  sewage sludge is Class  B,  site restrictions are
imposed to prevent exposure to the sewage sludge.   The different alternatives for achieving pathogen
reduction are discussed in  Chapter 8. Table 4-2 indicates which of the pathogen alternatives in Subpart
D apply to bulk sewage sludge and to sewage sludge sold or given away in a bag or other container.
Table 4-3 lists the alternatives that the preparer must  meet and those that the applier must  meet.

  TABLE 4-2  PATHOGEN AND VECTOR ATTRACTION REDUCTION REQUIREMENTS
      FOR APPLICATION OF SEWAGE SLUDGE TO  DIFFERENT TYPES OF LAND
                 Sewage Sludge
          Regulatory Requirements
 •  Exceptional quality sewage sludge

 •  Material meeting exceptional quality criteria

 •  Bulk sewage sludge or material derived from bulk
    sewage sludge applied to a lawn or a home garden

 •  Sewage sludge sold or given away in a bag or a
    other container
Pathogens—Class A:  one in §503.32(a)
Vectors—one in §§503.33(b)(l) through 503.33(b)(8)
or equivalent as determined by the permitting
authority
   Bulk sewage sludge applied to:

   -  Agricultural land
   -  Forest
   -  Public contact site
   -  Reclamation site
Pathogens—Class A or'Class B:  one in §503.32(a)
or §503.32(b)
Vectors—one in §§503.33(b)(l) through
503.33(b)(10) or equivalent to one in §§503.33(b)(l)'
through 503.33(b)(8)
                                             4-42

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                 4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-3 PATHOGEN AND VECTOR ATTRACTION REDUCTION REQUIREMENTS
                       FOR LAND APPLICATION
PATHOGEN AND VECTOR ATTRACTION REDUCTION
< REQX3JREMENTS FOR PREPARERS OF SEWAGE SLUDGE
Class A Pathogen Reduction
Alternative 1 Time and temperature
Alternative 2 , pH, temperature and time
Alternative 3 One-time demonstration correlating pathogen
levels and operating parameters
Alternative- 4 Concentrations of enteric viruses and helminth
ova ,
Alternative 5 Processes to Further Reduce Pathogens (PFRP)
1. Composting .
2. Heat drying . .
3. Heat treatment "
. . . 4. Thermophilic aerobic digestion
5. Beta ray irradiation
6, Gamma ray irradiation
7. Pasteurization
Alternative 6 Equivalent to PFRP
In addition all six alternatives include pathogen levels for fecal
coliform or Salmonella '
Class B Pathogen Reduction
Alternative 1 Density of fecal coliform
Alternative 2 Processes to Significantly Reduce Pathogens
(PSRP)
1. Aerobic digestion
2. Air drying
3. Anaerobic digestion
4. . Composting
5. Lime stabilization
Vector Attraction Reduction
Option 1 38 percent volatile solids reduction
Option 2 Lab demonstration of volatile solids reduction
anaerobically
Option 3 Lab demonstration of volatile solids reduction
aerobically '
Option 4 SOUR < 1 .5 mg 02/hour/g total solids •
Option 5 Aerobic process for 14 days at > 40°C
Option 6 pH to £ 12 and retain at 11.5
Option 7 a 75 percent solids for stabilized solids
Options a 90 percent solids for unstabilized solids
• • .'' ' \ • ' ' " •
'
- • . ' ' ' ' '
PATHOGEN AND VECTOR ATTRACltON REDUCTION REQUIREMENTS FOR APPLD3RS Of
SEWAGE SLUDGE
'Class B Pathogen Reduction
Alternative 3 Equivalent to PSRP ,
Class B Sludge Site Restrictions ' "
§503.32(b)(5) Site Restrictions
(i) Food crops with harvested parts above ground but touching
after application.
(ii) Food crops with harvested parts below the surface shall not
remains on the surface for 4 months or longer prior to incor
(iii) Food crops with harvested parts below the surface shall not
remains on the surface for less than 4 months prior to incorf
(iv) : Food/feed/fiber crops shall not be harvested for 30 days afte
(v) Animals shall not be grazed on land for 30 days after applic
(vi) Turf grown where sewage sludge is applied shall not be han
on land with a high potential for public exposure or on a lav
(vii) Public access to land with a high potential for public exposu
(viii) Public access to land with a low potential for public exposui
Vector Attraction Reduction
Option 9 Injection below land surface
Option 10 Incorporation into soil
ie sewage sludge/soil mixture shall not be harvested for 14 months
ae harvested for 20 months after application when the sewage sludge
Deration into the soil, j ' -
be harvested for 38 months after application when the sewage sludge
oration into the soil. ,
r application. ~-
ition.
nested for 1 year after application when the harvested turf is placed
/n, unless otherwise specified by the permitting authority.
re shall be restricted for 1 year after application.
e shall be restricted for 30 days after application.
                                4-43

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                         4. LAND APPLICATION - PART 503 SUBPART B
4.6.2   VECTOR ATTRACTION REDUCTION

Part 503 provides for numerous options for vector attraction reduction and a permittee may choose to use
any of the options.  The permit writer should not specify the option that has to be met.  To verify that
the permittee is using an appropriate option, the permit writer should consider the following:

     •  Final Use of Sewage Sludge—The permit writer must be certain what type of land is to be used
        by the permittee.

     •  Sewage  Sludge Treatment  Processes—The permit writer should  identify which  treatment
        processes the permittee employs. The permit writer should review any submitted sewage sludge
        quality data and evaluate any information regarding existing or proposed sewage sludge treatment
        processes to verify that  the permittee is  capable of meeting the vector attraction reduction
        requirements for the land application practice proposed.  The permit writer should then identify
        which specific vector attraction reduction options are:

        - Required by Part 503 for the type of land on which sewage sludge is applied
         Possible given the permittee's sewage sludge treatment processes.
One of the first 10 vector attraction reduction requirements in § 503.33(b) must be met when bulk sewage
sludge is applied to agricultural land, forest, public contact sites, and reclamation sites. It is not feasible
to inject or incorporate bulk sewage sludge applied to lawns or home gardens or sewage sludge that is
sold or given away in a bag or other container.  Therefore, one of the first 8 vector attraction reduction
requirements in §503.33(b) must be met for these sewage sludges.  The different options for achieving
vector attraction reduction are discussed in Chapter 8.  The proposed amendments to Part 503 (60 PR
54771) will allow use of an alternative vector reduction attraction method that the permitting authority
determines is equivalent to one of the first eight methods in §503.33(b). Table 4-2 indicates which of
the vector attraction  reduction requirements in  Subpart D apply to bulk sewage sludge and to sewage
sludge sold or given away in a bag or other container.  Table 4-3 lists the options that the preparer must
meet and those that the applier must meet.

4.7    FREQUENCY OF MONITORING REQUIREMENTS

The permit writer will  often impose the sewage sludge monitoring requirements on the generator and
should require the generator to share the analytical results with appliers or other preparers who may need
sewage  sludge quality information to comply with Part 503  when land applying the sewage sludge,
preparing the sewage sludge for land application, or preparing the sewage sludge for sale or give away
in a bag or  other container.  The permit writer  will frequently encounter circumstances  where a
subsequent preparer must monitor the sewage sludge  quality.  Any time a preparer of sewage  sludge
receives sewage sludge from a generator and then changes the quality of the sewage sludge, the preparer
is required to monitor the quality of the  sewage  sludge.  Sewage sludge monitoring requirements  should
be imposed on a preparer that accepts sewage sludge from multiple generators-and mixes or otherwise
handles the sewage sludge. Sewage sludge that has been treated to reduce pathogens and vector attraction
and then stored for several months  or longer may need to be resampled and reanalyzed for Salmonella
or fecal coliform prior to being applied to the land.
                                             4-44

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                         4. LAND APPLICATION - PART $03 SUBPART B
In developing permit conditions for monitoring sewage sludge applied to the land, the permit writer
should consider including the following:

     • Parameters to be monitored                           .

     • Monitoring frequencies

     • Monitoring locations                                                '
     -               '            t   .                          ..''..'
     • Sampling types and preservation protocol

     • Analytical methods.

In addition, the permit writer may find that including a provision that specifies that QA/QC procedures
must be followed will ensure that the results of the monitoring program are reliable and precise.  The
following subsections briefly highlight each of the above-listed monitoring issues that should be addressed
in the permit.

4.7.1  PARAMETERS TO BE MONITORED

Section 503.16 requires monitoring .of sewage sludge for pollutant concentrations, pathogen densities, and
vector attraction reduction.  Parameters that must be monitored are listed in Table 4-4.   Because the
pollutant concentrations in sewage sludge must be recorded on a dry weight basis, the percent solids
content of the sewage sludge  must be determined each time monitoring  is performed.  The monitoring
requirements for pathogens and vector attraction reduction are discussed in more detail in Chapter 8 of
this manual.  The permit writer will need to select the appropriate monitoring  requirements and establish
permit conditions specific to  the pathogen and vector attraction reduction requirements met by the
permittee.                                                                             •   .

4.7.2  MONITORING FREQUENCY

The frequency of monitoring'is typically established through individual permits, on a case-by-case basis.
However, to enhance the self-implementation of the  regulation, monitoring  frequencies have been
established in Part 503 for pollutants, pathogen density requirements, and the vector attraction reduction
requirements in §§503.33(b)(l)-(4) and (b)(6)-(8). The monitoring frequencies established by §503.16
for land application are shown in Table 4-5.  However, the permit writer has the discretion to require
more frequent monitoring than established by Part 503. "Additionally;  §503.16(a)(2)  gives the permit
writer discretion to reduce the pollutant monitoring frequency if, after 2 years, the variability of pollutant
concentrations  is low  and  compliance is demonstrated so  that a reduction in frequency  appears
appropriate.  If the permittee is using pathogen Class A alternative 3, the permit writer can reduce the
monitoring frequency for enteric viruses and viable helminth ova after 2 years.

For a generator or other preparer who land applies sewage sludge, the monitoring frequency is based on
the amount of sludge land applied in a given 365-day period. If the sewage sludge is sold or given away
in a bag or other container for land application, the monitoring frequency is based on the amount of
sewage sludge received in a given 365-day period by the person who prepares the sewage sludge for sale
or" give away, hot on the amount of sewage sludge actually sold or the amount of sewage sludge product
(e.g., compost) produced.  Whenever possible, the permit writer should specify the 365-day period and
                                              4-45

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                      4. LAND APPLICATION - PART 503 SUBPART B
  TABLE 4-4  PARAMETERS TO MONITOR IN LAND APPLIED SEWAGE SLUDGE
                               Parameters To Be Monitored
     Pollutants*
      Pathogens
Vector Attraction Reduction
     Arsenic
     Cadmium
     Copper
     Lead
     Mercury
     Molybdenum
     Nickel
     Selenium
     Zinc
Fecal coliform or Salmonella
Enteric viruses'"
Helminth ovab
Percent volatile solids reduction0
Specific, oxygen uptake rated
pHc
Percent solidsf
 "Percent solids of sewage sludge must be monitored to report pollutant concentrations on a dry weight
 basis
 bClass A options 3 and 4                       •
 'Vector attraction reduction options 1, 2, and 3
 dVector attraction reduction option 4
 "Vector attraction reduction option 6
 'Vector attraction reduction options 7 and 8.                   .                         	
         TABLE 4-5 FREQUENCY OF MONITORING - LAND APPLICATION
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
Frequency1*
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 or the amount of sewage sludge received by
a person who prepares the sewage sludge that is sold or given away hi a bag or other container for
application to the land (on a dry weight basis).
bAfter the sewage sludge is monitored for 2 years at the above frequency, the permitting authority may
reduce the frequency of monitoring for pollutant concentrations and for the pathogen density
requirements in §§503.32(a)(5)(ii) and (a)(5)(iii).
Source:  §503.16
                                          4-46

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                         4.  LAND APPLICATION - PART 503 SUBPART B
the corresponding monitoring frequency.  The permit writer should also specify that if the amount of
sewage sludge to be land applied during the 365-day period is going to exceed the amount on which the
monitoring frequency was based, then  the permittee  must increase the monitoring frequency to that
required for the amount of sewage sludge to be land applied. For example, if the permittee is expected
to apply between 200 and 750 metric tons per year during the 5-year permit period, the permit writer
could specify two monitoring frequencies.  Alternatively, the permit writer could simply apply the more
frequent of the two monitoring frequencies for the entire 5-year permit period.

The permit writer should consider increasing the  monitoring frequency beyond the frequency required
by §503,16 in cases where the permit writer has noted the following:

     •  Concentrations of pollutants vary significantly between measurements

     • , Concentrations of pollutants are close to the ceiling concentrations

     •  A trend indicating worsening sewage sludge quality

     •  A lack of historical data on sewage sludge quality
           \  . '  '  '      •          •                '•'"'.             -       '
     •  Other criteria that the permit,writer believes substantiate an increased monitoring frequency.

The permit writer also has the discretion to reduce the monitoring frequency after 2 years of monitoring
at the frequency specified in Table 4-5.  In deciding whether to reduce the frequency of monitoring, the
permit writer should consider the following:
                                     - •         '      .      ,  -                        _     |
     •  Variability of the pollutant concentrations—The frequency of monitoring should riot be reduced ,
        where sewage sludge quality varies significantly such that compliance with applicable numeric
        limits may be in question.

     •  Trends in pollutant concentrations—Preparers with data indicating an increase  in .pollutant
        concentrations over the 2-year time period should not be granted a reduction in monitoring.

     «  The magnitude of the pollutant'concentrations—If all sampling data reveal that the concentrations
        ,of pollutants  are significantly below, pollutant limitations, a reduction in monitoring  may be
        appropriate.

The frequency of monitoring in Table 4-5 assumes  that sewage sludge is land  applied continuously
throughout a 365-day period. Often, sewage sludge is stored before it is land applied. This could affect
how frequently samples of the sewage sludge are collected and analyzed.                '

Part 503 requires that samples of sewage sludge that are collected and analyzed be representative of the
sewage sludge that is used or disposed.  Each time  a sample is collected,  no matter how .frequently
samples are collected, it should be a representative sample. Collecting a representative sample of sewage
sludge that is stored before use or disposal may be more difficult than collecting a representative sample
of sewage sludge that is used or disposed continuously.  For example, samples of the sewage sludge at
different locations in a storage pile and at various depths may have to be collected and then composited
to obtain a representative sample of the stored sewage sludge.  When sewage sludge is used qr disposed
continuously, a single grab sample may be appropriate. Whatever the situation, samples of sewage sludge
                                               4-47

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                         4.  LAND APPLICATION - PART 503 SUBPART B
analyzed to show compliance with Part 503 must be representative of the sewage sludge that is used or
disposed.                                                                                .

The frequency of monitoring may vary when sewage sludge is stored before use or disposal depending
on the parameters for which the sewage sludge samples are analyzed.  This is illustrated below for
pollutants.  The frequency of monitoring for  pathogen densities  and vector attraction reduction  is
discussed in chapter 8.

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 land applied.  Also assume that the frequency of
monitoring required by Part 503 is once per month.

Two approaches can be used for the frequency of monitoring for pollutants in this example. In the first
approach, a representative sample of the sewage sludge could be collected and analyzed every month to
show compliance with the Part 503 pollutant limits.  Every sample would have to meet the ceiling
concentration  limits in Table  1 of §503.13.   If the  TWTDS  is attempting to  meet the pollutant
concentration limits, the monthly average pollutant concentrations in the samples collected during a month
would have to meet the pollutant concentration limits in Table 3 of §503.13.

If the TWTDS is attempting to meet cumulative pollutant loading rates in Table 2 of §503.13, the
pollutant concentrations in the  samples analyzed each month would be averaged." That average then
would be used along with the annual whole sludge application rate for the sewage sludge to calculate the
amount of each inorganic pollutant in the sewage sludge that is used or disposed.

In the second  approach, a representative sample of the stored  sewage sludge would be collected and
analyzed just prior to when the  sewage sludge is land applied.  This sample would be representative of
the entire amount of sewage sludge that is stored. It would have to meet the ceiling concentration limits
in Table 1 of §503.13.  It would also have to either meet the monthly average pollutant concentration
limits in Table 3 of §503.13 or the measured pollutant concentrations in the representative sample would
be used to calculate  the amount of each pollutant in the sewage sludge applied to a site, under the CPLR
concept.

The above two approaches may result in a different number of samples that are analyzed. In both cases,
however, 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.

4.7.3  MONITORING POINTS

Representative sampling is one of the most important aspects of monitoring.  To obtain a representative
sample of sewage sludge, the sample must be taken from the correct location and represent the entire
amount of sewage sludge.  In some  situations, the location of the sampling point may have a dramatic
effect on the monitoring results.  It is important that samples be collected from a location representative
of the final sewage sludge that is land applied. Because the pollutant limits pertain to the quality of the
final sewage sludge applied to  the  land, samples must be collected after the last treatment  process.
Samples should be taken at the same point  and in the same manner each time monitoring is performed.
The sampling location should be safe and accessible.         .
                                             4-48

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                         4.  LAND APPLICATION - PART 503 SUBPART B
The permit writer should determine how specific the description of the sampling location should be,
depending on the following considerations:

   '  • The variability of the sewage sludge at different points

     • The ability to obtain a well-mixed sample.                                    ,

For example, if a commercial preparer or applief receives sewage sludge from several different generators
on a batch basis, the ability to mix the sewage sludge to get a sample representative of all the sewage
sludges may be difficult. The permit writer may then want to specify the exact location where the sample
is to be taken to obtain the most representative sample.  If the sewage sludge separates easily between
its liquid and solids fraction, then the permit writer may want to specify where the sample should be
taken to ensure a well-mixed homogeneous sample.            ,                    -

EPA  has developed three guidance manuals and a video that provide more detail  on proper sample
collection for sewage sludge:
                                                                          *            '
     • Control of Pathogens arid Vector Attraction in Sewage Sludge (EPA 1992e)      '

     • POTW Sludge Sampling and Analysis Guidance Document (EPA 1989a)

  .'.'•' Sampling Procedures and Protocols for the National Sewage Sludge Survey (EPA 1989b)

     • Sludge Sampling Video (EPA 1992d).           ,                       .

4.7.4  SAMPLE COLLECTION AND PRESERVATION PROTOCOL

Also important in ensuring representative samples of sewage sludge are the methods for sample collection
and preservation.  The sampling technique varies depending on whether the sewage sludge is flowing
through pipes, moving on a conveyor, or stored in a pile or bin.  Sewage sludge that flows through pipes
or moves on a conveyor should be sampled at equal intervals during the time the unit operates in a day.
When sampling from piles or bins,  core samples  should be taken from at least four points in the pile or
bin.

The permit writer should consider whether it is more appropriate to specify that the  permittee collect a
single grab sample or composite samples.  With sewage sludge, as with wastewater, grab samples  are
instantaneous samples where an amount of sewage sludge is collected all at one time.  Composite samples
are a series of grab samples combined to make a single sample to be analyzed. Composite samples can
be made from a series of grab samples collected from several points in the cross-section of the entire
sewage sludge amount, or they can be a series of grab samples collected at regular time intervals.

In determining whether to specify that a sample be collected using a single grab sample or composite
sampling method, the permit writer may evaluate factors such as:

      • How well the sewage sludge is mixed

      • Whether the sample is collected from a single batch of sewage sludge or from-a stock pile made
       up of several batches

      • Whether the composition of the sewage sludge varies over time.                    ,..-.•'
                                             4-49

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                         4.  LAND APPLICATION - PART 503 SUBPART B
In general, compositing several samples may provide a more representative sample than collecting one
grab sample.  Therefore, in most situations, .composite samples should be required.  Sewage sludge is
most often used or disposed  in a solid form  and may be treated in batch processes.  Sewage sludge
characteristics may also vary over time. For these reasons, the quality may vary from day to day or even
within the sewage sludge volume itself due to the inability to completely mix sewage sludges that have
high solids contents.                                                                            .

Appropriate preservation techniques ensure that a sample remains representative for the period it is held
prior to being analyzed.  For field and laboratory preservation of sewage sludge samples, cooling to 4
degrees Celsius is,  in most cases,  the most appropriate method due to the inability to mix high solid
sewage sludges with other preservatives. The permit writer should consider specifying this preservation
method in the permit because it differs from the more common wastewater practices.

4.7.5  ANALYTICAL METHODS
                                                                       '  .  .•           '
All analyses performed to show compliance with the monitoring requirements must be conducted using
the methods specified in Part 503.  Methods to analyze specific parameters in sewage sludge are specified
in §503.8 and shown in Table 4-6.  The permit writer should identify the method needed for each
analysis in the permit or incorporate the method by referencing the regulatory  citation. In addition to
listing the analytical methods specified by Part 503 for the regulated pollutants and pathogens, Table 4-6
lists suggested analytical methods for the various nitrogen forms and other soil characteristics.  Other
methods developed by States may be more applicable for soils in a specific area.

4.7.6  QUALITY ASSURANCE/QUALITY CONTROL(QA/QC)

A QA program is used to achieve a desired quality for activities, such as sample collection, laboratory
analysis, data validation and reporting, documentation, and recordkeeping.  A QA program will typically
address the following major areas:

     • Proper collection procedures, equipment, preservation methods, and chain-of-custody procedures
       to ensure representative samples

     • Proper sample preparation procedures, instruments, equipment, and methodologies used for the
       analysis of samples

     • Proper procedures and schedules for calibration and maintenance of equipment and instruments
       associated with the collection and analysis of samples

     • Proper recordkeeping to produce accurate and complete records and reports, when required.

QC, which is part of the QA program, relates to the routine use of established  procedures and policies
during sample collection and analysis.  The objective of QC procedures is to ultimately control both the
accuracy and the precision of all analytical-measurements.  QC for sample collection includes the use of
duplicate and spiked samples and sample blanks. QC of analytical procedures includes the use of spiked
and split samples, proper calibration protocols, and appropriate analytical methods and procedures. While
QA/QC is standard practice for most laboratories, the permit writer may determine that specificity in the
permit will ensure more reliable data.  This may be appropriate in cases  where the sewage sludge is
variable or  where  past permit history suggests  that the  permittee's  self-monitoring  program is
questionable.
                                             4-50

-------
4.  LAND APPLICATION - PART 503 SUBPART B











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                        4.  LAND APPLICATION - PART 503 SUBPART B
4.8    RECORDKEEPING REQUIREMENTS

Records must be kept to demonstrate that the Part 503 requirements are being met. Part 503 requires
specific information be kept to-show compliance with pollutant concentrations and loadings, pathogen
reduction requirements, vector attraction reduction requirements, and  management practices.  These
records must be retained for 5 years, except for specific cumulative pollutant loading information which
must be kept indefinitely.  The recordkeeping  requirements for land application of sewage sludge are
shown in Table 4-7.  This table identifies the minimum requirements for which records must be kept,
who must keep the records, and how long they must be retained.  The requirements differ depending on
the pollutant limits that are met.  The generator, other preparer, and land applier may each be required
to keep records.

         TABLE 4-7  MINIMUM REQUIRED RECORDS FOR LAND APPLICATION
  (A) Exceptional  Quality Sewage Sludge  and  Exceptional  Quality Material Derived from
      Sewage  Sludge That Did  JSFot  Meet Exceptional  Quality Criteria  [§ 5Q3JL7(aHl) and
                                                                                          '
  If sewage sludge or a material derived from sewage sludge applied to the land meets the ceiling
  concentrations in §503.13(b)(l), the pollutant concentrations in §503.13(b)(3), the Class A pathogen
  requirements in §503.32(a), and one of the vector attraction requirements in §§ 503.33(b)(l) through
  503.33(b)(8), or an equivalent vector attraction  reduction  requirement as  determined  by .the
  permitting authority; the person who prepares the sewage sludge or the person who derives the
  material that meets those requirements shall develop the following information and shall retain the
  information for a period of 5 years:                                                       ,

  (i)  The concentration of  each pollutant  listed in Table 3 of §503.13 in the sewage sludge or
      derived material.

  (ii) A certification that the information submitted to determine compliance with the pathogen and
      vector attraction reduction requirement is accurate.

  (iii) A description of how the Class A pathogen requirements  in  §503.32(a) are met (refer to
      Chapter 6).

  (iv) A description of how one of the  vector attraction  requirements in §§503.33(b)(l)  through
      503.33(b)(8), or  an equivalent vector attraction reduction requirement as determined by the
      permitting authority, is met (refer to Chapter 6).	   ,	   '
   (B)  Material  Derived  from Sewage  Sludge  That  Meets Exceptional  Quality  C
                   and (gfl                                  . 1..-	'
   None
                                              4-57

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                        4.  LAND APPLICATION - PART 503 SUBPART B
  TABLE 4-7 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
 (C) Bulk Sewage Sludge Meeting Pollutant  Concentrations*  Class A Pathogen Reduction
     Requirements, and Vector Attraction Reduction Alternative 9 or 10 t§503»17{a)(3)|
 If the pollutant concentrations in §503.13(b)(3), the Class A pathogen requirements in §503.32(a),
 and the vector attraction reduction requirements in either §503.33(b)(9) or §503.33(b)(10) are met
 when bulk sewage sludge is  applied to agricultural  land,  forest, a public  contact site, or a
 reclamation site:

 (i)  The person who prepares the bulk sewage sludge shall develop the following information and
     shall retain the information for 5 years.

     (A) The concentration of each pollutant listed in Table 3  of  §503.13 in the  bulk sewage
         sludge.

     (B) A certification that the information submitted to determine compliance with the pathogen
         requirements is accurate.

     (C) A description of how the pathogen requirements in §503.32(a) are met.

 (ii)  The person who applies the bulk sewage sludge shall develop the following information and
     shall retain the information for  5 years.

     (A) A certification that  the  information  submitted to determine  compliance  with the
         management practices and  vector attraction reduction requirements is accurate.

     (B) A description of how the management practices in §503.14 are met for each site on which
         bulk sewage sludge is applied.
                                                                                . \
     (C) A description of how the vector attraction reduction requirements in either §503.33(b)(9)
	or §503.33(b)(10) are met  for each site on which bulk sewage  sludge is applied.
                                           4-58

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                       4.  LAND APPLICATION - PART 503 SUBPART B
 TABLE 4-7  MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
(D) Bulk Sewage Sludge Meeting Pollutant Concentrations and Class B Pathogen Reduction.
    Requirements [§503,17
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                        4. LAND APPLICATION - PART 503 SUBPART B
  TABLE 4-7 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
(E)  Bulk Sewage Sludge Subject to Cumulative Pollutant Loading Rates [§503¥17(a)(5)]
If the requirements in §503.13(a)(2)(i) are met when bulk sewage sludge is applied to agricultural
land, forest, a public contact site, or a reclamation site:

(i)   The person who prepares the bulk sewage sludge shall develop the following information and
     shall retain the information for 5 years.

     (A)  The concentration of each pollutant listed  in Table  1  of §503.13  in the bulk sewage
         sludge.

     (B)  A certification that the information submitted to determine compliance with the pathogen
         requirements and the vector attraction reduction requirements (if applicable) is accurate.

     (C)  A description of how the pathogen requirements  in either §503.32(a) or §503.32(b) are
         met.

     (D)  When one of the vector attraction requirements  in §§503.33(b)(l) through 503.33(b)(8), or
         an equivalent vector attraction  reduction requirement as determined by the permitting
         authority is met, a description of how the vector attraction requirement is met.

(ii)  The  person who applies the bulk sewage sludge shall develop the following information,  retain
     the information in §§503.17(a)(5)(ii)(A) through 503.17(a)(5)(ii)(G) indefinitely, and retain the
     information in §§503.17(a)(5)(ii)(H) through 503.17(a)(5)(ii)(M) for 5 years.

     (A)  The location, by either street  address or latitude and longitude, of each site on which bulk
         sewage sludge is applied.         .

     (B)  The number of hectares in each site on which bulk sewage sludge is applied.

     (C)  The date bulk sewage sludge is applied to each  site.

     (D)  The cumulative amount of each pollutant (i.e.,  kilograms) listed in Table 2 of §503.13 in
         the bulk sewage sludge applied to each site, including the amount in §503.12(e)(2)(iii).

    (E)  The amount of sewage sludge (i.e., metric tons) applied to each site.

    (F)  A  certification  that  the information  submitted  to determine  compliance  with  the
         requirement to obtain information is accurate.
                                           4-60

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                       4. LAND APPLICATION - PART 503 SUBPART B
 TABLE 4-7  MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
(E) Bulk Sewage Sludge Subject to Cumulative Polluiant Loading Rates (Continued)
    (G) A description of how the requirements to obtain information in §503.12(e)(2) are met.

    (H) A  certification that the  information  submitted to  determine compliance  with  the
        management requirements is accurate.

    (I)  A description of how the management practices in §503.14 are met for each site on which
        bulk sewage sludge is applied.

    (J)  If the bulk sewage sludge meets the  Class B pathogen requirements in §503.32(b), a
        certification that  the  information submitted to  determine compliance  with the  site
        restrictions is accurate.                                     ,        „

    (K) A description of how the site restrictions in §503.32(b)(5) are met for each site on which
        Class B bulk sewage sludge is applied.

    (L) If the vector attraction reduction requirements in either §§503.33(b)(9) or 503.33(b)(10)
         are met, a certification statement that the information submitted to determine compliance
        with the vector attraction reduction requirements is accurate.

    (M) If the vector attraction reduction requirements in either §§503.33(b)(9) or 503.33(b)(10)
         are met, a description of how the requirements are met.    	   •	
 (P)  Sewage Sludge Sold or Given Away in a Bag or  Other Container Subject to Annual
     Pollutant Loading Rates E§ 503.17(a)(6>]                             	-	-	
 If the requirements in §503.13(a)(4)(ii) are met when sewage sludge is sold or given away in a bag
 or other container for application to the land, the person who prepares the sewage sludge for sale or
 give away in a bag or other container shall develop the following information and shall retain the
 information for 5 years:

 (i)  The annual whole sewage sludge application rate for the sewage sludge that does not cause the
     annual pollutant loading rates in Table 4 of §503.13 to be exceeded.      ,

 (ii)  The concentration of each pollutant listed in Table 4 of § 503.13 in the sewage sludge.

 (iii) A certification that the information submitted to determine compliance with the pathogen  and
     vector attraction reduction requirements is accurate.

 (iv) A description of how the Class A pathogen requirements in §503.32(a) are met.        ,

 (v)  A description of how one of the vector  attraction requirements in  §§503.33(b)(l)  through
     503.33(b)(8), or an  equivalent vector attraction  reduction requirement  as  determined by the
     permitting authority is met.	   ,         	•  '   •   •
                                             4-61

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                         4. LAND APPLICATION - PART 503 SUBPART B
 The permit writer is obligated .to include the minimum appropriate recordkeeping conditions in each
 permit.  Additionally, the permit writer may specify that other records be obtained or developed and
 maintained by the permittee to determine compliance with permit conditions. The following technical
 guidance provides examples of specific records the permit writer may want to specify that the permittee
 retain.                 .                                          '

 4.8.1   DOCUMENTATION FOR POLLUTANT CONCENTRATIONS

 At a minimum, the person who prepares the sewage sludge for application to the land must keep sampling
 and analysis results.  This documentation should include:

     •  Sampling records, including the date and time of sample collection, sample location, sample type,
        sample volume, name of person collecting the sample, type of sample container, method of field
        preservation, and sampling QC.

     •  Analytical records, including date and tune of analysis, name of analyst, analytical methods,
        laboratory bench sheets with raw data and calculations used to determine results, analytical QC,
        and analytical results.

 4.8.2   DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION REDUCTION

 Records must be maintained of certifications made by the preparer and the land applier that the pathogen
 reduction requirements and vector .attraction reduction requirements were met and a description of how
 the requirements were met. Permit conditions should specify the required certification statement to be
 used by the permittee. These  certifications must be signed by a responsible individual.  If the permit is
 an NPDES permit, there may already be language in the standard conditions defining the person who
 must sign all records and reports.  If not, then the NPDES language in §122.22 may be used.

 The description of how the pathogen and vector attraction reduction requirements  were met should be
 supported by analytical results documenting pathogen density, logs documenting operational parameters
 for sewage sludge treatment  units,  and  records describing site restrictions to  properly demonstrate
 compliance with the provisions.   Further discussion of the suggested monitorjing and recordkeeping
 requirements and supporting documentation is provided in Chapter 8.
                                                                     i      '         •
4.8.3   DOCUMENTATION TO SHOW COMPLIANCE WITH MANAGEMENT PRACTICES

Persons who land apply bulk sewage sludge are required to certify that they are meeting the management
practices in § 503.14 and to describe how the management practices are met unless they are land applying
a sewage sludge that meets the exceptional quality criteria.  If non-exceptional quality sewage sludge is
prepared for sale or give away in a bag or other container, the preparer must meet the management
practice requiring a label.  The permit writer, at a minimum,  can specify that the certification and
description be maintained.  After review of the permittee's application package  and/or a field visit to
application sites or in response to public concern, the permit writer may determine that more specific
requirements are necessary  to  ensure compliance with the management practices.  If the permit writer
decides that more specific information is needed to determine compliance with the management practices,
the permit writer must establish permit conditions that identify specific information, additional reports,
or records that must be kept by the permittee.  The following discussions for each management practice
                                            4-62

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                         4. LAND APPLICATION - PART 503 SUBPART B
provide examples of specific information that may be requested to demonstrate compliance with the
management practices.

Endangered Species or Critical Habitat Protection

Some of the following documentation may be necessary to demonstrate that the application site has been
evaluated  for potential effects on threatened'or endangered species of plant,  fish,  or wildlife or their
designated critical habitat and that necessary protective measures have been identified and implemented:

     •.  The general proximity of the nearest critical habitat, including migration routes for threatened
        or endangered species to the application site   .

     •  A list of endangered or threatened species in the  area or documentation that none exist

    , •  If there are endangered or threatened species, a determination from the FWS or appropriate State
        or local agency that the land application activity will not adversely affect the survival of the
        species or its  critical habitat                                     ^

   '  •  If the above determination indicates that adverse impacts can be avoided if specific measures are
        taken, records containing documentation of the measures and how they have been met.

Application of Sewage Sliidge to Flooded, Frozen, or Snow^Covered Land

Some of the  following information  may be needed to prove that it was highly unlikely for the sewage
sludge  applied to the flooded, frozen, or snow-covered land  to have entered any surface-waters  or
wetlands:                                                                           ,         „

     •  A copy of any permit issued pursuant to  either  Section 402 or 404 Of the CWA for allowing
        application of sewage sludge near wetlands

     •  A description of the general climatic conditions and the records of the average daily temperature
        and amount of snowfall in the area of the application site

     •  The  average uninterrupted slope of the land application site and the distance of nearby surface
        waters or wetlands from the boundary of the application site                            !

     •  A description of the run-off controls used at the site to prevent any sewage sludge from entering
        nearby surface waters or,wetlands

      •  Records of the average daily amounts of precipitation in the area and a description of how land
        application of sewage sludge is avoided during periods of high rainfall

      •  The average  depth to the ground water and records of the periods and extent of any flooding
        caused by ground water upsurges                           '

      • The types of crops grown and a brief description of  any irrigation method used and typical
        periods when irrigation occurs.
                                              4-63

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                          4. LAND APPLICATION - PART 503 SUBPART B
Distance to Surface Waters

Some of the following records may be appropriate to document that an adequate buffer zone is maintained
to prevent sewage sludge from entering adjacent surface water bodies:

     •  A log book entry for each application site describing the slope of the land application site, the
        distance between the boundary  of the land application site and nearest surface water body, or
        documentation that surface water (which includes wetlands and intermittent stream beds) does not
        exist near the land application site                               \

     •  If there is surface water near the land application site: the approximate length of each water
        body frontage; width, length, and slope of the protective buffer zone provided for that water
        body; and description of the vegetative cover of the buffer zone

     •  A log entry documenting the condition of any buffer zone, including its width and vegetative
        cover

     •  Site maps submitted  at the tune each site is identified, showing location of any surface waters
        with buffer zones clearly identified.

Agronomic Application Rate

The following documentation should be  kept on file to demonstrate compliance with the agronomic rate
requirement:

     •  The original calculations used  to determine the whole sludge application rate,  including all
        assumptions  and sources  of background information, and data for  the variables used in  the
        calculation, such as:

        -  Nitrogen required by, the crop or vegetation (available from Land Grant Universities, local
          extension agents, and Soil Conservation Service representatives)

        -  Values for the nitrogen content (organic nitrogen, ammonia nitrogen, and nitrate-nitrogen) of
          the sewage sludge                                                                      v

        -  Values for nitrogen content of supplemental fertilizers, if applicable

        -  Values for nitrogen available from sewage sludge applied in previous years, if applicable

        -  Nitrogen available from crop residue, if applicable

     •  The actual quantity of sewage sludge (dry weight basis) applied to the land application site

     •  The type of vegetation actually grown on the land and the annual nitrogen requirement for  the
        vegetation or the annual whole sludge application rate authorized by the permitting authority

     •  The amount of supplemental fertilizer actually applied to the land, if known, and the nitrogen
        content of the fertilizer.                                  ,
                                              4-64

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                         4.  LAND APPLICATION - PART 503 SUBPART B
Label or Information Sheet

Preparers of sewage sludge subject to annual pollutant loading rates are required to keep a copy of a label
or information sheet for at least 5 years.  Part 503 requires that each label or information sheet contain
at least the following:   .                                                       ,

     • The name and address of the person who prepared the sewage sludge for sale or give away in
       a bag or other container for application to the land

     • A statement that prohibits the application of the sewage sludge to the land except in accordance
       with  the instruction on the label, or information sheet

     • The annual whole sludge application rate (AWSAR) for the sewage sludge that does not cause
       the annual pollutant loading rates to be exceeded.

The permit writer should specify that each time the quality of the sewage sludge changes enough to affect
the AWSAR, the new label or information sheet be kept in the records.

4.9   REPORTING REQUIREMENTS
  Statement of Regulation         '            *                        ,               ,  'T  -
                                                          S-.            \  f
    §503>18(a)    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 10,006 people
                or more shall submit the following information to the permitting authority;

            (1) The information in 503J7{a), except the information in 503.17(a)(3)(ii),  503,17(a)(4)(ii} and in
                S03.l7(a)(5)(ii), for the appropriate requirements on February 19 of each year.

            (2) The information in 503.17(a)(5)(ii)(A), through 503,17(a)(SXu)(G) OB February 19 of each year
                when 90 percent or more of any of the cumulative pollutant loading rates in Table 2 of §503.13
                !s reached at a site*                        \             >'      •
As was described in the previous section, virtually all persons involved in the preparation of sewage
sludge for land application or in the land application itself are required to keep records.  However, only
a subset of persons that are required to keep records are then required to report under §503.18.

The reporting requirements in §503.18  apply to the following persons:      .

     •  Class I sludge management facilities       ;                       .

     •  POTWs with a flow rate  equal to  pr greater than 1 mgd

     •  POTWs serving  a population of 10,000 or greater.

TWTDS that are not automatically required to report can be designated as a Class 1 sludge management
facility by the Regional  Administrator.  These TWTDS, which could include  compost processes and
pelletization processes, would then be subject to the reporting requirements.-
                                              4-65

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                          4.  LAND APPLICATION - PART 503 SUBPART B
 At a minimum,  §503.18  specifies that certain persons report annually the information that they are
 required to develop and retain under the recordkeeping requirements.  The permit writer should develop
 permit conditions that specifically identify the information that must be reported, the dates by which the
 information must be received, and the address to which the report must be submitted.  The following
 technical guidance addresses these issues.

 The permit writer is  expected to set forth conditions requiring persons to meet the minimum reporting
 requirements.   At a minimum,  this  includes the results of sewage sludge analyses for pollutant
 concentrations and a certification and description of how the pathogen reduction requirement was met.
 If the person used one .of the treatment related vector attraction reduction alternatives [§§503.33(b)(l)
 through (8)],  then the report must include a certification and description of how the vector attraction
 reduction requirement was met.  In addition,  if the sewage sludge prepared by the  reporting person is
 land applied under the cumulative pollutant loading rates, that person is required to report site-specific
 information when the cumulative loading of any pollutant reaches 90 percent of the cumulative pollutant
 loading rate for that pollutant at that site.      /
                                                                  "  '                     #     ',' •
 When the preparer is instructed to report the results of sewage sludge analyses for pollutant concentrations
 or for pathogen density, he/she should be required to include the following information to improve the
 reliability of the report:

     • Units  for reported concentrations

     • Dry weight concentrations

     • Number of samples collected during the monitoring period

     • Number of excursions during the monitoring period                  ,

     • Sample collection techniques

     • Analytical methods.

Whenever possible, the permittee should identify the specific elements to be contained in the description
of how the pathogen  and vector attraction reduction requirements were met.  Refer  to Chapter 8 for a
detailed discussion of appropriate elements for each pathogen reduction and vector attraction reduction
alternative.  The permit writer may require that additional information be reported  over the minimum
requirements to determine the compliance status.   In the case where additional information  is  to be
reported, the permit writer must specifically require that information in the permit.

The permit writer Will need to consider whether yearly reporting requirements are sufficient  depending
on site-specific conditions.  He may want to require some reports to be submitted at a more frequent
interval than the yearly reporting  requirement.  For example, if the permit writer has imposed quarterly
monitoring requirements for pollutants in the permit, it may be appropriate to require quarterly reporting
of the concentrations or pollutant loadings  to determine compliance  with the pollutant limits and to
respond to noncompliance in a timely manner.  In addition, several situations may warrant the inclusion
of more frequent reporting, such  as:
                                              4-66

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                         4. LAND APPLICATION - PART 503 SUBPART B
     • Where sewage sludge data show significant variations in quality or where sewage sludge data
       .indicate a trend toward poorer quality sewage sludge.  In these eases, more frequent reporting
       may assist regulatory officials in addressing problems  before violations of land application
       requirements occur.  Additionally, the permit writer may have more advanced warning of the
       need to reopen a permit to address these situations.

     • Where a compliance schedule was specified.

The permit writer should instruct the permittee to submit reports to the Water Compliance Chief at the
appropriate EPA Regional office or to the appropriate State counterpart in an approved State. The permit
should require that the reports be signed  by an authorized representative.  If the permit is an NPDES
permit, the standard conditions may already contain language defining the authorized representative.  If
not, then the regulatory language found in §122.22 may be included to clearly identify the authorized
representative.

4.10    SCENARIOS FOR A LAND APPLICATION STANDARD

This section discusses different scenarios for a land application standard for bulk sewage sludge and for
sewage sludge that is  sold or given away in a bag or other container for application to the land.  Each
scenario contains the appropriate 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).  .

Each of the scenarios is  discussed in terms of whether the sewage sludge is classified as Exceptional
Quality (EQ). This concept is discussed below.

Two approaches are taken in Part 503 to protect public health and the environment from the reasonably
anticipated adverse effect of pollutants in sewage sludge when the sewage sludge is applied to the land.
In one approach, sewage sludge is treated to meet the Part 503 requirements for pollutants, pathogens,
and vector attraction reduction.  Because those requirements are met through treatment, controls are not
needed at the application site either to ensure  any  of the Part 503 requirements are met (e.g., injection
of the sewage sludge below  the land surface to reduce the attraction of vectors) or to prevent exposure
to the sewage sludge.
     ^*              .        '           -•...•              •                 •    '
thider the other approach, the Part 503 requirements are met through a combination of treatment of the
sewage sludge and restrictions on the application site.  In this case, control of  the application site must
be  maintained to ensure that activities are performed at the site to  meet a  Part 503 requirement or that
certain site restrictions are' met.  In both approaches, public health and the environment are protected,
but through different means  (i.e., treatment as opposed to a combination of treatment and restrictions  on
exposure).

During the development of Part 503, EPA received several comments that encouraged the Agency to use
the treatment approach to identify sewage sludges that are equivalent to other types of fertilizers.  Because
the Part 503 requirements for pollutants, pathogens, and vector attraction reduction would be met through
treatment, no controls would be needed at the  application site.  Thus, the sewage sludge could be treated
like other fertilizers (i.e., generally, no site controls are imposed when other fertilizers are land applied).
                                              4-67

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                          4. LAND APPLICATION - PART 503 SUBPART B
 In response to the comments, EPA modified the applicability section in subpart B of the final Part 503.
 Sections 503.10 (b) and (c) indicate that if bulk sewage sludge or a bulk material derived from bulk
 sewage sludge meets the ceiling concentration limits in Table 1 of §503.13, the pollutant concentration
 limits in Table 3 of §503.13, one of the Class A pathogen alternatives in §503.32(a),  and one of the
 vector attraction reduction options in §§503.33 (b)(l) through (b)(8), or an equivalent vector attraction
 reduction option  as determined by the permitting authority, the bulk sewage sludge or bulk material
 derived from bulk sewage sludge is not subject to the general requirements in § 503.12 or the management
 practices in §503.14 when the bulk sewage sludge is land applied.                   •'        -       -

 A bulk sewage sludge or bulk material derived from sewage sludge that meets the above requirements
 is known as exceptional quality (EQ).  This term is used so that the above quality requirement do not
 have to be repeated each time they are discussed.  The term exceptional quality is not used in the Part
 503 regulation.                                                     ,

 The term  exceptional quality  identifies a sewage  sludge for  which the Part 503  land application
 requirements are  met by treating the sewage sludge.  A non-EQ sewage sludge is a sewage sludge 'for
 which the Part 503 requirements are met through a combination of treatment and restrictions on exposure
 to the sewage sludge after it is land applied.  Public health and the environment are protected when either
 EQ or non-EQ sewage sludge is land applied.                      *    •    '

 Sewage sludge that is sold or given away in a bag or other container for application to the land and that
 meets the above three quality requirements also is considered EQ.  Thus,  an EQ sewage sludge can be
 applied to agricultural land (including pasture and range land), forest, a public contact site, a reclamation
 site, a lawn, or a home garden and not be subject to the Part 503 land application general requirements
 and management practices.

 In the case of bulk EQ sewage sludge or a bulk  EQ material derived from sewage sludge, the EPA
 Regional Administrator  or  the State Director in the case where a State has  an approved sludge
 management program can require that the Part 503 land application general requirements and management
 practices be met when the bulk EQ sewage sludge or bulk  EQ material is  land applied (see
 §§503.10(b)(2) and (c)(2)). In this case, the EPA Regional Administrator or State Director has to show
 that  the general requirements and management practices are needed to protect public health and the
 environment from the reasonably anticipated adverse effect that may occur from any pollutant .in the bulk
sewage sludge or bulk material. This provision does not apply to sewage sludge that is sold or given
 away in a bag or other container for application to the land.

 EPA concluded that a sewage sludge that meets the treatment-related Part 503 requirements for pollutants,
pathogens, and vector attraction reduction has  value and, thus, most likely will not be land applied
 inappropriately (e.g., at a rate that is greater than the agronomic rate for the site). For this reason and
because control over an application site is not needed to ensure that any of the Part 503 requirements for
pollutants,  pathogens, and vector  attraction reduction are met,  the Agency also concluded that an EQ
sewage sludge should be handled like other types of fertilizers with respect to application requirements.

The  scenarios presented in this  section are defined in terms of whether the sewage sludge is EQ. For
example, the first scenario is for an EQ sewage  sludge and the third scenario is for bulk  sewage sludge
that is non-EQ because the Class B pathogen requirements are met.
                                             4-68

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                         4.  LAND APPLICATION - PART 503 SUBPART B
4.10.1 SCENARIO 1 - EXCEPTIONAL QUALITY (EQ) SEWAGE SLUDGE

For. this scenario, the ceiling concentration limits, the pollutant concentration limits, one of the Class A
pathogen requirements, and one of the first eight vector attraction reduction options (or an equivalent
option) are met. When all of those requirements are met, the sewage sludge can be applied to agricultural
land (including pasture and range land), forest, a public contact site, a reclamation site,  a lawn, or a
home garden without being subject to the Part 503 land application general requirements and management
practices.  It also can be sold or given away in a bag or other container for application to the land without
being subject to the land application general requirements and management practices.

The elements of a Part 503 standard for this scenario are presented below.
                  ELEMENTS OF A PART 503 STANDARD - SCENARIO 1

  General requirements:        None

  Pollutant limits:             Ceiling concentration limits in Table 1 of §503.13

                             Pollutant concentration limits in Table 3 of § 503,13

  Management practices:       None_
  Operational standard
  (pathogens):
                             One of the Class A alternatives in §503.32(a)
  Operational standard                    -                   •
  (vector attraction reduction): One of the vector attraction reduction options in §§ 503.33(b)(l)
                             through (b)(8) or an option determined to be equivalent by the
                             permitting authority

  Frequency of monitoring:    Requirements in §503.16(a)                 ,

  Recordkeeping:             Requirements in either §503.17(a)(l) or §503.17(a)(2)

  Reporting:                  Requirements in §503.18(a)(l)	      '
                                              4-69

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                         4.  LAND APPLICATION - PART 503 SUBPART B
4.10.2 SCENARIO 2 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF VECTOR
       ATTRACTION REDUCTION

In this scenario, the ceiling and pollutant concentration limits, the Class A pathogen requirements, and
either vector attraction reduction option 9 (injection) or 10 (incorporation) are met.  Control over the
application site has to be maintained to ensure that the vector attraction reduction option is met.  When
the requirements in this scenario are met, bulk sewage sludge can be applied to agricultural land, forest,
a public contact site, or a reclamation site. It can not be applied to a lawn or a home garden because
vector attraction reduction options 9 and 10 are not feasible for a lawn or home garden.

This scenario does not apply to sewage sludge sold or given away in a bag or other container for
application to the land.  One of the treatment related vector attraction reduction options (i.e., Options 1
through 8) has to be met in this case.
                  ELEMENTS OF A PART 503 STANDARD - SCENARIO 2

 General requirements:       Requirements in §§503.12(a), (d), (e)(l), (f), (g), (h), and (i)
 Pollutant limits:
 Management practices:

 Operational standard
 (pathogens):
Ceiling concentration limits in Table 1 of §503.13

Pollutant concentration limits in Table 3 of §503.13

Requirements in §§503.14(a) through (d)


One of the Class A pathogen alternatives in §503.32(a)
 Operational standard
 (vector attraction reduction):  Either the vector attraction reduction option in §§503.33(b)(9) or
 Frequency of monitoring:    Requirements in §503. 16(a)

 Recordkeeping:              Requirements in §503.17(a)(3)

 Reporting:                  Requirements in §503.18(a)(l)
                                           4-70

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                        4.  LAND APPLICATION - PART 503 SUBPART B
4.10.3 SCENARIO 3 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF PATHOGEN
       REDUCTION

In this scenario, the ceiling and pollutant concentration limits, one of the Class B pathogen alternatives,
and one of the first eight vector attraction reduction options (or an equivalent option) are met.  Because
the Class B pathogen requirements are met, restrictions are imposed on the application site to prevent
exposure to the bulk sewage sludge for certain periods. Bulk sewage sludge that meets the requirements
in this scenario can be applied to agricultural land, forest, a public contact site, or a reclamation site, but
not to a lawn or home garden.  It is not feasible^to impose the Class B site restrictions on a lawn or a
home garden.
               >     .      • '               f .   •     •                       '•
This scenario does  not apply to sewage sludge sold or given away in a bag or other  container for
application to the land.  When sewage sludge is solcl or given away in a bag or other container for
application to the land one of the Class A pathogen alternatives  has to be met.

The elements of a Part 503 standard for this scenario are presented below.        .                 ,
                  ELEMENTS OF A PART 503 STANDARD - SCENARIO 3

 General requirements:       Requirements in §§503.12(a), (d), (e)(l), (f), (g), (h), and (i):
 Pollutant limits:
  Management practices:

  Operational standard
  (pathogens):
Ceiling concentration limits in Table 1 of §503.13

Pollutant concentration limits in Table 3 of §503.13

Requirements in §§503.14(a) through (d)


One of the Class B alternatives in §503.32(b) and the site restrictions
in§503.32(b)(5)
  Operational standard
  (vector attraction reduction):  One of the vector attraction reduction options in §§503.33(b)(l)
                             through (b)(8) or an option determined to be equivalent by the
                             permitting authority          '                    •

  Frequency of monitoring:    Requirements in §503.16(a)

  Recordkeeping:              Requirements in §503.17(a)(4)                             ,

  Reporting: '                 Requirements in §503.18(a)(l)   	/	
                                             4-71

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                         4.  LAND APPLICATION - PART 503 SUBPART B
4.10.4 SCENARIO  4 -  BULK  SEWAGE  SLUDGE  THAT  IS  NON-EQ  BECAUSE  OF
       POLLUTANT CONCENTRATIONS

In this scenario, the ceiling concentration limits, the CPLRs, one of the Class A pathogen alternatives,
and one of the firsf eight vector attraction reduction options are met.  Because the bulk sewage sludge
is subject to the CPLRs, records have to be kept of the amount of each pollutant applied to the land in
bulk sewage sludge. When the requirements in this scenario are met, bulk sewage sludge can be .applied
to agricultural land, forest, a public contact site, or a reclamation site. It  can not be applied to a lawn
or a home garden because it is not feasible to keep records of the amount of each pollutant applied to a
lawn or home garden in bulk sewage sludge.

This scenario does not apply to sewage sludge sold or given away in a bag  or other container for
application to the land. In this case, the locations of the many application sites are not known.  Thus,
records of the amount of each pollutant applied to a site in sewage sludge  can not be kept.

The elements of a Part 503 standard for this scenario are presented below.
                  ELEMENTS OF A PART 503 STANDARD - SCENARIO 4
 General requirements:


 Pollutant limits:



 Management practices:

 Operational standard
 (pathogens):
Requirements in §§503.12(a), (b), (d), (e)(l), (e)<2), (f), (g), (h), (i),
and (j)

Ceiling concentration limits in Table 1 of §503.1.3

Cumulative pollutant loading rates in Table 2 of §503.13

Requirements in § § 503.14(a) through (d)


One of the Class A pathogen alternatives in §503.32(a)
 Operational standard
 (vector attraction reduction):  One of the vector attraction reduction options in §§503.33 (b)(l)
                            through (b)(8) or an option determined to be equivalent by the
                            permitting authority

 Frequency of monitoring:    Requirements in §503.16(a)

 Recordkeeping:      ,   .    Requirements in §503.17(a)(5)

 Reporting:                  Requirements in §§503.18(a)(l) and (a)(2)
                                            4-72

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                        4. LAND APPLICATION - PART 503 SCBPART B
4.10.5 SCENARIO 5 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF VECTOR
       ATTRACTION REDUCTION AND PATHOGEN REDUCTION
                                                   i     _
Inthis scenario, the ceiling concentration limits in Table 1 of §503.13, the pollutant concentration limits
in Table 3 of §503.13, one of the Class B pathogen alternatives in  §503.32(b), and either the vector
attraction reduction option in §§503.33(b)(9) or (b)(10) are met.  Control over the application site must
be maintained to ensure that the Class B site restrictions and the vector attraction reduction option are
met at the site.  When the Part 503 requirements in this scenario are met, bulk sewage sludge can be
applied to agricultural land, forest, a public contact site, or a reclamation site, but not to a lawn or home
garden.

This scenario does not apply to  sewage  sludge sold or given away in a bag  or other container for
application to the land.  Control over the application site is not maintained when sewage sludge is sold
or given away in a bag or other container.                                     ,

The elements of a Part 503 standard for this scenario are presented below.
                  ELEMENTS OF A PART 503 STANDARD - SCENARIO 5

  General requirements:       Requirements in §§ 503.12(a), (d), (e)(l), (f), (g), (h), and (i)
  Pollutant limits:
  Management practices:

  Operational standard
  (pathogens):
Ceiling concentration limits in Table 1 of §503.13

Pollutant concentration limits in Table 3 of §503.13

Requirements in §§ 503.14(a) through (d)
One of the Class B pathogen alternatives in §503.32(b) and the Class
B site restrictions in §503.32(b)(5)
  Operational standard
  (vector attraction reduction):  Either the requirements in §§503.33(b)(9) or (b)(10)

  Frequency of monitoring:    Requirements in §503.16(a)     >

  Recordkeeping:             Requirements in §503.17(a)(4)

  Reporting:,           ,     Requirements in §503.18(a)(l)   .     .	   .
                                             4-73

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                        4. LAND APPLICATION - PART 503 SUBPART B
4.10.6 SCENARIO 6 - BULK SEWAGE SLUDGE THAT IS NON-EQ BECAUSE OF VECTOR
       ATTRACTION REDUCTION AND POLLUTANT CONCENTRATIONS

In this scenario, the ceiling concentration limits in Table  1 of §503.13, the CPLRs in Table 2 of
§503.13, one of the Class A pathogen alternatives, and the vector attraction reduction option in either
§§503.33(b)(9) or (b)(10) are met. Because the CPLRs and either vector attraction reduction option 9
or 10 are met, control over the application site has to be maintained so that records of the amount of each
pollutant applied to the land in bulk sewage sludge can be maintained and so that vector attraction
reduction can be achieved.  When the requirements in this scenario are met, bulk sewage sludge can be
applied to agricultural land, forest, a public contact site, or a reclamation site, but not to a lawn or home
garden.

This scenario does not  apply to sewage sludge  sold or given  away in a bag or  other container for
application to the land.  Control over the application site is not maintained when sewage sludge is sold
or given away in a bag or other container.
                                                                           '     _/         i
The elements of a  Part 503 standard for this scenario are presented below.
                 ELEMENTS OF A PART 503 STANDARD - SCENARIO 6

 General requirements:
 Pollutant limits:
 Management practices:

 Operational standard
 (pathogens):
Requirements in §§503.12(a), (b), (d), (e)(l), (e)(2),'(f), (g), (h), (i),
and (j)

Ceiling concentration limits in Table 1 of §503.13

Cumulative pollutant loading rates in Table ;2 of § 503.13

Requirements in §§503.14(a) through (d)


One of the Class A pathogens in §503.32(a)
 Operational standard
 (vector attraction reduction):  Either the requirements in §§503.33(b)(9) or (b)(10)

 Frequency of monitoring:     Requirements hi §503.16(a)

 Recordkeeping:              Requirements in § 503.17(a)(5)

 Reporting:	       Requirements in §§503.18(a)(l) and (a)(2)
                                           4-74

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                        4.  LAND APPLICATION - PART 503 SUBPART B
4.10.7 SCENARIO 7 - BULK SEWAGE  SLUDGE  THAT IS  NON-EQ  FOR PATHOGEN
       REDUCTION AND POLLUTANT CONCENTRATIONS                ,

In this scenario, the ceiling concentration limits  in Table 1 of §503.13, the CPLRs in Table, 2 of
§ 503.13, one of the Class B pathogen alternatives, the Class B site restrictions, and one of the first eight
vector attraction reduction options (or an equivalent option) are met.  Control over the application site
has to be maintained to ensure that records of the amount of each pollutant applied to the site in bulk
sewage sludge are kept and to ensure that the Class B site restrictions are met.  When  the Part 503
requirements in this scenario are met, bulk sewage sludge can be applied to agricultural land,  forest, a
public contact site, or a reclamation, but not to a lawn or home garden.

This scenario does not apply to  sewage sludge sold or given away in a bag or other container for
application to the land.  When sewage sludge is sold or given away in a bag or other container for
application to the land, control over the application site is not maintained.  Thus, there  is no way to
implement the site related requirements in this scenario.

The elements of a Part 503  standard for this scenario are presented below.
                  ELEMENTS OF A PART 503 STANDARD - SCENARIO 7

  General requirements:
  Pollutant limits:
  Management practices:

  Operational standard
  (pathogens):
Requirements in §§503.12(a), (b), (d), (e)(l), (e)(2), (f), (g), (h), (i),
and (j)

Ceiling concentration limits in Table 1 of §503.13

Cumulative pollutant loading rates in Table 2 of §503.13

Requirements in §§503.14(a) through (d)
One of the Class B pathogen alternatives in §503.3l(b) and the Class
B site restrictions in §503.13(b)(5)
  Operational standard                  .
  (vector attraction reduction):  One of the vector attraction reduction options in §§503.33(b)(l)
                             through (b)(8) or an option determined to be equivalent by the
                             permitting authority

  Frequency of monitoring:    Requirements in §503.16(a)
                        \

  Recordkeeping:             Requirements in §503.17(a)(5)

  Reporting:                  Requirements in §§503.18(a)(l) and (a)(2)
                                             4-75

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                         4.  LAND APPLICATION - PART 503 SUBPART B
4.10.8 SCENARIO  8 - BULK SEWAGE SLUDGE  THAT IS  NON-EQ  FOR VECTOR
       ATTRACTION  REDUCTION,   PATHOGEN  REDUCTION,  AND  POLLUTANT
       CONCENTRATIONS

In this scenario, none of the requirements for an EQ sewage sludge are met.  Instead, the ceiling
concentration limits, the CPLRs, the Class B pathogen requirements, the Class B site restrictions, and
either vector attraction reduction option 9 or 10 are met.  Control over the application site has to be
maintained to ensure that records of the amount of each pollutant applied to the site in sewage sludge are
kept; to ensure that the Class B site restrictions are met; and to ensure that either vector attraction
reduction option 9 or 10 is met. When the requirements in this scenario are met, bulk sewage sludge can
be applied to agricultural land, forest, a public contact site, or a reclamation site, but not to a lawn or
a home garden.                                          •

This scenario does not apply to sewage sludge sold or given away in  a bag or other container for
application to the land. The  requirements related to the application site can not be implemented when
sewage sludge is sold or given away in a bag or other container because control over the application site
is not maintained.

The elements of a Part 503 standard for  this scenario are presented below.
                  ELEMENTS OF A PART 503 STANDARD - SCENARIO 8
 General requirements:


 Pollutant limits:



 Management practices:

 Operational standard
 (pathogens):
Requirements in §§503.12(a), (b), (d), (e)(l), (e)(2), (f), (g), (h), (i),
and (j)

Ceiling concentration limits in Table 1 of §503.13

Cumulative pollutant loading rates in Table 2 of §503.13

Requirements in §§503.14(a) through (d)
One of the Class B pathogen alternatives hi §503.32(b) and the' Class
B site restrictions in §503.32(b)(5)
 Operational standard
 (vector attraction reduction):  The vector attraction reduction option in either §§503.33(b)(9) or
 Frequency of monitoring:    Requirements in §503.1 6(a)

 Recordkeeping:             Requirements in §503. 17(a)(5)

 Reporting:                  Requirements in §§503. 18(a)(l) and (a)(2)
                                            4-76

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                          4.  LAND APPLICATION - PART 503 SUBPART B
 4.10.9 SCENARIO 9 - SEWAGE SLUDGE SOLD OR GIVEN AWAY IN A BAG OR OTHER
        CONTAINER FOR APPLICATION TO THE LAND THAT IS NON-EQ BECAUSE OF
       , POLLUTANT CONCENTRATIONS

 In this scenario, the ceiling concentration limits, the APLRs, one of the Class A pathogen alternatives,
 and one of the first eight vector attraction reduction options (or an equivalent option) are met.  Control
 over the application site is not maintained in this scenario. When the requirements in this scenario are
 met, sewage sludge can be applied to any type of land but most likely will be applied to a public contact
 site, a lawn, or a home garden.

 This scenario does not apply to bulk sewage sludge that is land applied-. It only applies to amounts up
 to one metric ton that are sold or given away in a bag or other container (e.g., a bucket, a box, a carton,
 or a vehicle or trailer with a load capacity of one metric ton or less). EPA assumed that small amounts
 of sewage sludge would be applied to a site for 20 years in developing the annual pollutant loading rates
- that are part of this scenario.

 The only difference between this scenario and Scenario 1 for .sewage sludge sold or given away in a bag
 or other container for application  to the land is the pollutant limits.  For  Scenario  1, the ceiling
 concentration limits and pollutant concentration limits are met, In this scenario, the ceiling concentration
 limits and APLRs are met.             .

 The elements of a Part 503 standard for this scenario are presented below:
                   -ELEMENTS OF A PART 503 STANDARD - SCENARIO 9

   General requirements:,       Requirements in §§503.12(a),(e)(l),( and (g)
   Pollutant limits:
   Management practice:

   Operational standard
   (pathogen):
Ceiling concentration limits in Table 1 of §503.13

Annual pollutant loading rates in Table 4 of §503.13

Requirements in §503.14(e)


One of the Class A pathogen alternatives in §503.32(a)
   Operatibnal standard
   (vector attraction reduction):  One of the vector attraction reduction options in §§503.33(b)(l)
                              through (b)(8) or an option determined to be equivalent by the
                              permitting authority

   Frequency of monitoring:    Requirements in §503.16(a)

   Recordkeeping:             Requirements in §503.17(a)(6)

   Reporting:                  Requirements in §503.18(a)	            .  ' •
                                              4-77

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                         4. LAND APPLICATION - PART 503 SUBPART B
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 Cole, D.W. 1980.  "Response of Forest Ecosystems  to Sludge and Wastewater Applications - A Case
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                                            4-78

-------
                        4. LAND APPLICATION - PART 503 SUBPART B
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                                            4-79

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                        4. LAND APPLICATION - PART 503 SUBPART B
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U.S. EPA.  1980. Procedures Manual for Ground Water Monitoring at Solid Waste Disposal Facilities.
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                                                     j-       . •»    '
U.S. EPA.  1983.  Process Design Manual for the Land Application of Municipal Sludge.  Municipal
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                                                            f
U.S. EPA.   1984. Ground Water Protection  Strategy,  office of Ground Water Protection. August
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                                            4-80

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                         4.  LAND APPLICATION - PART 503 SUBPART B
 U.S. EPA.  1986a. RCRA Groundwater Monitoring. Technical Enforcement Guidance Document. Office
 of Solid Waste and Emergency Response.  9950.1.

 U.S. EPA.  1987.  Guidance For Applicants for State Wellhead Protection Program Assistance Funds
 Under the Safe Drinking Water Act.  Office of Ground Water Protection. Washington, DC. EPA 440/6-
 87-011.

 U.S. EPA.   1988.   Guidance for Writing Case-by^Case Permit Requirements for Municipal Sewage
 Sludge.  Draft. Office of Water Experiment.  Permits Division.      . .               .

 U.S. EPA.  1989a.  POTW Sludge Sampling and Analysis Guidance Document.  Permits Division.

 U.S. EPA.  1989b.  Sampling Procedures and Protocols for the National Sewage Sludge Survey. Office
 •of Water Regulations and Standards.                             ,

 U.S. EPA. 1991. Summary of Phase II Regulations.  U.S. Environmental Protection Agency, Office of
 Ground Water Protection, Washington, DC.  EPA 570/9-91-022. October 1991.

 U.S. EPA. 1992. Comprehensive State Ground Water Protection Program Guidance.  Draft.  Office of
 Ground Water Protection.  Washington, DC.

 U.S. EPA 1992.  Final Technical Manual for Solid Waste Disposal Facility Criteria-40 CFR Part 258.
. Office of Solid Waste.  Washington, DC.

 U.S. EPA.   1992.  Guidance Specifying Management Measures for Sources of Nonpoint Pollution in
 Coastal Waters.

 U.S. EPA.    1992a.  Monitoring, Record Keeping and Reporting Requirements for Generators and
 Preparers of Sewage Sludge,  Draft. Office of Wastewater Enforcement and Compliance.

 U.S. EPA.   1992b. Monitoring, Record Keeping and Reporting Requirements for Land Appliers of
 Sewage Sludge. Draft. Office of Wastewater Enforcement and Compliance.

 U.S. EPA.   1992c.  The Preamble  to 40 CFR Part 503 Standard for the Use and Disposal of Sewage
 Sludge.  February 1993, FR 9248.                                              ,

 U.S. EPA.  1992d. Sludge Sampling Video. Office of Wastewater Enforcement and Compliance.

 U.S. EPA.   1992e.  Control of Pathogens and Vector Attraction in Sewage Sludge.  December 1992.
 EPA/625/R-92/013.                 >

 U.S. Federal Emergency Management Agency.  How to Read a Flood Insurance Rate Map.
                                            4-81

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            5.  SURFACE DISPOSAL - PART 503 SUBPART  G
                                QUICK REFERENCE INDEX
INTRODUCTION

SPECIAL DEFINITIONS

GENERAL REQUIREMENTS
     COMPLY WITH THE PART 503 SURFACE DISPOSAL REQUIREMENTS
     LOCATION OF ACTIVE SEWAGE SLUDGE UNIT WITHIN 60 METERS OF A FAULT,
     IN AN UNSTABLE AREA, OR IN A WETLAND
     WRITTEN CLOSURE AND POST-CLOSURE PLAN
     NOTIFICATION TO SUBSEQUENT OWNER
Section

5.1

5.2

5.3
Page

 5-2

 5-4

 5-8
 5-8

 5-8
 5-9
5-14

5-15
POLLUTANT LIMITS                                                      5.4,
     AN ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM WITH A UNIT
     BOUNDARY TO SITE PROPERTY LINE DISTANCE OF 150 METERS OR MORE               ,-           5-16
     AN ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM WITH A UNIT
     BOUNDARY TO SITE PROPERTY LINE DISTANCE OF LESS THAN 150 METERS                         5-17
     SITE-SPECIFIC POLLUTANT LIMITS                                                        5-18
MANAGEMENT PRACTICES      ,                                     _      5.5  ,
     ENDANGERED SPECIES OR CRITICAL HABITAT PROTECTION
     BASE FLOOD FLOW RESTRICTIONS
     REQUIREMENTS IN A SEISMIC IMPACT ZONE
     REQUIREMENT OF 60 METERS OR MORE FROM A FAULT
     UNSTABLE AREAS                                   ,
     WETLAND PROTECTION
     STORM WATER RUN-OFF MANAGEMENT
     LEACHATE COLLECTION AND DISPOSAL
     METHANE GAS CONTROL                 '       '              •     "  ••
     FOOD, FEED, AND FIBER CROPS AND GRAZING RESTRICTIONS
     PUBLIC ACCESS CONTROL    ,
     GROUND-WATER PROTECTION

OPERATIONAL STANDARDS                                     .5.6
     PATHOGENS             .
     VECTOR ATTRACTION REDUCTION

FREQUENCY OF MONITORING REQUIREMENTS                                  5.7
     PARAMETERS TO BE MONITORED
     MONITORING FREQUENCY                                           '      .
     MONITORING POINTS
     SAMPLE COLLECTION AND PRESERVATION PROTOCOL
     ANALYTICAL METHODS
     QUALITY  ASSURANCE/QUALITY CONTROL (QA/QC)

RECORDKEEPING REQUIREMENTS.                                           5.8       >
     DOCUMENTATION FOR POLLUTANT CONCENTRATIONS                 .
     DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION REDUCTION
     DOCUMENTATION TO SHOW COMPLIANCE WITH MANAGEMENT PRACTICES

REPORTING REQUIREMENTS                                                5.9

SCENARIOS FOR A SURFACE DISPOSAL STANDARD                               5.10
     SCENARIO 1 - ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER AND LEACHATE COLLECTION
     SYSTEM WITH A UNIT BOUNDARY TO SITE PROPERTY LINE DISTANCE OF 150 METERS OR GREATER
     SCENARIO 2 - ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER AND LEACHATE COLLECTION  ,
     SYSTEM WITH A UNIT BOUNDARY TO SITE PROPERTY LINE DISTANCE LESS THAN 150 METERS
     SCENARIO 3 - ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER AND LEACHATE COLLECTION
     SYSTEM FOR WHICH SITE-SPECIFIC POLLUTANT LIMITS ARE DEVELOPED
     SCENARIO 4 - ACTIVE SEWAGE SLUDGE UNIT WITH A LINER AND LEACHATE COLLECTION SYSTEM
                  5-20
                  5-20
                  5-21
                  5-23
                  5-25
                  5-27
                  5-30
                  5-32
                  5-34
                  5-43
                  5-47
                  5-48
                  5-49

                  5-60
                  5-60
                  5-61

                  5-62
                  5-62
                  5-62
                  5-64
                  5-65
                  5-66
                  5-69

                  5-69
                  5-70,
                  5-71
                  5-71

                  5-77

                  5-79

                  5-80

                  5-81

                  5-82
                  5-83
                                            5-1

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                            5. SURFACE DISPOSAL - PART 503 SUBPART C
 5.1    INTRODUCTION

 This chapter provides guidance on implementation of the requirements for surface disposal contained in
 Part 503, Subpart C. It is presumed that the permit writer has established that the sewage sludge being
 disposed is regulated by Part 503. Chapter 2 provides a detailed discussion of sewage sludge that is and
 is not regulated by Part 503.

 Major challenges in determining  whether this subpart is applicable to a particular facility include:

     •  Distinguishing surface disposal from land application

     •  Distinguishing surface disposal from treatment

     •  Distinguishing surface disposal from storage.

 A surface disposal site is defined as an area of land that contains pne or more active sewage sludge units.
 An active sewage sludge unit is an area of land on which sewage sludge is placed for disposal.  Land
 does not include waters of the United States, as defined in § 122.2.  Examples of sewage sludge surface
 disposal practices include sewage sludge-only landfills  (monofills), sewage sludge piles, and lagoons
 designed for the final disposal of sewage sludge.

 Surface disposal differs  from land application in that it principally uses the land as final disposal, instead
 of using the sewage sludge to enhance the productivity of the land. Surface disposal occurs when sewage
 sludge is applied at rates in excess of the agronomic rate needed by vegetation grown on the site (and the
 site  is not a reclamation site).

 However, some surface disposal practices, where the sewage sludge is applied on the surface of the land,
 may be very similar to  land application practices.  For example, a surface disposal site where sewage
 sludge is applied and a food, feed, or fiber crop is grown or animals are grazed may appear to be a land
 application site.  However, the site is a surface disposal site if it is for the final disposal of sewage
 sludge.  In these situations, management  practices must be implemented to control activities such as
 growing of crops or animal grazing.

 The  storage or treatment of sewage sludge (other than treatment to reduce pathogen levels and vector
 attraction characteristics) is not regulated by Part 503. If sewage sludge is placed on an area of land for
 either treatment or storage, §503.20(c) makes clear that neither the land nor the sewage sludge  placed
 on that land for treatment or storage is subject to the requirements in Subpart C. Lagoons, in particular,
 are frequently used to dewater or  stabilize the sewage sludge, as well as for storage. Storage of sewage
 sludge is the placement of sewage sludge on land  on which it remains for 2 years or less. The most
obvious indicator that the land-based activity is treatment or storage is whether the treatment works has
designated a subsequent sewage sludge use or disposal practice. Unless a final use or disposal practice
has been identified for the sewage sludge, the permit writer should permit the land-based activity as final
disposal or require that  the permittee develop a final use or disposal plan  for its sewage sludge.
                                              5-2

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                             5.  SURFACE DISPOSAL - PART 503 SUBPART C
  Statement of Regulation                                                      \
      i                       i
  , §503.20{b)    This subpart does not apply to sewage sludge stored on the land or to the land on which sewage
                 sludge is stored. It also does not apply to sewage sludge that remains on the land for longer than
                 2 years when the person who prepares the Sewage sludge demonstrates that the land on which
                 the sewage sludge remains is not an active sewage sludge unit.  The demonstration shall include
                 the following information, which shall be retained by the person who prepares the sewage sludge
                 for the period that the sewage sludge remains on the land:

             (1)  The name and address of the  person who prepares the sewage sludge.

             (2)  The name and address of the  person who either owns the land or leases the land.

             (3)  The location, by either street  address or latitude and longitude, of the land*

             (4)  An explanation of why sewage sludge needs to remain on the land for longer than 2 years prior
                 to final use or disposal.

             (5)  The approximate time period  when the sewage sludge will be used or disposed.

    §503.20(c)    This subpart does not apply to sewage sludge stored or treated on the land or to land on which
                 sewage sludge is treated.                                                     "	
 Another factor used to distinguish between storage and final disposal is the length of time that the sewage
 sludge remains on the land.  Sewage sludge that remains on the" land for periods greater than 2 years is
 being disposed unless the person who prepares the sewage sludge establishes through written justification
 a basis for leaving the sewage sludge on the land for longer than 2 years according to §503.20(b). The
 permit  writer  should evaluate each  situation with  regard  to  protection of public health and the
 environment and the reasonableness of a particular activity in determining whether it should be regarded
 as final disposal.  Treatment works that generate small quantities of sewage sludge  may  reasonably
 stockpile sewage sludge for a period of time before use or disposal.  Even some large  treatment works
 may stockpile sewage sludge for periods when they unexpectedly lose access to their use  or disposal
 practice.  In contrast, there are a number of treatment works that indefinitely stockpile sewage sludge
 under conditions that should be considered disposal.  It is common in some areas to construct sewage
 sludge  "storage" lagoons with  a  15-year  capacity  to postpone final disposal.  These lagoons are
 constructed  similarly to a surface disposal  site and poses the same threat to human health and the
 environment, particularly ground water, as a surface disposal site and therefore should be regulated as
 such.

 Some provisions of Subpart C apply to the sewage sludge, some to the location or siting of the surface
 disposal site and others to the operation of the surface disposal site. Not all of the management practices,
 frequency of monitoring, and recordkeeping requirements apply to every  surface disposal site.  For
 example, some apply only to sites with a liner and leachate collection system; others  apply only to sites
 on which a  cover is placed over  sewage sludge.

 When the preparer is not the owner/operator of the surface disposal site, the permit writer must decide
 how to allocate the permit requirements. Most of the general requirements and management practices
 apply to the site owner/operator.  Requirements for pathogen and vector attraction reduction should be
 allocated according to whether they are met by the preparer, the owner/operator, or both.  The pollutant
 limits may be placed in both permits; when they are based on site conditions the preparer's permit might
- contain a condition to meet the pollutant limits that are imposed on the owner/operator.
                                                 5-3

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
5.2    SPECIAL DEFINITIONS

Section 503.21 contains definitions related specifically to surface disposal of sewage sludge.  This section
of the guidance manual briefly explains some of the terms in §503.21 applicable to surface disposal of
sewage sludge and  lists the remaining definitions in §503.21.  This  section also provides  selected
definitions from §503.9 (general definitions for the Part 503 rule) for reference purposes.

Aquifer
  Statement of Regulation                                                                -  -<
                                                                    '     -i '.           t  -,  V
    §503.21(b)    Aquifer is a geologic formation, group of geologic formations, or a portion of a geologic
 	           formation capable of yielding ground water to wells or springs.
An aquifer is a saturated permeable geologic unit that can transmit significant quantities of water under
normal hydraulic gradients.  An aquifer is typically described as being either confined, unconfined, or
perched.  In a confined aquifer, the permeable water-bearing and transporting material lies between two
layers of less-permeable confining material referred to as aquitards. An unconfined aquifer will have an
aquitard as its lower boundary and the water table as its upper limit. A perched aquifer is a phenomenon
where a less permeable formation existing in the unsaturated zone above the water table acts as a lower
aquitard.  Water percolating down toward the water table is intercepted and collected, forming an isolated
saturated zone and perched water table.
                                                    Soil Surface
Saturated
  Zone
                           Unsaturated
                               Zone
                               Main Water
                                  Table
                                                                   |  | Unsaturated
                                                                      sandstone layer
                                                                      sandstone layer

                                                                   F3 Shale layer
                                     AQUIFER
Cover
  Statement of Regulation                '"'"'",'!    - '    '"'/        ,    J> "f "  , „

    §503.21(d)    Cover is soil or other material used'to cover sewage sludge placed on an active sewage sludge
                unit.
Cover is the placement of earthen material over the sewage sludge once it has been placed in an active
sewage sludge unit.  Cover is placed over the sewage sludge to reduce vector attraction characteristics,
to contain pathogens, and/or to mitigate odor problems. Virtually any soil is considered suitable cover
material if it accomplishes the desired objectives; very coarse soils; however, may be inappropriate if the
                                              5-4

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
moisture content of the sewage sludge is so high that the soil sinks into the sewage sludge rather than
mounding over the surface.

Other materials  may be used as alternatives to soil cover material.  The permit writer may require a
demonstration (similar to that required for municipal solid waste landfills by the Part 258 regulations) that
the alternate material is suitable.  Suggested methods for the applicant to demonstrate alternative cover
suitability are: (1) side-by-side comparison test of soil cover  and alternative material; (2) full-scale
demonstration; or (3)  short-term full scale tests.   Alternatives to  soil cover include fpams, polymer-
bonded paper applied in a slurry/spray form, removable and reusable geotextiles, tarps, wood chips, and
amended soils.   Alternatives may be used provided they control disease  vectors and odors without
presenting a threat to human health and the environment (EPA 1992a).       .             '

A daily cover, applied at the end of the operating day,  is one of the vector  attraction reduction options
allowed under §503.25(b).

Liner
  Statement of Regulation
                 liner is soil at synthetic material that has a hydraulic conductivity of 1 X Iff7 centimeters
                 per second or less,                                   ___ ,
A liner is an impediment used to retard the downward movement of liquid.  The liner must have a
hydraulic conductivity (the rate at which liquid moves through the liner) of 1  x 10~7 (one ten-millionth)
centimeters per second or less.  There are three general types of liners:  soil, flexible membrane and
composite.   A soil  liner is usually  composed of compacted clay.   Flexible membrane liners  (or
geomembranes) are generally polymeric materials, such as plastics and synthetic rubbers. Composite
liners are flexible membrane liners overlying a compacted low-permeability soil layer.

Appendix B describes  the types  of liners that are commonly used and  how the permit writer may
determine if a site has a liner that meets the above  hydraulic conductivity requirement and  would
appropriately be classified as a liner under Part 503.

Qualified Ground-Water Scientist
  Statement of Regulation'  '

    §503.21(1)     Qualified ground-water scientist Is an individual with a baccalaureate or post-graduate degree
                 in the natural sciences or engineering who has sufficient training and experience m ground-water
                 hydrology and related fields, as may be demonstrated by State registration, professional
                 certification, or completion of accredited university programs, to mafce sound professional
          :       judgments regarding ground-water monitoring, pollutant fate and transport,, and. corrective
                 action.
 The qualifications of a ground-water scientist are defined in Part 503 to ensure that professionals with
 appropriate qualifications and judgment capabilities are used.  The ground-water scientist must have an
 education and background that allows him or her to evaluate ground-water flow, ground-water monitoring
                                                5-5

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                             5.  SURFACE DISPOSAL - PART 503 SUBPART C
systems, and ground-water monitoring technologies and methods.  The ground-water scientist must be
able to solve solute transport problems and evaluate ground water remediation techniques.  The most
appropriate  education includes undergraduate or  graduate studies  in hydrogeolpgy, ground-water
hydrology, engineering hydrology, water resource engineering, geotechnical engineering, geology, or
ground-water modeling.  Although a ground-water scientist's  education may  vary from this list, the
individual's  education should be through  an accredited institution.   Some States have  certification
programs for ground-water scientists (EPA 1992a).

Sewage Sludge Unit
  Statement of Regulation

    §503.21(n)    Sewage sludge unit is land on which only sewage sludge is placed for final disposal. This does
                 not include land on which sewage sludge is either stored or treated. Land does not include
                 waters of the United States as defined in 4Q CFR 1,22,2,
A sewage sludge unit is usually a confined area of land within the surface disposal site used for the
disposal of sewage sludge (including a material derived from sewage sludge).  Some units will be lined
and employ leachate collection systems. Numerous types of structures fall within the definition of sewage
sludge unit, including excavated trenches or fill areas of varying dimensions and area fill mounds that
may actually be located in depressions on the surface of the land.
The remaining definitions from §503.21 and selected definitions from §503.9 are shown below for
reference purposes.
  Statement of Regulation                                      	  , t  ,,

    §503.21(a)    Active sewage sludge unit is a sewage sludge unit that has not closed.
                                                                                          ••-"?'(:.„
§503.9(b)


§S03.21(c)
                 Base flood is a flood that has a one percent chance of occurring in any given year (i.e., a flood
                 with a magnitude equalled once in 100 years).             '               ',< •
                 Contaminate an aquifer means to introduce a substance that causes flue maximum contaminant
                 level for nitrate iit 40 CFR 141.11 to be exceeded in ground water or that causes the existing
                 concentration of nitrate in ground water to increase when the existing concentration of 'nitrate
                 in the ground water exceeds the maximum contaminant level for nitrate jto 40 CFR. 141.11.
                                                                       ' '
                                                                                          s
    §SQ3.9(d)      Cover crop is a small grain crop, such as oats^ wheat, or barley, not grown for harvest.
                                                5-6

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
Statement of Regulations
  §503.21(e)     Displacement is the relative movement of any two sides, of a fault measured in any direction,

  §503.21(f)     Fault is a fracture or zone of fractures in any materials along which strata on one side are
                displaced with respect to strata on the other side.

  §503.9(j)      Feed crops are crops produced primarily for consumption by animals.

  §503.9(k)     Fiber crops are crops such'as flax and cotton.

  §503.2l{g)     Final covet is the last layer of soil or other material placed on a sewage sludge unit at closure.

  §503.9(1)      Food crops ate crops consumed oy humans.  This includes, but is not limited to,  fruits,
                vegetables, and tobacco,                          •          -
                                      1                     s
  §503.9(m)     Ground water is water below the land surface in the saturated zone.

  §503.21(h)     Holocene time is the most recent epoch of the Quaternary period, extending from the end of the
                Pleistocene epoch to the present.

  §503,21®     Leachate  collection system is a system or device installed immediately above  a liner .that is
                designed,  constructed, maintained,  and operated to collect and remove leachate  from a sewage
                sludge unit.                                       "          •            ,

  §503.21(k)     Lower explosive limit for methane gas is the lowest percentage of methane gas in ah", by volume,
              ,  that propagates a flame at 25 degrees Celsius and atmospheric pressure*

  §503,9(s)     Place sewage sludge or sewage sludge placed means disposal of sewage sludge on a surface
                disposal site,

  §S03.9(v)     Runoff is rainwater, leachate, or other liquid that drains overland on any part of a land surface
                and runs  off of the land surface.

  §503,21
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
 5.3     GENERAL REQUIREMENTS

 Section 503.22 CFR outlines four general requirements for placing sewage sludge on an active sewage
 sludge unit.   First, sewage sludge cannot be  placed  on an active  sewage sludge unit unless  the
 requirements of Subpart C are met.  Second, the active sewage sludge unit cannot be located within 60
 meters of a fault, in an unstable area, or in a wetland.  Third, the owner/operator of an active sewage
 sludge unit must submit a written closure and post-closure plan to the permitting authority 180 days
 before the unit is due to close.   Finally,  the owner of a surface  disposal site must provide written
 notification to the subsequent owner of the site that sewage sludge was placed on the land. The following
 sections discuss each of these requirements.

 5.3.1    COMPLY WITH THE PART 503 SURFACE DISPOSAL REQUIREMENTS
  Statement of Regulation
                                                                           1- Si,! ! 'H!^  > f
    §503.22(a)        No person shall place sewage sludge on an active sewage sludge unit unless the requirements
                    in this subpart are met,             ,  ,  '                   ->   - ^,.,       1WJ
 The first general requirement is that no person shall place sewage sludge on an active sewage sludge unit
 except in accordance with the requirements in the surface disposal subpart.  This general requirement
 places the responsibility on the person who places sewage sludge on an active sewage sludge unit to
 ensure that the requirements related to the surface disposal are met when the sewage sludge is actually
 placed on the unit.

 The person who places sewage sludge on the land could be either the preparer or the owner/operator of
 the surface disposal  site.  If the person who places the sewage sludge is not the preparer, she should
 request information from the preparer that indicates that the treatment-related Part 503 surface disposal
 requirements have been met, as appropriate. This includes pollutant concentrations in the sewage sludge,
 and whether pathogen reduction and vector attraction reduction is achieved through-treatment.

 5.3.2   LOCATION OF ACTIVE SEWAGE SLUDGE UNIT WITHIN 60 METERS OF A FAULT,
        IN AN UNSTABLE AREA, OR IN A WETLAND
  Statement of Regulation
                                                     •"     -,''•,  \J^    v     f           •• •"([•! ...JW *>•
    §S03.22(b)    An active sewage sludge unit located within 60 meters of a fault that has displacement m
                Holocene time; located in an unstable area; or located hi a wetland, except as provided in a
                permit issued pursuant to section 402 or 404 of the CWA, shall close by March 22,19S>4, unless, „
                m the case of an active sewage sludge unit located within  60 meters oif a fault that has
 	displacement in Holocene tane, otherwise specified by the permitting authority.
The permit writer should refer to Section 5.5 to determine whether the active sewage sludge unit is
located in any of the three prohibited or restricted areas identified above.  The specific sections that
address these requirements are:
                                             5-8

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                            5. SURFACE DISPOSAL - PART 503 SUBPART C
     •  Fault areas—Section 5.5.4                                           '

     •  Unstable areas—Section 5.5.5

     •  Wetlands—Section 5.5.6.                "                                                ,

The permit writer should develop specific permit conditions to require an active sewage sludge unit to
close if he has determined that one of the following situations exists:   -   •

     •  The  site is located within 60 meters of a fault with displacement  in Holocene time (i.e., last
        11,000 years) and has not been adequately designed to withstand seismic impacts

     •  The  site is located in an unstable area

     •  The  site is located in a wetland without a Section 402 or 404 permit.                    .   ,

Part 503 requires active sewage sludge units located as described above to close by March 22, 1994.
Therefore, all such active sewage sludge units are  in non-compliance unless, for those within 60 meters
of a fault with displacement in Holocene time, they have requested and received permission to remain
open from the permitting authority.  If the permit writer believes that an active sewage sludge unit falls
into one of the categories that requires .closure, she will need to ask the owner/operator why it has  not
closed and discuss possible enforcement actions. This will include development of a compliance schedule
that addresses  closure activities and time frames.
                              -/ '         '                                      '               '   '
5.3.3   WRITTEN CLOSURE AND POST-CLOSURE PLAN
  Statement of Regulation
    §503,22{c)     The owner/operator of an active sewage sludge unit shall submit a written closure and post
                 closure plan to the permitting authority ISO days prior to'ihe date that the active sewage sludge
                 unit closes.  The plan shall describe how fiffi sewage sludge unit will be closed and, at a
                 minimum, shall include:
             
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                            5.  SUM-ACE DISPOSAL - PART 503 SUBPART C
     •  Operation and maintenance of the leachate collection system if the unit has a liner and leachate
        collection system
                                                                                  \
     •  Methane gas monitoring if a final cover is placed on the unit

     •  Public access restriction to the site.

The permit writer has the authority and discretion during  the development of permit conditions to
elaborate on the Federal requirements  and to include additional requirements if needed.  For example,
the regulation uses general language in specifying what the closure and post-closure plan must cover -
i.e., how the leachate collection system will be operated and maintained, the system used to monitor for
methane gas, and how public access will be restricted. The permit writer may  develop more specific
permit conditions that detail what the discussion or description must contain.  Table 5-1  is an example
outline of a closure and post-closure plan.

The closure and post-closure plan  also  should  discuss post-closure  activities  - i.e., operating  and
maintaining the systems that prevent or monitor releases' from the unit and monitoring activities that will
be conducted throughout the 3-year period following the unit's closure. The plan  should provide the
following specific information:

     •  Name, address, and telephone number of a person to contact about the site

     •  Description of land use after closure, including any use restrictions

     •  Schedule or frequency at which post-closure activities are conducted

     •  Procedure for verifying that post-closure was provided in accordance with the plan

     •  Inspection and routine maintenance schedules  (e.g., site visits,  vegetation control)

     •  Personnel responsible for post-closure activities (e.g., company, title, responsibilities)

     •  Procedures for non-scheduled repairs

     •  Contingency plans (EPA  1992a).

Operation and Maintenance of the Leachate Collection System

Leachate can contaminate  ground water, surface water, arid soil if it  is not controlled.   If the active
sewage sludge unit has a liner and leachate collection system, the closure/post-closure plan must describe
how the leachate collection system will be operated and maintained for 3 years after closure. The owner/
operator must comply with all NPDES and other applicable requirements for leachate collection  and
disposal. The closure and post-closure plan should furnish specific information on the operating schedule,
leachate management plan, and the leachate removal schedule. Section 5.5.8  provides additional details
on the operation and maintenance of the leachate collection system.
                                              5-10

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                          5. SURFACE DISPOSAL - PART 503 SUBPART C
        TABLE 5-1  SAMPLE CLOSURE AND POST-CLOSURE PLAN OUTLINE
   Owner/Operator Name:
   Mailing Address:
   Telephone Number:
   Site Location Address:
I.    ACTIVE SEWAGE SLUDGE UNIT CONDITIONS

     A. General information
        1. Size of active sewage sludge unit (hectares or acres)
        2. Description of liner, if applicable
        3. Description of leachate collection system, if applicable
        4. Copy of NPDES permit if there are discharges to U.S. waters
     B. Schedule of final closure (milestone chart)
        1. Final date of sewage sludge accepted
        2. Date all on-site disposal completed
        3. Date final cover completed, if applicable
        4. Final date vegetation planted or other material placed
        5. Final date closure completed
        6. Total time  required to close the active sewage sludge unit

ri.   DISPOSING OF  SEWAGE  SLUDGE

     A. Total amount of sewage sludge to be disposed of on the active sewage sludge unit (m3 or yd3)
     B. Description of procedures for disposing of sewage sludge
        1. Size of surface disposal site, number of active sewage sludge units and size of units necessary for
           disposing of sewage sludge (include site map of disposal area)
        2. Design and construction of active sewage sludge units

m.  COVER AND VEGETATION

     A. Final cover, if applicable
         1. Total area  to be covered (m2 or yd2)
        2. Characteristics of final cover
           a.  Type(s) of material(s)       .                        •
           b.  Depth of material(s)
           c.  Total amount of material(s) required             .             .
        3. Final cover design
           a.  Slope of cover
           b.  Length of run of slope
           c.  Type of drainage and diversion  structures
     B. Vegetation (if vegetation is to be planted)
         1. Total area  requiring vegetation (hectares or acres)
     C.  Erosion Control (if vegetation is not to be planted)
         1.  Procedures and materials for controlling cover erosion
         2. Justification for procedures and materials used
                                              5-11

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                          5.  SURFACE DISPOSAL - PART 503 SUBPART C
  TABLE 5-1 SAMPLE CLOSURE AND POST-CLOSURE PLAN OUTLINE (Continued)
IV.  GROUND-WATER MONITORING, IF APPLICABLE

     A. Analyses required
        1. Number of ground-water samples to be collected
        2. Ground-water monitoring schedule (e.g., quarterly, semi-annually)
        3. Details of ground-water monitoring program
     B. Maintenance of ground-water monitoring equipment

V.   COLLECTION, REMOVAL AND TREATMENT OF LEACHATE

     A. Description of leachate collection system (i.e., pumping and collecting procedures), if applicable
        1. Description of the leachate sampling and analysis plan
        2. Estimated volume of leachate collected per month
     B. Description of leachate treatment process, if on-site
        1. Design objectives
        2. Materials and equipment required
     C. Disposal of leachate
        1. If discharged to  surface waters, include copy of NPDES permit
        2. If hauled off site, provide final destination
     D. Maintenance of equipment
        1. Repairs and replacements required
        2. Regular maintenance required over the duration of closure and post-closure periods

VI.  METHANE MONITORING, IF APPLICABLE

     A. Monitoring requirements
        1. Monitoring locations
        2. Frequency of analyses
     B. Maintenance of monitoring equipment
     C. Planned response to exceedences of limits

VH. MAINTENANCE ACTIVITIES

     A. Surface disposal  site inspections
        1. List all structures, areas, and monitoring systems to be inspected
        2. Frequency of inspections for each
     B. Planned responses to probable occurrences (including those listed below)
        1. Loss of containment integrity
        2. Severe storm erosion
        3. Drainage failure
     C. Maintaining cover and/or vegetation
        1. Cover maintenance activities and schedule
        2. Mowing schedule
        3. Reseeding and mulching schedule
        4. Soil replacement
           a. Labor requirements
           b. Soil requirements
        5. Fertilizing schedule
        6. Sprinkling schedule
        7. Rodent and bisect control program
                                            5-12

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
    TABLE 5.1  SAMPLE CLOSURE AND POST-CLOSURE PLAN OUTLINE (Continued)
       D. Controlling erosion
          1.  Maintenance program for drainage and diversion system
          2.  Activities required to repair expected erosive damage
          3.  Replacement cover soil, if applicable
             a.  Amount to be stored on site during the post-closure period
             b.  Specification  of  alternative sources  of  cover soil, if applicable (i.e.,  off-site  purchase
                agreement or on-site excavation)                     ,

  Vin. INSTALLATION OR MAINTENANCE OF THE FENCE, IF APPLICABLE

       A. If a fence already exists, describe required maintenance at closure to ensure it is hi good condition
       B. If fence is to be installed, specify:
          1.  Area to be enclosed
          2.  Type of materials used
          3.  Dimensions of fence                                                           *
       C. Security and public access practices planned for the post-closure period
          1.  Description of security system
          2.  Maintenance schedule

  IX.  CLOSURE SCHEDULE

       A. Schedule for closure procedures.       •       •                     .     '  '.
       B. Schedule of periodic inspections
Methane Gas Monitoring System                            ,

Methane gas is a byproduct of the anaerobic decomposition of organic matter and is explosive within a
certain concentration range in air.  Consequently, Part 503 requires continuous monitoring of air for
methane gas  at sites where the sewage sludge is  covered.  Additionally, air must be monitored for
methane for a period of 3 years after closure, if a final cover is placed on an active sewage sludge unit
at closure.  At sites where methane monitoring is required, air must be monitored inside structures at the
site and at the site boundary to prevent the accumulation of methane gas to levels that could cause hazards
such as explosions, fires,  and asphyxiation.

To provide for adequate monitoring  of methane for 3 years after an active sewage sludge unit Closes, the
closure and post-closure plan should specifically describe  the monitoring equipment.  Data must be
collected continuously and must be retained for 5 years.  Section 5.5.9 furnishes additional information
on methane monitoring and collection systems.

Public Access Restriction

Part 503 restricts public access to a closed sewage sludge unit to prevent:                     .

     •  Possible exposure to methane

     •  Direct contact with, or ingestion of, the sewage sludge or sewage sludge-soil mixture

     •  Traffic that could damage the final cover.
                                              5-13

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
Section 5.5.11 provides examples of proper public access control that should be described in the closure
plan.

Final Cover

If a final cover is placed on an active sewage sludge unit that is to be closed, the cover should be
designed to:

     •  Control volatilization of pollutants                      .

     •  Account for settling or subsidence in the unit

     •  Resist erosion

     •  Control runoff and prevent other damage to the cover.

The closure plan should describe how the final cover accommodates settlement and subsidence, caused
by decomposition and consolidation of the sewage sludge, which can impair the integrity of the final
cover system (EPA 1992a).   The plan should include  erosion control  to prevent surface water and
precipitation from damaging the cover if soil is removed from the cover or the cover system is somehow
degraded.  Erosion control should be designed to minimize the amount of water that flows across the
cover and, thus, minimize  damage to the unit's physical structure, prevent discharges of pollutants in
solution or suspension in the runoff, and limit downward percolation of water through the sewage sludge
that creates leachate.

When the final cover is installed, repairs and maintenance may be necessary for the cover to continue
functioning properly.  The permit writer should seek information on landfill closure technology,  design,
and maintenance procedures relevant to sewage sludge unit closure.  He may  use this information to
develop permit conditions that meet the requirements for closing an active sewage sludge unit.

5.3.4   NOTIFICATION TO SUBSEQUENT OWNER
  Statement of Regulation
     inr-mnxjjiju	tjl - Jv-:-IT--j-u-.-inr.-n.-rr                                    ,  /^\ ^J, J&S& -s 4, VK -S •,

    §503.22(d)    The owner of a surface disposal site shall provide written notification to the subsequent owner
                of the site that sewage sludge was placed on the land.
This section addresses the two issues that the permit writer will encounter in implementing  this
requirement: (1) identifying the type(s) of information that need to be provided to the subsequent owner
of surface disposal sites; and (2) determining an appropriate mechanism for ensuring that this information
is passed on to the subsequent owner. According to Part 503, a subsequent owner must be provided with
a written notification stating that the land has been used for surface disposal of sewage sludge.   The
notice should describe the sewage sludge disposal activities as well as provide specific details about the
design and operations of the site.
                                              5-14

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
The permit writer should consider requiring the following information in the notification statement: .

     •  Name(s) and address(es) of the former owner(s) and operator(s) of the surface disposal site

     •  Map of the surface disposal site clearly showing the geographical location of sewage sludge units
        as well as a depth profile of the former sewage sludge units at the surface disposal site

     •  Estimate of the total amount of sewage sludge that has been disposed in each sewage sludge unit
        at the surface disposal site

     •  Results of methane gas monitoring (if conducted)                       '

     •  Type of liner and leachate collection system installed, if appropriate, and leachate volume and
        characteristics

     •  Copy of any written closure and post-closure plan.                         ;         ~     '   ,

5.4    POLLUTANT LIMITS

Sewage sludge placed in an active sewage sludge unit  that is not equipped with a liner and a leachate
collection system must  meet pollutant limits for three metals:  arsenic, chromium,  and nickel.  The
specific pollutant limits to apply depend on the distance between the active sewage sludge unit boundary
and the surface disposal site property line.

No pollutant limits pertain to sewage sludge placed in  a unit that is equipped with a liner and leachate
collection system because the liner retards the movement of pollutants in sewage sludge into the ground
water.  Owners/operators of sites that have liners and leachate collection systems must demonstrate that
the liner meets the specifications in §503.210. If the liners are substandard, then the sewage sludge
placed in these units must meet the pollutant concentrations for unlined units.  -Appendix B  contains
information to assist in evaluating whether a liner was  designed, installed, and continues  to maintain a
hydraulic conductivity of 10~7 centimeters per second.                                             ,

The permit writer also may determine that the conditions of the active sewage sludge unit warrant the
development of site-specific limits. In this case, the permit writer may use the permittee's site-specific
data and the Tables in Appendix E to calculate site-specific sewage sludge pollutant limits.

The permit writer needs the following information to determine the appropriate pollutant limits applicable
to the sewage sludge placed on an active sewage sludge unit:

      •  Information on the liner and leachate collection system - in developing the specific pollutant
        •limits for sewage sludge placed in these units, it was assumed that the liner would achieve a
        minimum level of protection by slowing the passage of leachate through the liner to a rate of less
        than 10'7, centimeters per  second.  If a liner does not meet  this specification,  then the unit  is
        considered unlined for purposes of assigning pollutant limits to the sewage sludge placed in the
        unit.

      •  Distance between unit boundary and the site property line - the distance of 150 meters was one
        of the assumptions used when developing the Part 503 pollutant limits.   If the unit boundary is
        closer to the property line, the potential for ground water contamination may be  increased due
        to proximity to a well; therefore, the pollutant limits needs to be reduced.
                                               5-15

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
Step 1:   Initially, the permit writer should review the permit application and determine whether the
          permittee has requested site-specific pollutant limits.   Refer to Section 5.4.3  for further
          instructions for the use of site-specific limits.   If site specific limits are not requested or
          appropriate, continue to the next step.

Step 2:   Determine whether the active sewage sludge unit has a liner and leachate collection system.
          If it does, no pollutant limits apply.  If the unit does not have both a liner and a leachate
          collection system,  or if the  liner does  not meet the hydraulic conductivity  specification,
          continue to the next step.          -

Step 3:   For an active unit without a liner and leachate collection system, identify the distance from the
          unit boundary to the site property line.  If the unit boundary is located 150 meters or further
          from the site property line, apply the pollutant limits listed in Table 1 of §503.23.  Refer to
          Section 5.4.1 for further instructions on how to apply these limits.

Step 4:   If this distance is less than 150 meters, apply the pollutant concentration limits listed in Table 2
          of §503.23 for the appropriate actual distance.  Refer to Section 5.4.2 for further instruction
          on how to apply these limits.

In addition, the. permit writer must recognize that a surface disposal site may have several different types
of active  sewage sludge units and that the sewage sludge placed on site may be subject to  different
pollutant limits depending on the active sewage sludge unit in which it is placed. In such situations, the
permit writer will  have  to designate  different pollutant limits and  monitoring  and recordkeeping
requirements  for each active sewage sludge unit.

5.4.1  AN ACTIVE SEWAGE SLUDGE UNIT WITHOUT  A  LINER AND LEACHATE
       COLLECTION  SYSTEM WITH A UNIT BOUNDARY TO SITE PROPERTY LINE
       DISTANCE OF 150  METERS OR MORE
  Statement of Regulation                 ,                             "!. '£
                                        \   ','  -,,%1   n.  „-,,»>'  -  '  '^-*«
    §503.23      Pollutant limits (other than domestic septage)

    §503.23(a)    Active sewage sludge unit without a liner and leachate collection system

    §503.23(a)(l>  Except as provided in §503.23(a)(2) and .«,_,%•, <. £ •., s ;  •,  "
         600
         *•  *• $s >v^3/V *  f
         420
 *Dry weight basis
                                             5-16

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
The permit writer  applies the pollutant concentrations in Table  1  of §503.23  when  the following
conditions exist:

     •  The active sewage sludge unit does not have a liner and leachate collection system or has a liner
        that fails to meet specified hydraulic conductivity priteria

     •  The unit boundary is 150 meters or more from the property line of the surface disposal site.

The permit should contain the pollutants and pollutant limits that appear in §503.23(a)(l). These limits
should be expressed as the maximum pollutant concentrations not to be exceeded.  These limits should
also be expressed on a dry weight basis. The metric units (mg/kg) should be included in the permit, but
English units also can be used. Conversion factors are provided in Appendix A.

5.4.2   AN ACTIVE  SEWAGE SLUDGE  UNIT  WITHOUT  A  LINER AND  LEACHATE
        COLLECTION SYSTEM  WITH A UNIT  BOUNDARY TO SITE PROPERTY LINE
        DISTANCE OF LESS THAN 150 METERS
  Statement of Regulation

    §503,23     - Pollutant limits {other than domestic septage)

    §503,23(a)     Active sewage sludge unit without,a liner and leachate-collection system

    §503.23(a)(2)   Except as provided in §S03.23(b)» the concentration of each pollutant listed in Table 1 of §503,23
                 in Sewage sludgfe placed on an active sewage sludge unit whose boundary is less than 150 meters ,
                 from the property line of 8ie surface disposal site shall not exceed the eoncentratioa determined
                 Using the following procedure.
                              t   f  !
                 (i)   Theactual distance from the active sewage sludge unit boundary to the property line of the
                     surface disposal site shall be determined.

                 (ii)  The concentration of each pollutant listed in Table 2 of §503.23 in'the sewage sludge shall
                     not exceed the concentration in Table 2 of §503,23 that corresponds to the actual distance
                     in §S03,23(a)(2)(i),

          TABLE 2 OF §503,23 - POLLUTANT CONCENTRATIONS - ACTIVE SEWAGE
                  UNIT WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM
                           THAT HAS A UNIT BOUNDARY TO PROPERTY
                        ;     LINE DISTANCE LESS THAN 150 METERS
                 Unit boundary to
                 property'linfe
                 distance (meters)

                 0 to less than 25
                 25 to less than 50
                 50 to less than 75
                 75 to less than 100
                 100 to less than 125
                 125 to less than 150
                                                Pollutant concentration*
Arsenic
ftng/kg)

  30
  34
  39
  46
  S3
  62
Chromium
(mg/kg>

 200
 220
 260
 300
. 360
 450'
Nickel
tog/kg>

 210
 240
 270   %
 320
 390
 420
   *Dry weight basis
                                               5-17

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                             5. SURFACE DISPOSAL - PART 503 SUBPART C
The risk assessment methodology used in developing pollutant limits for sewage sludge placed in an
unlined active sewage sludge unit assumed that the boundary of each unit would be at least 150 meters
from the site property line of the surface disposal site.  Sewage sludge placed in an active sewage sludge
unit located closer than 150 meters from the site property line must meet more stringent pollutant limits
to ensure protection of ground water.

To determine the appropriate pollutant limits for an active unit without a liner and leachate  collection
system with a boundary that is less than 150 meters from the disposal site property line, the permit writer
must know the actual distance from the active sewage sludge unit boundary to the property line of the
surface disposal site.  This distance should be the shortest distance measured between any point on the
unit boundary to any point located on the property line of the  surface disposal site.

The permit writer should use the actual distance from the sewage sludge unit boundary to the property
line of the site  and read the corresponding pollutant limits for arsenic, chromium, and nickel from
Table 2 of §503.23. This procedure is illustrated in the worksheet in Figure 5-1.  The permit writer can
determine the applicable limits by using this worksheet and following the example provided in the figure.

The permit should include the pollutant limits that appear in §503.23(a)(2) for the actual distance from
the unit boundary to the site property line.  These limits should be expressed as the maximum pollutant
concentrations not to  be exceeded.  These limits should be  expressed on a dry weight basis  using the
metric units (mg/kg),  but English units can also be used. Conversion factors are provided in  Appendix
A.                                                         .

5.4.3   SITE-SPECIFIC POLLUTANT LIMITS
  Statement of Regulation
    §503.23
Pollutant limits (other than domestic septage)
    §503.23(b)    Active sewage sludge unit without a litter and kachate collection system - site-specific limits
                                                         * ..cU*       •,        •"    * •.  ""
                                                     1^ ..  ^ V * ^   •,    V       ( _,    ^ &      V „ ., »
    §503.23(b)(l)  Attire time of permit application, the owner/operator of a surface disposal site may request site-
                 specific pollutant limits in accordance with §503.23(b)(2) 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 §503*23 and when the permitting authority determines that site-
                 specific pollutant limits are appropriate for the active sewage sludge unit.
                                                             A -. HK4 IK      ' .,  &''s'~ "**           r,.   s
    §503.23(b)(2)  The concentration of each pollutant listed in Table 1 of §503,23 to sewage sludge placed on an
                 active Sewage sludge unit without a Jiner and leachate collection system 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*                                 -            - -    '
Site-specific pollutant limits can be developed for active sewage sludge units without liners and leachate
collection systems. If the owner/operator of a surface disposal site requests site-specific pollutant limits,
the permit writer will need to determine if such a request is valid and if site-specific pollutant limits are
appropriate.  Thereafter, he should use the  information hi Appendix E to determine the site-specific
pollutant concentration limits.  To determine whether a request for site-specific pollutant limits is valid,
the permit writer  should request current information on specific site parameters  and  compare this
information to the values used in developing the pollutant limits in §503.23(a).
                                                5-18

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                       5. SURFACE DISPOSAL - PART 503 SUBPART C
The permit writer should follow these steps to determine the appropriate pollutant concentration limits to
apply to an active sewage sludge unit that does not have a liner and leachate collection system or to a unit
whose liner fails to meet the hydraulic conductivity requirements:

Step 1:  Obtain the actual distance from the active s.ewage sludge unit boundary to the site property line.

Step 2:  Review the columns in the table below to locate the range containing the distance obtained in
        Step 1.                                    ,           •   :

Step 3:  Incorporate the pollutant limits provided in the appropriate column into the permit for the surface
        disposal site.

       POLLUTANT CONCENTOATIONS FOR AN ACTIVE SEWAGE SLUDGE UNIT
              WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM
                               (milligrams  per kilogram*)
Pollutants
Arsenic
Chromium
Nickel
^150
73
600
420
<15€kSil25
62
450
420
<125«S»100
53
360
390
<:iOD-:>75
46
300
320
< 75« as SO
39
260
270
<50*St25
34
220
240
<2S-^0
30
200
210
*Dry weight basis
 For example, to obtain the pollutant limits for an active sewage sludge unit whose boundary is
 located 88 meters from the site property line, the permit writer would review the above table to
 identify the distance range,  <100  to >75 meters.   The following pollutant  limits would be
 included hi the permit:

     Arsenic     46 mg/kg
     Chromium 300 mg/kg
     Nickel     320 mg/kg
            FIGURE 5-1  WORKSHEET FOR CALCULATING POLLUTANT
      LIMITS FOR ACTIVE SEWAGE SLUDGE UNITS WITHOUT LINERS AND
                        LEACHATE COLLECTION SYSTEMS
                                          5-1?

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                             5.  SURFACE DISPOSAL - PART 503 SUBPART C
 The permit writer should  consult Appendix E to determine if the site-specific parameter values are
 substantially different from those used in developing the §503.23(a) pollutant limits.  Before proceeding
 with the site-specific assessment, the permit writer should review all available sewage sludge pollutant
 concentration data.  The site-specific limits issued in the permit must be the lower of either the values
 derived from the site-specific tables or the existing concentration of the pollutant in the sewage sludge.

 5.5    MANAGEMENT PRACTICES

 5.5.1   ENDANGERED SPECIES OR CRITICAL HABITAT  PROTECTION
   Statement of Regulation                                      '             "     <    .,,

     §S03.24(a)    Sewage sludge shall not be placed on an active sewage sludge unit if it is likely to adversely affect
                 a threatened or endangered species listed under section 4 of the Endangered Species Act or its
                 designated Critical habitat.
 Permitting Factors

 Active sewage sludge units are often located in rural areas that either contain or are surrounded by a wide
 variety of plant, fish, and wildlife species,  some of which may be endangered or threatened.  The
 designated critical habitat is any place where  a threatened or endangered species lives and grows during
 any stage in its life cycle. All threatened or endangered species of plants, fish, and wildlife are listed
 in 50 CFR §§ 17.11 and 17.12. A copy of the lists with references to the original Federal Register listing
 notice can be obtained from the U.S.  Department of Interior, Fish and Wildlife Service (FWS).

 The permit writer may need to verify if any endangered or threatened species of plant, fish, or wildlife
 exist on or near the active sewage sludge unit. In addition, a surface disposal site may be located in the
 migratory route of  an endangered or threatened species of fish or wildlife and may become a temporary
 but  critical habitat for such species.  The permit writer  can  obtain such information  or  verify the
 information provided in the permit application by contacting the  field office of the FWS.  To provide the
 permit writer with the requested information, the FWS biologist may need specific data, such as the exact
 location (preferably in terms of latitude and longitude), the size of the site, location and size of any
 nearby body of water, and type and extent of vegetative cover.

 If threatened or endangered species or their designated critical habitats are present in the areas proposed
 to receive the sewage sludge, the permit writer will need to determine whether the placement of the
 sewage sludge  on the active sewage sludge unit  will likely cause an adverse effect upon the species or
 their habitats.  An adverse effect would be the destruction or adverse modification of the critical habitat
 to the extent that the likelihood of survival and recovery of the species is diminished. Unfortunately, it
 may not be possible to predict the effects of the placement of sewage sludge on the species or habitat
 without site  specific field studies.  In some  cases, it may be necessary to prohibit the application of
 sewage sludge on sites where threatened or  endangered species or their critical habitats are present.
 However, it may be possible to  allow the placement of sewage sludge concurrent with field studies
 designed to measure the  effects  on the species  and their  habitats.  EPA policy or best professional
judgment (BPJ) should be used if specific management practices  are necessary to protect the species and
 their habitat.
                                              5-20

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
Permit Conditions

Section 503.24(a) only applies if endangered species of plant, fish, or wildlife are identified within or
near an active sewage sludge unit or if it is determined that the unit is located in the migratory path of
any endangered or threatened species of wildlife.   However, as a precautionary measure,  the permit
writer may include this management practice in the permit as it appears in Part 503.

If it is  determined  that the active  sewage sludge unit supports or is part of a critical habitat for a
threatened or endangered species of plant, fish, or wildlife, the permit writer should consult with FWS
personnel or other informed State or local agency personnel to determine and develop necessary permit
conditions.1 For example,  if the unit is located within the migratory path of an endangered species, the
permit writer could develop a permit condition prohibiting the application of bulk sewage sludge during
the migration period.

Other conditions that the permit writer may include are the following:

      •  Buffer zones that provide an adequate distance from the critical habitat of the endangered species

      •  Requirements for increased monitoring and reporting in certain areas

      •  Requirements to conduct special studies to determine the impact on the endangered species or its
        critical habitat.

5.5.2  BASE FLOOD FLOW RESTRICTIONS
  Statement of Regulation

    §50$.24{b) '   An active sewage sludge unit shall not restrict the flow of a base flood.
 Permitting Factors

 The siting of active sewage sludge units on areas
 subject to flooding requires special considerations
 to ensure that the flow  of  floodwaters  is not
 restricted.  Restricting the flow of a base flood
 can increase the velocity of the flow downstream
 of the site, reduce the temporary storage capacity
 of the flood plain, or increase the level  of the
 flood waters.
Base flood is a flood that has a one percent
chance of occurring in any given year (i.e.* a
flood with a magnitude equalled once in 100
years), [§503.9(b)l
 An active sewage sludge unit located in the base flood area that affects the flow of the base flood and
 flood water storage capacity of the flood plain is acceptable, unless the effect is large enough to cause
 higher flood levels and greater flood damage.  If the owner/operator of the active sewage sludge unit can
 demonstrate that the active sewage sludge unit will not pose unacceptable threats of higher flood levels
     'FWS and EPA are in the process of developing consultation guidance for such permitting activities.
                                               5-21

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
and flood velocity, the requirements of this provision are met.  If this demonstration can not be made,
the owner/operator must close the active sewage sludge units located in the 100-year flood plain. Closure
must be performed in accordance with the closure and post-closure plan required by §503.22(c).
                                                 Restriction of the. flow of a base flood is defined as
                                                 the raising of flood levels by one foot or jaore doe
                                                 to the presence of an obstruction.
 The permit writer should first determine whether
 the active sewage sludge unit is located within an
 area that is likely to be inundated during the 100-
 year base flood (i.e., within the 100-year flood
 plain).  River flood plains are readily identifiable
 as the flat areas adjacent to the river's normal   mmmmmtiitmmmmmmimmmiimmmmiiimamii^^
 channel.  The 100-year flood plains are identified
 in the flood insurance rate maps (FIRMS) and flood boundary and floodway maps published by the U.S.
 Federal Emergency Management Agency (FEMA).  Guidance in using FIRMS is provided in "How to
 Read a Flood Insurance Rate Map" published by FEMA.  FEMA also publishes "The National Flood
 Insurance Program Community Status Book" which lists communities that are in Emergency or Regular
 Flood Insurance programs,  including communities that may not be involved in  the  National Flood
 Insurance  Program but which have FIRMS or floodway maps published.   Maps and other FEMA
 publications may be obtained from the FEMA Distribution Center. Areas not covered by the FIRMS or
 floodway maps may be included in flood plain maps available through the U.S. Army Corps  of
 Engineers, the U.S. Geological Survey (USGS), the U.S.. Soil Conservation Service, the Bureau of Land
 Management,  the Tennessee Valley Authority, and State and local agencies. Many of the river channels
 covered by these maps may  have undergone modification for hydropower or flood control projects and
 the flood plain boundaries represented may not be accurate or representative.  The permit writer may
 want to compare the flood plain map series to recent aerial photographs to identify current river channel
 modifications  and land use watersheds that could affect flood plain designation (EPA 1992a).

 If flood plain maps are not available and the surface disposal site is located within a flood plain; then a
 field study to  delineate the 100-year flood plain may be required. A flood  plain delineation program
 would be based primarily on meteorological records and physiogeographic information, such as existing
 and planned watershed land use, topography, soils and geologic mapping, and aerial photo interpretation
 of geomorphic (land form) features.   The U.S.  Water Resource Council provides  information  to
 determine the  potential for floods in a given location by stream gauge records. Estimation of the peak
 discharge by these methods also allows an estimation of the probability of exceeding the 100-year flood
 (EPA 1992a).

 If the active sewage sludge units are not  located on the 100-year flood plain, the permit writer need not
 include any condition in the  permit.  However, if the surface disposal site is located near a flood plain
 and there is a potential that future active sewage sludge units may be placed in the flood plain, the permit
 writer should include a permit condition that any active units constructed or placed in service during the
 term of the permit must not  restrict the flow of the base flood.

 If the active sewage sludge unit is located in a 100-year  flood plain,  the permit writer must evaluate
 whether the sewage sludge unit will restrict the flow of a base flood. The demonstration that the active
sewage sludge unit does not restrict the flow of a base flood relies on estimates of the flow velocity and
volume of flood plain storage in the vicinity of the active sewage sludge unit during a base flood.  The
assessment should consider the flood plain storage capacity and floodwater velocities that would exist in
the absence of the active sewage sludge  unit. Raising the base flood level by more than one foot can
                                            5-22

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
indicate that the active sewage sludge unit may reduce and restrict storage capacity and flow.  In some
smaller areas, a greater than one foot increase in the flood level may be acceptable (EPA 1992a).,

The assessment of flood water velocity will require that the channel cross section be known above, at,
and below the active sewage sludge unit.  Friction factors on the overbank are determined from the
surface conditions and vegetation present.  River hydrologic models may be used to simulate flow levels
and estimate flood velocities through these river cross sections. The U.S.  Army Corps of Engineers has
developed several numerical models to aid in the prediction of flood hydrographs, flow parameters, the .
effect of obstructions on flow levels, the simulation of flood control structures, and sediment transport
(COB  1982).

If the permit writer determines that the active sewage sludge unit will restrict base flood flow, she may
need to write site-specific conditions into  the permit that will prevent restriction of the  flow of a base
flood or require closure of the active sewage sludge units.   To determine whether to draft such site-
specific  conditions,  the permit writer will  require additional information about the site, the design
parameters of the active sewage sludge units, and  management practices that will be used to prevent
restriction of the base flood. The permit writer also may need to develop  permit conditions that require
the active sewage sludge unit to be adequately protected from flood damage, such as embankment designs
with rip-rap and geotextiles to prevent scour.  Guidelines for design with these materials may be found
in Maynard (1978) and the Department of Agriculture (1983).  Embankment designs  will require an
estimate of river flow velocities, flow profiles (depth), and wave activity.  The use of alternative erosion
controls such as gabions (cubic-shaped wire structures filled with stone), paving bricks, and mats may
be considered (EPA 1992a).

5.5.3   REQUIREMENTS IN A SEISMIC IMPACT 2ONE
  Statement of Regulation

    §503.24(c)    When a surface disposal site is located in a seismic impact zone, an active sewage sludge unit
                 sftaB be designed to, withstand the maximum recorded Horizontal ground teyel acceleration.
                                                   Seismic Impact zione is an area that toas a 10 percent
                                                  " or- greater probability that the horizontal ground
                                                   level acceleration of the tock in the-area exceeds
                                                   (UQ gravity once in 250 years.  [§503.21{m)J
Permitting Factors

Ground  motion  from earthquakes  can cause
structural failure  of the  active  sewage  sludge
unit(s).  Studies indicate that, during earthquakes,
superficial  (shallow)   slides  and  differential   ^^w^^m^^^t^^^
displacement are produced, rather  than massive
slope failures (Dept. of Navy 1983).  Stresses
created by superficial failures can affect liner and final cover systems, and leachate and gas collection and
removal system performance.  For  example, tensional stresses within the liner system can fracture the
soil liner and/or tear the flexible membrane  liner.  The effects of seismic activity on earth material are
discussed in Section 5.5.5.                 ,                                 .

First, the permit writer should determine whether the surface disposal site is located in a seismic impact
zone. If it is, the permit writer must require  that the owner/operator ensure that the active sewage sludge
units are designed to withstand the  maximum recorded horizontal ground level acceleration.  Table 5-2
lists documents and Table 5-3  identifies governmental and  non-governmental organizations that can
                                               5-23

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
 provide  information on  seismic impact zones and seismic hazards.   These lists  are not a complete
 compilation of sources for seismic information but should provide the permit writer with enough
 information to make an informed decision.

       TABLE 5-2  SOURCES OF INFORMATION ON SEISMIC IMPACT ZONES AND
                                       FAULT AREAS
    "Preliminary Map of Horizontal Acceleration in Rock With 90% Probability of Not Being Exceeded in
    250 Years" - Algermissen and Perkins, Probabilistic Estimates of Maximum Acceleration and Velocity
    in Rock in  the Contiguous United States, U.S. Geological Survey Open-File Report 82-1033,  1982
    (Updated 1991) Available from .USGS Map Center.

    Preliminary  Young Fault Maps, MF916, U. S.  Geological Survey,  1978  -identifies the location of
    Holocene faults in the United States.  Available from USGS Map Center.

    National Aerial Photographic Program/National High Altitude Program (NAPP/NHAP) high altitude,
    high resolution aerial photographs. Available from U.S. Geological Survey, EROS Data Center.

    USGS State seismic maps - USGS Map Distribution

    Building Seismic .Safety Council, "NEHRP Recommended Provisions  for the Development of Seismic
    Regulations for New Buildings"  (U.S. Federal Emergency Management Agency 1991).  Available  from
    FEMA.
      TABLE 5-3 GOVERNMENTAL AND NON-GOVERNMENTAL ORGANIZATIONS
                    THAT MAY PROVIDE SEISMICITY INFORMATION
    USGS                  '                                                   .    .

    Earthquake Information Center, Colorado School of Mines, Golden, Colorado (seismicity maps of all 50
    states and a database of known earthquakes and fault zones)

    State Geologic Surveys

    The National Information Service for Earthquake Engineering

    The Building Seismic Safety Council

    The American Institute of Architects            ,                                  •
If active sewage sludge units are located in seismic impact zones, the permit writer should determine the
amount of risk posed by geological and hydrogeological conditions. The permit writer should investigate
the following potential site hazards:

     • Liquefaction (the partial or total loss of shear strength of loose, saturated fine sands as a result
       of an increase in pore water pressure; the soil acts like a liquid)

     • Soils with low foundation strength

     • Slope instability
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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
                                                  The  horizontal  acceleration is expressed  as a
                                                  percentage of the acceleration due to gravity (g).
                                                  The acceleration due to gravity is £,8 meters/sec1.
     •  Ground deformation

     •  Fault rupture.

For active sewage sludge units located in an area
with   an   estimated ,  maximum    horizontal
acceleration greater than  0.1 gravity (g),  the
permit  writer's  evaluation  of seismic  effects
should consider both foundation soil stability and  ^•^•^^^••M^^^H
sewage sludge stability under seismic loading.
Conditions that may be considered for the evaluation include the construction phase (maximum open
excavation depth of new active sewage sludge unit) and closure activities.

There are no  standard  procedures for  designing  active sewage sludge units for seismic  events.
Winterkorn and Fang (1975) and Department  of the Navy (1983) do, however, review engineering
evaluations that consider the influence of local soil conditions on ground response and shaking intensity,
soil settlement, soil liquefaction,  and slope instability during earthquakes.  Design modifications to
accommodate  an earthquake may include shallower active sewage sludge unit side  slopes and more
conservative design of dikes and  runoff controls.  Well compacted cohesion-less  embankments or
reasonably flat slopes in insensitive clay are less likely to fail under moderate seismic shocks (up to 0.15g
and 0.20g acceleration). Additional contingencies should be installed for leachate collection in the event
primary systems  are disrupted. The materials that make up the individual components must be able to
withstand seismic forces while contributing to the unit's strength.  New active sewage sludge units can
be designed to these standards or to the requirements of this part (EPA 1992a).

5.5.4   REQUIREMENT OF 60 METERS OR MORE FROM A FAULT
  Statement of Regulation
                                             -•*''''
    §303.24(d)    An active sewage sludge unit shall he located 60 meters or nidre  from a fault that  has
                displacement in Holqcene time unless 0thenMse specified fey the permitting authority*
Permitting Factors

Seismologists generally believe that the structural integrity of an engineered unit cannot be unconditionally
guaranteed when it is built within 60 meters (200 feet) of a fault along which movement is highly likely
to occur (EPA  1991b).   A 60  meter (200 feet) buffer zone is, in most  cases, sufficient to protect
engineered structures from seismic damages. The permit writer must first determine whether an active
sewage sludge unit is within 60 meters (200 feet) of a fault that has had movement during the Holocene
epoch. To make this determination, the permit writer should obtain information on any lineaments that
suggest the presence of any faults within a 915 meter (3,000 foot) radius  of the site.  Sources  of the
information are:

     • A review of available maps, logs, reports, scientific literature, or insurance claim reports

     • An aerial reconnaissance of an area within a five mile radius of the site, including an aerial photo
        analysis
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
      •  A  reconnaissance  based  on  walking
        portions of the  area within 915 meters
        (3,000 feet) of the unit (EPA 1992a).

In  1978,  the  USGS published a map  series
identifying the location of Holocene faults m the
United  States (Preliminary  Young Fault Maps,
MF916).   For an area where movement along a
Holocene fault is known to have occurred since
1978, when the maps were made, the owner/
operator  will  need  to conduct  a  geologic
reconnaissance of the site and surrounding areas.
The  National   Aerial  Photographic  Program/
National High  Altitude Program (NAPP/NHAP)
aerial photographs with  stereo coverage  are  a
useful remote  sensing aid for  delineating fault
traces and structural lineaments. This series  of
aerial photography provides coverage over most
of the United States and is available through the
USGS, EROS Data Center (EPA 1992a).  Tables
5-2 and 5-3 list sources of more information about
   A fault is a fracture or a zone of fractures in
   any materials along which strata on one side
   are 'displaced with respect to strata on the other
   side.  [§503,21(1)3  A fault may have sudden
   movement  or   it  may  have   very  slow
  , movement,  A fault includes main, branch, or
   secondary faults.

   Displacement is the relative movement of any
   two sides of a fault measured in any direction.
   [§503.21(6)]    "   7"   "  '

   Holocene time is the most recent epoch of the
   Quaternary  period, extending from the end of
   the Pleistocene Epoch to the present This is
   approximately    the   last   11,000  years,
   [§503.21(h)]
fault areas.
If a fault (or faults) is located within 915 meters (3,000 feet) of the active sewage sludge unit, the owner/
operator should investigate further and determine the presence or absence of any faults within 60 meters
(200 feet). A fault may be located by performing one or more of the following activities:

     •  Conducting a site walkover to detect any fault related phenomena, such as offset curbs or walls,
        offset drainage channels, or fault scarps

     •  Conducting subsurface exploration,  including drilling and trenching to locate fault zones and
        evidence of faulting

     •  Trenching perpendicular to any fault or lineaments within 60 meters (200 feet) of the unit

     •  Determining the age of any displacements

  •   •  Constructing supporting maps and other analyses (EPA  1992a).

Displacement of surficial deposits across a fault may indicate that such displacement has  occurred in
recent times.  In addition, seismic epicenters recorded in recent times may indicate recent movement or
activity along structures  in a  given area.  The results  of the investigation  should be prepared by a
qualified professional.  Data that should be contained in  the report are:

     •  A plan view of any faults within 915 meters (3,000 feet) of the site

     •  A map showing all faults within 60 meters of the unit boundary and identification of faults that
        have had movement during the Holocene epoch
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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
     • A site topographic map of sufficient detail to show any offset streams, linear ridges, fault scarps,
       and other horizontal features

     • A description of geology with respect to stratigraphy (e.g., comparison of soils across a fault)
       which can determine the fault's age.

Permit Conditions

If an active sewage sludge unit is not-located within 60 meters (200 feet) of a fault that has displacement
in Holocene  time, the permit writer does  not need to place any conditions addressing this Part 503
requirement in the permit.

If an active sewage sludge unit is located within 60 meters of a fault that has displacement in Holocene
tune, the permit writer must require the unit to be closed, if she cannot conclude that continued operation
of the active sewage sludge unit is protective to human health and the environment. If an active sewage
sludge unit is not located within 60 meters of a fault that has displacement in Holocene time, but is
located within 915 meters (3,000 feet) of a fault that has displacement in Holocene time, the permit writer
might consider additional requirements.  These could include (1)  a requirement to map all fault traces
within 915 meters; (2) a requirement that all engineered structures must be at least 60 meters from any
fault; or (3) a requirement to  submit a site engineering plan that  contains the  investigative report and
mapping of all faults.

5.5.5   UNSTABLE AREAS
  Statement of Regulation         -  ,

    §S03.24(e)    An active sewage sludge unit shall not be located in an unstable area.
Permitting-Factors

The permit writer should be able to recognize
unstable areas such as landslide-prone areas, karst
terrain,  volcanic regions, areas  that  overlay
extensive underground mining  operations, and
areas that overlay oil, gas, or water withdrawal
operations.   The owner/operator should certify
that an active sewage sludge unit is not located in
an unstable area.  The permit writer may want to
require  the  owner/operator   to   conduct  . an
engineering assessment if the unit is located in a
potentially unstable area.  This assessment should
be  performed   by   a  qualified  engineering
professional and 'should contain the following
information:
Unstable area is land subject to natural or
human-induced forces that  may  damage the
structural components of an active sewage
sludge disposal unit.  This includes, but is not
limited to, land on which the, soils are subject
to mass  movement.   (§503.21(q)]  Unstable
areas have  features  that indicate protective
measures cannot be designed to withstand a
natural event.  Examples  of unstable areas are:
areas within 60 meters of a fault, karst terrains,
fissures,   surface   areas    weakened   by
underground mining  or  other excavations or
oil, gas, or water withdrawals, and areas near
volcanoes.
        A detailed  geotechnical and  geological  ^^^^^^^^^^^^ma^^^m
        evaluation to  assess the stability of the
        foundation soils, adjacent man-made and natural embankments, and slopes
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
     •  A geotechnical evaluation of the ability of the subsurface to support the active sewage sludge unit
        adequately, without damage to the foundation or other structural components.
                                            '"            ,           *
Landslide-Prone Areas

Landslides are a problem that can be remedied with varying degrees of success.  Recognizing areas
susceptible to downslope movements is important to design considerations.  Many features are unstable
when combined with seismic impact zones, such as liquefaction potential and slope failure. The type of
slope material determines the earthquake resistance of the slope. The permit writer should require the
owner/operator to assess the slope materials in areas subject to seismic activities.  Slope stability maps
should be available from State geological surveys.  Slope materials  vulnerable to earthquake shocks
include:                                                         .

     •  Very steep slopes of weak, fractured and brittle rocks or unsaturated loess that are vulnerable to
        transient shocks caused by tensional faulting

     •  Loess and saturated sand that may be liquefied by seismic shocks causing the sudden collapse of
        structures and flow  slides

     •  Sensitive cohesive soils when natural moisture exceeds the soil's liquid limit

     •  Dry cohesion-less material on a slope at the angle of repose that responds to seismic shock by
        shallow sloughing and slight flattening of the slope (Winterkorn and Fang 1975).

Where the active sewage sludge units  are comprised of the above types of slope materials, the permit
writer should require closure of the units in areas where seismic activities occur.

Slope failures occur when the driving forces imposed on the soils  or engineered structure exceed the
resisting forces of the material.  Such a slope failure often occurs in the absence of seismic activity.  Non-
seismic slope failure can be caused by:

     •  Excessive rainfall on steep slopes

     •  Removing the toe (downslope edge) of a slope
                                               s
     •  Overloading a slope

     •  Removing vegetation from a slope.

The site can be evaluated by a site walkover to find evidence that may indicate a potential landslide
problem.  Specific features to look for include:

     •  Retaining walls, fences, and posts that are aligned in a uneven pattern

     •  Utility poles with taut or sagging wires

     •  Hummocky or step-like ground features

     •  Seeping water from the base or toe of a slope.
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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
A computer software package and technical manual, Geotechnical Analysis for Review of Dike Stability
(GARDS), developed by EPA's Risk Reduction Engineering Laboratory (RREL), can assist in evaluating
earth dike stability.  GARDS details the basic technical concepts and operational procedures for the
analysis of site hydraulic conditions, dike slope and foundation stability, dike settlement, and liquefaction
potential of dike,and foundation  soils.  The program was designed as a geotechnical support tool to
facilitate evaluation  of existing arid proposed earthen dike  structures at hazardous waste  sites  (EPA
1988b).  The GARDS concepts also apply to active sewage sludge disposal units.

The permit  writer may want to include monitoring activities that could indicate potential problems.
Monitoring parameters may include settlement, lateral movement and pore water pressure.  Monitoring
for pore water pressure usually is accomplished with piezometers screened in the particularly sensitive
strata.  Lateral  movements  may be  detected ,on the surface by surveying  (horizontal and vertical)
movements  while subsurface movements may be detected by slope  inclinometers.  Settlement may be
monitored by surveying benchmarks.

Karst Terrain                                                                                ,

Karst terrains are subject to progressive and/or catastrophic  failure of subsurface conditions from sink
holes, solution cavities, and subterranean caverns. Therefore, no active sewage sludge units should be
located  in Karst terrain.

Underground Mining Operations

Areas with extensive underground mining operations are subject to catastrophic failures and subsidence
in a manner similar to karst terrains. Some mining operations may weaken the structural support for the
overlying strata.  In extreme cases, roof collapse of the mine could cause a catastrophic failure of any
overlying engineered structures.   Mine grouting or filling actions may not be feasible  due to the
uncertainty  in the volume that is required to successfully fill the void and the interconnections between
mines and breached barrier pillars.  State mining departments can be contacted to obtain mine maps.
Streets or roads located over land subject to underground  mining operations that have a wavy, uneven
pitch are good indicators of subsidence.

Oil, Gas, and Water Withdrawal Operations

Oil  and gas operations and/or water pumping  operations  can lead to locally developed subsidence
condition that can damage structural components. Oil arid gas extraction subsidence tends to be more
localized than subsidence due to water pumping operations.  Subsidence due to oil and gas and/or water
pumping operations  occasionally can be reversed. To do this, water is injected into a formation to raise
the fluid pressure in the formation.

Permit Conditions

Where  a surface disposal site is located in an unstable area, the permit writer should develop a permit
condition that prohibits the siting  of any active sewage sludge units in unstable areas. Where an existing
unit is located over  potentially unstable areas (such as karst topography  or landslide-prone areas) > the
permit  writer  should  require the  owner/operator  to submit a detailed geotechnical and geological
evaluation of the area and an engineering analysis of the design measures to ensure that the active sewage
sludge unit has sufficient ground support to withstand any ground movement that could rupture the unit's
integrity and cause a release,of the sewage sludge pollutants.  These investigations should be performed
                                               5-29

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
by qualified ground-water and engineering professionals.  Existing active sewage sludge units located in
unstable areas must have closed by March 19, 1994, to be in compliance with Part 503.

5.5.6   WETLAND PROTECTION
  Statement of Regulation

    §503.24(1)     An active sewage sludge unit shall not be located in a wetland, extent as provided in a permit
                issued pursuant to section 402 or 404 of the CWA.                   	

                                                  If wetlands are within the surface disposal site
                                                            •,     •,      •, y  \ A'iiW.liy ss&J i      *
                                                  boundary and the owner/operator  plans to
                                                  locate an active sewage siudge  unit within a
                                                  wetland, the owner/operator must apply for and
                                                  receive a Section 404 permit from the U+S.
                                                  Army Corps of Engineers.  If an active sewage
                                                  sludge unit  is currently located  in a wetland,
                                                  the owner/operator  should produce a  valid
                                                  Section 404"permit  or a NPDES  permit to
                                                  demonstrate compliance  with this  regulatory
                                                  provision.
Permitting Factors

EPA, the U.S. Army Corps of Engineers (COE),
and FWS have identified wetlands protection as a
top priority. Constructing and operating active
sewage sludge units in wetland areas is essentially
a  fill  activity;  therefore,  this  activity  has  the
potential to significantly alter  the structure and
function of a wetland.  Once damaged by  fill
activities,  wetland ecosystems  are  difficult  or
impossible to restore because of their complexity
and fragility. Proposals to locate active sewage
sludge units in wetlands should undergo rigorous
demonstration requirements to establish that there
are no suitable alternative locations.  COE is the                            ^	.,	_ y^:
Federal  agency  with jurisdiction  for  issuing   ^^^^gaiiB^BBiBiiiiiBBgB^^iBaBMiiiiBii^iiaBiiM
permits to  entities proposing fill activities in wetlands.  Fill activities in, wetland areas are regulated by
the COE and EPA under Sections 404 and 402 of the CWA.  Many States also regulate activities in
wetlands.

Any active sewage sludge unit  located hi a wetland and not covered by a valid Section 404 or NPDES
permit must have been closed in accordance with §503.22(b) by March 22, 1994.  An owner/operator
of a surface disposal site that is planning construction or opening of a new active sewage sludge unit must
determine whether the proposed location or construction activity is subject to Section 404 and obtain  a
Section 404 permit,  if applicable, prior to project initiation.

To implement §503.24(f), the permit writer first needs  to know if any active sewage sludge units are or
will be located within a  wetland.  As part of the permit application, the permit writer should receive
information as to whether the active sewage sludge unit  is located in a wetland. If this information is not
provided, the permit writer should require the owner/operator of the surface disposal site to indicate
whether it  holds or is applying for a valid Section 404  or 402 permit.

If the permittee does not have  a Section 404 or 402 permit, the permit writer needs  to determine (or
require the owner/operator to certify) whether there is a wetland onsite.  Wetlands are identified on the
basis of soil conditions, vegetation type,  and site hydrology.  They are typically found along the fringe
of waterbodies.  Some types of wetlands such as prairie potholes, vernal pools,  and cypress domes are
not directly associated with surface water, but are found in surface depressions in the  land.  These
depressional wetlands  can be particularly difficult to identify because they are usually dry for a portion
of the year.  If the permit writer or the owner/operator suspects that there are wetlands on the site where
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
                                                  Definition of Wetlands

                                                  Wetlands  are  areas  that are  inundated, or
                                                  saturated by surface water or ground water at
                                                  a frequency and duration sufficient to support,'
                                                  and that  under  normal  circumstances  do-
                                                  support, a prevalence of vegetation adapted for
                                                  growth in water or wet soil. Wetlands include/
                                                  but are not limited to, swamps, marshes, bogs,
                                                  prairie pot holes,  playa  basins,  and similar
                                                  areas.  [§503.9{bb)J
active sewage sludge units are or may be located,
he/she should  contact  the local  COE  District.
Office and request a wetland delineation.2 A list
of  the  District  Offices  and  their  address  is
published  annually  in  33  CFR  Part   330.
Additionally,  any  State  agency  that regulates
activities  in  wetlands should be  contacted and
invited to inspect the location of an active sewage
sludge unit.

A wetlands assessment should be conducted by a
qualified and experienced multidisciplinary team
with a soil scientist and a botanist or biologist.   	
The assessment identifies:   (1) the limits of the
wetland boundary based on soil and plant types, (2) the type  and relative abundance of vegetation
including trees, and (3) rare, endangered, or otherwise protected species of flora and fauna and their
habitat (EPA 1992a).   Criteria used in wetlands  identification  have been developed by a task force
consisting of representatives from the EPA, FWS, Soil Conservation Service, and COE and are presented
in the Federal  Manual For Identifying and Delineating Jurisdictional Wetlands (COE 1989).   This
publication also contains an extensive list of literature available on identification and prevalence of plant
species characteristic of wetlands throughout the United States, hydraulic soil classifications, and related
wetland topics (EPA 1992a). Additional published information useful to the permit writer in identifying
areas that are wetlands is listed in Table 5-4. If it is determined that wetlands are at the surface disposal
site and the site does not have a Section 404 or 402 permit, the permit writer should require the active
sewage sludge units at the site to close.

           TABLE 5-4  SOURCES OF INFORMATION TO  IDENTIFY WETLANDS
    Federal Manual For Identifying and Delineating Jurisdictional Wetlands (COE 1989)

    USGS topographic maps           '                          ,'''•'•

    National Wetland Inventory (NWI) Maps                   ,.•'„.

    Soil Conservation Service (SCS) soil maps

    Local wetland inventory maps
If the owner/operator has a Section 402 or 404 permit, the permit writer should require the owner/
operator to demonstrate that the site is in compliance with the permit.  The permit writer can contact the
Section 404 permitting authority and inquire about the permittee's compliance status.  If the  site is not
in compliance with its Section 404 or 402 permit, the permit writer, working with the U.S. Army Corps
of Engineers, should determine whether the active sewage sludge unit(s) at the site should be closed.
   2The definition and regulatory strategy for wetlands is currently being reevaluated at the Federal level and
may be revised.                                             '    " -    _
                                              5-31

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
Permit Conditions

If there are wetlands at the surface disposal site, it may be appropriate to include a permit condition
requiring compliance with the Section 404 permit or to incorporate the Section 404 permit into the
NPDES permit by reference, if the site has an NPDES permit. If the wetland assessment indicates that
there are no wetlands on the surface disposal site, then the permit writer may  either disregard this
provision or include, as a general prohibition, that no future expansions of the surface disposal site may
be located in wetlands, unless authorized in a permit issued pursuant to Section 404 of the CWA.

5.5.7   STORM WATER RUN-OFF MANAGEMENT
  Statement of Regulation                              ,','   '

    §503.24(g)(l)  Run-off from an active sewage sludge unit shall be collected and shaJl be disposed in accordance '
                with National Pollutant Discharge Elimination System permit requirements and any other
                applicable requirements                                                      '; ' '
                                                    ••  ~ *                  "& JJ, V J 1 •* J r  ;
    §503.24(g)(2)  The run-off collection system for an active sewage sludge unit shall have the capacity to handle
                run-off frtaR a 24-hour, 25-year storm event.
Permitting Factors

Storm water run-off is a point source discharge
regulated by the NPDES program.  The run-off
collection system from an active sewage sludge
unit must have the capacity to handle the water
volume generated from a 24-hour, 25-year storm.
A  25-year  storm  is   a storm  event  with a
frequency of occurrence of 25 years.
Runoff is rainwater^ leachate, or other liquid
that  drains overland on any  part  of a  land
surface and  runs off of  the land  surface.
Control of surface run-off can be accomplished in the following ways:  (1) by minimizing water that
enters the active sewage sludge units (i.e., run-on controls); (2) by minimizing the size and number of.
active sewage sludge units in a surface disposal site; (3) by preventing the placement of sewage sludge
with low solids content on an active sewage sludge unit; and (4) collecting and managing the run-off.  ,

The permit writer should determine whether appropriate  controls and  capacity for collecting and
controlling a 24-hour, 25-year storm have been incorporated into the design of the surface disposal site.
Therefore, brief descriptions of how to calculate the water volume generated by storm events and  the
different types of controls that may be used are provided below to aid the permit writer in making this
determination.

Design for 24-Hour, 25-Year Storm                 ,

The typical approach to designing run-on/run-off controls includes the following:

     • Identifying the intensity of the design storm

     • Determining peak discharge rates
                                              5-32

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
     •  Calculating the, run-off volume during peak discharges                                   •   '

     •  Designing the controls.
                 •                    '                       x
Site-specific design storm information is generally obtained from local planning agencies, civil works
departments,  or local zoning boards.   The most accurate  determination of the design storm  uses
precipitation from at least the past 25 years. The permit writer may wish to verify the information used
by the owner/operator by referring to_a publication entitled  "Technical Paper 40, Rainfall Frequency
Atlas of the United States for Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100
Years" prepared by the National Weather Service of the Department of Commerce (1963) for the eastern
and central United States.  In western states, the permit-writer should refer to the "NOAA Atlas 2,
Precipitation Frequency  Atlas of the United States" prepared by the National Oceanic and Atmospheric
Administration of the Department of Commerce (1973).

To determine peak run-on/run-off flows, a designer most commonly uses one of two methods (although
others are available).  One method is the Soil Conservation Service (SCS) Method (USDA 1986).  This
model assumes that the rate and amount of rainfall is uniform throughout the watershed over a certain
amount of time.   The rainfall run-off volume is  estimated from  cumulative rainfall data by using a
typified unit hydrograph.   This  allows  the estimation of both peak discharges  and  total run-off
hydrograph. Run-off curves used in this methodology have been developed to account for the effects of
soils, plant cover, amount of impervious areas, interception, and surface storage.  Another method, the
Rational Method, assumes that maximum  run-off, resulting from uniformly intense precipitation, will
occur when the entire watershed upstream  of the site location contributes to the discharge (Dunne et al.
1978).  Details of these  methods can be found in many common references and textbooks.

The permit writer may  request calculations for, the  determination of peak flow and  run-off volume
associated with the 25-year, 24-hour storm from the owner/operator to ensure that the appropriate storm
volume'has been considered in sizing the run-off controls and collection systems. The owner/operator
must design the controls and collection systems for at least the volume of storm water produced by the
25-year, 24-hour  storm.  If the area is located within  an area subject to flooding, the owner/operator of
the site may need to design controls that address flooding and a higher volume of storm water than the
25-year, 24-hour  storm would produce (see Section 5.5.2).

The permit writer will need to review the storm'water run-off management information  provided by the
owner/operator to determine  that:

     •  All the storm water controls and collection systems  for the active sewage sludge units or the
        entire surface disposal site are sized appropriately "for the storm water magnitude of a 24-hour,
  -.  ,    25-year storm event
                          V' '
     •  The calculation'of run-off volume used to size the controls is correct

     •  The run-off is collected and disposed of in accordance with an NPDES  or other permit.

Run-dn/Run-off  Storm Water Controls

Often, the most economical designs for collecting and controlling storm water discharges include run-on
controls as well as run-off controls to prevent additional storm water from becoming contaminated and
to minimize the amount  of water that must be collected  and treated.  Both run-on and  run-off controls
                                              5-33

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                            5. SURFACE DISPOSAL - PART 503 SUBPART C
 are generally used in partnership and they will both be discussed.  The permit writer should remember,
 however, that run-on controls are not required specifically by Part 503.

 Run-on and  run-off control structures,  whether temporary or permanent, can be incorporated into the
 surface disposal site design.  Because of the variety of types of controls, specific design considerations
 are beyond the scope of this document,  and only a brief description of the more commonly used control
 structures is  presented in Table 5-5.  The permit writer- can use the information in the table to review a
 choice of controls for a site and to determine which aspects of the design may need additional conditions
 in the permit to ensure proper collection and disposal of the storm water.

 Maintenance and Inspections

 One aspect of the controls and best management practices (BMPs) that the permit writer may want to
 evaluate is operation and maintenance. Often controls and BMPs require specific maintenance activities.
 Some are considered temporary and will need to be maintained and rebuilt on a regular basis if disturbed
 due to storm water or other activities.  The permit writer will  want to  ensure that the appropriate
 maintenance  activities are  being performed at the surface disposal site so  that the controls and BMPs
 maintain their ability to collect the volume of run-off from the 24-hour 25-year storm.  The permit writer
 may  request inspection and maintenance schedules  from  the owner/operator and incorporate  these
 schedules in  the permit. Inspections should be made monthly and after  every storm event that is of a
 measurable size.   A measurable storm event is often defined as having 0.1  inch of rainfall..

 Erosion and Sedimentation Best Management Practices

 Although not specifically required, the permit writer may wish to address  other BMPs or run-off control
 measures in the permit.  Conditions for minimizing erosion and sedimentation at surface disposal sites
 where large areas of land are disturbed  may be appropriate.  For more information on the erosion and
 sedimentation BMPs, see EPA's  "Storm Water Pollution Prevention  for  Industrial Activities" (EPA
 1992b).

 Permit Conditions

 If the site  is located within an area subject to  flooding, the permit writer may want to put  special
 conditions in the permit for the surface disposal site to be able to retain  a higher volume of storm water.
The permit writer also may establish permit conditions for inspection and maintenance of the storm water
run-on controls.

5.5.8  LEACHATE COLLECTION  AND DISPOSAL
  Statement of Regulation
§503.24(h)
§503.24(i)
                The leachate collection system for an active sewage stodge unit that "has a liner and leachate
                collection system shall be operated and maintained nurfag the period the sewage sludge wnit fe
                active and for 3 years after the sewage sludge unit closes.
                                              '*'    j.v^'w).    v.v.a.w.™. ^r.w  •,           ,, I j l$i ,f -.
                Leachate from an active sewage sludge unit that has a liner and leachate collection system shall
                be collected and shall be disposed in accordance with the applicable requirements during the
                period the sewage sludge unit is active and for 3 years after the sewage sludge unit closes.
                                              5-34

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                    5. SURFACE DISPOSAL - PART 503 SUBPART C
TABLE 5-5TYPICAL RUN-ON/RUN-OFF CONTROL BEST MANAGEMENT PRACTICES
' Control
!*
Dikes and Berms

•. -•




_






/


Drainage Swales,
Channels and
Waterways








• '

t .



Description
Dikes and berms are
compacted ridges or
ledges, generally
earthen, constructed
immediately upslope
or around the
perimeter of an active
sewage sludge unit.









Drainage swales,
channels and
waterways are
drainage ways
installed to collect and
convey the flow of ,
storm water run-off in
a manner that does not
contribute to erosion.

These .controls can be
temporary or
permanent and can be
lined with vegetation,
rip rap, asphalt,
concrete, or other
materials.
Purpose/
' Function
Diverts
uncontaminated storm
water around the
active sewage sludge
unit to natural or
manmade drainage
channels, manmade
outlets, or
sedimentation basins.
Dikes can be used as
interceptors to reduce
slope lengths,
minimize erosive
forces, and divert the
run-off away from a
source of .
contamination.
Cross-sections vary
and can be
trapezoidal, triangular
or parabolic..
Generally swales have
a less steep cross
section and when
vegetated may-
promote infiltration of
some of the storm
water discharge;
however, they are
appropriate only for
uncontaminated
discharges.


Maintenance
Relatively
impermanent. Must
be inspected
regularly, especially
after heavy storms to
maintain their
integrity. Typically,.
dikes and berms are
reconstructed yearly:








Should be inspected to
remove debris within
24 hours of rainfall,
or daily during
periods of prolonged
rainfall. Drainages to
conveyances should be
repaired as soon as
possible.








Special (Design) .
Considerations
Construction -is simple
and typically designed
from standard
specifications. [ ,













Design of drainage
swales, channels and
waterways must
consider the local
drainage patterns, soil
permeability, annual
precipitation, area
land use, and other'
characteristics of the
watershed
contributing to the
run-off.





                                   5-35

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                    5. SURFACE DISPOSAL - PART 503 SUBPART C
TABLE 5-5 TYPICAL RUN-ON/RUN-OFF CONTROL BEST MANAGEMENT PRACTICES
                               (Continued)
Control
Terraces and
Benches

















Chutes and Down
Pipes










Seepage Drains
and Ditches















Description
Terraces and benches
are earth
embankments or ridge
and channels
constructed along the
contour of a steep
slope, generally one
with no vegetation and
with a water erosion
problem.









Specifically, chutes
are excavated earthen
channels that have
been lined with non-
erodible materials,
such as bituminous
concrete or grouted
riprap. Down pipes
are rigid or flexible
piping that has been
installed.

A seepage basin
typically consists of
the actual basin, a
sediment trap, and a
bypass for extra flow
and emergency
overflow.










Purpose/
Function
Diverts storm water
run-off away from
steep slopes where
erosion may occur.
Also minimizes
erosion by reducing
both the length of a
slope and the velocity
of the run-off. The
permit writer will
want to ensure that
any contaminated
discharges are
diverted to an .
appropriate outlet that
leads to a discharge
that is in compliance
with an NPDES
permit.
Chutes and down
pipes carry run-off to
the bottom of a slope
so that erosion is
prevented while the
sewage sludge unit is
inactive and covers
have been
constructed, yet
stabilization of the
surface has not been
completed.
Seepage drains and
ditches provide in-situ
treatment and
recharge to ground
water. Not
appropriate for
contaminated run-off
and should not be
used for discharges
from active sewaae
sludge units. Most
effective in highly
permeable soils and
typically are used in
areas where the water
table is close to the
surface.
Maintenance
Should be inspected at
least once a year and
after major storms.
















Must be inspected on
a regular schedule and
after major storms to
promptly clear
clogged pipes.







Drains and ditches
must be inspected
regularly for pipe
breaks or clogging
debris in ditches. '












Special (Design)
i Considerations
Must be designed
with adequate outlets,
such as a grassed
waterway, vegetated *
areas, or tile outlet.
Should not be
constructed on slopes
with sandy or rocky
soils.










The maximum
recommended
drainage area for a
chute and down pipe
is approximately 10
acres.






If contaminated
discharges could be
directed to a seepage
drain or ditch, the
permit writer should
consider adding a
permit condition to
ensure compliance
with the requirements
that the discharge
from a 24-hour, 25-
year storm be
disposed in
accordance with an
NPDES permit.


                                 5-36

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                          5.  SURFACE DISPOSAL - PART 503 SUBPART C
 TABLE 5-5 TYPICAL RUN-ON/RUN-OFF CONTROL BEST MANAGEMENT PRACTICES
                                        (Continued)       .
i % >
Control
Sedimentation
Basins














Surface
Roughening






-
Description
Major components
.include a principal and
emergency spill way,
an anti-vortex device,
and the basin.
Sedimentation basins
often serve as the last
step in the collection
of 'Storm water run-off
from a site.






Soil is roughened by
the creation of
horizontal grooves,
depressions, or steps
that run parallel to the
contour of the land.



i
Purpose/
Rinction
Sedimentation basins
detain run-off so that
settling of suspended
solids can occur.
They also store storm
water run-off so that
the discharge can be
released at a slower
rate. Sedimentation
basins can be
constructed by
excavation or by
placing an earthen
embankment across a
low area or drainage
swale.
This .practice reduces
erosion on steep
slopes. It slows run-
off, increases
infiltration, traps
sediment, and helps
establish vegetative
•cover.

Maintenance
Maintenance is
imperative to provide
the designed capacity
for storage. If the
basin becomes filled
with sediments, the '
capacity will be
lessened. Inspections
are also important to
make sure the
embankments are
stable and that the
outlet is not cloggdd
with trash or other
debris.

Should be seeded as
soon as possible.
Regular inspections
should be made,
especially after
storms. Rills should
be filled, graded, and
reseeded.

Special (Design)
Considerations
The permit writer
should assess the need
for specific permit,
conditions addressing
sediment basins.
•










The surface grade
should be greater than
2 percent to%promote
collection of the run-
off and inhibit
ponding but less than
5 percent to reduce
flow velocities and to
minimize soil erosion.
Source: Extracted from Dunne & Leopold (1978), EPA (1992a).

Permitting Factors

To  implement these requirements, the permit  writer must draft permit conditions  that require the
owner/operator of a surface disposal site to:

     • Operate and maintain the leachate collection system during the life of the active sewage sludge
       unit and for 3 years after the unit closes

     • Collect and dispose of the leachate properly.
                          .                      |                        ,       .
The permit writer should request that the owner/operator describe the leachate collection system and the
provisions made'for operating and maintaining the system while the  sewage sludge units are active and
for at least 3 years after closure. This information may be supplied by the owner/operator in the permit
application.

To evaluate the data furnished by the owner/operator and develop adequate permit conditions, the permit
writer will need to be familiar with the design and operation of  leachate  collection systems.   The
following technical guidance introduces the permit writer to leachate collection systems and to the options
available for treatment and/or disposal of leachate.
                                             5-37

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5. SURFACE DISPOSAL - PART 503 SUBPART C
                       Leachate collection system is a system or
                       device installed immediately above a liner
                       that is designed, constructed,, maintained, and
                       operated to collect and remove leachate from ..
                      " a sewage sludge unit,  [| 5Q3.21(i)]
 Leachate Collection System

 When a liner is included in the design of a surface
 disposal site to protect ground water, a leachate
 collection system must be installed.  A leachate
 collection and removal system is installed under
 the active sewage sludge unit to relieve hydraulic
 pressures within a  lined .sewage sludge  unit.
 Without a  collection and removal system, the   ^^_^^^^^^^^^____^_^^^_^^^^^
 leachate  may  accumulate   and  increase  the
 possibility of its migration through the liner. Also, the leachate may back up in the unit and eventually
 result in seepage at the surface.            -

 Part 503 requires that the leachate collection system for an active sewage sludge unit that has a liner be
 operated and maintained during the period the sewage sludge unit is active and for a period of 3 years
 after the sewage sludge unit closes. The permit writer may want to evaluate the following three aspects
 of the active sewage sludge unit to determine if the permit for the surface disposal site needs to contain
 special conditions for the operation and maintenance of the leachate collection system:

     •  Design of the system

     •  Operations

     •  Maintenance.                                                                             '
      f1                                                 '
 Each aspect is briefly discussed below.

 Design                                                                                  '   ...

The design considerations for a leachate collection system for an active sewage sludge unit are similar
to those for solid waste landfills.  Each leachate collection system consists of the following components:
                         i                  ff                   '
     •  A low permeability base  (i.e., liner).              •

     •  A high permeability drainage layer of either natural granular material, such as sand and gravel,
        or synthetic materials, such as a geonet.   The drainage /layer is placed either directly over the
        liner or over  a protective layer (e.g., filter fabric) of the liner.

     *  Perforated leachate collection pipes within the high permeability layer to collect and convey the
        leachate to the sumps where it can be removed.

     •  A protective filter material  that surrounds  the pipe  to  prevent  clogging  of the pipes or
        perforations.

     •  A protective filter layer over the high permeability'drainage material to prevent clogging of the
       permeable layer by finer  materials.                                        .

     •  Leachate collection sumps or  header pipe system where  leachate can be removed.

     • Storage tanks or ponds for storage, treatment or disposal (EPA 1978, EPA 1988b).
                  5-38

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
At a minimum, the permit writer will, want a description of the design of the leachate collection system
and the procedures for inspection, cleaning, maintenance, and operation of the system. Proper design
is crucial to the long-term reliability of the system, and the permit writer may consider evaluating' certain
aspects of the design to ensure that proper operation and easy maintenance  are provided. In particular:

     •  Sedimentation by granular drainage materials may clog pipes, and can be avoided by surrounding
        pipes with filter fabric (EPA 1992a).

     •  Precipitation of dissolved ionic species may settle in, and foul pipes; the system design should
        prevent this by allowing for  flow velocities  that are high  enough to provide a self-cleansing
        action.  These velocities depend on the diameters and specific gravities of the particles,  but
        generally flows ranging from one to two feet per second are sufficient (EPA 1988b). The permit
        writer may request documentation and calculations for the designed flow rates and flow volumes.

     •  Biological  fouling can  also  occur,  and for this  reason  the system  should be designed to
        accommodate pipe system cleanings as follows:

        - A minimum of six-inch diameter pipe to facilitate cleaning
        - Access points located at major pipe intersections or bends to facilitate inspections and cleaning
        - Valves, ports, or other appurtenances to introduce biocides or cleaning solutions (EPA 1988b).

The strength of the structural materials and chemical compatibility between the materials and leachate can
affect the continued operation of the leachate collection system.   The pipe materials  should  have the
strength required to withstand the loads of the wastes  and cover system of the active sewage sludge unit
as well as the loads required by the equipment during the unit's construction.  The  permit writer may
want to look at loading calculations to see that these loads were considered in the design.

Another design aspect is the size and construction of  the pumps used, in particular:

     •  Sufficient capacity to  ensure leachate removal at the expected rate  of generation

     •  Sufficient operating head to lift the leachate to the required height  from the sump to the access,
        point                                                            ',-'•'

     •  Resistance to corrosion

     •  Ability to perform during the 3-year closure period.

Calculations and specifications should  be available from the owner/operator that can verify these
considerations.

Operations

The leachate must be removed from the active sewage sludge unit, at a  frequency dependent on the
amount of liquid being generated at the unit, and then must be treated or  disposed.  Usually, leachate
collection systems are designed to maintain a certain level of leachate over the liner and, correspondingly,
removal of leachate at a regular rate.  The permit writer should develop permit conditions  requiring
adherence to operation schedules that ensure that the leachate is removed at the designed rate.  The permit
                                               5-39

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
writer should also require the owner/operator to
maintain documentation that demonstrates leachate
collection, treatment and disposal. For example,
if the leachate is hauled off-site for treatment or
disposal,  the volume of leachate hauled and the
dates that the leachate was hauled off-site should
be maintained by the owner/operator.

Operations at the site should allow for easy access
to the removal points, whether they are sumps or
tanks.  Often access to the sumps is provided by
either a solid pipe laid in a shallow trench along
the  sidewalls  or  a  vertical  manhole  that is
constructed as the unit is filled (EPA 1988b).

Maintenance
  Clogging is the primary cause of concern in the
  long-term performance of leachate  collection
  and removal systems.  Clogging can occur by
  the  following means:   (1) the sand filter can
  clog the drainage gravel;  <2) solid material ia^
  the  leachate can clog the 4rainage material or
  geonet; and (3) solid suspended material in the
  leachate can clog the safld filter or  geotextile
  fabric* Biological clogging arises  from slime,
 , sheath formation,  and biomass accumulation.
  Inorganic clogging can be caused by cohering,
  sulfjde deposition and carbonate deposition.
  For; de|er|r|irung the potential for biological
_,    V4* <$^>l-VCnt.?'i •t-"V -*£•>»     C   r1     f     v 7sf
-  clogging, a high biochemical oxygen demand
  (BQP) in the leachate is a good indicator
     '""       ""--                    "
Maintenance of title  leachate collection system
entails regular inspection and cleaning, including the following:

     •  Maintenance of pumps

     •  Periodic flushing (or by cleaning by mechanical means) with biqcides to remove deposited solids
        and to prevent biological fouling

     •  Inspection of equipment and piping to detect clogging problems or material failure.

Inspection and cleaning should be conducted periodically after the sewage sludge is placed in the unit.
To flush particulates and to prevent biological clogging, a low-pressure cleaning jet system introduced
into  the drains of the leachate collection system dislodges the particles  from the filter and drainage
materials (EPA 1983a).  For biological growth, biocides can be introduced with the flushing water or
added to the system during manufacture.  -

Inspections are important aspects of any good operation and maintenance program.  The  intent of an
inspection is to determine if the system is in the process of becoming clogged or has clogged so that
maintenance procedures can be performed immediately or so that contingency plans can be set into action.
A weekly inspection  routine is  recommended as well as inspections after large storm events.  The
following components should be present in a good inspection program:
                                                          1 y    ' !        . '
     •  Confirmation that leachate levels above the liner in the sewage sludge unit are equal to, or less
        than, the design depth at all points

     •  Confirmation of the depth of leachate in the collection sumps

     •  Confirmation that pumps and piping are in good operating order

     •  Recording of leachate depths and flow rates in all parts of the system.
                                              5-40

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5. SURFACE DISPOSAL - PART 503 SUBPART C
                       Leachate is the liquid that is generated in a
                       surface disposal unit due to: (1) percolation of
                       surface waters into the soil; (2) water content
                       of the  sludge when, disposed;   (3)  water
                       produced during decomposition of the sludge;
                       and (4) water migration from surrounding soils
                       and sludges.   The leachate's  quality varies
                       depending -upon the  quality   of  the  sludge,
                      .Generally,  leachate  is  high   in  biochemical
                       oxygen  demand, organic? and, sometimes, in
                       metals.    Because  of  these  characteristics,
                       leachate has the potential for  causing adverse
                       conditions  when discharged  to  surface  or
                       ground  water.  Therefore, it  is important to
                       treat and/or 'dispose of it properly  so that it
                       does not cause harm to human .health and the
                       environment.,                 ,
Detailed inspection guidance is not feasible in this
document because there are many different types
of systems.  The permit writer, when evaluating
the inspection program provided by  an owner/
operator,  should ensure that the program has
provisions for what, where, why and how checks
will be made.  Specific criteria that will .trigger
corrective action should also be stated.

Disposal or Treatment of Leachate

Part 503 requires that the leachate from an active
sewage sludge unit that has a liner and leachate
collection system be collected and disposed in
accordance  with the conditions  of a  National
Pollutant  Discharge Elimination  System permit
and/or  other applicable  requirements.   This
requirement extends for the tune that the sewage
sludge unit is active and for 3 years after the unit
is closed.   Collected leachate may  b,e treated   ^^^^^^^^^^^^^^^.^^^^^^^^^
and/or  disposed through one or more of the
following methods:

     •  Discharge or haul to a publicly owned treatment works

     •  On-site treatment and  release to surface waters

     •  Off-site disposal.

The treatment or disposal option used by the owner/operator should be evaluated by the permit writer to
determine if appropriate requirements are  being  met or if special conditions for the disposal  of the
leachate should be incorporated into the permit.

Discharge or Haul to a Publicly Owned Treatment Works (POTW)

If leachate is discharged directly to a POTW collection system or hauled to a POTW for treatment, the
owner/operator may be required to pretreat the leachate prior to discharging it into the treatment works.
In some cases, the leachate may need pretreatment for high organic and metals loadings.  The permit
writer may  request information from the owner/operator showing compliance with local requirements,
such as permits or other control mechanisms issued by the POTW as well as local  ordinances. The
permit writer may contact the  POTW directly for the compliance status on the active sewage sludge unit
leachate discharge.
                   5-41

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
On-Site Treatment

Most commonly, on-site treatment of leachate consists of the following processes:

     • Biological processes, both anaerobic and aerobic

     • Physical-chemical treatment

     * Evaporation in ponds.

Biological treatment processes include anaerobic filters, anaerobic sewage sludge bed reactors, aerated
lagoons, rotating biological contactors, and trickling filters. Physical-chemical systems include chemical
precipitation using lime  and oxidation with calcium hypochlorite or ozone.  Some systems may also
employ carbon adsorption. Evaporation ponds are shallow lagoons used in areas where the evaporation
rate is high.  Ponds should be designed to provide ample capacity for storm water from a 25-year, 24-
hour storm  event so that the pond does not get washed out during large storms .and threaten surface
waters.

A surface disposal site is required to have an NPDES permit  for any discharge of treated leachate to
surface water.  If the site has an existing NPDES permit, the permit writer should evaluate provisions
in the permit to ensure that the site is in compliance.  If the site is new, or does not currently have an
NPDES permit, the permit writer should require the submittal of an NPDES permit application for a point
source discharge.                                   -                           .        .

Off-Site Disposal

Where off-site disposal is practiced, the permit writer should request a detailed description of how the
leachate is collected and  how it is transferred to the off-site disposal site.  Also, the permit writer may
want to contact the off-site disposal facility to identify leachate disposal requirements and whether those
requirements are being met.                         .

Permit Conditions

The permit writer will need to assess the operation and maintenance of the leachate collection system and
the current treatment or disposal system for the collected leachate.  He may need to .draft specific permit
conditions for such a system. When the permit writer determines that design, operation or maintenance
of the leachate collection system is inadequate, she should include a compliance schedule in the permit
to require the owner/operator to  correct the inadequacies.  The permit writer should develop permit
conditions focusing on these issues.  For example, the permit writer could  develop specific conditions
that require the owner/operator to conduct inspections of the leachate collection system and to maintain
documentation of these inspections.                            ,

If leachate goes to a POTW or is hauled off site for disposal,  the permit writer may want to establish
permit conditions that require the owner/operator of the  surface disposal site to comply with any
requirements imposed by the POTW or other off-site disposal facility.
                                              5-42

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                            5. SURFACE DISPOSAL - PART 503 SUBPART C
5.5.9   METHANE GAS CONTROL
  Statement of Regulation                                       ,  , •      -

    §503.24(j)(l)   When a cover is placed on an active sewage sludge unit, the concentration of methane gas in air
                 in any structure within a surface disposal site shall wot exceed 25 percent of the lower explosive
                 limit  for methane gas during the  period that the sewage sludge unit is active and  the
                 concentration of methane gas in air jat the property line of the surface disposal site shall not
                 exceed the lower explosive limit tar methane gas during the period thai the sewage sludge unit
                 is active.           •                                  , ••

            (2)   When a final cover is placed on a sewage sludge unit at closure, the concentration of methane
                 gas in air in any structure within the surface disposal site shall not exceed 25 percent of the lower
                 explosive limit for methane gas for $ years  after the sewage sludge unit closes and  the
                 concentration of methane gas in air at the property line of the surface disposal site shall not
                 exceed the lower explosive limit for methane gas for 3 years after the sewage sludge unit closes,
                 unless otherwise specified by the permitting authority*
                                                    Cover Is soil _ or other material used to cover
                                                    sewage sludge placed on  an active sewage
                                                    sludge unit Final cover is the last layer of soil
                                                    or other material  placed  on a sewage sludge
                                                    Limit at closure.
Permitting Factors

If sewage  sludge is  covered with soil or other
material, the owner/operator of an active sewage
sludge unit is required to install equipment to
monitor methane continuously in air in structures
and at the site property line.  Methane gas levels
cannot exceed 25 percent of the lower explosive
limit (LEL) in on-site structures such as buildings.
Methane levels cannot exceed the LEL at the site  --..''...
property boundary.  The LEL for methane is 5 percent by volume in air. -.-

Methane Generation and Migration

Methane is generated as a result of anaerobic microbial decomposition of sewage sludge, and is a-concern
at surface disposal sites  because it is odorless and highly combustible.  In addition to methane, carbon
dioxide and lesser amounts of  other  gases (hydrogen and hydrogen sulfide) are produced.  While
hydrogen (H2) is explosive and is occasionally detected in gas from surface disposal sites, it readily reacts
to form methane or hydrogen sulfide.  Hydrogen sulfide (H2S) is an asphyxiant and is readily identified
by its "rotten egg" smell at a threshold concentration near 5 ppb (EPA 1992a).

Gas composition  may vary spatially within a sewage sludge unit as  a result of pockets of microbial
activity.  Partial pressure, density of the materials, and temperature gradients affect the migration of
gases. Gas in an active sewage sludge unit tends to migrate laterally if the active sewage sludge unit has
been covered with geoniembranes or clay materials and if interior side slopes of the unit do not contain
an effective gas barrier such as may exist with a composite infiltration layer.  Lateral gas migration is.
common in active sewage sludge units that lack clay or geomembrane systems.  The degree of lateral
migration depends on the type of natural soils surrounding the unit.  Coarse, porous soils, such as sand'
and gravel, allow greater lateral migration or transport of gases than finer-grained soils.  Generally,
resistance to gas flow increases slightly as moisture content increases, and an effective barrier to gas flow
is created under saturated conditions.  Thus, readily drained soil conditions, such as sands and gravels
                                                5-43

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
above the water table, may provide a preferred flowpath, but unless finer-grained soils are saturated,
gases will not exclusively flow in the sand and gravel deposits (EPA 1992a).

Gas Monitoring

Detectors that monitor gas  in  the  air continuously must be installed  in the monitoring locations.
Automatic detectors that sense the presence of combustible and/or toxic gases should be installed in
ventilation areas, work areas, and utility vaults.  The detectors should sound alarms or other types of
warnings when gas levels exceed 25 percent of the LEL in onsite structures or the LEL at the property
line.  Detectors are sensitive to temperature and humidity changes and require regular calibration and
periodic replacement.

Part 503 does not  define "continuous monitoring."   The monitoring frequency necessary to  prevent
dangerous methane  levels varies with the site conditions.  The permit writer should use her BPJ to decide
what "continuous monitoring" should mean in each situation.  The proximity to residential areas,  the
presence or absence of structures, and the presence of staff to maintain the monitors are among  the
conditions to be considered when deciding how to define "continuous."

Section 503.24(j)(2) requires that the methane gas be monitored for 3 years after a sewage sludge unit
is closed. This is the minimum amount of time that the permit writer must specify in the permit. The
permit writer, however, may specify longer monitoring periods based on the potential for methane gas
generation at the active sewage sludge unit. The regulatory requirement is based on studies performed
with sewage sludge that had been treated in anaerobic or aerobic processes.  Because these processes
provide a more  stabilized sewage sludge, the permit writer may want  to require  a longer monitoring
period for sewage sludges placed on an active sewage sludge unit that are not treated by such processes
(e.g., lime stabilized sludges).

Explosive Conditions

If the methane concentration exceeds 25 percent of the LEL in air in a structure or'exceeds the  LEL in
air at the surface disposal site property line, the danger of explosion is imminent.  All personnel should
be evacuated from the area immediately.   Venting the building upon exit (e.g., leaving the door open)
is desirable but should not replace evacuation procedures (EPA 1992a).   Emergency procedures should
be defined clearly in a site health and safety plan.

Because the presence of explosive conditions at a surface disposal site may endanger human health and
the environment, the permit writer may require special conditions in the permit to develop emergency
procedures and/or remedial action plans for potentially explosive conditions. These procedures or plans
should be required  if there is a history of methane gas problems at the  site.  The permit writer should
require that  these procedures and/or plans be maintained on site at all times.

Gas  Control Systems

Some active sewage sludge units .where  the sewage sludge is covered are designed with  gas  control
systems to prevent  the build-up of explosive gas at the site.  The permit writer should be aware of the
type of system employed at the site, and may wish to request additional information on the system during
the application process if gas problems have occurred at the site.  The following information introduces
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
the permit writer to gas control systems and some of the design considerations for both passive and active
systems,                           s

Systems used to control Or prevent gas migration are categorized as either passive or active systems.
Passive systems provide preferential flpwpaths by means of natural pressure, concentration, and density
gradients.  Passive systems are primarily effective in controlling convective flow;  they have limited
success controlling diffusive flow. Active systems' use mechanical equipment to direct or control"gas by
providing negative or positive pressure gradients.  They are effective in controlling both types of flow.
Suitability of the systems is based on the design and age of the sewage sludge unit, the soil; and the
hydrogeologic and hydraulic conditions of the surface disposal site.
                                 •               '          r ^           *   -    -       ~
Passive System

A passive gas control  system relies on natural pressure and convection mechanisms  to vent gas to the
atmosphere.  A passive system typically uses "high-permeability" or "low-permeability" techniques, either
singularly or in combination  at  a site.   A high-permeability system uses conduits such as ditches,
trenches, vent wells, or perforated vent pipes  surrounded by coarse  soil to vent gas to the surface.  A
low-permeability system blocks lateral migration using barriers such as synthetic membranes and high
moisture-containing fine-grained soils (EPA 1992a).

A passive system  may be incorporated into the unit design or may be used for remedial or corrective
purposes. It may  be installed  within an active sewage sludge unit, along the perimeter, or between the
active sewage sludge unit and the surface disposal site property line. A detailed  discussion of passive
systems  for  remedial  or  corrective purposes  is found in the Handbook—Remedial Action at Waste
Disposal Sites (EPA 1985).

A passive system may also be incorporated into the final cover.  It  may consist  of perforated gas
collection pipes, high permeability soils, or high transmissivity geosynthetics located just below the low-
permeability gas and hydraulic barrier or infiltration layer in the  cover system.  These  pipes may be
connected to other pipes that vent gas through the cover system or are connected to header pipes located
along the site's perimeter.  The gas collection system also may be connected with the leachate collection
system to Vent gases in the headspace of leachate collection pipes (EPA 1992a).

A high-permeability passive control system should be installed in a gravel-lined trench at the boundary
of the sewage sludge unit. The depth of the trench depends on the unit depth and the geology of the area
in the unit's vicinity. The piping component of this passive control system has horizontal perforated pipes
and vertical solid-wall pipes used to vent gas  to the atmosphere if the top of the trench  is blocked by
debris.  Polyvinylchlofide (PVC) perforated pipe is the most common type of pipe installed.  Joints can
be cemented, heat welded, or screwed together. After the pipes are laid, the trench is filled with crushed
gravel.  The top should be sloped to provide runoff control and the ground should be graded to draw
away from the trench to prevent the washing of soil into the voids of the stone (EPA 1985).  However,
this method may not be suitable if air emission requirements cannot be met.

A low-permeability design is identical to the high permeability system except that a  synthetic barrier lines
the trench and a low permeability material is used as a backfill. A geomembrahe draped over the far wall
of the-trench is the barrier and the excavated earth is used for the backfill.
                                              5-45

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
The two types of passive systems can be combined. In a combined low/high permeability passive system,
the membrane is installed, and then the piping and high permeability material are installed in front.  The
high permeability material should be rounded gravel to avoid puncturing the geomembrane.  This
combination encourages gas to flow through the system.

Passive systems are prone to clogging through accumulation of snow and dirt, vandalism, and biological
clogging.   To  work properly,  passive systems should  be designed to keep  components  clear  of
obstructions.

Active System

An active gas control system removes methane gas through either positive pressure (air injection)  or
negative pressure (gas extraction).  A positive pressure  system induces a pressure greater  than the
pressure of the migrating  gas and drives the gas out of the soil and/or the unit in a controlled manner.
A negative pressure system extracts gas from a unit by using a blower to pull gas out of the unit.  The
negative pressure system has wider  use because it is  more effective and offers  more  flexibility  in
controlling gas  migration. The gas may be discharged directly to the atmosphere, recovered for energy
conversion, treated, or burned hi a flare system.  A negative pressure system may be used as either a
perimeter  gas control system or  an interior gas collection/recovery system (EPA 1992a).

An active system uses a series of wells, collection headers, and blowers to  extract  gas. The wells are
installed to the  depth of the seasonably low water table or to depth of the base of the sewage sludge unit,
whichever is less. The well bore diameter should be between 12 and 36 inches in diameter.  A 2 to 6
inch pipe, perforated in the monitoring zone and solid above, is installed in the wellbore. The wellbore
is filled with crushed stone and a clay or cement seal is placed around the solid portion of the pipe at the
top of the well  to minimize infiltration of atmospheric air into the system.  A valve is placed on top  of
the well to regulate the gas flow and to balance multi-well systems.

Well spacing is a critical consideration in the design of an active system, and depends on the size of the
sewage sludge  unit, the magnitude of the vacuum, and the rate  of gas withdrawal.  The radius  of
influence should allow for overlap  between wells.  The wells should be constructed first to  allow system
components to  be positioned according to well location.  The header system  and piping can be buried  or
placed aboveground. Blowers or vacuums must also be installed and the header system connected to the
gas treatment facility. In addition, construction materials should be resistant to corrosion because of the
high moisture content of the gas. Monitoring effectiveness of the system is identical to those for passive
systems.

An active  system is not as sensitive to freezing or saturation of cover soils as  a passive system.  Although
an active  gas system is more effective in withdrawing gas from the  sewage sludge unit, the capital,.
operation, and maintenance costs of such systems are higher and these costs continue throughout the post-
closure period.  As the disposal unit ages, the owner/operator may wish  to convert active gas controls
into a passive system when gas  production diminishes.  The conversion option and its environmental
effects (i.e., gas releases causing odors and health and safety concerns) should be addressed in the
original design (EPA 1992a).
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
Permit Conditions

In addition to writing permit language implementing §503,24(j), the permit writer may want to'require
the owner/operator to:

   '  •  Develop inspection, calibration, and replacement schedules for the methane gas detection devices.
        The schedules can be included in the closure plan for methane monitoring requirements.

     •  Develop a remedial action plan for use if methane gas levels exceed the allowable levels. This
        plan  should include procedures  to reduce the methane gas levels, emergency procedures  to
        prevent potentially explosive conditions, and an evacuation plan.

The permit writer may also want to require a longer period of time for monitoring the air for methane
gas.       ;            ,•       '       '•.-.•              '    •  •        ••'•"•-.

5.5.10  FOOD, FEED, AND FIBER CROPS AND GRAZING RESTRICTIONS
  Statement of Regulation      -                                                    '       ,

                      *                        ''';-••''''
    §5Q3.24(R)    A. food crop, a feed crop, or a fiber crop shall not be grown on an active sewage sludge unit,
                unless the owner/operator of the, surface disposal site demonstrates to the permitting Authority
                that through management practices public health and the environment are protected from the
                reasonably anticipated adverse effects of pollutants in sewage sludge when crops are grown,

    §503,24(1)     Animals shall not be grazed on an active sewage sludge unit, anless the owner/operator of the
                surface disposal site demonstrates to the permitting authority that through management practices
                public health and the,environnient are protected from the reasonably anticipated adverse effects
 	.  -   of pollutants in sewage sludge when animals are grazed.                -             *
Permitting Factors

Food  crops  are  crops   grown  for   human
consumption (e.g., fruits and vegetables) or for
use in making products for human consumption
(e.g., soybeans for soybean oil).  Feed crops are
crops  used to  feed animals  raised  for  human
consumption (e.g., pigs) or to feed animals whose
products are consumed  (e.g., cows for milk).
Fiber crops are crops used for making textiles
(e.g., flax and cotton).

In general, the permit writer should prohibit,
through a permit condition, the growing of food,
feed,  or fiber crops or the grazing of animals on active sewage sludge units.  However, if the owner/
operator requests permission to grow food, feed, or fiber crops or graze animals on the active sewage
sludge unit,  the permit  writer may  allow such activity if the  owner/operator demonstrates to the
permitting  authority that management practices will be implemented that will adequately protect public
health and the environment from reasonably anticipated adverse effects of pollutants in the sewage sludge.
The permit writer will need to assess whether the proposed management practices are sufficient to protect
                                                  Food crops are crops consumed by humans.
                                                  These include, ,but-are not limited to, fruits,
                                                  vegetables, and tobacco, [§ 503,9(1)J

                                                  Feed crops  are crops produced primarily jfor
                                                  consumption by animals.  [§503.9(j>]

                                                  Fiber drops are' crops sueh as flax and cotton.
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
human health and the environment if these activities are allowed. For example, the permit writer may
need  to  evaluate the pollutant loadings to the  surface disposal  site  and assess  the potential for
accumulation of these pollutants in the food, feed, or fiber crop or animals grazing  on the land. The
permit writer may want to establish management requirements, such as monitoring the crops and animal
products, to ensure that human health is protected.

Permit Conditions

If the permit writer allows the growing of food, feed, or fiber crops or the grazing of animals, specific
management practices should be applied as well as all the associated monitoring, recordkeeping and
reporting requirements.  The permit writer should also consider imposing requirements in the permit to
monitor  the food, feed, or fiber crop grown or the animals grazed  or  products (such-as milk) from
animals grazed on the site.                            s

5.5.11  PUBLIC ACCESS CONTROL
  Statement of Regulation
    §S03.24(m)    Public access to aswrface disposalsite shall be restricted for the period that the surface disposal
                 site contains an active sewage sludge unit and for 3 years after the last active sewage sludge unit
                 in the surface disposal site closes.             	      ,            	'"'
Permitting Factors

The permit writer must require, through conditions in the permit, that the owner/operator of a surface
disposal site  ensure that exposure of the public to the sewage sludge placed on the active sewage sludge
unit within the surface disposal site does not occur.   The permit writer will need to determine  the
existence and adequacy of current management practices that restrict public access. This information may
be in the permit application;  if not, the permit writer may need to request this information from  the
owner/operator.  The permit writer will have to consider whether the existing access restriction practices
are adequate.

As part of her evaluation, the permit writer should consider the population density of the surrounding area
and the  land use practices of the surrounding areas.   In general,  the higher the population density or
sensitivity of current land use practices in the surrounding area, the greater the degree  of protection
required. A  land use practice that is sensitive  to the presence of a surface disposal site is one which will
increase the probability of exposure of the public to sewage sludge during a normal  course of activity.
For example,  if the surface disposal site is  hi an urbanized area surrounded by residential housing
developments, the likelihood of the public entering the surface disposal unit is high.  Therefore, stringent
measures must be used to prevent access.

Numerous measures are appropriate for controlling access to a surface disposal site,  such as:

     •  Installation  of perimeter fencing around the  surface disposal site with gates and locks.  The
         fencing can be chain link, barbed wire added to chain link, or open farm fence

     •  Restriction of vehicular traffic across access roads by installing locked gates in conjunction with
        perimeter fencing
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
     •  Installation of  warning  signs  such as "Do not  enter,"  "Sewage  sludge disposal site, no
        trespassing," and "Access restricted to authorized personnel only."

The,use of natural barriers, such.as trees, hedges, embankments, berms and ditches, is not considered
adequate access restriction because they can be crossed by pedestrians and off-road vehicles fairly easily.
However, natural barriers coupled with warning signs in a remote rural area may be adequate.

At surface disposal sites containing active and/or closed sewage sludge units  located in areas with high
population densities or sensitive land use practices, several of the above management practices may be
necessary. In areas that are less susceptible to public trespass, such as, rural areas, warning signs alone
may suffice.  In areas with a high  probability of  vehicular traffic  across  the surface disposal site,
measures restricting vehicular traffic must be taken. If a surface disposal site contains only closed sewage
sludge units, provision must be made to maintain the access control practices for 3 years from the date
that the last active sewage sludge unit on that surface disposal site closes.

Permit Conditions

The regulatory requirement of §503.24(m) can be embodied in the permit in three ways:

     •  By using the exact language from Part 503

     •  By prescribing specific public access controls as permit  conditions

     •  By  incorporating a  permit condition  that  requires submission of  a plan and  schedule for
        implementation of best management praptices to restrict public access.

If the permit writer determines that current access management practices are. adequate, she may want to
include these management practices in the permit or  reference the surface disposal site's design plan or
other document where these management practices  are described. The permit writer should also include
a permit condition requiring the maintenance and upkeep of access  restriction measures.

5.5.12  GROUND-WATER PROTECTION
  Statement of Regulation

    §503.24(n)(l)  Sewage sludge placed on an active sewage sludge unit shall not contaminate ail aquifer.

    §503.24{h)(2)  Results of a ground-water monitoring program developed by a qualified ground-water scientist
                at a certification by a qualified ground-water scientist shall be used to demonstrate that sewage
                sludge placed on an active sewage sludge unit does not contaminate an aquifer.
Permitting Factors

Part 503 prohibits  contamination of an aquifer.  The regulation provides for two alternatives for the
owner/operator to demonstrate that the aquifer is not contaminated:  providing a certification that the
sewage sludge being placed on the  active sewage sludge unit  will not contaminate the aquifer,  or
performing ground-water monitoring.  The certification is not a simple signed statement; rather, it is a
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                            5. SURFACE DISPOSAL - PART 503 SUBPART C
 hydrogeologic assessment by a qualified ground-
 water scientist.  Based on the hydrogeology of the
 site and the design of the surface disposal site, the
 scientist determines the likelihood of ground-water
 contamination occurring at the  site and then
 certifies that, based on his/her knowledge of the
 site,  contamination  is not likely to occur.   The
 ground-water monitoring alternative, on the other
 hand, is  an  actual demonstration that  aquifer
 contamination is not  occurring through  actual
 measurement of nitrate in the ground water below
 the surface disposal site.

 The permit writer must  verify the information
 submitted  to  support either  option.   While
 verifying  information, the permit writer should
 consider  the potential  of  the site  to  cause
 contamination, and the risks to human  health and
 the environment should  contamination  of the
 ground water occur.
                                ^
,, Contaminate an aquifer means to introduce^
  substance   tliat   causes ,  the   maximum
,  contaminant level for  nitrate in  40  CFR
— § 141.1J to be exceeded in  ground water or
  that causes the existing concentration of nitrate
  in ground^ water to increase when me existing
  concentration of nitrate  in the ground water
  exceeds the  maximum contaminant level for,
  nitrate in fWLll. [§503.21(c)J
  Aquifer  is  a geologic formation, group of
  geologic formations,, or a portion of a geologic
  formation capable of yielding ground water to
  wells or springs.  [§5Q3*21(b)J
To perform these assessments, the permit writer should obtain appropriate documentation from the owner/
operator, and the State and local ground-water protection agencies, to determine if the surface disposal
site is located over an aquifer designated for ground-water protection or whether the aquifer is already
contaminated.  In addition, preliminary design information and site-specific geological information may.
indicate if the site needs special consideration.

The first assessment should determine the potential of the surface disposal site to cause or contribute to
nitrate contamination.  This potential will depend on many considerations, such as:

     • Age of the surface disposal site or sewage sludge unit

     • Site design features (e.g., lined versus unlined)

     • Site-specific hydrogeological and meteorological features.

Second, the permit writer should determine the risk to human health and the environment associated with
the contamination  of an aquifer below the surface disposal site. This assessment should consider the
degree of contamination that  could occur (i.e., whether the increase in nitrate levels in the aquifer will
lead to levels above the maximum contaminant levels [MCLs]).  This assessment also should consider
the size of the affected community if contamination  occurs (i.e., whether the site is located over a sole
source aquifer serving a small community or  serving several large communities).   The permit writer
should also determine if any  applicable State or locality-specific ground-water protection requirements
apply. To do so, the permit  writer should consult the following documents, if available:

     • State Wellhead Protection Plan

     • Comprehensive State Ground-Water Protection Program Plan.
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
A State Wellhead Protection Plan is a plan that is established under the Wellhead Protection (WHP)
Program to protect ground waters that supply wells and well fields Contributing drinking water to public
water supply systems (SDWA 1986).  The Comprehensive State Ground Water Protection Program Plan
is developed by States to implement the  1991 EPA Ground-Water Protection Strategy (EPA  199 Ic).
These plans may include information useful to the permit writer, such as:

     •  Ground-water protection goals                  ,

     •  Identification of ground-water classification systems,  special  aquifers requiring protection,  or
        priorities for ground-water protection

     •  Designated wellhead protection areas (WHPA) for each wellhead based on hydrogedlogic data,
        ground-water flow,  and aquifer recharge and discharge.

Performing these assessments  allows the permit writer to assign the surface disposal site a relative risk
factor.  However, the permit writer should be aware that the determination of whether a site has a low,
medium or-  high risk factor is  a  subjective  determination.  Sonic States and/or localities may have
prioritized areas within their jurisdiction and have actually identified specific criteria  on which to base
the judgment (e.g., Wellhead  Protection Programs or State Ground-Water Protection Programs) while
others may not have: ',

Where the permit writer does not find institutionalized policies on assigning priorities and risks, she may
develop a system for assigning  the relative risk factors.  The system may ibe based on one of several
criteria:                                                  ^

     •  Quality of ground water beneath the active sewage sludge unit

     •  Designated uses or potential uses of ground water below the active sewage sludge unit

     •  Design of the active sewage sludge unit (i.e., lined versus unliried, and stable versus unstable
        land).

The permit writer may wish to develop the relative risk factor system based on one of these criteria or
a combination of all three. For example, using the first criterion, low-risk sites may be identified as sites
located over contaminated aquifers.  A high-risk site would be located over ground water of exemplary
quality.   An example using  all three criteria  would yield low-risk sites where  ground waters  are
contaminated and will never be useable as a drinking water source because of the cost of remediation,
and where the sewage sludge Unit  has a liner and leachate collection system.  A high potential risk site
would be an unlined site located in an area with known seismic activity and over a high-quality drinking
water source that is irreplaceable and ecologically vital.

Based on the relative risk factors  assigned to the site, the .permit writer can decide if the appropriate
measures have been taken.  In general, a certification is appropriate for a surface disposal site with low
to medium relative risk factors. Ground-water monitoring may be necessary for high-risk surface disposal
sites. Both the certification and the ground-water monitoring program must be developed by a qualified
ground water scientist.  The permit writer should request that information on the qualified ground-water
scientist's educational and work experience be submitted along with  the certification or ground-water
monitoring plan to allow the permit writer to evaluate the scientist's credentials and expertise.
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
Certification

As  mentioned  above,   the  certification
alternative is most appropriate  for  low to
medium risk sites.   This certification  is a
hydrogeologic assessment that the aquifer will
not be contaminated by sewage sludge placed
in the active sewage sludge unit(s).  This
hydrogeological assessment must be based on
site-specific  data.   The  assessment report
should:
,A qualified ground-water scientist is an individual
 With a baccalaureate or post-graduate degree in the
 natural sciences or engineering who has sufficient
 training and experience in ground water hydrology
 and related,fields, as may be demonstrated by State
 registration,   professional   certification,   or
 completion of accredited university'programs* to
 make  sound  professional  judgments  regarding
 ground  water  monitoring,   pollutant  fate  and
 transport, and corrective action- J§503.21(1)]
     •  Identify   regional   geologic   and
        hydrogeologic characteristics, such as	
        geologic  formations   and  origins,                                           • '
        geomorphology, seismic activity, drainage,  surface waters  and their  quality,  soils, aquifer
        recharge and discharge  areas, regional topography, and meteorological and  climatological
        information

     •  Analyze  the  effect of site topographic .and geomorphic  features on  the  site ground-water
        hydrology

     •  Classify and describe site hydrogeological properties, such as aquifer thickness, porosity, texture,
        hydraulic conductivity, infiltration rates, transmissivity,  and structure

     •  Include structural contour maps and geological sections showing  hydrogeology of uppermost
        aquifer, perched zones, interconnections, and water table elevations

     •  Characterize ground water, including water levels, flow patterns, flow rates, and water quality.

The complexity of the certification depends on the relative risk factor and on specific site characteristics.
For low  relative risk  sites,  the permit writer may require  that the certification  be based  on a
hydrogeological assessment prepared from already existing documentation on the hydrogeology of the site
and surrounding areas.  Such documentation includes historical records  (e.g., precipitation or land
development), USGS information or State geologic survey maps, Soil Conservation Service reports and
maps indicating soil types, studies performed on nearby sites, and geologic  logs of existing wells or test
borings that have been taken near the site.   Ascertaining  that  the aquifer is not and will not be
contaminated would be  deduced from this information.

For medium relative risk sites, the permit writer may require that the above existing information on the
hydrogeology of the site be verified or supplemented with site-specific, field-collected measurements, such
as soil borings, rock corings, material tests,  surface geophysical surveys, and  hydraulic conductivity
measurements. For medium relative risk sites that have existing problems with jiitrates, the permit writer
may consider requiring  in the permit that the certification be based on fate and transport demonstrations,
such as:

     •  Site-specific,  field collected measurements,  sampling, and analysis of physical, chemical and
        biological processes affecting nitrate fate and transport
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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
     •  Nitrate fate and transport predictions that maximize nitrate migration and consider impacts on
        human health and the environment.                      •

The permit writer could require a one-time monitoring of the aquifer to" verify that the active sewage
sludge units are not contaminating the aquifer.  The permit writer may decide that  there are sufficient
wells in close proximity to the surface disposal site to provide the needed monitoring information or he
may require the construction of wells specifically for this purpose. The monitoring  information should
be submitted with the certification.  The results can be used by the permit writer to  determine the need
for additional periodic monitoring at that surface disposal site.  If wells were ponstructed for this initial
assessment,  they can then be used for the required periodic monitoring.
' -    . •                                        I                       •..-,'
Ground-Water Monitoring

Sites  that a  permit writer determines have a high relative risk factor may be required to monitor the
ground water to demonstrate that the sewage sludge placed on any active sewage  sludge units at the
surface disposal site does not contaminate an aquifer. Such a demonstration is made by analyzing ground-
water samples collected from monitoring wells placed downgradient and comparing the analytical results
of the nitrate concentrations to samples taken from wells placed upgradient of the active sewage sludge
unit.

Before the permit writer can determine which ground-water monitoring permit conditions to incorporate
into the permit, he must have a clear understanding of the hydrogeological conditions at the surface
disposal site. This is accomplished by requiring the owner/operator to submit a hydrogeologic report of
the disposal site and to develop a ground-water monitoring plan.  The permit writer should review and
evaluate the hydrogeological report and ground-water monitoring plan.  If the owner/operator does1 not
have adequate information or resources to develop such a hydrogeologic report and monitoring plan for
the permit application, the permit writer may  choose to require the owner/operator to  submit all available
hydrogeologic information and issue the permit incorporating a compliance schedule for development and
implementation of a ground-water monitoring program. The milestones in the compliance schedule could
address the development of an  adequate hydrogeologic  report, completion of a monitoring plan,
commencement of monitoring well development, and commencement of monitoring well sampling.

Hydrogeologic Assessment and Ground-Water Monitoring Plan

The permit writer must require that the ground-water monitoring plan be prepared by a qualified ground-
water scientist. This plan can then be used by the permit writer to develop permit conditions for periodic
ground-water monitoring. At a minimum, thq permit writer should require the owner/operator to submit
the following information as part of a hydrogeologic study that assesses aquifer contamination:

      •  A characterization of the site geology and hydrology (hydrogeologic  assessment) including
        seasonal variability in ground-water flow directions and an interpretation of the information and
        data submitted            '                                    r

      •  A description of the ground-water monitoring system design and installation for the active sewage
        sludge unit(s) (including a well location map)           .                            ,
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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
     • A discussion of sampling and analytical procedures including statistical methods used

     • Results  of  nitrate-nitrogen  analyses  of  ground-water  samples  with  associated  quality
       assurance/quality control (QA/QC) data.

The permit  writer will need to determine whether the ground-water hydrogeologic assessment and
monitoring plan is complete and whether the information provided by the owner/operator verifies the
absence of aquifer contamination. This type of evaluation requires:  (1) a review of the data quality; (2)
an understanding of the interpretation of the hydrogeologic and water quality data; and (3) an analysis
of whether the data and information submitted fully characterize the potential ground-water  impact of
placing the sewage sludge on the sewage sludge unit.  Finally, the evaluation should also  include a
comparison of the nitrate-nitrogen levels reported for each ground-water sample to the MCL for nitrate-
nitrogen (10 mg/1) to verify the  absence of aquifer contamination.

Several other guidance documents published by EPA may be useful to the permit writer in reviewing the
ground-water assessment and monitoring plan.  These documents are listed in Table 5-6.  Much of the
information  provided in these documents is not duplicated in this document.  Instead, only the most
important technical considerations that the permit writer must address in a review of a hydrogeologic
assessment and ground-water monitoring program are discussed.  The following discussion details the
type of information  that should be included in  the hydrogeologic assessment  and monitoring plan
submitted by the owner/operator.
       TABLE 5-6 SUPPORTING DOCUMENTS FOR REVIEW OF GROUND-WATER
                         ASSESSMENT AND MONITORING PLANS
Document Title
The Ground Water Monitoring
Technical Enforcement Guidance
Document
RCRA Comprehensive Ground-Water
Monitoring Evaluation
Statistical Analysis of Ground-Water
Monitoring Data at RCRA Facilities
(EPA/530-SW-89-026)
Procedures Manual for Ground Water
Monitoring at Solid Waste Disposal
Facilities
Guidance Provided to the Permit Writer,
Provides technical guidance on the development of ground-
water monitoring programs, including site characterization,
well design and placement, and well construction
Provides guidance to evaluate the compliance of a ground-
water monitoring system
Provides information to review and evaluate ground-water
quality data using statistical methods
Provides guidance for hydrogeologic investigation including
characterization of site hydrogeology, design of detection
monitoring systems, design and construction of monitoring
wells, and sampling and analysis of ground water
Characterization of Site Geology and Hydrology

The permit writer should require that the owner/operator provide data on the site geology and hydrology
to identify all potential migration pathways and the target monitoring zones. The collection of subsurface
samples, ground water-level measurements,  water quality data, aquifer data, meteorological  and
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
climatological data, arid descriptions of other site-specific conditions are used to formulate interpretative
tools, such as geologic cross sections,  isoconcentration maps, water-level contour maps, flow nets, and
aquifer characteristics.   The final hydrogeologic assessment should identify the spatial variability of
geologic units and the seasonal/temporal variability expected to occur in the ground- water flow systems.

The geologic units that compose the targeted monitoring zone must be identified and characterized.  It
is important to determine how these units may vary spatially and how they are connected hydraulically
with surrounding  units.   The quantity of data required to Characterize the target monitoring  zone(s)
depends on the site's geological complexity.   For example,  a subsurface environment composed of
geologic units that are highly variable and appear to be discontinuous may require considerably more data
than a system that is relatively homogeneous and predictable.

Important geologic features that indicate a high degree of variability and irregularity within the subsurface
are: fracture zones, solution cavities, pinchout zones (i.e., discontinuous strata across the site), tilted or
folded beds, or high hydraulic conductivity zones.  These types of geologic features often control the
directipn and velocity of ground1water flow. For example, since fractures are often preferred pathways
for ground water,  the orientation of fractures can control the direction of ground-water flow.

Seasonal and temporal variability of ground-water flow directions and ambient ground-water quality must
be characterized.  The influence of surface water bodies on the ground-water system (e.g., tidal variations
and river stage variations) is often an important control on the direction and quality of ground-water flow.
Other local influences on ground-water flow that can change seasonally or temporally include on or off-
site pumping wells, injection wells, irrigation or agricultural activities, and other land-use activities.

Site conditions-may help identify the amount and extent of potential contaminant migration. For example,
orientation and dimensions  of an active sewage sludge unit will affect the placement of ground-water
monitoring wells,  and should be evaluated to ensure that all migration pathways are monitored.

The site characterization is adequate when the following conditions are satisfied:  (1) the target monitoring -
zone is identified (usually the uppermost aquifer); (2) the degree of hydrogeologic variability within the
targeted monitoring zone is defined; and (3) all potential contaminant migration pathways from the active
sewage sludge unit are identified.  This information fosters accurate placement of monitoring wells to
detect potential contamination.

Description of the Ground-Water Monitoring System
                                                                -••'..-"             \
The permit writer should require  that the  owner/operator provide a well location map as well  as
information on well installation and construction.  Monitoring wells should be placed downgradient of
the active sewage sludge unit to intercept ground water that ,flows beneath the unit;  This requires
identification of the area of ground-water flow that could interact with potential contaminant migration
from the unit.  The number  of downgradient wells should be sufficient to determine water quality at the
point of compliance  (i.e.,  as  close to  the unit  boundary as  possible).   Typically,  at.least three
downgradient wells are required to monitor the lateral extent of contaminant migration.  An upgradient
well, which is not influenced by the sewage sludge unit but is within the vicinity to represent background
ground water quality, should be part of the ground-water monitoring system. To avoid potential pathways
of contamination,  an upgradient/background well  should be located where it  won't be influenced by
ground-water mounding beneath the unit.
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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
Monitoring wells should be screened laterally and vertically within the target monitoring zone(s) and be
constructed of materials that will not affect the quality of ground-water samples.  The owner/operator of
the surface disposal site should explain the number and placement of the monitoring wells.  After
consideration of all migration pathways and the effects of temporal variations on the ground water flow
system, additional monitoring wells or alternative monitoring techniques such as vadose zone monitoring
or tracer tests may  be required.  For example, fracture and solution channels in an aquifer (e.g., karst
hydrology) may require non-conventional  monitoring  techniques.   In addition, certain subsurface
conditions such as multiple aquifers may require additional monitoring for hydrologic interconnectiveness.

Sampling and Analytical Procedures

The permit writer  should  require that the owner/operator  submit a description of all sampling  and
analytical procedures used  to collect the data.  The following components of the sampling  and analysis
program should be  addressed in the plan:

     •  Sample collection,  preservation, and handling

     •  Analytical procedures                   .

     •  Statistical methods used to assess ground-water monitoring data  '

     •  Chain-of-custody procedures

     •  Field and laboratory quality assurance/quality control procedures.

A representative ground-water sample is collected when the following are ensured: (1) the use of proper
well evacuation techniques;  (2) sampling  equipment and techniques that  minimize alteration of the
chemical constituents in the ground water; (3)  adequate documentation of field activities;  and (4)
identification and reporting of errors or anomalies. Sample integrity must be maintained through proper
sample preservation, handling, and chain-of-custody procedures.

All activities related to characterizing the  site hydrogeology, design and installation of ground-water
monitoring wells, and sampling and analysis should include a quality assurance/quality control (QA/QC)
program. All samples must be evaluated with respect to standard QA/QC procedures and to the specified
data quality  objectives  (i.e., the  amount  of imprecision and bias  that will  be tolerated).   QA/QC
procedures should include  the use of standards, laboratory blanks, field and trip blanks, and duplicates.
Field QA/QC procedures should include equipment decontamination  and chain-of-custody.

The frequency of any initial compliance sampling and number of samples collected should represent any
expected seasonal variation in ground-water quality. Typically,  at least four rounds of ground-water
samples are collected over a course of 1 year to ensure seasonal variability.  Statistical procedures are
often used to determine the appropriate sampling interval that will  reflect site-specific hydrogeologic
conditions.

Developing Permit Conditions for Ground-Water Monitoring

Permit conditions for ground-water monitoring are developed according to the complexity of the site, site
hydrogeology, and potential and real risks.  The variability  of sites is so great that it becomes difficult
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                            5. SURFACE DISPOSAL - PART 503 SUBPART C
 to provide guidance to the permit writer in developing the ground-water monitoring permit conditions.
 Appropriate permit conditions could-range from simply incorporating the owner/operator's ground-water
 monitoring plan by  reference to developing  detailed conditions specifying  construction details and
 statistical procedures. The following discussion provides the minimum information that the permit writer
 should address in the permit and furnishes guidance on the consideration of more detailed provisions.

 If the permit writer determines that the proposed ground-water monitoring plan provides a sound technical
 basis for detection monitoring, the permit  writer may incorporate the plan by reference in the ground-
 water monitoring section of the permit. If, however, the permit writer determines that the ground-water
 assessment and monitoring plan is deficient, she may decide to specify the terms and conditions of the
 monitoring to be performed in the permit.  At a minimum, the conditions associated with ground-water
 monitoring that the permit writer should address in the permit include:

      •  Frequency of monitoring               .    ,

      •  Well location, construction, and maintenance              ^

      •  Monitoring program and data evaluation          '

      •  Reporting and recordkeeping.       "   -                              '
                                                                         v       >  '
 Frequency of Periodic Ground-Water Sampling and Analysis

 The permit writer should specify an appropriate frequency for sampling and analysis of nitrate in ground
 water for any  active sewage sludge  units  at the surface  disposal site. Monitoring frequency can be
 influenced by the following factors:

      •  Rate and direction of the ground-water flow

      •  Location of the monitoring well                        ,                       >

      •  Trends in the water quality data

      •  Climatological and meteorological  characteristics

      •  Others (such as the resource value of the aquifer and the fate and transport of the nitrate in
        ground water).

 The permit writer must, therefore, develop  a flexible monitoring schedule, allowing for modification
 based on these factors.  Initially, the permit writer may want to base the frequency of monitoring on the
 ground-water flow rate, location,  and climate.  However, he may want to  modify  this provision later,
 based on the trends in the site's water quality data. Special considerations are warranted for sites where
 contamination  is suspected and the frequencies must be altered for aquifer contamination assessment
 reasons,                              .

. Flow rates  are primarily dependent on the aquifer porosity and permeability  as well as the hydraulic
 gradient at  the site.   The higher the flow rate,  the greater the monitoring frequency needed.  For sites
 that are underlain by impervious clay soils, semi-annual or annual monitoring may be sufficient.  For
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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
sites that have fracture or solution porosity aquifers, it is possible that nitrogen could migrate from the
active sewage sludge unit within weeks or even days.  Thus, quarterly or monthly monitoring may be
more appropriate.                                                        .

By considering regional climatological characteristics, the permit writer may obtain information on the
fluctuations of leachate development that may occur over the year. This type of information may indicate
that, instead  of arbitrarily assigning a sampling  date every third month (for quarterly monitoring),  it
would be more appropriate to correlate the sampling period with ground-water recharge periods when
leachate generation is greatest.

Frequency  of monitoring may also be based on the level  of concentration of nitrate found in the ground
water and whether the surface disposal site is located over an aquifer used for drinking water or with the
potential to be used for drinking water. If the surface disposal site is located over an aquifer used for
drinking water, the permit writer may elect to specify, in the permit, trigger-based monitoring such as
that used in EPA's Phase II Rule for National Primary Drinking Water  Standards.  These regulations
require that ground-water systems sample for nitrate annually as a baseline frequency. If any sample is
greater than or equal to 50 percent of the  MCL, this triggers  an increase in monitoring frequency to
quarterly sampling. If four quarterly samples are shown to be reliably and consistently below the MCL,
then the  sampling  can be again reduced to annually, in  which case  samples  must be taken during the
quarter that previously yielded the highest analytical result.

Well Location, Construction and Maintenance

The permit writer should specify, in the permit, the design specifications for the ground-water monitoring
system. This monitoring system may be the same system as that provided in the ground-water monitoring
plan furnished by the owner/operator.  If the permit writer determines that any aspect of the proposed
system is deficient,  the  appropriate design  specifications should be included in  the  permit.   At a
minimum, the permit writer should specify the design of the monitoring network, including the number,
location, and sampling depths of all background and downgradient monitoring wells. This information
can be specified through the  use of maps  and cross-sections.   Construction materials and well design
should also be specified.  This may  include as much detail as possible on drilling methods, well casing
and materials, well diameter,  well intake design, well development procedures, and methods for sealing
the annular space.
                      '*       ,  ,
The spacing and required number of downgradient wells is  based on the size of the active sewage sludge
unit.  However, the permit writer should, at a minimum,  require three downgradient wells located as
close as possible to the edge of the unit penetrating the entire saturated thickness of the aquifer. The line
of wells should not have  less  than one downgradient well for every 76 meters of frontage (EPA 1980).
The permit writer may specify an additional well within the surface disposal site to indicate whether
leachate  is reaching ground water and to give early warning  of potential aquifer  contamination.  In
addition, the permit writer may want to add a provision that any detection  of nitrates in the indicator well
will trigger the owner/operator to monitor the downgradient wells more frequently.

The number and location of upgradient wells to determine background water quality should be specified
based on the variability of the water quality prior to flowing under the site.  In many cases,  the permit
writer may want to require multiple background wells to provide better measurements.  However, at a
minimum,  one must be required.  Additionally, the statistical procedure used to determine the presence
or absence of contamination may  dictate  how  many wells are needed.   Background wells do not.
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
 necessarily have to be placed upgradierit of the active sewage sludge unit, but the permit writer should
 review any placement criteria to ensure that the wells are not being influenced by any contamination at
 the site.                                                          "

 The permit should  require that  the 'owner/operator provide  appropriate maintenance  for  the wells.
 Ground-water monitoring plans should contain a schedule for maintaining the ground-water monitoring
 system, including replacing or redrilling monitoring wells, replacing seals and caps, repairing or replacing
 pumps, and any other kinds of general equipment maintenance.

 Monitoring Program and Data Evaluations

 The permit should specify  sample  collection, preservation,  chain of custody  controls,  analytical
 procedures and QA/QC procedures to be used for the ground-water monitoring.  The permit writer may
 also want to specify evacuation techniques to remove stagnant water from the wells prior to sampling.
 Monitoring wells  require  sampling at different depths  to  ensure that the contamination potentially
 migrating from the site will be intercepted by the wells.  The permit writer should specify the amount
 of sampling and the sampling required in the vertical dimension.   The permit writer should be careful
 when specifying sampling depths to avoid mixing of waters of different quality during sampling.  In most
 cases, sampling  of sites on the downgradient boundary requires sampling at the water table and several
 additional depths.

 The sampling and analysis section of the permit should include provisions to measure static water
 elevations in each  well prior to each sampling event.  This collection of the water elevation is important
 in determining if horizontal and vertical flow gradients have changed since the initial hydrogeological
 characterization  (EPA 1992a).  Any  changes would then require  that the owner/operator modify the
 existing ground-water monitoring system.

 The permit writer  should also specify that the owner/operator use a statistical procedure that provides a
 reasonable confidence that the migration of nitrates in amounts that could cause contamination from the
 active sewage sludge unit into an aquifer is detected. The  statistical performance standards will limit the
possibility of making false conclusions from the monitoring data (EPA 1992a).

Recordkeeping and Reporting

At a minimum,  the  permit writer should require that the owner/operator maintain the  results of any
ground-water monitoring in the operating record during the period the sewage sludge unit is active and
for 3 years after  the sewage sludge unit closes.  At high-risk sites, however, the permit writer may want
to require that, in addition, the monitoring results be reported on a periodic basis.  In this case,  the
owner/operator should be  required to submit  the results to the permitting  authority along with an
explanation of the sampling and analytical methods used and the statistical methods employed to determine
presence or absence of contamination.

At  a minimum,  reporting should be required for those  sites  that have trigger-based monitoring
requirements or when the owner/operator determines that there is a statistically significant increase above
the MCL concentration for  nitrates  or, if the aquifer  is  already contaminated,  above the existing
concentration. In the case of contamination, the owner/operator may be required to submit an application
for a permit modification to establish corrective action requirements in the permit.
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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
5.6    OPERATIONAL STANDARDS

5.6.1   PATHOGENS

Sewage sludge to be placed in an. active sewage sludge unit must meet one of the Class A or Class B
pathogen reduction alternatives in §503.32 unless the sewage sludge placed on an active sewage sludge
unit is covered with soil or other material at the end of each operating day.  The site restrictions in
§503.32(b)(5) associated with the Class B pathogen reduction alternatives do not apply to sewage sludge
placed in a surface disposal site.  Each of the pathogen requirements listed in Table  5-7 and their
associated monitoring and recordkeeping requirements are further discussed in Chapter 8.


  TABLE 5-7 PATHOGEN AND VECTOR ATTRACTION REDUCTION REQUIREMENTS
                          FOR PREPARERS OF SEWAGE SLUDGE
    Pathogen Reduction
Vector Attraction Reduction
    Class A

    Alternative 1  time and temperature
    Alternative 2  pH, temperature and time
    Alternative 3  one-time demonstration correlating
                 pathogen levels for enteric viruses
                 and viable helminth ova and
                 operating parameters
    Alternative 4  pathogen levels for enteric viruses
                 and viable helminth ova
    Alternative 5  Processes to Further Reduce
                 Pathogens (PFRP)
                 1.   Composting
                 2.   Heat drying
                 3.   Heat treatment
                 4.   Thermophilic aerobic digestion
                 5.   Beta ray irradiation
                 6.   Gamma ray irradiation
                 7.   Pasteurization
    Alternative 6  equivalent to PFRP
    In addition all six alternatives include pathogen
    levels for fecal coliform or Salmonella
Option 1      38 percent volatile solids reduction
Option 2      lab demonstration of volatile solids
             reduction anaerobically
Option 3      lab demonstration of volatile solids
             reduction aerobically  ,
Option 4      SOUR <  1.5 mg 02/hour/g total
             solids
Option 5      Aerobic process for 14 days at
             > 40°C
Option 6      pH to  > 12 and retain at 11.5
Option 7      > 75 percent solids for stabilized
             solids
Option 8      ^90 percent solids for
             unstabilized solids
    Class B

    Alternative 1  pathogen levels for fecal coliform
    Alternative 2  Processes to Significantly Reduce
                 Pathogens (PSRP)
                 1.   Aerobic digestion
                 2.  , Air drying
                 3.   Anaerobic digestion
                 4.   Composting
                 5.   Lime stabilization
    Alternative 3  equivalent to PSRP	
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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
 Table 5-7 lists the pathogen requirements that apply to the preparer of the sewage sludge.  If the owner/
 operator covers  the  sewage sludge at the  end of each operating  day [vector  attraction reduction
 requirement of §503.33(b)(ll)], then no pathogen requirements need to be met by the preparer of the
 sewage sludge.                            .

 In developing permit conditions, the permit writer will need to rely on the information provided by the
 applicant on the pathogen treatment processes employed by the preparer and by the owner/operator.  The
 pathogen requirements for the owner/operator  depend on whether the sewage sludge provided to the,
 owner/operator by the  preparer already meets one of the Glass A or Class B  pathogen reduction
 alternatives. If so, then the owner/operator would not be subject to any pathogen requirements. If the
 preparer does not meet one of the Class A or Class B pathogen reduction alternatives, the owner/operator
 must either meet  one of them or cover the sewage sludge daily.

 5.6.2   VECTOR ATTRACTION REDUCTION

 Sewage sludge to be  placed in an active sewage sludge unit  must meet one of the vector attraction
 reduction alternatives listed in §503.33, or an alternative equivalent to one of the first eight methods, as
 determined  by the permitting authority.  Each of the vector attraction reduction requirements listed in
 Table 5-7 and Table 5-8 and their associated monitoring and  recordkeeping requirements are further
 discussed in Chapter 8.  Table 5-7 lists the vector  attraction reduction requirements that apply to the
 preparer of the sewage sludge. Table 5-8 summarizes those that apply to the owner/operator of an active
 sewage sludge unit.

   TABLE 5-8  PATHOGEN AND VECTOR  ATTRACTION REDUCTION REQUIREMENTS
               FOR OWNERS/OPERATORS OF SURFACE DISPOSAL SITES
Pathogen Reduction
None
\
Vector Attraction Reduction
Option 9
Option 10
Option 11 .
injection below land surface
incorporation into soil
daily cover
In developing permit conditions, the permit writer will need to rely on the information provided by the
applicant on the vector attraction reduction treatment processes employed by the preparer and by the
owner/operator.  The vector attraction reduction requirements for the owner/operator depend on whether
the sewage sludge provided to the owner/operator by the  preparer already meets one of the vector
attraction reduction requirements in §§503.33(b)(l) through  (8) or an equivalent alternative. If so, then
the owner/operator would not be subject to any vector attraction reduction requirements.  However, if
the preparer does not meet one of these vector attraction reduction requirements, then the owner/operator
,would be required to comply with the. vector attraction reduction alternatives in §§503.33(b)(9) through
(11).                     ,                                                                 &
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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
5.7    FREQUENCY OF MONITORING REQUIREMENTS

In developing permit conditions for monitoring sewage sludge placed on active sewage sludge units., the
permit writer should consider including the following:

     • Parameters to be monitored

     •' Monitoring frequencies

     • Monitoring locations

     • Sampling types and preservation protocol

     • Analytical methods.
                                                                             \
In addition, the permit writer may find that including a provision that specifies that QA/QC procedures
must be followed will ensure that the results of the monitoring program are reliable and precise. The
following subsections briefly highlight each of the above-listed monitoring issues that should be addressed
in the permit.

If an active sewage sludge unit is not owned and/or operated by the generator of the sewage sludge, the
permit writer  needs to decide whether to impose the sewage sludge monitoring requirements on the
surface disposal site, the generator, or both.

5.7.1  PARAMETERS TO BE MONITORED

Sewage sludge placed onunlined units must be monitored for the three regulated pollutants/pathogen
reduction,  and vector attraction reduction. Sewage sludge placed on units that are equipped with liners
and  leachate  collection  systems  are only subject  to  the pathogen and vector attraction reduction
requirements.   If a cover is  placed  over the sewage sludge, air monitoring for methane is  required
continuously at the surface disposal  site property line and within any structures at the site.  This air
monitoring is required while the sewage sludge unit is active and for 3  years after it is closed.  This
monitoring was discussed earlier as a management practice in Section 5.5.9.           '

The sewage sludge quality parameters established by §503.26 have been reproduced in Table 5-9.   In
addition, various pathogen and vector attraction  reduction alternatives are technologies  that must  be
maintained and monitored  on a  regular basis.   Chapter 8  describes all  the alternatives and  the
recommended monitoring frequencies for each aspect of the technology.

5.7.2   MONITORING FREQUENCY

The frequency of monitoring is typically established through permits on a case-by-case basis. However,
to enhance the self-implementation of the regulation, monitoring frequencies have been established in Part
503 for pollutants, pathogen density requirements, and the vector attraction reduction requirements in
 §§503.33(b)(l)-(4) and  (b)(6)-(8).  The monitoring frequencies established by §503.26  for surface
disposal are shown in Table 5-10, but the permit  writer has the discretion  to  require more frequent
monitoring than established by Part 503. Additionally, the regulation gives the permit writer discretion
 to reduce the pollutant monitoring frequencies if, after 2 years, the variability of pollutant concentrations
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                          5. SURFACE DISPOSAL - PART 503 SUBPART C
               TABLE 5-9 PARAMETERS REQUIRED TO BE MONITORED
                              AT SURFACE DISPOSAL SITES
- ' , Parameters To Be Monitored ' , ,
Pollutants" Pathogens
Arsenic Fecal coliform of Salmonella
Chromium , Enteric viruses'1
Nickel Helminth ovab
Vector Attraction Reduction
Volatile solids reduction0
Specific oxygen uptake rated
PHC .
Percent solidsf
"Percent solids of sewage sludge must be monitored to report pollutant concentrations on a dry .weight basis
bClass A alternatives 3 and 4
"Vector attraction reduction options 1, 2, and 3
•dVector attraction reduction option 4 ,
eVector attraction reduction option 6
/Vector attraction reduction options 7 and 8.
           TABLE 5-10 FREQUENCY OF MONITORING - SURFACE DISPOSAL
, Amount of Sewage Sludge8
: (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
Freqtiencyb
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)
aAmount of sewage sludge placed on active sewage sludge unit (on a dry weight basis).
bAfter the sewage sludge is monitored for 2 years at the above frequency, the permitting authority may reduce
the frequency of monitoring for pollutant concentrations and for the pathogen density requirements in
§§503.32(a)(5)(ii) and (a)(5)(iii) [§503.26(a)(2)].
Source:  §503.26
are low and compliance is demonstrated so that a reduction in frequency appears appropriate.  If no
sewage sludge is disposed, there is no frequency of monitoring requirement. If the permittee is using
pathogen Class A alternative 3, the permit writer can reduce the monitoring frequency for enteric viruses
and viable helminth ova after 2 years.

The monitoring  frequency is based on the amount of sewage sludge placed in an active sewage sludge
unit in a given 365-day period. Whenever possible, the permit writer should specify the 365-day period
and the corresponding monitoring  frequency.  The permit writer should also specify that if the amount
of sewage sludge placed on the active sewage sludge unit during the 365-day period exceeds the amount
on which the monitoring frequency was based, then the permittee must notify the permitting authority and
increase the monitoring frequency  to that required for the amount of sewage sludge to be placed.  For
example, if the permittee is expected to place between 200 and 750 metric tons per year during the 5-year
permit period,,the permit writer could specify two monitoring frequencies.  •-   '    •.
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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
The permit writer should remember that, in some cases',  it may be more appropriate to increase the
monitoring frequency beyond the frequency required by §503.26, particularly where the permit writer
has noted the following:                                                                      '

     •  Concentrations of pollutants vary significantly between measurements

     •  Concentrations of pollutants are close to the pollutant limits

     •  A trend indicating worsening sewage sludge quality

     •  A lack of historical data on sewage sludge quality.

Sewage sludge data collected over a 2-year period should be adequate to calculate the variability of
pollutant concentrations and to determine trends in pollutant concentrations.  The permit writer also has
the discretion to reduce the pollutant monitoring frequency after 2 years of monitoring at the frequency
specified  in Table 5-10.  In deciding whether to reduce the frequency of monitoring, the permit writer
should consider the following:

     •  Variability of the pollutant concentrations—The frequency of monitoring should not be reduced
        where sewage sludge quality varies significantly such that compliance with applicable numeric
        limits may be in question.

     •  Trends in pollutant concentrations—Treatment works with data indicating an increase in pollutant
        concentrations over the 2-year time period should not be granted a reduction in monitoring.
     •  The magnitude of the pollutant concentrations—If all sampling data reveal that the concentration
        of pollutants are significantly below pollutant limitations, a reduction in monitoring may be
        appropriate.

 The monitoring frequencies in Table 5-10 assume that the sewage sludge is placed on an active sewage
 sludge unit throughout the 365-day period.  The frequency of monitoring could be affected if the sewage
 sludge is stored before it is placed on an active sewage sludge unit.

 Two approaches that could be use when sewage sludge is stored before it is used or disposed tosshow
 compliance with pollutant concentrations 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.
 Frequency of monitoring for sewage sludge that is stored prior to use  or disposal to show compliance
 with pathogen and vector attraction reduction requirements also is discussed in section 8.4.

 When pathogen and vector attraction reduction is achieved by covering an active sewage sludge unit daily,
 that requirement has to  be met at the end of each operating day. Thus, the frequency of monitoring
 requirements in Table 5-10 are not appropriate in this case.

 5.7.3   MONITORING POINTS

 Representative sampling is one of the most important aspects of monitoring. To obtain a representative
 sample of sewage sludge, the sample must be taken from the correct location and represent the entire
 volume of sewage sludge.  For some treatment works, the location of the sampling point may have a
                                               5r64

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
 dramatic effect on the sewage sludge quality.  It is important that samples be collected from a location
 representative of the final sewage sludge that is placed on an active sewage sludge unit. Samples should
 be taken in the same manner each time monitoring is performed.  The sampling location should be safe
 and accessible.   •                                                   •

 The'permit writer should determine if there is an appropriate monitoring location to specify in the permit.
 For example, there may be a receiving station or temporary storage pile that receives all sewage sludge
 loads hauled to the site for placement on an active sewage sludge unit. Instead of a specific monitoring
 location, the permit writer could specify that  each load or a random number of loads of sewage sludge
 be sampled. For generators that send sewage sludge to a surface disposal site not owned or operated by
 the generator, the permit writer should determine whether a general description of the sampling location,
 such as "a location just prior to shipment to the surface disposal site" or a specific description of the exact
 location for collecting samples is appropriate, depending on the following considerations:

     • The variability of the sewage sludge at different sample points

     • The ability to obtain a well-mixed sample.

 For example, where a surface disposal site receives sewage sludge from several different treatment works
 on a batch-basis, the ability to mix the sewage sludge to get a sample representative of all the sewage
 sludge may be difficult. The permit writer may want to require sampling of each,sewage sludge load or
 a percentage of all the sewage sludge loads hauled to the site.

 EPA has developed three  guidance manuals  and  a  video that provide more  detail on proper sample
 collection for sewage sludge:

     • Control of Pathogens and Vector-Attraction in Sewage Sludge (EP'A 1992c)

     • POTW Sludge Sampling and Analysis Guidance Document (EPA 1989a)                      ;

     • Sampling Procedures and Protocols for the National Sewage Sludge Survey (EPA 1989b)

     • Sludge Sampling Video (EPA 1992d).         .
                                                   y         •  •  '
5.7.4  SAMPLE COLLECTION AND PRESERVATION PROTOCOL

Also important in ensuring representative samples of sewage sludge are the methods for sample collection
and preservation prior  to analysis.  The technique  for sampling sewage sludge varies depending on
whether the sewage sludge is flowing through pipes, moving on a conveyor, or stored in a pile or bin.
Sewage sludge that flows through pipes or moves on a conveyor should be sampled at equal intervals
during the amount of time the unit operates in a day.  When sampling from piles or bins, core samples
should be taken'from at least four points in the pile or bin.

The permit writer should consider whether it is more appropriate to specify that the permittee collect a
single grab sample or composite samples.  With sewage sludge, as with wastewater, grab samples are
instantaneous samples where an amount of sewage sludge is collected all at one time.  Composite samples
for sewage sludge are a series.of equal amount grab samples  collected and then combined to make a
single sample.   Composite samples can be made from a series of grab samples collected from several
                                            5-65

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
points in the cross-section of the entire sewage sludge amount, or they can be a series of grab samples
collected at regular time intervals over the duration of a sewage sludge discharge.

In determining whether to specify that a sample be collected using a single grab sample or composite
sampling method, the permit writer may evaluate factors such as:

     •  How well the sewage sludge is mixed

     •  Whether the sample is collected from a single batch of sewage sludge or from a stock pile made
        up of several batches

     •  Whether the composition of the sewage sludge varies over time.

In general, combining several samples of the sewage sludge may provide a more representative sample
than collecting one grab sample. Therefore, in most situations, composite samples should be required.
Sewage sludge is most often used or disposed in a solid  form and/or may be treated in batch processes.
Sewage sludge characteristics may also vary over time.   For these reasons,  the quality may  not be
homogeneous  from day to day  or even within the sewage  sludge volume itself due to the inability to
completely mix sewage sludges  that have high solids contents.

Appropriate preservation techniques ensure that  a sample remains representative for the period of tune
it is held prior to being analyzed.  For field and laboratory preservation of sewage sludge samples,
cooling to 4°C is  usually the most appropriate  method due to the inability to mix high solid sewage
sludges with other preservatives. The permit writer should consider specifying this preservation method
in the permit because it differs.from the more common methods for wastewater.

5.7.5   ANALYTICAL METHODS

All analyses performed to show compliance with the monitoring requirements  of Part 503 must be
conducted using the methods specified in Part 503.  Methods to analyze specific parameters in sewage;
sludge are specified in the Part 503 regulation  and shown in Table 5-11.  The permit writer should
indicate the methods needed for each analysis in the permit or incorporate the method by referencing the
regulatory citation.

The permit  writer should specify the methods needed for each  analysis in the permit.  When specifying
methods, the permit writer should consider the following:

     •  The detection limit of the method should be below the pollutant limit  in the permit

     •  Matrix interferences (many of the wastewater methods must be combined with digestio'n methods
        because of the solids contents of sewage sludge).
                                              5-66

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                    5. SURFACE DISPOSAL - PART 503 SUBPART C

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
 5.7.6   QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)

 A QA program is used to achieve a desired quality for activities, such as sample collection, laboratory
 analysis, data validation and reporting, documentation, and record keeping.  A QA program should
 address the following major areas:

     •  Proper collection procedures, equipment, preservation methods, and chain-of-custody procedures
        to  ensure representative samples       ;,

     •  Proper sample preparation procedures, instruments, equipment, and methodologies used for the
        analysis of samples               ,

     •  Proper procedures and schedules for calibration and maintenance of equipment and  instruments
        asspciated with the collection and analysis of samples

   ,  ••, Proper recordkeeping to produce accurate and complete records and reports, when required.

 QC, which is a part of the QA program, relates to the routine use of established procedures and policies
 during sample collection and analysis. The objective of QC procedures is to ultimately control both the
 accuracy and the precision of all analytical measurements.  QC for sampling procedures would include
 the use of duplicate, spiked, split samples  and samples blanks.  QC of analytical procedures should
 include the use of spiked and split samples, proper calibration protocols, and appropriate analytical
 methods and procedures.  While QA/QC is standard practice for most laboratories, the permit writer may
 determine that  specificity in the permit will ensure more reliable data, particularly  where  the sewage
 sludge is variable or where past NPDES permit  history suggests that the self-monitoring  program is
 questionable.

 5.8     RECORDKEEPING REQUIREMENTS

 Records must be kept to demonstrate that the permit conditions that implement all applicable Part 503
 regulatory  requirements  are being  met.   Part 503 requires specific  information  be  kept to show
 compliance with pollutant  concentrations,  pathogen reduction,  vector attraction reduction,  and
 management practices. These records must  be retained for 5 years. The record keeping requirements
 for surface disposal of sewage sludge are shown in Table 5-12.  This table identifies the minimum
 requirements for which records must be kept, who must keep the records, and how long they must be
 retained.                                    '      ,:    '    '  '     ^ '. .

 The permit writer is obligated to include at least the minimum appropriate recordkeeping conditions in
 each permit. Additionally, the permit writer may specify that other records be obtained or developed and
 maintained by the permittee to determine compliance with permit conditions.  For example, if the permit
writer determines that the active sewage sludge unit is located in a seismic zone, requirements to maintain
 geologic studies and design calculations should be placed in the permit.  The following technical guidance
provides examples of specific records the permit writer may want to require that the permittee retain.
                                             5-69

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
   TABLE 5-12 RECORDKEEPING REQUIREMENTS FOR SURFACE DISPOSAL SITES
   Record Keeping (§503.27)

   (a)  When sewage sludge (other than domestic septage) is placed on an active sewage sludge unit:

        (1)     The person who prepares the sewage sludge shall develop the following information and
                shall retain the information for five years.

           (i)   The concentration of each pollutant listed in  Table 1 of §503.23 in the sewage sludge
                when the pollutant concentrations in Table 1 of § 503.23 are met.

           (ii)  A certification statement.

           (iii)  A description of how the pathogen requirements in §§503.32(a), (b)(2), (b)(3), or (b)(4)
                are met when one of those requirements is met.

           (iv)  A  description  of how  one  of the vector  attraction  reduction requirements  in
                §§503.33(b)(l) 'through (b)(8), or  an equivalent vector attraction reduction requirement as
                determined by the permitting authority, is met when one of those requirements is met.

        (2)     The owner/operator of the surface disposal site shall develop the following information
                and shall retain that information for five years.

           (i)   The concentration of each pollutant listed hi  Table 2 of §503.23 in the sewage sludge
                when the pollutant concentrations hi Table 2 of §503.23 are met or when site-specific
                pollutant limits in §503.23(b) are  met.

           (ii)  A certification statement.                                     .

           (iii)  A description of how the management practices in §503.24 are met.

           (iv)  A description of how  the vector attraction  reduction  requirements in §§503.33(b)(9)
                through (b)(ll) are met if one of those requirements is met.	
5.8.1   DOCUMENTATION FOR POLLUTANT CONCENTRATIONS

Whoever is required to meet pollutant limits should be required to keep sampling and analysis results
documenting the pollutant concentrations. , The permit writer should require that  this documentation
include:

     •  Sampling records, including the date and time of sample collection, sample location, sample type,
        sample volume, name of person collecting sample, sample container, field preservation, and
        sampling QC.                                                 .
                                                  X*                       ,    ,      "     "
     •  Analytical  records including date and tune of analysis, name 'of analyst, analytical methods,
        laboratory bench sheets with raw data and calculations used to determine results, analytical QC
        and analytical results.
                                               5-70

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
5.8.2   DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION REDUCTION

Records must be maintained of certifications made  by the preparer and the owner/operator that the
pathogen reduction requirements and vector attraction reduction requirements were met and a description
of how the requirements were met.  Permit conditions should specify the required certification statement
to be used by the permittee.  These certifications must be signed by a responsible individual from the
treatment  works or surface disposal site.  If the permit is an NPDES permit,  there may already be
language in the standard conditions defining the person who must sign all records and reports. If riot,
then the NPDES language in § 122.22 may be used.                           .

The description of how the pathogen and vector attraction reduction requirements were met should be
supported by analytical results documenting pathogen density,  logs documenting operational parameters
for sewage sludge treatment units, and records  describing site restrictions to  properly  demonstrate
compliance with the provisions.  Further discussion of the suggested monitoring and recordkeeping
requirements and supporting documentation is provided in Chapter 8.

5.8.3   DOCUMENTATION TO  SHOW COMPLIANCE WITH MANAGEMENT PRACTICES

Records are required to contain a certification that the owner/operator of a surface disposal site is meeting
the management practices in §503.24 and to describe how the management practices have been met.
There are specific signatory requirements for the certification as discussed in the previous section. Please
note that the signatory requirements for  certifying compliance with the management practice for aquifer
non-contamination differ. The permit writer, at a minimum, can require that a description be maintained
in the records or may be more specific in the permit as to the documentation that is required.  If the
permit  writer decides  that  more  specific information is needed to  determine compliance  with a
management practice, the permit writer must specify in the permit the type of information or additional
reports that are to be kept in the records.           .

The following discussions provide recommendations on the type of documentation that could be required
to demonstrate compliance with the management practices. Some information can be used for several
management practices so they have been grouped together.,,

Endangered Species
                      •   '         -                 -      . •'        '                  , '     j
The following documentation may be necessary to demonstrate that the site was evaluated for potential
effects on threatened or endangered species of plant, fish, or wildlife or their habitat and that necessary
protective measures were identified and implemented:

     •  The general proximity of the nearest  critical habitat, including migration routes for threatened
        or endangered species to the surface disposal site

     •  A description of how the nearby threatened or endangered species of plant, fish, or  wildlife and
      1, their critical habitat were protected when sewage sludge was placed on an active sewage sludge
        unit                                    -

     •  A list of endangered or threatened species in the area or documentation that none exist
                                             5-71

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
     • If there are endangered or threatened species, a determination from the FWS or appropriate State
       or local agency that the placement  of sewage sludge on an active sewage sludge unit will not
       likely adversely affect the survival of the species or its critical habitat

     • If the above determinatipn indicates that adverse impacts can be avoided if specific measures are
       taken, records containing documentation of the measures and how they have been implemented.

Flood Flow Restrictions                                                  .

The types of information required to demonstrate compliance with flood flow restrictions may include
the following:

     • A flood plain insurance rate map (available from the U.S. Federal Emergency Management
       Agency) with the surface disposal site location marked. Other sources of this information include
       the U.S. Army Corps of Engineers, the USGS, Bureau of Land Management, Tennessee Valley
       Authority, and local and State agencies.

     • If an active sewage sludge unit is in the 100-year flood plain, a description of the design details
       and management practices that will prevent  restricted flow of the base flood, including a plan
       view, a cross section of the unit, and calculations used to determine that the site will not restrict
       the base flood flow.

Seismic Zone

The following types of information may be  required  to demonstrate compliance with the seismic impact
zone management standards:                                                                    <

     • A seismic map available from State or local agencies with the site location marked on the map

     • Reports from State or local  agencies on earthquake activity

     • The maximum recorded horizontal ground level acceleration (as a percentage of the acceleration
       due to gravity (g), g=9.8 m/s2) (this information is probably contained in reports on earthquake
       activity obtained from State or local agencies)

     • A reconnaissance of the site that focuses on slopes that may  have had the toe removed, water
       seeps from the base of a slope, less resistant strata at the base of a slope, posts and fences that
       are not aligned, utility poles with sagging or  too tight wires, leaning trees, or cracks in walls and
       streets

     • If the  surface disposal  site is  located in a seismic impact zone, documentation  on design
       modifications to accommodate the ground motion from earthquakes,  such as shallower unit side
       slopes, more conservative design of dikes and runoff controls, and contingency plans for leachate
       collection systems

     • Design plans for the active sewage  sludge unit indicating the maximum ground motion that unit
        components  are designed to withstand, including foundations, embankments, leachate collection
                                              5-72

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                            5. SURFACE DISPOSAL - PART 503 SUBPART C
        systems, liners (if installed), and any ancillary equipment that could be damaged from the seismic
        shocks                           '

      • Copy of local building codes applicable to the active sewage sludge unit and building permits

      • Certification by an engineer with seismic design and geotechnical experience that the  unit is
        designed to withstand the maximum recorded horizontal ground level acceleration.          '•

 Fault Zones

 Documentation to support this management practice may include the following:

      • A Holocene fault map [available from local, State agencies, or the U.S. Geological Survey
        (USGS)] with the site location marked on the map. In 1978, the USGS published a map series
        identifying the location of Holocene faults in the United States (Preliminary Young Fault Maps
        MF916).      -    .

  .    • A report on the area reconnaissance findings of the site,  emphasizing the location of  faults,
        lineaments,  or other features associated with fault movement, such as offset streams, cracked
        culverts and foundations, shifted curbs, scarps, or other linear features.

      • A geotechnical report on the site indicating the presence or absence of any faults or lineations.

Unstable Areas

The following information may be required to demonstrate that the surface disposal site and individual
sewage sludge units are located in stable areas:

     •  A detailed geotechnical and geological evaluation of the stability of the foundation soils, adjacent
        manmade and natural embankments and slopes

     •  An evaluation of the ability of the subsurface to support the active sewage sludge unit adequately,
        without damage to the structural components.

Wetlands

The types of information necessary to demonstrate compliance with wetlands restrictions may include the
following:                                                                    ...

     •  The location of the surface disposal site on a wetlands delineation  map, such as a National
        Wetlands Inventory map, Soil Conservation Service (SCS) soil map, or a local wetlands inventory
       .map •• '.   ,                                               •

     •  A permit or permit application for a Section 402 or Section 404 permit

     •  Description of wetlands assessment conducted by a qualified and experienced multidisciplinary
        team, including a  soil scientist and a botanist or biologist.                                •
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                          5. SURFACE DISPOSAL - PART 503 SUBPART C
Storm Water Run-off Controls

The types of information required to support this management practice may include the following:  ,

     •  Copies of the NPDES permit and any other permits

     •  Description of the design of the system used to collect and control run-off, including plan view,
        drawing details, cross sections, and calculations showing  that the system has the capacity to
        collect total run-off volume

     •  Calculation of peak run-off flow, including data sources and methods used to calculate the peak
        run-off flow      •

     •  Description of inspection and maintenance required for the system

     •  Description of the procedures for managing liquid  discharges and complying with NPDES and
        other requirements.

Leachate Collection and Control

If the active sewage sludge unit has a liner and leachate collection and removal system (LCRS), the
owner/operator must present evidence that the LCRS  is properly operated and maintained.  In addition,
documentation must indicate that the leachate is properly disposed.  The types of. information required
to demonstrate compliance with the management practice for leachate collection and removal systems may
include the following:         ,

      •  Detailed material specifications for the liner, including drainage layer, filter layer, piping, and
        sumps

      •  Description of the LCRS design, leak  detection, and removal' of leachate and liquid from the
        system

      •  Design details, including layout of system and components shown in plan view and cross section,
        spacing and configuration of pipes, sumps, pumps, drainage plans

      •  Test results demonstrating the system's compatibility with sewage sludge and leachates for all
        system components and materials
      • Description of inspection and maintenance of systems and schedules

      • Operational plan describing method of treatment and/or disposal  of leachate and disposal
        schedules.

 Methane Monitoring and Control

 Methane monitoring is required at covered sewage sludge units while they are active and for 3 years after
 closure.  The system should be designed by an engineer with experience in methane monitoring at
 landfills, surface impoundments, or sewage sludge units.  The methane monitoring system is required to
                                              5-74

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                            5.  SURFACE DISPOSAL - PART 503 SUBPART C
 detect the presence of methane in air in site structures and in air at the property line.  Alarms, lights, or
 other warning devices should be deployed tov notify site personnel of any methane levels exceeding 25
 percent of the lower explosive limit (LEL) for methane in  air in structures and levels exceeding  100
 percent of the LEL for methane in air at the property line.  Contingency plans should be developed as
 part of the methane monitoring plan.  These plans may  include a control  system. •  The  types of
 information required to demonstrate  compliance with the management  standards  may  include  the
 following:                           s,

     •  Description of the system design

     •  Design details of the site, including monitoring locations

     •  Descriptions  of methane  monitoring schedules,  alarm systems,  emergency  procedures,
        contingency plans, system maintenance schedules,  and methane mitigation

  • >  •  Cover design details, including plan view of the unit, details  of penetrations for gas vents, and
        cross  sections at several points

     •  Results of methane monitoring, including the maximum and average levels recorded.

 Aquifer Contamination

 The placement of sewage sludge on a sewage sludge unit  shall not contaminate an aquifer.  Part 503
 allows two options for demonstrating compliance with this  management practice; either a ground-water
 monitoring program  or a certification by a qualified ground-water scientist  that the aquifer  is not
 contaminated.                                             ,     ,

 If the first option is used, the permit writer should require that the ground-water monitoring records ,be
 retained.                                                                            ,

 The certification, which is supplied by  a  qualified ground-water  scientist,  must  be supported  by
 documentation that demonstrates a hydrogeologic assessment has been made that indicates that the aquifer
 is not contaminated.  This documentation may include:

     • Description of the methods used to reduce the possibility of contaminating ground water, such
       as liners and leachate collection systems

     • Demonstration that the liner construction and/or geology of the site are sufficient to retard liquid
       flow during the active life and post closure period

     • Data indicating that ground water is at a great depth,  or hydrologic data demonstrating low
       rainfall at the active sewage sludge unit such that there is a low  probability that contaminants will
       leach to ground water.

Food, Feed or Fiber Crops

Growing food, feed or fiber crops on any active sewage  sludge  unit is prohibited,  unless explicitly
authorized by the permitting authority.  If crops are grown,  the permit writer should specify the records
                                             5-75

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
and documentation that must be maintained to demonstrate compliance with the site-specific management
practices established to protect the public health and environment. For example, the permit writer might
require crop tissue sampling and analysis of pollutants.

Grazing                                                            _     .

Animal grazing on active sewage sludge units is prohibited, unless specifically authorized by the
permitting  authority.  The type of information necessary to demonstrate compliance with the grazing
restriction on active sewage sludge units may include a description (and map showing the placement) of
animal restriction devices, such as grates at gate entrances or electrified fencing.

If animal grazing is allowed,  the permit writer will need to specify the records and documentation that
must be  maintained to demonstrate that the site-specific management practices are being implemented.
For example, the permit writer may want to require periodic analysis of animal tissue.
Public Access

The following types of information may be required to demonstrate compliance With the public access
restriction standards:

     •  Site map, showing the access control locations

     •  Description of access restriction measures, such as placement of vehicle barriers, signs, and
        construction plans with the placement and configuration of fences and gates

     •  Language on warning signs

     •  Inspection schedule for the access controls arid repair procedures .        .

     •  Schedules for security guard postings or security inspections.

 Storage of Sewage Sludge

 As discussed at the beginning of this chapter, sewage sludge that is placed on the land for less than 2
 years is not covered by Part 503.  If sewage sludge remains on the land for longer than 2 years the site
 is considered an active sewage sludge unit unless there is a demonstration otherwise. At a minimum, this
 demonstration must include the following:

      • The name and address of the person who prepares the sewage sludge

      • The name and address of the person who either owns the land or leases the land

      • The location, by either street address or latitude and longitude, of  the land

      • An explanation of why sewage sludge needs to remain on the land  for longer than 2 years prior
        to final use or disposal

      • The approximate time period when the sewage sludge will be used or disposed.
                                               5-76

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                           5.  SURFACE DISPOSAL - PART 503 SUBPART C
 The permit writer must determine if there are mitigating, factors at the site justifying this longer period
 for sewage sludge to remain on the land before final use or disposal.  The permit writer may want to
 develop specific conditions pertaining to sewage sludge storage.  If necessary, the permit writer may want
 to stipulate that the treatment works develop plans to eliminate or reduce storage of sewage sludge.

 5.9    REPORTING REQUIREMENTS
  Statement of Regulation,              "       ,      „

    §5<»<28(a)    Class I sMdge management facilities, Poiws (as defined a 4fr CFR £01.2) with a design flow
                rateteiiju3l to or greater than QneimUlion gallons per day, and POTWs that sem 10,00$ people
                or more shall submit tfae information in 503.27(a) to toe permitting authority on February 19 of
              '  each year.
Only a subset of treatment works required to keep
records are required to report under §503.28 of
the regulations.   The reporting requirements in
§503.28 apply to the following facilities:

     •  Class I sludge management facilities

     •  Publicly owned treatment works with a
        flow  rate equal to or greater  than one
        mgd                  ' •       ,
                 (
     *  Publicly owned treatment works serving
        a population of 10,000 or greater.

However, the permitting agency has the authority
and  discretion to  require reports  from  other
facilities not  specified in Part 503.  Under the"
NPDES regulations, the head of  the permitting
agency  may  designate  any  treatment  works
treating Domestic sewage as a Class  I  sludge
management facility because of the potential for
its sewage sludge use or disposal practices to adversely affect public health and the environment.  The
permit writer may want to consider the following conditions to determine the need for a TWTDS to
report:                                                          ,

     •  The amount of sewage sludge being used or disposed

     •  The design of the surface disposal site                                     .

   •  •  The operational and management practices at the site

     •  Other  conditions  that  show the potential for any adverse effect on public health and the
        environment.
A Class I sludge management facility is any
publicly owned treatment works (POTW),  as
defined in §50L2, identified, under 40 CPR
§403\8(a)  as being  required  to  have  an
approved pretreatment program (including such
POTWs located in a State that has  elected  to
assume local program responsibilities pursuant
to  §403.iO(e))  and  any treatment  works
treating  domestic  sewage,  as-  defined   in
§501.2, classified  as   a  Class   I  'sludge
management facility by the EPA Regional
Administrator, or,  in "the  case  of approved
State   programs,  sthe -EPA   Regional
Administrator in  conjunction with  the State
Director*  because of the potential'  for  its
sewage sludge use or disposal  practices  ta
affect  public health- and the  environment
adversely.  §5Q3.7(b).
                                             5-77.

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                           5. SURFACE DISPOSAL - PART 503 SUBPART C
The reporting requirements specify that Class.I sludge management facilities and other POTWs report
annually on the information they are  required to develop and retain under §503.27. The permit writer
should develop permit conditions that specifically identify the information that must be reported, the date
by which the information must be received, and the address to which the report musfbe submitted.

When the permittee is  instructed to  report the  results  of sewage  sludge analyses  for pollutant
concentrations as  §§503.27(a)(l)  and (2) require, she should be required to  include the following
information:                   '

     •  Units for reported concentrations

     •  Dry weight concentrations

     •  Number of samples collected during the.monitoring period

     •  Number of excursions during the monitoring period

     •  Sample collection techniques

     •  Analytical techniques.

The permittee should report separately all data collected during the reporting period.

The permittee should identify the specific elements to be contained in the description of how the pathogen
and vector attraction reduction requirements were met.  Refer to Chapter 8 for a detailed discussion of
appropriate elements for each pathogen reduction and vector attraction reduction alternative.

The permit writer may also require that additional information be reported to determine the  compliance
status of the TWTDS.  In the  case where additional inforrnation is needed, the permit writer must
specifically require that information  in the permit.

The permit writer should consider whether a yearly reporting requirement is sufficient.  He may want
to require some reports to be submitted at a more frequent interval than the yearly reporting requirement.
Situations that may warrant the  inclusion of more frequent reporting include:

      •  Where sewage sludge data show significant variations in quality or sewage sludge data indicate
         a trend toward poorer quality sewage sludge.  In these cases, more frequent reporting may assist
         the permitting authority in addressing problems before violations.

      •  Where conditions at the site warrant more frequent reporting of the certification for management
         practices  to ensure compliance with the practices.

      •  Where a compliance  schedule was specified.

 The permit writer should instruct the permittee to submit reports to the Water Compliance  Chief at the
 appropriate EPA Regional office or to the appropriate State counterpart in an approved State.  The permit
 should  require that the reports be signed by an authorized representative.  If the permit is an NPDES
 permit, the standard conditions  may already contain language defining the authorized representative.  If
                                               5-78

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                                 5.  SURFACE DISPOSAL - PART 503 SUBPART C
 not, then the regulatory language found in § 122.22 may be included to clearly identify the authorized
 representative.
  Signatory Requirement

        (I)  Alt certifications, reports, or information submitted shall be signed as follows:
                For a corporation:  by a responsible^corporate officer, 'For the purpose of this section^ a responsible corporate
                officer  means:  (1), a president,  secretary treasurer,, or vice-president of the corporation in charge of a
                principal business function, or any other person who performs similar policy or decision-making functions for
                the corporation; or {2) fee manager of one, or  more manufacturing, production or operating  facilities
(a)
                accordance with corporate procedures,-

                      f'~                 '    *           ''          ~~   "~
            (c)  For a municipality, State, Federal, or other public agency- by either a principal executive officer or ranking
           -  ,  elected official. For purposes of this part, a principal executive officer of a Federal agency includes (J)'the
                chief executive officer of the agency, or <2) a senior executive officer having  responsibility tor fee overall
                operations of a principal geographic unit of the agency (e.g.; Regional! Administrator! of EPA),

       (2)  Alt reports required by file permit and other information requested by the Director shall be sighed by a person
            described above or by a, duly authorized representative of that person.

            A person Js a duly authorized representative only if:      -                                  -

            
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                         5.  SURFACE DISPOSAL - PART 503 SUBPART C
5.10.1  SCENARIO 1  -  ACTIVE SEWAGE SLUDGE UNIT  WITHOUT A LINER AND
       LEACHATE COLLECTION SYSTEM WITH A UNIT BOUNDARY TO SITE PROPERTY
       LINE DISTANCE OF 150 METERS OR GREATER

The elements of a Part 503 standard for this scenario are presented below.
                 ELEMENTS OF A PART 503 STANDARD - SCENARIO 1

 General requirements:    Requirements in §§503.22(a)-(d)
 Pollutant limits:
Pollutant concentrations in Table 1 of §503.23(a)(l)
 Management practices:    Requirements in §§503.24(a)-(g) and (j)-(n)
 Operational standards
 (pathogens):

 Operational standards
 (vector attraction
 reduction):
One of the Class A or Class B pathogen alternatives in §503.32, unless
the active sewage sludge unit is covered daily

One of the vector attraction reduction options in §§503.33(b)(l) -
(b)(ll) or an option determined by the permitting authority to be
equivalent to one of the options in §§503.33(b)(l) - (b)(8)
 Frequency of monitoring:  Requirements in §§503.26(a) and (c)

 Recordkeeping:           Requirements in §503.27(a)

 Reporting:               Requirements in §503.28	
                                           5-80

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                         5.  SURFACE DISPOSAL - PART 503 SUBPART C
5.10.2  SCENARIO 2  -  ACTIVE  SEWAGE SLUDGE  UNIT WITHOUT  A LINER  AND
       LEACHATE COLLECTION SYSTEM WITH A UNIT BOUNDARY TO SITE PROPERTY
       LINE DISTANCE LESS THAN 150 METERS                         ,

The elements of a Part 503 standard for this scenario are presented below.
                 ELEMENTS OF A PART 503 STANDARD - SCENARIO -2

 General requirements:     Requirements in §§503.22(a)-(d)     .      ,
 Pollutant limits:
Pollutant concentrations in Table 2 of §503.23(a)(2)
 Management practices:    Requirements in §§503.24(a)-(g) and (j)-(n)

 Operational standards;     One of the Class A or Class B pathogen alternatives in § 503.32, unless,
 (pathogens):

 Operational standards
 (vector attraction
 reduction):
the active, sewage sludge unit is covered daily

One of the vector attraction reduction options in §§503.33(b)(l) -
(b)(ll) or an option determined by the permitting authority to be
equivalent to one of the options in §§503:33(b)(l) - (b)(8)
 Frequency of monitoring:  Requirements in §§503.26(a) and (c)

 Recordkeeping:          Requirements in §503.27(a)

 Reporting:               Requirements in §503.28
                                         5-81

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                         5.  SURFACE DISPOSAL - PART 503 SUBPART C
5.10.3  SCENARIO 3  -  ACTIVE SEWAGE  SLUDGE UNIT WITHOUT  A  LINER  AND
       LEACHATE  COLLECTION  SYSTEM FOR WHICH  SITE-SPECIFIC POLLUTANT
       LIMITS ARE DEVELOPED

The elements of a Part 503 standard for this scenario are presented below.
                 ELEMENTS OF A PART 503 STANDARD - SCENARIO 3

 General requirements:     Requirements in §§503.22(a) - (d)
 Pollutant limits:
Site-specific in §503.23(b)
 Management practices:    Requirements in §§503.24(a)-(g) and (j)-(n)
 Operations standards
 (pathogens):

 Operations standards
 (vector attraction
 reduction):
One of the Class A or Class B pathogen alternatives in §503.32, unless
the active sewage sludge unit is covered daily

One of the vector attraction reduction options in §§503.33(b)(l) -
(b)(ll) or an option determined by the permitting authority to be
equivalent to one of the options in §§503.33(b)(l) - (b)(8)
 Frequency of monitoring:  Requirements in §§ 503.26(a) and (c)

 Recordkeeping:           Requirements in §503.27(a)

 Reporting:               Requirements in §503.28
                                           5-82

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                         5~. SURFACE DISPOSAL - PART 503 SUBPART C
5.10.4 SCENARIO 4 - ACTIVE SEWAGE SLUDGE UNIT WITH A LINER AND LEACHATE
       COLLECTION SYSTEM
                           '          '                    **"               ' '    '
The elements of a Part 503 standard for" this scenario are presented below.
                 ELEMENTS OF A PART 503 STANDARD - SCENARIO 4

 General requirements:     Requirements in §§503.22 (a) - (d) •
 Pollutant limits:
None
 Management practices:    Requirements in §§503.24(a)-(n)
 Operational standards
 (pathogens):

 Operational standards
 (vector attraction
 reduction):
One of the Class A or Class B alternatives in §503.32, unless the active
sewage sludge unit is covered daily

One of the vector attraction reduction options in §§503.33(b)(l)-
(b)(ll) or an option determined by the permitting authority to be
equivalent to one of the options in §§503.33(b)(l) - (b)(8)
 Frequency of monitoring:  Requirements in §§503.26(a) and (c)

 Recordkeeping:           Requirements in §503.27(a)'

 Reporting:               Requirements in §503.28
                                          5-83

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                          5. SURFACE DISPOSAL - PART 503 SUBPART C
                                      REFERENCES
Alter, et al.  1985.  DRASTIC: A Standardized System for Evaluating Ground Water Pollution Potential
Using Hydrogeologic Settings. U.S. EPA. Robert S. Kew Environmental Research Laboratory.  Ada,
OK.

Barfield, B.J., R.C. Warner and C.T. Haan.  1981. Applied Hydrology and Sedimentology for Disturbed
Areas. Oklahoma Technical Press.

Dunne, Thomas and Lyna B. Leopold.  1978.  Water in Environmental Planning.  W.H. Freeman and
CO.                                      '  -  ^ , ;   '     ,    . |    .        '  •            ;

Keller, E.A.  1978. Environmental Geology.  Charles E. Merrill Publishing Co., Columbus, Ohio.

Maynard, S.T.  1978.  "Practical Riprap Design." Hydraulics Laboratory Miscellaneous Paper H-78-7.
U.S. Army Engineers Waterways Experiment Station.  Vicksburg, MS.

McCandless, R.M., A. Bodoczi and P.R. Cluxton.  1986.  Geotechnical Analysis for Review Dike
Stability (GARDS). Technical Manual.  Cincinnati, OH:  U.S. Environmental Protection Agency, Office
of Research and Development.

Merritt, Frederick S.  1983.  Standard Handbook for Civil Engineers.  McGraw-Hill Book Co.  Third
Edition.

Public Law 99-399. 1986.  Safe Drinking Water Act (SDWA).

U.S. Army Corps  Of Engineers. 1970. Laboratory Soils  Testing.  EMI 110-2-1906.

U.S. Army Corp of Engineers.  1989. Federal Manual for Identifying and Delineating Jurisdictional
Wetlands.  Washington, DC:  U.S. Army Corps of Engineers, U.S. EPA, U.S. Fish and Wildlife
Service, and USDA Soil Conservation Service; Cooperative Technical Publication.

U.S. Department of Agriculture,  1983.  Maryland Standards and Specifications for Soil Erosion and
Sediment Control.  College Park, MD: Soil Conservation Service.                     ,

U.S. Department of Agriculture.  1986.  Urban Hydrology for Small Watersheds. Soil Conservation
Service. PB87-10.1580.

U.S. Department of Commerce. Technical Paper 40. Rainfall Frequency Atlas of the United States for
Durations from 30 Minutes to 24 Hours  and Return Periods from  1 to 100 Years.  National Weather
Service.                                                                 ..    "  .

U.S.  Department  of Navy.   1983.   Soil Dynamics,  Deep Stabilization, and Special Geotechnical
 Construction. Design Manual.  NAVFAC DM-7.3.  Washington, DC.

 U.S.  Environmental Protection Agency  (EPA).  1978.  Process Design Manual-Munitipal  Sludge
Landfills. Washington, DC:  Office of Solid Waste. EPA/625/1-78-010.
                                             5-84

-------
                          5. SURFACE DISPOSAL - PART 503 SUBPART C
 U.S. EPA. 1980. Procedures Manual for Ground Water Monitoring at Solid Waste Disposal Facilities.
 Office of Water and Waste Management.  SW-611.

 U.S. EPA.  1983a.  Draft Permit Writers' Guidance Manual for Hazardous Waste Land Treatment,
 Storage, and Disposal Facilities.  Volumes 1 and 2.  Washington, DC;  Office of Solid Waste and
 Emergency Response.                                       .
                                             •  - .          .             . N   ,. -  •  .
 U.S. EPA.   1983b.  Methods for the Chemical Analysis of Waters and  Wastes.  Environmental
 Monitoring and Support Laboratory.

 U.S. EPA. 1985. Remedial Action at Waste Disposal Sites. Handbook. Washington, DC: Office of
 Emergency and Remedial Response. EPA/625/6-85/006 (9380.0-04).

 U.S. EPA. 1987. Test Methods for Evaluating Solid Waste-Physical/Chemical Methods.  Washington,
 DC: Office of Solid Waste and Emergency Response.  EPA SW-846. Third, edition and Update to the
 Third Edition.                                            .

 U.S. EPA. 1988a. Geotechnical Analysis for Review of Dike Stability (GARDS). Cincinnati, OH: Office
 of Research & Development.

 U.S. EPA. 1988b. Guide to Technical Resources for the Design of Land Disposal Facilities. (Location):
 Risk Reduction Engineering Laboratory. EPA/625/6-88/018.

 U.S. EPA. 1988c.  Guidelines for Ground Water Classification Under the Ground Water Protection
 Strategy.  Washington, DC: Office of Ground-Water Protection.                  '

 U.S. EPA. 1988d.  "Solid Waste Disposal Facility Criteria."  Proposed Rule. 40 CFR Parts 257 and
 258. Federal Register.  53 FR 33314, August 30, 19158.

 U.S. EPA.  1988e.  Design, Construction, and Evaluation of Clay Liners for  Waste Management
Facilities.  Washington, DC:  Office of  Solid Waste and Emergency Response. NTIS PB 86-134496.

U.S. EPA. 1989a. Final Covers on Hazardous Waste Landfills and Surface Impoundments.  Technical
Guidance Document. Washington, DC:  Office of Solid Waste and Emergency Response. EPA/530-SW-
 89-047.                  "'•'                        ^

U.S. EPA. 1989b.  POTW Sludge Sampling and Analysis Document. Permits Division.

U.S. EPA.  1989c.  Requirements for Hazardous Waste Landfill Design, Construction, and Closure.
Seminar Publication.  Washington, DC:  Office of Research and Development. EPA/625/4-89-022.

U.S. EPA.  1989d.  Sampling Procedures and Protocols for the National Sewage Sludge Survey.
Washington, DC.

U.S. EPA. 1989e. "Standards for the Disposal of Sewage Sludge." 'Proposed Rule. 40 CFR Parts 257
and 503.  Federal Register. 54 FR 5746, February 6, 1989.
                                           5-85

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                         5. SURFACE DISPOSAL - PART 503 SUBPART C
U.S. EPA.  1990.   Guidance for Writing Case-by-Case Permit Requirements for Municipal Sewage
Sludge.  Washington, DC:  Office of Water.  EPA/505/jg90-001.

U.S. EPA. 1991a.  Design and Construction of RCRA/CERCLA Final Covers.  Seminar Publication.
Washington, DC:  Office of Research and Development.  EPA/625/4-91/025.

U.S. EPA. 1991b.  "Solid Waste Disposal Facility Criteria."  Final Rule. 40 CFR Parts 257 and 258.
Federal Register. 56 PR 50978, October 9, 1991.

U.S. EPA. 1991c.  "Protecting the Nations Ground-Water: EPA Strategy for the 1990s."  Final Report.
Office of the Administrator, 21Z-1020.                                     ,              ,    ,

U.S. EPA. 1992a.  Draft Technical Manual for Solid Waste Disposal Facility Criteria.  40 CFR Part
258. Washington, DC:  Office of Solid Waste.

U.S. EPA. 1992b.  Draft Storm Water Pollution Prevention for Industrial Activates.  Washington, DC:
Office of Water.

U.S. EPA.  1992c.  Control of Pathogens and Vector Attraction in Sewage Sludge.  December  1992.
EPA/625/R-92/013.

U.S. EPA. 1992d.  Sludge Sampling Video. Office of Wastewater Enforcement and Compliance.

U.S. Federal Emergency Management Agency (FEMA).  1980. How to Read a Flood Insurance Rate
Map. Washington, DC.  Available from FEMA Regional Office.

U.S. FEMA.   1992.   The  National Flood Insurance Program Community  Status Book.   GPO.
Washington, DC.  (Each publication is for one State and is updated annually).

U.S. FEMA. 1991. NEHRP Recommended, Provisions for the Development of Seismic Regulations for
New Buildings.  Washington,  DC: Building Seismic Safety Council.

U.S. Geological Survey.  1978. Preliminary Young Fault Maps. (MF916).

Washington State Department of Ecology.  1992.  Draft Stormwater Management Manual for the Puget
Sound Basin.                           .

Winterkorn, H.F. and H.Y.  Fang.  1975.  Foundation and Engineering Handbook.  Van Nostrand
Reinhold.  New York.
                                            5-86

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      6.  PLACEMENT OF SEWAGE SLUDGE IN A MUNICIPAL
                        SOLID WASTE LANDFILL UNIT
                                 QUICK REFERENCE INDEX
INTRODUCTION

PART 503 REQUIREMENTS

     REQUIREMENTS FOR QUALITY OF MATERIALS PLACED
     IN A MUNICIPAL SOLID WASTE LANDFILL UNIT
     PART 258 CRITERIA FOR LANDFILL UNIT

FREQUENCY OF MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS
6.3
                  Page

                   6-1

                   6-1
6-2
6-4

6-4
6.1    INTRODUCTION

This chapter provides guidance to the permit writer on implementation of the Part 503 requirements for
sewage sludge disposal in a municipal solid waste landfill (MSWLF). The permit writer will not find
the specific requirements for disposal of sewage sludge in a MSWLF in Part 503.  Instead Part 503
requires compliance with Part 258.  The Part 258 Criteria for MSWLFs are jointly promulgated under
CWA and RCRA authorities. The following are the Part 258 definitions of a municipal solid waste
landfill unit and household waste.                :
  Statement of Regulation

    §258.2       Municipal solid 'waste landfill unit means a discrete area of land or an excavation that  ••
                receives household waste, and that Js not a land application unit, surface impoundment,
                injection well, or waste pile, as those terms are defined under 257.2.  A MSWLF unit also
              ••  may receive other types? of RCRA subtitle D wastes, such as commercial solid waste,
                nonhazatdoiis sludge, small quantity generator waste and industrial solid waste.  Such a
                landfill may be publicly or privately owned. A MSWLF unit may be a new MSWLF unit, an
                •existing MSWLF unit or a lateral expansion.

                Household waste means any solid waste (including garbage, trash, and sanitary waste in septic
             :   tanks) derived from households (including single and multiple residences, hotels and motels,
                bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds, and day-use
                recreation areas).   '                                   /"
6.2    PART 503 REQUIREMENTS

Part 503  indicates that disposal of sewage sludge in a MSWLF and that meets the criteria in Part 258
constitutes compliance with section 405(d) of the CWA.  Thus, Part 503 relies on the Part 258 criteria
to protect public health and the environment in this case.  The person who prepares sewage sludge for
disposal in a MSWLF must- ensure that the sewage sludge meets the Part 258 requirements for quality
of materials disposed in a MSWLF unit.
                                             6-1

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          6. PLACEMENT OF SEWAGE SLUDGE IN A MUNICIPAL SOLID WASTE LANDFILL UNIT
  Statement of Regulation
    §503.4       Disposal of sewage sludge in a municipal solid waste landfill unit, as defined in 40 CFR
                258,2, that complies with the requirements inf40 CFR Part "258 constitutes compliance with
                section 40S(d) of the CWA» Any person, who prepares sewage sludgfe that Ss disposed in a
                municipal solid waste landfill unit shall ensure that the sewage sludge meete the requirements
                in 40 CFR Part 258 concerning the quality'61 materials disposed! in a  municipal solid waste
                landfill unit,                               ^, .,.,•>.,„     «               ,
6.2.1  REQUIREMENTS FOR QUALITY OF MATERIALS PLACED IN A MUNICIPAL SOLID
       WASTE LANDFILL UNIT

The Part 258 Criteria for MSWLFs do not establish pollutant specific numerical criteria for each toxic
pollutant of concern hi the sewage sludge that is co-disposed with household waste in the MSWLF. For
a number of reasons1, EPA concluded that it was not technically feasible to develop specific pollutant
numeric  limits for this  sewage sludge disposal practice.  Instead the design standards and operating
standards for MSWLFs established hi Part 258 serve as alternative standards for protection  of public
health and the environment.

The Part 258 criteria for quality of materials placed in a MSWLF unit that pertains to sewage sludge are
in the following three sections:

     *   §258.20 - Procedures for Excluding the Receipt of Hazardous Waste
     •   §258.28-Liquids Restrictions
     •   §258.21 - Cover Material Requirements

Because  §503.4 requires the preparer of the sewage sludge to ensure that the sewage sludge meets the
requirements in Part 258 concerning the quality of materials disposed, the preparer must ensure that:

     • The sewage sludge is nonhazardous

     • The sewage sludge does not contain "free liquids" as defined by Method 9095  (Paint Filter
       Liquids Test) in "Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods" (EPA
       Pub. No. SW-846).

The owner or operator of a MSWLF unit must ensure that a material, including sewage sludge, used to
cover the unit is suitable for that purpose  (capable of controlling disease vectors, fires, odors, blowing
litter, and scavenging without presenting a threat to human health and the environment).  In some cases,
the sewage sludge may have to be treated for vector attraction reduction prior to its use as cover material.
Use of sewage sludge as an alternative cover material must be approved by the State agency regulating
MSWLFs.
    'A discussion of EPA's reasons for concluding that numerical limitations for co-disposed sewage sludge were
 not feasible can l?e found in the preamble to the final rule for Parts 257 and 258, Solid Waste Disposal Facility
 Criteria, FR 50997, Vol 56, No. 196, October 9, 1991.
                                               6-2

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          6-  PLACEMENT OF SEWAGE SLUDGE IN A MUNICIPAL SOLID WASTE LANDFILL UNIT
Statement of Regulation

  §2S8.2fl(a)     Owners nr operators of all M$S¥LF units must implement a program at the facility for
                detecting and preventing the disposal of regulated hazardous wastes as defined In part 261 of
                this diapleFaffd ptily<^ormaTiednb"ipieijyls (PCBJ^waste^^as^defihed-in part 761 ofthis --- — -
                chapter,  This program mast include, at a minimum:

  §258.20(a)(l)  Random inspections of incoming loads unless the owner or, operator takes other steps to
                ensure that incoming loads do not contain, regulated hazardous wastes or PCB wastes,;

  §2SS.20Ca)(2)  Records of any inspections?

  §258.2Q(a)(3J  Training of facility personnel to recognize regulated hazardous waste and PCB wastes?  and
                                           ' f     ~ f        \                          f
  §258,20)     For purposes of this section, regulated hazardous waste means a solid waste that is a
                hazardous waste, as defined in 40 CFR 261.3, that is not excluded from regulation as a
                hazardous waste under 40 CFR 261.4(b) or was  not generated by a conditionally exempt
                small quantity generator as defined in §261,5 of this chapter,

  §258,28(a)     Bulk or noncontainerized liquid waste may not he placed  to MSWLF units unless;

  §258J828
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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
                                               6-4

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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.
                                             6-5

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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
7.5
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
                                            7-1

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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
                                               7-2

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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.                                   ,
                                               7-3

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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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                              7. INCINERATION - PART 503 SUBPART E
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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                              7. INCINERATION - PART 503 SUBPART E
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.  INCINERATION - PART 503 SUBPART E
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
                                             7-11

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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
                                               7-12

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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.
                                               7-13

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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.
                                              7-14

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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:
                                              7-15

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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:
                                      7-16

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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.
                                             7-17

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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.
                                               7-19

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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
                                                  7-20

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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
                                              7-21

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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.
                                             7-22

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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
                                                7-23

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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.
                                              7-24

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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
                                              7-26

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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
                                               7-27

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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
                                                 7-31

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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
                                             7-32

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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).
                                             7-34

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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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                             7. INCINERATION - PART 503 SUBPART E
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
                                             7-38

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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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                             7. INCINERATION - PART 503 SUBPART E
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.
                                              7-47

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                            7. INCINERATION - PART 503 SUBPART E
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.
                                            7-48

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                          7. INCINERATION - PART 503 SUBPART E
                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
                                         7-49

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                           7. INCINERATION - PART 503 SUBPART E
                                     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).  .
                                        8-1

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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.
                                              8-2

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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.
                                               8-3

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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.
                                            8-4

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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
                                              8-6

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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:                                                               .   •     -
                                            8-7

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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.
                                              8-8

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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
                                               8-9

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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)
                                               8-14

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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.
                                              8-18

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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.
                                                 8-21

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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.              •               ;

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              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

-------
              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

-------
             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

-------
             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

-------
              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

-------
              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

-------
              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

-------
             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

-------
                '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

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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

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        APPENDIX B




SURFACE DISPOSAL SITE LINERS

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                             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

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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

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                       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

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                       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

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     APPENDIX C




INFORMATION SOURCES

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                                 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.
                                             C-2

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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
                                             C-3

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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.  ,
                                             C-5

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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
                                             D-2

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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

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                      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

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                       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 
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                      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

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                      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

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                     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

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               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
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                 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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