vvEPA
             United States
             Environmental Protection
             Agency
                 Office Of Water
                 (EN-338)
EPA831B-93-002a
August 1993
                                                 e,
   Preparing Sewage Sludge
   For Land Application Or
   Surface Disposal

   A Guide for Preparers of Sewage Sludge
   on the Monitoring, Record Keeping, and
   Reporting Requirements of the Federal
   Standards for the Use or Disposal of
   Sewage Sludge, 40 CFR Part 503
                  »a\ Protection
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           Chicago.

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General questions concerning the
Standards for the Use and Disposal of
Sewage Sludge should be directed to the
EPA Regional Sludge Coordinator.  The
Sludge Coordinators can be reached by
calling the following numbers:
• Region 1
• Region!
• Region 3
• Region 4
• Region 5
• Region 6
• Region?
• Regions
• Region 9
• Region 10
Boston, MA
New York, NY
Philadelphia, PA
Atlanta, GA
Chicago, IL
Dallas, TX
Kansas City, KS
Denver, CO
San Francisco, CA
Seattle, WA
(617) 565-3560
(212)264-5677
(215) 597-9078
(404) 347-2391
(312) 353-2106
(214) 655-7520
(913)551-7443
(303) 293-1627
(415) 744-1910
(206) 553-1728
                                                                               REGION 1
                                                                     648-07
 Mail compliance reports required under the Standards for the Use and Disposal of Sewage Sludge to
 the Water Compliance Branch Chief in your EPA Region at the address listed on the back cover.
                                                                                   6461-7 shell

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                              TABLE OF CONTENTS
                                                                            Page
1. INTRODUCTION  	    1
    1.1 Definition of Person Who Prepares Sewage Sludge	    3
    1.2 Responsibilities of Preparers of Sewage Sludge	    3

2. MONITORING	    7
    2.1 Regulated Parameters (or what to monitor)	    7
    2.2 Monitoring Frequency (or when to monitor)	   11
    2.3 Procedures for Sampling and Analysis (or how to monitor)	   13

3. RECORDKEEPING	   17
    3.1 Records of Pollutant Concentrations	   17
    3.2 Records of Pathogen Reduction	   18
    3.3 Records of Vector Attraction Reduction	   27

4. NOTIFICATION AND REPORTING	   33
    4.1 Notice and Necessary Information	   33
    4.2 Notice of Interstate Transport	   35
    4.3 Annual Reports	   35

REFERENCES  	   38
                                  APPENDICES

APPENDIX A - WORKSHEET FOR CALCULATING THE ANNUAL WHOLE SLUDGE
             APPLICATION RATE TO MEET THE ANNUAL POLLUTANT LOADING
             RATE

APPENDIX B - SAMPLE FORMAT PROVIDING NOTICE AND NECESSARY INFORMATION

APPENDIX C - EQUATIONS FOR CONVERTING SLUDGE VOLUME TO METRIC TONS

APPENDIX D - CERTIFICATION STATEMENT


                               LIST OF FIGURES

Figure 1   Sludge Quality Requirements for Use or Disposal Practices  	   4

Figure 2   Expressing Pollutant Concentrations on a Dry Weight Basis	   9

Figure 3   Pathogen Reduction Alternative A3—Analysis and Operation  	  24

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                                     LIST OF TABLES

Table 1     Compliance Deadlines for 40 CFR Part 503	    2

Table 2     Pollutants Monitored for Land Application and Surface Disposal  	    8

Table 3     Indicator Organisms and Pathogens Monitored Under 40 CFR Part 503	   10

Table 4     Monitoring Frequency  	   11

Table 5     Methods for the Analysis of Metals in Sewage Sludge	   15

Table 6     Recordkeeping Requirements for Class A Pathogen Reduction Alternatives	   19

Table 7     Recordkeeping Requirements for Class B Pathogen Reduction Alternatives	   20

Table 8     Recordkeeping Requirements for Vector Attraction Reduction Sludge
           Processing Options  	   28
                                             11

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 Section One	Introduction
                                    1.  INTRODUCTION

 Under the authority  of Section 405(d) of the Clean Water Act as amended,  the U.S. Environmental
 Protection Agency (EPA) has promulgated, at 40 Code of Federal Regulations (CFR) Part 503, Phase
 I of the risk-based regulations that govern the final use or disposal of sewage sludge.  The intent of this
 Federal program is to ensure that the use or disposal of sewage sludge occurs in a way that protects both
 human health and the environment. The Part 503 regulation establishes general requirements, pollutant
 limits, operational standards, and management practices, as well as monitoring,  recordkeeping, and
 reporting requirements.  These requirements apply to sewage sludge that is land applied, placed on a
 surface disposal site, or incinerated in a sewage sludge only incinerator. The following types of sludge
 are not subject to Part 503 but are regulated under other Federal rules:

      •   Sludge generated from the treatment of industrial process waste at an industrial facility (40
          CFR Part 257 if non-hazardous)
      •   Hazardous sewage  sludge (40 CFR Parts 264, 265, 267 and 268)
      •   Sewage sludge with a polychlorinated biphenyls (PCB) concentration of 50 ppm or greater (40
          CFR Part 761)
      •   Drinking water treatment sludge (40 CFR Part 257).

 Part 503 imposes requirements on four groups:

      •   Persons who prepare sewage sludge or material derived from sewage sludge
      •   Land appliers of sewage sludge
      •   Owners/operators of sewage sludge surface disposal sites
      •   Owners/operators of sewage sludge incinerators.

The regulation is largely self-implementing.  This means that anyone engaged in activities covered by this
regulation must comply with  the appropriate requirements on or before the compliance deadlines (see
Table 1).  A person who violates Part 503 is  subject to administrative, civil, and/or criminal enforcement
actions.
EPA recognizes that implementation of Part 503 requirements may be a source of confusion for those
who already have a State or local permit with sewage sludge requirements because these people now have

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Introduction                                                                           Section One
                                              Table 1
                            Compliance Deadlines for 40 CFR Part 503
Requirement
Monitoring, recordkeeping, and reporting requirements
All other requirements (i.e., general requirements,
pollutant limits, pathogen reduction, vector attraction
reduction, and management practices)
Compliance Deadline
July 20, 1993
February 19, 1994*
   *If compliance requires construction of new pollution control facilities, the compliance deadline is extended to February 19,
   1995. A new pollution control facility is any building, structure, facility, or installation from which there is or may be a
   discharge of pollutants, the construction of which began after the promulgation of Part 503, and includes any building,
   structure, facility, or installation that replaces or substantially upgrades the process or production equipment necessary to
   meet a standard under this Part. The definition of new pollution control facility does not include:  (1) replacement of any
   building, structure,  facility, or installation due to normal operational wear and tear; and (2)  installation of monitoring
   equipment or devices, including the purchase of computer hardware or software for monitoring purposes.
to comply with two sets of requirements—those in their permit and those in Part 503.  To reduce some
of this confusion, EPA developed a series of guidance documents to explain the requirements of Part 503.
A list of these documents is provided in the references section at the end of this document.

This particular document focuses on the monitoring, recordkeeping, and reporting requirements that apply
to persons who prepare sewage sludge or a material derived from sewage sludge.  The remainder of this
introduction  defines  persons  who  prepare  sewage  sludge and  then   summarizes  their  general
responsibilities. The introduction is followed by three sections that detail the monitoring, recordkeeping,
and notification and reporting requirements, respectively.

Separate documents explaining the monitoring, record keeping,  and reporting responsibilities of land
appliers and owners/operators of surface disposal sites are also  available.  The following documents may
be obtained through the EPA regional offices listed on the back cover of this document:
      •   Land Application of Sewage Sludge — A Guide for Land Appliers on the Recordkeeping and
          Reporting Requirements of the Federal Standards for the Use and Disposal of Sewage Sludge
          Management in 40 CFR Part 503 (EPA, 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 and Disposal of Sewage Sludge in 40 CFR Part 503 (EPA, 1993).

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 Section One	Introduction
 1.1  Definition of Person Who Prepares Sewage Sludge
 The regulation defines the person who prepares sewage sludge as "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." This definition covers two types of operations—those that generate sewage sludge
 and those that take sewage sludge after it has been generated and blend or mix it with another material
 to further process or prepare it before its ultimate use or disposal.  Operations that generate sewage
 sludge include publicly owned treatment works, privately owned treatment works, and federally  owned
 treatment works that  treat, recycle, or reclaim either domestic sewage or a combination of domestic
 sewage and industrial waste.  Operations that derive a material from sewage sludge include composting
 facilities and fertilizer blending facilities that change the initial  quality of the sewage sludge and create
 a product for use as a soil amendment or fertilizer.  Any time the sludge quality (pollutant concentrations,
 pathogen levels, or vector attraction characteristics) is changed,  the person responsible for the change is
 defined as a person who  prepares sewage sludge.  For example, any sludge management facility, such
 as regional composting operation, that mixes or blends sewage sludge received from other facilities is a
 preparer.
   Sewage Sludge—Solid, semi-solid, or liquid residue generated during the treatment of domestic
   sewage in a treatment works. Sewage sludge includes but is not limited to:
        «  Domestic septage (including septage from portable toilets)
        *  Scum  or solids removed in primary,  secondary, or  advanced wastewater treatment
            processes
        *  A material derived from sewage sludge.
   Sewage sludge does not include:
        «  Ash generated in a sewage sludge incinerator
        *  Grit and screenings generated during preliminary treatment of domestic sewage in a
            treatment works.
1.2  Responsibilities of Preparers of Sewage Sludge
The person who prepares the sewage sludge is responsible for documenting sludge quality.  The quality
of the sludge affects the final use or disposal practices available.  As illustrated in Figure 1, the sludge
quality requirements differ within a use or disposal practice.  For example,  under surface disposal, the
sludge quality limits are affected by whether or not the active sewage sludge unit has  a liner and leachate

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Introduction
                                                                    Section One
     Final Use or
      Disposal
      Practice
 Pathogen
 Reduction
Alternatives
 Vector
Attraction
Reduction
                                                                        Pollutant Limits
^H - ^^ Options ^^|
LAND APPLICATION
Bulk sewage
sludge applied
to:
*^

Class A


Any of vector
options 1-8
^^

• Lawn or home garden
Sell or give
away in bag or
other container

Bulk sewage
sludge applied
to:



Class A

Class A or B

^^

Any of vector
options 1-8

Any of vector
options 1-10
^^



Limits — Table 3 of §503.13
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc

Monthly Avg.
(mg/kg)
41
39
1200
1500
300
17
18
420
36
2800


Limits — Table I of §503.13
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc

Maximum
(mg/kg)
75
85
3000
4300
840
57
75
420
100
7500

Ceiling concentration limits and annual pollutant loading
rate OR ceiling concentration limits and pollutant
concentration limits

Ceiling concentration limits and cumulative pollutant
loading rate OR ceiling concentration limits and pollutant
concentration limits
    • Agricultural land, including pasture
    • Forest land
    • Public contact site
• Reclamation site
SURFACE DISPOSAL
Unlined
sewage sludge
unit

Sewage sludge
unit with
liner/leachate
collection



Class A or B or
daily cover

Class A or B or
daily cover
^-




Any of vector
options 1-11


*Site specific limits may be
approved by the permitting
authority, if requested.
Any of vector
options 1-11


Unit Boundary to
Property Line
Distance in Meters
Oto<25
25 to < 50
50 to < 75
75 to < 100
100 to < 125
125 to < 150
150 and greater
Pollutant Concentrations*
Arsenic
mg/kg
30
34
39
46
53
62
73
Chromium
mg/kg
30
34
39
46
53
62
73
Nickel
mg/kg
30
34
39
46
53
62
73
No pollutant limits
     INCINERATION
     CO-DISPOSAL WITH MUNICIPAL SOLID WASTE
Sewage sludge
incinerator
»-

None
^^

None


Site specific pollutant limits 1
Municiapl
solid waste
landfill


None
^-

None


• Demonstrate non- 1
No pollutant limits, but must: hazardous using TCLP 1
• Perform paint filter test 1
                Figure 1: Sludge Quality Requirements for Use or Disposal Practices
                                                                                                646-02


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 Section One	Introduction
 collection system.  The preparer must know what the final use or disposal practice will be and document
 that the sludge quality meets the appropriate requirements.

 EPA anticipates that most preparers generating sewage sludge are able to control the type and amount
 of pollutants that ultimately end up in the sludge through implementation of local mechanisms, such as
 pretreatment programs.   Therefore,  the Part 503  regulation requires the preparer to evaluate sludge
 quality, maintain records, submit compliance reports, and distribute  sludge quality information to
 subsequent users who need the information to comply with the other requirements of the sewage sludge
 regulation. Subsequent users may include:

      •   Sludge  processors, such  as fertilizer blenders,  composting  operations, and pelletization
          facilities, that further prepare the sludge and either land apply it themselves or distribute it for
          land application
      •   Land appliers
      •   Owners or operators of surface disposal facilities
      •   Owners or operators of sewage sludge incinerators.

 These subsequent users will usually  rely on the  preparer  to provide  them  with  the sludge quality
 information necessary to comply with the requirements of the regulation.    However,  there are several
 circumstances where the subsequent users will perform sludge monitoring in addition to or instead of the
 initial preparer.  Sometimes the preparer generating  the sewage sludge transfers it to a processing facility
 where it is prepared for land application.  It is possible that the preparer generating the sludge and the
 preparer processing the sludge may enter into an agreement stipulating that the preparer processing the
 sewage sludge will be responsible for some or all of the monitoring requirements instead of the preparer
 generating the sludge. When sewage sludge is placed on an active surface disposal unit fewer than 150
 meters from the site property line, then the owner/operator of the site is responsible for monitoring sludge
 quality instead of the preparer. Finally, regional incinerator that accepts sludge from numerous preparers
 may choose to monitor the combined sludge fed into the incinerator to verify that the mixture meets the
 sludge quality limits.

If a subsequent user derives a material from the sewage sludge, then that user is a preparer by definition,
as described in the previous section. The subsequent user/preparer who changes the quality of the sludge
is required to  independently  evaluate the final sewage sludge  product and keep records  documenting
sludge quality.  However,  if the original sewage sludge meets the criteria for exceptional quality sewage

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Introduction	Section One

sludge (see box given below), then additional monitoring is not required as long as records document the

receipt of exceptional quality sewage sludge.
   Exceptional Quality Sewage Sludge—Sewage sludge or material derived from sewage sludge is
   classified as exceptional quality if it meets the following criteria;

        •   Requirements concerning pollutant concentrations [40 CFR 503,13(b)(3)]
        •   One of the Class A pathogen reduction alternatives [40 CFR 5Q3.32(a)]
        *   One of the vector attraction reduction options accomplished  during sludge treatment
            (Options 1-8) [40 CFR 503.33(b)( 1X8)1-

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 Section Two	Monitoring
                                    2.  MONITORING

 Monitoring sewage sludge quality is a key step to ensuring compliance with the Part 503 requirements.
 Most preparers must establish a self-monitoring program to document that sludge quality levels are met
 consistently.  The following materials contain detailed guidance on the collection and analysis of sewage
 sludge samples:

      •  POTW Sludge Sampling and Analysis Guidance Document (EPA, 1989 and updates)
      •  Standard Methods for the Examination of Water and Wastewater, 18th edition (APHA, 1992)
      •  Test Methods for Evaluating Solid Waste Physical/Chemical Methods, EPA Publication SW-846
         (EPA, 1986)
      •  Environmental Regulations and Technology:  Control of Pathogens and Vectors in Sewage
         Sludge, EPA/625/R-92/013 (EPA, 1992)
      •  Sewage Sludge Sampling Techniques.  Demonstration Video (EPA,  1993).

 2.1  Regulated Parameters (or what to  monitor)
 Regulated parameters include inorganic pollutants (i.e., metals), pathogenic and non-pathogenic indicator
 organisms, and vector attraction characteristics. The specific parameters to monitor vary depending on
 whether the sludge is land applied, incinerated, or placed on a surface disposal site. The parameters also
vary depending on which pathogen reduction alternative or vector attraction reduction option is used.

 Sludge that is land applied or placed on an unlined surface disposal site must be monitored for inorganic
pollutants.  The sludge must also be monitored for pathogens, indicator organisms, and vector attraction
characteristics when called for by the pathogen reduction alternative or vector attraction reduction option.
Sludge does not have to meet pollutant limits when it is placed on a surface disposal site that is equipped
with a liner and  leachate collection system,  but it must meet pathogen and vector attraction reduction
requirements.  Note that sludge placed on a  surface  disposal site does  not have  to meet pathogen
reduction requirements if it is covered with soil or other suitable material after placement.  Sludge that
is incinerated only has to be analyzed for inorganic pollutants.

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Monitoring
Section Two
   Indicator Organism—An indicator organism (e.g., fecal colifona) is a non-pathogenic organism
   whose presence implies that contamination has occurred.  Indicator organisms are selected to be
   conservative estimates of potential contamination.
   Vector Attraction—Characteristics (e.g., odor) that attract birds,  insects, and other creatures
   capable of transmitting infectious agents.
Pollutants
The presence of inorganic pollutants in sludge is the first component of sludge quality. Table 2 lists the
inorganic pollutants regulated under 40 Code of Federal Regulations (CFR) Part 503 for land application
or surface disposal (unlined units).  At a minimum, sludge must be monitored for these pollutants.  The
preparer may  have to monitor the  sewage sludge for additional pollutants if specified  in a permit or
required by the person(s) responsible for the ultimate use or disposal of the sludge. When bulk sewage
is going to be land applied, nitrogen analysis must also be conducted.
                                            Table 2
                Pollutants Monitored for Land Application and Surface Disposal
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Land Application
/
/
/
/
/
/
/
/
/
/
Surface Disposal
(unlined units)
/

/




/


The pollutant limits are expressed as dry weight concentrations.  Therefore, in addition to the pollutants,
the percent solids content of the sludge must be determined to verify compliance with pollutant limits.

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 Section Two	Monitoring
 The percent solids value is used to convert pollutant concentrations to a dry weight basis, as demonstrated
 in Figure 2.
    If you assume that the specific gravity of the solids is equivalent to the specific gravity of water,
    a simplified equation can be used to express the concentration of a pollutant on a dry weight
    basis:
                                 A ?* + Percent Solids = B^
                                     L                       kg

    where:   A is the concentration of the pollutant in the sewage sludge on a wet basis in mg/L and
              B is the concentration of the pollutant in the sewage sludge on a dry weight basis in
              mg/kg.
    For example, assume that the concentration of zinc in the sewage sludge is reported as 200 mg/L
    and the percent  solids content of the sewage sludge is 24 percent.  The concentration can be
    converted to a dry weight basis using the equation given above:
                                   200 -38 + 0.24 = 8334 ^
                                         L                 kg

             Figure 2:  Expressing Pollutant Concentrations on a Dry Weight Basis
Pathogenic Organisms
The presence of pathogenic organisms, such as bacteria and viruses, is another component of sludge
quality.  When sludge is prepared for land application or surface disposal, it must comply with applicable
pathogen reduction requirements. There are no pathogen reduction requirements for sewage  sludge that
is incinerated.

The Part 503 regulation allows nine pathogen reduction alternatives, which are divided into two distinct
classes:  Class A and Class B. Class A alternatives produce a sludge that is virtually pathogen free (see
Table 3 for allowable levels). Class B alternatives, while not as effective as Class A, significantly reduce
the pathogen level in sludge. Both Class A and B alternatives specify maximum levels of fecal coliform,
Salmonella sp. bacteria, enteric viruses, and/or helminth ova allowed in the sludge.  Most alternatives
also specify operating parameters  that must be consistently achieved during sludge treatment.   The
operating parameters are described in Section 3.2 (Records of Pathogen Reduction) because records must
be kept to demonstrate that the operating parameters were met on a regular basis. The remainder of this

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Monitoring
Section Two
section addresses monitoring for the presence of fecal coliform, Salmonella sp. bacteria, enteric viruses,
and viable helminth ova.
                                            Table 3
                     Indicator Organisms and Pathogens Monitored Under
                                       40 CFR Part 503
Pathogen Reduction
Alternatives
All Class A Alternatives
1,2,3,4,5,6

All Class A Alternatives
1,2, 3,4,5,6

Class A Alternatives
3 and 4 only
Class A Alternatives
3 and 4 only
Class B
Alternative 1
Organism to be
Monitored
Fecal Coliform

Salmonella sp.
bacteria (in lieu of
fecal coliform)
Enteric Viruses
Viable Helminth
Ova
Fecal Colifonn
Allowable Level in Sludge
1,000 Most Probable Number (MPN) per
gram (Class A) of total solids (dry
weight)
3 MPN per 4 grams total solids (dry
weight)

Less than one plaque-forming unit per 4
grams total solids (dry weight)
Less than one viable helminth ovum per 4
grams of total solids (dry weight)
Less than 2 x 106 MPN or less than 2 x
106 colony-forming units per gram of
total solids (dry weight) (expressed as
geometric mean of the results of 7
individual samples)
All  of the Class A and  one of the Class B  pathogen reduction alternatives require monitoring to
demonstrate that the density of pathogens or indicator organisms in the sewage sludge is below specified
values. Depending on which pathogen reduction alternative is used, the preparer may need to monitor
for one or more of the following organisms: fecal coliform, Salmonella sp. bacteria, enteric viruses, and
viable helminth ova. Table 3 describes which organisms must be monitored for each alternative requiring
analysis.  Note that allowable pathogen levels also are expressed as dry weight.

Vector Attraction Characteristics
Vector attraction characteristics are the third basic component of sludge quality. Vectors are animals and
insects (e.g., rodents, flies, birds) that could potentially transmit pathogenic organisms from the sewage
sludge to humans.  Vectors may be  attracted to sludge by its odor and putrescibility. Therefore, these
characteristics must be reduced by using any of the 11 options given hi the regulations.
                                                10

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Section Two                                                                         Monitoring
The types of parameters used to demonstrate vector attraction reduction include volatile solids reduction,
specific oxygen uptake rate, and percent total solids. Most of the vector attraction reduction alternatives
also involve the documentation of operating parameters and evaluation of sludge management activities
to demonstrate compliance.  Facilities are required to maintain records describing the methods used and
certifying that requirements for vector attraction reduction have been met.  Section 3.3 describes the
specific types of records that must be kept to demonstrate compliance.

2.2  Monitoring Frequency (or when to monitor)
The Part 503 regulations establish a monitoring frequency for sewage sludge and materials derived from
sewage sludge.  As shown in Table 4, the monitoring frequency increases as the amount of sludge used
or disposed increases. The monitoring frequency established by the regulation does not restrict preparers
from analyzing sludge  quality more often.   In fact,  more  frequent sampling and analysis may be
advantageous.  The results of each sampling event represent the sludge quality from the date the sample
was taken until the date of the next sample.  If a preparer samples quarterly and the results show that the
sludge quality exceeded a  limit, then all the sludge used or disposed after that sample was collected will
be in violation until another sample is collected and analyzed to show that the sludge is in compliance.
Thus, preparers who collect samples of sludge  more frequently may be able to document that in general
the sludge quality consistently meets applicable requirements and that exceedances, if any, are abnormal
events.
                                            Table 4
                                     Monitoring Frequency
Amount of Sewage Sludge Used or Disposed
(metric tens per 365-day period; dry weight)
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
Monitoring Frequency
Per Year
Once
Quarterly (4 times)
Bimonthly (6 times)
Monthly (12 times)
Technically, sludge does not exceed use or disposal requirements until it is used or disposed. A preparer
can prevent a violation from occurring by waiting for the analytical results before releasing the sludge
for use or disposal.   The concentrations of the regulated parameters (i.e.,  pollutants and pathogens)
                                               11

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Monitoring	Section Two
remain fairly constant once the sludge has been prepared for final use or disposal, with the exception of
fecal coliform and Salmonella sp. bacteria.  Therefore, after a reasonable waiting period (of 3-7 weeks),
the analytical results of the sludge sampled should still reflect the quality of the sludge used or disposed.

Obviously, a preparer's ability to use this strategy will  depend on the availability of space to store the
sewage sludge in a manner that will protect it from contamination.  Where storage is not a feasible
alternative, preparers will have to be more conservative in how they use or dispose of the sludge until
they have generated enough historical monitoring data to demonstrate that the sludge consistently meets
sludge quality requirements.  Until preparers are confident they can consistently achieve Class A, they
may want to manage sludge as if it is Class B.

The Part 503 regulation specifies the number of sampling events that must occur during a year.  The
interval between sampling events is  also defined. For example, the monitoring frequency "once per
quarter (4 times per year)" means a total of four sampling events must occur at  3-month intervals (i.e.,
one sampling event every  3 months).  The four sampling events cannot occur in 4 consecutive days (or
weeks or months) if the preparer is continuously  using or disposing of sludge for 365 days.  There may
be individual situations where the interval stipulated by the regulation (e.g., once every 60 days) can be
modified.

For example, sewage sludge  may be prepared at a faster rate than the preparer  uses or disposes of the
sludge. It is possible for a facility to prepare, over a  12-month period, an amount of sewage sludge that
requires bimonthly sampling and analysis (e.g., 3,000 dry metric tons). The facility may, however, only
land apply the sludge during a 3-month period because of the local growing season. In this situation, the
preparer may sample and analyze the sewage sludge on  a bimonthly (every 2 months) basis for all
applicable parameters that remain fairly constant hi the sludge after it has been processed and prepared
for final use  or disposal (i.e., metals, enteric viruses, viable helminth ova).  However, because fecal
coliform and  Salmonella are prone to regrowth, analysis for these parameters must be performed during
the 3-month period that the sewage sludge is land  applied.  The preparer should perform biweekly (every
2 weeks) monitoring during that period to comply with the monitoring frequency  (six times per year) and
the timing restriction (at the time of use or disposal).

For most treatment works treating domestic sewage,  monitoring events should be performed at regular
intervals throughout  the year as the sludge is being prepared rather than after it has been stockpiled or
otherwise stored.  Regular monitoring gives the preparer timely feedback on changes hi  sludge quality,
                                               12

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Section Two	Monitoring
thereby allowing the preparer to identify and correct problems early.  However, if the sludge quality is
likely to change between the time it is prepared and the time it is used or disposed, then the monitoring
events should be scheduled so that the data are representative of the sludge that is ultimately used or
disposed.  For example, if a sludge with a high liquid content is stored in a tank or lagoon, it is likely
to produce a leachate or supernatant that will be drawn off the sludge solids as they settle.  This could
result in increased concentrations of pollutants in the sludge since the metals bind more readily to the
solids than the liquid fraction of the sludge.   The monitoring events  should be scheduled to collect
representative samples of the sludge used or disposed at a frequency appropriate for the amount of sludge
used or disposed during the calendar year.

Another situation requiring possible modification of the monitoring interval is when the preparer has been
stockpiling sludge for an extended period of time and, now that the regulations are in effect, needs to start
sampling as the sludge is used or disposed. In this case,  the preparer should determine how much sludge
will be used or disposed in a 365-day period and calculate the corresponding monitoring frequency.  The
preparer should schedule sampling events at evenly spaced intervals during the time when sludge is used
or disposed.

2.3 Procedures for Sampling and Analysis (or how to monitor)
This section describes three critical factors in the development and implementation of a self-monitoring
program that will produce precise and reliable analytical results:
      •    Collection of representative samples of the sewage sludge
      •    Use of appropriate analytical techniques
     •    Adherence to quality assurance/quality control (QA/QC) procedures for sampling and analysis.

Representative Samples
To obtain a valid sample of sewage sludge, the sample must be taken from the correct location, represent
the entire amount of sludge,  and be handled properly from the time of collection through analysis.  It is
important that samples be collected from a location that is representative of the final sewage sludge or
sewage sludge product.  Therefore, sludge samples must be collected after the last treatment process
(e.g., digestion, dewatering,  drying, composting). Samples should be taken at the same point and in the
same manner each time monitoring is performed.  This location should be safe and accessible.
                                               13

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Monitoring	Section Two
The technique for sampling the sludge will vary depending on whether the sludge is flowing through
pipes, moving along a conveyor, or contained hi a truck, pile, or bin.  Sludge that is flowing or moving
should be sampled at equal intervals during the amount of time the unit operates in a day.  This technique
is desirable because moving sludge is likely to be better mixed than sludge in a pile or bin.  If sludge
samples must be collected from a pile or bin, the appropriate number of sample aliquots to collect from
various points in the pile should be determined using the statistical procedure described in the POTW
Sludge Sampling and Analysis Guidance Document (EPA,  1989 and updates). At a minimum, full-core
samples should be taken from  at least four points in the pile or bin.  Sludge sampling techniques are
described in the following references, which are available  through the Regional sludge coordinator:

     •   POTW Sludge Sampling and Analysis Guidance Document (EPA, 1989 and updates)
     •   Environmental Regulations and Technology:  Control of Pathogens and Vectors in Sewage
         Sludge, EPA/1625/R-92/013 (EPA, 1992)
     •   Sewage Sludge Sampling Techniques.  Demonstration Video (EPA, 1993).

Appropriate preservation techniques ensure that samples remain representative during the time that are
held prior to analysis.  At a minimum, all sludge samples in the field and in the laboratory should be
preserved  by cooling to 4°C.  In addition to preservation,  the holding time influences the validity of
analytical results. It is important to know and respect sample holding times for each parameter being
analyzed.  With the exception  of mercury,  the metals do not degrade easily and can be held up to 6
months.  Mercury can be held for 13 days hi a plastic  container and 38  days hi a glass  container.
Bacteria have a very short holding time; if the samples cannot be  delivered to the laboratory within 1
hour, they should be chilled promptly (using an ice and water bath) to 4°C and delivered within 24 hours.
Samples for viable helminth ova can be held for up to 1 month if chilled to 4°C.  Viruses can be frozen
for up to 2 weeks.

In addition, appropriate sample containers must be used. For some parameters, such as volatile organics,
glass containers are  essential.  However, either plastic or glass containers can be used to collect samples
for the  analysis of  metals, indicator organisms, and pathogens.  The containers must be  clean and
contaminant free. Sterile containers must be used for indicator organisms and pathogens.

Finally, sufficient sample volumes must be collected to perform  the  analyses.  The sample volumes
needed for each analysis vary depending on the percent total solids of the sewage sludge and the detection
                                               14

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 Section Two	Monitoring

 level of the analytical method used.  Check with your laboratory to make sure you collect more than

 enough sludge for analysis.  A conservative rule of thumb is to collect 500 ml for metals analysis and

 1 L for pathogens and indicator organisms.


 Appropriate Analytical Techniques

 All analyses performed to comply with Part 503 must be conducted using methods specified in Part 503.

 Pollutant analysis for  metals must be performed using the methods provided in  Test  Methods for

 Evaluating Solid Waste (SW-846) (EPA 1986).  Table 5  lists the methods for the analysis of regulated

 pollutants.  Methods for pathogen analysis, specific oxygen uptake rate, and total, fixed, and volatile

 solids can be found in the following references:
         Enteric Viruses:  Standard Practice for Recovery of Viruses From Wastewater Sludge, Section
         11, Water and Environmental Technology (ASTM, 1992).

         Fecal Coliform:  Standard Methods for the Examination of Water and Wastewater, Part 9221
         E or Part 9222 D, 18th edition, (APHA,  1992).

         Helminth Ova:  W.A. Yanko,  Occurrence of Pathogens in Distribution and Marketing
         Municipal Sludges (EPA, 1987).

         Salmonella Sp. Bacteria:  Standard Methods for the Examination of Water and Wastewater,
         Part 9260 D.I., 18th edition, (APHA, 1992); B.A. Kenner and H.A. Clark, Determination and
         Enumeration  of Salmonella  and Pseudomonas  aeruginosa,  J.  Water Pollution  Control
         Federation, 46(9): 2163-2171, 1974.

         Specific  Oxygen Uptake Rate:  Standard Methods for the Examination of Water and
         Wastewater, Part 2710 B, 18th edition, (APHA, 1992).

         Total, Fixed, and Volatile  Solids:   Standard Methods for the Examination of Water and
         Wastewater, Part 2540 G,  18th edition, (APHA,  1992).
Quality Assurance/Quality Control

QA programs are used to achieve a desired quality for activities, such as sample collection, laboratory

analysis, data validation and reporting, documentation, and recordkeeping. QA programs should address

the following major areas:


     •   Proper sample 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
         analyses of samples
                                             15

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Monitoring
Section Two
                                              Table 5
                       Methods for the Analysis of Metals in Sewage Sludge
Pollutants
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Sample Preparation and Analytical
Methodologies
SW-846*
EPA Methods 3050/3051 + 7061
EPA Methods 3050/3051 + 6010/7131/7130
EPA Methods 3050/3051 + 6010/7191/7190
EPA Methods 3050/3051 + 6010/7210
EPA Methods 3050/3051 + 6010/7421/7420
EPA Method 7471/7470
EPA Methods 3050/3051 + 6010/7481/7480
EPA Methods 3050/3051 + 6010/7520
EPA Methods 3050/3051 + 6010/7741/7740
EPA Methods 3050/3051 + 6010/7950
   *Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846, Second Edition (1982)
   with Updates I (April 1984) and II (April 1985) and the Third Edition (November 1986) with Revision I (December 1987)
   and Update I (July 1992).  The Second Edition and Updates I and II (PB-87-120-291) are available from the National
   Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161. The Third Edition and Revision I and Update
   I (Document number 955-001-00000-1) are available from the Superintendent of Documents, Government Printing Office,
   941 North Capitol Street, NE, Washington, DC, 20002.  Future updates will be noticed in the Federal Register.


      •   Proper procedures  and  schedules for the calibration and  maintenance  of equipment  and
          instruments associated with the collection and analyses 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 made. QC for sample collection includes the

use of duplicate and spiked  samples, as well as sample blanks.  QC for sample analysis includes the use

of spiked and  split samples,  proper  calibration protocols, and  appropriate  analytical  methods  and

procedures.   Guidance on QA/QC for  sample collection and analysis is contained in Chapter 1 of  Test

Methods for Analysis of Solid Waste (SW-846)(EPA, 1986). Each analytical method describes additional

QC procedures for the specific method.
                                                  16

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 Section Three                                                                   Recordkeeping
                                  3.  RECORDKEEPING

 Persons who  prepare sewage  sludge are required to keep records  of sludge quality.  With respect to
 pollutants,  the  Part 503  regulation requires the preparer to  maintain  records documenting the
 concentration of pollutants in  the sludge.  With respect to pathogens and vector attraction, the records
 must describe how the pathogen and vector attraction reduction requirements were met and include a
 signed certification of their achievement.  The regulations specify that records be maintained for a period
 of at least 5 years.
 This section provides guidance to preparers on the specific records needed to document compliance. The
 records must be kept so that they are readily accessible to State and EPA inspectors. Preparers should
 be aware that failure to keep adequate records is a violation of the Part 503 regulations and subject to
 administrative, civil, and/or criminal penalty under the Clean Water Act.

 3.1  Records of Pollutant Concentrations
 The preparer  is responsible for maintaining the following documentation of sampling and analysis for
 pollutant concentrations:

      •  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 the analyses and the calculation of
         results (unless a contract laboratory performed the analyses for the preparer)
      •  Name of contract laboratory, if applicable.
      •  Sampling and analytical quality assurance/quality control(QA/QC) procedures
      •  Analytical results expressed in dry weight.

When sewage  sludge or the material  derived from sewage sludge that is going to be land applied does
not meet the pollutant concentration limits  in Table  3 of 40 CFR Part 503.13 (see Figure 1 on page 4),
additional records must be kept to demonstrate compliance with the pollutant limits in 40 CFR 503.13.
These records must demonstrate compliance with either the cumulative pollutant loading rate or the annual
                                              17

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Recordkeeping                                                                    Section Three
pollutant loading rate, as appropriate.  If the preparer plans to sell or give away the sewage sludge in a
bag or other container, he or she must develop and retain the following additional records:
         Calculation of an annual whole sludge application rate (AWSAR) that will not exceed the
         annual pollutant loading rate in Table 4  of 40 CFR 503.13  for each regulated pollutant.
         Appendix A of this document provides a worksheet to assist in calculating the AWSAR. The
         AWSAR must be distributed with the sewage sludge on a label  or information sheet.
         A copy of the label or information sheet provided to persons who will land apply the sludge.
If the preparer is going to land apply bulk sewage sludge, additional records that track the cumulative
pollutant loading rate for each land application site must be developed and maintained.  The preparer
should refer to the  guidance document  for  land appliers  for  detailed information on additional
recordkeeping requirements for land appliers.

3.2  Records of Pathogen Reduction
The Part 503 regulation require the maintenance of records that include a description of how compliance
was achieved and a certification that the pathogen requirements were met. In general, the description
should explain the treatment process for pathogen reduction and be supported by analytical results for
pathogens and  indicator organisms and log books documenting operational  parameters for sludge
treatment units.  If the sludge is only  Class B, the land applier must keep  records describing site
restrictions to prevent public exposure to  pathogens.  The following paragraphs briefly  explain each
pathogen reduction alternative and the types  of records used to demonstrate compliance.   The Class A
alternatives are designated Al through A6 and the Class B alternatives are designated Bl through B3.
Table 6 summarizes the recordkeeping requirement for each Class A alternative, and Table 7 covers each
Class B alternative.

Alternative Al—Time and Temperature
Alternative Al  requires that sludge treatment units be operated to maintain the sludge  at a specific
temperature for a specific amount of time.  Both of these parameters are determined using one of the
formulas provided in the regulations.  The appropriate equation used to determine the time-temperature
relationship is based on the percent total solids of the sewage sludge and on the mechanisms used by the
treatment process to heat the sludge.
                                               18

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Section Three
Recordkeeping
                                          Table 6
                          Recordkeeping Requirements for Class A
                              Pathogen Reduction Alternatives
Alternative Al— Time and Temuerature
• Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
• Sludge temperature (either continuous chart or two readings per day, at least one per shift)
• Time (days, hours, minutes) temperature maintained
Alternative A2— Alkaline Treatment
• Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
• Sludge Ph (beginning, middle, and end of treatment)
• Time (hours) pH maintained above 12 (at least 72 hours)
• Sludge temperature (beginning, middle, and end of treatment and hourly to demonstrate 12 hours above 52°C)
• Percent solids in sludge after drying (at least SO percent)
Alternative A3 — Analysis and Operation
• Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
• Analytical results for density of enteric viruses (plaque forming unit/4 grams total solids) prior to pathogen
reduction and, when appropriate, after treatment
• Analytical results for density of viable helminth ova (number/4 grams total solids) prior to pathogen reduction
and, when appropriate, after treatment
• Values or ranges of values for operating parameters to indicate consistent pathogen reduction treatment
Alternative A4— Analysis Only
• Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
• Analytical results for density of enteric viruses (plaque forming unit/4 grams total solids)
• Analytical results for density of viable helminth ova (number /4 grams total solids)
Alternative AS— Processes to Further Reduce Pathoaens (PFRP)
• Heat Drying
- Analytical results for density of Salmonella sp.
bacteria or fecal coliform (most probable number)
- Moisture content of dried sludge < 10 percent
- Logs documenting temperature of sludge particles
or wet bulb temperature of exit gas exceeding 80° C
(either continuous chart or two readings per day, at
least one per shift)
• Thermophilic Aerobic Digestion
- Analytical results for density of Salmonella sp.
bacteria or fecal coliform (most probable number)
- Dissolved oxygen concentration in digester ^ 1
mg/L
- Logs documenting temperature maintained at 55-
60°C for 10 days (either continuous chart or two
readings per day, at least one per shift)
• Heat Treatment
- Analytical results for density of Salmonella sp.
bacteria or fecal coliform (most probable number)
- Logs documenting sludge heated to temperatures
greater than 180°C for 30 minutes (either
continuous chart or three readings at 15 minute
intervals)
• Pasteurization
- Analytical results for density of Salmonella sp.
bacteria or fecal coliform (most probable number)
- Temperature maintained at or above 70 °C for at
least 30 minutes (either continuous chart or two
readings per day, at least one per shift)
• Composting
- Analytical results for density of Salmonella sp.
bacteria or fecal coliform (most probable number)
- Description of composting method
- Logs documenting temperature maintained at or
above 55°C for 3 days if within vessel or static
aerated pile composting method (either continuous
chart or two readings per day, at least one per
shift)
- Logs documenting temperature maintained at or
above 55°C for 15 days if windrow compost
method (minimum of two readings per day, at least
one per shift)
- Logs documenting compost pile turned at least five
times per day, if windrow compost method
• Gamma Ray Irradiation
- Analytical results for density of Salmonella sp.
bacteria or fecal coliform (most probable number)
- Gamma ray isotope used
- Gamma ray dosage at least 1.0 megarad
- Ambient room temperature log (either continuous
chart or two readings per day, at least one per
shift)
• Beta Ray Irradiation
- Analytical results for density of Salmonella sp.
bacteria or fecal coliform (most probable number)
- Beta ray dosage at least 1.0 megarad
- Ambient room temperature log (either continuous
chart or two readings, at least one per shift)
Alternative A6-PFRP Eauivalent
• Operating parameters or pathogen levels as necessary to demonstrate equivalency to the PFRP
• Analytical results for density of Salmonella sp. bacteria or fecal coliform (most probable number)
                                            19

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Recordkeeping	Section Three

                                                 Table 7
                              Recordkeeping Requirements for Class B
                                   Pathogen Reduction Alternatives
    Alternative 81—Fecal Coliform Count
     •  Number of samples collected during each monitoring event

     •  Analytical results for density of fecal coliform for each sample collected
     Alternative 82—Processes to Significantly Reduce Pathogens (PSRP)
       Aerobic Digestion
       -  Dissolved oxygen concentration
       -  Volatile solids content before and after digestion
       -  Mean residence time of sludge in digester
       -  Logs showing temperature was maintained for sufficient period of time (ranging from 60 days at 1S°C to
          40 days at 20°C) (continuous charts or two readings per day, at least one per shift)

       Air Drying
       -  Description of drying bed design
       -  Depth of sludge on drying bed
       -  Drying time in days
       -  Daily average ambient temperature

       Anaerobic Digestion
       -  Volatile solids content before and after digestion
       -  Mean residence time of sludge in digester (between 15 days at 35°C to 55°C and 60 days at 20°C)
       -  Temperature logs of sludge in digester (continuous charts or two readings per day, at least one per shift)

       Composting
       -  Description of composting method
       -  Daily temperature logs documenting sludge maintained at 40 °C for 5 days (either continuous chart or two
          readings per day, at least one per shift)
       -  Hourly readings showing temperature exceeded 55 °C for 4 consecutive hours

       Lime Stabilization
       -  pH of sludge immediately and then 2 hours after addition of lime
     Alternative B3-PSRP Equivalent
     •  Operating parameters or pathogen levels as necessary to demonstrate equivalency to PSRP
The time and temperature requirement for sewage sludge with a solids content of 7 percent or higher is
determined using equation 1:

                                             .  131.700.000
                                                    10o.i«ot

where:
D     =   Time in days
t      =   Temperature in degrees Celsius.
                                                    20

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Section Three	Recordkeeping
This equation was developed for sewage sludges that are at least 7 percent total solid and are treated by
pasteurization or composting. To use this equation to determine pathogen reduction reliably, the sludge
temperature must be maintained at 50° C or higher and the detention time must be at least 20 minutes.

The minimum time endpoint is not appropriate for treatment processes that heat the  small particles of
sewage sludge with warm gases or an immiscible liquid. If sewage sludge particles are heated by either
warm  gases or  an immiscible liquid and the percent total solids is 7 percent or higher, the  specific
temperature and time relationship is  still determined using equation (1).  However, the minimum value
for time that can be used in the equation is now 15 seconds.  The shorter time is  allowed because heat
transfer is more efficient for such processes  as rotary driers that use this technique for heating sludge
particles. The minimum value for the temperature variable is still 50° C.

When  the percent total solids is less than 7 percent and the detention time is greater than 15 seconds but
less than 30 minutes, then equation (1) is still used to determine the specific time and temperature values
that achieve compliance with the requirement.

When  the percent total solids is  less then 7 percent  and the time  is more than  30 minutes  and the
temperature of the sewage sludge is 50° C or higher, then a less stringent equation (eq. 2) may  be used
to determine the specific time and temperature values.
                                      D  =  —»—»vw                               (eq. 2)
                                               1Q0.1400T

where:
D    =   Time in days
t     =   Temperature in degrees Celsius.

To demonstrate compliance with the operational parameters, the responsible individual should check the
temperature in the sludge treatment unit(s) and record it to demonstrate that the sludge was held at a
constant temperature for the required number of days.  If the temperature is not recorded continuously,
it should be checked and recorded during each work shift or at least twice a day.

The  objective is to obtain temperature readings that are representative of the  temperature maintained
throughout the treatment process.  So, for example, if the treatment unit is operated 24 hours a day, each
                                               21

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Recordkeeping	Section Three
temperature reading should be evenly spaced, if feasible.  Otherwise, temperature readings should be
taken at the beginning and end of the work day.  If the process is operated for 1 day or less, record the
sludge temperature at the beginning, middle, and end of treatment.

In addition, records must document the detention time of the sludge in the treatment unit. Records should
also identify the daily input of sludge to the treatment unit(s) and the withdrawal of supernatant and
processed sludge.  The size (gallons) of the treatment unit(s) should also be documented.

In  addition to  documenting  the  treatment unit  operating   parameters,  Alternative Al  requires
documentation of monitoring for either Salmonella sp. bacteria or fecal coliform at the time of use or
disposal.  The preparer should keep the following records documenting sampling and analysis for either
Salmonella sp. bacteria or fecal coliform and percent solids:

      •   Date and tune 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 the analyses and the  calculation of
          results (unless a contract laboratory performed the analyses for the preparer)
      •   Name  of contract laboratory, if applicable
      •   Sampling and  analytical QA/QC procedures
      •   Analytical results expressed as dry weight.

Alternative A2—Alkaline Treatment
Alternative A2, like Alternative A1, requires the analysis of sludge quality and the evaluation of operating
parameters.  As with the time and temperature alternative,  the  sludge must be monitored for either
Salmonella sp. bacteria or fecal coliform. The sludge must be kept at a pH of 12 for 72 hours.  The
temperature must be greater than 52°C for at least 12 of these hours. At the end of the 72-hour period,
the sludge must be air-dried until it is more than 50-percent solid.   When properly performed, this
pathogen reduction alternative also achieves vector attraction reduction (see Section 3.3).

Use of this alternative requires that operating logs be kept that document pH, temperature, residence time,
and percent total solids.  The temperature of the sewage sludge should be checked and recorded to
                                              22

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Section Three                                                                    Recordkeeping
document it is above 52°C for 12 continuous hours during the required 72-hour holding period.  If the
temperature is not continuously monitored, it should be checked hourly when feasible.  At a minimum,
it should be recorded at the beginning, middle, and end of treatment.  Similarly, the pH of the sewage
sludge should be recorded at the beginning, middle, and end of the required 72-hour holding period.  The
percent total solids also should be determined for each batch.  Analytical records (described under the
time and temperature alternative) for pathogenic organisms must document that sludge was analyzed at
the time of use or disposal for either Salmonella sp. bacteria or fecal coliform at the frequency specified
in Table 4.

Alternative A3—Analysis and Operation
Alternative A3, like the first two  alternatives, utilizes a combination of sludge quality analysis  and
documentation of operating parameters.  In addition to monitoring for either fecal coliform or Salmonella
sp. bacteria, preparers must monitor for enteric viruses and viable helminth ova. If the preparer follows
the steps outlined in Figure 3, he or she can substitute documentation of operating parameters for periodic
analysis of enteric viruses and viable helminth ova.  The preparer must sample sludge prior to pathogen
reduction.  If the analytical results show that enteric viruses and viable helminth ova are not detected,
then the sludge meets  Class A.   Otherwise,  the preparer must sample and  analyze the sludge after
pathogen reduction treatment.  If this final sludge meets the Class A requirements after treatment, the
preparer may document consistent maintenance of operating parameters shown to achieve appropriate
pathogen reductions instead of analyzing samples  of the sewage sludge for enteric viruses and/or  viable
helminth ova. Regardless of how the preparer demonstrates compliance with the enteric virus and  viable
helminth ova requirement, the final sludge must be sampled and analyzed at the time of use or disposal
for either fecal coliform or Salmonella sp. bacteria according to the frequency specified in Table  4.

Records must include documentation of sludge sampling and analysis before and after pathogen reduction
treatment.  Refer to the time and temperature alternative for a list of sampling and analysis records. The
records also must define the values used for operating parameters between the before- and after-treatment
sludge analyses.  If operating parameters are substituted for periodic sludge monitoring, records must also
document that these values are maintained consistently.  The specific operating parameters that must be
recorded to demonstrate compliance may vary  depending on the particular pathogen reduction process
used (e.g.,  composting, pasteurization).
                                               23

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                      Fecal Collform/Salmonella sp. Bacteria
                                                                    AND
                                                                                           Enteric Viruses
                                                                                                                             AND
                                                                                                                                                 Viable Helminth Ova
 "3
t
 3
  Sample sludge  after pathogen reduction
  treatment, but prior to use or disposal and
  analyze for either fecal coliform OR
  Salmonella sp. bacteria.
9

I
S
I

                                      OR
                    Fecal Coliform

                Analytical results show
                density less than  1000
                MPN per gram of total
                        solids.
I
 sr
 g
 a
f
 a
 §
                         Salmonella sp. Bacteria

                         Analytical results show
                           density  less than  3
                         MPN per four grams of
                               total solids.
  Sludge is Class A
until next monitoring
       interval.
                                             Sludge is Class A
                                           until next monitoring
                                                 interval.
                                                                             Sample sludge  before pathogen reduction
                                                                             treatment and analyze for viruses.

                                                                             Begin pathogen reduction treatment and
                                                                             record operating parameters.
                                                                                                 OR
Analytical results show
density less than 1
PFU per 4 grams of
total solids.

Analytical results show
density greater than or
equal to
1 PFU per 4 grams of
total solids.
Sludge is Class A
until next monitoring
interval.

Monitor sludge again
after pathogen
reduction treatment.
Sample sludge before pathogen reduction
treatment and analyze for viable helminth
                                                                                                                                      Begin pathogen reduction treatment and
                                                                                                                                      record operating parameters.
                                                                                                                                                                                                    4
Analytical results show
density less than 1
PFU per 4 grams of
total solids.

Analytical results show
density greater than or
equal to
1 PFU per 4 grams of
total solids.
Sludge is Class A
until next monitoring
interval.

Monitor sludge again
after pathogen
reduction treatment.
                                                                                     Density is less than 1
                                                                                      PFU per 4 grams of
                                                                                          total solids.
                                                                                                                                                             Density is less than
                                                                                                                                                            1  per 4 grams of total
                                                                                                                                                                   solids.
Notes:   Monitoring intervals are provided in Table 4.
         Results of all analyses must be reported in dry weight.
         MPN = Most Probable Number.
         PFU = Plaque Forming Unit
                                                                                                   Sludge is Class A without
                                                                                                  further monitoring as long as
                                                                                                  records demonstrate that the
                                                                                                  operating parameters of the
                                                                                                  pathogen reduction treatment
                                                                                                        remain constant.
                     Sludge is Class A  without
                   further monitoring as long as
                    records demonstrate that the
                    operating parameters of the
                   pathogen reduction treatment
                         remain constant.
                                                                                                                                                                                                     I
                                                                                                                                                                                                     8

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 Section Three                                                                    Recordkeeping
 Alternative A4^A\nalvsis Only
 Alternative A4 relies solely on the analysis of sewage sludge for pathogens (i.e., Salmonella sp. bacteria,
 enteric viruses, and viable helminth ova) and  indicator organisms (i.e., fecal coliform) to demonstrate
 pathogen reduction.
 Records must document that these parameters were sampled and analyzed at least as often as specified
 in the Part 503 regulation (see Table 4). The preparer should keep records documenting the following
 items for each sampling event:

      •    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 the analyses and  the calculation of
          results (unless a contract laboratory performed the analysis for the preparer)
      •    Name of contract laboratory, if applicable
      •    Sampling and analytical QA/QC procedures
      •    Analytical results expressed as dry weight.

 Alternative AS—Processes to Further Reduce Pathogens
 Alternative A5 requires a combination of sludge analysis for  either fecal coliform or Salmonella sp.
 bacteria and documentation of operating parameters.  The specific  operating parameters that must be
 evaluated are  defined by the  Processes to Further  Reduce Pathogens (PFRPs) that were originally
 established in 40 CFR Part 257.   These have been modified slightly and are included in Appendix B of
 Part 503.  The seven different processes  and the specific operating parameters for each are  included in
 Table 6.  Records should include a description of the pathogen reduction process, documentation of
 sampling and  analysis of the  sludge  for fecal  coliform  or Salmonella sp.  bacteria,  and  log books
 documenting proper operation of pathogen reduction processes.

 Alternative A6—PFRP Equivalent
Alternative A6 requires a combination of sludge analysis and documentation of operating parameters.
As  with the other Class A  alternatives, the sludge must be  monitored for  either fecal coliform or
Salmonella sp. bacteria. Alternative A6 requires sewage sludge to be treated in a process equivalent to
                                              25

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Recordkeeping                                                                    Section Three
a PFRP, as determined by the permitting authority.  The permitting authority should have specified the
appropriate  records  to  demonstrate compliance  with  this alternative.   The records could  include
temperature in sludge treatment units, retention time,  pH, solids or moisture content, and dissolved
oxygen (DO) concentration.

Alternative Bl—Fecal Coliform Count
Alternative Bl requires the analysis of the sewage sludge for fecal coliform.  The responsible individual
should maintain the following records demonstrating compliance with the fecal coliform level:

     •   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 the analyses and the calculation of
         results (unless analysis was performed by a contract laboratory)
     •   Name of contract laboratory, if appropriate
     •   Sampling and analytical QA/QC procedures
     •   Analytical results expressed as dry weight
     •   Calculation of the geometric mean of the seven samples analyzed to demonstrate compliance
         with the maximum allowable level (see Table 3).

In addition, the use of this  alternative and  any other Class B pathogen reduction alternative for bulk
sewage sludge that will be land applied requires that the land applier demonstrate compliance with specific
site restrictions. The preparer is responsible for keeping records on the site restrictions only when he
or she  is also performing the land application.

Alternative B2—Processes to Significantly Reduce Pathogens
The Processes to Significantly Reduce Pathogens (PSRPs) were originally established in 40 CFR Part 257.
These have been modified slightly and are included hi Appendix B of Part 503.  As with the PFRP
alternative,  the specific operating parameters that must be evaluated vary depending on the  sludge
treatment process used, as listed in Table  7. Records should include  a description of the pathogen
reduction process and  log books  documenting  regular  and frequent  evaluations of the operating
parameters.
                                               26

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Section Three                                                                    Recordkeeping
Alternative B3—PSRP Equivalent
Alternative B3 requires sewage sludge to be treated in a process equivalent to a PSRP, as determined by
the permitting authority.  The permitting authority should have specified the appropriate records to
demonstrate compliance with this alternative.  The records could include temperature in sludge treatment
units, retention time, pH, solids or moisture content, and DO concentration.

3.3 Records of Vector Attraction Reduction
When sewage sludge is land applied or placed in an active surface disposal unit, the Part 503 regulation
requires a certification that the vector attraction reduction requirements were met and a description of how
these requirements were achieved. The description should be supported by documentation of process
controls and management practices for treatment processes that achieve vector attraction reduction. As
with the pollutant and pathogen records, this documentation must be kept for 5 years.

There are a total of 11  options to comply with the vector attraction reduction requirements.  The first
eight options (see Table 8) apply to both the land application  and surface  disposal sludge quality
requirements.  These eight options, referred to as the sludge  processing options,  involve sludge treatment
to reduce vector  attraction characteristics.  They are performed primarily by  preparers during or
immediately after pathogen reduction.   Options 9 through 11, referred to as the sludge management
options, are performed by land appliers at the  land application site or  by owners/operators of surface
disposal sites after placement on the  sewage sludge unit.  These sludge management options are not
included in this guidance because they are not performed by the preparer, unless the preparer is also the
land applier or owner/operator of the surface disposal site. However, they are discussed in the following
documents:
     •   Land Application of Sewage Sludge—A Guide for Land Appliers on the Recordkeeping and
         Reporting Requirements of the Federal Standards for the Use or Disposal of Sewage Sludge,
         40 CFR Part 503 (EPA, 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, 1993).
                                              27

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Recordkeeping
Section Three
                                            Table 8
    Recordkeeping Requirements for Vector Attraction Reduction Sludge Processing Options
Option 1— Volatile Solids (VS) Reduction
• Volatile solids concentration of raw and final
sludge streams (mg/kg)
• Calculations showing 38 percent reduction in
volatile solids
Options 2 mid 3— Bench-Scale VS Reduction
• One-time description of bench-scale digester
• Time (days) that sample was further digested in
bench-scale digester (30 days for aerobically and
40 days for anaerobically digested sludge)
• Temperature logs (at least two readings per day)
showing temperature maintained at 20°C for
aerobically or between 30 °C and 37 "C for
anaerobically digested sludge
• Volatile solids concentration of sludge (mg/kg )
before and after bench-scale digestion
Option 4— Specific Oxygen Update Rate
• Dissolved oxygen readings for sludge sample
over 15-minute intervals (mg/L)
• Temperature logs at beginning and end of DO
readings showing test was conducted at 20 °C
• Total solids for sludge sample (g/L)
• SOUR calculations (mg/g)
Option 5— Aerobic ProcessingfThennophilic
Aerobic Digestion/Composting)
• Sludge detention time in digester/composting
• Temperature logs (at least two readings per day)
showing average temperature above 45 °C and
minimum temperature above 40 °C for 14
consecutive days
Options 6— Alkaline Treatment
• Logs demonstrating hours pH of sludge/alkaline
mixture was maintained (12 for 2 hours and 1 1.5
for an additional 22 hours)
• Amount of alkaline added to sludge (Ibs or gals)
• Amount of sludge treated
Options 7 and 8— Drying
• Results of percent solids (dry weight) test
• Presence of unstabilized solids generated during
primary treatment
Options 1 Through 3—Volatile Solids Reduction
Volatile solids are representative of the unstable, putrescable organic matter in the sludge.  Reductions
in organic matter reduce  putrescibility and, thus, vector attraction.  Option 1 requires a demonstration
that volatile solid concentrations are reduced by 38 percent between the raw sludge and the digested
sludge.  Control of Pathogens and Vectors in Sewage Sludge (EPA, 1992) presents several methods of
calculating volatile solids reduction.  The simplest equation is reproduced below:
                                              28

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Section Three                                                                      Recordkeeping
                      Reduction
                                            %VS(raw) ~  % ^(stabilized)
                                   %vs(raw)  -  [%vs(raw) x %vs(stabilized)]
where:
^Reduction         = Percent reduction of volatile solids
                     = Volatile fraction in raw sewage sludge
                     = Volatile fraction in stabilized sewage sludge.
The preparer needs to maintain records on the volatile solids content (mg/kg) of both of these streams
and the calculation of volatile solids reduction.   While most preparers evaluate this parameter regularly
to document constant process operation, records must show that volatile solids reduction was evaluated
at least as frequently as specified in Table 4 in Section 2.

Options 2 and 3 are methods to demonstrate that vector attraction reduction is achieved even though 38
percent volatile solids reduction was not attained. Option 2 applies to anaerobically digested sludge, and
Option 3 applies to aerobically digested sludge.  These methods involve taking a sample  of the final
digested sludge and digesting it further in a bench-scale apparatus for a specified period over a specific
temperature range.  It is important to dilute the sample of aerobically digested sludge to 2 percent solids
or less. Bench-scale tests run with a higher percent solids do not produce reliable results. Percent solids
does not affect tests performed on anaerobicly digested sludge. If the sludge sample is from an anaerobic
digester, the bench-scale unit must be operated between 30 °C and 37 °C for 40 days.  Vector attraction
reduction is achieved if the volatile solids are reduced by less than 17 percent in the bench-scale digester.
If the sample is taken from an aerobic digester, the bench-scale unit must be operated at a temperature
of 20 °C for 30 days. Vector attraction reduction is achieved if the volatile solids are reduced by less than
15 percent in the bench-scale digester. The following records demonstrate that these alternatives are met:

     •  A description of the bench-scale digester and its operation
     •  The time (days) that the previously digested sludge sample was further digested hi the bench-
         scale digester
     •  The temperature (degrees Celsius) maintained  in the bench-scale digester for the  time (days)
         the sample was being further digested; the temperature should either be recorded continuously
         or it should be checked and recorded during each work shift or during at least two well-spaced
         intervals during each day.
                                               29

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Recordkeeping _ Section Three
Option 4 — Specific Oxygen Uptake Rate
The specific oxygen uptake rate (SOUR) is the rate by which oxygen is consumed by microorganisms in
the sludge.  A reduction of this rate indicates a lack of organic matter to be further oxidized or broken
down and, therefore, reduced vector attractiveness.  Vector attraction reduction is achieved if the SOUR
is equal to or less than 1.5 mg of oxygen per hour per gram of total solids at a temperature of 20°C.
The preparer should perform the SOUR test and record the  following information to demonstrate
compliance:

     •   DO readings of the sludge taken at 1 -minute intervals over a 15-minute period or until the DO
         is  reduced to less than 1 mg/L and the average DO value used in the SOUR calculation
     •   Calibration records for the DO meter
     •   Total solids determination for the sludge in g/L
     •   Temperature (degrees Celsius) taken at the beginning and end of the procedure
     •   Calculation of SOUR using the following equation:
               oxygen  consumption rate per  minute j
   SOUR  = - — 25 — i (60 minlhouf)
                                 total solids (g/L).

While most preparers evaluate this parameter regularly to document constant process operation,  the
records must demonstrate that the SOUR was evaluated at least as frequently as specified in Table 4 hi
Section 2.
Option 5 — Aerobic Processing
Aerobic processing, such as thermophilic aerobic digestion and composting, is effective for reducing
vector attraction characteristics because the higher operating temperatures achieve higher rates of organic
solids reduction. To achieve vector attraction reduction under Option S, the aerobic process must be
operated for 14 days with a minimum temperature greater than 40°C and an average temperature between
45°C and 60°C.  The preparer should record the following information to demonstrate compliance:

     •   Sludge residence tune
     •   Temperature (degrees Celsius) of the sewage sludge; the temperature should either be recorded
         continuously or checked and recorded at least once per work shift or at least twice a day.
                                             30

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Section Three                                                                     Recordkeeping
   Sludge residence time is  determined by dividing die digester volume (one-time measurement
   {gallons}) by the volumetric flow rate through the digester (measured on a continuous basis [gpd]).
Option 6—Alkaline Treatment
The alkaline treatment process destroys or inhibits pathogens and the microorganisms that decompose
sludge. Therefore, odors and putrescibility are reduced, leading to reduced vector attraction.  For Option
6, the pH of the sewage sludge must be raised to 12 and maintained there for 2 hours without adding
extra alkaline.  Then the pH must remain at or above 11.5 for an additional 22 hours.   The preparer
should maintain the following records to document alkaline treatment:

      •  pH (standard units) recorded  at least at the 0", 2", and 24-hour intervals of treatment
      •  Duration of time (hours) that pH is maintained at or above specified minimum levels
      •  Amount (pounds or gallons) of alkaline material added
      •  Amount of sludge treated (e.g., gallons, kilograms).

Options 7 and 8—Drying
Heat and air drying remove moisture from the sludge, thereby reducing pathogenic organisms and odor.
Odor reduction leads to reduced vector attractiveness.  Two vector attraction reduction  alternatives
involve drying. The primary distinction between the two is whether or not unstabilized solids generated
during primary wastewater treatment are a component of the sewage sludge.  If unstabilized primary
wastewater solids (i.e., raw sludge) are present, then the percent total solids of the final  sewage sludge
must be at least 90 percent to meet  the vector attraction reduction requirement. If raw sludge  is not
present,  then the percent total solids of the final sewage sludge must be 75 percent (or  greater).  The
preparer should determine percent total solids for each batch of sludge and keep the following records
to demonstrate compliance:

     •  Results of solids analysis of sewage sludge prior to mixing with other material(as dry weight)
         expressed as percent of final sludge
     •  Presence of unstabilized solids generated during primary treatment.
                                              31

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Recordkeeping                                                                      Section Three

Records must demonstrate that the analysis of percent total solids was performed at least as frequently

as specified in Table 4 in Section 2.
   Unstabilized solids — Utistabilized solids are organic materials in sewage sludge that have not been
   treated in either an anaerobic or aerobic treatment process.
                                                32

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 Section Four	Notification and Reporting
                        4.  NOTIFICATION AND REPORTING

 Several notification and reporting requirements are directed at persons who prepare sewage sludge. These
 include notice and necessary information, notice of interstate transport, and annual reports.  The first two,
 notice and necessary information and notice of interstate transport, are applicable when the sewage sludge
 is going to be land applied. However, if the sewage sludge that is prepared for land application meets
 the exceptional quality criteria, then the notification requirements do not apply. This section describes
 all three notification and reporting requirements.

 4.1  Notice and Necessary Information
 When sewage sludge is prepared for land application in bulk form or for distribution in a bag or other
 container, the preparer must inform the applier of the sludge quality. The notification requirements are
 different if the sludge is sold or given away in a bag or other container rather than being land applied in
 bulk.  The notice and necessary information requirement does not apply when the  sewage sludge or the
 material derived  from sewage sludge  meets  the exceptional quality  criteria.  A sample  format for
 providing notice and necessary information is in Appendix B.

 Bulk Sewage Sludge
 When bulk sewage sludge that is not  exceptional  quality is prepared  for land application, both the
 preparer and the land applier have notification requirements.  The preparer must provide  the following
 sludge quality information to the land applier:

      •   Pollutant concentrations
      •   Nitrogen concentration (TKN, ammonia, and nitrate nitrogen)
      •   Pathogen reduction level achieved (Class A or Class B)
      •   Vector attraction reduction option used (Options 1-8).

 The land applier must have this information to comply with the Part 503 regulation when land applying
the sewage sludge. If the pollutants do not meet the  pollutant concentration limits in Table 3 of 40 Code
of Federal Regulation (CFR) 503.13, then the land  applier must track the cumulative pollutant loading
rates.  If a Class B pathogen reduction alternative was used, then the land applier must ensure that the
site restrictions are met.  If the preparer did not perform one of the sludge processing vector attraction
reduction options (Options  1-8), then the land applier must perform one of the sludge management vector
                                              33

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Notification and Reporting                                                         Section Four
attraction reduction options (Options 9-10).  For a more detailed description of the responsibilities of the
land applier,  refer  to Land  Application  of  Sewage  Sludge:  A  Guide for Land Appliers on  the
Recordkeeping and Reporting Requirements of the Federal Standards for the Use or Disposal of Sewage
Sludge (EPA,  1993).

The land applier is also responsible for providing the land owner or lease holder of the land notice and
necessary information to comply with the Part  503 requirements. For example,  if the sludge only met
Class B pathogen reduction, then the land owner or lease holder must be informed of the site use and
access  restrictions.  In addition, if the  pollutant concentration limits in Table 3 of 40 CFR 503.13 are
not met, the land applier must track the cumulative pollutant loading rates for each land application site.
In this case, the  land applier must document and provide the land owner or  lease holder with the
following information:

     •   Location of land application site
     •   Date bulk sludge was applied
     •   Time bulk sludge was applied, if Vector Attraction Reduction Option 9 or 10 was used
     •   Number of hectares where the sludge was applied
     •   Amount of bulk sludge applied
     •   Cumulative amount of each pollutant (i.e., kilograms)  applied.

The land owner or tenant may request specific information, such as analytical results on sludge quality
or documentation on how the management practices are met.  In general, the example form in Appendix
B may  be used to satisfy the notice and necessary information requirements of both the preparer and the
land applier.

Sewage Sludge Sold or Given Away in a Bag or Other Container
When sludge that does not meet the pollutant concentration limits in Table 3 of 40 CFR 503.13 is sold
or given away in a bag or other container, it must be accompanied by a label or instruction sheet.  The
label or instruction sheet must contain the following information:

     •   Name and address of the person who prepared the sewage sludge for distribution
     •   Statement that land application is prohibited except in accordance with  the instructions
                                              34

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Section Four                                                        Notification and Reporting
      •   Instructions on the annual whole sludge application rate that will comply with the annual
          pollutant loading rates in Table 4 of 40 CFR 503.13.
4.2 Notice of Interstate Transport
When bulk sewage sludge that does not meet the exceptional quality criteria is going to be applied to land
outside the State in which the sludge was prepared, the preparer is required  to provide written notice
prior to the initial application of the sewage sludge.  The written notice  must include the following
information:

     •   Location, by either street address  or latitude and longitude, of each  land application site
     •   Approximate time when bulk sewage sludge will be applied to the site
     •   Name, address, telephone number, and National Pollutant Discharge Elimination System permit
          number for the person who prepares the bulk sewage sludge.

This notice must be submitted to the permitting authority for the State in which the bulk sewage sludge
is proposed to be applied. Contact the appropriate EPA Regional office for specific information on where
to send this notification.

4.3 Annual Reports
Most preparers are required to report annually to the permitting authority under 40  CFR Part 503.
Annual reports cover information and data collected during the calendar year (January 1 to December
31).l Reports on sludge quality must include the results from monitoring pollutant concentrations and
pathogen  levels, a description of operating parameters for pathogen reduction and vector attraction
reduction, and certifications that pathogen and vector attraction reductions were achieved.  Permits issued
by EPA or the State may contain additional  reporting requirements.

Who Is Responsible For Submitting Reports Under 40 CFR Part 503?
Facilities responsible for reporting annually  are described in the regulation as:
    1 The first annual report required under the regulation is due February 19, 1994.  It must contain
information generated after the July 20, 1993, compliance deadline through December 31, 1993.
                                              35

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Notification and Reporting                                                         Section Four
      •   Publicly owned treatment works (POTW) with an average design influent flow rate equal to
         or greater than 1 million gallons per day
      •   POTWs serving a population of 10,000 or more
      •   Class I sludge management facilities.

Class I facilities are defined  as POTWs identified under 40 CFR 403.8(a) as being required to have
approved pretreatment programs (even if they are in a State that has elected to assume local pretreatment
program responsibility).  In addition, the EPA Regional Administrator and State Director may designate
any other treatment works as a Class I facility, including sludge generators, processors, land appliers,
and owners/operators of surface disposal sites and incinerators.  All facilities defined or designated as
Class I facilities are subject to the reporting requirements described in this section.

What Information is Required
The Part 503 regulation specifies that reports cover the information that preparers are required to keep
in their records.  This includes background information on the generation, use, and disposal of sludge;
the results of sludge quality analysis; and a description and certification for pathogen and vector attraction
reduction requirements.   This section  describes the specific data and documentation that must be
submitted.

Preparers are asked to report basic information about the sludge amount and its use or disposal. Specific
facts needed by EPA and the  State include the following:

      •   Amount of sludge generated,  in metric tons expressed as a dry weight (see Appendix C for
         equations to convert sludge volume to metric tons)
      •   Use or disposal practices
      •   Amount of sludge that goes to each use or disposal practice
      •   Name and address of the preparer who will receive the sludge next, if applicable
      •   Name and address  of the land applier and owner/operator of the  surface disposal site  , if
         different from the generator.

The  reporting requirements  for pollutant limits include submission of the analytical  results from
monitoring pollutant concentrations in the sewage sludge.  Reports should include the results of all
                                               36

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Section Four                                                         Notification and Reporting
analyses performed during the reporting period using the prescribed analytical method(s).  Analytical
results must be reported as milligrams per kilogram dry weight.  Reports should also indicate which
analytical methods were used, how frequently sludge was monitored, and the types of samples collected.
Preparers may have to report additional  information regarding pollutants if they beneficially use or
dispose of the sludge themselves.

Preparers also are  required to submit a certification and description of how the pathogen reduction
requirements were met.  A detailed description of the pathogen reduction treatment process should include
the type of process used and  standard operating procedures.  It should identify specific values for all
operating parameters.   The description should also  include a schematic diagram.  The certification
statements required by the 503  Rule are listed in  Section 503.17, Recordkeeping,  and  have  been
reproduced in Appendix D of this document. It should be noted that the preparer of sludge meeting only
Class B pathogen reduction requirements does not have to report records kept by the land  applier, land
owner, or lease holder on the site  restrictions used to limit public contact with the sludge once it is
applied.  In addition, if sludge is placed on an active surface disposal unit and covered daily, the preparer
does not have to perform or report on pathogen reduction.

Finally, preparers are required to report information regarding vector attraction reduction  when one of
the sludge processing options is used (Options 1-8).   The  report must contain a description  and
certification that the vector attraction reduction requirements were met.

When and Where Are Reports Submitted?
Annual reports required under Part 503 are due February  19  every  year beginning in 1994.  Annual
reports must be submitted to the  Permitting Authority, which  is the EPA Regional Water Compliance
Branch Chief until State sludge management programs are delegated the responsibilities of the Federal
program.  The address for each Branch Chief is provided on the inside back cover of this booklet.  The
map on the front cover shows the EPA Region in which each State is located.
                                               37

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                                                                                References

                                      REFERENCES

U.S. Environmental Protection Agency.  1993. A Guide to the Federal EPA Rule for Land Application
    of Domestic Septage to Non-Public Contact Sites.  EPA/832-B-92-005.

U.S. Environmental Protection Agency.  1993. Land Application of Sewage Sludge — A Guide for Land
    Appliers on the Recordkeeping and Reporting Requirements of the Federal Standards for the Use and
    Disposal of Sewage Sludge, 40 CFR Part 503.  Washington, DC:  Office of Water.

U.S. Environmental Protection Agency.   1993.  Sewage Sludge Sampling Techniques.  Demonstration
    Video.

U.S. Environmental Protection Agency.  1993. Summary of 40 CFR Part 503.

U.S. Environmental  Protection Agency.   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 and Disposal of Sewage Sludge, 40 CFR Part 503.
    Washington, DC: Office of Water.

American Public Health Association.  1992.  Standard Methods for the Examination of Water and
    Wastewater, 18th ed. Washington, DC.

U.S. Environmental  Protection Agency.  1992.  Environmental Regulations and Technology:  Control
    of Pathogens and Vectors in Sewage Sludge.  Cincinnati, OH.  EPA/625/R-92/013.

U.S. Environmental Protection  Agency.   1989.   POTW Sludge Sampling and Analysis Guidance
    Document. Washington, DC: Office of Water.

U.S. Environmental  Protection Agency.  1989. Sampling Procedures and Protocols for the National
    Sewage Sludge Survey.  Washington, DC:  Office of Water.

Yanko, W.A. 1987.  Occurrence of Pathogens in Distribution and Marketing Municipal Sludges. EPA
    600/1-87-014, NTIS PB  88-154273/AS.

U.S. Environmental  Protection Agency.  1986. Test Methods for Evaluating Solid  Wastes  (SW-846).
    Washington, DC: Office of Solid Waste.

U.S. Environmental Protection Agency.  1983. Methods for the Chemical Analysis of Water and Wastes.
    Washington, DC. EPA-600/4-79-020.
                         ADDITIONAL REFERENCES FROM EPA

Draft Materials Available During Fall/Winter 1993 — Guide to 503 Risk Assessment, Odor Control
    Handbook, Plain English Guide to 503, Update to Beneficial Use Policy.

Additional fact sheets and guidance documents that address specific topics related to the use or disposal
of sewage sludge are also under development.
                                            38

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                           APPENDIX A

WORKSHEET FOR CALCULATING THE ANNUAL WHOLE SLUDGE APPLICATION RATE
            TO MEET THE ANNUAL POLLUTANT LOADING RATE

-------
 Applicability;
 For sewage sludge sold or given away in a bag or other container where the pollutant concentrations exceed those in Table 3 of
 §503.13 but do not exceed those in Table 1 of §503.13.
 Procedure:
 Step 1:  Measure the concentration of the pollutants listed in column 1 for the sewage sludge.  Record the concentration in
        column 3 according to milligrams of pollutant per kilogram of solids in the sludge.
 Step 2:  Perform the calculation as shown for each pollutant and record the annual whole sludge application rate in column 4.
   COLUMN 1
   POLLUTANT
      COLUMN 2
ANNUAL POLLUTANT
   LOADING RATE,
    kg/ha/365 days
    COLUMNS
   POLLUTANT
CONCENTRATION,
      mg/kg
      COLUMN 4
   ANNUAL WHOLE
SLUDGE APPLICATION
RATE, tonnes/ha/365 days
 ARSENIC
 CADMIUM
 CHROMIUM
 COPPER
 LEAD
 MERCURY
 MOLYBDENUM
 NICKEL
 SELENIUM
 ZINC
         2.0
         1.9
         150
         75
          15
         0.85
         0.90
         21
         5.0
         140
                    X1000
                    X1000
                    X1000
                    X1000
                    X1000
                    X1000
                    X1000
                    X1000
                    X1000
                    X1000
Step 3: Compare each of the annual whole sludge application rates in column 4 and choose the lowest recorded rate.  Record
       the number in the space provided below.
THE ALLOWABLE AWSAR* IS:
                               metric tons per hectare per 365 days.
    Please note that any time the sludge quality changes, the annual whole sludge application rate must be reevaluated. To
    reduce the frequency that the label must be changed, the preparer may opt to base the AWSAR on the highest
    concentration recorded for each pollutant from historical data. However, the preparer must continue to compare sludge
    concentrations data to the pollutant concentrations used to develop the AWSAR.
                                                 A-l

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                      APPENDK B
SAMPLE FORMAT PROVIDING NOTICE AND NECESSARY INFORMATION

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                                  NOTICE AND NECESSARY INFORMATION

 This form is to assist compliance with the bulk sewage sludge notification requirements [503.12(f)J.  Please note, however,
 that if the sewage sludge meets the exceptional quality criteria, then the notification requirements do not apply. This form
 can be used by preparers of sewage sludge to transmit information to land appliers and also by land appliers to transmit
 information to land owners or lease holders.


\	Part I — To Be Completed fay PREPARERS of Sewage Stodge	

 A.   Please provide pollutant concentrations
Name
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Nitrogen Concentration
Concentration (mg/kg)
Dry Weight











Pollutant Concentrations
(Table 3, 40 CFR 503. 13)
(monthly average)
41 mg/kg
39 mg/kg
1200 mg/kg
1500 mg/kg
300 mg/kg
17 mg/kg
18 mg/kg
420 mg/kg
36 mg/kg
2800 mg/kg
N/A
Ceiling Concentrations*
Table 1,40 CFR 503. 13)
(daily maximum)
75 mg/kg
85 mg/kg
3000 mg/kg
4300 mg/kg
840 mg/kg
57 mg/kg
75 mg/kg
420 mg/kg
100 mg/kg
7500 mg/kg
N/A
 '"Sludge may not be land applied if any pollutant exceeds these values.
B.   Pathogen Reduction (40 CFR 503.32) — Please indicate the level achieved
            Class A                       Class B

C.   Vector Attraction Reduction (40 CFR 503.33) — Please indicate the option performed

      I — I   Option 1                I — I    Option 2               I _ I    Option 3

                                   I — I    Option 6               I _ I    Option 7
            Options
I—I   Option 4

I	I   Option 8
      D
            No vector attraction reduction options were performed
D.   CERTIFICATION
     I certify under penalty of law that this document and all attachments were prepared under my direction or supervision
     in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
     submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible
     for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
     complete.  I am aware that there are significant penalties for submitting false information, including the possibility of
     fine and imprisonment for knowing violations.
A. Name and Official Title (type or print)
C. Signature
B. Area Code and Telephone Number
D. Date Signed
                                                     B-l

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B.
C.
                               Part D - To Be Completed by LAND APPUERS of Scwige Sludge
                                                                                                                              3
A.    If the pollutant levels in the sewage sludge do not meet the pollutant concentration limits in Table 3, then the land applier must
      provide the land owner with the following information:
      1.    Location of land application site.
      2.   Number of hectares where the sludge was applied.

      3.   Date and time bulk sewage sludge was applied	

      4.   Amount of bulk sludge applied	
      5.   Record the amount of each metal and nitrogen applied in pounds per acre or kilogram per hectare.
Utflto

Anenlc

Cadmium

Chrottduia

Copper

IMA

Mercury




Nfck«l

Sttehoa

Zinc

NliVQ£iti

      If a Class B pathogen reduction alternative was used (see Part I), then the following site restrictions must be met.  Please check the
      boxes if any of the site restrictions apply.

      1.     Food crops that may touch the sewage sludge/soil mixture cannot be harvested before the end of the following waiting
            period:

            LJ  a.  If harvested parts  are totally above the land, wait to harvest for 14 months after the application of sludge.

            LJ  b.  If harvested parts  are below the land surface and the sludge sat on top of the soil for 4 months before the field
                    was plowed, wait  to harvest for 20 months after the initial application of sludge.

            LJ  c.  If harvested parts  are below the land surface and the sludge was incorporated into the soil within 4 months of
                    being applied, wait to harvest for 38 months after the initial application.
      2.

      3.

      4.


      5.


      6.
                 Feed crops cannot be harvested for 30 days after application of the sludge.

                 Animals cannot graze on the land for 30 days after application of the sludge.

                 If harvested turf is used for a lawn or other purpose where there is a high potential for public exposure, then the turf
                 cannot be harvested for 1 year after the application of the sludge to the land.

                 Public access to land with a high p?ten.tifll (parks, playgrounds, golf courses) for public exposure will be restricted
                 for 1 year after the application of the sludge.

                 Public access to land with a low potential (private property, remote or restricted public lands) for public exposure
                 will be restricted for 30 days after the application of the sludge.
      If the preparer did not perform vector attraction reduction options (see Part I), then either option 9 or 10 must be performed by the
      land applier.  Please indicate if option 9 or 10 was performed. Check appropriate box.

      LJ   Option 9—Subsurface Injection    LJ   Option 10—Incorporated (plowed) into the Soil    LJ   N/A

D.    CERTIFICATION

       I ceitify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system
       designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who
       manage the system or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and
       belief, true, accurate, and complete.  I am aware that there are significant penalties for submitting false information, including the possibility of fine
       and imprisonment for knowing violations.
A. Name and Official Title (type or print)
C. Signature
B. Area Code and Telephone Number
D. Date Signed
                                                              B-2

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                    APPENDIX C





EQUATIONS FOR CONVERTING SLUDGE VOLUME TO METRIC TONS

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            EQUATIONS FOR CONVERTING SLUDGE VOLUME TO DRY METRIC TONS


Applicability;

The amount of sewage sludge used or disposed must be reported as metric tons, dry weight.

Procedure;

Step 1:  Convert the common measure (e.g., cubic yards or gallons) to the English System or short tons, dry
        weight.
                Dry short tons = gallons of sewage sludge x —	x ——— x Percent Solids
                                                           gallon    2000 Ib

          8.34 Ib/gal is the density of water.  This equation is therefore applicable to liquid sludges (less
          than 5 percent solids). Site-specific densities may be determined and substituted in this equation
          for a more accurate result.
Dry short tons  = cubic yards (wet) of sewage sludge x

                                                              cubic yard    2000 Ib
                                                                                   x Percent Solids
         Y Ib/cubic yard is the site-specific bulk density of the sewage sludge.  It must be determined for
         each type of sludge prepared and substituted in the equation for accurate results.
Step 2:  If you are starting with the English System or short tons, convert them to dry weight.

                                  Dry tons = Wet tons x Percent Solids



Step 3:  Convert the English System or short tons to metric tons.

                                Dry metric tons = Dry short tons x .907
                                                 C-l

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      APPENDIX D





CERTIFICATION STATEMENT

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          EXAMPLE CERTIFICATION STATEMENT  FOR
                 PATHOGEN REDUCTION AND
             VECTOR ATTRACTION REDUCTION

    "I certify, under penalty of law, that the [insert either Class A pathogen
requirements in §503.32(a) or Class B pathogen requirements in §503.32(b)]
and the vector attraction reduction requirement in [insert one  of the vector
attraction reduction requirements in §503.33(b)(l) through §503.33(b)(8)]
[insert either have or have not] been met.  This determination has been
made under my direction and supervision in accordance with the system
designed to ensure that qualified personnel  properly gather and evaluate
the information used to determine that the pathogen and vector attraction
reduction requirements have been met. I am aware that there are significant
penalties for false certification including fine and imprisonment."

Note:    The exact language of the certification  should be tailored to
accurately describe which  requirements have been met and which have
not been met, when applicable.
                              D-l

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              GUIDANCE FOR DETERMINING DEWATERED SLUDGE BULK DENSITV
Applicability;

         Determine the site-specific bulk density of sewage sludge to accurately determine the amount of
         sewage sludge used or disposed.

Procedure:

Step 1:   Using a container of known volume [i.e., cubic feet (cu. ft.)] and known weight, obtain a sample
         of dewatered sludge  (cake) from truck  trailer, storage container, or pile.   Since this sample
         should be representative of the cake  as it is hauled away, the container should not be filled  by
         forcing an excessive quantity of cake into it.   It is recommended that the sample of cake  be
         dropped into the sample container from a height of 1 - 2 feet until it overflows. The excess cake
        , should then be scraped away so that the  top of the sample is even with the top of the container.
         Alternatively, the container may  be held about one foot  under the dewatered sludge discharge
         conveyor or pump  if the location can be safely accessed.

Step 2:   Obtain the net weight of the cake sample in the container as follows:


                        Wet Weight of Sample and Container
                     -   Weight of Container	^
                        Wet Weight of Sample

Step 3:   Calculate the bulk density of the sample of sewage sludge. The bulk density is the weight of the
         sample per unit volume of the sample container (i.e., X Ib/cu. ft).
                        Wet Weieht of Sample (lb) 	  =  Xlb/cu.ft.
                        Volume of container (cu. ft.)

Step 4:   Convert the bulk density obtained  from Step #3  to pounds (wet weight) per cubic yard.
         Example:


                        (X Ib/cu. ft.) x (27 cu. ft./cu. yd.)  =  Y lb  (wet weight)/cu. yd.

         The site-specific bulk density determined is now used in  the equation presented in Appendix C
         of the document entitled Preparing Sewage Sludge for Land Application or Surface Disposal to
         calculate dry short tons and then dry metric tons.

Step 5:   More than one sample should be collected and the density determined to improve the accuracy.
         It is suggested that a minimum of seven samples be collected.  Use the average of the results of
         the samples.   Also, this  analysis should be conducted  periodically to monitor any possible
         changes in the  bulk density.

Step 6:   It is recommended that a  minimum sample container (or bucket) volume equivalent to at least
         2.5 gallons be used to collect the cake sample. The volume of  your container should be verified
         by measuring the liquid volume capacity to the top of the container.  Assuming your container
         capacity is in gallons, convert the volume of the container to cubic feet by the following formula:


                        Volume of container (cu. ft.)  =     Volume of container gallons)
                                                                      7.48
         Avoid using a narrow  mouth container to collect dewatered sludge samples.

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