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LAND APPLICATION OF MUNICIPAL SEWAGE SLUDGE

FOR THE PRODUCTION OF FRUITS AND VEGETABLES



 A Statement of Federal Policy and Guidance
    U.S.  ENVIRONMENTAL PROTECTION AGENTY
     U.S.  FOOD AND DRUG ADMINISTRATION
       U.S.  DEPARTMENT OF AGRICULTURE
                    1981

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                              CONTENTS
                                                           Page No.
PART I:

PART II
A Statement of Federal Policy

Technical Guidance

Plan Considerations

I.  Minimum Requirements

    A.  Annual and Cumulative Cadmium
        Application Rates
    B.  Soil pH
    C.  PCBs
    D.  Pathogen Reduction
            II
           III
APPENDIX I:
APPENDIX II:
    Additional Recommendations

    A.  Use of High Quality Sludge
    B.  Cumulative Lead Application Rate
    C,  Pathogenic Organisms
    D.*'  Physical Contamination and
        Filth
    E.  Soil Monitoring
    F.  Choice of Crop Type

    Available Guidance and Assistance

  Relative Accumulation of Heavy Metals into
  Edible Plant Parts by Different Crops

  Examples of Forms Used for Evaluating
  Sludge Applications
APPENDIX III:  References

APPENDIX IV:
  Example of an Evaluation of Long-Term
  Sludge Benefits
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                Land Application of Municipal
               Sewage Sludge for the Production
                   of Fruits and Vegetables

                            Part I
A Statement of Federal Policy

     In some areas of the country, municipal wastewater sludges

have been used for many years as a soil amendment for croplands

producing fruits and vegetables.  This document draws upon the

expertise within the Environmental Protection Agency, the Department

of Agriculture, and the Food and Drug Administration in providing the

first statement of unified Federal guidance for those locations where

such programs are to continue.

     Since the passage of the Resource Conservation and Recovery

Act of 1976, the Environmental Protection Agency has been developing

a series of regulations which address the broad spectrum of waste

management.  One segment of those regulations entitled, "Criteria

for Classification of Solid Waste Disposal Facilities and Practices"*

was promulgated on September 13, 1979, and addressed the land appli-

cation of municipal wastewater sludges for food-chain crop production,

Although promulgated by EPA, the regulation also incorporated inputs

from EPA, the Food and Drug Administration, and the U.S. Department
* Federal Register/Vol.  44, No. 179,  pp. 53438-63464 (40 CFR Part 257),
  September 13,  1979.

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of Agriculture.  These three Agencies are responsible for maintaining




the integrity of our environment,  our food products,  and our agricul-




tural production, respectively.




     Shortly after promulgation of the "Criteria," some food




processors raised a series of questions concerning the perceived




safety and legality of food crops  grown on sludge-amended soils,




and procedures necessary to properly manage the application of




sewage sludge to land used to grow fruits and vegetables.  In order




to respond to these inquiries, the EPA, FDA and USDA have collaborated




in the development of this document.  It is structured upon the




"Criteria" which, in turn, embody  the requirements of the Resource




Conservation and Recovery Act (RCRA) and the Clean Water Act (CWA).




It is intended to supplement those regulations and provide a




coordinated Federal perspective on the use of municipal wastewater




sludges in fruit and vegetable crop production.  The document sets




forth the use of high quality sludges and proper management practices




so that growers, processors and consumers can be assured that the




current high standards of food quality in this nation will not be



compromised.




     For many years the use of high quality sludges has been an




attractive source of soil conditioners and nutrients, providing




economic benefit to growers.  However, many sludges also contain




substances which could contaminate such crops and make them unfit




for consumption.  The contaminants of greatest concern are the




heavy metals, toxic organic compounds, and pathogenic microorganisms,




which are addressed in the aforementioned EPA regulation.

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     Establishing tolerances or action levels in foods for various




sludge-borne contaminants, such as heavy metals, has been cited as




the preferred means of reducing the uncertainty associated with the




agricultural use of sludge.  The Federal government is presently




developing and collecting data from survey programs to establish such




tolerances if necessary.  Until the data collection and analyses are




complete, the bases for establishing tolerances will not exist.




Nevertheless, the Federal agencies believe that the use of high




quality sludges, coupled with proper management procedures, should




safeguard the consumer from contaminated crops and minimize any




potential adverse effect on the environment.




     The technical guidance in Part II of this document addresses




the use of high quality sludge, maximum soil contaminant levels,




pathogen reduction, physical contamination and filth, and soil




monitoring.  This guidance represents a reasoned approach, based




upon current knowledge and experience, in which risks are minimized




and continuing production of high quality food is assured.




     Pursuant to other statutes beyond RCRA and CWA, such as the




Toxic Substances Control Act, the Federal Food, Drug and Cosmetic Act,




and others, the Agencies will continue to develop regulations designed




to insure proper use and disposal of sewage sludge, and this document




will not constrain that effort.  As part of that rulemaking effort,




EPA will continue to evaluate new scientific data and consult with




the public.  As with all regulations and guidelines, this document




will be reviewed periodically and updated, if necessary, as experience




dictates.

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     Of necessity,  it should be understood that by following the

guidelines of this  document, the Federal government cannot offer

any indemnity against product recall,  seizure,  or other enforcement

actions, since these measures could result from unforeseen circum-

stances beyond the  control of the Federal government.   However,  the

risk of such enforcement actions would be no greater than the risks

associated with normal farming or processing practices.

     It is, therefore, the position of the Environmental Protection

Agency, the Food and Drug Administration, and the U. S.  Department

of Agriculture that, with the adherence to the guidance contained

in Part II of this  document, the safety and wholesomeness of the

fruit and vegetable crops grown on sludge amended soils will be

assured.
                            Administrator
                            U.S. Environmental Protection Agency
                            Secretary
                            U.S. Department of Agriculture
                            Commissioner
                            U.S. Food and Drug Administration

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                Land Application of Municipal
              Sewage Sludge for the Production
                   of Fruits and Vegetables

                           Part II

                      Technical Guidance


     The following guidance is offered by the Environmental

Protection Agency, the Food and Drug Administration, and the

U.S.  Department of Agriculture to minimize any risks and achieve

the goals of optimal utilization of sludge nutrients and production

of high quality fruit and vegetable crops.  To achieve those objec-

tives, the guidance is structured upon existing regulations, coupled

with systems of good operating practices of interest to both the

grower and food processor.


                        PLAN CONSIDERATIONS

     A  written operating plan, agreed upon between the grower and

the food processor (and perhaps having the input of the State environ-

mental or agricultural department), should include consideration of

each of the following elements.  In order to assure accessibility, it

is recommended that wastewater treatment plants keep a copy of this

operating plan on record.

I.   Minimum requirements are the limits prescribed in the present

     regulations,  hereafter referred to as the "Criteria."*  The

     essential components of these regulations are:
* Federal Register/Vol.  44, No. 179,  pp. 53438-53464 (40 CFR Part 257),
  September 13,  1979

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     A.    Annual  and  Cumulative Cadmium Application Rates




          Sludge  shall be  applied at an annual  rate not to exceed 0.5




          kilograms of cadmium per hectare.  Cumulative loadings of




          cadmium shall  not  exceed 5,  10, or 20 kilograms of




          cadmium per hectare, depending upon background soil pH




          and  soil cation  exchange capacity.  (See Appendix IV for




          an example  of  evaluating sludge benefits.)




     B.    Soil pH




          Soxl pH shall  be at 6.5 or greater (top six  inches of the




          soil) at the time  of each sludge  application.




     C.    PCBs




          If the  sludge  contains greater than 10 mg/kg PCBs, it




          must be incorporated  (injected or plowed) into the soil.




     D.    Pathogen Reduction




          The  sludge  must  be treated by an  effective pathogen




          reduction process  before being applied to the soil.  A




          12 or 18 month waiting period may be  required depending




          upon, a) the type  of processing used  to reduce pathogens




          in the  sludge  (further pathogen reduction processes are




          more effective than processes to  significantly reduce




          pathogens--see Appendix II of the Criteria), b) whether




          the  land is to provide access to  the  public  (camping,




          recreation, etc.), or c) whether  it is to be used for




          grazing or  to  grow crops for direct human consumption.




II.   Additional factors  presented below provide further assurance




     of safe and  wholesome food products:
                                 8

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     A.    Use of High Quality Sludge

          Growers should know the quality of the sludge that is

          intended for application on their land.   Sludge quality

          information obtained from the treatment  plant should

          provide the following:*

          1)    Concentration and availability to plants of the

          primary nutrients (nitrogen,  phosphorus,  and potassium),

          the micro-nutrients (zinc and copper), and other consti-

          tuents, where they would provide benefits to plants.

          2)    Concentrations of contaminants present in the sludge.

          A high quality sludge should not contain  more than 25

          mg/kg cadmium, 1000 mg/kg lead, and 10 mg/kg PCBs, on  a

          dry weight basis.  [NOTE:  This level of PCBs assumes  that

          carrots will receive the normal processing of scrubbing

          and peeling, since carrots tend to accumulate PCBs in  the

          skin.]

          3)    Type of pathogen reduction process  used at the treat-

          ment plant, and operating results.

     B.    Cumulative Lead Application Rate

          In  addition to maximum cumulative cadmium levels estab-

          lished by the Criteria, the maximum cumulative application

          of  lead to the soil should not exceed 800 kilograms per

          hectare.  (See Appendix IV for an example of evaluating

          sludge benefits.)
* (See Appendix II for examples of forms that may be used for
   presenting this information.)

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C.   Pathogenic Organisms



     For those geographic locations which desire to provide



     further assurances beyond the "Criteria," foods to be



     eaten raw, or which may be processed without sufficient



     blanching to destroy all pathogens,  should not be planted



     within 36  months of sludge application.   This recognizes



     that pathogen survival is greater in warm, moist environ-



     ments, than in extremely arid or cold environments.  The



     necessary waiting period can be achieved by including, in



     normal rotation, crops which are cooked or properly heat



     processed (peeled, washed, etc.) prior to delivery to



     consumers.



D.   Physical Contamination and Filth



     Sludge should be applied directly to the soil.  In no



     case should sludge be applied directly to growing food



     crops.  This will avoid the possibility of contamination



     by chemicals, filth or microbiological agents.  To further



     avoid the possibility of contamination, crops grown on



     sludge-amended soils should be processed in accordance



     with good established industry practices  (washed, peeled,



     etc.).  This is especially true for root crops and low-



     growing fresh fruits and vegetables.




E.   Soil Monitoring



     Monitoring of soil should be performed on a regular basis



     to assure consistent quality and safety of crops.  Soils



     should be monitored at least annually for pH.  Every  few



     years, the soil should also be tested for the cumulative






                            10

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           levels of cadmium and lead.   Standard test procedures for




           analysis of these heavy metals are listed in the EPA




           regulations of 40 CFR Part 136 (see Appendix III).




      F.    Choice of Crop Type




           Although high uptake crops may be safely grown as long




           as the technical guidance contained in this document is




           followed, growers can further preserve crop quality by




           planting fruits and vegetables which tend to exclude heavy




           metals.   Certain fruits and vegetables,  such as tomatoes




           and legume vegetables,  do not readily take up and translo-




           cate heavy metals to edible tissues, while other types will




           absorb metals to a somewhat greater degree.  Appendix I




           indicates the relative  tendencies of fruits and vegetables




           to accumulate heavy metals in edible tissues.




Ill.   Available Guidance and Assistance




      Growers may obtain guidance  on proper agronomic methods from




      USDA's Soil Conservation Service,  and the county-level




      Agricultural  Extension Services.   Additional  technical infor-




      mation on the subject of sludge use in fruit  and vegetable




      crop production is available in publications  from EPA and USDA.




      Some appropriate references  are contained in  Appendix III.
                                  11

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                             APPENDIX I
   Relative Accumulation of Heavy Metals into Edible Plant
                   Parts by Different Crops
 High
 Uptake
Moderate
Uptake
Low
Uptake
Very Low
Uptake
Lettuce

Spinach

Chard

Escarole

Endive

Cress

Turnip Greens

Beet Greens

Carrot
Kale

Collards

Beet

Turnip Root

Radish globes

Mustard

Potato

Onion
Cabbage

Sweet corn

Broccoli

Cauliflower
Snapbean family

Pea

Melon family

Tomato
Brussel Sprouts  Pepper

Celery           Eggplant

Berry fruits     Tree fruits
     The above classification is based upon the response of crops
grown on acidic soils that have received a cumulative cadmium
application of 5 kilograms per hectare.

     It should not be implied that the above higher uptake crops
cannot be grown on such a soil, or soils of higher cadmium concen-
trations.  Such crops can be safely grown if the soil pH is 6.5 or
greater at the time of planting, since the tendency of the crop to
accumulate heavy metals is significantly reduced as the soil pH
increases above 6.5.
                                15

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                         APPENDIX II




     Examples of Forms Used for Evaluating Sludge Applications






     Forms A and B are offered as examples of methods of organizing




soil, sludge and crop information.   Form A presents the results of




soil and sludge testing for an individual landspreading site.  It




also presents data on the crop to be grown.  Form B,  using the




information contained in Form A,  presents the various sludge application




rate options.  Some agricultural extension services,  through the




State universities, maintain a computer program for calculating




application rates.  Forms A and B are examples of the input




information and application rate output generated by such a program.




     The annual application rate of sludge can be determined on




the basis of either the nitrogen or phosphorus needs of the crop.




In general, less sludge is required to supply the crop phosphorus




than the crop nitrogen needs.  The amount of phosphorus applied in




excess of crop needs, that might result from determining the annual




sludge application based on crop nitrogen needs,  should not generally




pose an adverse environmental problem.




     The maximum annual addition of sludge that can be applied to a




given soil is based upon limiting the amount of cadmium.  The total




cumulative additions of sludge that can be applied are based upon




limiting cadmium and lead.  These limitations are given to protect




human health from the effect of excessive amounts of cadmium and




lead in the soil.




     Also, some States limit the maximum amount of sludge that can be




added to a given soil, based upon the application of additional
                              16

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heavy metals, such as zinc, copper, and nickel.  These metals do



not pose a health problem.  These limitations are given rather to



protect against possible toxicity to plants.   As an example, data



for these additional metals are shown in Forms A and B.



     From a review of the literature, it is evident that the



methodologies for determining application rates are area and site



specific.  The local agricultural extension service and/or responsible



local environmental authority should be consulted when determining



an appropriate sewage sludge application rate.
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                             FORM A
                           INPUT FORM
Name:   Rudolph Tucker
Address: RR # 10
City; Centreville, Ohio
Year: 1980
Field Size: 24 acres
Crop:  Carrots
     Soils Information
     A
     B
     C
     D
     E
     PH:
        5.9
     Cation Exchange Capacity (CEC):
     Phosphorus Test Value:
     Potassium Test Value:
     Lime Test Value:
Sludge Information
A.   Ammonium Nitrogen (%):
B.   Organic Nitrogen (%):
C.   Phosphorus (P %):
D.   Potassium (K %):
E.   Zinc (mg/kg):
F.   Copper (mg/kg):
G.   Nickel (mg/kg):
H.   Cadmium (mg/kg):
I.   Lead (mg/kg):
J.   PCB (mg/kg)
Crop Information
A.   This year's crop:
B.   Last year's crop:
C.   Yield goal in bu/acre; cwt/acre;
     or tons/acre:
27.3 & 4.8 meq/lOOg
39.9 mg/kg (79.8 Ib/acre)
330 mg/kg (660 Ibs/acre)
	67	

	3 .0%	
	3.0%	
	2.0%	
	0.9%	
	1192	
	645	
	33.6	
	9.7	
	786	
	
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                              FORM B

            INFORMATION ABOUT THE SLUDGE AT ALTERNATIVE

               APPLICATION RATES FOR A CARROT CROP
Sludge
ITEM
Metals
Zinc
Copper
Nickel
Cadmium
Lead
PCBs
Nutrients
Nitrogen
-Required
-From Sludge
Phosphate ^205)
-Required
-From Sludge
Potash (K20)
-Required
-From Sludge

Sludge value
this year
Assuming 2.3 tons/acre
1
Application
2
Rates
3
(tons/acre)
4
5
6
Ib/acre
2.3
1.2
0.05
0.02
1.5
0.0

85
72*
75
91*
0
22

40.
lime
4.7
2.5
0.1
0.04
3.1
0.0

85
144
75
182
0
43
$/Ton
5 25.5
required to
7.1
3.8
0.2
0.06
4.7
0.0

85
216
75
272
0
65

21
raise
9.5
5.1
0.2
0.08
6.2
0.0

85
288
75
363
0
86

18.7
soil pH
11.9
6.4
0.3
0.10
7.8
0.0

85
360
75
454
0
108

17.1
to 6. 5
14.3
7.7
0.4
0.12**
9.4
0.0

85
432
75
545
0
130

14.1

*   Approximately 1 dry ton/acre of this sludge will provide the
    crop's nitrogen and phosphorus needs.

**  0.12 Ibs Cd/acre is equivalent to 0.13 kg Cd/ha; maximum annual
    Cd application = 23 T/A to reach 0.5 kg Cd/ha in soil.
                                  19

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                            APPENDIX III

                             REFERENCES

EPA REGULATION AND GUIDANCE

0    "Criteria for Classifxcation of Solid Waste Disposal Facilities
     and Practices" (40 CFR Part 257), Federal Register,  September 13,
     1979.

0    "A Guide to Regulations and Guidance for the Utilization and
     Disposal of Municipal Sewage Sludge," EPA 430/9-80-015-MCD-72.

0    "Municipal Sludge Management - Environmental Factors,"
     EPA 430/9-77-004, MCD-28,  October 1977.

8    Sludge Treatment and Disposal, Volume II, October 1978.
     Technology Transfer (Design Seminar Series), EPA 625/4-78-012.

0    "Guidelines Establishing Test Procedures for the Analysis of
     Pollutants" (40 CFR Part 136).

USDA GUIDANCE

0    Utilizing Municipal Sewage Wastewaters and Sludges on Land for
     Agricultural Production.  North Central Regional Extension
     Publication No. 52.  November 1977.

0    Applications of Sludges and Wastewaters on Agricultural Land:
     A Planning and Educational Guide, March 1978.  North Central
     Research Publ. 235.  (Reprinted by EPA Office of Water Program
     Operations, MCD-35.)

0    Utilization of Wastes on Land:  Emphasis on Municipal Sludge,
     National Workshops.  Sponsored by USDA,  Anaheim, Calif.,
     Aug. 12-14, 1980.  (Unpublished report available from Hunter
     Follett, Dept. of Agronomy, Kansas State University, Manhattan,
     Kansas 66506.)

OTHER GUIDANCE

0    Miller, R. H.  The Ohio Farm Bureau Federation (OFBF) and
     research project on land application of municipal sewage
     sludges.  Proceedings of the Second Annual Conference of
     Applied Research and Practice on Municipal Industrial Waste.
     Madison, Wise., September 17-21, 1979.  321-333 p.

0    Ohio Guide for Land Application of Sewage Sludge Research
     Bulletin 1079  (revised), Ohio Agricultural Research and
     Development Center.  Bulletin 598  (revised), Cooperative
     Extension Service, Ohio State University.

0    Application of Sewage Sludge to Cropland: Appraisal of Potential
     Hazards of the Heavy Metals to Plants and Animals.  November 1976,
     Council for Agricultural Science & Technology, Report No. 64.
     EPA 430/9-76-013.

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                            APPENDIX IV




       EXAMPLE OF AN EVALUATION OF LONG-TERM SLUDGE BENEFITS






     Knowledge of sludge quality will allow an assessment of the




long-term consequences of sludge use.  If, for example, a sludge




which contains 5 percent available nitrogen and 2.5 percent




phosphorus is applied to a soil at rates which would supply either




the nitrogen or phosphorus requirements of the crop, compliance




with the Criteria regulations could easily be achieved (assuming a




high quality sludge with a cadmium concentration of 10 mg/kg, and




a lead concentration of 250 mg/kg).  If such a sludge were applied




at a rate of 1 dry metric ton per hectare (which would supply the




phosphorus requirements of most vegetable or fruit crops), or 4 dry




metric tons per hectare (which would supply the nitrogen require-




ments of most vegetable or fruit crops), the sludge could be used




on the same field for 125 to 500 years before reaching the Criteria




limitations on cumulative additions of cadmium, or the recommended




maximum cumulative additions of lead.  Although the cumulative




cadmium or lead application limits may eventually be reached, the




soil would remain suitable for the growth of all food-chain crops,




including fruits and vegetables, providing that no additional sludge




is used.
                                21

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