United States
Environmental Protection
Agency
Office of Water
(EN-336)
EPA 505/8-90-001
May 1990
xvEPA
Guidance For Writing
Case-By-Case
Permit Requirements For
Municipal Sewage Sludge
EPA/505/8-90/001
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EPA/505/8-90/001
May 1990
Guidance for Writing Case-by-Case
Permit Requirements for Municipal
Sewage Sludge
Office of Water Enforcement and Permits
U.S. Environmental Protection Agency
Washington, D.C. 20460
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Notice
This document has been reviewed in accordance with the U.S. Environmental Protection
Agency's peer and administrative review policies and approved for publication. Mention
of trade names or commercial products does not constitute endorsement or
recommendation for use.
11
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Contents
Tables vii
Figures ix
Acknowledgments x
Chapter 1 Introduction 1
1.1 Purpose and Use of this Guidance 1
1.2 History of Sludge Requirements in the Clean Water Act 2
1.3 Implementation of the Water Quality Act of 1987 3
1.3.1 Legal Basis for Interim Sludge Requirements 3
1.4 Permitting Requirements and Recommendations 5
1.5 Development of this Guidance 6
Chapter 2 Applicability of this Guidance 7
2.1 Facilities Covered 7
2.2 Facilities Not Covered 7
2.3 Practices Covered 8
2.3.1 Landfilling 8
2.3.2 Incineration 8
2.3.3 Surface Disposal 9
2.4 Practices Not Covered 9
2.4.1 Ocean Disposal 9
2.4.2 Sludge Storage 9
2.4.3 Sludge Treatment Processes 9
2.4.4 Septage Disposal 9
2.4.5 Disposal of Hazardous Waste 10
2.5 Relationship Between Sludge Permitting and the Pretreatment Program ... 10
Chapter 3 Overview of Sludge Treatment Processes and Their Effect on Sludge Properties .... 11
3.1 Introduction 11
3.2 Sludge Treatment Alternatives 11
3.2.1 Thickening 11
3.2.2 Stabilization 11
3.2.3 Conditioning 12
3.2.4 Dewatering 12
3.2.5 Composting 13
3.3 Pathogen Reduction 13
3.3.1 Processes to Significantly Reduce Pathogens (PSRP) 13
3.3.2 Processes to Further Reduce Pathogens (PFRP) 13
3.3.3 PSRP and PFRP Equivalency 15
3.4 Effect on Sludge Properties 15
Chapter 4 Summary of Permitting Procedures and Requirements 17
4.1 Gathering Information 17
4.2 Secondary Information Sources 17
4.3 Setting Priorities 19
4.4 Standard Permit Requirements 19
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4.4.1 General 19
4.4.2 Monitoring Requirements 20
4.5 Additional Permit Requirements for Class I POTWs 20
4.5.1 Case-by-Case Sludge Conditions 20
4.5.2 Case-by-Case Monitoring Requirements 20
Chapter 5 Landfilling 23
5.1 Introduction 23
5.1.1 Permitting Responsibilities 23
5.2 Technology Guidelines 25
5.2.1 Sludge-Only Monofills 25
5.2.2 Co-Disposal Landfills 26
5.3 Characteristics of Sludges Suitable for Landfilling 27
5.3.1 Sludge Pollutant Concentration Limits 27
5.3.2 Sludge Physical Properties 28
5.3.3 Landfilling of Sludges Containing Radionuclides 29
5.4 Operating Conditions and Management Practices 29
5.4.1 Endangered Species Protection 29
5.4.2 Floodplain Restrictions 29
5.4.3 Ground Water Protection 30
5.4.4 Surface Water Protection 33
5.4.5 Safety 34
5.4.6 Air Quality Control 35
5.4.7 Gas Control 35
5.4.8 Pathogen and Disease Control 36
5.4.9 Other State Management Practices 37
5.5 Monitoring, Reporting, and Record Keeping 37
5.5.1 Sludge Monitoring 37
5.5.2 Ground Water Monitoring 38
5.5.3 Gas Monitoring 39
5.5.4 Surface Water Monitoring 39
5.5.5 Monitoring for Hazardous Wastes 39
5.5.6 Reporting and Record Keeping 39
Chapter 6 Land Application 41
6.1 Introduction 41
6.1.1 Agricultural Utilization 41
6.1.2 Forest Utilization (Silviculture) 41
6.1.3 Land Reclamation 42
6.1.4 Dedicated Land Disposal 42
6.2 General Requirements and Guidance for All Forms of Land Application 43
6.2.1 Permitting Responsibilities 43
6.2.2 Characteristics of Sludges Suitable for Land Application 45
6.2.3 Operating Conditions and Management Practices 48
6.2.4 Monitoring, Reporting, and Record Keeping 53
6.3 Additional Requirements and Guidance for Agricultural Land
Application 59
6.3.1 Permitting Responsibilities 59
6.3.2 Technology 60
6.3.3 Characteristics of Sludge Suitable for Agricultural
Land Application 60
6.3.4 Operating Conditions and Management Practices 62
6.3.5 Additional Monitoring Considerations for Agricultural
Land Application 67
6.4 Additional Requirements and Guidance for Silvicultural (Forest Land)
Application 67
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6.4.1 Characteristics of Sludges Suitable for Silvicultural
Land Application 67
6.4.2 Operating Conditions and Management Practices for Silviculture .. 67
6.4.3 Additional Monitoring Considerations for Silviculture 68
6.5 Additional Requirements and Guidance for Land Reclamation 68
6.5.1 Characteristics of Sludges Suitable for Land Reclamation 69
6.5.2 Operating Conditions and Management Practices
for Land Reclamation 69
6.5.3 Additional Monitoring Considerations for Land Reclamation 71
6.6 Additional Requirements and Guidance for Dedicated Land Disposal 71
6.6.1 Permitting Responsibilities 71
6.6.2 Characteristics of Sludges Suitable for Dedicated Land Disposal ... 71
6.6.3 Operating Conditions and Management Practices
for Dedicated Land Disposal 72
6.6.4 Additional Monitoring Recommendations
for Dedicated Land Disposal 73
Chapter 7 Distribution and Marketing 75
7.1 Introduction 75
7.1.1 Permitting Responsibilities 75
7.2 Technology Guidelines 76
7.3 Characteristics of Sludges Suitable for Distribution and Marketing 78
7.3.1 Sludge Pollutant Concentration Limits 78
7.3.2 Physical Properties 81
7.4 Operating Conditions and Management Practices 81
7.4.1 Surface Water Protection 81
7.4.2 Ground Water Protection 81
7.4.3 Storage 81
7.4.4 Buffer Zones/Access Controls 82
7.4.5 Crop Use Limits 82
7.4.6 Other Conditions 82
7.5 Monitoring, Reporting, Record Keeping, and Labeling 82
7.5.1 Pollutant Concentration Monitoring 82
7.5.2 Treatment Process Monitoring 83
7.5.3 Soil Monitoring 83
7.5.4 Reporting and Record Keeping 84
7.5.5 Product Labeling 84
Chapter 8 Incineration 91
8.1 Introduction 91
8.1.1 Permitting Responsibilities 91
8.2 Incineration Technology 92
8.2.1 Definitions 92
8.3 Current Regulatory Requirements 93
8.3.1 New Source Performance Standards (NSPS) (40 CFR Part 60) 93
8.3.2 National Emissions Standards for Hazardous Air Pollutants
(NESHAPs) (40 CFR Part 61) 93
8.3.3 Toxic Substances Control Act (TSCA) 93
8.3.4 National Ambient Air Quality Standards (NAAQS) and State
Implementation Plan (SIPs) (40 CFR Part 50) 93
8.3.5 New Source Review Standards (NSRS) (40 CFR 51.160) 95
8.3.6 Prevention of Significant Deterioration (PSD)
(40 CFR 52.21) 95
8.4 Characteristics of Sludges Suitable for Incineration 95
8.4.1 Pollutant Concentration Limits for Sludge Feed and Air
Emissions 95
8.4.2 Sludge Physical Properties 98
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8.5 Operating Condition and Management Practices 99
8.5.1 General Operating Conditions and Management Practices 99
8.5.2 Operating Guidelines for Specific Incineration Technologies 102
8.5.3 Guidelines for Pollution Control Systems 103
8.6 Monitoring, Reporting, and Record Keeping 104
8.6.1 Monitoring 104
8.6.2 Reporting and Record Keeping 106
Chapter 9 Surface Disposal 109
9.1 Introduction 109
9.2 Characteristics of Sludges Suitable for Surface Disposal 109
9.2.1 Sludge Pollutant Concentration Limits 109
9.2.2 Sludge Physical Properties 110
9.3 Operating Conditions and Management Practices 110
9.3.1 Floodplain Restrictions 110
9.3.2 Surface Water Protection Ill
9.3.3 Ground Water Protection Ill
9.3.4 Buffer Zones 112
9.3.5 Access Control 112
9.3.6 Pathogen and Disease Control 113
9.3.7 Air Quality Control 113
9.3.8 Endangered Species Protection 113
9.3.9 Explosive Gases 113
9.3.10 Other Sludge Lagoon Restrictions 113
9.4 Monitoring, Reporting, and Record Keeping 114
9.4.1 Monitoring 114
9.4.2 Reporting and Record Keeping 114
Appendix A Sewage Sludge Interim Permitting Strategy 115
Appendix B Regional and State Air, Solid Waste, Ground Water,
and Sludge Contacts 141
Appendix C Distribution and Marketing Labels and Instructions 145
Appendix D 40 CFR 257 - Criteria for Classification of Solid Waste Disposal Facilities
and Practices 159
Appendix E State Requirements and Guidance for Sludge Use and Disposal 169
VI
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Tables
1-1 Sludge Management Regulations of the Environmental Protection Agency 4
1-2 Pollutants Specifically Addressed in this Guidance 5
3-1 Increased Metals Concentration During Processing (mg/kg dry weight) 15
4-1 Information Gathering for Writing Sludge Conditions 18
5-1 40 CFR Part 257 Required Management Practices for Sludge-Only
and Co-Disposal Landfills, Land Application Sites, and Sludge
Lagoons and Stockpiles 24
5-2 Maximum Concentrations for Contaminants Analyzed for EP Toxicity
and TCLP Tests 40
6-1 40 CFR Part 257 Pathogen Reduction Requirements for Land
Application and Distribution and Marketing of Sludges 46
6-2 Half-Life of Radionuclides Identified in POTW Sludges 48
6-3 Sample Calculation for Sludges that Contain Radium 49
6-4 Recommended Slope Limitations for Land Application of Sludge 53
6-5 Sludge Monitoring Programs for Two Agricultural Land Applications 54
6-6 Soil Monitoring Programs for Two Agricultural Land Application Operations 56
6-7 Potential Crop Monitoring Parameters 56
6-8 40 CFR 257.3-5 Contaminant Limits for Sludge Used
on Food-Chain Croplands 59
6-9 Maximum Permissible Cumulative Cadmium Application to a Land
Application Site Used to Produce Food-Chain Crops 60
6-10 Summary of Current State Annual Contaminant Application Rates
for Land Application 61
6-11 Summary of Current State Cumulative Contaminant Application Rates
for Land Application 61
6-12 Maximum Metal Application (kg/ha) for Unamended Soil at Indicated
Soil Cation Exchange Capacity (CEC) 62
6-13 Years of Application for Cadmium and Nickel 63
6-14 Years of Application for Copper, Lead, and Zinc 64
6-15 Relative Accumulation of Cadmium into Edible Plant Parts
by Different Crops 65
6-16 Recommended Distance to Surface Waters for Agricultural Land Application 65
6-17 General Guide to Months Available for Sludge Application
to Different Crops in North Central States 66
6-18 Recommended Distances to Surface Water for Silvicultural Applications 68
6-19 State Sludge Contaminant Concentration Limits for Land Reclamation 69
6-20 State Regulations for Annual and Cumulative Application
Rates and Variances for Land Reclamation 70
7-1 Incremental Index Values of Toxicity to Humans 79
7-2 Maximum Metal Application (kg/ha) for Unamended Soil
at Indicated Soil Cation Exchange Capacity (CEC) 80
7-3 Summary of Current State Sludge Contaminant Limits
for Distribution and Marketing 80
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7-4 Years of Application in SI Units for Cadmium and Nickel 85
7-5 Years of Application in SI Units for Copper, Lead, and Zinc 86
7-6 Years of Application in English Units for Cadmium and Nickel 87
7-7 Years of Application in English Units for Copper, Lead, and Zinc 88
7-8 Sample Calculations for Years of Application 89
8-1 National Ambient Air Quality Standards 94
8-2 Health Effects of Air Pollutants 94
8-3 Levels of Net Emissions Increase that Qualify as Major Modifications
Requiring PSD Review 95
8-4 Federal Concentration Units for Contaminants 96
8-5 Summary of Suggested Incinerator Operating Guidelines 101
8-6 Prohibited Sludge Incineration Practices 102
Vlll
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Figures
3-1 Typical sludge treatment trains 14
6-1 Example land application program contract 44
9-1 Comparison of wastewater lagoon and sludge lagoon 110
IX
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Acknowledgments
The Guidance for Writing Case-by-Case Permit Requirements for Municipal Sewage
Sludge was prepared by U.S. EPA's Office of Water Enforcement and Permits with the
assistance of Camp, Dresser & McKee Inc. The principal U.S. EPA authors were Tom
Wall, Martha Segall, Greg McBrien, Debora Clovis, Cristina Morrison, Robert Goo, John
Melby and Catherine Crane. The principal Camp Dresser & McKee authors were Chris
Clarkson, Tom Broderick, Joe Wiseman, Bill Dowbiggin, and Anne Cole. SAIC authors
were Mary Waldron and Susan Moore. Stuart Miner, Claire Gesalman, Joe Spollen,
Mary Hobson and Flaminia Mangone of Roy F. Weston, Inc. developed the information on
State sludge use and disposal requirements.
Comments on a previous draft of this document were provided by EPA's Sludge
Permitting Workgroup. These reviewers included EPA Regions, a number of states,
EPA's Office of Research and Development, and representatives of a number of EPA
Headquarters Offices with an interest in sludge use and disposal. The efforts of these
reviewers are greatly appreciated. In particular, we want to thank Bob Bastian, Al
Rubin, Joe Farrell, and Chuck Henry for their generous contributions. We would also
like to thank those who commented on the September 1988 draft.
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Chapter 1
Introduction
1.1 Purpose and Use of this Guidance
Section 405 of the Clean Water Act (referred to as the
Act) requires that EPA regulate the use and disposal
of sewage sludge to protect public health and the
environment from any reasonably anticipated
adverse effects of these practices. In the Act,
Congress directs EPA to develop technical standards
for sludge use and disposal options and to incorporate
these standards into National Pollutant Discharge
Elimination System (NPDES) permits issued to
Publicly Owned Treatment Works (POTWs) under
Section 402 of the Act. EPA has proposed an initial
round of technical sludge standards (40 CFR Part
503) which are expected to be promulgated in 1991.
Congress also specified that sewage sludge use and
disposal practices be regulated immediately. This
mandate initiated EPA's development of an interim
program (Sewage Sludge Interim Permitting
Strategy) to control sludge use and disposal until all
the necessary regulations are completed.
The purpose of this guidance document is to provide
technical information and assistance to EPA permit
writers in developing interim sludge requirements on
a case-by-case basis. The guidance provides
information on existing regulations for use in
developing sludge permit conditions. It also
recommends additional permit conditions that are
based on current federal guidance as well as State
requirements and/or recommendations. Permit
writers may consider including these additional
conditions in permits on a case-by-case basis
exercising their best professional judgment (BPJ).
Separate chapters (5-9) address each major sludge
use or disposal option and summarize all federal and
State requirements as well as recommendations. This
guidance document also describes monitoring and
reporting requirements as well as standard permit
conditions for inclusion in all new or reissued POTW
permits. Although this guidance document is
addressed to EPA permit writers, the information it
contains should also be useful to State permit writers
for developing sludge permit conditions and
identifying potential sludge use or disposal problems.
EPA intends this guidance to serve as the primary
reference for writing interim, case-by-case sludge
requirements for POTWs. The need for writing
interim sludge requirements will continue until final
promulgation of applicable technical sludge
standards at 40 CFR Part 503. Even after
promulgation of the standards, BPJ limits may be
needed to address pollutants or management
practices of concern at a particular POTW that are
not addressed in the technical standards. In addition,
the first round of technical standards may not
address the disposal option employed by a particular
POTW. For example, sludge lagoons and other
methods of surface disposal where sludge is retained
for less than a year, which are addressed in Chapter 9
of this guidance, were not covered in the first round of
technical standards as proposed. For these situations,
this guidance will continue to be useful for permit
writers.
The recommendations contained in this manual have
been carefully reviewed for consistency with the
forthcoming technical regulations (40 CFR Part 503).
This guidance is intended to help the permit writer
identify and address, through permits, existing or
potential problems with sludge use or disposal, in the
absence of promulgated technical standards. The
guidance is not intended to supplant the 40 CFR Part
503 standards or implement them before they are
final. In developing permit limits for POTWs in the
interim, the primary source of information for permit
writers should be the Case-by-Case Guidance.
Information from other sources, of course, may be
considered and evaluated by the permit writer in the
exercise of his or her best professional judgment.
The proposed 40 CFR Part 503 standards are
currently undergoing revision in response to the
public comments received and peer review
undertaken during the 180 day comment period.
These inputs, as well as the results of the National
Sewage Sludge Survey, may result in final standards
that are significantly different from the proposal. In
light of these circumstances, reliance on the proposed
standards should be limited. Permit writers should
not rely on the proposed numeric limits in 40 CFR
Part 503 in developing case-by-case sludge conditions
unless they can establish independently the
appropriateness of such conditions based on the
circumstances of the particular sludge practice at
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issue. Any sludge conditions other than those based
on existing regulations must have a sound technical
basis that is explained in the permit's fact sheet.
Under the Sewage Sludge Interim Permitting
Strategy, EPA may defer to State implementation of
the Interim Strategy pursuant to a State/EPA
agreement. When a State has assumed responsibility
for implementation of sludge requirements, EPA
must review and approve permit conditions for those
POTWs which are considered permitting priorities.
This guidance document can be used by EPA
Regional Offices for that purpose and, where
appropriate, to develop supplemental requirements.
(See "Sewage Sludge Interim Permitting Strategy" in
Appendix A for a fuller explanation of the procedures
for coordinating State/EPA permitting activities.)
Because of the multi-media impacts of sludge
disposal and a history of a fragmented approach to
sludge regulation, writing interim sludge limits will
require a great deal of coordination among EPA
offices and between EPA and the States. For
example, determining appropriate permit conditions
for incinerators will require cooperation and support
from EPA and State air program officials. Similarly,
determining what conditions to place in a permit for
a POTW that disposes of its sludge in a landfill will
require cooperation and support from EPA and State
solid waste programs. This guidance document
provides guidance on how, when, and with whom to
coordinate (see Appendix B for contacts in State and
Regional solid waste and air program offices).
1.2 History of Sludge Requirements in
the Clean Water Act
Over the past 15 years, Congressional concern with
the proper use and disposal of sewage sludge has led
to increased attention in the Clean Water Act
("CWA"). In the Federal Water Pollution Control Act
Amendments of 1972, Congress prohibited the
disposal of sewage sludge to navigable waters
without a permit (Section 405). It also directed EPA
to issue regulations governing the issuance of
permits that would apply "each criterion, factor,
procedure, and requirement applicable to a permit
issued under Section 402 [NPDES]...." Thus, initially
Congress provided for the regulation of sewage
sludge in the same manner as other pollutant
discharges to navigable waters.
In the 1977 amendments to the CWA, Congress
expanded its concern about sewage sludge disposal
beyond discharges to navigable waters. The focus of
these amendments was to encourage the beneficial
use of sludge, i.e., to treat the growing amounts of
sewage sludge as a resource rather than a disposal
problem. To this end, Congress directed EPA in
Section 405(d) of the CWA to issue regulations that
would identify: 1) use and disposal options; 2) factors
to be taken into account in determining the measures
and practices applicable to each option; and 3)
concentrations of pollutants in the sludge that
interfere with each option.
The 1977 amendments prohibited POTWs from
disposing of sewage sludge by any method for which
Section 405 standards were established unless in
compliance with such standards, but did not require
that the standards be implemented through federally
enforceable permits. In an amendment to Section
307(b), Congress also explicitly linked sewage sludge
disposal to the pretreatment program by allowing for
removal credits (i.e., credits given to industrial users
for pollutant removals achieved by the POTW) for
toxic pollutants treated by a POTW, although credits
could be granted only if this would not result in
violation of the sewage sludge use and disposal
requirements under Section 405. (See Section 54 of
the CWA of 1977, P.L. 95-217.)
The sludge use and disposal standards envisioned in
the 1977 amendments to the CWA led to the
promulgation of 40 CFR Part 257 (under the joint
authority of the CWA and the Resource Conservation
and Recovery Act). 40 CFR Part 257 (see Appendix D)
established standards for cadmium, PCBs, and
pathogens in sludge applied to land and established
general management standards for solid waste
landfills. Currently, these are the only sludge
disposal standards promulgated under the authority
of Section 405(d) of the CWA. (Other regulations
promulgated by EPA, however, govern various
aspects of sewage sludge disposal. These are
described in Chapter 2.)
With the passage of the Water Quality Act of 1987
(P.L. 100-4) ("WQA"), Congress reaffirmed its intent
to have EPA comprehensively regulate the use and
disposal of sewage sludge. Congress again called for
the promulgation of technical standards, and in
Section 405(d)(2) placed new emphasis on identifying
and limiting those toxic pollutants in sewage sludge
that may adversely affect public health or the
environment. It also enacted strict deadlines for
compliance with these standards: within one year of
promulgation unless construction of new pollution
control facilities is necessary, in which case
compliance is required within two years. Congress
further required that EPA implement the technical
standards through NPDES permits issued to POTWs
and other treatment works treating domestic sewage
unless the standards were already included in a
permit issued under other federal programs listed in
Section 405(f)(D or under State programs approved
by EPA as adequate to ensure compliance with
Section 405. Congress also directed EPA to begin
immediate regulation of sewage sludge use and
disposal. The 1987 amendments state that:
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Prior to the promulgation of the regulations
required by paragraph (2) [technical standards],
the Administrator shall impose conditions in
permits issued to publicly owned treatment
works under Section 402 of this Act or take such
other measures as the Administrator deems
appropriate to protect public health and the
environment from any adverse effects which may
occur from toxic pollutants in sewage sludge.
[Section 405(d)(4) of CWA added by the WQA of
1987.]
Thus, even before promulgation of the technical
standards, EPA must begin to address sewage sludge
use and disposal in NPDES permits issued to
POTWs. It must also identify other measures that
may be appropriate to ensure environmentally sound
sludge disposal practices.
1.3 Implementation of the Water Quality
Act of 1987
EPA activities to fulfill the Congressional mandate
under Section 405 can be divided into two parts. One
part involves the development of technical standards
to regulate sewage sludge use and disposal and the
other involves the establishment of administrative
procedures for incorporating these technical
standards into permits.
Recent activities to establish technical standards
have resulted in the proposal of two new regulatory
packages. In 1988, EPA's Office of Solid Waste
proposed new regulations (40 CFR Part 258) for
operation and maintenance of municipal landfills
which would cover co-disposal of sewage sludge with
municipal solid waste. In 1989, EPA's Office of Water
Regulations and Standards proposed regulations (40
CFR Part 503) which identify sludge quality
requirements as well as management practices for
sewage sludge use or disposal by means of land
application, distribution and marketing, sludge-only
monofills, incinerators, and surface impoundments.
To provide a mechanism for including the technical
limits in permits, EPA promulgated regulations
designed to incorporate sewage sludge use and
disposal requirements into permits as required under
Section 405(d) of the Clean Water Act. On May 2,
1989, (published at 54 FR 18716), EPA issued final
revisions to the regulations contained in 40 CFR
Parts 122 and 124 which identify permit
requirements under Section 402 of the Clean Water
Act. These regulations require inclusion of sludge
conditions in National Pollutant Discharge
Elimination System (NPDES) permits issued to
municipal sewage treatment works. The regulations
also authorize issuance of permits to facilities which
do not discharge wastewater under the NPDES
program. In general, these regulations, which
already addressed discharges of water, were
expanded to cover the sludge generated as a by-
product of wastewater treatment operations.
EPA also promulgated regulations for State sludge
management programs (40 CFR Parts 501 and 123)
(published at 54 FR 18716; May 2, 1989). These
regulations specify procedures for States to receive
approval to implement sludge management
programs in lieu of the federal program. In order to
receive program approval, a State must demonstrate
adequate legal authority and administrative
procedures to issue permits and determine
compliance with and enforce federal and State
sewage sludge regulations and requirements.
To carry out the congressional directive to take
immediate steps before promulgation of technical
regulations, EPA has developed a "Sewage Sludge
Interim Permitting Strategy" (1989) (see Appendix
A). EPA's Interim Permitting Strategy: 1) discusses
the identification of permitting priorities; 2)
identifies minimum permit requirements; and 3)
describes how EPA and the States will coordinate
interim permitting and other activities. The major
goal of the interim program is to identify and control
known or potential problem facilities and target
these facilities for more site-specific permit
requirements, thereby facilitating compliance with
the technical standards once promulgated. This will
be accomplished by: 1) ensuring that all NPDES
permits issued or reissued to POTWs after February
4, 1987 contain certain minimum conditions,
including a requirement that the permittee comply
with all existing federal regulations governing the
use and disposal of sewage sludge, and with
applicable 40 CFR Part 503 technical standards
when promulgated; 2) requiring POTWs to perform
sludge monitoring and reporting; and 3) providing
case-by-case permit conditions for POTWs which
have been identified as a priority for sludge
permitting (i.e., pretreatment POTWs and POTWs
whose sludge or sludge use and disposal practices
have the potential to adversely affect the public
health and environment).
1.3.1 Legal Basis for Interim Sludge
Requirements
EPA's legal authority to include sludge requirements
in NPDES permits for POTWs before promulgation of
technical standards comes directly from Section
405(d)(4) of the CWA. As explained in the previous
section, Congress clearly intended that EPA begin
regulating sewage sludge use and disposal
immediately, prior to and in the absence of
promulgated technical standards. Also, as noted
throughout this chapter, EPA's authority to take
interim measures is very broad and includes taking
any measure "the Administrator deems appropriate
to protect public health and the environment from
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any adverse effects which may occur from toxic
pollutants in sewage sludge." Thus, EPA has a
responsibility to identify and address problems
caused by contaminated sludge or poor disposal
practices. EPA's authority under Section 405(d)(4) is
flexible enough to address known problems with
sewage sludge use or disposal that may fall outside
the core objective to include interim sludge limits in
new or reissued POTW permits. For example, this
authority allows the modification of existing permits
to address sludge disposal problems.
Where existing federal regulations apply to a
particular sewage sludge use or disposal practice,
Section 405(d)(4) of the CWA gives EPA the
authority to implement the requirements through
NPDES permit conditions (which may simply be a
matter of incorporating those requirements by
reference). In addition, 40 CFR 122.44(b)(2) requires
that permits include standards under Section 405(d).
(This means that the 40 CFR Part 257 requirements,
which were promulgated under the joint authority of
RCRA and Section 405 of the CWA, are to be
implemented through NPDES permits unless
sufficiently covered in another permit.)
In addition to the Clean Water Act, there are several
other federal laws that provide authority for
regulating various aspects of sewage sludge disposal.
These include the Clean Air Act (CAA); Subtitles C
and D of the Resource Conservation and Recovery Act
(RCRA); the Marine Protection, Research, and
Sanctuaries Act (MPRSA); and the Toxic Substances
Control Act (TSCA). POTWs already are under an
obligation to comply with existing federal
regulations. Nevertheless, placing federal
regulations in the POTW's NPDES permit reinforces
the importance of compliance for purposes of the
Clean Water Act and helps to ensure that sludge
disposal practices will not threaten public health and
the environment. It also provides a more direct link
to pretreatment controls which are an important
means of improving sludge quality. Table 1-1 lists
current federal regulations that directly apply to
sludge use and disposal. Permit writers should
consult with the program offices responsible for
implementing these programs to see if NPDES
permit conditions aimed at improving sludge quality
and disposal practices would help ensure compliance
with the existing requirements.
By providing for interim sludge permit conditions
before promulgation of the technical standards,
Congress clearly indicated that reliance on the status
quo would be insufficient. For most priority POTWs,
existing federal requirements will not be enough to
provide for protection of public health and the
environment. Where permit conditions based on
existing regulations are insufficient to protect public
health and the environment from adverse effects that
may occur from toxic pollutants in sewage sludge,
Table 1-1
Coverage
Sludge Management Regulations of the
Environmental Protection Agency
Reference
Application
Polychlonnated 40 CFR Part 761
Biphenyls (PCBs)
Ocean Dumping 40 CFR Part 220-
228
New Sources of
Air Emissions1
40 CFR Part 60
NESHAPs: Mercury 40 CFR Part 61
and Beryllium
Cadmium, PCBs, 40 CFR Part 257
Pathogenic
Organisms
Extraction 40 CFR Part 261
Procedure Toxicity3 Appendix II
All sludges containing
more than 50
milligrams per kilogram
The discharge of
sludge from barges or
other vessels
Incineration of sludge
at rates above 1,000
kilograms per day
Incineration and heat
drying of sludge
Land application
(including distribution
and marketing) of
sludge, landfills,2
storage lagoons
Defines whether
sludges are hazardous
Source: Use and Disposal of Municipal Wastewater Sludge
(EPA 1984).
1 Revisions to this part were final on October 6, 1988, (53 FR
39412). Additional limits on air emissions may apply to particular
facilities based on a State Implementation Plan (SIP). SIPs are
codified at 40 CFR Part 52. Other air regulatory programs that
may limit emissions include National Ambient Air Quality
Standards (NAAQS) (40 CFR Part 50), New Source Review
Standards (40 CFR 51.160) and Prevention of Significant
Deterioration (PSD) (40 CFR 52.21).
2 Municipal Solid Waste Landfills will be regulated under 40 CFR
Part 258 when regulations are promulgated late in 1990.
3 The EP toxicity test will be replaced by the TCLP test effective
September 25, 1990, (55 FR 11798, March 29, 1990). See
Chapter 5 for a discussion.
permit conditions should be developed on a case-by-
case basis using best professional judgment ("BPJ")
to fulfill the statutory standard.
Using best professional judgment to develop interim
sludge requirements follows the same general
principles used in developing best professional
judgment effluent limits in NPDES permits. Permit
conditions developed using BPJ are based on the
sound technical opinion of the permit writer after
consideration of all reasonably available and
pertinent data or information. Unlike the
technology-based BPJ effluent limits governed by the
criteria in 40 CFR Part 125.3(c), however, BPJ sludge
limits are health-based, i.e., designed to protect
public health and the environment from the adverse
effects of toxic pollutants in sewage sludge.
While BPJ authority gives the permit writer
considerable flexibility in developing sludge
requirements on a case-by-case basis, it also places a
burden on him or her to show that the permit
conditions are based on a sound technical analysis
and designed to protect public health and the
environment. Like other permit conditions, interim
sludge requirements may be subject to legal
-------
challenge; therefore, the need for the permit
condition and the basis for its establishment should
be clearly defined and documented (e.g., in the fact
sheet for the permit).
1.4 Permitting Requirements and
Recommendations
This guidance sets forth the existing federal
requirements in each of the major sludge use and
disposal practices. However, for many disposal
options or situations, federal requirements have not
been promulgated. Therefore, this guidance also
includes recommendations for each disposal practice.
These recommendations are provided to assist permit
writers in developing contaminant limits and
management practice requirements on a case-by-case
basis to protect public health and the environment
from adverse effects that may occur from toxic
pollutants in sewage sludge. Recommended
contaminant limits and management practices are
based on federal guidance and/or widely applied State
requirements or guidelines. Specific recommenda-
tions based on State regulations or guidelines alone
were adopted after consideration by a work group and
in response to comments received from outside
parties.
Table 1-2 lists all pollutants for which federal or
State limits or guidance have been identified for
sludge use or disposal. Limits are not recommended
for all these pollutants. It is also important to note
that permit writers are not restricted to addressing
these pollutants in writing BPJ limits. If a particular
pollutant is causing or threatening to cause a
disposal problem, the permit writer may place a limit
for it in the permit. As a general rule, only pollutants
of concern (i.e., those which exceed or potentially
exceed the level appropriate to protect public health
and the environment), whether addressed in federal
or State guidance or regulations, should be limited in
the permit.
Table 1-2 (Continued)
Federal
Regula-
Pollutant lion
Cobalt
Copper X4
Cyanide
2,4-0
f\ r\ r\ tr\ r\ c tr\ rvr
DDD/DDE/DDT
Dieldrin
Dimethyl-nitrosamme
Dioxin
Endnn
Fluoride
Heptachlor
Heptachlor Epoxide
Iron
Lead
Lindane
Lithium
Manganese
Mercury X"
Methoxychlor
Mirex
Molybdenum
Nickel X4
Nitrogen Compounds X8
Nitrates
Oil & Grease
Organics
Phenols
Pesticides
Phosphorus
Potassium
PCBs X?.9
Radium
Radon
Selenium X4
Silver
Silvex
Sodium
Total Hydrocarbons
Total Org. Carbon
Toxaphene
Trichloroethylene
Uranium
Vinyl Chloride
Zinc X4
Federal
Guidance
X
X3
X5
X5
X5
X2
X,X5
X5
XX5
X5
X
X2
X5
X2
X
X,X5
X
X5
X5
X5
X1
X5
X
X
State
Require-
ments
X
X
X3
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
x
X
X3
X
X
X
* In addition, pathogen reduction standards will
application and to distribution
503
Proposed
X
X
X
X
X
X
X
x
X
X
X
x
X
X
X
X
apply to land
and marketing. See 40 CFR Part
Table 1-2
Pollutants* Specifically Addressed in this
Guidance
Pollutant
Aldrin
Aluminum
Arsenic
Barium
Benzene
Benzo(a)-pyrene
Beryllium
Bis(2-ethyl-hexyl)-
phthalate
Boron
Cadmium
Carbon Monoxide
Chlordane
Chlorine
Chromium
Federal
Regula-
tion
X4
X6
X4.9
X8
X4
State
Federal Require-
Guidance ments
X
X
X5 X
X5 X
X
X
X
X5 X
X
X
X1
X» X
503
Proposed
X
X
X
X
X
X
X
X
X
257, Appendix II.
1 Process Design Manual for Municipal Sludge Landfills (EPA
1978) recommends monitoring for these parameters at landfills.
2 Process Design Manual for Land Application of Municipal
Sludge (EPA 1983) recommends monitoring for these parameters
at land application sites.
3 State monitoring and reporting requirements for sludge and
compost (EPA 1987).
4 Final revisions to the New Source Performance Standards for
Sewage Sludge Incinerators (40 CFR 60.150 (53 FR 39412))
require initial testing for these metals.
s Maximum Groundwater Contaminant Limits from 40 CFR Part
257 are found in Appendix C. Appendix C also provides maximum
contaminant limits for coliform bacteria, radium-226, and gross
alpha radiation.
6 National Emission Standards for Hazardous Air Pollutants
(NESHAP) (40 CFR Part 61).
7 Sewage sludge containing over 50 mg/kg PCBs must comply with
TSCA(40CFR Part 761).
s National Ambient Air Quality Standards (NAAQS) (40 CFR Part
50).
9 40 CFR Part 257.
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Generally, EPA permit writers should also include
any applicable State requirements, unless they are
less stringent than what is required by federal
regulation (since federal requirements must be
included as a minimum). This will help minimize
disruption to existing State programs, especially
during the interim phase of implementing Section
405. Again, the permit writer should use best
professional judgment in applying State require-
ments and recommendations. While incorporation of
State requirements would be appropriate in most
cases, permit writers should do as much as possible to
ensure that requirements they adopt can be
reasonably defended.
1.5 Development of this Guidance
The Office of Water Enforcement and Permits
(OWEP) formed a Workgroup on Sludge Permitting
Issues to assist in developing policy and guidance
materials. The Workgroup included representatives
from: EPA Headquarters offices with experience in
regulating or providing guidance on sludge use and
disposal (including the Office of Water Regulations
and Standards (OWRS), Office of Municipal Pollution
Control (OMPC), Office of Research and
Development (ORD), Office of Solid Waste and
Emergency Response (OSWER), and other offices);
all 10 EPA Regional Offices; and several States (New
Jersey, Iowa, Wisconsin, Connecticut, Missouri,
California, and Kansas). The Workgroup reviewed
and commented on drafts of policy and guidance and
participated in key early decisions about such issues
as permitting priorities, appropriate monitoring and
other permit requirements for non-Class I POTWs,
and the basis for developing technical guidance for
writing interim limits.
With assistance from OMPC and EPA Regional
Offices, OWEP gathered and summarized
information on the technical requirements and
guidelines of State sludge programs for use in this
guidance. Upon distribution of the draft guidance in
September 1988, States were asked to review
information and submit any revisions or corrections
to OWEP. Appendix E presents the summaries that
were revised to reflect this new information. These
tables are designed for quick reference and to direct
permit writers to the source of State information.
Appendix E reflects the fact that it was not always
possible to distinguish between requirements and
recommendations. The permit writer should be
aware of this and should consult with State officials
during the course of a permit's development or review
to clarify and distinguish State requirements from
State recommendations.
Similar efforts were undertaken to summarize
current federal requirements and guidance and
summarize other technical literature on sludge use
and disposal. Based on the data collected, OWEP
developed draft permitting requirements and
recommendations. These were reviewed by and
discussed with staff in OSWER, the Office of Air and
Radiation (OAR), the Air Enforcement Division of
the Office of Enforcement and Compliance Monitor-
ing (OECM), OMPC, and OWRS to ensure
consistency with requirements of other EPA program
offices and with the forthcoming proposed technical
standards under Section 405(d). OWEP then
submitted a draft of this guidance document to the
Workgroup for review and comment. EPA released
the guidance in draft final form in September 1988 to
States, Regions and interested parties for use in
writing POTW permits. The present guidance has
been revised in response to comments received on the
draft guidance.
References
EPA 1978. Process Design Manual for Municipal
Sludge Landfills. U.S. Environmental Protection
Agency, EPA-625/1-78-010, October 1978.
EPA 1983. Process Design Manual for Land
Application of Municipal Sludge, U.S.
Environmental Protection Agency, EPA-625/1-83-
016, October 1983.
EPA 1984. Use and Disposal of Municipal
Wastewater Sludge. U.S. Environmental Protection
Agency, EPA 625/10-84-003, September 1984.
EPA 1987. State Requirements for Sludge
Management, U.S. Environmental Protection
Agency, Office of Municipal Pollution Control and
Office of Water Enforcement and Permits,
Washington, D.C., 1987 (Revised 1989).
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Chapter 2
Applicability of this Guidance
This chapter explains the scope of this guidance
document and EPA's Sewage Sludge Interim
Permitting Strategy. It also refers permit writers to
other guidance documents that might be useful for
addressing specific problems not covered by this
guidance. In addition, it provides information on
coordinating with other offices on the development of
permit conditions when the publicly owned
treatment works' (POTW's) sludge use or disposal
practice may already be regulated under other
programs. Finally, it explains the relationship
between sludge permitting and the pretreatment
program.
2.1 Facilities Covered
Based on the language of Section 405(d)(4) of the
Clean Water Act (CWA), EPA's Interim Permitting
Strategy focuses on POTWs with National Pollutant
Discharge Elimination System (NPDES) permits.
Certain minimum requirements, such as compliance
and notice provisions and monitoring requirements,
apply to all new and reissued permits for POTWs.
(See Chapter Four and Appendix A). Ideally, permit
writers should evaluate the need for sludge require-
ments in all NPDES permits issued to POTWs. How-
ever, in the face of limited resources, EPA has
identified a subset of all NPDES POTWs which need
to be targeted for more comprehensive permit cover-
age. The Interim Permitting Strategy calls this group
of POTWs "Class I sludge management facilities"
(this term is synonymous with the "priority" POTW
designation used in the earlier draft of the Interim
Permitting Strategy).
Class I facilities are: all POTWs that are required to
have an approved pretreatment program, any other
facility with known or suspected sludge problems,
and any POTWs using sludge incineration unless
evidence exists to demonstrate absence of existing or
potential problems (see Part III, Sewage Sludge
Interim Permitting Strategy in Appendix A for
discussion of "Class I" POTWs). These facilities will
need additional case-by-case sludge conditions unless
the permitting authority determines, based on
information about the facility's sludge quality and
use or disposal practices, that the sludge is already
adequately controlled. This guidance is primarily
directed to the Class I sludge management facilities .
2.2 Facilities Not Covered
The following types of facilities are not covered by the
Interim Permitting Strategy: non-NPDES POTWs
(i.e., POTWs that do not discharge their effluent to
surface waters), federal facilities, sewage sludge
treatment or disposal facilities that are not connected
to wastewater treatment works, privately owned
sewage treatment works (including individual septic
systems and septage treatment facilities where
septage is trucked in, treated, then land applied), and
industrial facilities that treat domestic sewage as
part of their wastewater treatment activities.
However, these other facilities may cause adverse
effects to public health or the environment through
sludge use or disposal practices. The CWA provides
EPA with broad authority to take interim measures
to address environmental or public health problems
created by sludge quality or practices at these other
facilities. Permit writers should be mindful of the
potential need for greater control at these other
facilities and may use this guidance where appro-
priate to address public health and environmental
concerns in a permit.
This guidance document focuses primarily on sewage
sludge generators, i.e., POTWs. However, effective
regulation of sewage sludge to prevent adverse
environmental or public health effects may require
controls at the ultimate disposal site as well. Permit
conditions that address both aspects of sewage sludge
control can be developed when the POTW controls
both generation and disposal of sewage sludge. A
POTW that generates sludge, but is not the end user
or disposer of the sludge presents a more difficult
situation since the POTW may not be able to easily or
effectively ensure compliance with use or disposal
requirements placed on the end users. For example,
this could occur when a small POTW transports its
sludge to an incinerator owned and operated by
another POTW, or when a POTW sends its sludge to a
privately owned solid waste landfill.
Since the technical standards authorized by Section
405(d) of the CWA will apply to users and disposers of
-------
sewage sludge as well as generators, determining
how best to regulate end users that are not also
generators is a significant issue. As a general rule,
this guidance recommends that the less control the
POTW or permit authority has over the end use, the
more stringent should be the permit requirements
regulating sludge quality. As reflected in the
recommendations in this guidance, permit conditions
can be developed and applied to a POTW to help
assure compliance with use and disposal
requirements by end users. For example, POTWs can
be required to label sludge products to inform the
user of safe use practices and limitations that apply
to use of the product. In addition, the permit can
prohibit the POTW from disposing of its sludge at a
facility not in compliance with applicable federal
requirements (e.g., a landfill that does not comply
with 40 CFR Part 257). EPA does not plan to institute
a widespread regulatory program for end users as
part of its Interim Permitting Strategy. However, if
problems due to the misuse of sludge by end users
occur and they cannot be addressed through POTW
permit conditions, the Regions should use their
authority under Section 405(d)(4) of the CWA to take
action to address the problem.
requirements (e.g., 40 CFR Part 257) and is not
endangering public health and the environment. As a
general rule, this guidance recommends allocating
responsibility for regulating landfilled sludge
(through permit conditions or enforcement actions)
based on the relative proportion of sludge in the
landfill. Thus, when a POTW uses a sludge-only
landfill (monofill) for disposal, the POTW permit
writer would determine appropriate permit
conditions to prevent the landfill from harming
public health or the environment. If the POTW sends
its sludge to a landfill that accepts wastes other than
sewage sludge (co-disposal), the permit writer should
consult with the appropriate solid waste office on
necessary measures when the sludge is a large
proportion of the landfill (e.g., more than 30 percent)
and generally defer to the solid waste office if the
sludge is only a small proportion of the landfill's
volume (e.g., under 30 percent). These guidelines are
intended to prevent duplication of effort while
making sure that NPDES permit writers fulfill their
responsibility under the CWA to take measures to
protect public health and the environment from
problems caused by sludge disposal.
2.3 Practices Covered
This guidance document addresses five sludge use
and/or disposal methods, each the subject of a
separate chapter:
• Landfilling (Chapter 5);
• Land application (Chapter 6);
• Distribution and marketing (Chapter 7);
• Incineration (Chapter 8); and
• Surface disposal (Chapter 9).
The disposal methods of landfilling, incineration and
surface disposal require further explanation to define
how these practices are specifically addressed by this
guidance. An explanation of each is provided below.
2.3.1 Landfilling
Guidance in Chapter 5 includes information on two
types of landfills which may accept sewage sludge:
sludge-only monofills and solid waste codisposal
landfills. Both are currently governed by 40 CFR
Part 257. EPA has proposed that in the future,
monofills will be covered by 40 CFR Part 503 and Co-
disposal landfills will be covered by 40 CFR Part 258.
These landfills may also be regulated under State
Subtitle D solid waste programs. Therefore, POTW
permit writers and solid waste offices should
coordinate permit development and issuance to
ensure that landfilled POTW sludge is disposed of in
an environmentally sound manner and that the
landfill accepting the sludge complies with existing
2.3.2 Incineration
Guidance in Chapter 8 covers incinerators that
accept primarily sewage sludge. Many of these
facilities are subject to regulation under various
Clean Air Act programs. Therefore, it is particularly
important for permit writers to determine the current
requirements applicable to the facility for possible
incorporation into permit documentation, and to
work with air program offices to develop appropriate
permit conditions. If the permit writer determines
that the incinerator is already permitted such that it
is not causing a problem to public health or the
environment, the permit writer may reference the
existing permit in the NPDES permit. This procedure
reduces the duplication of effort.
The guidance does not address municipal waste
incinerators that may accept small amounts of
sewage sludge. Since sewage sludge is sufficiently
different from other municipal waste to discourage
most municipal incinerators from accepting it, the
instances in which a POTW sends its sludge to a
municipal waste incinerator should be rare. In this
situation, the permit writer should take reasonable
steps to ensure that the POTW sends its sludge to a
facility that is in compliance with existing
requirements.
Disposal of the ash generated during incineration is
not discussed in this guidance (or in the proposed 40
CFR Part 503 sludge technical regulations) but will
continue to be covered under 40 CFR Part 257 (or 40
CFR Part 258 when promulgated) as a solid waste.
-------
2.3.3 Surface Disposal
A recent EPA survey of solid waste disposal facilities
identified 197,500 surface impoundments, of which
1,938 contain municipal sewage sludge (EPA 1986).
EPA also has information suggesting that some
communities use surface impoundments for extended
periods of time, indicating that the practice is the
community's method of disposal. In the proposed 40
CFR Part 503, the Agency defined a "surface disposal
site" as an area of land on which only sewage sludge
is placed for a period of one year or longer. The one-
year time period is used to differentiate surface
disposal from treatment or temporary storage.
During interim implementation and in the first
round of technical standards, EPA does not intend to
address temporary sludge storage practices (e.g. less
than one year) or treatment processes. When used for
long term storage or disposal, however, surface
impoundments may endanger the environment due
to the same types of problems created by poorly sited
or operated landfills. As a general rule, the permit
writer should consider imposing conditions if sludge
is held in a surface impoundment for more than one
year (see 54 FR 5824-25 for a discussion of the
differences between landfills, surface impoundments,
non-agricultural land application to dedicated land,
waste water treatment lagoons, etc.).
2.4 Practices Not Covered
quality of the sludge and assist the POTWs in
developing appropriate land-based disposal methods.
2.4.2 Sludge Storage
EPA does not intend to address temporary sludge
storage practices (e.g. less than one year). However,
the Agency does intend (as included in the proposed
40 CFR Part 503) to regulate "surface disposal sites."
These are impoundments or areas of land on which
only sewage sludge is placed for a period of one year
or longer. The one-year time period is used to
differentiate surface disposal from treatment or
temporary storage. This guidance document does not
cover temporary storage practices such as sludge
lagoons and other surface impoundments where
sludge is held less than one year. Currently, EPA has
no evidence to suggest that short-term storage
presents an environmental threat warranting
national concern. Nevertheless, EPA has the
authority to address problems created by short-term
storage practices if warranted at a particular site.
When a permit writer suspects that problems with
storage practices exist, he or she should include
conditions to address the problem in the facility's
permit. Problems may occur, for example, at storage
lagoons holding sludges with high levels of
contaminants, lagoons that are regularly emptied
and replenished, or those located at sites with
particularly important or vulnerable ground-water
or surface water resources.
2.4.1 Ocean Disposal
Ocean disposal of sewage sludge is not covered in the
proposed technical standards and is not covered in
this guidance document. Ocean disposal of sewage
sludge is regulated by the Marine Protection,
Research, and Sanctuaries Act (MPRSA) (40 CFR
Parts 220-228). EPA's Office of Marine and Estuarine
Protection currently issues permits pursuant to the
sludge disposal requirements of the MPRSA. In
November 1988, Congress passed the Ocean
Dumping Ban Act (PL100-688), amending MPRSA.
Among other things, the purpose of the amendment
to this Act is to terminate the ocean-dumping of
sewage sludge by December 1991. At that time,
POTWs that currently ocean dispose of their sewage
sludge will have to implement land-based sludge
management alternatives, which will be subject to
the jurisdiction of the CWA. If applicable sludge
standards have not been promulgated, permit
conditions will have to be developed on a case-by-case
basis. In the interim, NPDES permits still must
include boilerplate standard conditions, e.g., notice of
changed disposal practice and a compliance provision
(which includes a reopener that would allow the
NPDES permit to be modified upon promulgation of
the technical standards). State and Regional permit
writers should work with the POTWs and MPRSA
authorities during this interim period to assess the
2.4.3 Sludge Treatment Processes
Prior to the ultimate use or disposal of sewage sludge,
POTWs generally use a combination of biological,
chemical, physical, and thermal processes to treat the
sludge. These treatment processes are designed
primarily 1) to increase the solids content of the
sludge by reducing its water content and 2) to
stabilize the sludge by reducing or eliminating
pathogens, odors, and volatile solids. Advantages of
such treatment include an improvement in the
characteristics of the sludge for a particular
use/disposal practice, an increase in the economic
viability of using a particular practice, and a
reduction in the potential for public health,
environmental, and nuisance problems. Chapter 3
briefly describes the various treatment processes,
their advantages and disadvantages, and how they
may affect final sludge quality or disposal options.
Except in two situations covered by existing federal
regulations (pathogen reduction requirements and
NESHAPs) this guidance does not cover or prescribe
particular sludge treatment processes.
2.4.4 Septage Disposal
Septage, or the pumpings from septic tanks, is a
concentrated waste that may introduce significant
pollutant loads to the environment (particularly
-------
ground-water) when disposed on land. While the
trend has been toward discharging septage into
POTWs for treatment, various land disposal methods
are still practiced. Under some existing federal
regulations, as well as under the proposed 40 CFR
Part 503 technical standards, septage disposal
practices are subject to the same standards as sewage
sludge disposal practices. Currently, land disposal of
septage is governed by 40 CFR Part 257. State and
local law may also regulate septage disposal.
However, septage disposal is outside the scope of this
guidance. Also, as with other facilities or practices
that are generally outside the scope of the existing
NPDES permit program, septage disposal is not
specifically addressed in EPA's Interim Strategy.
Nonetheless, EPA has the authority to address
known problems with septage disposal. For guidance,
permit writers should refer to EPA's Handbook on
Septage Treatment and Disposal (EPA 1984).
2.4.5 Disposal of Hazardous Waste
Neither the interim nor the long-term sewage sludge
disposal program under Section 405 of the CWA will
govern sewage sludge that is classified as hazardous
waste, as determined in accordance with the RCRA
regulations (40 CFR Part 261). Instead, these sludges
will continue to be regulated under Subtitle C of
RCRA (40 CFR Parts 264 and 265).
Sewage sludge is not a listed hazardous waste.
Moreover, available evidence from characteristic
tests suggests that POTW sludges are unlikely to be a
characteristic hazardous waste. However, the non-
hazardous nature of POTW sludge cannot be
assumed, and as sludge generators, POTWs are
required under 40 CFR Part 262.11 to determine
whether or not their sewage sludge is a hazardous
waste by virtue of its characteristics.
A solid waste may be a characteristic hazardous
waste if it exhibits characteristics of ignitability (40
CFR 261.21), corrosivity (40 CFR 261.22), reactivity
(40 CFR 261.23), or EP toxicity (40 CFR 261.24).
Permit writers should require the POTW to submit
the results of any characteristic tests that have been
run on the POTW's sludge. Although sewage sludge
conceivably could exhibit the characteristics of
ignitability, corrosivity, or reactivity, most concerns
about sewage sludge have focused on EP toxicity.
Therefore, this guidance recommends that permit
writers include conditions in Class I permits
requiring the POTW to conduct an EP toxicity test if
factors are present indicating a likely EP toxicity
problem (e.g., POTW receives significant loadings of
pollutants covered by the test) and the POTW does
not have current data showing that the sludge is not
a hazardous waste. (Note: EP toxicity test will be
replaced by Toxicity Characteristic Leaching
Procedure (TCLP) test effective September 25, 1990.
(See discussion, Chapter 5).
If a POTW sludge turns out to be a hazardous waste
but is not currently being regulated under RCRA, the
permit writer should notify the RCRA office, which
will be responsible for regulating the generation and
disposal of hazardous sludge. The permit writer need
only include the standard sludge conditions (e.g.,
notice requirements, compliance provision) in the
POTW's NPDES permit. (Note: Where appropriate,
these standard provisions may be added in
conjunction with the effort currently underway to
reopen permits of POTWs that are RCRA "permit-by-
rule" facilities to add corrective action requirements.)
2.5 Relationship Between Sludge
Permitting and the Pretreatment Program
Reducing the amount of pollutants entering a POTW
reduces the amount of contaminants in sewage
sludge. A major goal of the national pretreatment
program is to ensure that non-domestic discharges to
a POTW do not interfere with the POTW's chosen
sludge use or disposal practice. Further, an objective
of the pretreatment program is to improve
opportunities for the reuse and recycling of municipal
effluents and sludges. POTWs that are required to
have approved local pretreatment programs and
those that experience recurring sludge
contamination problems may have to develop or
recalculate local discharge limits for their users in
order to reduce the pollutants in the sludge to
acceptable levels. (See 40 CFR Part 403.5(c).)
Therefore, if the POTW cannot meet current sludge
requirements because of high contamination levels,
the permit writer could consult with the
pretreatment approval authority to consider
requiring the POTW to develop additional local
limits. Additional information about detecting and
remedying sludge contamination problems can be
found in two EPA guidance documents available
from the Office of Water Enforcement and Permits
(OWEP): Guidance Manual for Preventing
Interference at POTWs (September 1987) and
Guidance Manual on the Development and
Implementation of Local Discharge Limitations
Under the Pretreatment Program (November 1987).
References
EPA 1984. Handbook on Septage Treatment and
Disposal. U.S Environmental Protection Agency,
Municipal Environmental Research Laboratory,
EPA 625/6-84-009, October 1984.
EPA 1986. Subtitle D Study Phase I Report. U.S.
Environmental Protection Agency, EPA 1530/SW/86-
054, October 1986.
10
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Chapter 3
Overview of Sludge Treatment Processes
and Their Effect on Sludge Properties
3.1 Introduction
The following section provides a brief discussion of
sludge treatment processes. The processes are
outlined here since many NPDES permit writers
have not been responsible for sludge regulation in the
past, and may be unfamiliar with sludge
management practices. Processes used to dewater,
stabilize, and condition the sludge may directly affect
sludge quantity and quality, while the type of
wastewater treatment techniques used, such as
chemical coagulation or lime addition, will affect
sludge characteristics and contaminant levels.
The quality of a sludge that does not comply with use
or disposal guidelines can sometimes be improved by
more careful sludge processing or by the use of
different treatment processes. In other cases, users of
the POTW will need to improve the pretreatment of
their wastewaters or the POTW may need to employ
different use or disposal options.
3.2 Sludge Treatment Alternatives
Several techniques are commonly used to process
sludge before ultimate use or disposal. Some of the
more widely used processes are discussed briefly
below. For more detailed descriptions, see the EPA
Process Design Manual for Sludge Treatment and
Disposal (EPA 1979).
3.2.1 Thickening
Thickening is generally the first process in a solids
processing train. It increases the solids content of
sludges by removing some of the water. Thickening
typically increases the solids concentration in the
sludge two to ten times, thus reducing the volume of
sludge to be treated in subsequent processes to one-
half to one-tenth the original volume. Because sludge
processing and disposal costs are greatly affected by
sludge volume, thickening can significantly reduce
capital and operating costs of subsequent operations.
Process equipment that may be used to thicken
sludge includes gravity thickeners, dissolved air
flotation thickeners, centrifuges, gravity-belt
thickeners, and rotary screen thickeners. Sludges
from primary, biological, and chemical wastewater
treatment can be blended and mixed in common
thickeners or thickened separately.
3.2.2 Stabilization
Stabilization processes decrease volatile solids,
offensive odors and pathogens in wastewater sludges.
Offensive odors are lessened by decreasing the
volatile content of sludges or by changing the sludge
properties so that the sludge decomposes less rapidly.
Some stabilization processes, especially aerobic and
anaerobic digestion, also substantially reduce the
quantity of suspended solids in the sludge.
Stabilization technologies include anaerobic
digestion, aerobic digestion, composting, lime
treatment, and chemical fixation.
Anaerobic Digestion
Anaerobic digestion is a biological process that is
widely used in municipal wastewater treatment
plants to stabilize sludge. The process is
accomplished by maintaining the sludge at elevated
temperatures for about 10 to 30 days in the absence of
free oxygen. The organic matter in the sludge is
biologically decomposed and the pathogen content is
reduced. The volatile content of the sludge is
typically reduced by about 50 percent, which in turn
reduces the sludge volume by about 30 percent.
The two operational temperature modes of anaerobic
digestion are mesophilic (90 to 95°F) and
thermophilic (120 to 135°F). Thermophilic digestion
requires a much shorter solids retention time thus
reducing the required digester capacity by about 50
percent. Thermophilic digestion also reduces the
pathogen content more than mesophilic digestion.
Aerobic Digestion
Aerobic digestion of sludge is similar to the activated
sludge treatment of wastewater. Both of these
processes rely on biological treatment under aerobic
conditions. The capital costs of aerobic digestion
systems are typically much lower than the capital
costs of an anaerobic digestion system. Because a
large amount of energy is required to provide oxygen
11
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for biological activity, aerobic digestion is typically
used in smaller plants where the reduction in capital
costs more than compensates for the increased energy
requirements. Aerobic digestion is also generally
easier to operate by a small project staff.
Lime Treatment
Adding lime to raw sludge to raise the pH to 12 or
greater for two hours decreases the concentration of
pathogens and other organisms in the sludge and
inhibits decomposition. However, as the pH of the
sludge drops after lime stabilization, biological
decomposition will resume, producing offensive
odors.
The advantages of lime addition include lower costs
and simplicity of operation. Nonetheless, sludge
remains stabilized only as long as the high pH is
maintained. Disposal costs are also increased because
the large quantity of lime added to the sludge
increases sludge volume.
Chemical Fixation
In the chemical fixation process, chemicals are added
to solidify the sludge mass, render it inoffensive, and
decrease the leachability of metals. Although there is
no decrease in volume, the sludge is stabilized.
Chemical fixation is best performed after dewatering,
which reduces the volume of sludge requiring final
disposal.
The process is carried out by adding chemicals to a
sludge, producing a colloidal solid that "sets" into a
semi-rigid mass. The product can be handled as a
solid material that can be landfilled, or used for
landfill cover.
3.2.3 Conditioning
Sludge conditioning refers to physical and chemical
methods for altering the properties of sludge to
improve its dewatering characteristics. In general,
the goal is to transform the hydrophilic, gel-like
solids into a porous material that will release water.
Proper conditioning improves the efficiency of the
dewatering process. The two methods most commonly
used are the addition of chemicals and heat
conditioning.
Chemical Conditioning
Common chemicals used before dewatering include
inorganics, such as lime and ferric chloride, and high-
molecular-weight organic polymers. Chemical
conditioning is widely practiced.
Heat Conditioning
This process involves heating sludge in a closed
reactor to temperatures of 300 to 400"F. The reactor
is under pressures of 250 to 300 psig, and holds the
sludge under these conditions for 20 to 30 minutes.
Heat treatment makes solids coagulate, breaks down
the gel-like structure, and reduces the water in the
sludge solids. As a result, the sludge is sterilized and
readily dewatered, without adding chemicals, to a
solids content of 30 to 45 percent. Heat conditioning
is much less common than chemical conditioning due
to its high energy usage.
3.2.4 Dewatering
Dewatering converts sludge from a flowing mixture
of liquid and solids to a cake-like substance more
readily handled as a solid. Mechanical and heat
drying techniques may be used. In addition to
significantly reducing the moisture content,
dewatering reduces sludge volume, increases the fuel
value of a sludge, and decreases transportation costs
for final disposal. Dewatering also prepares sludges
for such forms of ultimate disposal as combustion,
landfilling, or land application. For a more detailed
description of municipal sludge dewatering, see
Dewatering Municipal Wastewater Sludges (EPA
1987).
Mechanical Dewatering Methods
Mechanical devices for dewatering include vacuum
filters, filter presses, centrifuges and belt filter
presses. Sludge cakes discharged from these units
will generally be 12 to 45 percent solids, depending
on the sludge being dewatered, the type of
conditioning employed, and the dewatering device. In
general, belt presses and centrifuges are preceded by
polymer conditioning; filter presses are preceded by
inorganic chemical, heat, or ash conditioning; and
vacuum filters by any of the above methods. Many
wastewater treatment plants employ mechanical
methods for dewatering sludge.
Heat Drying
Heat drying is the process of evaporating water from
sludge by thermal means. The units most commonly
used evaporate the water by direct drying, that is, hot
air directly contacts the sludge to be dried, as in a
rotary kiln. The heat-dried products generally
contain 10 percent moisture or less. Heat drying is
employed at a few treatment plants (e.g., Milwaukee,
WI and Houston, TX), and is usually used to produce
products such as Milorganite and Huactonite.
Multiple-Effect Evaporation
The Carver-Greenfield Light Oil Process (oil-medium
dehydration) is a patented technique for the
12
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evaporation of water from sludge. It produces either a
sterile fertilizer or a dry (approximately 95 percent
solids content) product capable of being utilized as an
energy source. At the present time, the Carver-
Greenfield Light Oil Process is an innovative
technology. Units are under construction or starting
up at four POTWs in the U.S.
Air Drying
A variety of natural solar evaporation techniques
including sand drying beds, vacuum assisted beds,
paved beds, and lagoons are used by a large number
of POTWs. Liquid sludge is naturally dewatered by
drainage and by evaporation to the air. Sludges are
placed in drying beds or lagoons, allowed to dry and
then removed. However, the use of drying beds is
generally limited to areas with available land and
suitable climates (i.e., annual evaporation rate
exceeds annual rainfall unless covered drying beds
are used). Despite the limitations of natural solar
evaporation techniques, drying beds and lagoons are
common at small POTWs throughout the country.
Some large POTWs, such as Chicago and San Diego,
have used drying beds, lagoons and paved beds for
sludge dewatering.
3.2.5 Composting
Composting is a sludge stabilization process
normally performed after dewatering. In composting,
the organic constituents of the sludge are aerobically
decomposed. The decomposition of organic matter as
a result of heat produced by biological activity during
composting of the sludge reduces pathogens as well as
volatile materials that cause odors. The final compost
product is a humus-like material suitable for use as a
soil conditioner and low nutrient fertilizer.
In general, the composting process consists of mixing
dewatered sludge, either raw or digested, with a
bulking agent such as woodchips, sawdust or finished
compost to increase the porosity and to reduce the
moisture content. The mixture is then aerated for
some time (11 to 15+ days) to raise the temperature
and further decrease moisture content through
evaporation. The high temperature (about 55C)
ensures pathogen destruction and aids in reducing
the moisture content. The compost is then usually
cured by storage at lower temperatures for extended
periods. The compost product is often screened to
recover and reuse coarse bulking agents such as
woodchips.
Composting methods include windrow, static-pile,
and a variety of in-vessel composting techniques.
Three example sludge treatment trains are shown in
Figure 3-1. Many other configurations are also
commonly in use. While some preliminary sludge
treatment processes are designed for specific final
disposal methods, most preliminary processes can be
used with a number of final disposal methods. Permit
writers should be familiar with the treatment
processes being used at a particular facility.
3.3 Pathogen Reduction
3.3.1 Processes to Significantly Reduce
Pathogens (PSRP)
40 CFR Part 257, promulgated under the joint
authority of the Clean Water Act and Subtitle D of
RCRA, requires that sewage sludge applied to land
(either applied to the land surface or incorporated
into the soil) be treated by a Process to Significantly
Reduce Pathogens (PSRP). In addition, three site
restrictions must be met: 1) public access to the land
application area must be controlled for 12 months; 2)
grazing by animals whose products are consumed by
humans must be prevented for one month; and 3) no
crops directly consumed by humans where the edible
portion of the crop comes into contact with the sludge-
amended soil may be grown for 18 months. (These
restrictions do not apply to sewage sludge that is
disposed of by a trenching or burial operation.)
Of the sludge treatment processes discussed above,
aerobic digestion, air drying, anaerobic digestion,
composting, and lime stabilization are accepted as
PSRPs in 40 CFR Part 257. In addition to the
processes discussed above, other sludge treatment
methods may be acceptable under 40 CFR Part 257 if
pathogens and vector attraction of the waste are
reduced to an extent equivalent to the reduction
achieved by the listed PSRPs. (See discussion on
PSRP and PFRP equivalency below.)
3.3.2 Processes to Further Reduce Pathogens
(PFRP)
Under certain circumstances, sludge that is applied
to land (on the surface or incorporated into the soil)
must be treated by a Process to Further Reduce
Pathogens (PFRP), which is more stringent than
PSRP. 40 CFR 257.3-6 requires that sludge applied to
land where crops for direct human consumption are
grown within 18 months of the sludge application,
and the crops will come in contact with the sludge-
amended soil, the sludge must be treated by a PFRP.
Where sludge is treated by a PFRP, no public access
or grazing restrictions apply.
Processes to Further Reduce Pathogens (PFRPs)
destroy a greater number of pathogens than do
PSRPs. PFRPs include more extensive composting,
heat drying, heat treatment, and thermophilic
aerobic digestion. PFRPs generally operate at higher
temperatures than PSRPs. Other methods or
operating conditions may also be acceptable PFRPs if
pathogens and vector attraction of the waste are
reduced to an extent equivalent to the reduction
13
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Raw
Wastewater
Effluent
Raw
Wastewater
^-
A
Return
i
F
Primary
Clarifier
Primary] Re
Sludge 1
t
teturn
Dewatering
^ Aeration
I Basin
i
i Secondary Sludge
i
w
^ Final
Clarifier
,-
\ r
Conditioninc
(Heat Treatme
Effluent
^
nt)
1
Land Disposal
Raw
Wastewater *-»
Removal Clarifier i k Basin
\^^X-"
3S?1
A t
| i
b Sludge ^
^ Blend Tank ' Tlnckeniiu
V t
Conditioning De water in
Final Effluentfc
Clarifier r
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r
3
y ^
Figure 3-1. Typical sludge treatment trains.
14
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achieved by any of the above PFRP methods. (See
discussion of PSRP and PFRP equivalency below.) In
addition, any PSRP may be considered to be a PFRP
if augmented by beta ray irradiation, gamma ray
irradiation, pasteurization, or other methods that
result in an equivalent reduction to these add-on
methods.
3.3.3 PSRP and PFRP Equivalency
As stated above, 40 CFR Part 257 acknowledges that
other treatment methods or other operating
conditions may be acceptable if they reduce pathogen
and vector attraction to an extent equivalent to that
achieved by the processes specified in the regulations.
Equivalent methods may be modifications to a named
PSRP or PFRP, a new process, or a combination of
processes.
The equivalency of these "other" processes are based
on documenting equivalent treatment. For PSRP the
process must consistently reduce pathogenic viruses
and bacteria densities by 1 log (base 10), and for
PFRP the operating conditions must ensure
pathogenic reduction to below detection limits. In
addition, PSRPs and PFRPs must reduce vector
attraction to the same extent as the reduction
achieved by a good anaerobic digester.
A Pathogen Equivalency Committee (PEC) was
formed by EPA in 1985. The committee reviews and
makes recommendations to EPA management on
applications for PSRP and PFRP equivalency. The
Committee does not formally approve or disapprove
methods or operational conditions but rather
provides guidance to the applicants on providing the
necessary data to determine equivalency.
Equivalency determinations in the past have shown
most processes submitted to be equivalent on a site-
specific basis only. Generally, equivalency has
applied only to a particular operation run at a
particular location under specified conditions.
However, one process has demonstrated national
equivalency, where the desired reductions in
pathogens and vector attractions remained constant
under the variety of conditions that would be
encountered around the country.1
An EPA document entitled Environmental
Regulations and Technology: Control of Pathogens in
Municipal Wastewater Sludge (September 1989)
describes the PSRP and PFRP processes listed under
current regulation, how equivalency is determined
and the process and data needed when submitting a
method or operating condition for an equivalency
determination.
3.4 Effect on Sludge Properties
Some sludge processes have little effect on the
concentration of pollutants in the sludge while others
increase or decrease the concentration of pollutants.
Changes in sludge pollutant concentrations are
important since many sludge reuse or disposal
requirements are limited by contaminant
concentrations and/or loading rates.
Simply removing water (as with gravity thickening
or dewatering) does not change the concentration
(mass of pollutants/mass of solid) of pollutants in the
sludge solids. But digestion and other stabilization
processes that decrease the volatile fraction of the
sludge increase the concentration of non-
biodegradable pollutants. Table 3-1 shows how
processes that reduce the volatile fraction of sludge
increase the concentration of metals in the remaining
sludge solids. Conversely, the addition of materials
such as bulking agents for composting or chemicals
for stabilization decreases the overall concentration
of metals in the sludge or sludge product.
Table 3-1 Increased Metals Concentration During
Processing (mg/kg dry weight)
Element
Chromium
Copper
Nickel
Zinc
No. Samples
Raw Primary Sludge
(79% volatile)
110
200
46
620
5
Lagooned Sludge
(56% volatile)
220
450
65
1,400
30
NOTE: 1977 data, Sacramento County Central treatment plant,
California.
Source: EPA 1979.
Some toxins can be biodegraded by stabilization
processes or removed from the sludge by volatiliza-
tion. However, data on these mechanisms for removal
of organic pollutants is very limited.
References
EPA 1979. Process Design Manual for Sludge
Treatment and Disposal, U.S. Environmental
Protection Agency, EPA 625/1-79-011, September
1979.
EPA 1987. Design Manual: Dewatering Municipal
Wastewater Sludges, U.S. Environmental Protection
Agency, EPA 625/1-87/014.
EPA 1989. Environmental Regulations and
Technology: Control of Pathogens in Municipal
Wastewater Sludge, U.S. Environmental Protection
Agency, EPA 625/10-89-006, September 1989.
1 Advanced Alkaline Stabilization with Subsequent Accelerated
Drying (AASSAD)
15
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Chapter 4
Summary of Permitting Procedures and Requirements
This section gives the permit writer some basic
guidance for developing permit requirements for
sludge. It addresses what application data are
needed, the priority of permits to consider for case-by-
case development of sludge requirements, standard
permit conditions for all POTW permits, and
recommended monitoring requirements.
4.1 Gathering Information
At present, the federal permit application forms for
POTWs (Standard Form A and Short Form A) ask for
some information that may be useful in evaluating
and developing permit limits for sludge. These forms
request information concerning basic influent and
effluent characteristics and use of wastewater
treatment lagoons. However, they do not ask for
specific information on sludge quality, treatment,
use, or disposal. The recently promulgated state
sludge management program rules and revisions to
the NPDES regulations (54 FR 18716, May 2, 1989)
require the following application information when
the POTW applies for issuance or reissuance of its
NPDES permit: annual sludge volume, other permits
held or requested, a topographical map extending one
mile beyond the POTWs boundaries, a narrative
description of POTWs use and/or disposal practices,
any sludge monitoring data the applicant may have
and any other information requested by the permit
writer. [40 CFR 122.21(d)(3)(ii); 501.15(a)(2)]
Whether any additional information is necessary to
write the permit will depend on such factors as
whether the POTW has been identified as a Class I
facility, and on the type of sludge use or disposal
option(s) the POTW uses. Table 4-1 describes how
information may be used by the permit writer when
establishing sludge requirements. To evaluate
whether additional specific information is needed,
either to determine if the POTW should be treated as
a Class I facility or to develop case-by-case permit
conditions, the permit writer will need to refer to the
permit requirements and recommendations under
the applicable use or disposal option in Chapters 5
through 9. For Class I permits, permit writers should
use this preliminary evaluation as a basis for
developing a "sludge fact sheet" for the POTW that
can be used in permit development and preparation of
the permit fact sheet.
The tables in Appendix E can serve as a tool for
permit writers by identifying State requirements and
recommendations. The permit writer will need to
ascertain whether the practice cited in Appendix E is
a requirement or a recommendation because this
distinction is not made in Appendix E. For example,
California pollutant concentration limits for land
application and distribution and marketing are only
recommended, not required.
Sampling and analysis data that may be needed for
application purposes is discussed in Sections 4.4 and
4.5.
4.2 Secondary Information Sources
Although the POTW has the burden of supplying the
information needed to write the permit, the permit
writer can also use secondary sources of information
to gain background data on sludge practices and their
potential impacts on public health and the
environment. Use of these other sources may be
helpful to supplement or confirm information
received from the POTW. Listed below are
potentially helpful information sources.
• EPA's National Sewage Sludge Survey (results to
be published in 1990). 400+ POTWs were
surveyed for information on sludge use and
disposal practices and 200 were sampled for
actual sludge quality data.
• State solid waste management plans. POTW
solid waste/sludge management plans; State
application forms.
• EPA Construction Grants program information.
This includes the NEEDS data base that
describes all treatment processes used at the
POTW and other basic information about the
facility's design and operation. Construction
grants staff may also be helpful in estimating
expected sludge quality and quantity from
particular plants and in evaluating whether
sludge use or disposal practices are designed and
17
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Table 4-1 Information Gathering for Writing Sludge Conditions
Data
Use
State or local bans or prohibitions
Disposal/use options currently used by POTW
Planned (major) changes for disposal/use options
Annual sludge volume to each disposal/use option
Current federal or state permits issued to POTW applicable to sludge
use/disposal options; approved sludge management plans; current
management practices
If sludge disposed off-site, current federal or state permits issued to
site operators
Type of wastewater treatment used at POTW generating the sludge,
e.g.:
- primary
- advanced primary
- secondary
- AWT (chemical addition)
For new facilities, engineering reports, facilities plans, manufacturer's
plans, when facilities go on-line, etc.
Sludge treatment processes used by POTW, e.g.:
- digestion (aerobic, anaerobic)
- composting
- heat treatment
- lime
Chemicals used in dewatering process
On-site sludge storage practices
When was sludge held on-site generated (e.g., in wastewater
lagoons or sludge stockpiles)?
Sludge quality
Characteristic hazardous waste determination (e.g, TCLP toxicity
test)
Influent quality
- Influent flows/loadings (BODJSS, priority pollutants)
- Percentage of flow and loadings from industrial sources or
centralized waste treaters
- Types of industrial contributions
- Pretreatment used by industrial contributors
Historical sludge management problems in the generator/transport or/
applicator/owner relationship?
Compliance history
- significant noncomphance or citizen complaints due to sludge
use/disposal problems
Unusual circumstances at POTW or disposal sites (e.g., disposal
near sensitive areas such as estuaries)
If sludge is landfilled, disposal in monofill or co-disposal facility
If sludge is land applied, use of land (e.g., crops grown)
Topographic map
Determine which options are not available to POTW.
Determine applicable requirements and recommendations for
POTW's current sludge practices.
Develop permit conditions for all planned options during permit term
and thereby avoid need for reopener provision for future changes.
Determine if there are capacity problems; track sludge volume to
each use/option.
Consider adopting by reference if protective of public health and the
environment.
Determine compliance by disposal site and possible remedial action
needed; need for POTW to find alternative disposal option.
Determine type and quantity of sludge produced.
Estimate expected quality and quantity of sludge produced.
Determine compliance with pathogen reduction requirements (land
application; distribution and marketing).
Determine need for POTW-site management practices (e.g., run-off
controls for composting facilities)
May affect procedures for analyzing organic compounds in sludge.
See POTW Sludge Sampling and Analysis Guidance.
Potential toxic contamination of sludge.
Determine need for conditions for long-term storage
Age of sludge may affect quality
Develop disposal plan for wastewater lagoon sludge if scheduled for
emptying.
Determine compliance with use/disposal option requirements. See
Sections 4.4 and 4.5 for recommended monitoring requirements.
If sludge is a hazardous waste, defer to RCRA regulation (see
Chapter 5).
Help estimate sludge quality and quantity.
Help identify potential sludge contamination problems and sources.
Pretreatment information can help permit writer and POTW
determine if needed improvements in sludge quality are feasible
through additional pretreatment.
May indicate need to develop more comprehensive solution than
POTW permit conditions alone.
Determine need to classify as a priority or develop conditions to
address problem.
Determine need to classify as a priority or develop conditions to
address problem.
For co-disposal will need to consult with solid waste officials (see
Chapter 5).
Additional requirements apply to food-chain cropland.
Identifies location of any sludge management facilities and potential
siting problems.
18
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operated in an environmentally sound manner.
(Contact EPA: Office of Municipal Pollution
Control).
• Pretreatment program information. Information
such as types and amount of industrial loadings
to the POTW and past or present sludge quality
problems can be found in the POTW's
pretreatment program application, annual
reports, and audit reports.
• NPDES compliance inspections or diagnostic
evaluations. Reports of these activities may
indicate problems that may adversely affect
sludge processes or quality (e.g., problems with
settling may indicate the presence of sludge with
too high a moisture content to be used for
practices requiring a relatively high percentage
of solids).
• Local or State health agencies, extension
agencies, and university agricultural research
departments. These sources may be particularly
useful to consult about particular site
characteristics or problems.
• Basin Plans and Water Quality Management
Plans. These sources may help identify sensitive
disposal sites, e.g., wetlands, drinking water
aquifers, etc.
4.3 Setting Priorities
Before developing permit conditions, a permit writer
must determine whether the POTW should be
considered as a Class I priority facility for sludge
permitting. The process for identifying priority
POTWs is explained in EPA's Interim Permitting
Strategy (see Appendix A). Briefly, Class I sludge
management facilities are those POTWs with
approved pretreatment programs and any POTW
designated as Class I due to the greater potential for
its sludge or sludge use or disposal practices to
adversely affect public health or the environment
(e.g., incinerators). In ascertaining whether a POTW,
not subject to pretreatment regulations, should be
considered a Class I facility, permit writers will need
to take reasonable steps to collect and evaluate
available evidence to determine if problems or
potential problems exist. Evidence consists of
information received from primary and secondary
sources during the application process, together with
information in this and other guidance on potential
environmental problems associated with POTW
sludge use or disposal practices. See Section III of the
Interim Permitting Strategy for examples of
potential Class I sludge management facilities
beyond the pretreatment cities.
4.4 Standard Permit Requirements
4.4.1 General
All reissued or new permits must include some
general requirements for sludge use and disposal,
whether or not the facility needs additional case-by-
case conditions. Most of the provisions are required
by the recently promulgated State sludge manage-
ment program and permitting regulations (54 FR
18716). The four primary areas each permit must
address are: compliance with existing requirements
and with 40 CFR Part 503 regulations when promul-
gated; reopening the permit when the 40 CFR Part
503 regulations are promulgated; notification of
change in sludge practices; and sludge quality
monitoring.
The first standard permit condition is that the permit
must require the POTW to comply with all existing
requirements for sludge use and disposal. For
example, those POTWs who land apply sludge must
comply with all applicable requirements under 40
CFR Part 257. The permit writer should also
ascertain if there are any existing permits which
govern the facility's sludge use and disposal
practices. If these are adequate to satisfy the require-
ments of Section 405(d), the NPDES permit need only
reference the other permit, and add any additional
requirements necessary to protect public health and
the environment. This compliance provision should
also notify the permittee that compliance with the
final 40 CFR Part 503 sludge technical standards by
the deadlines established in the rule will be required
regardless of whether or not the permit is reopened.
The reopener clause is another standard condition
which must be included in the NPDES permit. It
authorizes reopening of the permit to include tech-
nical standards if the technical standards are more
stringent or more comprehensive than the conditions
in the permit. The reopener provision notifies the
permittee of future legal obligations under the CWA,
and of the potential need to modify the permit to
incorporate 40 CFR Part 503 requirements once they
are promulgated. (Note that the POTW is required to
comply with applicable Part 503 requirements
whether or not such requirements have been
incorporated in its permit.)
The notification provision requires the permittee to
give notice to the permitting authority when a
significant change in the sludge use or disposal
practice is planned that could require modifications
to the permit. Notice of new use or disposal sites that
were not previously identified is also required.
In addition to the standard sludge boilerplate
conditions described above, many of the standard
permit conditions that apply to effluent discharge
activities will also apply to sludge use and disposal
19
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activities (e.g., duty to mitigate, duty of proper
operation and maintenance, and entry and inspection
requirements). Other conditions have been modified
to specifically address sludge use and disposal (e.g.,
record keeping for 5 years). Conversely, a few of the
40 CFR Part 122 regulations have been revised to
limit their applicability only to effluent discharge
activities (e.g., anti-backsliding). Further discussion
of these standard requirements can be found in
Appendix A.
4.4.2 Monitoring Requirements
Current regulations require sludge monitoring and
reporting at a frequency dependent on the nature and
effect of the permittee's sludge use or disposal
activities, but at least once a year [40 CFR
122.44(c)(2) as revised May 2, 1989]. This means that
if the permit contains a limit for a certain parameter,
the permit must also require the permittee to sample
and analyze the sludge for that pollutant at least once
a year. Monitoring results should be reported on the
discharge monitoring report (DMR) or standard form
identified in the permit.
Given the fact that few permits are likely to contain
pollutant limits, compliance monitoring will not
yield enough information to fully characterize the
sludge quality. The Interim Permitting Strategy
(Appendix A) includes a sewage sludge monitoring
policy to help ensure that permit writers have enough
information on sludge quality to evaluate the impact
of the permittee's sludge use or disposal practices.
The Interim Permitting Strategy recommends the
following monitoring:
• For Class I POTWs, an annual scan of the 126
priority pollutants, and more frequent
monitoring of the pollutants for which numeric
limits have been proposed in the proposed 40 CFR
Part 503 regulations for the POTWs particular
use or disposal practice.
• For non-Class I POTWs with industrial users, a
priority pollutant scan at the time of permit
application, and annual monitoring of the
pollutant for which 40 CFR Part 503 technical
standards have been proposed.
• For non-Class I POTWs with no industrial users,
annual monitoring of six metals: cadmium,
copper, chromium, lead, nickel, and zinc.
A list of the pollutants for which technical standards
have been proposed is contained in the monitoring
discussion for each disposal option, in subsequent
chapters. Permit writers may relax these monitoring
requirements after the absence of particular priority
pollutants has been established (or where detection
at low levels clearly show no cause for concern)
through repeated testing. Future testing for those
pollutants need not be required unless a change
occurs at the POTW.
Permit writers need not require annual monitoring
for POTWs that use wastewater stabilization lagoons
as their sole treatment process if the sludge will not
be removed for disposal during the permit term,
unless the permit writer determines monitoring is
needed. If such permit does not require monitoring, it
should contain a requirement that the permittee
notify the permit authority if the sludge is pumped
out of the lagoon within a one-year period. The
permit writer will then need to modify the permit to
require monitoring and impose sludge use or disposal
conditions.
Permit writers will also need to specify monitoring
methods in the POTWs permit. The NPDES
regulations specify that permittees be required to
monitor sludge according to test procedures approved
under 40 CFR Part 136 unless otherwise specified in
40 CFR Part 503, when final, or unless test
procedures are specified in the permit. Permit writers
should refer to the POTW Sludge Sampling and
Analysis Guidance Document (EPA, August 1989) for
additional information on appropriate sludge
sampling and analytical procedures.
4.5 Additional Permit Requirements for
Class I POTWs
4.5.1 Case-by-Case Sludge Conditions
In addition to the standard permit conditions
described above, permits for Class I POTWs must
include any requirements (management practices
and/or sludge concentration limits) developed on a
case-by-case basis that the permit writer determines
may be necessary to protect public health and the
environment. The basis for these limits should be
explained in a fact sheet modeled after the NPDES
fact sheet developed for majors. Chapters 5 through 9
discuss additional conditions the permit writer may
want to include on a case-by-case basis.
4.5.2 Case-by-Case Monitoring Requirements
As stated earlier, the Interim Permitting Strategy
recommends that Class I POTWs be required to
perform an annual priority pollutant scan and more
frequent monitoring of the pollutants proposed in 40
CFR Part 503. This monitoring would be in addition
to the current NPDES requirement for annual
compliance monitoring for those pollutants limited in
the permit. There are several circumstances for
which permit writers should determine additional
monitoring frequencies and parameters on a case-by-
case basis. More frequent monitoring might be
appropriate, for example, where the POTWs influent
varies considerably and safe use or disposal depends
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on careful limiting of particular pollutants. In
particular, permit writers should consider requiring
more frequent monitoring for commonly occurring
metals (e.g., Cd, Cu, Cr, Pb, Ni, Zn) since the harm
posed by metals is well documented, there are more
limits and guidance on regulating metals, and
analysis for metals is relatively inexpensive. Other
types of monitoring (e.g., ground water monitoring,
soil sampling) may also be appropriate depending on
the specific conditions surrounding the use or
disposal practice. Specific recommendations for
monitoring requirements are discussed in Chapters 5
through 9 for each disposal practice.
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Chapter 5
Landfilling
5.1 Introduction
According to current EPA estimates, 42 percent of
municipal sewage sludge generated in the United
States is disposed of in landfills. This figure includes
the 1 percent of sewage sludge generated that is
disposed of in sludge-only landfills (54 FR 5756). The
two types of sludge landfilling practices are (EPA
1978):
• Sludge-only disposal (or "monofilling") - sludge is
buried alone, usually in trenches; and
• Co-disposal - sludge is buried in a municipal solid
waste (refuse) landfill.
Non-hazardous municipal sludge is considered a solid
waste residual generated during wastewater
treatment. It is regulated at the federal level by the
Clean Water Act and Subtitle D of the Resource
Conservation and Recovery Act (RCRA). Subtitle D
established a cooperative framework for federal,
State, and local governments to control the
management of non-hazardous solid waste. As part of
this framework, EPA promulgated criteria in 1979
that set minimum performance standards for all solid
waste disposal facilities. These "Criteria for
Classification of Solid Waste Disposal Facilities and
Practices" (40 Part CFR Part 257) consist of location,
design, and operational performance standards that
must be met by solid waste management facilities.
The landfill criteria pertain to endangered species,
surface water, ground water, disease, air quality,
public safety, and proximity to floodplains (EPA
1986b).
Currently, sludge-only monofills and co-disposal
landfills are regulated at the federal level under the
Criteria for Classification of Solid Waste Disposal
Facilities and Practices (40 CFR Part 257). In the
future, sludge-only monofills will be regulated under
the new Standards for the Disposal of Sewage Sludge
regulations (40 CFR Part 503), while co-disposal
landfills will be regulated under the Criteria for
Municipal Solid Waste Landfills (40 CFR Part 258)
that are being developed by the Office of Solid Waste.
The Criteria for Municipal Solid Waste Landfills
were proposed on August 30, 1988 (53 FR 33314) and
are expected to be promulgated in late 1990. Proposed
40 CFR Part 258 would require that the POTW
sending its sludge to a landfill ensure that the sludge
is nonhazardous, that the sludge passes the paint
filter liquids test, and that it goes to a State
permitted landfill. Until these new rules are
promulgated, however, only the existing
requirements of 40 CFR Part 257 have the force of
regulation.
5.1.1 Permitting Responsibilities
Permits issued to POTWs that dispose of their sludge
in sludge-only monofills or co-disposal landfills must
require that the POTWs use facilities that comply
with existing federal regulations for solid waste
disposal facilities (40 CFR Part 257). By including
such a requirement, permit writers can ensure that
the POTW's sludge will be disposed of in accordance
with existing regulations, even if the POTW does not
own or operate the landfill receiving its sludge.
Where the POTW owns and operates the sludge-only
monofill or co-disposal landfill receiving its sludge,
the permit writer should request certification that
the landfill is in compliance with 40 CFR Part 257.
When the sludge is being sent offsite to a monofill or
co-disposal landfill that is not owned and operated by
the POTW, the permit writer should contact State,
local and EPA solid waste officials to ascertain
whether the facility is in compliance with 40 CFR
Part 257 requirements. The 40 CFR Part 257
regulations which apply to sludge-only monofills and
co-disposal landfills are summarized in Table 5-1. A
copy of the rule appears in Appendix D.
The criteria promulgated in 1979 (40 CFR Part 257)
represent the minimum regulatory standards that a
State program must apply to solid waste
management facilities. Many States have
incorporated these criteria into State solid waste
management plans. Although EPA has approved 25
State solid waste management plans and partially
approved six others (EPA 1986b), it has not actively
reviewed these State plans since 1981. There are a
number of States without approved programs which
have comprehensive, well-staffed programs that may
meet the minimum criteria for EPA approval. In fact,
a number of States have established regulatory
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Table 5-1 40 CFR Part 257 Required Management Practices for Sludge-Only and Co-Disposal Landfills, Land Application
Sites, and Sludge Lagoons and Stockpiles
Environmental Concern
Management Practice
Floodplains
Endangered Species
Surface Water
Ground Water
Disease
Air
Safety
Facilities in floodplams shall not restrict the flow of the 100-year flood, reduce the temporary water storage
capacity of the floodplam, or result in washout of solid waste, so as to pose a hazard to human life, wildlife, or
land or water resources. (As a matter of policy, EPA expects that if sludge is land-applied to the surface and
incorporated into the soil and if vegetation is grown, the criteria should be satisfied. See p. 40, A Guide to
Regulations and Guidance for the Utilization and Disposal of Municipal Sludge, EPA 1980.)
Facilities shall not cause or contribute to the taking of any endangered or threatened species of plants, fish, or
wildlife, and shall not result in the destruction or adverse modification of the critical habitat of endangered or
threatened species.
Questions about the potential for adversely affecting endangered or threatened species at a particular site
should be directed to the nearest Regional office of the U.S. Fish and Wildlife Service. (Note: Notices of draft
NPDES permits also are routinely sent to the U.S. Fish and Wildlife Services. See 40 CFR 124.10(C).)
Facilities shall not cause a discharge of pollutants into waters of the United States in violation of Section 402 of
the Clean Water Act, shall not cause a discharge of dredged or fill material in violation of Section 404 of the
Act, and shall not cause non-point source pollution that violates an approved Section 208 water quality
management plan.
Facilities shall not contaminate an underground drinking water source beyond the solid waste boundary, or
beyond an alternative boundary. Consult the regulation for procedures necessary to set alternative boundaries
(see Appendix D). To determine contamination, Appendix I of 40 CFR Part 257 provides a list of contaminant
concentrations. Release of a contaminant to ground water which would cause the concentrations of that
substance to exceed the level listed in Appendix I constitutes contamination.
Disease vectors shall be minimized through the periodic application of cover material or other techniques as
appropriate to protect public health.
Facilities shall not engage in open burning of residential, commercial, institutional, or industrial solid waste.
Infrequent burning of agricultural wastes in the field, silvicultural wastes for forest management purposes, land-
clearing debris, diseased trees, debris from emergency clean-up operations and ordinance is allowed.
1. Explosive gases generated by the facility shall not exceed 25 percent of the lower explosive limit for the
gases in facility structures and 100 percent of the lower explosive limit at the property line.
2. Facilities shall not pose a hazard to the safety of persons or property from fires.
3. Facilities within 10,000 feet of any airport runway used by turbojet aircraft, or within 5,000 feet of any
airport runway used by piston-type aircraft shall not pose a bird hazard to aircraft.
4. Facilities shall not allow uncontrolled public access so as to expose the public to potential health and safety
hazards at the disposal site.
requirements for their Subtitle D facilities that are,
in many instances, more stringent than the existing
Subtitle D criteria. States which have approved solid
waste management programs must meet the
permitting requirements as prescribed by RCRA. In
States without approved programs, coordination may
be complicated by the presence of multiple permitting
authorities that permit the landfill or situations
where control is divided between monofills and co-
disposal landfills. State and local regulatory agencies
which may regulate landfills include: solid waste
management agencies, water quality control
agencies, health departments, building departments,
planning and zoning commissions and boards of
county commissioners. Information on State sludge
management requirements is summarized in several
tables presented in Appendix E. Since State
regulatory programs may change from time to time,
the permit writer should not assume that the
information in Appendix E is definitive. Rather, the
permit writer should consult with the appropriate
State agency to determine current requirements and
recommendations.
When permitting POTWs that dispose of their sludge
in monofills, the permit writer should consult State,
local and EPA solid waste officials for information
regarding the monofills used by the POTW. These
authorities may also have permit and
inspection/enforcement files that permit writers
should review. If the sludge-only monofill that a
POTW uses is not in compliance with existing federal
regulations, the permit writer, in conjunction with
enforcement personnel, should take action that will
bring the POTW's sludge disposal into compliance.
An example of such action would be to develop and
attach to the permit a compliance schedule that sets a
date within the term of the permit by which the
POTW will dispose of its sludge in a sludge-only
monofill (or any other method) that complies with
federal requirements. While the appropriate term for
compliance depends on a number of factors, the
potential for harm to public health or the
environment should be the primary consideration.
When permitting POTWs that use co-disposal
landfills, permit writers should consult with State,
local, and EPA solid waste officials to determine if
the co-disposal landfills that the POTW uses are in
compliance with existing federal requirements.
Approximately 80 percent of the nation's municipal
solid waste landfills are inspected at least once a year
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and 25 percent of these landfills have ground water
monitoring systems in operation (EPA 1986b). Thus,
facility performance data may be available for many
of these landfills. If a co-disposal facility is violating
40 CFR Part 257 requirements, the permit writer
should pursue one of the following courses of action
depending upon the sludge/solid waste ratio of the
landfill:
• If sludge comprises a small proportion of the fill
sent to the co-disposal facility (e.g., less than 30
percent of total received mass), the permit writer
should defer to solid waste regulatory officials in
determining an appropriate response.
• If sludge comprises a substantial proportion of
the fill disposed of in a co-disposal facility (e.g.,
more than 30 percent), the permit writer should
work with solid waste regulatory officials in
determining an appropriate response. An
appropriate response will depend on the
availability of more protective use or disposal
alternatives and, most importantly, the potential
for adverse effect on public health and the
environment.
The recommendation that a proportion of 30 percent
sludge to refuse in a co-disposal landfill serve as a
dividing line between deferring to and consulting
with solid waste officials is just a rule of thumb.
There is no scientific basis to this division. It is the
permit writer's responsibility to determine whether
sludge volumes in any amount are increasing the
potential for environmental degradation in each
particular case.
5.2 Technology Guidelines
5.2.1 Sludge-Only Monofills
Most sludge-only landfills consist of a series of
trenches where dewatered sludge is deposited below
ground surface and covered with soil. Other sludge-
only designs include area fill mounds, area fill layers,
and diked containment. Each of these methods
involves sludge deposition above the ground surface.
These above-ground methods are rarely used and will
not be discussed further. Additional information on
all sludge-only disposal methods can be found in
EPA's Process Design Manual: Municipal Sludge
Landfills (EPA 1978).
Both narrow trench and wide trench techniques are
used for the burial of sludge. Narrow trenches are
defined as having widths less than 10 feet; wide
trenches are defined as having widths greater than
10 feet. The depth and length of both narrow and
wide trenches are variable and dependent upon a
number of factors. Trench depth is a function of (1)
depth to ground water and bedrock, (2) sidewall
stability, and (3) equipment limitations. Trench
length is virtually unlimited, but inevitably
dependent upon property boundaries and other site
conditions. In addition, trench length may be limited
by the need to discontinue the trench for a short
distance or place a dike within the trench to contain a
low-solids sludge and prevent it from flowing
throughout the trench (EPA 1978).
A soil cover is normally applied over sludge the same
day that it is received, although cover application
may be less frequent in some cases. The frequency of
cover application optimizes odor control; therefore,
trenches are more appropriate for unstabilized or
partially stabilized sludges than other landfilling
methods. The soil excavated during trench
construction provides the material that is required
for daily cover. Accordingly, soil importation is
seldom required in trench applications (EPA 1978).
Narrow Trench Method
As stated previously, a narrow trench has a width of
less than 10 feet. Sludge is usually deposited in a
single application and a single layer of cover soil is
applied atop this sludge. Relevant sludge and site
conditions as well as design criteria for this form of
disposal include (EPA 1978):
Sludge and Site Conditions for Narrow Trenches
Sludge solids content - 15-20% for 2-3 ft widths
- 20-28% for 3-10 ft widths
Sludge characteristics -
Hydrogeology
Ground slopes
unstabilized or stabilized
deep ground-water and
bedrock
<20%
Design Criteria for Narrow Trenches
Trench width - 2-10 ft
Bulking required - no
Cover soil required - yes
Cover soil thickness - 2-4 ft
Imported soil
required
Sludge application
Equipment
no
1,200-5,600 yd3/acre
backhoe with loader, exca-
vator, trenching machine
The main advantage of a narrow trench is its ability
to handle sludge with a relatively low solids content.
As shown above, a 2- to 3-ft width is required for
sludge with a solids content between 15 and 20
percent. Normally, soil applied as cover over sludge of
such low solids would sink to the bottom of the
sludge. However, because of the narrowness of the
trench, the soil cover receives support from the solid
ground on either side of the trench and bridges over
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the sludge. Cover is usually applied in a 2- to 3-ft
thickness (EPA 1978).
Sludge with a solids content of 20 to 28 percent is
more appropriate for a 3- to 10-ft trench width. Cover
is usually applied in a 3- to 4-ft thickness and
dropped from a minimum height to minimize the
amount of soil that sinks into sludge deposits (EPA
1978).
The main disadvantage of a narrow trench operation
is that it is relatively land-intensive. As shown
above, typical sludge application rates in actual fill
areas (including inter-trench areas) range from 1,200
to 5,600 yd/acre. Generally, application rates for
narrow trenches are less than for other methods.
Another drawback with narrow trench operations is
that the installation of liners is impractical (EPA
1978).
application rates range from 3,200 to 14,500 yd3/acre.
Another advantage of a wide trench is that liners can
be installed to contain sludge moisture and protect
the ground water. When liners are to be used,
excavation may proceed closer to bedrock or ground
water than when narrow trenches without such
protection are used.
One disadvantage of a wide trench is that a sludge
solids content of 20 percent or above is needed. A
sludge solids content of 28 percent or greater is
required to support equipment that may be operated
on the sludge itself. It should be noted that sludge
with a solids content of 32 percent or more will not
spread out evenly in a trench when dropped from
vehicles working outside of the trench. Another
disadvantage of a wide trench is the need for flatter
terrain than that required for narrow trench
techniques.
Wide Trench Method
A wide trench has a width of ten feet or greater.
Relevant sludge and site conditions as well as design
criteria are:
Sludge and Site Conditions for Wide Trenches
Sludge solids content - 20-28% for land-based
equipment
> 28% for sludge-based
equipment
Sludge characteristics - unstabilized or stabilized
deep ground-water and
bedrock
Hydrogeology
Ground slopes
Design Criteria for Wide Trenches
Trench width - >10ft
Bulking required - no
Cover soil required - yes
Cover soil thickness - 3-4 ft for land-based
equipment
4-5 ft for sludge based
equipment
Imported soil - no
required
Sludge application 3,200-14,500 yd3/acre
Equipment track loader, draigline,
scraper, track dozer
As with narrow trenches, wide trenches should be
oriented parallel to one another to minimize inter-
trench areas. Distances between trenches should be
large enough to provide sidewall stability and
adequate space for soil stockpiles, operating
equipment, and haul vehicles (EPA 1978).
One advantage of a wide trench is that it is less land-
intensive than narrow trenches. Typical sludge
5.2.2 Co-Disposal Landfills
At co-disposal landfills, wastewater sludge is
deposited in a landfill together with municipal solid
waste. In this way, the absorption characteristics of
the solid waste and soil conditioning characteristics
of the sludge can complement each other. The solid
waste absorbs excess moisture from the sludge and
reduces leachate migration. Sludge mixed with soil
can also aid in revegetation of the completed landfill.
Sludge/Refuse Mixture
In a sludge/refuse mixture operation, sludge is
deposited at the working face of the landfill and
applied on top of the refuse. The sludge and refuse are
then mixed as thoroughly as possible. This mixture is
then spread, compacted, and covered in the usual
manner at a refuse landfill. Relevant sludge and site
conditions as well as design criteria are presented in
the following table (EPA 1978):
As shown on the following page, sludges with solids
content as low as 3 percent may be received in such
operations. Usually, such sludge is spray-applied
from a tank truck to a layer of refuse at the working
face. The bulking ratio for a 3 percent solids sludge
should be at least 7 tons of refuse to 1 wet ton of
sludge. Usually, only sludges with solids contents of
20 percent or more are mixed with refuse in such
operations and fewer operational and environmental
problems may be expected than when a 3 percent
solids sludge is received. Also, less bulking agent is
required with the higher solids content sludge and
ratios as low as 4 tons of refuse to 1 wet ton of sludge
are successfully practiced (EPA 1978). Some POTWs
use sludge as a top dressing on landfills. For example,
in Chicago the sludge (65% solids) is layered into a
total depth of 9 feet. On at least one level, the landfill
is then sealed with a 2-foot layer of clay.
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Sludge and Site Conditions
Sludge solids content - 3:3%
Sludge characteristics - unstabilized or stabilized
Hydrogeology
Ground slopes
deep or shallow ground-
water or bedrock
Bulking required
Bulking agent
Bulking ratio
Cover soil required
Cover soil thickness
Imported soil
required
Sludge application
Equipment
Design Criteria
<30%
yes
refuse
4-7 tons refuse/wet ton
sludge
yes
0.5-1 ft of interim
2 ft of final
no
500-4,200 yd3/acre
track loader, track dozer
Also as shown above, sludge application rates for
sludge/refuse mixtures compare favorably with other
methods despite the fact that sludge is not the only
waste being disposed on the land. Application rates
generally range from 500 to 4,200 yd3 of sludge per
acre (EPA 1978).
Sfafe Requirements - Sludge/Refuse Mixture
Three States specify loading limits for sludge at
refuse landfills. New Hampshire recommends a 4:1
volume ratio of refuse to sludge, and mandates that
the ratio be no less than 3:1. In addition, sludge must
be dewatered to a minimum 20 percent solids.
Washington requires that the refuse to sludge ratio
be between 4:1 and 5:1 such that the resulting
mixture contain less than 40 percent moisture.
Hawaii requires that the sludge/refuse mixture be
spread and compacted in layers not exceeding 2 feet.
Sludge/Soil Mixture
In a sludge/soil mixture operation, sludge is mixed
with soil and applied as interim or final cover over
completed areas of the refuse landfill. This is not
strictly a sludge landfilling method since the sludge
is not buried. However, it is a viable option for
disposal of sludge at refuse landfills that could be
used in many cases. Relevant sludge and site
conditions as well as design criteria are presented in
the following tabulation (EPA 1978).
One advantage to a sludge/soil mixture operation is
that it removes sludge from the working face of the
landfill where it may cause operational problems.
Other advantages are that the mixture can be used to
support the growth of vegetation over completed fill
areas, a savings in fertilizer can be realized, and
Sludge solids content
Sludge characteristics
Hydrogeology
Ground slopes
Sludge and Site Conditions
^ 20%
stabilized
deep or shallow ground-
water or bedrock
Design Criteria
Bulking required
Bulking agent
Bulking ratio
Cover soil required -
Imported soil
required
Sludge application -
Equipment
<5%
yes
soil
1 soil:l sludge
no
no
I,600yd3/acre
tractor with disc
siltation and erosion problems can be minimized
(EPA 1978).
A disadvantage to a sludge/soil mixture operation is
that it generally has greater manpower and
equipment requirements than would be incurred by
landfilling the same sludge quantity at the working
face. Another disadvantage is that since the sludge is
not completely buried, odors may be more severe than
for sludge/refuse mixtures. For this reason, only well
stabilized sludges are recommended for use in
sludge/soil mixture operations (EPA 1978).
5.3 Characteristics of Sludges Suitable
for Landfilling
5.3.1 Sludge Pollutant Concentration Limits
Federal Regulations
There are no federal pollutant concentration
limitations for sewage sludge that is disposed of in
landfills. The only federal requirement regarding
sludge quality is that hazardous sludges must be
disposed of according to the requirements of RCRA
Subtitle C. Any municipal sewage sludge that is not a
RCRA Subtitle C hazardous waste may be disposed of
at an approved Subtitle D solid waste facility,
provided the practice is allowed by State law.
Case-by-Case Recommendations
A review of federal guidance documents and State
requirements for the disposal of sewage sludge in
landfills revealed no recommended or required
sludge contaminant limits. Therefore, no
contaminant limit recommendations are presented.
Permit writers should set contaminant concentration
limits if they determine such limits are necessary to
protect public health or the environment (e.g.
drinking water supply). The permit writer will have
to document this decision in the permit fact sheet.
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The management practices and site characteristics of
landfills receiving sludges containing high
concentrations of contaminants should be closely
examined.
5.3.2 Sludge Physical Properties
This section will cover recommended sludge
dewatering and stabilization requirements for
sludge-only and co-disposal landfills.
Federal Regulations
Neither stabilization nor dewatering of sewage
sludge are specifically required by 40 CFR Part 257
prior to landfilling.
Federal Guidance
Not all municipal sewage sludges are suitable for
landfilling due to odors from insufficiently stabilized
sludge or operational problems arising from low
solids content. An assessment of the suitability of
various sludge types for disposal in sludge-only
monofills and co-disposal landfills was discussed in
Section 5.2, which provides information on landfill
technologies.
As noted in Section 5.2, sludges with a solids content
less than 15 percent are not suited for disposal in
sludge-only monofills. Sludges having solids contents
less than 15 percent usually will not support cover
material. Obviously, the addition of soil to a low-
solids sludge may act as a bulking agent and produce
a sludge suitable for disposal at sludge-only
monofills. However, soil bulking operations are
generally not cost effective on sludges with solids less
than 15 percent. Further dewatering should be
performed at the treatment plant if sludge-only
monofilling is the disposal option selected.
If suitably designed and operated, co-disposal
landfills can accept sludges with solids contents as
low as 3 percent. However, sludge moisture should
not exceed the absorptive capacity of refuse at a co-
disposal landfill. Accordingly, low-solids sludge
should be received at such sites only if it constitutes a
small percentage of the total waste landfilled (EPA
1978).
Generally, only stabilized sludges are recommended
for landfilling and some degree of stabilization
should occur if landfilling is the selected disposal
option. Stabilization of sewage sludge reduces odors
and reduces vector attraction. Stabilization, however,
is not required by all States. Suggested procedures for
landfilling unstabilized sludges can be found in
EPA's Process Design Manual for Municipal Sludge
Landfills (EPA 1978).
State Requirements
State sludge dewatering regulations vary greatly. A
total of thirty-two States and Puerto Rico require
some degree of dewatering. Six States do not allow
landfilling of sludges containing free liquids. One
State, Oklahoma, will allow free liquids if the site
has a leachate collection system. Thirteen States
specify minimum percent solids allowed: Alaska
requires 10 percent, Idaho and South Carolina
require 15 percent, Massachusetts requires 18
percent, six States require 20 percent, two States
require 30 percent, and Iowa requires 75 percent
solids. Four States require dewatering but do not
specify to what degree, while Connecticut evaluates
the need for dewatering on a case-by-case basis.
Several States have dewatering requirements for
specific types of sludge or landfilling options.
California requires a minimum of 20 percent solids
for primary sludge and 15 percent for secondary
sludge or a mixture of the two. Texas requires a
minimum of 15 percent solids in sludge-only trench
and fill landfills. For filling above the ground surface,
Washington requires 15 to 20 percent solids. The
sludge dewatering requirements for each State are
listed in Appendix E, Table E5-1.
Twenty States require sludge to be stabilized prior to
landfilling. Only Kentucky mandates a stabilization
process or operational criteria (e.g., a certain temper-
ature for a certain length of time). Oklahoma re-
quires that raw sludge must be disposed of in remote
locations. Individual State requirements regarding
stabilization can also be found in Table E5-1.
Case-Jby-Case Recommendations
In general, permit writers should require sludge
solids content be consistent with the design
standards of the monofill or landfill. If the permit
writer finds there is a potential for liquids to leach
into and contaminate ground water, specifying a
sludge solids content in the permit is appropriate.
For co-disposal landfills, the proposed 40 CFR Part
258 regulations would prohibit the disposal of bulk or
non-containerized liquid wastes. Liquid waste has
been defined as any waste that is determined to
contain "free liquids" as defined by the Paint Filter
Liquids Test (as described in "Test Methods for
Evaluating Solid Wastes, Physical/Chemical
Methods," EPA Pub. No. SW-846). Permit writers
may want to consider requiring POTWs to perform
the Paint Filter Liquids Test on sludges with less
than 20 percent solids.
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5.3.3 Landfilling of Sludges Containing
Radionuclides
POTWs that have hospitals or industries discharging
wastes that contain radionuclides into their systems,
or those located in areas of the country where there
are naturally occurring radionuclides in their
drinking and industrial waters, can expect to see
radionuclides concentrating in their sludges. Specific
radionuclides that are common in POTWs are 1*31,
Ra226, U238, Cs137, and Cs137- A more comprehensive
list is provided in Table 6-2 and a more in-depth
discussion is provided in Section 6.2. Two States,
Illinois and Wisconsin, have specific requirements for
sewage sludges containing radium. These
requirements have been included in Table E5-6.
5.4 Operating Conditions and
Management Practices
This section contains federal regulations and
guidance, State requirements, and case-by-case
recommendations for the permit writer to use in
developing permit conditions to regulate the disposal
of sewage sludge. This information can be applied to
both sludge-only monofills and co-disposal landfills.
Required Permit Conditions
At a minimum, the permit writer should include the
federal regulations in the NPDES permit, unless
they are already contained in another permit held by
the POTW. The Interim Strategy requires permit
writers to evaluate Class I POTWs for the potential
need to incorporate additional case-by-case permit
conditions. The permit writer should be aware that
several of these requirements and recommendations
are restrictions that apply to the location of new
landfills rather than the operation and management
of existing landfills. If the permit writer finds that
the POTW is disposing of its sludge in a landfill that
is in violation of the federal regulations for location,
the permit writer should require the POTW to
develop alternate sludge use or disposal options.
5.4.1 Endangered Species Protection
Federal Regulations
Facilities or practices shall not cause or contribute to
the taking of any endangered or threatened species of
plants, fish, or wildlife. The facility or practice shall
not result in the destruction or adverse modification
of the critical habitat of endangered or threatened
species as identified in 50 CFR Part 17 (40 CFR Part
257).
Federal Guidance
In general, sludge landfills should not be located in
environmentally sensitive areas when feasible
alternatives exist. EPA has identified five
environmentally sensitive areas where landfilling
should be avoided (EPA 1978). These include:
wetlands, floodplains, permafrost areas, critical
habitats of endangered species, and recharge zones of
sole source aquifers.
State Requirements
No State has specific regulations governing the
protection of endangered species in its sludge or solid
waste regulations. Of course, all States that have
adopted 40 CFR Part 257 into their State solid waste
management plans will have incorporated
regulations covering endangered species.
Case-by-Case Recommendations
If the POTW is sending its sludge to an existing
landfill that is violating the endangered species
provision (40 CFR 257.3-2), the permit writer should
require the POTW to develop an alternate sludge use
or disposal option. If the POTW is in the process of
siting and constructing a new landfill, the permit
writer should prohibit placement in an
environmentally sensitive area.
5.4.2 Floodplain Restrictions
Federal Regulations
Facilities or practices in floodplains shall not restrict
the flow of the base flood, reduce the temporary water
storage capacity of the floodplain, or result in
washout of solid waste, so as to pose a hazard to
human life, wildlife, or land or water resources (40
CFR Part 257).
State Requirements
Thirty-three States, the Virgin Islands and Puerto
Rico have regulations governing the siting of a
sludge landfill in a floodplain. Seven of those States
have adopted the intent of 40 CFR Part 257, allowing
sludge landfills in floodplains only if they are
protected from flooding by levees or other devices,
and do not restrict the base flood. Fifteen States
prohibit siting a sludge landfill in a floodplain; ten of
these specifically refer to the 100-year floodplain.
Four other States require official approval for a
sludge landfill to be sited in a floodplain. State
regulations regarding sludge-only and co-disposal
landfills located in floodplains are summarized in
Table E5-2.
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5.4.3 Ground Water Protection
Federal Regulations
Federal regulation (40 CFR Part 257) protects ground
water by requiring that sludge-only and co-disposal
landfills shall not contaminate an underground
drinking water source beyond the solid waste
boundary or beyond an alternative boundary
determined in accordance with provisions in the
regulation. Ground water contamination is defined
in 40 CFR Part 257 as introduction of a pollutant that
would cause the maximum contaminant
concentration level specified in Appendix I of 40 CFR
Part 257 to be exceeded, or that would cause an
increase in concentration of a pollutant that already
exceeds the limit listed in Appendix I of 40 CFR 257.
(40 CFR Part 257 is presented in Appendix D of this
document.)
It is well known that metals are more mobile in low
pH soils than in high pH soils and that a soil pH of 6.5
is generally sufficient to prevent the movement of
metals. Soil pH may be a moot question in connection
with landfills with liners and leachate collection
systems. In reviewing permits for unlined landfills,
however, the permit writer should be fully aware of
the possible link between low pH soils, low pH refuse
mixtures and adverse effects on ground water quality
due to metal migration.
There are presently no existing federal regulations
specifically requiring liners and leachate collection, a
minimum depth to ground water from the bottom of
waste disposal areas, or a minimum distance to
nearby drinking water wells. However, the proposed
regulations under 40 CFR Part 258 will require some
design requirements such as a flexible membrane
layer, compacted earth, and leachate collection
systems.
Federal Guidance
One of the primary environmental concerns about
landfilling sewage sludge is the potential for ground
water contamination. The overall EPA program for
the protection of ground water is presented in the
1984 EPA Ground Water Protection Strategy, and
includes elements from other federal legislation. The
elements that are most germane to the question of
sludge disposal are found in RCRA and in the Safe
Drinking Water Act (SOWA).
Ground Water Protection Strategy
The Ground Water Protection Strategy (EPA 1984)
provides for three ground water classification
categories:
Class I - Special Ground Waters are those that are
highly vulnerable to contamination because of the
hydrological characteristics of the areas in which
they occur and are characterized by one of the
following two factors: (a) Irreplaceable, in that no
practical, sufficient alternative source of drinking
water is available to substantial populations; or (b)
Ecologically vital, in that the ground water
contributes to maintaining the base flow for a
particularly sensitive ecological system that, if
polluted, would destroy a unique habitat.
Class II - Current or Potential Sources of Drinking
Water and Waters Having Other Beneficial Uses are
all other ground waters currently used or potentially
available for drinking water or other beneficial use.
Class III - Ground Waters Not Current or Potential
Sources of Drinking Water and of Limited Beneficial
Use are those (1) with a total dissolved solids (TDS)
level over 10,000 mg/1 or (2) so contaminated by
naturally occurring contaminants or human activity
(not associated with a particular waste disposal or
other site) that it cannot be cleaned up using methods
reasonably employed in public water system
treatment, or (3) where yields are insufficient to meet
the minimum needs of an average household.
The Agency released draft Guidelines for performing
ground water classification in December 1986.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) established
the Wellhead Protection (WHP) program for the
protection of ground water. Under this program,
States are to determine the extent of wellhead
protection areas necessary to provide protection from
contaminants that may have an adverse effect on
human health. The SDWA required States to submit
an adequate program to EPA by June 1989.
Some of the major requirements of a wellhead
protection program are to:
• Determine the extent of the wellhead protection
area based on hydrologic and other information,
• Describe a program to protect the water supply
within the WHP area from anthropogenic sources
of contaminants,
• Develop contingency plans for the provision of
alternative drinking water supplies in the event
of well or wellfield contamination, and
• Require that all potential sources of
contamination in a potential WHP area be taken
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into consideration before the construction of new
wells.
Guidance is available from the Office of Ground
Water Protection on the WHP program (EPA 1987b).
Except to the extent that monitoring may be
incorporated into a wellhead protection program,
neither the SDWA nor the Ground Water Protection
Strategy require ground water monitoring in the
vicinity of solid waste disposal facilities.
Subtitle D of RCRA requires that the designers of a
solid waste disposal facility take the proximity to
ground water into consideration during facility
design, and in the placement of observation wells and
sampling stations that may be installed. Monitoring
requirements are not specified under Subtitle D of
RCRA, although they may be specified by State
agencies that administer Subtitle D. However, the
proposed 40 CFR Part 258 regulation will require
ground water monitoring when promulgated.
Under Subtitle C of RCRA, generators of hazardous
waste must meet stringent disposal requirements
including stringent ground water monitoring
requirements. The general requirements are
described in 40 CFR 264.90 through 264.100.
Assuming that the land application or landfilling of
municipal sludge does not entail the disposal of
hazardous materials, ground water monitoring
requirements should be evaluated on a case-by-case
basis after reference to State regulation and in
consultation with State Subtitle D program officials.
Liners and Leachate Collection
Leachate enters the ground water system by both
vertical and lateral movement through the soil.
Careful site selection and attention to design
considerations can prevent or minimize leachate
contamination of ground water. The control of
leachate may be accomplished through:
• Natural conditions and attenuation by the soil
• Imported soils or soil amendments used as liners
and/or cover
• Membrane liners
(EPA 1978)
If a site design includes provisions for leachate
containment (e.g., a liner), a leachate collection
system must be installed. The collection system may
consist of a sump into which leachate collects and is
subsequently drained or pumped to a holding tank or
pond. Leachate may also be collected by a series of
drain pipes or tiles that intercept and channel the
leachate to the surface or to a sump (EPA 1978).
Collected leachate may be handled or disposed of by
one of the following methods:
• Discharge to a wastewater collection system or
haul directly to a treatment plant.
• Recycle through the landfill.
• Evaporation of leachate in collection ponds.
• On-site treatment and discharge to a receiving
stream.
• Transport to chemical waste disposal site.
(EPA 1978)
Depending on the leachate characteristics, volume,
and local regulations, it may be possible to discharge
collected leachate to an existing wastewater system
for subsequent treatment with municipal waste-
water. Local wastewater treatment plant personnel
should be consulted for leachate acceptability to
determine special requirements for discharge to the
treatment plant (e.g., large slugs of highly
contaminated leachate may have to be mixed with
municipal wastewater to prevent plant upset) (EPA
1978). In some cases leachate may have to be
pretreated to reduce high organic and heavy metal
concentrations. An additional source of guidance is
the Guidance Manual on the Development and
Implementation of Local Discharge Limitations under
the Pretreatment Program (EPA, December 1987). To
obtain a copy of this manual contact the Office of
Water Enforcement and Permits (EN-336),
Washington, D.C. 20460.
If discharge to the wastewater system is impractical
or if the leachate is potentially disruptive to
treatment plant operations, on-site treatment or
transportation to a chemical waste disposal site will
have to be utilized (EPA 1978).
On-site treatment may consist of recycling the
leachate through the landfill, placing the leachate in
a shallow basin to allow it to evaporate, or installing
a small (specially designed) treatment plant on site.
The latter alternative should be avoided if at all
possible due to its high cost and the unproven
reliability of such small plants (EPA 1978).
Leachate recycling has been shown to be useful
because it:
• Promotes rapid development of anaerobic
decomposition in the wastes.
• Increases the rate and predictability of biological
stabilization.
• Reduces the volume of leachate to be handled by
evaporation of the water during dry periods.
However, leachate recycling systems are not feasible
at some sites. Areas with high rainfall and high
application rates are not suitable. Its primary
application should probably be restricted to co-
disposal sites in climates where the evaporation rate
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exceeds rainfall to a significant extent (EPA 1978).
Some States are presently considering a ban on
leachate recycling.
A detailed discussion of natural attenuation and
liner systems (soil and synthetic) and leachate
collection and treatment can be found in EPA's
Process Design Manual for Municipal Sludge
Landfills (EPA 1978).
Depth to Ground Water
The technical literature recommends, and some
States require, that a minimum thickness of soil be
maintained between the bottom of the waste disposal
site and the seasonal high ground water table. This
separation prevents ground water from passing
through waste cells and takes advantage of
attenuating properties of the underlying soil.
Recommended minimum separation generally varies
from 2 to 5 feet. Greater separations may be required
for higher than normal soil permeabilities or sludge
loading rates.
State Requirements
Liners and Leachate Collection
Twenty-eight States and Puerto Rico specify some
requirement for liners at sludge landfills. "State-of-
the-art" design criteria and requirements for liner
systems have been adopted by some States, in
particular New Jersey and Massachusetts, in their
solid waste regulations. Five States and Puerto Rico
impose liner requirements based upon case-by-case
site evaluations. The remaining State regulations
vary widely and are not very specific. California
requires liners with a permeability of no greater than
1 x 10 6cm/sec, or a 2-ft thick clay layer. Louisiana
and Illinois mandate a material of certain
permeability and require a thickness of that material
of 3 and 10 feet, respectively. These or equivalent
regulations should be consulted prior to design or
review of any liner system. State liner requirements
are summarized in Table E5-3.
Twenty-seven States have some requirements
regarding leachate collection. Massachusetts
requires leachate collection only at sludge-only
landfills. Two States, Massachusetts and New Jersey,
have incorporated "state-of-the-art" leachate
collection system design standards into their landfill
regulations. New York requires leachate collection if
wet sludge comprises greater than 25 percent of
materials disposed of at the facility each day. Eleven
States require leachate collection but do not specify
any treatment or management criteria. Alabama,
Georgia, and Illinois require leachate collection on a
case-by-case basis. Table E5-3 contains a State-by-
State listing of leachate collection requirements. Five
States specify that leachate should be treated. In
Washington, leachate treatment is required in areas
receiving greater than 25 inches of rainfall per year.
These standards, or their equivalent, should be
consulted before design or review of leachate
collection systems.
Depth to Ground Water
Twenty-three States presently have regulations
requiring minimum separations between the bottom
of disposal facilities and the seasonal high ground
water table. The required separations and the
number of States mandating that separation are
listed below:
Depth to Seasonal
High Water Table (ft)
Number of States
>4
>5
>6
The individual State requirements are listed in Table
E5-2.
Distance to Wells
Sixteen States require a minimum distance between
nearby drinking water wells and a sludge-only or co-
disposal landfill. Distances range from 200 to 1,200
feet, with most States requiring a 1,000 foot
separation. Oklahoma requires disposal facilities to
be 250 feet from private wells and 660 feet from
public water supply wells. New Hampshire requires a
distance of 500 feet for community wells and 1,000
feet for municipal wells. A complete list of each
State's requirements is provided in Table E5-2.
Soil Type
Twenty-two States require some type of soil analysis
in conjunction with landfilling of sludge. Michigan
requires that the landfill soil have clay
characteristics. Montana requires that the
percolation rate not exceed 1.5 in/hr.
Case-by-Case Recommendations
The permit writer should evaluate site-specific
conditions in determining whether it is appropriate
for sludges to be disposed of in sludge-only or co-
disposal landfills that do not have liners and leachate
collection systems or adequate buffers between
ground water and drinking water wells. Among the
important factors to consider are sludge quality, the
value of the ground water resource, the proximity of
ground water uses, ground water flow direction and
velocity, and evidence of migration of contaminants
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from the landfill. Solid waste and ground water
program officials should be consulted in determining
the appropriateness of using a particular landfill for
sludge disposal.
Depth to Ground Water
Generally, a minimum soil buffer (or overburden) of 4
feet is recommended between the bottom of both
types of landfills and the seasonal (annual) high
ground water table at the site. Typically, disposal
facilities that are designed well and perform well
would require less depth to ground water than poorly
designed, poorly managed facilities.
Distance to Wells
While the appropriate distance to drinking water
wells is a site-specific determination, generally a
minimum distance of 500 feet between waste disposal
areas at both types of landfills and drinking water
wells is recommended. Some of the more important
factors to consider in determining an appropriate
setback from drinking water wells are sludge quality,
direction of ground water flow, ground water velocity
and any evidence of migration of contaminants from
the landfill into ground water. If no data are
available for those factors, a conservative setback
may be appropriate.
Additional Permit Conditions
In addition to site specific conditions, other
recommendations for permit conditions that can help
minimize ground water contamination include:
• Sludge pollutant concentration limits
• Sludge solids content requirements
• Compliance schedule for the POTW to identify
alternate sludge use or disposal option.
5.4.4 Surface Water Protection
Federal Regulations
40 CFR 257.3-3 states that a facility or practice shall
not cause a discharge of pollutants that is in violation
of the requirements of the National Pollutant
Discharge Elimination System (NPDES) under
Section 402 of the Clean Water Act. In addition, the
regulation states that the facility or practice shall not
cause non-point source pollution of the waters of the
U.S. No minimum distances to surface waters are
established.
Federal Guidance
Buffer Zones
While the appropriate distance to surface water is a
site-specific determination, a minimum distance of
100 feet between waste disposal areas at both types of
landfills and surface water is generally
recommended. In determining an appropriate
setback from surface waters the permit writer should
consider the adequacy of systems to control
precipitation run-on and run-off, the potential for
leachate migration through the underlying soil or
ground water into the surface water of concern, and
the slope and vegetative cover of the buffer zone.
Run-on/Run-off Controls
The technical literature generally recommends that
all upland drainage be collected and directed around
the landfill to prevent run-off from contacting the
sludge and/or solid waste and thereby prevent surface
water pollution or leachate generation. The drainage
channels may be constructed of earth, corrugated
metal pipe, gunite-lined earthen ditches, or stone-
lined (rip rap) ditches. If the access or on-site roads of
the landfill are paved, they may be used to channel
drainage across the landfill (EPA 1978). The
dimensions for drainage structures should be based
upon accepted storm run-off calculation methods
such as those developed by the U.S. Soil Conservation
Service. Systems to control and divert the 24-hour,
25-year storm around active disposal areas are
recommended.
On the landfill itself, all active and completed site
working areas should be properly graded. The surface
grade should be greater than 2 percent to promote
run-off and inhibit ponding of precipitation, but less
than 5 percent to reduce flow velocities and minimize
soil erosion. If necessary, siltation ponds should be
constructed to settle the solids contained in the run-
off from the site. Straw bales, berms, and vegetation
may be used in conjunction with ponds to control run-
off and siltation on the site (EPA 1978). In addition,
leachate collection systems at the landfill help
mitigate the effects of run-on from storm events.
State Requirements
Buffer Zones
Twenty-two States have limits on the distance
between sludge disposal facilities and surface water.
The minimum distances and the number of States
mandating the distance are listed below:
Distance Surface
Water (ft)
Number of States
50
100
200
300
500
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Wisconsin requires a distance of 300 feet to a river
and 1,000 feet to a lake. The distance required by
Kentucky varies from 250 feet to 1,000 feet. Rhode
Island does not allow facilities to be located in a water
supply watershed. Connecticut sets the distance to
surface water on a case-by-case basis. The State
requirements for the distance from sludge-only and
co-disposal landfills to surface water are listed in
Table E5-2.
Run-on/Run-off Controls
Thirty-six States, Puerto Rico and the Virgin Islands
require some form of run-off control at sludge
landfills; however, few States are very specific about
their requirements. Alabama and Delaware require a
minimum 2 percent slope on the completed fill.
Connecticut and Oklahoma require slopes to be less
than 4 percent, while Vermont and Mississippi
require slopes to be less than 5 percent and 8 percent,
respectively. Alaska and Louisiana recommend the
construction of dikes, levees, or other diversion
devices to control run-off. Finally, Montana, New
Hampshire and New Mexico require that controls be
maintained to divert run-off away from active
disposal areas. State requirements for run-on/run-off
controls are summarized in Table E5-3.
Case-by-Case Recommendations
Complying with the federal requirements for surface
water protection normally requires the installation of
proper run-on/run-off protection at landfills. In
developing permit conditions to protect surface
water, the permit writer should evaluate the
existence and adequacy of run-on/run off control
structures, the type and size of buffer zones, and
management practices used at the landfill. For
instance, the daily cover application at a narrow
trench type monofill may be sufficient to protect
surface water from contamination by sewage sludge
because the cover material forms a bridge over the
sludge. However, daily cover at other types of
landfills does not offer the same degree of protection.
5.4.5 Safety
Federal Regulations
Existing federal regulations (40 CFR Part 257)
pertaining to safety at sludge landfills cover
explosive gases (methane), fires, bird hazards to
aircraft, and access control. Methane gas migration
and control will be addressed separately; fires, bird
hazards and access control are discussed below.
Existing federal regulations pertaining to fires,
access control, and bird hazards to aircraft state:
• Fires - a facility or practice shall not pose a fire
hazard to the safety of persons or property. This
may be accomplished through compliance with 40
CFR 257.3-7 (prohibition of open burning)
through the periodic application of cover material
or other techniques as appropriate, and control of
generation of explosive gases.
• Bird hazards to aircraft - a facility or practice
disposing of putrescible wastes that may attract
birds and which occurs within 10,000 feet of any
airport runway used by turbojet aircraft or
within 5,000 feet of any airport runway used by
only piston-type aircraft shall not pose a bird
hazard to aircraft.
• Access - a facility or practice shall not allow
uncontrolled public access so as to expose the
public to potential health and safety hazards at
the disposal site.
Federal Guidance
The technical literature suggests that water onsite
for fire protection is a factor that should be considered
in the design and operation of a landfill. Insuring
that solid waste and sludge are covered at the end of
each day is also a protective measure against fire.
Access to landfills should be limited to one or two
entrances with gates that can be locked when the site
is unattended. Depending on the topography and
vegetation of the site and adjoining areas, as well as
nearby population density, entrance gates may
suffice to prevent unauthorized vehicular access. At
some sites it is desirable to construct peripheral
fences to keep out any trespassers and animals.
Keeping trespassers and animals off sludge landfills
is more important than for refuse landfills because
the sludge may not be sufficiently stable to support
their weight (EPA 1978).
Fencing requirements will be greatly influenced by
the relative isolation of the site. Sites close to housing
developments may require fencing to keep out
children and to provide a visual screen for the
landfill. Establishing a buffer zone between the
landfill and nearest dwelling also helps limit public
exposure to the landfill. EPA recommends at least a
250-foot buffer. Landfills that are in relatively
isolated rural areas may require a less sophisticated
type of fencing or only fencing at the entrance and
other places to keep out unauthorized vehicles (EPA
1978).
State Requirements
Buffer Zones
Only six States require a buffer zone between sludge-
only and co-disposal landfills and airports. Two
States have adopted the Part 257 standard of 5,000
feet from piston-type only airports and 10,000 feet
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from turbojet aircraft airports. Two States require
10,000 feet of separation between landfills and all
airports. A list of the State regulations regarding
distances to airports is provided in Table E5-2 under
Buffer Zones.
Thirty-two States, Puerto Rico and the Virgin Islands
require some form of access control at sludge
landfills. Seventeen States require either or both
perimeter fencing and locked entrance gates. One
State mandates access by roadway only. A list of
access control requirements for each State is provided
in Table E5-3.
Twenty-one States and the Virgin Islands require
either a separation of landfilling operations from the
facility property line or a separation from the nearest
dwelling, or both. Four States require property line
setbacks of 50 feet. Three States require 100-foot
property line setbacks. Texas requires a 200-foot
setback from the property line and Vermont requires
a 300-foot setback. Idaho will allow a separation
ranging from 100 to 300 feet depending on vegetative
screen.
Separation requirements from the nearest dwelling
range from 200 feet to 3/4 mile, 500 feet being the
most common (See Table E5-2). Nevada requires a
separation from one-quarter to three-quarters of a
mile depending on the class of landfill.
Other requirements include a 100-foot separation
from roads, and a 100-foot separation from highways
and parks. Table E5-2 contains each State's
requirements for buffer zones.
Fire Protection
Only one State, Wyoming, mentions fire protection in
its regulations. The State requires fire lanes and
other forms of fire protection at all sites.
5.4.6 Air Quality Control
Federal Regulations
A facility or practice shall not engage in open
burning of residential, commercial, institutional, or
industrial solid waste (40 CFR Part 257). The facility
also shall not violate applicable requirements
developed under a State Implementation Program
approved under the Clean Air Act.
Federal Guidance
The technical literature suggests that odors at sludge
landfills can be a serious problem unless preventive
measures are taken. The sludge should be covered as
frequently as necessary to minimize odor. Sludge
stabilization reduces odor. Lime or chemical masking
agents can be applied to reduce odors. An effective
means of reducing odors is to limit storage of sludge
at the landfill. Ideally, sludge should be stored at the
wastewater treatment plant (EPA 1978).
In areas where odor is of concern, sludge disposed of
at both types of landfills should be stabilized. Sludge
stabilization processes are discussed in Chapter 3.
Permit writers should consider requiring sludge
treatment processes that reduce volatile solids and
vector attraction for sludges that may be disposed of
near airport runways.
State Requirements
Only two States have regulations covering air
quality or odors. Louisiana requires daily checks for
odor and monthly checks for amines and chlorinated
hydrocarbons. Maryland requires that odors not be
excessive or persistent.
5.4.7 Gas Control
Federal Regulations
Federal regulations (40 CFR 257.3-8) pertaining to
the monitoring and control of methane gas migration
at sludge-only and co-disposal landfills specify that
the concentration of explosive gases generated by the
facility or practice shall not exceed:
• Twenty-five percent of the lower explosive limit
for the gases in facility structures (excluding gas
control or recovery system components) and
• The lower explosive limit for the gases at the
property boundary.
Federal Guidance
Gas is produced by the decomposition of organic
matter in sludge and refuse. The primary gases of
decomposition are methane and carbon dioxide. Some
nitrogen and oxygen are found. Traces of ammonia,
hydrogen sulfide, hydrogen, and volatile organic
species are sometimes found in landfills. The amount
and composition of gases produced depends on the
quantity and characteristics of sludge deposited, the
amount of moisture present, and other factors (EPA
1978). Accumulation of particular gases in enclosed
areas can result in explosions.
Methane, like carbon dioxide, is odorless; unlike
carbon dioxide, methane is relatively insoluble in
water. However, when methane is present in air at
between 5 and 15 percent concentrations, and is
confined in an enclosed area, it is explosive. The
lower explosive limit is defined as the lowest percent
by volume of a mixture of explosive gases that will
propagate a flame in air at 25°C and atmospheric
pressure. Thus, for methane, 25 percent of the lower
explosive limit is 1.25 percent methane in air, and
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100 percent of the lower explosive limit is 5 percent in
air. Methane can move by diffusion through the
sludge into the atmosphere where it is harmlessly
dissipated. The gas can also move laterally from the
landfill into surrounding soils, especially if the cover
material is relatively impermeable. Through lateral
movement, methane could seep into nearby buildings
or utilities. A build-up of methane to a concentration
exceeding the lower explosive limit is hazardous.
Migrating gas can also damage vegetation
surrounding a sludge landfill by excluding oxygen
from the root zone (EPA 1978).
Installation of gas control facilities is not necessary if
the site is isolated and will remain isolated from
inhabited structures. However, when inhabited
structures are near the landfill and monitoring wells
indicate that a structure is threatened, gas migration
controls are required. Migration can be controlled by
installing barriers to gas flow and/or by collection
and venting the gas. Gas control techniques can
generally be classified into permeable and
impermeable methods (EPA 1978).
Permeable Methods
Permeable methods of gas venting usually entail the
installation of a gravel-filled trench outside the filled
area. The trench, which generally extends below the
bottom of the fill area, intercepts migrating gas and
vents it to the atmosphere.
Gravel-packed well vents are often used in
conjunction with lateral-surface vents buried below
the final cover in a gravel trench. Wall vents should
penetrate into the upper waste cell. Waste gas
burners are also often installed above the well vents
(Tchobanoglous 1977).
Gas Extraction and Recovery Systems
An effective method of gas control in refuse landfills
involves the placement of an impermeable barrier
combined with a gas extraction and recovery system
via strategically located forced exhaust vents.
However, such systems are only feasible at larger
landfills and may not be suitable for sludge landfills
because the high moisture content typically found in
sludge does not permit gas movement, and sludge can
enter and clog the evacuation pipes.
State Requirements
Thirty-eight States require some sort of gas
monitoring or control program. Three States have set
concentration limits for methane. Refer to table E5-3
in Appendix E for more information on State gas
control management practices.
5.4.8 Pathogen and Disease Control
Federal Regulations
No facility or practice shall exist or occur unless the
on-site population of disease vectors is minimized
through the periodic application of cover material or
other techniques as appropriate so as to protect public
health (40 CFR Part 257).
Federal Guidance
Cover recommendations for sludge-only and co-
disposal landfills were discussed previously in
Sections 5.1.2. These recommendations are
summarized below:
Impermeable Methods
Placing a barrier of very low permeability material
around the perimeter of the landfill minimizes
lateral gas migration. The movement of gas through
soils can be controlled by using materials that are
more impermeable than the surrounding soil (EPA
1978).
The most common material used for construction of
gas barriers is compacted clay. A clay layer
approximately 2 ft thick is probably adequate. Often,
a thicker layer is required in order to ensure an
adequate seal if the side slope exceeds 50 percent. To
be effective, the clay layer must be continuous. The
clay liner should be constructed as the fill progresses,
because prolonged exposure to air will dry the clay
and cause it to crack. Synthetic membranes may be
considered for the control of migrating gas but their
effectiveness has not been established. PVC is
thought to be the most effective (EPA 1978).
Method
Recommended Cover Thickness
Narrow Trench
Wide Trench
Sludge/Refuse
Mixture
Sludge/Soil Mixture
2-4 ft
3-4 ft (for equipment working
outside the trench)
4-5 ft (for equipment working
inside the trench)
0.5-1 ft interim
2 ft final
None
Daily and final cover applications of 6 inches and 24
inches, respectively, are recommended at both
sludge-only and co-disposal landfills. Stabilization of
sewage sludge prior to disposal is another technique
used to minimize vector attraction.
36
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State Requirements
Twenty-nine States, Puerto Rico and the Virgin
Islands have some requirement for daily,
intermediate, or final cover at landfills accepting
municipal sewage sludge. Fourteen States require 6
inches of daily cover and one State, Iowa, requires 12
inches. Texas requires 6 inches of daily cover over
stabilized sludges and 2 feet over unstabilized
sludges. Four other States require only that solid
waste and sludge be covered at the end of each day.
Intermediate cover is specified by three States.
Mississippi requires 24 inches of intermediate cover,
while New York and Ohio require 12 inches.
Fourteen States specify a depth of final cover: eleven
States require 2 feet, Kentucky requires 2.5 feet, two
States, Oklahoma and Texas, require 3 feet, and New
York requires 4 feet. The State requirements for
cover are listed in Table E5-3.
Twenty-three States indicate that they have
regulations covering pathogen control at sludge
landfills. However, only six States dictate specific
means by which pathogens are to be controlled.
Montana, Virginia, Wyoming, Pennsylvania and
Rhode Island require that, prior to landfilling, sludge
be treated by one of the "Processes to Significantly
Reduce Pathogens" (PSRP) which are described in 40
CFR Part 257, Appendix II, Section A. These
processes include: aerobic digestion, air drying,
anaerobic digestion, composting, lime stabilization,
or any other equivalent method. The required
operating parameters of each of these processes are
described in Appendix II of 40 CFR Part 257.
Illinois requires sludge to be digested at sites when
used as or with a cover. West Virginia requires that
the sludge be demonstrated non-infectious. Alaska
requires that sludge generated in permafrost areas be
disinfected prior to landfilling. The individual State
regulations for pathogen and disease control are
listed in Table E 5-3.
5.4.9 Other State Management Practices
A list of additional State management practices that
were not listed in Tables E5-1 through E5-4 is
provided in Table E5-5.
5.5 Monitoring, Reporting, and Record
Keeping
5.5.1 Sludge Monitoring
Federal Regulations
The current NPDES regulations require sludge
monitoring and reporting at a frequency dependent
upon the nature and effect of the permittee's sludge
use or disposal activities, but at least once a year for
every pollutant limited in the permit. This means
that if the permit contains a limit for cadmium, the
permittee must be required to monitor its sludge at
least annually for this pollutant.
Currently, there are no federal regulations which
require sewage sludge quality be monitored for
specific constituents or characteristics prior to
disposal in a monofill or landfill. The existing federal
regulations stipulate that sewage sludge disposed of
in a landfill shall not be hazardous or cause the
contamination of ground water.
Federal Guidance
In addition to the required compliance monitoring,
the Sewage Sludge Interim Strategy recommends
annual monitoring of the 126 priority pollutants as
well as more frequent monitoring of the pollutants
for which numeric limits have been proposed in the
40 CFR Part 503 Technical Sludge Standards. For
monofills, these pollutants include:
Arsenic
Benzene
Benzo(a)pyrene
Bis(2-ethylhexyl)pthalate
Cadmium
Chlordane
Copper
DDT/DDE/DOD (total)1
Dimethyl mtrosamine
Lead
Lindane
Mercury
Polychlorinated biphenyls
Nickel
Toxaphene
Trichloroethylene
1 DDT-2,2-Bis(chlorophenyl)-l ,1,1 -tnchloroethane
DDE-1,1 -Bis(chlorophenyl)-2,2-dichloroethene
DDD-1,1 -Bis(chlorophenyl)-2,2-dichloroethane
State Requirements
Twenty-one States have regulations that stipulate
sludge quality monitoring at sludge landfills. Four
States mandate that the sludge be tested to
demonstrate that it is non-hazardous. Six States
require monitoring for specific contaminants and
characteristics, including: percent solids, pH,
nitrogen, ammonia, nitrates, PCBs, and metals
(cadmium, copper, lead, selenium, and zinc are
mentioned).
Only four States specified the frequency with which
sludge sampling must occur. Maryland and Michigan
require an initial testing with additional sampling
required as needed based on quality or use. Texas
requires semiannual sampling, while New
Hampshire varies sampling frequency based upon
the size of the treatment plant: plants larger than 1
mgd must be sampled 3 times per year; plants
smaller than 1 mgd must be sampled annually.
Individual State requirements for sludge quality
monitoring can be found in Table E5-4.
37
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If radionuclides in the sludge are a concern and need
to be addressed by the permit writer, then
consideration should be given to at least annual
monitoring of the sludge.
If the permit writer is unsure of the quality of the
sludge or concerned about potential contamination
because sludge quality is poor and landfill design and
operation is marginal, the permit writer should
develop concentration limits and/or monitoring
requirements for pollutants of concern.
5.5.2 Ground Water Monitoring
Federal Regulations
While existing federal regulations prohibit contam-
ination of ground water, they do not specifically
require ground water monitoring at sludge-only or
co-disposal landfills.
State Requirements
Thirty-six States presently have some policy in-place
regarding ground water monitoring at Subtitle D
landfills. Twenty-eight of these States require
monitoring at all sites, while seven States decide on a
case-by-case basis, generally based upon individual
hydrogeologic conditions.
Louisiana and Oklahoma specifically require a
minimum of 1 upgradient and 2 downgradient wells.
New York requires a minimum of 1 upgradient and 3
downgradient wells. Maine requires a minimum of
three monitoring wells but does not specify their
location. Four States require that a ground water
monitoring plan be submitted as part of a permit
application. The individual State requirements are
listed in Table E5-4.
Of the thirty-six States that require ground water
monitoring, only three specify the frequency of
sampling. Michigan and Vermont require quarterly
sampling; Louisiana requires annual sampling.
Only two States, California and Texas, list specific
parameters that must be monitored. These include:
ground water table elevation, temperature, specific
conductance, pH, nitrates, COD, sodium, chloride,
iron, manganese, sulfates, phenol, and sulfur. One
study cited in the literature indicated that State
requirements in Subtitle D landfills often include
monitoring of pH, specific conductance, TDS and
organic carbon (EPA 1986b).
Case-by-Case Recommendations
The permit writer should evaluate site-specific
conditions in determining whether a monitoring
system is necessary. If monitoring is deemed
necessary, the permit writer needs to write
monitoring system specifications (number of wells,
well configuration, etc.) into the permit.
The number of wells required to adequately monitor
a sludge-only or co-disposal landfill is highly site-
specific, and generally depends on the hydrogeologic
conditions at the site and the goals of the ground
water monitoring program. A qualified hydro-
geologist should be consulted to assist in determining
the number of wells required and their location (EPA
1978). Solid waste and ground water program
officials should be consulted when making deter-
minations regarding ground water monitoring at
landfills.
Regardless of the number, monitoring wells should
be placed both upgradient and downgradient of the
facility. Upgradient wells indicate the natural or
background ground water quality at the site, while
downgradient wells measure ground water quality
after it has passed beneath the facility to detect any
contamination. It is highly desirable to install all
monitoring wells and begin sampling at least 6
months to a year before the site is activated to
establish background quality, including any seasonal
fluctuations (EPA 1978).
Information about the ground water flow system can
be determined from monitoring wells. Ground water
elevations should be measured at scheduled
frequencies and the ground water flow gradient
determined. Flow rate of ground water can be
determined using tracers in the monitoring wells.
This information is very valuable in the event of
contamination and should be obtained and utilized in
consultation with a qualified hydrogeologist.
The frequency of ground water sample collection is
dependent upon the specific characteristics of a site,
including aquifer flow rate and the resource value of
the aquifer. Analyses of the initial and second
samplings may suggest an adjustment of the
sampling frequency. Studies indicate that leachates
frequently are released in slugs, or high concentra-
tions, at periodic intervals that are seasonably or
climatically influenced. This may dictate intensified
sampling efforts at certain times. Quarterly
sampling is most often recommended, however,
sampling frequency is site-specific and should be
adjusted if experience indicates that more frequent
samplings are necessary (EPA 1978).
A phased approach is recommended for ground water
monitoring in sludge monofills. In Phase I, samples
should be analyzed for pH, TKN-N, Nitrates, TOC,
and TDS. If Phase I indicates that contamination is
occurring, then more detailed Phase II monitoring
should be required. Phase II analytes should consist
of iron, heavy metals (especially lead), chorides, and
any other drinking water parameters. Monitoring of
all contaminants for which drinking water standards
38
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[called Maximum Contaminant Levels (MCL's)] have
been established (see Appendix I of 40 CFR Part 257)
is recommended so that the extent and degree of
ground water contamination can be determined.
Monitoring ground water for contaminants found in
analyses of the sludge is also recommended (EPA
1978).
The EPA Process Design Manual for Municipal
Sludge Landfills (EPA 1978), recommends monitor-
ing for the following parameters as appropriate: pH,
TDS, nitrate, chlorides, TOC, and heavy metals, and
methylene blue-active substances.
5.5.3 Gas Monitoring
Federal Regulations
The concentration of explosive gases generated by a
Subtitle D facility shall not exceed 25 percent of the
lower explosive limit for gases in facility structures,
and 100 percent of the lower explosive limit for gases
at the property boundary (40 CFR Part 257).
Federal Guidance
The technical literature generally recommends that
sludge-only and co-disposal landfills located near
structures conduct periodic gas monitoring to detect
gas migration and accumulation. In most cases, over
70 percent of the gas volume produced from the
decomposition of solid wastes and sludge consists of
methane and carbon dioxide; methane is the gas of
major concern.
State Requirements
Thirty-seven States and Puerto Rico have some policy
regarding gas migration and control at Subtitle D
facilities. Nine other States cite the limit of less than
25 percent of the lower explosive limit in structures.
Eight States do not have specific numerical
standards but simply state that gas migration and
accumulation should be prevented. Four States
decide upon the need for gas control on a case-by-case
basis. Table E5-3 contains a summary of the gas
control policy for each State.
None of the thirty-seven States that have regulations
governing landfill gas specify sampling frequency.
5.5.4 Surface Water Monitoring
State Requirements
Twenty States presently have some policy regarding
surface water monitoring. A total of twelve States
require surface water monitoring at all sludge
landfills. The remaining eight States have the option
of requiring surface water monitoring on a case-by-
case basis.
Only Maine specifies the number of surface water
sampling stations; a minimum of two. Maryland
requires that a plan for surface water monitoring be
proposed. The individual State requirements are
listed in Table E5-4. No States presently specify
either the frequency of surface water monitoring or
the parameters that should be monitored in their
regulations.
5.5.5 Monitoring for Hazardous Wastes
To fulfill the stipulation that hazardous sludge not be
disposed of in a nonhazardous material landfill, the
permit writer may want to require monitoring to
demonstrate that the sludge is not hazardous.
Currently, the Extraction Procedure (EP) toxicity
test is generally performed to determine whether
sludge is hazardous. The EP toxicity test (40 CFR
Part 261, Appendix II) involves the preparation of
aqueous extract of the suspected hazardous waste,
which is analyzed for the constituents in Table 5.2.
The sludge exhibits the characteristics of EP toxicity,
and therefore is a hazardous waste, if the extract
from a representative sample contains any of the con-
taminants listed in the table at a concentration equal
to or greater than the respective tabulated value.
Effective on September 25, 1990, the Toxicity Char-
acteristic Leaching Procedure (TCLP) (55 FR 11798)
will replace the EP toxicity test. The two main
advantages of the TCLP are that the TCLP evaluates
a greater number of compounds than the EP toxicity
test, and the TCLP more closely mimics the behavior
of pollutants in a landfill. The constituents analyzed
in the TCLP test are listed in Table 5-2. (Note: The
use of the EP in addition to the TCLP may continue to
be required under State law. See 55 FR 11848 Part V
for a complete discussion of compliance dates and
implementation of the TCLP.) Tests of the draft
TCLP performed on 18 municipal sludges have
shown that none of the sludges contained hazardous
levels of pollutants. Several of the sludges, however,
had contaminant concentrations at levels close to
those defined by the TCLP test as hazardous (EPA
1987).
5.5.6 Reporting and Record Keeping
Federal Regulations
The recently promulgated revisions to the NPDES
Permitting Regulation (54 FR 18716) require the
POTW to report monitoring results with a frequency
dependent on the nature and effect of the sewage
sludge use or disposal practices, but in no case less
than once a year [40 CFR 122.44(i)(2)]. The
regulations also require that records required by the
permit for the permittee's sewage sludge use and
39
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Table 5-2 Maximum Concentrations for Contaminants
Analyzed For EP Toxicity and TCLP Tests
Contaminant
A
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
m-Cresol
p-Cresol
Cresol
2,4-D
1 ,4-Dichlorobenzene
1 ,2-Dichloroethane
1,1-Dichloroethylene
2,4-Dmitrotoluene
Endnn
Heptachlor (and its
hydroxide)
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5-Tnchlorophenol
2,4,6-Tnchlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
EP Tox.
Max Cone. (mg/L)
c f\
b.Q
100.0
1.0
-
-
5.0
~
•
-
10.0
-
-
-
-
.002
-
-
-
5.0
04
.4
0.2
10.0
-
-
-
-
-
5.0
-
0.5
-
-
.
1.0
-
TCLP Max Cone.
(mg/L)
K f\
5.U
100.0
Oc
.0
1.0
0.5
0.03
100.0
6.0
5.0
200.0
200.0
200.0
200.0
10.0
7.5
0.5
0.7
0.13
0.02
0.008
0.13
0.5
3.0
5.0
A A
0.4
0.2
10.0
200.0
2.0
100.0
5.0
1.0
5.0
0.7
0.5
0.5
400.0
2.0
1.0
0.2
and quality. Ohio and Oklahoma require a log of
daily operations at the facility.
The frequency with which reports must be submitted
varies from monthly to quarterly to semi-annually.
Only three States specify a reporting frequency in
their regulations.
References
EPA 1978. Process Design Manual: Municipal Sludge
Landfills. U.S. Environmental Protection Agency,
Office of Solid Waste, 1978.
EPA 1984. Ground Water Protection Strategy. U.S.
Environmental Protection Agency, Office of Ground
Water Protection, Washington, D.C., 1984.
EPA 1986a. State Subtitle D Regulations on Solid
Waste Landfills. U.S. Environmental Protection
Agency, Office of Solid Waste and Emergency
Response, Washington, D.C., 1986.
EPA 1986b. Subtitle D - Phase I Report. U.S.
Environmental Protection Agency, Office of Solid
Waste and Emergency Response, Washington, D.C.,
1986.
EPA 1987. Cooperative testing of Municipal Sewage
Sludges by the Toxicity Characteristic Leaching
Procedure and Compositional Analysis, Draft Report,
U.S. Environmental Protection Agency, May 18,
1987.
EPA 1987a. State Requirements for Sludge
Management, U.S. Environmental Protection
Agency, Office of Municipal Pollution Control and
Office of Water Enforcement and Permits,
Washington, D.C., 1987(Revised 1989).
disposal activities must be retained for a period of at
least 5 years [40 CFR 122.21(p)].
State Requirements
Reporting and record keeping requirements vary
widely from State to State. Thirty States require
some degree of reporting and record keeping at
sludge landfills. Seven States require keeping
records of the source of sludge, and sludge quantity
EPA 1987b. Guidelines for Delineation of Wellhead
Protection Areas. U.S. Environmental Protection
Agency, EPA 440/6-87-010, June 1987.
EPA 1988. Guidelines for Ground Water
Classification Under the EPA Ground Water
Protection Strategy. U.S. Environmental Protection
Agency, Office of Ground-Water Protection,
Washington, D.C., 1988.
Tchobanoglous, G. et al., 1977. Solid Waste, McGraw-
Hill, New York.
40
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Chapter 6
Land Application
6.7 Introduction
Currently, about 18 percent of municipal sewage
sludge is applied to the land (EPA 1987a). Land
application options include:
• Agricultural Utilization: Use of sludge as a
source of fertilizer nutrients and/or as a soil
amendment to enhance crop production.
• Forest Utilization (Silviculture): Use of sludge on
forested land to enhance forest productivity.
• Land Reclamation Utilization: Application of
sludge to strip-mined lands, mine tailings, or
other disturbed or marginal land for the purpose
of re vegetation and reclamation.
• Dedicated Land Disposal (OLD); Application of
sludge to soils, with or without vegetation, for the
primary purpose of sludge disposal. This option
differs from the others in that sludge is generally
applied at higher rates and system management
is more intensive. Crop production (if any) is of
secondary importance.
This chapter describes the permit requirements and
recommendations for land application sites. This
section briefly describes each of the different land
application practices. Section 6.2 then provides the
general requirements and recommendations
applicable to all forms of land application. Finally,
sections 6.3, 6.4, 6.5 and 6.6 address any additional
requirements and recommendations for agricultural
utilization, forest utilization, land reclamation
utilization and dedicated land disposal, respectively.
6.1.1 Agricultural Utilization
Hundreds of communities, both large and small, have
developed successful agricultural utilization
programs. Agricultural utilization is especially
common in New Jersey, Pennsylvania, Ohio, Illinois,
Michigan, Missouri, Wisconsin, and Minnesota.
These programs benefit the municipality generating
the sludge by providing an ongoing, environmentally
acceptable means of sludge disposal, and provide the
participating farmer with a substitute or supplement
for conventional fertilizers.
Agricultural utilization assumes that the sludge is
applied at "agronomic rates," defined as the annual
sludge application rate at which the nitrogen (N)
and/or phosphorus (P) supplied by the sludge and
available to the crop does not exceed the annual N
and/or P growth requirements of the crop. Therefore,
assuming contaminant concentrations are low, the
amount of sludge applied to the site is determined by
the available N or P requirement of the crop to be
grown.
Sludge application rates for agricultural utilization
(dry unit weight of sludge applied per unit of land
area) are usually low relative to other land
application practices. Thus, large land areas may be
needed, which may require the cooperation of many
individual land owners. In addition, because of
planting, harvesting and delays caused by adverse
climatic conditions, scheduling sludge transport and
application requires careful management.
6.1.2 Forest Utilization (Silviculture)
Except for certain areas in the Great Plains and the
Southwest, forested lands are abundant and well
distributed throughout most of the United States.
Many major municipalities are located near forests;
in fact, it is estimated that close to one-third of the
land within the standard metropolitan areas is
forested. Furthermore, approximately two-thirds of
all forest land in the United States is commercial
timberland. Thus, the application of sludge to forest
soils has the potential to be a major sludge
utilization/disposal practice.
Studies have shown that sludge application can
greatly improve forest productivity (EPA 1984).
Forest soils have perennial root systems (which allow
year-round application in mild climates), large
amounts of organic material (which immobilize
metals in the sludge) and high infiltration rates
(which reduce run-off and ponding). Another
advantage is that forest products such as wild edible
berries, mushrooms, game and nuts make up a very
small part of the average human diet (EPA 1984).
41
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Studies in forests where sludge has been applied have
suggested that there is no accumulation of trace
metals in the muscle tissue of wild animals (Haufler,
Hest, 1985). Data have also shown no statistical
difference in metal accumulations (Zabowoski and
Zasoski, 1986) in wild berries grown on sludge
amended soil. The primary environmental and public
health concern associated with forest application is
pollution of water supplies (EPA 1984).
Although silviculture is not yet a common practice,
approximately 12 States have silviculture sites.
Silvicultural sludge application may be particularly
beneficial to recently cleared land and newly
established (i.e., 3 to 10 years) forest plantations, as
well as established forests. Municipalities in
Washington have particularly well developed
programs, and the State of Washington has a
guidance document for forest land application
(WDOE 1982).
6.1.3 Land Reclamation
Surface mining, mineral exploration, and deposition
of spoils and tailings from mining operations have
created over 1.5 million hectares (3.7 million acres) of
drastically disturbed land. The properties of these
and other drastically disturbed and marginal lands
vary considerably from site to site. Their inability to
support vegetation is the result of several factors:
• Lack of nutrients - The soils have low N, P, K,
and/or micro-nutrient levels.
• Physical properties - Stony or sandy materials
have poor water-holding capacity and low cation
exchange capacity (CEC). Clay soils have poor
infiltration, permeability, and drainage.
• Chemical properties - The pH of mine soils,
tailings, and some drastically disturbed soils
range from very acidic to alkaline. Potentially
phytotoxic levels of Cu, Zn, Fe, and salts may be
present.
• Organic matter - Little, if any, organic matter is
present.
• Biological properties - Soil biological activity is
generally reduced.
• Topography - Many of these lands are
characterized by steep slopes that are subject to
excessive erosion.
Historically, reclamation of these lands is
accomplished by grading the surface to slopes that
minimize erosion and facilitate revegetation. In some
cases, topsoil is added. Soil amendments such as lime
and fertilizer are added, and grass, legumes, and/or
trees are planted. Although these methods are
sometimes successful, numerous failures have
occurred primarily because of the very poor physical,
chemical, or biological properties of these disturbed
lands.
There have been a number of successful land
reclamation projects involving the use of sludge or
sludge compost. Most have been conducted on strip-
mined land or mine tailings in the Eastern coal
States of Pennsylvania, Illinois, Virginia, West
Virginia, and Alabama. No significant ground water
degradation problems associated with sludge
application have been documented at any of these
sites. Philadelphia has a program which regularly
uses sludge in reclamation projects.
Typically, sludge is applied only once to land
reclamation project sites. Therefore, an ongoing
program of sludge application to disturbed lands
requires that a planned sequence of additional sites
be available for the life of the program. This objective
may be achieved through arrangements with land
owners and mining firms active in the area, or
through the planned sequential rehabilitation of
existing disturbed land areas. In some cases,
reclaimed areas may be used for agriculture
production using agronomic rates of sludge
application.
6.1.4 Dedicated Land Disposal
Generally, a project utilizing land dedicated to sludge
disposal has the following characteristics:
• The primary purpose is long-term sludge
application. Any additional site activities or
benefits such as the production of agricultural
crops or improvement of soil characteristics are
secondary to the sludge disposal activity.
• Normally, sludge application rates are
substantially higher than for other options, e.g.,
agriculture, forest, etc. Obviously, higher
application rates reduce the area of land
required.
• Usually, the municipality owns or has a long-
term lease on the land, which gives the
municipality substantial latitude in use of the
land for sludge disposal.
• The site should be more carefully designed,
managed, and monitored than sites where sludge
is applied at agronomic rates as a fertilizer
amendment to cropland, forest land, etc. Access
restrictions should be in place at all times.
• Site design and operations are focused upon
containing any environmentally detrimental
sludge constituents within the dedicated disposal
site. Surface run-off, ground water leachate, and
42
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harvested crops (if any) are carefully monitored.
Strict controls are almost always required, both
during operation and site closure. Some States
require a notation on the land deed that the site
has been used for land application.
A special case occurs when animal feeds are grown on
land dedicated to sludge disposal. Regulations
generally require operators of these projects to
implement an extensive facility management plan to
prevent adverse environmental impacts or human
health.
6.2 General Requirements and Guidance
for All Forms of Land Application
6.2.1 Permitting Responsibilities
Permits must state that sludge be applied to lands in
accordance with the general 40 CFR Part 257
requirements for solid waste disposal facilities and
practices. (See Table 5-1 in the Landfill Chapter.)
These requirements address floodplains, endangered
species, surface water, ground water, disease, air,
and safety.
To ensure that sludge of an appropriate quality is
applied to lands in a manner that protects public
health and the environment, three types of permit
conditions are needed:
• Sludge quality. The permit should contain
conditions to ensure that the quality of the sludge
is suited to the particular form of land application
practice. It is particularly important that the
permit writer consider the metals content of
sludges that will be applied to soils with a pH of
6.5 or less because metals tend to be more mobile
in low pH soils than in high pH soils and may
have an adverse impact on ground water quality.
• Selection of appropriate application sites. The
permit should contain conditions ensuring that
only sites that are suited to sludge application
are used. For example, it is generally not
appropriate to apply sludge within 200 feet of a
drinking water well. As another example, sludge
should generally not be applied to agricultural
sites where the slope exceeds more than 15
percent; and
• Management of application sites. The permit
should require that application sites be properly
managed. For example, to protect surface waters,
buffer strips should be maintained between the
sludge application site and surface water. To
protect ground and surface waters, sludge should
not be applied during periods when the soil is
saturated.
As the sludge generator, the POTW is always
responsible for sludge quality. However, ensuring
that sludge application sites are selected and
managed properly is not always within the control of
the POTW. Many POTWs employ a contractor to
select and manage sludge application sites. Some
POTWs provide sludge to a farmer who applies the
sludge and manages the site.
To ensure that sludge application sites are selected
and managed properly, permit writers should
consider requiring a POTW either:
• To select and manage application sites itself,
following the conditions set forth in the permit
and the guidelines in the POTWs general land
application plan (discussed in the next
paragraph), EPA's Process Design Manual for
Land Application of Municipal Sludge (EPA
1983), or State or local guidelines that the permit
writer determines are appropriate; or
• To establish contracts with any parties who
assume responsibility for site selection and site
management. Contracts should specify how sites
will be selected or managed (for example, by
reference to the sources described just above).
Contracts should also address issues such as
when the sludge may be applied (for example,
application by heavy vehicles when the soil is wet
may damage soil structure), how much sludge
can be applied and under what conditions sludge
application can be terminated by one of the
parties to the contract (EPA 1984). An example
contract, drawn from the 1984 EPA Intra-Agency
Sludge Task Force Report (EPA 1984) is
presented in Figure 6-1.
A permit that does not require a POTW to select and
manage land application sites itself, and that does
not require the POTW to have contracts with other
parties who select and manage land application sites,
should be based on the recommendations for
distribution and marketing of sludge in Chapter 7.
During the life of the permit, a POTW may apply
sludge to many individual sites. Thus, at the time
that it applies for a permit, the POTW may not be
able to answer important questions such as: where
will the sludge be applied; how does the site compare
to a good set of evaluation criteria; what
management practices should be employed? Permit
writers should consider requiring POTWs to develop
an approvable plan, similar to a Best Management
Practices (BMP) plan, that sets guidelines for how
sludge application sites will be selected and
managed. These plans should not only address the
recommended permit conditions in this Chapter, they
should also address a number of other considerations
such as those discussed in the Process Design Manual
for Land Application of Municipal Sludge (EPA 1983)
43
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THIS CONTRACT, made this
day of
, 19
, hereinafter referred to as Owner, and
, by and between
referred to as City, witnesseth that
WHEREAS, Owner is the owner of a parcel of agricultural real property located in
(COUNTY) Ohio, which can be reached as follows:
, hereinafter
PARCEL NO.), TOWNSHIP) .
, and
WHEREAS, City operates a waste treatment or disposal plant which after processing produces a product known as sewage
sludge, and
WHEREAS, Owner will allow sewage sludge from City to be placed on the above-mentioned real property only on the terms set
out below,
NOW THEREFORE, Owner and City mutually agree as follows:
1. The "Ohio Guide for Land Application of Sewage
Sludge," Bulletin 598 of the Cooperative Extension Service
of the Ohio State University, as revised in May, 1976, shall
be used as a guideline for responsible management prac-
tices. Hereinafter Bulletin 598 will be referred to as "The
1976 Guide."
2. The City will deliver sewage sludge to the above-men-
tioned property of Owner and will properly spread or other-
wise deposit said sewage sludge on said property without
charge to the Owner. City shall be responsible for all equip-
ment used to deliver and spread such sewage sludge.
3. The Owner and the City will mutually agree on the
specific portion of said property which is to receive sludge. In
the absence of unusual factors, they will abide by the site
selection criteria of the 1976 Guide.
4. The Owner or his representative may decline to receive
sludge on said property when, in Owner's or his represen-
tative's judgment, the sludge application equipment would
damage the soil structure because of excessive soil moisture
at the disposal site. When possible, the Owner will give City
notice of poor field conditions 24 hours prior to the appointed
application time. However, the City does realize that this is
not always possible and that there will be some days when
untimely excessive rainfall will require termination of spread-
ing activities at a moment's notice on a given field.
5. The Owner will notify City in writing of the dates
between which City may deliver and spread sewage sludge.
The City may deliver said sewage sludge only during the
period thus described. The Owner will make himself or his
representative available to City or its employees during such
period to ensure said sewage sludge is deposited on the
proper location on said property.
6. Owner shall specify the access to be used by the City
when sewage sludge is applied to a specific portion of said
property. The Owner shall provide and maintain an access
for use by the City without charge to the City, and the City
shall not be liable for any damages thereto, except damage
caused by City's negligence.
OWNER:
Address:
7. Using the criteria of the 1976 guide, the Owner and the
City have mutually agreed on the rates and amounts per acre
said sewage sludge is to be applied during the Contract
period. For the term of this Contract, the City will adhere to
mutually agreed upon application rates listed in Attachment A
which is included as a part of this Contract.
8. The City shall properly analyze its sewage sludge on a
monthly basis for the total nitrogen, ammonia and nitrate
nitrogen, phosphate, potassium, lead, zinc, nickel, copper,
and cadmium content. The results of such analysis will be
provided to the Owner or his representative upon request
without charge before sludge is applied to said property.
9. City shall keep and maintain records of the following
items, and shall make such records available to Owner or his
representative upon request:
(a) All analyses of the composition of sewage sludge
produced by the City.
(b) All reports concerning the operation of production
of sewage sludge by the City.
(c) All applications to agricultural land of sewage
sludge produced by City including dates of
application, amounts applied, specified rates of
application, specific parcels of land upon which
sewage sludge has been applied.
(d) All required governmental permits or approvals for
the application of sewage sludge on agricultural
land.
10. City will deliver and apply sludge which is well stabilized
and which does not present a severe odor nuisance to Owner
or other rural residents who live in the vicinity of the sludge
disposal site. The Owner may refuse to accept any sludge
which is exceptionally odorous.
11. The Contract shall continue in effect for a period of
three years following the date first above written. The Parties
hereto may renew this Contract in writing. Either party may
cancel this Contract by giving written notice to the other party
of the intention to do so. Cancellation will be effective five
days after receipt of such notice. Such notices shall be
delivered personally or by certified mail to the Address(es)
listed at the end of this Contract.
CITY:
By_
Title,
By_
Title
Address:
Figure 6-1. Example land application program contract.
Source: EPA 1984
44
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that are not listed in this Section as recommended
permit conditions. In general, these considerations
are very site-specific in nature and are not easily
summarized as a permit condition. For example, site
soil texture and parent geologic material should be
evaluated because these factors influence
permeability, infiltration and drainage. However,
while highly permeable soil (e.g., sand) and highly
impermeable soil (e.g., clay) may present design and
operational problems, sludge can be successfully
applied to virtually any soil (EPA 1983).
Permit writers should require the POTW to develop
the plan within a reasonable period of time (e.g., four
months) and submit it to the permit writer for
approval. Permit writers should compare the plan to
this guidance, the Process Design Manual and any
State or local guidelines. If necessary, the permit
writer should request that the POTW make changes
to the plan to ensure that sludge application sites are
selected and managed properly. In Regions that have
separate permits and construction grants sludge
coordinators, the construction grants coordinator
may be able to provide assistance in reviewing land
application plans.
A land application plan may not be needed if: 1) the
POTW provides with its application a list of the sites
it will use during the life of the permit, 2)
demonstrates that the sites are appropriate, and 3)
specifies the management practices that it (or a
contractor) will follow. Also, a plan may not be
needed if a State or local agency evaluates land
application sites using criteria that the permit writer
determines will adequately protect public health and
the environment, and has an effective program for
monitoring compliance with appropriate site
management practices.
Permit writers should require POTWs to keep records
identifying the location and owner of each
application site, who applied the sludge, and what
use is made of the site. For example, if a site is used
for agriculture, are fruits and vegetables grown,
other types of food-chain crops, or non-food chain
crops only (e.g., turf or ornamental plants)? With
each subsequent permit application, permit writers
should require POTWs to submit a site-by-site
summary of cumulative loadings of heavy metals
limited in the permit. Also, unless records are
available from a State or local agency showing site
suitability, the POTW should keep records that show,
for each site, what evaluation criteria were used to
select the site, how the site compared to the criteria,
and any site management practices that were
determined to be necessary.
When drafting permit conditions for land application,
the permit writer should first ensure that existing
federal and State requirements will be met. Next, the
permit writer should consider whether further
conditions may be appropriate to protect public
health and the environment. Then, within this
framework, he or she should encourage beneficial
use/recycling (the ultimate selection of sludge
use/disposal practices is up to the municipality). In
many cases using sludge provides environmental
benefits, particularly when compared to current
practices or site conditions. For example, if the sludge
contains high levels of heavy metals, which may
result in loadings of metals that exceed the
recommendations for agriculture, it may be
appropriate to use it if it will clearly improve the
quality of ground water or surface water run-off at a
site that has been strip-mined and is now barren
(particularly if the site is clearly not suitable for
agriculture, or the POTW can assure that the site
will not be used for food-chain crops during the life of
the permit and the metals limits would only be
exceeded by a small amount).
Section 6.2.2 addresses the specific requirements and
guidance concerning sludge quality and Section 6.2.3
addresses the specific requirements and guidance
concerning operation conditions and management
practices. Each topic discussion addresses applicable
federal regulations, federal guidance, and State
regulations. Appendix E presents additional
information on State management practices. Table
E6-5 summarizes State management practices for
land application. Additional land application
management practices specified by only one or two
States are presented in Table E6-6. State
requirements for site-specific considerations are
summarized in Table E6-3. State prohibitions for
land application are presented in Table E6-7. Land
reclamation management practices are summarized
in Table E6-8. Ohio, Arizona and Washington
reported management practices for forest application
(see Table E6-9). Texas reported management
practices for land treatment (i.e. dedicated lands) (see
Table E6-10).
6.2.2 Characteristics of Sludges Suitable for
Land Application
Sludge Pollutant Concentration Limits
Federal Regulations
Pathogens
Permits must state that sludge applied to land will be
treated by a pathogen reduction process that meets
the requirements of 40 CFR Part 257 (See Table 6-1).
Briefly, pathogen reduction is required whether or
not food-chain crops (as defined in 40 CFR Part 257)
are grown. Among other conditions, if public access to
the sludge application site is controlled for twelve
months, the sludge must only be treated by a "Process
to Significantly Reduce Pathogens" (PSRP) (e.g.,
anaerobic digestion, air drying for three months,
45
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composting which includes a minimum 4-hour period
during which the temperature exceeds 55 degrees
Centigrade, and lime stabilization). If the public will
have access to the site within a year of sludge
application, or if the edible portion of a crop that is
grown for human consumption within eighteen
months of application will contact the sludge (e.g.,
root crops such as beets and potatoes or low-growing
crops such as bush beans and strawberries), a
"Process to Further Reduce Pathogens" (PFRP) is
required (e.g., heat drying or composting which
includes a period during which temperature exceeds
55°C for at least three days). 40 CFR Part 257 also
states that land application shall not occur unless
disease vectors are minimized through the periodic
application of cover material "or other techniques as
appropriate so as to protect public health." Treatment
of sewage sludge or septic tank pumpings by one of
the pathogen reduction processes described above
(which substantially reduce the vector attraction of
sludge) should satisfy this requirement.
Polychorinated Biphenyls (PCBs)
Sludge containing concentrations of PCBs equal to or
greater than 10 mg/kg (dry weight), but less than 50
mg/kg, must be incorporated into the soil when
applied to land used for producing animal feed,
including pasture crops for animals raised for milk.
Incorporation of the sludge into the soil is not
required if it is assured that the PCB content is less
than 0.2 mg/kg (actual weight) in animal feed or less
than 1.5 mg/kg (fat basis) in milk (40 CFR Part 257).
Sludges containing greater than 50 mg/kg of PCBs
must meet the requirements of 40 CFR 761.60 which
allow only incineration, disposal in a chemical waste
landfill, or alternate disposal method if approved by
the Regional Administrator.
Other than the pathogen and PCB restrictions
discussed above and a cadmium limit for food-chain
crops discussed further in the chapter, there are no
federal regulations on contaminant levels in sewage
sludge that is land-applied.
Sfafe Requirements
Multi-Grade Pollutant Concentration Limits
At least six States define and regulate more than one
grade of sludge. States with multiple sludge grades
define those grades according to contaminant levels.
In Massachusetts, sludge grading depends on
contaminant levels, stabilization, and content of
putrescible materials. Allowable uses are specified
for each grade along with the degree of State review
required. New Jersey's grades are based on metal
concentration and the length of time a given
concentration could be applied at agricultural rates
before reaching cumulative loading limits. Colorado
Table 6-1 40 CFR Part 257 Pathogen Reduction Requirements
for Land Application and Distribution and
Marketing of Sludges
• Sewage sludge or septic tank pumpings that are applied to the
land surface or incorporated into the soil must be treated by a
Process to Significantly Reduce Pathogens (PSRP). These
processes include:
• aerobic digestion at residence times ranging from 60 days
at 15°C to 40 days at 20°C with a volatile solids reduction of
at least 38%;
• air drying on underdrained sand beds or paved or unpaved
basins in which the sludge is at a depth of nine inches for at
least three months. The average daily temperature must
exceed 0°C for two of these months;
• anaerobic digestion at residence times ranging from 60
days at 20°C to 15 days at 35-55°C with a volatile solids
reduction of at least 38%;
• composting at a minimum operating temperature of 40°C for
five days. For four hours during this period the temperature
must exceed 55°C; and
• lime stabilization in which sufficient lime is added to produce
a pH of 12 after two hours of contact. Other processes may
be acceptable if pathogens and volatile solids are reduced to
an equivalent level.
• When sludge is treated by a PSRP, public access to the site
must be restricted for at least twelve months and grazing by
animals whose products are consumed by humans must be
prevented for at least one month.
• If crops for direct human consumption are grown within 18
months after sludge or septic tank pumpings are applied to a site
and the edible portion of the crop will contact the waste, the
sludge or pumpings must be treated by a Process to Further
Reduce Pathogens (PFRP). PFRPs include:
• composting at a temperature of at least 55°C for three days
if the m-vessel or static aerated pile methods are used. Using
the windrow method, a temperature of at least 55 °C must be
maintained for 15 days and the pile must be turned five times
during this high temperature period;
• heat drying dewatered sludge cake until the moisture content
is reduced to no more than 10%. Sludge particles must be
heated to at least 80 °C or the wet bulb temperature of the
gas stream in contact with the sludge must exceed 80°C at
the point where it leaves the dryer;
• heat treating liquid sludge to temperatures of 180°C for 30
minutes;
• thermophilic aerobic digestion at residence times of ten
days at 55-60°C with a volatile solids reduction of at least
38%; and
• a PSRP followed by either beta or gamma ray irradiation
at a dosage of at least 1.0 megarad at room temperature
(20°C) or pasteurization for at least 30 minutes at a minimum
temperature of 70°C. Other processes may be acceptable if
pathogens and volatile solids are reduced to an equivalent
level.
• The Sludge Regulation and Management Branch of the Office of
Water Regulations and Standards leads a Pathogen Equivalency
Committee which evaluates and makes recommendations on the
equivalency of proposed sludge treatment processes to the
processes identified in 40 CFR Part 257. The Committee also
provides technical assistance to persons preparing proposals for
Committee review. For further guidance please consult "Environ-
mental Regulations and Technology: Control of Pathogens in
Municipal Wastewater Sludge." (EPA September 1989).
46
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sets numerical limits for each grade and specifies the
types of use allowed for each grade. The
contaminants and the multiple grades of sludge
quality regulated by these States are shown in Table
E6-1.
Generally, the States allow certain uses such as land
application only for better quality sludge, Grades 1
and 2 in most cases. New Jersey, taking a resource-
use approach, prohibits landfilling of high-quality
sludge. Allowed uses, application rates, and
safeguards all may vary with sludge quality. Grade 3
and 4 sludge cannot be used on food-chain crops, but
usually is allowed for land reclamation or other uses.
No States have specific contaminant limits for
silviculture or dedicated lands. Some States allow
higher concentrations for land reclamation. See
Table E6-2 for State sludge concentration limits for
use in land reclamation.
Pathogens
In addition to the contaminant concentration
limitations listed in Table E6-1, thirty-four States
have regulations or guidelines addressing pathogen
control. Twenty-one of these States have
requirements similar to the current federal
regulations. Eleven States did not detail their
requirements other than to acknowledge that
pathogen control is required. Note that only the listed
processes in 40 CFR Part 257 Appendix II are
acceptable methods of pathogen control to meet PSRP
and PFRP standards.
Physical Properties
The improvement of the characteristics of the sludge
facilitates ultimate use or disposal. For land
application, the degree of sludge stabilization is a
very important characteristic. Stabilization refers to
a number of processes that reduce the potential for
odor. Stabilization processes also reduce pathogen
levels and usually help to reduce the volatile solids
content. The most common methods of stabilization
include anaerobic digestion, aerobic digestion, lime
stabilization, and composting. Anaerobic digestion is
the most common method of sludge stabilization and
generally biodegrades about 50 percent of the volatile
solids in a sludge. Because much of the organic
matter has already been eliminated, stabilized
sludges tend not to cause odor problems. Low odor
potential is desirable and is sometimes required by
States for land application.
Another sludge characteristic of importance for land
application is water content. Sludge water content
affects the design of a land application program
because:
• The higher the sludge solids content, the lower
the volume of sludge that will have to be
transported, stored, etc., because less water must
be handled.
• The type of transport that can be utilized, e.g.,
type of truck, feasibility of pipeline transport, etc.
depends in part on sludge water content.
• The removal of water reduces the nitrogen
content because much of the nitrogen appears as
ammonia (NH3 + ) and exists in the aqueous
phase.
• The method of sludge application and sludge
application equipment needed (e.g., type of
sludge application vehicle, need for incorporating
the sludge into the soil, etc.), and the methods
available to transfer and store sludge depend in
part on sludge water content.
Treatment processes such as thickening,
conditioning, dewatering, composting, and drying
can lower sludge water content and raise the percent
solids.
Federal Regulations
There are no specific federal regulations for sludge
dewatering. The requirements for pathogen control
discussed previously dictate the degree of
stabilization that is required.
State Requirements
Thirty one States require sludge stabilization prior to
land application (see Table E6-5). Sixteen States
currently have regulations addressing sludge
dewatering requirements for sludge that is to be land
applied. Alaska and Colorado have established
minimum solids content percentages. These are 10
and 16 percent, respectively.
Land Application of Sludges Containing
Radionuclides
Case-by-Case Recommendations
In some areas of the country radionuclides in
wastewater sludges has become an issue. Where
there is a significant level of radioactivity in POTW
sludges, some simple requirements applied to POTW
wastes can reduce potential risks to public health and
the environment.
Any POTW that has a hospital or industry
discharging wastes which contain radionuclides to its
system or is located in an area of the country that has
naturally occurring radionuclides in drinking or
industrial source waters can expect to find
radionuclides concentrating in wastewater sludges.
47
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Fortunately most of the radionuclides used in
hospitals have a short half-life, but this is not the
case with many naturally occurring radionuclides
found in drinking water. The naturally occurring
radionuclides of concern are typically radium,
uranium and radon. The half-life of some
radionuclides that have been identified in POTW
sludges are shown in Table 6-2.
Table 6-2 Half-Life of Radionuclides Identified in POTW
Sludges
Isotope
2ti Am
131|
s'Cr
?5Se
9«Tc
"'OS
226Ra
228Ra
238U
Source
Smoke Alarm
Manufacturers
Nuclear Medicine
Nuclear Medicine
Nuclear Medicine
Nuclear Medicine
Nuclear Fallout
Natural
Natural
Natural
Half-Life
432 y
8.04 d
27.8 d
120 d
6.02 h
N/A
1620 y
6.7 y
4.5 x 109 y
Source: EPA 1986b
Because the sludges containing radionuclides are of
concern in both landfilling and land application,
background soil information helps put the issues into
perspective. The nationwide average concentration of
naturally occurring radionuclides radium-226,
thorium-232 and uranium-238 in soils are each about
1 pCi/g soil and virtually all State averages are less
than 1.5 pCi/g soil (EPA 1989b). Because the half-life
of radium-226 is 1,620 years and the half life of
thorium and uranium isotopes are tens of thousands
to billions of years, one cannot dismiss the
importance of these radionuclides where they are
found in POTW sludges.
One way to obtain information regarding naturally
occurring radionuclides is to check with the States'
water supply staff or obtain local community water
supply information. If the water supply has
significantly less than the 5 pCi/L which is the
maximum contaminant level (MCL) for radium
(combined), then the permit may not need to address
the contaminant. If, on the other hand, the radium
level in water is a significant percentage of the MCL,
then the permit writer should consider putting
specific conditions in the permit. Another
consideration is the concentration of radionuclides
received by the POTW from medical or industrial
wastes which may also necessitate specific permit
conditions. For land application of sewage sludge
containing radionuclides it is recommended that the
soil concentration of a particular radionuclide not be
increased to a significant amount above the
background level of that radionuclide in the soil. A
sample calculation using radium has been provided
in Table 6-3.
EPA's Office of Drinking Water has developed draft
guidance (March 1989) which is directed towards the
land application of drinking water sludges. Although
this information was not developed for wastewater
sludge disposal or use, it may be useful in some
instances. Permit writers identifying a problem with
radionuclides may want to consult this guidance.
Sfafe Requirements
Two States, Illinois and Wisconsin, have specific
requirements for sewage sludges containing radium.
These requirements have been included in Table E7-
11.
6.2.3 Operating Conditions and Management
Practices
This section addresses the operation conditions and
management practices that are required and
recommended of those facilities that land apply their
sludge. The conditions and practices are categorized
into the following eight groups: floodplains, surface
water protection, ground water protection, endan-
gered species protection, safety/access control, sludge
application method and storage.
Floodplains
Federal Regulations
Federal regulations (40 CFR 257.3-1) allow the
location of land application sites in a floodplain.
However, these sites must not restrict the flow of the
base flood, reduce the temporary water storage
capacity of the floodplain, or result in washout of
solid waste, so as to pose a hazard to human life,
wildlife, or land or water resources. The base flood is
defined as the 100-year flood.
Part 257 requires that facilities or practices within
the 100-year floodplain not "result in washout of solid
waste, so as to pose a hazard" to public health and the
environment. EPA has determined that this
requirement should be satisfied if sludge applied to
lands within the 100-year floodplain is incorporated
into the soil and vegetation is grown promptly (EPA
1980).
Sfate Requirements
Twenty-seven States have regulations addressing
land application of sludge in floodplains (see Table
E6-3). Nine States restrict application within the
100-year floodplain. Three of those States indicate
that application within the 100-year floodplain may
be allowed if protective measures such as diversion
dikes are constructed. Eight States use the 10-year
floodplain as the boundary within which land
application is prohibited. Two States allow
48
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Table 6-3 Sample Calculation for Sludges that Contain Radium
1. 226Ra and 228Ra Concentration
Average Sludge Concentration 12 pCi/g
2. Sludge Application:
Typical Example Sludge Application Rate (Nitrogen limited) 30,000 gal/acre
Typical Example % Solids 4.0%
Application Method incorporation, 1 ft
3. Yearly Application Rate of Radium:
= Application Rate x % Solids x Sludge Ra Concentration
= (30,000 gal/acre) x (1 ft3/7.48 ga|) x 62.4 lb/1 ft3) x (1 kg/2.2 Ib)
x (1000 g/1 kg) x (0.04) x (12 pCi/g)
= 5.4 x 107 pCi/yr
4. Weight of Soil:
1 acre-ft of soil weighs 1.639 x 1 o9 g
5. Maximum Increase Allowed in Soil:
The maximum concentration of radionuclides allowed in the soil should be
decided on a case-by-case basis. Limits are set either as a maximum
concentration or as a maximum increase. Guidance exists in Wisconsin,
Illinois, and EPA Office of Drinking Water.
For purposes of this example only, the maximum increase allowed shall be
set at 0.1 pCi/g soil
6. Annual Increase to Soil Radium:
= Radium Yearly Application Rate / Weight of Soil
= (5.4 x 107 pCi/yr) / (1.639 x 109 g)
= 0.033 pCi/g/yr increase
7. Number of Years Sludge Can be Applied at Rate:
= Max. increase of RA allowed in soil / Annual increase to Soil Ra
= (0.1 pCi/g)/(0.033 pCi/g/yr)
3.0 years
application within the 10-year floodplain if the
sludge is injected or incorporated.
Surface Water Protection
Federal Regulations
Federal regulations do not specifically address run-
off controls for surface water protection. However, 40
CFR 257.3-3 does state that a facility or practice shall
not cause non-point source pollution of waters of the
United States that violate applicable legal
requirements implementing an areawide or
Statewide water quality management plan that has
been approved by the Administrator under section
208 of the Clean Water Act, as amended.
Federal Guidance
The EPA Technology Transfer publication Use and
Disposal of Municipal Wastewater Sludge (EPA
1984) recommends the use of good soil conservation
practices and discourages application to saturated,
snow-covered, or frozen ground.
State Requirements
Thirty States have regulations or guidelines for run-
off control (see Table E6-3). The types of control
49
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measures include a minimum vegetative cover
requirement or a requirement that the sludge be
incorporated, avoidance of application during rain or
when soil moisture is high, limitation of the quantity
of sludge applied, and good soil conservation
practices.
Two States relate run-off controls to particular storm
events. Arizona references the 25-year, 24-hour
storm and Texas references the 10-year, 1-hour
storm.
Thirty-three States reported minimum allowable
distances to surface waters (see Table E6-3). The
reported minimum setbacks from surface waters
range from 25 to 3,000 feet and vary with the type of
surface water body and its use. For surface water
bodies used for water supply, the required setback is
typically greater than 300 feet.
Case-by-Case Recommendations
Each facility should be designed to handle a defined
storm event so as to minimize stormwater run-off
related problems. The permit writer should
determine the design storm for a particular State. If
there is no State designated design storm, the 25-
year, 24-hour storm is recommended.
Ground Water Protection
Federal Regulations
Federal regulations (40 CFR 257.3-4) require that
land application facilities or practices not contam-
inate an underground drinking water source or
potential underground drinking water source (any
aquifer with less than 10,000 mg/1 dissolved solids)
beyond the outermost perimeter of the solid waste
boundary (projected in the horizontal plane) as it
would exist at the end of disposal activity. States may
establish an alternate boundary if such a change
would not contaminate drinking water resources.
Contamination of an underground drinking water
source is defined in 40 CFR Part 257 as introducing a
pollutant that would cause the maximum contam-
inant concentration level specified in Appendix I of
40 CFR Part 257 to be exceeded, or that would cause
an increase in concentration of a pollutant that
already exceeds the limit listed in Appendix I of 40
CFR 257. (40 CFR Part 257 is presented in Appendix
D of this document.)
State Requirements
Thirty-three States have rules addressing ground
water monitoring (see Table E6-4). Twenty of these
States indicate ground water monitoring may be
required in some cases. The criteria under which
monitoring would be required are generally not
specified. However, some examples include high
seasonal ground water levels, repeated applications
at a single site, and application rates in excess of the
rate based on nitrogen uptake by crops. Thirteen
States require ground water monitoring. Parameters
measured include depth to water table, nitrates,
metals, organics, pH, and fecal coliform levels.
Minnesota requires semiannual analyses.
Thirty-four States reported minimum allowable
distances to wells (see Table E6-3). The distance
required varies with the use of the well. Land
application sites must generally be 500 feet or more
from public water supply wells. The required setback
from private water supply wells ranges from 100 to
500 feet.
Thirty-five States reported minimum allowable
depths to ground water (see Table E6-3). The
minimum depths range typically from 1 to 10 feet,
although Arizona requires that the mean annual
ground water elevation be at least 40 feet below the
surface. The lower end of the range in several cases
refers to the seasonal high water level. Illinois
specifies a minimum depth of 10 feet for the
application of liquid sludge and 5 feet for the
application of solid sludge and notes that
permeability is also a factor, and Texas allows a
decrease in required depth from 4 to 3 feet if the soil
has "slow permeability."
Nine States reported minimum allowable depths to
bedrock (see Table E6-3). The allowable depths range
from 20 inches to six feet.
Endangered Species
Federal Regulations
Land application facilities or practices shall not
cause or contribute to the taking of any endangered
or threatened species of plants, fish, or wildlife. In
addition, the facilities or practices must not result in
the destruction or adverse modification of the critical
habitat of a federally-listed endangered or threatened
species (40 CFR 257.3-2).
Sfafe Requirements
No States were identified as having specific regula-
tions or guidelines addressing endangered species.
Safety/Access Control
Federal Regulations
Owners and operators of land application sites are
required by 40 CFR 257.3-8 to limit exposure of the
public to any potential health and safety hazards. For
sites where sludge has been treated by a Process to
Significantly Reduce Pathogens, public access must
be controlled for at least 12 months after sludge
50
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application, and grazing by animals whose products
are consumed by humans must be prevented for at
least one month (40 CFR 257.3-6).
If crops for direct human consumption are to be
grown within 18 months subsequent to sludge
application or incorporation, the sludge must be
treated with a process to further reduce pathogens
(PFRP). These processes are listed in 40 CFR Part
257 Appendix II and Chapter 3 of this document. If
the sludge will not contact the edible portions of the
crop, pathogen reduction to PSRP levels is acceptable
(40 CFR Part 257). 40 CFR 257.3-8 requires that a
facility or practice within 10,000 feet and 5,000 feet of
airport runways for turbojet and piston-type aircraft,
respectively, shall not pose a bird hazard to aircraft.
Federal Guidance
The extent of access control needed to limit exposure
to a land application site should be based on these
site-specific considerations: 1) the degree to which
the sludge has been treated to reduce pathogens, (2)
the procedures used to apply and incorporate the
sludge into the soil, (3) the remoteness of the sludge
application site from public use areas, and (4) the
ownership of the site area, whether private or public.
In general, if there is potential for exposure of the
public to health or safety hazards, some sort of
positive access control must be implemented, the
exact means dependent on those considerations listed
above (EPA 1983).
State Requirements
Thirty-five States have requirements for access
control and/or grazing restrictions (see Table E6-5).
The most common practice is the same as the federal
requirement to control public access for at least 12
months after sludge application. Twenty-one States
have buffer zone requirements (see Table E6-3). Six
States reported minimum allowable distances to
roads, ranging from 15 to 300 feet. Twelve States
reported minimum allowable distances to property
lines, ranging from 25 to 500 feet. The required
distance is typically less for subsurface sludge
application than for sludges applied to the surface.
The most frequently cited setback from property lines
was 50 feet.
The setbacks that States require from dwellings
varies with the type of application and the density or
perceived sensitivity of nearby developments. The
most commonly recommended setbacks range from
250 to 500 feet. If the sludge is injected or
incorporated, the required setback is typically
between 50 and 250 feet. Setback requirements are
generally greater near schools, institutions,
recreational areas, or residential subdivisions. These
setbacks range from 600 to 1,000 feet.
Air Quality Control
State Requirements
Only three States have regulations or guidelines
addressing maintenance of air quality and odor
control. Rhode Island, Washington, and Wisconsin
reported rules requiring odor controls, but methods
for odor control were not specified.
Soil Characteristics
Soil characteristics can have a direct affect on both
surface and ground water. Soil characteristics of
concern for a land application site include soil
permeability, soil pH, and soil cation exchange
capacity. Soil cation exchange capacity is an indirect
measure of the soil's ability to capture positive ions,
the form in which most metals are found in the soil.
High soil pH immobilizes most metals and reduces
their absorption by plants. However, it has not been
demonstrated that pH control is necessary on forested
sites where soils are naturally acid (EPA, 1986a).
Permeability refers to the ease with which water is
transmitted through soil. Soils with very low
permeability are poor candidates for land application
due to ponding, potential for run-off problems, and
subsequent limitations in allowable loading rate.
Soils with very high permeability are also ill-suited
to land application where leaching to the ground
water aquifers is a concern.
Federal Regulations
The only federal regulation with regard to soil
characteristics is the allowance of cumulative
cadmium application rates over 5 kg/ha on food-chain
croplands in cases where the background soil pH is
greater than 6.5 and the soil cation exchange
capacity is 5 meq/100 g or greater. If the background
soil pH is less than 6.5, the maximum allowable
cumulative cadmium application rate can still be
greater than 5 kg/ha provided that the pH of the soil
and sludge mixture is adjusted and maintained at 6.5
or greater, or if the only food-chain crop produced is
used solely for animal feed and other requirements
are met (See Appendix D).
Federal Guidance
The Process Design Manual for Land Application
(EPA 1983) contains the following guidelines for the
permeability of the most restricting soil layer above a
1-meter depth and its associated degree of limitation
for agricultural sludge application:
51
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Permeability (cm/hr)
<0.08
0.08 - 0.24
0.24 - 0.8
0.8 - 2.4
>2.4
Degree of Limitation
Severe
Moderate
Slight
Moderate
Severe
Soil permeability characteristics alone do not limit
sludge utilization. It is important in combination
with other site conditions including slope, depth to
ground water, and rainfall patterns.
State Requirements
Only four States have specific numerical criteria for
soil permeability (see Table E6-3). Minnesota does
not allow land application at sites where the
permeability is less than 0.2 inches/hr (0.5 cm/hr) or
greater than 6 inches/hr (15 cm/hr) throughout the
top five feet of soil. Kentucky does not allow land
application where the permeability is less than 0.2
inches/hr (0.5 cm/hr) or greater than 20 inches/hr (51
cm/hr). Vermont and Wisconsin do not allow land
application where the soil permeability is greater
than 6 inches/hr (15 cm/hr). Several States have
requirements for a minimum depth of permeable soil
or the texture of the soils present at the site. In
general, these States require 2 feet of permeable soil.
Texture requirements range from sandy loam to silty
clay.
Twenty-five States have pH regulations (see Table
E6-5). The most common requirement is that the pH
of the soil or sludge/soil mixture be at least 6.5. Four
States specify that the pH must be maintained at 6.5
or greater for a period of time after application
(typically two years).
Topography
Topography influences surface and subsurface water
movement, which in turn affect the soil erosion and
potential run-off of applied sludge. Topography can
indicate the kinds of soil to be found on a site. Soils on
ridge tops and steep slopes are typically well drained,
well aerated, and usually shallow. Steep slopes
increase the possibility of surface run-off of sludge
unless very permeable soils are present. Soils on
broad flat lands frequently are poorly drained, and
may be waterlogged during part of the year. The soils
between these two extremes will usually have
intermediate properties with respect to drainage and
run-off.
Federal Guidance
To protect surface waters, permit writers should
require that the recommended slope limitations in
EPA's Land Application Manual, or similarly
protective State or local guidelines, be followed.
Table 6-4 presents those recommendations.
State Requirements
A review of State regulations indicates the same
general slope limitations as presented in Table 6-4
(see Table E6-3). Thirty-six States have regulations/
guidelines regarding the slopes allowable for sludge
application sites. The typical requirement is a
maximum allowable slope ranging from 5 to 15
percent. The maximum allowable slope typically is
higher if the sludge is incorporated into the soil or if
"solid" or "cake" sludge is used rather than liquid
sludge.
Sludge Application Methods and Seasonal
Restrictions
State Requirements
A few States have specific provisions for sludge
application methods. Michigan requires sound
agricultural practices (e.g. avoid soil compaction).
New Jersey requires uniform applications for land
application. South Dakota specifies that the sludge
application vehicles should have deflection plates.
West Virginia requires the equipment to have high
flotation tires for land application.
Twenty-one States have requirements addressing
incorporation of the applied sludge (see Table E6-5).
Four States specify incorporation if the PCS content
of the sludge is greater than 10 ppm. Five States
require incorporation within 48 hours. Oklahoma
requires incorporation at the time of application.
Twenty-eight States have seasonal limits on land
application of sludge (see Table E6-5). In general,
these regulations prohibit application during
rainfall, on saturated ground, or on ice/snow-covered
ground. Application to frozen or snow-covered ground
is allowed in some States at sites meeting certain
slope restrictions. These restrictions usually require
slopes less than 2 to 6 percent.
Case-by-Case Recommendations
Sludge should not be applied during periods of
inclement weather. In some States, sludge should not
be applied to soils that are frozen or covered with
snow (see Table E6-5). Soil moisture is a major
consideration which impacts the timing of sludge
application. Traffic on wet soils during or
immediately following heavy rainfalls may result in
compaction and, in the case of agriculture, reduced
crop yields. Muddy soils also make vehicle operation
difficult. Application to frozen or snow-covered
ground with greater than 3 percent slope may result
in excessive run-off into adjacent streams.
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Table 6-4 Recommended Slope Limitations for Land Application of Sludge
Slope Comment
0-3% Ideal; no concern for runoff or erosion of liquid sludge or dewatered sludge.
3-6% Acceptable; slight risk of erosion; surface application of liquid sludge or dewatered sludge okay.
6-12% Injection of liquid sludge required for general cases, except if closed drainage basin and/or extensive runoff
control. Surface application of dewatered sludge is usually acceptable.
12-15% No liquid sludge application without effective runoff control; surface application of dewatered sludge
acceptable, but immediate incorporation recommended.
> 15% Slopes greater than 15% are only suitable for sites with good permeability where the slope length is short and
is a minor part of the total application area.
Source: EPA 1983
Storage
Storage facilities are needed to hold sludge during
periods of inclement weather, equipment breakdown,
frozen or snow-covered ground, or when access would
damage the field or crop.
Federal Guidance
The volume of storage required may range from the
equivalent of 15 days production in climates where
weather rarely prevents sludge application to 160
days in cold, damp climates where sludge application
may be impossible over much of the year (EPA 1984).
A very conservative design for storage capacity is for
1 year's production (EPA 1983).
State Requirements
Three States have regulations regarding sludge
storage needs. Indiana and Missouri require a
minimum 90-day and 30-day storage capacity
respectively. Michigan limits field storage to less
than 7 days unless the sludge is covered and a
seepage barrier provided.
6.2.4 Monitoring, Reporting, and Record
Keeping
This section discusses compliance and environmental
monitoring requirements, reporting and recordkeep-
ing for land application sites. Elements of the land
application system that may require monitoring
through the life of the project include the quality of
the applied sludge, the soil, the crop, ground water,
and surface water.
Sludge Monitoring
Federal Regulations
The current regulations require sludge monitoring
and reporting at a frequency dependent upon the
nature and effect of the permittee's sludge use or
disposal activities, but at least once a year for every
pollutant limited in the permit. This means that if
the permit contains a limit for PCB's for example, the
permittee must monitor its sludge at least annually
for this pollutant. (40 CFR 122.44(c)(2)). Also a
minimum of annual monitoring is obviously
necessary to demonstrate compliance with the 40
CFR Part 257 contaminant regulations for cadmium,
PCBs, and pathogens.
Federal Guidance
Regular sludge quality analyses are necessary to
ensure that unacceptable quantities of sludge
constituents are not applied to the site. The frequency
of sludge sampling will be a function of:
• System size - A larger system should sample
more frequently.
• Historical variations in sludge characteristics -
The greater the variability that has been found in
sludge physical and/or chemical characteristics,
the more often the sludge should be analyzed.
Where no historical data exist, monitoring should
be more frequent to build a database.
• Land application option being used - Dedicated
land disposal sites may require the same
frequency of monitoring as landfills. Land
reclamation, forest application, and agricultural
application sites generally require intermittent
monitoring (EPA 1983). The quality of sludges
applied to food-chain croplands should be
frequently monitored.
• The industries discharging to the POTW.
• Problems and/or compliance history of the
POTW.
Sludge should be analyzed periodically for pH,
percent solids, nitrogen, phosphorus, potassium,
heavy metals, and any other contaminants listed in
the facility permit. If the system used is sensitive to
53
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pathogens and/or priority organics, these parameters
should also be measured (EPA 1983).
The Sewage Sludge Interim Permitting Strategy
recommends annual monitoring of the 126 priority
pollutants as well as more frequent monitoring of the
pollutants for which numeric limits have been
proposed in the 40 CFR Part 503 Technical Sludge
Standards. For the disposal practice of land
application these pollutants include:
Table 6-5 Sludge Monitoring Programs for Two
Agricultural Land Applications
Frequency
Lead
Lmdane
Mercury
Nickel
Polychlormated biphenyls
Selenium
Toxaphene
Zinc
Aldnn/dieldrin
Benzo (a) pyrene
Cadmium
Chlordane
Copper
DDT/DDE/DDD (total)
Heptachlorobenzene
Hexachlorobutadiene
1 DDT-2,2-Bis(chlorophenyl)-1,1,1 -trichloroethane
DDE-1,1 -Bis(chlorophenyl)-2,2-dichloroethene
DDD-l,1-Bis(chlorophenyl)-2,2-dichloroethane
State Requirements
Thirty-six States have regulations addressing sludge
monitoring. These regulations are summarized in
Table E6-4 (summary of State monitoring and
reporting requirements). The parameters typically
monitored include:
• Percent solids
• pH
• Nutrients - nitrogen, phosphorus, potassium
• Metals - arsenic, cadmium, chromium, copper,
lead, mercury, nickel, selenium, zinc
• PCBs.
Other parameters monitored by some States are
conductivity, benzene, and EP toxicity. The
frequency of sludge sampling is often related to the
size of the treatment facility. In Kentucky, for
example, facilities less than 1 mgd in size are only
required to sample annually. Facilities between 1
and 2 mgd must sample semi-annually. Facilities
between 2 and 10 mgd are required to sample
quarterly. Facilities greater than 10 mgd are
required to sample monthly. Three States require
sampling and analysis prior to each application of
sludge. The testing and monitoring program for
sludges applied to land as part of Madison,
Wisconsin's METROGRO operation and Salem,
Oregon's BIOGRO operation are summarized in
Table 6-5. In both of these programs, digested sludge
is applied to privately-owned farmland.
Constituent Measured
Aldnn/Dieldrin
Aluminum
Ammonia Nitrogen
Arsenic
Benzene
Benzidme
Benzo(a)pyrene
Benzo(a)anthracene
Bis(2-ethylhexyl)phthalate
Boron
Cadmium
Calcium
Carbon Tetrachlonde
Chlordane
Chloroform
Copper
Cobalt
Conductivity
Chromium
Cyanide
3,3-Dichiorobenzidme
Dichloromethane
2,4-Dichlorophenoxy Acetic Acid
Dimethyl Nitrosamme
Dissolved Solids
Endnn
Fecal Coliform
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Iron
Lead
Lmdane
Lithium
Magnesium
Malathion
Manganese
Mercury
Molybdenum
Nickel
PCB
Pentachlorophenol
pH
Phenanthrene
Phenol
Priority Pollutant Scan
Salmonella
Selenium
Strontium
Tetrachloroethylene
Total Nitrogen
Total Phosphorus
Total Potassium
Total Solids
Total Sulfur
Toxaphene
2,4,6-Trichlorophenol
Vinyl Chloride
VSS Reduction
Zinc
Madison, Wl
Bi-monthly
Semi-annual
Daily
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Semi-annually
Bi-monthly
Semi-annually
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Semi-annually
Monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
-
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Semi-annually
Bi-monthly
Bi-monthly
Semi-annually
Semi-annually
Bi-monthly
Semi-annually
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Annually
Bi-monthly
Bi-monthly
Semi-annually
Bi-monthly
Daily
Bi-monthly
Bi-monthly
Daily
Semi-annually
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Salem, OR
-
-
Monthly
Quarterly
-
-
-
-
Quarterly
Monthly
-
-
-
-
Monthly
-
-
Quarterly
-
-
-
-
-
Quarterly
-
-
-
-
-
Quarterly
Quarterly
-
-
Quarterly
-
Quarterly
Quarterly
Quarterly
Monthly
-
-
Quarterly
-
-
Monthly
-
Quarterly
-
-
Monthly
Monthly
Monthly
Monthly
-
-
-
-
-
Monthly
Source: EPA 1983, METROGRO 1989.
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Case-by-Case Recommendations
If a particular pollutant, such as radionuclides, is a
concern, consideration should be given to more
frequent monitoring of the sludge for that pollutant.
Sludges applied to lands used for producing food-
chain crops should be monitored more frequently
than is generally recommended in other land
application processes. The pH of the sludge-soil
mixture should be measured each time sludge is
applied to food-chain croplands and whenever food-
chain crops are grown. Once, during the first year of
the permit, the soil cation exchange capacity of food-
chain croplands where sludge is applied should be
measured.
So/7 Monitoring
Federal Regulations
There are no federal regulations addressing soil
monitoring at land application sites.
Federal Guidance
The need for soil monitoring depends on the site
characteristics and the particular land application
option being used. In general, monitoring
requirements for dedicated land disposal sites are
more extensive than for other land application
options.
The major parameters of concern for agricultural
land application are pH maintenance at 6.5 standard
units or greater to reduce potential metal migration;
cation exchange capacity (CEC), and soil nitrogen,
phosphorus and potassium if optimum crop yields are
a project goal. If sludge is applied at or below
agronomic rates, EPA recommends analyses of the
soil for pH every year sludge is applied and for cation
exchange capacity once during the life of the permit
and every 2 years for other parameters (EPA 1983).
Soil constituents of interest in forest application
systems include pH, metals, and nutrients. Forest
soils are typically more acidic than agricultural sites;
soil pH values of 5.5 and lower are common.
Experience with sludge applications to forest soils in
established forests indicates that the increased
metals available due to lower soil pH do not cause
phytotoxicity in most forest plant species. In addition,
because forest products are not food chain crops,
increased metal content of the plants themselves is
not a concern for public health. For these reasons,
lower pH limits can be allowed with forest
application, if there is no danger of trace metal
migration to useful aquifers (EPA 1983).
The Process Design Manual for Land Application of
Municipal Sludge (EPA 1983) contains a suggested
minimal monitoring program for land reclamation
sites. Elements of this program for soils include:
• Collection of samples prior to sludge application.
Samples of topsoil should be collected throughout
the site and analyzed for buffer pH to determine
lime requirements to raise the soil pH to 6.5 and
to determine the CEC. Samples from the
complete soil profile should be collected at depths
from 0 to 6 inches, 6 to 12 inches, 12 to 24 inches,
and 24 to 36 inches.
• Samples should be collected again one year
following sludge application. These samples
should be taken at depths of 0 to 6 inches, 6 to 12
inches, and 12 to 24 inches.
Samples collected prior to application and 1 year
following application should be analyzed for pH,
phosphorus, calcium, magnesium, potassium,
sodium, iron, aluminum, manganese, copper, zinc,
chromium, cobalt, lead, cadmium, nickel, and
Kjeldahl nitrogen. At the end of the second year after
sludge application, surface soil samples should be
collected and analyzed for pH to determine if it is still
at 6.5.
Sfafe Requirements
Twenty-three States have soil sampling/monitoring
requirements for land application (see Table E6-4).
Generally, the States require pre-application soil
sampling and follow-up sampling after application.
The frequency of follow-up sampling varies. Three
States require annual monitoring. The parameters
measured include pH, CEC, nutrients, metals,
conductivity, PCBs, and organic matter content.
Table 6-6 summarizes the soil analyses and sampling
frequency for agricultural land application
operations in Madison, Wisconsin and Salem,
Oregon.
Three states have separate requirements for soil
monitoring at land reclamation sites. Arkansas
requires monitoring prior to application and then
annually following application. In Illinois, the
monitoring program is proposed by the applicant at
the time he seeks a permit for sludge disposal at a
land reclamation site. New Jersey requires soil
monitoring.
Vegetation Monitoring
Vegetation monitoring is usually only necessary if
heavy sludge application rates are used, as with a
dedicated disposal site, and there is concern that food
chain vegetation being grown on the site may be
accumulating potentially harmful quantities of
heavy metals, particularly cadmium, from the sludge
amended soil.
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Table 6-6 Soil Monitoring Programs for Two Agricultural Land Application Operations
Monitoring Frequency
Soil-Plow Layer Soil-Subsoil Layer
Constituent Salem, OR
Aluminum Prior to application
Boron Prior to application
Cadmium Prior to application
Calcium Prior to application
CEC Prior to application
Chromium
Conductivity Prior to application
Copper Prior to application
Iron Prior to application
Lead Prior to application
Magnesium
Manganese Prior to application
Mercury Prior to application
Molybdenum Prior to application
Nickel Prior to application
Organic Matter Annually during application
pH Annually during application
Phosphorous: Available Annually during application
Phosphorous: Total
Potassium: Available Annually during application
Potassium: Total
Sodium Prior to application
Zinc Prior to application
Federal Regulations
There are no federal regulations addressing
vegetation monitoring at land application sites.
Federal Guidance
Generally, if sludge is applied at low agronomic rates
there is little need to sample and analyze the
vegetation. Table 6-7 contains a list of potential crop
monitoring parameters for agricultural crops (EPA
1983). Actual parameters monitored may vary from
this list, depending on the sludge constituents of
concern.
State Requirements
Madison, Wl Salem, OR Madison,
Prior to application
Prior to application
Prior to application Every three
Prior to application
One time Prior to application
Every three
Prior to application
Prior to application Every three
Prior to application
Every three
Prior to application
Prior to application
Prior to application
Prior to application
Prior to application Every three
Every three years
Every three years - -
_ _ _
Every three years
_
Every three years
- - -
Prior to application Every three
Wl
years
years
years
years
years
years
Table 6-7 Potential Crop Monitoring Parameters
A. Heavy Metals
B. Macronutnents (optional)
C. Other Elements or Constituents*
Cadmium
Copper
Molybdenum
Nickel
Zinc
Nitrogen
Phosphorus
Potassium
Antimony
Arsenic
Chromium
Iron
Manganese
Mercury
Selenium
PCBs
Ten states have regulations addressing crop
monitoring and plant tissue sampling and analysis
(see Table E6-4). Illinois and Maine indicate analyses
may be required for some sites. Idaho requires
biennial analyses for metals.
* The constituents listed under C are analyzed only if there are
significant quantities contained in the sludge being applied, and
the constituent may enter the food chain.
Source: EPA 1983.
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Ground Water Monitoring
Ground water monitoring may be required to ensure
that an application site is not contaminating ground
water aquifers in the sludge application or sludge
storage area. The constituents monitored in a ground
water monitoring program depend on the goals of the
program. Ground water monitoring is often required
for dedicated land disposal sites. It may be required
for forest application or land reclamation sites over
vulnerable aquifers. Ground water vulnerability is
dependent on geologic and hydrologic factors
including precipitation, depth to ground water,
physical and other characteristics of geologic
material, soils, etc. The permit writer may want to
consult a qualified geologist or hydrogeologist to
evaluate ground water vulnerability. Ground water
monitoring is generally not required for agricultural
projects if the sludge application rate is limited by
crop nutrient requirements. Ground water
monitoring programs to prevent contamination of
water supplies should include monitoring of indicator
parameters (See Federal Guidance below, and
Appendix C of The Land Application Manual (EPA
1983), and The Procedures Manual for Ground Water
Monitoring at Solid Waste Disposal Facilities (EPA
1977b)). If high concentrations of certain heavy
metals, toxic chemicals, or fecal bacteria are present
in the sludge, they should be included in the ground
water monitoring program.
Federal Regulations
40 CFR Part 257 requires that sludge application not
contaminate underground drinking water sources
(any aquifer with less than 10,000 mg/1 dissolved
solids) with contaminants in concentrations equal to
or greater than the levels specified in Appendix I (40
CFR Part 257). Contamination is measured at the
boundary of the application area as it would exist
when the solid waste disposal activity (sludge
application) ceases. However, an alternate boundary
can be set which considers, among other factors, the
natural attenuation and dilution characteristics of
the aquifer and the proximity and withdrawal rates
of ground water users (See Appendix D).
Federal Guidance
The following is a list of parameters generally
included in a ground water monitoring program
(EPA 1983):
pH
Electrical conductivity and/or TDS
Total hardness
Alkalinity
Chlorides
Sulfates
Total organic carbons
Nitrate-nitrogen
• Total phosphorus
• Methylene blue active substances (surfactants)
• Selected metals or toxic organic substances
• Indicator microorganisms
State Requirements
Thirty-four states have rules addressing ground
water monitoring (see Table E6-4). Thirty-three
states require ground water monitoring in some
cases. Parameters measured include depth to water
table, nitrates, metals, organics, pH, and fecal
coliform bacteria. Sampling frequency is variable,
with one state requiring semiannual analyses and
another quarterly analyses. Twelve states set ground
water monitoring requirements on a case-by-case
basis. High seasonal ground water levels, repeated
sludge applications at a single site, and application
rates in excess of the rate based on nitrogen uptake
by crops are considered grounds for requiring ground
water monitoring.
The Madison, Wisconsin and Salem, Oregon land
application programs require ground water
monitoring prior to application and at three and five
year intervals after application. The parameters
measured prior to application at Madison include
dissolved solids, nitrates, total coliform, chloride, and
zinc. Follow-up analyses were conducted for dissolved
solids and nitrates. At Salem, the parameters
measured prior to application and at 3 and 5 year
intervals after application include dissolved solids,
nitrates, total coliforms, arsenic, and mercury.
Case-by-Case Recommendations
When a ground water monitoring condition is
written, permit writers should require the use of
Appendix C of the Process Design Manual for Land
Application of Municipal Wastewater Sludge (EPA
1983) and the Procedures Manual for Ground Water
Monitoring at Solid Waste Disposal Facilities (EPA
1977b), or similarly protective guidelines, to design
and operate ground water monitoring systems. Using
lysimeters to detect leachate in the unsaturated zone
above an aquifer can provide early warning of
potential future ground water contamination.
Surface Water Monitoring
Federal Regulations
Federal regulations do not specifically address
surface water monitoring. However, 40 CFR 257.3-3
does state that a facility or practice shall not cause
non-point source pollution of waters of the United
States that violates applicable legal requirements
implementing an areawide or statewide water
quality management plan that has been approved by
the Administrator under Section 208 of the Clean
Water Act, as amended.
57
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Federal Guidance
Properly designed land application sites should be
located, constructed, and operated to minimize the
chance of surface water run-off containing sludge
constituents. For agricultural sites where sludge is
applied at agronomic rates, surface water monitoring
is typically not required. Generally, surface water
monitoring should be considered in the following
situations (EPA 1983):
• Surface water run-off from the site is collected,
stored, and discharged to surface waters outside
the application area under an NPDES permit.
• The sludge application site is in close proximity
to surface waters that are sensitive (e.g.,
drinking water supplies, swimming areas, etc.),
and monitoring is required to ensure that
migration of sludge constituents to these surface
waters does not occur.
• It is desirable to alleviate community concern
about surface water quality impacts.
Generally, the parameters of concern in a surface
water monitoring program are those that may affect
public health, or those that may contribute to
eutrophication, e.g., nitrogen and phosphorus. An
illustration of parameters that are often analyzed in
surface water samples taken in connection with
sludge application site(s) monitoring is shown in the
following list (EPA 1983):
Fecal coliforms
Total P
Total N (Kjeldahl)
Dissolved oxygen
BODorTOC
Temperature
pH
Suspended solids
State Requirements
Twenty states have regulations addressing surface
water monitoring (see Table E6-4). Six states require
monitoring on a case-by-case basis. Idaho requires
baseline monitoring and follow-up monitoring during
the life of the project for nitrogen, metals, organics,
pH, and fecal coliform bacteria.
Reporting and Record Keeping
Federal Regulations
The recently promulgated revisions to the NPDES
Permitting regulations (54 FR 18716) require that
the permit contain a requirement that the permittee
report monitoring results with a frequency
dependent upon the nature and effect of the sewage
sludge use or disposal practice but in no case less
than once a year (40 CFR 122.44(i)(2)). The regula-
tions also require that records pertaining to the
POTW's sludge use and disposal activities (as set
forth in 40 CFR 501.15 (2)) be retained for 5 years (40
CFR 122.21(p)).
Federal Guidance
Operational and monitoring data may be required by
local, state, or federal agencies. Consequently, any
municipality implementing a sludge application
system should develop an adequate record keeping
program.
Management and reporting activities may include
equipment use and maintenance records,
performance records, required regulatory reports,
cost records, and public relations activities (e.g.,
complaints). These records can also be used as the
basis for scheduling future site inspections and
evaluating the efficiency of operations.
Records on the sludge application portion of the
program should contain at least the following:
• Sludge characteristics and amounts applied to
specific locations.
• Major operational problems, complaints, or
difficulties.
• Qualitative and/or quantitative data related to
the selection and operation of the land
application site, including monitoring data on
ground and surface water, soils, and crops.
State Requirements
Thirty states have reporting/record keeping
requirements (see Table E6-4). These states may
require the POTW to keep records of one or more of
the following: the amount and quality of sludge
applied, the location at which the sludge is applied,
the use of harvested crops, the amount of lime or
fertilizer required, and the results of all
environmental monitoring analyses. The required
reporting frequency varies from monthly to
quarterly, semi-annually, or annually. Three states
require deed records for land application sites.
Kentucky requires a deed record regarding cadmium
application. Massachusetts requires a deed notice for
land application sites receiving sludge/seepage
classified as type II or III under the state's sludge
classification system. Mississippi requires a deed
record of the amount of PCBs and cadmium applied.
58
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6.3 Additional Requirements and
Guidance for Agricultural Land
Application
6.3.1 Permitting Responsibilities
Unless a condition prohibits sludge application to
lands used for producing food-chain crops, the permit
must state that the POTW will comply with the
requirements of 40 CFR 257.3-5 (See Table 6-8).
Briefly, these regulations set annual and cumulative
loading limits for cadmium and management prac-
tices (primarily, adjustment of the sludge-soil
mixture as needed to attain pH 6.5 or greater at the
time of sludge application and whenever food-chain
crops are grown). The regulations also require that
sludges containing PCBs at levels equal to or greater
than 10 mg/kg (dry weight) be incorporated into the
soil when applied to land used for producing animal
feed, including pasture crops for animals raised for
milk. If the POTW can assure that PCB
concentrations in animal feed or milk are low,
incorporation is not required.
Provided special restrictions are followed, 40 CFR
257.3-5 allows for cadmium applications to exceed
the generally required rates. However, these
restrictions include pH maintenance, the develop-
ment of a facility operation plan which demonstrates
how the animal feed (if grown) will be distributed to
preclude ingestion by humans and a stipulation in
the land record or property deed stating that food-
chain crops should not be grown on the land. These
kinds of restrictions generally make high rate
cadmium applications appropriate only in a
dedicated land disposal setting (EPA 1983).
If the permit writer incorporates conditions
(discussed in the recommendations section below)
requiring that sludges be applied at agronomic rates
(e.g., at a rate that will supply only as much available
nitrogen as the particular crop grown on an applica-
tion site can assimilate), and implementing the depth
to ground water and seasonal limit recommenda-
tions, the ground water provisions of 40 CFR 257.3-4
should be satisfied. When sludge is applied at
agronomic rates in agricultural settings, the access
control provisions of 40 CFR 257.3-8 should be
satisfied without writing a permit condition
requiring fences or signs.
6.3.2 Technology
Methods of sludge application on agricultural land
are dependent on the physical characteristics of the
sludge and soil and the crops grown. Liquid sludges
can be applied by surface spreading or subsurface
injection. Surface application methods include
spreading by farm tractors, tank wagons, special
applicator vehicles equipped with flotation tires,
Table 6-8 40 CFR 257.3-5 Contaminant Limits for Sludge
Used on Food-Chain Croplands
Cadmium
a. The pH of the sludge and soil mixture must be greater
than 6.5 at the time of sludge application unless the
sludge contains less than 2 mg/kg (dry weight) cadmium.
b. The annual application of cadmium from sludge must not
exceed 0.5 kg/ha for tobacco and food-chain crops.
c. The cumulative application of cadmium from sludge must
not exceed the following values which depend upon the
cation exchange capacity (CEC) and background pH of
the soil:
CEC Maximum Cumulative Application
pH meq/100 g kg/ha
>6.5 <5 5
5-15 10
>15 20
<6.5* - 5
The cumulative application rates for soils with a
background pH equal to or greater than 6.5 may be used
if the pH of the solid waste and soil mixture is adjusted to
and maintained at 6.5 or greater whenever food-chain
crops are grown.
d. If animal feed is the only food-chain crop produced, there
is no limit to the cadmium application rate, as long as the
pH of sludge and soil mixture is 6.5 or greater at the time
of sludge application or at the time the crop is planted,
whichever occurs later, and this pH level is maintained
whenever food-chain crops are grown. A plan must also
be developed which demonstrates how the animal feed
will be distributed to preclude human ingestion, and the
measures to be taken to safeguard against possible
health hazards from cadmium entering the food chain,
which may result from alternative land uses. Future
property owners must also be notified by a stipulation in
the land record or property deed which states that the
property received sludge at high cadmium application
rates and that food-chain crops, except for animal feed,
should not be grown due to possible health hazards.
PCBs
Sludge containing concentrations of PCBs equal or greater
than 10 mg/kg (dry weight) must be incorporated into the soil
when applied to land used for producing animal feed,
including pasture crops for animals raised for milk.
Incorporation is not required if it can be assured that the PCB
content is less than 0.2 mg/kg (actual weight) in animal feed
or less than 1.5 mg/kg (fat basis) in milk. Sludge containing
more than 50 mg/kg PCBs must be disposed of in a chemical
waste landfill or incinerated under special conditions (see 40
CFR 761 Subpart D for PCB disposal requirements).
* The other constituents listed under C are analyzed only if there are
significant quantities of those contained in the sludge being applied
and the constituent may enter the food chain.
Source: EPA 1983.
tank trucks, portable or fixed irrigation systems, and
ridge and furrow irrigation.
Surface application of liquid sludge is normally
limited to sites with less than 6 percent slopes.
Surface application of liquid sludge is normally
practiced when forage crops are grown. After sludge
has been applied to the soil surface and allowed to
partially dry, it is commonly incorporated by plowing
or disking prior to planting the crop (i.e., corn,
soybeans, small grains, cotton, other row crops).
Ridge and furrow irrigation systems can be designed
to apply sludge during the crop growing season but it
is difficult to provide even distribution. Spray
irrigation systems generally should not be used to
59
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apply sludge to forage or row crops during the
growing season unless proper management is
provided (e.g., application to recently harvested hay
fields, subsequent irrigation with fresh water) since
the adherence of sludge to plant vegetation can
reduce photosynthesis and have a detrimental effect
on crop yields. In addition, spray irrigation tends to
increase the potential for odor problems. Surface
application of liquid sludge by tank trucks and
applicator vehicles is the most common method for
agricultural croplands.
Liquid sludges can also be injected below the soil
surface. Available equipment includes tractor-drawn
tank wagons with injection shanks (originally
developed for liquid animal wastes) and tank trucks
fitted with flotation tires and injection shanks
(developed for sludge application). Both types of
equipment minimize any odor problems and reduce
ammonia volatilization by immediate mixing of soil
and sludge. Sludge can be injected either before
planting or after harvesting all crops except forage
crops that are cut and baled. Because some injection
shanks can either ruin the forage stand or create deep
ruts in the field, specialized equipment should be
used to inject sludge into forage crop fields.
Dewatered sludges are applied to cropland by
handling equipment similar to that used for applying
animal manures, limestone, or solid fertilizers.
Typically, the dewatered sludge will be surface-
applied and then incorporated by plowing or disking.
Incorporation is not generally used when dewatered
sludges are applied to forage crops.
6.3.3 Characteristics of Sludge Suitable for
Agricultural Land Application
The constituents of a sludge have a direct bearing on
the options available for sludge use and disposal. For
agricultural land application, the most important
constituents are nutrients, pathogens, metals, and
certain toxic organic chemicals. The form and the
concentration of the nutrients nitrogen, phosphorus,
and potassium in the sludge affect the fertilizer value
of the sludge for agricultural land application. The
amount of available nitrogen in excess of plant
requirements is of concern for potential nitrate
contamination of ground water. Pathogen reduction
is required prior to agricultural land application to
prevent potential human health problems. High
metal concentrations are of concern in agricultural
land application because of their potential to damage
crops, and to enter the food chain. Certain toxic
organic chemicals are of concern due to their
potential to enter the food chain or to infiltrate into
ground water.
This section summarizes current federal and state
regulations for the agricultural land application
disposal option. These are in addition to the
requirements and recommendations contained in
Section 6.2.
Sludge Pollutant Concentration Limns
Federal Regulations
Current federal regulations address cadmium, PCBs,
and pathogens.
Cadmium
Annual cadmium applications to sites growing food-
chain crops for human consumption, including
tobacco, are limited to 0.5 kg/ha/yr (40 CFR Part
257). The cumulative application of cadmium to a site
is limited based on pH and soil cation exchange
capacity according to the schedule listed in Table 6-9.
Table 6-9 Maximum Permissible Cumulative Cadmium
Application to a Land Application Site Used to
Produce Food-Chain Crops
Soil Cation Exchange.
Capacity
(meq/100 g)
Maximum Cumulative Application (kg/ha)
Background Soil Background Soil
pH <6.5 pH >6.5
<5
5-15
>15
5
5
5
5
10
20
If the only crop produced is used exclusively as
animal feed, then cadmium application rates are not
limited, provided that the following conditions are
met:
• The pH of the sludge and soil mixture is
maintained at 6.5 or greater whenever the crop is
grown.
• To preclude ingestion by humans and safeguard
against possible health hazards from cadmium
entering the food chain, a facility operating plan
is prepared that describes how the animal feed
will be distributed.
• The land record or property deed states that the
property received sludge at high cadmium
application rates and that food-chain crops,
except for animal feed, should not be grown due
to possible health hazards. (40 CFR Part 257)
Permit writers should use the recommendations for
dedicated lands in Section 6.5 when cadmium
loadings will exceed the levels set forth in Table 6-9.
There are no current federal regulations for cadmium
loadings to crops that are non food-chain crops as
defined in 40 CFR Part 257.
60
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PC8s
Sludge containing concentrations of PCBs equal to or
greater than 10 mg/kg (dry weight), but less than 50
mg/kg, must be incorporated into the soil when
applied to land used for producing animal feed,
including pasture crops for animals raised for milk.
Incorporation of the sludge into the soil is not
required if it is assured that the PCB content is less
than 0.2 mg/kg (actual weight) in animal feed or less
than 1.5 mg/kg (fat basis) in milk (40 CFR Part 257).
Pathogens
For agricultural land application, 40 CFR Part 257
contains some specific requirements. If crops for
direct human consumption will be grown within 18
months subsequent to sludge application or
incorporation, the sludge must be treated with a
process to further reduce pathogens (PFRP). These
processes are also listed in 40 CFR Part 257 Appendix
II, Chapter 3 and Section 6.2 of this document. If the
sludge will not contact the edible portions of the crop,
pathogen reduction to PSRP levels is acceptable (40
CFR Part 257).
State Requirements
Some states have set cumulative loading limits for
contaminants in sludge applied to cropland (see
Table E6-2 in Appendix E). Where more restrictive
state limits apply, permit writers should determine
the basis for these limits and consider incorporating
them into the permit.
Some states have set sludge contaminant
concentration limits, primarily for heavy metals and
PCBs (See Table E6-1). One state has set limits for a
number of pesticides. However, it appears that these
limits were based on analytical detection limits. At
this time, EPA does not generally recommend
contaminant concentration limits beyond those in the
Joint EPA/FDA/USDA Guidance on Land
Application of Municipal Sludges for the Production
of Fruits and Vegetables (1981). Permit writers
should consider incorporating state limits after
determining the basis for these limits.
State contaminant concentration limits are
presented in Table E6-1. In general, the state "Grade
1" sludge limits in this table allow unrestricted
agricultural use. States may impose restrictions or
ban use of lower grades of sludge for agriculture.
Table 6-10 summarizes existing state regulations for
annual loading of sludge contaminants at
agricultural sites. Table 6-11 is a similar summary
for the allowable cumulative loading of sludge
contaminants at agricultural sites. Table E6-2
presents all state annual and cumulative application
rate limits and variances for sludge contaminants.
Table 6-10
Summary of Current State Annual
Contaminant Application Rates for Land
Application
No.
States*
Max. Annual Application Rate (kg/ha)
Constituent Regulating Median Mode Range
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Zinc
2
25
4
6
5
2
6
6
57
.5
47
18
53
10
11
28
-
.5
-
14
56
-
-
28
2-112
.5-.6
27-56
9-56
22-252
8-11
5-63
18-112
* See Table E6-2 for variances allowed by many states based
upon cation exchange capacity (CEC), or in some states, for
other parameters.
Table 6-11 Summary of Current State Cumulative
Contaminant Application Rates for Land
Application
Constituent
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
PCB
Selenium
Zinc
.
States' -
Regulating
1
36
6
31
32
2
1
31
2
2
31
rtax. Annual
Median
112
5
313
140
530
3
9
56
1
13
280
Application Rate (kg/ha)
Mode
112
5
140
140
560
-
9
56
-
-
280
Range
112
.5-20
140-560
84-560
200-2520
.6-6
9
341-627
1-2
9-18
168-1120
* See Table E6-2 for variances allowed by many states based
upon cation exchange capacity (CEC), or in some states, for
other parameters.
Case-by-Case Recommendations
Contaminant Cumulative Loading Limits
In addition to the required limits for cadmium and
PCBs, EPA and USDA have issued guidance on the
recommended maximum cumulative sludge metal
applications for croplands (EPA 1977a, 1984; USDA
1984) (See Table 6-12). For permits issued to POTWs
applying sludge to lands used for producing food-
chain crops, permit writers should consider requiring
POTWs or their agents to not exceed these loadings of
heavy metals. Permit writers also may want to set
limits on cumulative sludge metal loadings to lands
used to produce non-food-chain crops (e.g., nurseries,
Christmas tree farms) so as to preserve future use of
these lands for food-chain crops. Tables 6-13 and 6-14
show, for various sludge application rates, how many
years sludges containing various concentrations of
61
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heavy metals could be applied before exceeding
recommended cumulative application rates. These
tables assume that sludge is applied to soils with less
than 5 meq/100 g cation exchange capacity. For sites
with a CEC between 5 and 15 meq/100 g, multiply the
number of years that appear in the tables by a factor
of two. For sites with a CEC of 15 meq/100 g or
greater, multiply the number of years by a factor of
four. In the table, 0 mg/kg means that the
concentration does not allow for any application of
sludge at that particular rate.
Table 6-12 Maximum Metal Application1 (kg/ha) for
Unamended Soil at Indicated Soil Cation
Exchange Capacity (CEC)
CEC2
Metal
Cadmium
Nickel
Copper
Zinc
Lead
0-5
5
50
125
250
500
5-15
10
100
250
500
1,000
15
20
200
500
1,000
2,000
1 Cadmium limits have the force of regulation (40 CFR Part 257).
Annual Cd application should not exceed 0.5 kg/ha. All
recommendations apply only to soils adjusted to pH 6.5 when
sludge is applied and maintained at no less than pH 6.5 thereafter.
2 meq/100 g.
257.3-5, sludges with higher PCB levels might also
be used (See Appendix D).
In certain circumstances, it may be acceptable to
allow sludges with somewhat higher amounts of
cadmium and lead to be used on lands for fruit and
vegetable production. For example, public health
should be adequately protected if the permit writer:
• Places a sludge cadmium limit of 38 mg/kg (dry
weight) in the permit, and a lead limit of 1500
mg/kg (dry weight). These limits are 50 percent
greater than generally recommended;
• Writes the recommended cumulative loading
limits into the permit (per 40 CFR 257.3-5,
annual cadmium loading cannot exceed 0.5
kg/ha);
• Limits sludge application to the agronomic rate;
and
• Requires that the sludge only be applied to lands
where, for the life of the permit, crops with low or
very low heavy metal uptake rates will be grown.
Table 6-15 presents the relative cadmium uptake
rates of various crops. Crop uptake rates for lead
are much lower than for cadmium.
Contaminant Annual Loading Limits
Research has shown that crop uptake and plant
toxicity are controlled by cumulative rather than
annual loading of heavy metals (EPA 1987b).
Provided conditions are placed in permits 1)
requiring that sludge be applied at agronomic rates;
and 2) limiting cumulative metals loadings,
incorporating limits on annual application of heavy
metals (other than the required cadmium limits) is
not generally recommended. Where applicable,
permit writers should consider incorporating state
limits (summarized in Table E6-2).
Pathogen Control
To provide additional assurance beyond the pathogen
reduction requirements of 40 CFR Part 257, the 1981
Joint EPA/FDA/USDA Guidance recommends that
in warm, moist climates, crops that are customarily
eaten raw or only partially blanched should not be
planted within 36 months of sludge application.
Studies since 1981 have confirmed that certain
pathogens can survive for long periods of times (e.g.,
three years) if the sludge/soil mixture is not turned
over at least two or three times to expose these
pathogens to air and sunlight which desiccate them.
Sludge Pollutant Concentration Limits
The 1981 Joint EPA/FDA/USDA Guidance on Land
Application of Municipal Sludges for the Production
of Fruits and Vegetables recommends that only
sludges with less than 25 mg/kg cadmium, 1,000
mg/kg lead and 10 mg/kg PCBs be applied to lands
used to produce fruits and vegetables (EPA 1981).
Research has shown that, for cadmium and lead,
these recommendations are very conservative and
provide a wide margin of safety (EPA 1987b). Based
on the 1981 Guidance, permit writers should
generally consider requiring that sludge applied to
lands used for fruits and vegetable production meet
these contaminant concentration levels. In this case,
sludge with higher levels of cadmium and lead could
still be applied to lands where grains or fodders are
grown. Within the restrictions imposed by 40 CFR
6.3.4 Operating Conditions and Management
Practices
Federal Guidance
Sludge Application Rates
Because of concerns about nitrate pollution of ground
water, permit writers should consider requiring that
sludges be applied at rates that do not exceed the
nitrogen requirement of the particular crop grown on
the application site (the agronomic rate). When
sludges are applied at greater than agronomic rates,
the recommendations for dedicated lands should be
considered (EPA 1983). Some states (for example,
Ohio) take a more conservative approach and limit
sludge application rates to plant phosphorus rather
than nitrogen requirements (EPA 1984). Limiting
62
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Table 6-13 Years of Application for Cadmium and Nickel
Years of Sludge Application at:
2 tonnes/hectare (dry weight)
0.9 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 4 6 12 27 41 83
Ni 41 62 125 277 416 833
Years of Sludge Application at:
20 tonnes/hectare (dry weight)
8.9 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 001248
Ni 4 6 12 27 41 83
Years of Sludge Application at:
70 tonnes/hectare (dry weight)
31 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 000012
Ni 1 1 3 7 11 23
Years of Sludge Application at:
340 tonnes/hectare (dry weight)
152 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 4 6 12 27 41 83
Ni 41 62 125 277 416 833
Years of Sludge Application at:
1 1 tonnes/hectare (dry weight)
4.9 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 0 1 2 5 7 15
Ni 7 11 22 50 75 151
Years of Sludge Application at:
44 tonnes/hectare (dry weight)
20 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 000113
Ni 1 2 5 12 18 37
Years of Sludge Application at:
1 1 2 tonnes/hectare (dry weight)
50 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 000001
Ni 0 1 2 4 7 14
Years of Sludge Application at:
900 tonnes/hectare (dry weight)
400 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal 600 400 200 90 60 30
Cd 4 6 12 27 41 83
Ni 41 62 125 277 416 833
Estimated Sludge Application in Dry Weight for Different Land Disposal Options
T D , nl Reported Range of Application Rates Typical Rate
Disposal Option Application mVha T/ac mt/ha T/ac
Agricultural Annual 2-70 1-30 11 5
Utilization
Forest Utilization 1 time or at 3-5 10-220 4-100 44 20
year intervals
Land 1 time 7-450 3-200 112 50
Land
Reclamation
Utilization
Dedicated
Disposal Site
1 time
Annual
7-450
220-900
3-200
100-400
112
340
50
150
Notes: The rates shown are only for the sludge application area and do not include area for buffer zone, sludge storage, or
other project area requirements. This table assumes that sludge is applied to soils with less than 5 meq/100 g cation
exchange capacity. For sites with a CEC between 5 and 15 meq/100 g, multiply the number of years that appear in
the table by a factor of two. For sites with a CEC of 15 meq/100 g or greater, multiply the number of years by a
factor of four.
63
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Table 6-14 Years of Application for Copper, Lead, and Zinc
Years of Sludge Application at:
2 tonnes/hectare (dry weight)
0.9 tons/acre
Concentration of Metal in Sludge (mg/kg)
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
5400 3600 2700 1800 1500
11 17 23 34 41
46 69 92 138 166
23 34 46 69 83
Years of Sludge Application at:
20 tonnes/hectare (dry weight)
8.9 tons/acre
Concentration of Metal in Sludge
5400 3600 2700 1800 1500
11234
4 6 9 13 16
23468
Years of Sludge Application at:
70 tonnes/hectare (dry weight)
31 tons/acre
Concentration of Metal in Sludge
5400 3600 2700 1800 1500
00011
12244
01122
Years of Sludge Application at
340 tonnes/hectare (dry weight)
1 52 tons/acre
Concentration of Metal in Sludge
5400 3600 2700 1800 1500
00000
00001
00000
1000
62
250
125
(mg/kg)
1000
6
25
12
900
89
277
138
900
6
27
13
(mg/kg)
1000
1
7
3
(mg/kg)
1000
0
1
0
900
2
7
4
900
0
1
0
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
5400
2
8
4
5400
0
2
1
5400
0
0
0
Years of Sludge Application at:
1 1 tonnes/hectare (dry weight)
4.9 tons/acre
Concentration of Metal in Sludge
3600 2700 1800 1500
3467
12 16 25 30
6 8 12 15
Years of Sludge Application at:
44 tonnes/hectare (dry weight)
20 tons/acre
Concentration of Metal in Sludge
3600 2700 1800 1500
0111
3467
1233
Years of Sludge Application at:
1 1 2 tonnes/hectare (dry weight)
50 tons/acre
Concentration of Metal in Sludge
3600 2700 1800 1500
0000
1123
0011
Years of Sludge Application at:
900 tonnes/hectare (dry weight)
400 tons/acre
Concentration of Metal in Sludge
5400 3600 2700 1800 1500
0
0
0
0000
0000
0000
(mg/kg)
1000
11
45
22
(mg/kg)
1000
2
11
5
(mg/kg)
1000
1
4
2
(mg/kg)
1000
0
0
0
900
12
50
25
900
3
12
6
900
1
5
2
900
0
0
0
1 .Sludge loading rate
2.Parameter concentration
3.Parameter cumulative loading rate
4.Parameter deposition rate
5.Years of use at that rate
Sample Calculations
SI Units
2 tonnes/hectare-yr
600 mg Cd/kg sludge
5 kg Cd/hectare
2 tonnes/hectare-yr x 1000 kg
sludge/tonne x .00003 kg Cd/kg/ sludge
= 1.2 kg Cd/hectare-yr
5 kg Cd/hectare * 1.2 kg
Cd/hectare-yr = 4.1667
(round to nearest integer)
English Units
.9 tons/acre/yr
600 mg Cd/kg sludge
5 kg/hectare
.9 ton/acre-yr x 910 kg/ton x 2.47
acre/hectare x .0006 kg Cd/kg/sludge =
1.2 kg Cd/hectare/yr
5 kg Cd/hectare •=• 1.2 kg Cd/hectare-yr
4.119
(round to nearest integer)
64
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Table 6-15 Relative Accumulation of Cadmium into Edible
Plant Parts by Different Crops*
Table 6-16 Recommended Distance to Surface Waters
for Agricultural Land Application
High
Uptake
Lettuce
Spinach
Chard
Escarole
Endive
Cress
Turnip greens
Beet greens
Carrot
Moderate
Uptake
Kale
Collards
Beet
Turnip
Radish globes
Mustard
Potato
Onion
Low
Uptake
Cabbage
Sweet corn
Broccoli
Cauliflower
Brussel sprouts
Celery
Berry fruits
Very Low
Uptake
Snapbean
family
Pea
Melon family
Tomato
Pepper
Eggplant
Tree fruits
Sludge Application
Method/Buffer
Condition
Type of Water Body
Continually
Flowing Intermittent Ditches
* The above classification is based upon the response of crops grown
on acidic soils that have received a cumulative Cd application of 5
kg/ha. It should not be implied that the above higher uptake crops
cannot be grown on such a soil, or soils of higher Cd concentra-
tions. 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.
Source: EPA 1983.
sludge application to the plant phosphorus
requirement typically lowers permissible sludge
application rates by a factor of two to five (EPA 1983).
EPA's Land Application Manual (EPA 1983)
presents detailed information on how to calculate
plant nutrient requirements and appropriate sludge
application rates. Permit writers should consider
requiring that POTWs or their agents use the Land
Application Manual or protective state or local
guidelines, where available, to calculate sludge
application rates.
Distance to Surface Waters
To ensure that sludge does not run off into surface
waters, permit writers should require that buffers be
maintained between the sludge application area and
water bodies. Buffers serve at least two purposes: 1)
they provide a factor of safety against errors during
sludge application; and 2) they provide treatment and
filtering of sludge and/or run-off from sludge
surfaces.
The condition of the ground surface of buffers is a
critical factor in determining appropriate size (for
example, bare soil provides virtually no filtering
while a grass surface offers fair treatment). Thus, as
illustrated in Table 6-16, the recommended size of
buffers depends on the method of sludge application,
the type of surface water being protected and the
condition of the ground surface of the buffer.
Seasonal Limitations
To protect surface waters and ground waters, permit
writers should prohibit sludge application to
Surface Applied:
Continually Vegetated 200ft 100 ft 50ft
Buffer
Bare Soil Buffer 200ft 200 ft 100ft
Injected/Incorporated: 100 ft 50ft 25ft
saturated ground (EPA 1984). Permit writers should
also require that sludge application cease during
storm events when precipitation exceeds 1/4 inch per
hour (EPA 1983). In general, permit writers should
require that sludge not be applied to frozen or snow-
covered ground because of potential run-off problems
(EPA 1984). However, it has been shown that when
proper precautions are used, unsaturated frozen
ground or snow-covered lands may provide some level
of benefit in stabilizing and dewatering sludges. If
this form of treatment is a consideration, the permit
writer should require the permit application to
demonstrate that a combination of slope restrictions
and run-off control measures will protect surface
waters.
The timing of sludge applications should conform to
farming operations, and is influenced by crop,
climate, and soil properties. In addition, sludge
applications must be scheduled around the tillage,
planting, and harvesting operations for the crops
grown. A general guide to allowable times for surface
and subsurface applications of sludge for north
central states is shown in Table 6-17. Individual
states or local USDA-SCS extension personnel can
provide similar information.
Depth to Ground Water
To protect ground water, permit writers should
generally prohibit sludge application to sites where
ground water is less than three feet from the surface
of the soil. Seasonal perched ground waters require
less protection (EPA 1983). Fields that are normally
flooded or saturated early in the spring may be
suitable application sites if depth to ground water is
at least three feet at the time that sludge is applied
and the field is not likely to be saturated during the
growing season.
Distance to Wells Used for Drinking Water
Limiting sludge application to the agronomic rate
and setting a minimum depth to ground water make
contamination of ground water unlikely. However, to
provide an additional margin of safety, permit
writers should consider prohibiting sludge
application within 200 feet of drinking water wells
65
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Table 6-17 General Guide to Months Available for Sludge Application to Different Crops in North
Central States*
Small Grainst
Month
January
February
March
April
May
June
July
August
September
October
November
December
Corn
S"
S*
S/l
S/l
P, S/l
c
c
c
c
H, S/l
S/l
S"
Soybeans
S"
S"
S/l
S/l
P, S/l
P, S/l
c
c
H, S/l
S/l
S/l
S"
Cotton*
S/l
S/l
S/l
P, S/l
C
c
c
c
c
S/l
S/l
S/l
Forages*
S*
S"
S
C
C
H, S
H, S
H, S
S
H, S
S
S'
Winter
C
C
C
C
C
C
H, S/l
S/l
S/l
P, S/l
C
c
Spring
S"
S"
S/l
P, S/l
c
c
H, S/l
S/l
S/l
S/l
S/l
S*
* Application may not be allowed due to frozen or snow-covered soils in some states; S/l, surface or incorporated
application; S, surface apphcation;C, growing crop present; P, crop planted; H, after crop harvested.
t Wheat, barley, oats, or rye.
* Cotton, only grown south of southern Missouri.
'Established forages, legumes (alfalfa, clover, trefoil, etc.), grass (orchard grass, timothy, brome, reed canary grass,
etc.), or legume-grass mixture.
Source: EPA 1983.
(EPA 1983). Permit writers should consult with
ground water program officials to determine if a state
wellhead protection program has set other
requirements.
Access Control
To lessen the possibility that humans will come into
direct contact with pathogens that may be present in
sludge, permit writers should consider prohibiting
application of sludge that has not been treated by a
Process to Further Reduce Pathogens within 300 feet
of inhabited dwellings, schools or playgrounds. If the
property owner (and any tenant) agrees, it may be
acceptable to apply sludge closer to dwellings located
on the application site.
In general, permit writers should prohibit sludge
application within 30 feet of property lines. If the
adjoining property is another farm field or wooded
lot, it may be acceptable to apply sludge within 30
feet of the property line.
State Requirements
Sludge application rates for agriculture are
calculated based on crop needs, permissible sludge
constituent concentrations (based on health and
environmental effects), and soil characteristics.
Application rates are designed so that the most
limiting constituent sets the appropriate application
rate for the sludge. The two constituents that are
usually most important to control are nitrogen and
cadmium. Nitrogen is typically the first sludge
component to limit the rate of sludge application,
since adding excess nitrogen to soil may potentially
contaminate ground water with nitrates.
Typical sludge application rates for agriculture range
from 1 to 30 dry tons of sludge per acre per year in
cases not restricted by high contaminant
concentrations. (EPA, 1984). Twenty-one States have
maximum loading limits in accordance with crop
nutrient requirements (i.e., agronomic rate
limitations). Seven States have maximum volumetric
loading limits, which range generally from 10,000 to
30,000 gallons per acre per year. Eight States have
maximum mass loading limits, which range
generally from 2 to 20 dry tons per acre per year.
A number of States place restrictions on animal
grazing. The most common restriction is to control
animal grazing for at least one month after sludge
application. In some States, however, access by
grazing animals is restricted for as much as 6 or 12
months. Three States require that fences and signs be
installed.
Forty-one States have crop use limitations (see Table
E6-5). Thirty-five States reported mandatory time
delays after sludge application before planting
human consumption crops. The delays ranged
generally from 1 to 3 years, and the most common
delay was 18 months for human consumption crops
(specified by 10 States; typically includes tobacco).
66
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Twenty-four States reported that some crops were not
allowed. Three States (Arizona, Georgia, and Rhode
Island) prohibit the application of sludge to land that
will be used to grow human consumption crops. Four
more States allow human consumption crops only if
special conditions are met. Five States do not allow
raw crops to be grown. Nine States do not allow
contact with root crops, food plants, or low fruits.
6.3.5 Additional Monitoring Considerations for
Agricultural Land Application
In addition to the monitoring requirements and
recommendation discussed in 6.2.2, sludges applied
to lands used for producing food-chain crops should be
monitored more frequently than is generally
recommended in other land application processes.
The pH of the sludge-soil mixture should be
measured each time sludge is applied to food-chain
croplands and whenever food-chain crops are grown.
Once, during the first year of the permit, the soil
cation exchange capacity of food-chain croplands
where sludge is applied should be measured.
6.4 Additional Requirements and
Guidance for Silvicultural (Forest
Land) Application
Forest land application rates are usually limited to
the nitrogen needs of the trees. This rate is typically 4
to 100 tons per acre in one single application or in a
set of closely spaced applications every 3 to 5 years. A
typical application rate would be 18 tons per acre
every 5 years, which is equivalent to an average
yearly application rate slightly less than that for
agricultural application (EPA 1984). This section
presents contaminant limits and management
practices for silvicultural application of sewage
sludge.
6.4.1 Characteristics of Sludges Suitable for
Silvicultural Land Application
Federal Regulations
The only federal sludge quality limits are the
pathogen reduction requirement of 40 CFR Part 257.
comply with the contaminant cumulative loading
limits recommended for food-chain croplands. If
sludge application is limited to the agronomic rate
(discussed below), metal toxicity to forest plants
should not be a problem (EPA 1983).
6.4.2 Operating Conditions and Management
Practices for Silviculture
Federal Regulations
There are no required permit conditions for sludge
application to forest lands beyond the 40 CFR Part
257 requirements that apply to all forms of land
application (See Tables 6-1 and 6-2). Recommended
permit conditions to ensure that the surface water
and ground water provisions of 40 CFR Part 257 are
met are discussed in the Case-by-Case Recommenda-
tion section.
Federal Guidance
Sludge Application Rate
Because of concerns about nitrate pollution of ground
water, permit writers should consider requiring that
sludges be applied at rates that do not exceed the
nitrogen requirement of the type of forest on the
application site (the agronomic rate). The forested
floor often includes a layer of organic matter high in
carbon and low in nitrogen, which will temporarily
immobilize nitrogen then slowly mineralize in later
years. It is this feature of forest soils that allows
heavier, multi-year applications. EPA's Process
Design Manual for Land Application of Municipal
Wastewater Sludge (EPA 1983) presents detailed
information on how to calculate nutrient
requirements and appropriate sludge application
rates. Permit writers should require that POTWs or
their agents use this manual or protective state or
local guidelines, where available, to calculate sludge
application rates. When sludges are applied at
greater than agronomic rates, the recommendations
for dedicated lands should be considered (EPA 1983).
State Requirements
Two states reported regulations addressing
maximum loading limits for forest land application
in cases not limited by high concentrations of
contaminants.
Case-by-Case Recommendations
If the permit writer is concerned that a silvicultural
sludge application site might be used at a later date
to grow food-chain crops, the permit writer should
consider requiring that the POTW or its agent
To protect the structure of forest soils from damage
caused by heavy application vehicles and to reduce
costs, sludges are typically applied to forest lands in a
single application (or closely-spaced series of
applications) once every three to five years. A typical
application rate would be 40 metric tons per hectare
every five years, which is an average yearly rate
slightly less than for agricultural application (EPA
1984). Such an application scenario is acceptable,
provided measures are taken to ensure sludge does
not run off into surface waters and that ground
waters are protected.
67
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Distance to Surface Waters
To ensure that sludge does not run off into surface
waters, permit writers should require that buffers be
maintained between the sludge application area and
water bodies. Buffers serve at least two purposes: 1)
they provide a factor of safety against errors during
sludge application; and 2) they provide treatment and
filtering of sludge and/or run-off from sludge
surfaces.
The condition of the ground surface of buffers is a
critical factor in determining appropriate size (for
example, bare soil provides virtually no filtering
while an undisturbed forest floor offers excellent
treatment). Thus, the recommended size of buffers
depends on the method of sludge application, the type
of surface water being protected and the condition of
the ground surface of the buffer as shown in Table 6-
18:
Table 6-18 Recommended Distances to Surface Water for
Silvicultural Applications
Type of Water Body
Sludge Application Large
Method/Buffer Continually Small
Condition Flowing Tributary Intermittent Ditches
Surface Applied:
Undisturbed
Vegetated Buffer
Disturbed Bare Soil
Buffer
Injected/Incorporated:
200ft
200ft
100ft
100 ft
200ft
100ft
50ft
100ft
50ft
25ft
50ft
25ft
If recommended conditions for sludge application
rates and slope restrictions are not included in the
permit, buffers should be wider.
Application Site Slope Limitations
Provided that the recommended buffers around
surface waters are written into the permit and sludge
application is limited to the agronomic rate,
application to forested sites with good vegetative
cover and slopes not exceeding 30 percent is
acceptable. Permit writers should consider defining a
wet season and generally prohibit application on
slopes greater than 15% during this period except
where slope length is short, is a minor part of the
total application area and is not associated with
streams, or where it can be demonstrated that
management techniques are effective in controlling
run-off.
Seasonal Limitations
The seasonal limitations recommended for
agriculture should be written into the permit.
Depth to Ground Water
High-rate sludge application once every three to five
years (to maintain an agronomic rate over the period
between applications) may result in excess nitrogen
being available in the first year or two after
application. Thus, to protect ground water aquifers
from nitrate pollution, permit writers should prohibit
sludge application in this manner on sites where
ground water is less than six feet from the surface of
the soil (EPA 1983). Seasonal, perched ground waters
require less protection (EPA 1983).
Distance to Wells Used for Drinking Water
To provide a margin of safety, depending on the
geology in the area, permit writers should consider
requiring a minimum setback distance of 300 to
1,500 feet from drinking water wells. (EPA 1983).
Permit writers should consult with ground water
program officials to determine if a state wellhead
protection program has set other requirements and
also with hydrogeologists for site-specific
considerations.
/Access Controls
The setback distance for areas which will be used by
the public will need to be considered on site-specific
basis depending on the potential exposure of the
public to health and safety hazards. A setback of at
least 300 ft. should be used when sludges that are
treated by a PSRP are applied (EPA 1983). This
distance may be lessened in remote areas and/or if
appropriate signs are posted. Access should be
controlled for at least 12 months in all of the above
situations. Sludge that has been treated by a PFRP
should not require access restriction.
State Requirements
For dedicated forest application sites, Ohio allows
application at 5 to 10 times agricultural rates.
Washington limits application rates to the nitrogen
needs of the forest crop.
6.4.3 Additional Monitoring Considerations for
Silviculture
For additional safety, if the aquifer immediately
under the application site is used as a source of
drinking water, permit writers should consider
requiring ground water monitoring. Nitrates will be
of particular concern where application rates exceed
the agronomic rates.
6.5 Additional Requirements and
Guidance for Land Reclamation
To ensure that sufficient nutrients and organic
matter are introduced into the soil to support
68
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vegetation until a self-sustaining ecosystem is
established, the amount of sludge applied at one time
during land reclamation can be relatively large,
ranging from seven to 450 dry metric tons per hectare
(EPA 1984). Thus, the permit needs to address the
potential for temporary pollution of surface and
ground waters. Permit writers should ask
themselves, provided the requirements of 40 CFR
Part 257 are met and public health and the
environment are protected, will using sludge provide
environmental benefits? If so, they should encourage
use of sludge in land reclamation projects.
6.5.1 Characteristics of Sludges Suitable for
Land Reclamation
Federal Regulations
There are no required permit conditions for sludge
application for land reclamation beyond the 40 CFR
Part 257 requirements that apply to all forms of land
application. (See Tables 6-1 and 6-2).
Case-by-Case Recommendations
If the permit writer is concerned that a site where
sludge is applied might be used at a later date to grow
food-chain crops, the permit writer should consider
requiring that the POTW or its agent comply with
the contaminant cumulative loading limits recom-
mended for food-chain croplands. If site conditions
make it unlikely that the reclaimed land could be
used to produce food-chain crops, additional metals
limits are not needed, so long as soil pH is adjusted to
provide the appropriate soil acidity for revegetation
(discussed below). With pH adjustment (as needed),
metal toxicity to plants grown on the site should not
be a problem (EPA 1983).
State Requirements
Five states specified maximum loading limits for
land reclamation sites in cases not limited by specific
contaminant concentrations. Florida limits applica-
tions to 30 dry tons per acre per year. Illinois notes
that loading limits are based on nitrogen and metals.
New Hampshire limits applications to 15 dry tons per
acre per year. New Jersey bases its limit on the
nutrient requirements of the proposed vegetation.
Pennsylvania limits application to 60 dry tons per
acre.
State sludge contaminant concentration limits for
land reclamation are specified in Table 6-19. State
regulations for annual and cumulative application
rates and variances for land reclamation are shown
in Table 6-20.
Table 6-19 State Sludge Contaminant
Concentration Limits for Land
Reclamation
State/Contaminant
California
Cadmium
Lead
PCBs
Florida
Cadmium
Copper
Lead
Nickel
Zinc
Limitation (mg/kg)
25
500
5
100
3,000
1,500
500
10,000
Source: EPA 1987c.
6.5.2 Operating Conditions and Management
Practices for Land Reclamation
Case-by-Case Recommendations
Soil pH Adjustment
Permit writers should consider requiring that the soil
pH of the site be adjusted, as necessary, to provide a
suitable environment for revegetation. Most grasses
and legumes along with many shrubs and deciduous
trees grow best in the soil pH range from 5.5 to 7.5
(EPA 1983). If the soil pH becomes highly acid,
phytotoxicity problems may be encountered from
both the trace metals applied in the sludge and native
toxic elements found at the site (EPA 1983).
Sludge Application Rates
The appropriate amount of sludge to apply to a land
reclamation site is highly site-specific (EPA 1983).
As noted above, sludge application rates vary from
seven to 450 dry metric tons per hectare. A typical
application rate is 112 metric tons per hectare (EPA
1983, 1984). Permit writers should ask permit
applicants to specify how much sludge will be applied
to a land reclamation site. This information is used
along with data on site features (soil pH, slope, depth
to ground water) to determine appropriate measures
to protect plants from metal toxicity (e.g., liming) and
to protect surface and ground waters.
Distance to Surface Waters
Permit writers should consider using the agricultural
buffer recommendations for land reclamation sites.
(The silvicultural recommendations assumed that a
forest floor would be present to filter and treat sludge
and/or run-off.) When large amounts of sludge are
used, wider buffers may be appropriate. However, in
some cases, sludge has been used to stabilize the
banks of waterways and, while probably causing a
small, temporary amount of surface water pollution,
69
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Table 6-20 State Regulations for Annual and Cumulative Application Rates and Variances for
Land Reclamation
Limitation (kg/ha)
State
PA
AR
CA
FL
PA
AR
CA
PA
FL
PA
AR
CA
FL
PA
PA
CA
AR
FL
CA
AR
PA
FL
Constituent
Cadmium
Cadmium
Cadmium
Cadmium
Chromium
Copper
Copper
Copper
Copper
Lead
Lead
Lead
Lead
Mercury
Nickel
Nickel
Nickel
Nickel
Zinc
Zinc
Zinc
Zinc
Annual
.67
0.5
5
67.2
16.8
125
67.2
500
.22
6.72
125
33.6
250
Cumulative
3.36
5
5
5
336
125
140
84
125
336
500
400
500
1.12
33.6
50
50
125
250
250
168
250
Basis for Standard
Farming
CEC<5
SoilpH, CEC<5
Farming
CEC<5
CEC<5
Reclamation for Farm
Farming
CEC<5
CEC<5
Farming
Farming
CEC<5
CEC<5
CEC<5
CEC<5
Farming
0.94
Variance Allowed
5.6 kg/ha
Max = 20 kg/ha when CEC > 15
560 kg/ha strictly land reclamation
Max = 500 kg/ha when CEC > 1 5
1 40 kg/ha strictly land reclamation
560 kg/ha strictly land reclamation
Max = 800 kg/ha when CEC > 5
1 .68 kg/ha strictly land reclamation
56 kg/ha strictly land reclamation
Max = 20 Ib/ac when CEC > 15
280 kg/ha strictly land reclamation
Source: EPA 1987C.
resulted in overall environmental benefits. 40 CFR
Part 257 requires that sludge application not cause a
discharge of pollutants into waters of the United
States in violation of NPDES requirements or the
requirements of a Section 208 water quality
management plan.
Application Site Slope Limitations
In general, permit writers should prohibit
application of sludge to slopes in excess of 15 percent
(EPA 1983). When sludge use will provide clear
environmental benefits and measures are taken that
will control run-off from the site, it may be acceptable
to use sludge on somewhat steeper slopes.
Seasonal Limitations
To protect surface and ground waters, permit writers
should strongly consider using the seasonal
limitations recommended for agriculture.
Depth to Ground Water
The typical, one-time, high-rate sludge applications
used in land reclamation projects may result in
excess nitrogen being available in the first year or
two after application. Thus, to protect ground water
aquifers from nitrate pollution, permit writers should
prohibit sludge application in this manner on sites
where ground water is less than three feet from the
surface of the soil (EPA 1983). Seasonal, perched
ground waters require less protection (EPA 1983).
Distance to Wells Used for Drinking Water
To provide a margin of safety, depending on the
geology in the area, permit writers should consider
requiring a minimum setback distance of 300 to
1,500 feet from wells used for drinking water. (EPA
1983). Permit writers should consult with ground
water program officials to determine if a State
wellhead protection program has set other
requirements. It may be appropriate to require
testing for nitrates in water drawn from nearby
wells.
Access Controls
Permit writers should consider prohibiting
application of sludge that has not been treated by a
Process to Further Reduce Pathogens within 300 feet
of areas used by the public. Where permit writers are
concerned that members of the public who may not
know that sludge has been applied will use the site,
they should consider requiring posting of signs
70
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stating that sludge has been applied to the site.
Sludge that has been treated by a PFRP should not
require access controls.
3. Same as 1 or 2 above, except run-off is controlled
and discharged in accordance with NPDES
permit conditions; or
State Requirements
Maryland requires even spreading for sludge
application on marginal land and contour plowing.
A number of States have requirements for land
reclamation (See Appendix E). Permit writers should
incorporate applicable State requirements where
appropriate.
6.5.3 Additional Monitoring Considerations for
Land Reclamation
For additional safety, if the aquifer immediately
under the application site is used for drinking water
nearby, permit writers should consider requiring
ground water monitoring.
6.6 Additional Requirements and
Guidance for Dedicated Land
Disposal
Dedicated land disposal uses land as a sludge
treatment system. Soil microorganisms, sunlight and
oxidation degrade the organic matter in the sludge
while the soil binds any metals that may be present.
To protect surface and ground waters, precautions
which may be necessary at dedicated sites may
include physical barriers to control run-off and
leaching and careful monitoring for contamination of
ground and surface waters. Often, leachate and run-
off water must be captured and treated prior to
release (EPA 1983,1984).
In most cases, the POTW or its contractor owns the
dedicated land disposal site. POTWs usually take one
of the following four approaches to dedicated land
disposal:
1. All surface water run-off is contained within the
site through use of dikes, lagoons, etc., and
disposed of through evaporation. All ground
water leachate is contained due to natural
impervious geological barriers (e.g., impervious
clay, bedrock, etc.) between the site and any
underground drinking water sources. No attempt
is made to remove moisture or other sludge
constituents (e.g., nitrogen, metals) from the site;
2. Same as 1 above, except crops are planted to
enhance removal of moisture and sludge
nutrients. In some cases, these crops are used as
animal feeds;
4. Same as 1, 2, or 3 above, except that ground
water leachate is intercepted, usually using
subsurface drain tiles, to prevent percolation into
ground water aquifers. Under favorable
geological conditions, interceptor ditches, well
point systems, deep well pumping or other
interception systems may also be feasible.
Intercepted leachate may be removed by
evaporation, discharge to a sewage treatment
plant, irrigation of site vegetation or discharge
directly to surface waters in accordance with a
NPDES permit (EPA 1983).
6.6.1 Permitting Responsibilities
Unless the permit prohibits use of the dedicated site
for food-chain crop production, permit writers should
use the required permit conditions for agriculture. In
this case, if the 40 CFR 257.3-5(a)(l) cadmium limits
will be exceeded (5-20 kg/ha), only animal feeds can
be grown, a stipulation must be placed in the
property deed notifying future owners that the
property has received high-rate cadmium
applications and should not be used to grow food-
chain crops, and a facility operating plan must be
prepared demonstrating how the animal feed will be
distributed to preclude ingestion by humans (See 40
CFR Part 257, Appendix D). If food-chain crop
production is prohibited, permit writers should use
the required permit conditions for silvicultural use of
sludge. All sludges applied to lands must be treated
by a Process to Significantly Reduce Pathogens.
A number of States have requirements for dedicated
land disposal (See Appendix E). Permit writers
should incorporate applicable State requirements
where appropriate. There are no reported State
contaminant limits specifically for dedicated land use
of sludge.
6.6.2 Characteristics of Sludges Suitable for
Dedicated Land Disposal
Sludge Pollutant Concentration Limits
Provided that the requirements of 40 CFR Part 257
are met, no additional contaminant loading limits
are recommended.
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6.6.3 Operating Conditions and Management
Practices for Dedicated Land Disposal
Case-Jby-Case Recommendations
Sludge Application Rates
To ensure that run-off control and ground water
protection measures will protect public health and
the environment, permit writers should ask
applicants to select a maximum annual sludge
application rate and write this rate into the permit.
Sludge application rates range from 100 to 400 tons
per acre (220 to 900 dry metric tons per hectare) per
year, approximately 20 times those of agricultural
lands. Dedicated sites where crops are grown will
have application rates toward the lower end of this
range (EPA 1984).
Distance to Surface Waters and Run-off Control
Measures
Permit writers should consider prohibiting
application of sludge to a dedicated disposal site
within 300 feet of any pond or lake used for
recreational or livestock purposes and any other
surface waters (EPA 1983). Applying sludge to
dedicated sites that are at least 200 feet from
intermittent streams should be acceptable (EPA
1983). Permit writers should require permit
applicants to demonstrate that run-off control
measures will protect surface waters from the 24-
hour, 25-year storm event.
Application Site Slope Limitations
Permit writers should consider prohibiting dedicated
site disposal of sludge on slopes equal to or greater
than 12 percent (EPA 1983).
Seasonal Limitations
Unless the permit writer is assured that run-off
control and ground water protection measures will
adequately protect surface and ground waters, the
permit writer should consider writing the seasonal
limitations recommended for agriculture into the
permit.
Disposal on dedicated sites with less than 10 feet of
depth to ground water may be acceptable if
appropriate measures are taken to protect ground
waters from leachate from the site.
To protect ground waters from contamination, permit
applicants should be required to demonstrate that
leachate from their dedicated disposal site will be
controlled in one of the following ways:
• The local climate is arid with a high net
evaporation, and underground drinking water
sources are deep;
• An impervious geological barrier (e.g., bedrock or
thick clay) lies between the site and the
underground drinking water source effectively
preventing percolation of volumes of leachate
which could contaminate these sources;
• A below ground leachate interception system will
be constructed (e.g., drain tiles, well points, etc.)
which will collect the leachate before it can
percolate into the aquifer; or
• The volume of leachate reaching the aquifer is
such a small percentage of the ground water
aquifer flow volume that potential degradation is
negligible (EPA 1983).
Permit writers should require that any collected
leachates be disposed of in a manner that complies
with all federal requirements, and should consider
requiring any additional measures that may be
necessary to protect public health and the
environment.
Distance to Wells Used for Drinking Water
To provide a margin of safety, permit writers should
consider requiring a minimum setback distance of
1,000 feet from wells used for drinking water (EPA
1983). Permit writers should consult with ground
water program officials to determine if a state
wellhead protection program has set other
requirements. It may be appropriate to require
testing for nitrates in water drawn from nearby
wells.
Depth to Ground Water and Leachate Control
Generally, permit writers should consider
prohibiting disposal of sludge on dedicated sites
where an underground drinking water source (any
aquifer with less than 10,000 mg/1 of dissolved solids)
is less than 10 feet from the surface of the soil (EPA
1983). Seasonal, perched ground waters require less
protection (EPA 1983). Permit writers should consult
ground water protection staff (Appendix B) with any
questions regarding the classification of aquifers.
Access Controls
Permit writers should consider prohibiting
application of sludge to dedicated disposal sites
located within 500 feet of areas used by the public. If
residential dwellings or other heavy public use areas
are adjacent to the site, a 2,000 foot buffer is
recommended (EPA 1983). Unless a dedicated
disposal site is located in a very remote area, permit
writers should consider requiring that the site be
enclosed by a fence with locking gates.
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6.6.4 Additional Monitoring Recommendations
for Dedicated Land Disposal
In general, to check for possible ground water
pollution from leachate, permit writers should
require ground water monitoring. In addition, permit
writers should consider requiring that any crops
grown for animal feed be tested periodically to ensure
that PCBs, cadmium and other metals that may be in
high concentrations in the sludge do not pose a threat
to the food-chain. If animal feeds are grown, the
sludge should be tested for contaminants more
frequently than is generally recommended.
References
EPA 1977a, Office of Water Program Operations
Municipal Sludge Management Environmental
Factors. EPA 430/9-77-004. October 1977
EPA 1977b, Procedures Manual for Ground Water
Monitoring at Solid Waste Disposal Facilities, EPA
530/SW-611.
EPA 1979, Process Design Manual for Sludge
Treatment and Disposal. EPA 625/1-79-011,
September 1979.
EPA 1980, Guide to Regulations and Guidance for
Utilization and Disposal of Municipal Sludge. U.S.
Environmental Protection Agency, 430/9-80-015,
September 1980.
EPA 1981, Land Application of Municipal Sewage
Sludge for the Production of Fruits and Vegetables: A
Statement of Federal Policy and Guidance. SW-905.
U.S. Environmental Protection Agency.
EPA 1983, Process Design Manual for Land
Application of Municipal Wastewater Sludge. EPA
625/1-83-016,1983.
EPA 1984, Environmental Regulations and
Technology: Use and Disposal of Municipal
Wastewater Sludge. EPA 625/10-003,1984.
EPA 1986(a), Proceedings of the Workshop on Effect
of Sewage Sludge Quality and Soil Properties on
Plant Uptake of Sludge Applied Trace Constituents.
Las Vegas, Nevada, November 13-16, 1985,
December 1986.
EPA 1986(b), Radioactivity of Municipal Sludge. US
EPA Office of Water Regulations and Standards.
Washington, DC 1986.
EPA 1987(a), Regulatory Impact Analysis of the
Proposed Regulations for Sewage Sludge Use and
Disposal. July 1987.
EPA 1987 (b), Proceedings of a workshop. Land
Application of Sludge: Food Chain Implications. A. L.
Page et al., editors; Lewis Publishers Inc. 1987.
EPA 1987(c), State Requirements for Sludge
Management, U.S. Environmental Protection
Agency Office of Municipal Pollution Control and
Office of Water Enforcement and Permits,
Washington, D.C., 1987. (Revised 1989.)
EPA 1989a, Environmental Regulations and
Technology: Control of Pathogens in Municipal
Wastewater Sludge for Application Under 40 CFR
Part 257. U.S. Environmental Protection Agency,
EPA 625/10-89-006. October 1989.
EPA 1989b, Draft - Suggested Guidelines for the
Disposal of Naturally Occurring Radionuclides
Generated by Drinking Water Treatment Plants. US
EPA Office of Drinking Water Criteria and
Standards Division, Washington D.C. 1989.
Haufler, J. and S. Hest 1985, Wildlife Responses to
Forest Application of Sewage Sludge. In the Forest
Alternative for Treatment and Utilization of
Municipal and Industrial Waste. P.H. Cole, C.H.
Henry and W.V Nutter, eds. University of
Washington Press. Seattle and London.
USDA 1984 Use of Sewage Sludge Compost as a Soil
Conditioner and Fertilizer for Plant Growth, U.S.
Department of Agriculture, Agricultural Information
Bulletin No. 464.1984.
WDOE 1982, Best Management Practices for Use of
Municipal Sewage Sludge. State of Washington
Department of Ecology, Olympia, WA, 1982.
Zabowoski, D. and R. Zasoski. 1986. Toxic Efforts of
Sludge: Mushrooms and Wildberries. Col. Forest Res.
Univ. of Washington, Seattle.
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Chapter 7
Distribution and Marketing
7.1 Introduction
Distribution and marketing refers to the sale or give
away of sewage sludge. Distribution and marketing
is similar to land application in that the sewage
sludge product is generally applied to the land, but is
different in that with distribution and marketing
there is little or no control over the end use of the
product. While land application generally has some
sort of a "contract mechanism" between the POTW
and the ultimate user which enables control of the
end use, often distribution and marketing sludges are
sold or given away for "home use" (either bagged or in
bulk form). Because the POTW cannot be certain (in
most cases) that users will comply with application
rates and management practices and because
distribution and marketing sludges have a strong
likelihood of human exposure, strict contaminant
concentration limits, pathogen controls and labeling
requirements are appropriate.
Many of the benefits and concerns associated with
land application apply to distribution and marketing
(D&M) as well. The primary benefits of distribution
and marketing relate to the soil conditioning and
fertilizer value of sludge, while its primary concern is
the possible exposure of the public to sludge
contaminants either through direct exposure or
introduction to the food chain.
Existing regulations allow the use of D&M sludge
products for many different applications such as
lawns, shrubs, ornamental plants, and vegetable
gardens. Products with moderate to high levels of
contaminants are not recommended for application to
vegetable gardens, however, because the amount of
sludge that is applied cannot be controlled as well as
it is in large-scale land application programs. This
lack of control raises the possibility that high levels
of contaminants might be applied to a given plot of
ground. Sludges with low levels of heavy metals and
toxic organic compounds, therefore, are most
appropriate for D&M programs because they pose
less of a risk to home gardeners (EPA 1984a). Three
States currently prohibit the use of composted sludge
on vegetables or in home gardens. Five additional
States prohibit applying sludge to food chain crops in
land application programs and may similarly restrict
sludge use in D&M programs.
7.1.1 Permitting Responsibilities
At present, while no federal regulations are
specifically tailored to the distribution and
marketing of sludge products, D&M is subject to the
same regulations as land application (40 CFR Part
257). The 40 CFR Part 257 regulations limit
cadmium and PCBs in sludge applied to land used for
producing food-chain crops (Appendix D, 40 CFR
257.3-5). Briefly, these regulations set annual and
cumulative loading limits for cadmium, PCBs, and
management practices (primarily pH adjustment of
the sludge-soil mixture to pH 6.5 or greater to reduce
cadmium mobility). Due to the practical difficulty for
the POTW in controlling proper application of D&M
sludges, permit writers should consider restricting
D&M to sludges with very low concentrations of
cadmium and PCBs, unless the permit requires the
POTW operator to provide a label or handout stating
that the sludge should not be used on food-chain
crops. Additional permit recommendations for
POTWs using D&M programs are provided below
under "Case-by-Case Recommendations."
The 40 CFR Part 257 regulations also set pathogen
reduction requirements for sludges that are applied
to land surface or incorporated into the soil
(Appendix D, 40 CFR 257.3-6). Briefly, pathogen
reduction is required whether or not food-chain crops
are grown. Among other conditions, if public access to
the sludge application site is controlled for twelve
months, the sludge must only be treated by a "Process
to Significantly Reduce Pathogens" (PSRP) (e.g.,
anaerobic digestion, air drying for three months,
composting at more than 55°C for four hours, lime
stabilization). If the public will have access to the site
within a year of sludge application, or if the edible
portion of a food-chain crop that is grown within
eighteen months of application will contact the
sludge (e.g., root crops such as beets and potatoes or
low-growing crops such as bush beans and
strawberries), a "Process to Further Reduce Patho-
gens" (PFRP) is required (e.g., composting at more
than 55°C for three days or heat drying). While it is
possible that a D&M sludge product will be used in a
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manner that will restrict public access for twelve
months, because of the uncontrolled use and frequent
human contact that characterize use of these
products, sludges used in D&M programs must be
treated by a PFRP, unless the POTW can ensure that
the appropriate public access and food-chain crop
restrictions will be met. Examples of D&M programs
where PSRP treatment would be adequate are sale of
sludge to the operators of a commercial Christmas
tree farm who restrict public access to the sludge
application sites, or give away of sludge to a parks
and recreation department for use in areas where the
public will not have access for twelve months.
7.2 Technology Guidelines
Due to the high potential for public contact in
distribution and marketing operations, the
technologies applied to the distribution and
marketing of wastewater sludge are primarily those
which meet the federal criteria for Processes to
Further Reduce Pathogens (PFRP) as defined in 40
CFR Part 257. If, however, the POTW can provide
documentation that appropriate public access and
food-chain crop restrictions will be met, Processes to
Significantly Reduce Pathogens (PSRP) may be
considered. The PSRP criteria and procedures are
outlined in Chapter 6. The PFRP criteria and other
design and operational criteria for specific distribu-
tion and marketing technologies are presented later
in this chapter. Heat-dried or composted sludges
usually meet PFRP criteria and are commonly used
in D& M programs because they have high solids
content and are therefore easily handled by the user
(EPA 1984a). Currently most POTWs with D&M
programs compost their sludge.
Composting
In 1985, there were 115 sludge composting facilities
in operation in the United States (EPA 1984a,
1985a). Wastewater sludge composting operations
entail mixing dewatered sludge with a bulking
agent, such as wood chips, straw, or previously
composted sludge, and then allowing the mixture to
decompose aerobically to produce a humus-like
product which may be used as a soil conditioner or
fertilizer. The purpose of the bulking agent is to lower
the moisture content and to enhance sludge porosity
so that air can be drawn through compost piles (EPA
1984a).
General guidelines for efficient biological processes
in composting include the following:
• The incoming sludge should be dewatered and
have a solids content in excess of 25 percent
(Sludge Composting and Improved Incinerator
Performance, EPA 1984b).
• The sludge-bulking agent mixture should have a
volatile solids content greater than 50 percent, a
moisture content no greater than 60 percent for
static pile and windrow composting and 65
percent for within-vessel composting, and a pH in
the range of 6 to 9 standard units. Composting is
possible at higher pH values though more time is
required (EPA 1985b).
• Sludge is normally composted for 21 to 30 days,
during which time the temperature typically
reaches temperatures of 55*0 or higher (EPA
1984a). The high temperatures (thermophilic
range of 50 to 70°C) provide efficient pathogen
destruction. Within-vessel systems require less
composting time, typically 14 to 20 days.
• After composting, the product is allowed to cure
for approximately 30 days, and then is often
stored for 60 to 90 days following curing to ensure
that the final product is dry and has no residual
odors (EPA 1984a). Within-vessel systems
require less time for curing, typically 20 days
(EPA 1984b).
• The product is typically screened before or after
curing to recover as much bulking agent as
possible.
The three composting methods most often employed
in the United States are (1) windrow composting, (2)
static aerated piles, and (3) within-vessel composting.
Windrow Composting
The windrow composting method involves placing
the sludge-bulking agent mixture in long, open-air
piles. The sludge is turned frequently to ensure an
adequate supply of oxygen throughout the compost
pile and to ensure that all parts of the pile are
exposed to temperatures capable of killing all
pathogens and parasites. Daily turning may be
required at first when the system has a high oxygen
demand, but turning three times per week should be
sufficient thereafter. Windrow composting can be
adversely affected by cold or wet weather and is
difficult to control when raw sludge is used (EPA
1984a).
Static Aerated Piles
For static aerated piles, the sludge-bulking agent
mixture is placed in rectangular piles that are
supplied with air by blowers connected to perforated
pipes running under the piles. The blowers draw or
blow air through the piles, assuring even distribution
of air throughout the composted sludge. An aeration
rate of about 500 cubic feet per hour per ton of dry
sludge is needed to maintain the desired oxygen level
of 5 to 15 percent throughout the pile (EPA 1979).
The aeration rate must be adequate to maintain
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aerobic conditions but may be decreased somewhat to
prevent cooling and maintain adequate temperatures
for pathogen destruction. Aeration rates of 300 to 350
cubic feet per hour per dry ton are recommended and
1/3 hp blowers are typically used for up to 30 dry tons
of sludge (EPA 1984b). Many static pile systems use 1
to 5 hp blowers that are cycled on and off (EPA
1985b).
Placing a layer of previously composted sludge over
the surface of the pile helps to insulate the pile and
assure that sufficient temperatures are attained
throughout the pile. Because the piles do not have to
be turned, and because the sludge is insulated by an
outer layer of previously composted sludge, static
aerated piles are less affected by cold and wet
weather than windrow composting (EPA 1984a).
Within-Vessel Composting
This technique involves placing the sludge-bulking
agent mixture in completely enclosed containers,
where environmental conditions such as temperature
and oxygen supply can be closely monitored and
controlled. This process is particularly desirable in
cold climates or where land is limited.
The ratio of bulking agent to sludge is typically lower
in within-vessel composting than with other
methods. Ratios of bulking agent to sludge range
from 3:1 to 4:1. Within-vessel systems have higher
capital cost but allow better process control and often
have lower operating cost (EPA 1984b).
Composting Processes to Further Reduce Pathogens
Composting operations must meet the following
requirements to qualify as a PFRP as defined in 40
CFR Part 257:
"Using the within-vessel composting method, the
solid waste is maintained at operating conditions
of 55°C or greater for three days. Using the static
aerated pile composting method, the solid waste
is maintained at operating conditions of 55°C or
greater for three days. Using the windrow
composting method, the solid waste attains a
temperature of 55°C or greater for at least 15
days during the composting period. Also, during
the high temperature period, there will be a
minimum of five turnings of the windrow."
Monitoring is essential to ensure adequate
composting performance. Parameters such as
temperature, air flow, and CO% and/or oxygen levels
(with tubes in piles or in the off-gas or within-vessel
systems) should be checked regularly at a number of
locations in the compost pile. Air flow for static
aerated piles and particularly for within-vessel
systems may be adjusted based on these
measurements. An atmosphere containing 5 to 15
percent oxygen is required throughout the pile to
ensure aerobic conditions (EPA 1985b).
Product maturity may be gauged by pathogen levels
or odor, or by tracking a number of other parameters.
These measures include CO2, and the evaluation of
changes in the carbon:nitrogen (C:N) ratio (EPA
1984b).
The composting conditions outlined in the
regulations for PSRP and PFRP, when met, reduce
all pathogenic viruses, bacteria and parasites to the
desired densities. However, composting under these
conditions may not adequately reduce vector
attraction. Generally longer composting times of 7
days or more for within vessel and 17 or more days for
static aerated pile and windrow should be sufficient
to fully stabilize the sludge. (EPA 1989).
Heat Drying
Heat drying involves heating the sludge to a
temperature of about 80°C for a short period of time
to destroy pathogens and to reduce sludge volume by
removing most of the water. Heat-drying is an
expensive process and hence is typically used only
where there is a good market for the resultant
product which is a good soil conditioner/fertilizer.
Heat-drying is typically accomplished with either a
flash drier or a rotary kiln (EPA 1979). Heat-drying
can result in contamination of the air by particulates
and volatile compounds to the point that air pollution
control devices may be necessary. Air pollution
control equipment is discussed in Chapter 8. Since
moisture creates an environment favorable for
regrowth of organisms, heat-dried sludge should not
be allowed to become rewetted.
A heat drying facility must meet the following
requirements to qualify as a PFRP as defined in 40
CFR Part 257:
"Dewatered sludge cake is dried by direct or
indirect contact with hot gases, and moisture
content is reduced to 10 percent or lower. Sludge
particles reach temperatures well in excess of
80°C, or the wet bulb temperature of the gas
stream in contact with the sludge at the point
where it leaves the dryer is in excess of 80°C."
Air Drying
Air drying of sludge is performed by placing/ sludge
on under-drained sand beds, or paved or uKpaved
basins in which the sludge is placed at a depth of
approximately six to twelve inches depending on
factors such as: moisture content of the sludge;
number of drying beds available; dewatering
characteristics of the sludge, desired operating
routine; and the weather (precipitation and
evaporation rate) expected for the site. Dewatering
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typically proceeds for a minimum of three months
with average temperatures over 0°C. Covered drying
beds are preferred where annual rainfall rates
approach or exceed annual evaporation rates.
Air drying is a fairly inexpensive and effective means
of dewatering sludge. However, air drying does not
qualify as a PFRP (see 40 CFR Part 257 Appendix II)
and hence air-dried sludge may not be suitable for
many distribution and marketing programs without
further treatment. Coupling air drying with pasteur-
ization, gamma ray irradiation, beta ray irradiation,
or other approved pathogen reduction methods can
qualify as a PFRP.
Chemical Processes
Chemical processes may be used in conjunction with
distribution and marketing operations to provide the
supplemental disinfection necessary to make a
process such as air drying qualify as a PFRP. Chem-
ical processes such as CHEMFIX may also be used to
solidify sludge into a cement matrix. Whether or not
a sludge that has been treated by chemical processes
is suitable for distribution and marketing will
depend on the chemical properties of the sludge (pH,
organic content, availability of plant nutrients, etc.)
as well as the contaminants that remain in the
product, and whether there is any market for this
product.
7.3 Characteristics of Sludges Suitable
for Distribution and Marketing
D&M uses of sludge take advantage of the soil
conditioning and fertilizer value of sewage sludge in
a manner very similar to land application of sludge.
Consequently, the exposure pathways and effects of
sludge contaminants are similar to those for land
application.
7.3.1 Sludge Pollutant Concentration Limits
Federal Regulations
The federal regulations limit cadmium, PCBs, and
pathogens in sludge applied to or incorporated into
the surface of the land (40 CFR Part 257). Currently,
no federal requirements limit contaminants in D&M
sludge products that are used on non-food-chain
crops. (Recommended limits are summarized below.)
Cadmium
Federal regulations (40 CFR 257.3-5) provide a
maximum allowable annual application rate of 0.5
kilograms of cadmium per hectare for all food chain
crops including tobacco. The maximum allowable
cumulative loading rate is 5 kilograms per hectare,
(kg/ha). If the soil and the mixture of soil and sludge
has a pH of at least 6.5 standard units, the maximum
allowable cumulative loading is 5 kg/ha for soil
cation exchange capacities (CECs) less than 5
meq/100 g, 10 kg/ha for CECs between 5 and 15
meq/100 g, and 20 kg/ha for CECs over 15 meq/lOOg.
Additionally, the pH restriction may be waived when
the sludge contains cadmium at concentrations of 2
mg/kg (dry weight) or less. It should be noted that
with distribution and since the municipality
typically has little control over what is ultimately
done with the sludge, it would be difficult to ensure
compliance with the cadmium loading requirements
unless cadmium concentrations in the sludge were
very low.
PCBs
Federal regulation (40 CFR 257.3-5) stipulates that
sewage sludge containing concentrations of PCBs
equal to or greater than 10 mg/kg (dry weight) must
be incorporated into the soil when applied to land
used for producing animal feed, including pasture
crops for animals producing milk. Incorporation of
the sludge into the soil is not required if it is assured
that the PCB content is less than 0.2 mg/kg (actual
weight) in the animal feed or less than 1.5 mg/kg (fat
basis) in the milk.
If the concentration of PCBs is 50 ppm or greater, the
sludge is subject to the requirements of the Toxic
Substances Control Act (40 CFR Part 761) and is not
appropriate for distribution and marketing opera-
tions.
Pathogens and Disease Vectors
The federal regulations set pathogen reduction
requirements for sludges that are applied to the land
surface or incorporated into the soil (40 CFR 257.3-6).
Pathogen reduction is required whether or not food-
chain crops are grown. If public access to the sludge
application site is controlled for twelve months, and
grazing by animals is controlled for one month, the
sludge must only be treated by a PSRP. If the public
will have access to the site within a year of sludge
application, animals for human consumption will
graze within one month, or if the edible portion of a
food-chain crop that is grown within eighteen months
of application will contact the sludge a PFRP is
required.
Federal Guidance
In the Summary of Environmental Profiles and
Hazard Indices for Constituents of Municipal Sludge:
Methods and Results (EPA 1985a), EPA evaluated
and prioritized the hazards posed by various
pollutants for a number of exposure pathways. The
incremental index values of toxicity to humans due to
consumption of plants fertilized with sludge, or
consumption of herbivorous animals that have
ingested plants fertilized with sludge are presented
in Table 7-1. These are included to provide insight
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into the types of contaminants that may cause
problems in land application or distribution and
marketing when they are present in high
concentrations (incremental index values less than
1.0 represent negligible toxicity risk or a cancer risk
of less than one in one million).
Table 7-1 Incremental Index Values of Toxicity to Humans
Toxicity from
Plant Consumption
Compound
PCBs
Hexachlorobenzene
Chlordane
Benzo(a)pyrene
Aldrin/Dieldrin
Toxaphene
Cadmium
DDT
Zinc
Heptachlor
Nickel
Lead
Selenium
Arsenic
Iron
Mercury
Incremental
Index
14,953
4,295
3,100
2,860
1,300
1,245
95
51
16.4
15
11.9
82
6.6
1.5
1.1
1.0
Toxicity from
Animal Ingestion
Compound
PCBs
Hexachlorobenzene
Chlordane
Chlordane
DDT
Aldrin/Dieldrin
Selenium
Heptachlor
Zinc
Mercury
Cadmium
Incremental
Index
64,953
1,345
1,095
180
151
100
15.7
7.0
3.7
2.75
2.5
Fluoride
0.4
Source: EPA 1985a.
This list is not directly applicable to permitting, but
it points out that wastewater sludges with high
concentrations of certain compounds, such as PCBs,
hexachlorobenzene, chlordane, benzo(a)pyrene,
aldrin, dieldrin, and toxaphene should be given
careful consideration before a sludge is used in a
distribution and marketing program. Additionally,
careful monitoring of the sludge product for
pollutants with high hazard indices would be
appropriate. The need for careful monitoring is
especially true for distribution and marketing
because the municipality or its contractor typically
have little control over what is ultimately done with
the sludge. Lack of control over use of the sludge
product is also an incentive to limit distribution and
marketing to sludges with low levels of heavy metals
and toxic organic compounds (EPA 1984a).
Because in most cases the POTW cannot be certain
that users will comply with application rates and
management practices and because distribution and
marketing sludges have a strong likelihood of human
exposure, strict contaminant concentration limits,
pathogen controls and labeling requirements are
appropriate.
The 1984 report of EPA's Intra-Agency Sludge Task
Force, Use and Disposal of Municipal Wastewater
Sludge (EPA 1984a), recommends the following
maximum heavy metal concentrations for
wastewater sludge composts that are distributed and
marketed without restriction:
Cadmium 12.5 - 30 mg/kg (dry weight)
Copper 500 - 900 mg/kg (dry weight)
Lead 285 - 1,000 mg/kg (dry weight)
Nickel 100 - 200 mg/kg (dry weight)
Zinc 1,250 - 1,800 mg/kg (dry weight)
Mercury 5 mg/kg (dry weight)
To support these recommendations the Task Force
cites the 1981 joint EPA, Food and Drug
Administration (FDA) and U.S. Department of
Agriculture (USDA) Land Application of Municipal
Sewage Sludge for the Production of Fruits and
Vegetables: A Statement of Federal Policy and
Guidance (EPA 1981), the Maryland Environmental
Service operating manual for sewage sludge compost
for the Blue Plains wastewater treatment plant
(MES 1984) and others. EPA believes that these
recommended limits for composts are suitable for
other forms of D&M sludge products as well (e.g.,
heat-dried sludges). Thus, with the exception of the
lead limit (discussed in the next paragraph below),
permit writers should consider requiring POTWs to
meet the heavy metal concentrations recommended
in the 1984 Task Force Report in all D&M sludge
products, unless the POTW provides labels or
handouts stating that the sludge product is not to be
used on home vegetable gardens.
Since 1984, EPA has learned more about the subtle,
negative effects of lead at very low concentrations in
the blood, and the Agency is concerned about the
implications for sensitive populations which include
children and young adults. While it appears that the
risk posed by lead in D&M sludge products is low,
particularly when compared to other sources of
exposure to lead, permit writers should consider
imposing D&M lead limits at the lower end of the
range recommended in the Task Force report, unless
the POTW provides labels or handouts stating that
the sludge product is not to be used on home
vegetable gardens.
Another good source of federal guidance is the 1984
USDA Agricultural Research Service publication
Utilization of Sewage Sludge Compost as a Soil
Conditioner and Fertilizer for Plant Growth. This
document recommends maximum sludge metal
applications for privately-owned croplands as shown
in Table 7-2. The document cites a 1982 paper by R.L.
Chaney of the USDA as a source for these
recommendations (Chaney, 1982).
The guidance on annual and cumulative application
limits will help the permit writer determine the
appropriate application rate for D&M sludges (as
described more fully below in the section on
79
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Table 7-2 Maximum Metal Application1 (kg/ha) for
Unamended Soil at Indicated Soil Cation
Exchange Capacity (CEC)
CEC2
Metal
Cadmium
Nickel
Copper
Zinc
Lead
0.5
5
50
125
250
500
5-15
10
100
250
500
1,000
15
20
200
500
1,000
2,000
1 Cadmium limits have the force of regulation (40 CFR Part 257).
Annual Cd application should not exceed 0.5 kg/ha. All
recommendations apply only to soils adjusted to pH 6.5 when
sludge is applied and maintained at no less than pH 6.5 thereafter.
2 meq/100 g.
Source: Chaney 1982.
recommended management practices, the permit
writer should consider requiring the POTW to
include application rate information in labels or
handouts given to the user of D&M sludges.)
For toxic organic compounds in sludges applied to
lands, the federal government has only set the
regulatory limits for PCBs described above. The
Intra-Agency Task Force report recommends that
distribution and marketing is most appropriate for
sludges with low levels of toxic organic compounds.
However, it does not provide any recommended
maximum contaminant concentrations levels. The
1981 joint EPA/FDA/USDA policy on sludge use for
producing fruits and vegetables recommends a 10
mg/kg PCB concentration limit. This guidance
assumes that carrots are washed and peeled prior to
consumption.
State Requirements
Pollutant Concentration Limits
Specific pollutant concentration limits addressed in
State regulations are provided in Appendix E, Table
E7-1. State information is taken from the EPA sludge
database (EPA 1987). Permit writers should verify
concentration limits with the State regulatory
agency to ensure that the limits are current.
Sludge Loading Limits
Seven States have loading limits for distribution and
marketing. The reported loading limits include: 10
dry tons per acre with cadmium levels less than 25
mg/kg (Illinois); site approval requirement if over
100 yd3 is to be used (New Jersey); 2 cubic yards per
year-person (Pennsylvania); a notation that loading
limits are required for uncontrolled use (Texas); and
5 to 20 kg/ha of cadmium on food chain crops
(Washington). Virginia and New Hampshire also
have restrictions on sludge loading.
Case-by-Case Recommendations
The permit writer should review applicable State
contaminant concentration limits for sludges used in
D&M programs (Table 7-3). For the heavy metals
addressed by EPA, the median and mode of State
limits fall within the range of limits EPA
recommends. For PCBs, the median and the mode of
eight States' limits is 2 mg/kg - 20 percent of EPA's
management practice threshold for lands used to
produce feed for food-chain animals and
recommended limit for fruit and vegetable
production. Nationally, EPA recommends that
permit writers consider requiring D&M sludges to
meet a 10 mg/kg PCB concentration limit. For
POTWs in the seven States with stricter PCB limits
Table 7-3
Summary of Current State Sludge Contaminant
Limits for Distribution and Marketing
No. of
States
Max. Product Cone, (mg/kg)
Contaminant
Aldnn/Dieldrin
Cadmium
Chlordane
Chromium
Copper
DDT/DDE/DDD
Heptachlor
Lead
Lmdane
Mercury
Molybdenum
Nickel
PCB
Toxaphene
Zinc
Regulating
1
10
1
2
8
1
1
10
1
5
1
8
8
1
8
Median
0.1
23
0.1
1,000
800
0.25
0.1
500
0.1
5
10
200
2
1
1,662
Mode
0.1
25
0.1
1,000
500
0.25
0.1
500
0.1
5
10
200
2
1
1,250
Range
0.1
2-40
0.1
1,000
500-1,200
0.25
0.1
300-4,800
0.1
5-10
10
100-1,250
0.5-10
1
1,000-
2,500
Source: EPA 1987.
(California, Maryland, New Jersey, New York, Ohio,
Texas and Wisconsin), permit writers should consider
imposing the State requirement but should consult
with State officials to determine the basis for the
more restrictive limit.
At this time, EPA defines a high quality sludge as
one with heavy metal concentrations that fall within
the ranges recommended in the 1984 Task Force
Report (as noted above, lead concentrations should
fall below the low end of the recommended range).
PCB concentrations should not exceed 10 mg/kg (dry
weight). However, if a POTW provides the user of its
D&M product with a label (bagged product) or a
handout (bulk distribution) that clearly states that
the product is not to be used on food-chain crops, EPA
believes that heavy metal and PCB concentrations
could safely exceed the levels recommended for high
80
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quality sludges by a factor of two or three (lead
concentrations should not exceed the 1984
recommendation by more than a factor of 1.5).
Because of the lack of control over the end use of
D&M sludges, permit writers should opt for sludge
quality limits rather than loading restrictions.
Where this is not practical the permit writer should
require the POTW to label the sludge product with
application or loading specifications based on sludge
quality. If pollutant concentrations are excessively
high, the permit writer should prohibit the uncon-
trolled distribution and marketing of the sludge.
7.3.2 Physical Properties
Wastewater sludge should be dewatered prior to
applying a process such as composting in order to
assure a product suitable for distribution and
marketing. Six States are reported to require sludge
dewatering and five States are reported to require
stabilization for distribution and marketing
operations (Table E7-4, State Sludge Treatment/
Management Requirements).
7.4 Operating Conditions and
Management Practices
This section contains federal regulations and
guidance, State requirements and case-by-case
recommendations for the permit writer to use in
developing permit conditions for the operating
conditions and management practices for
distribution and marketing.
Distribution and marketing management practices
reported by the States are presented in Table E7-2,
State Management Practice Requirements, and
Table E7-3, State Site Specific Requirements.
State Requirements
Seven States report requirements for the minimum
distance to the nearest surface water (Table E7-3).
The reported requirements were a minimum distance
of 200 feet (Illinois), 200 feet and not in a water
supply watershed (Rhode Island), 50 to 200 feet
(Utah), 50 feet (Virginia), 25 feet for a drainage ditch,
and 50 to 300 feet to a stream depending on its
classification (Maryland).
Eleven States require run-off control (see table E7-2).
Case-by-Case Recommendation
The permit writer should evaluate whether the
imposition of buffer zones or run-off collection
structures are necessary to protect surface water.
7.4.2 Ground Water Protection
Federal Regulations
Federal regulation (40 CFR 257.3-4) forbids the
contamination of existing or potential underground
drinking water sources by the disposal of non-
hazardous solid waste, including sludges generated
by treatment of domestic sewage. Maximum ground
water contaminant levels are specified in Appendix I
of 40 CFR Part 257.
Federal Guidance
Composting operations (mixing, composting, curing,
and storage) should always be performed on
impervious (i.e., concrete or asphalt) surfaces to
prevent migration of leachate to the ground water.
Leachate collection facilities and/or ground water
monitoring should be considered for facilities where
there is potential for contamination.
7.4.1 Surface Water Protection
Federal Regulations
A facility or practice shall not cause a discharge of
pollutants that is in violation of the NPDES
regulations, a discharge of dredged or fill material
that is in violation of Section 404 of the CWA or cause
non-point source pollution (40 CFR 257.3-3).
Federal Guidance
Runoff from compost facilities should be collected and
treated. Sludge treatment facilities and sludge
disposal sites for treated sludge must not cause non-
point source pollution of waters of the United States
or violate an areawide or Statewide water quality
management plan that has been approved under
Section 208 of the Clean Water Act, as amended.
State Requirements
Eight States report requirements on an acceptable
distance between composting facilities and nearby
wells. The reported requirements for a minimum
distance to a drinking water well range from 100 feet
in Virginia to 1,000 feet in Rhode Island.
7.4.3 Storage
Federal Guidance
A significant amount of storage is provided by the
composting operation itself. However, 6 to 9 months
of additional storage may be necessary depending on
site climate, seasonal fluctuation in the compost
market, and the potential need for further drying or
reduction of odors. To maintain product quality,
storage facilities should protect the finished compost
81
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from contamination and rainfall that would create
run-off or leachate (EPA 1984a).
Some storage of sludge prior to composting may also
be necessary to facilitate system operation and to
provide a back-up in the event of system problems.
State Requirements
Eight States have requirements for storage as a
management practice (EPA 1987). States which
specify a minimum storage time are New Hampshire
(30 days), New York (50 days), and Virginia (60
days).
7.4.4 Buffer Zones/Access Controls
Federal Regulation
Federal regulations state that a facility shall not
allow uncontrolled public access so as to expose the
public to potential health and safety hazards.
State Requirements
Eleven States require buffer zones/access control for
compost facilities (see Table E7-3). The State of
Nevada requires a minimum buffer of 500 feet to the
property line and 1000 feet to the nearest road. The
State of Rhode Island requires a minimum distance of
400 feet to the nearest dwelling. Three other States
reported minimum distance buffer requirements.
7.4.5 Crop Use Limits
State Requirements
Thirteen States reported crop use limits (Table E7-3).
These limits apply primarily to human food chain
crops. The only reported numerical limit was a
Maryland requirement that a product with over 45
percent iron (dry weight basis) must be labeled to
warn against use on pasture. An example label is
seen in Appendix C.
Case-by-Case Recommendations
Information gathered by EPA (EPA 1987) shows that
three States (New Hampshire, Arkansas and
Minnesota) prohibit use of D&M sludge products on
vegetables or in home gardens. Three additional
States prohibit applying sludge to home gardens
(Connecticut), to fruits and vegetables (Oregon), or
on all food-chain crops (Rhode Island) in land
application programs, and may similarly restrict
sludge use in D&M programs. While States may
place whatever restrictions on sludge use they
believe to be appropriate, as a national
recommendation, EPA supports the use of high
quality sludges by home gardeners on all food-chain
crops including fruits and vegetables.
7.4.6 Other Conditions
Case-by-Case Recommendations
Allowing only specific contractors to distribute
and/or market sludge products would provide much
better control over the final use than would general
distribution to the public. Although this requirement
may limit the size of the product market for the
municipality, it may be appropriate where
variability of sludge quality makes the screening or
qualification of D&M manufacturers a wise
precaution in order to assure compliance with
applicable requirements and the safe use and
disposal of the product.
7.5 Monitoring, Reporting, Record
Keeping, and Labeling
Monitoring the sludge, the treatment process, and
the sludge product quality is essential in a
distribution and marketing program from both an
operational and marketability standpoint as well as
for protection of the environment and the public
health. The primary concern with D&M programs is
contaminants in the sludge product and the
subsequent public contact with the product. From a
regulatory standpoint, heavy metals, toxic organics
and primary pathogens (such as viruses, bacteria,
protozoa, and parasites) are the major public health
concerns.
The success of a D&M program is largely influenced
by the ability to produce a consistent product quality,
both physical (e.g., consistent moisture content) and
chemical (e.g., consistently low contaminant
concentrations). Producing a consistent product
involves periodic monitoring of the sludge quality,
the treatment process, and the final sludge product.
7.5.1 Pollutant Concentration Monitoring
Since composting is a biological process, it does not
eliminate heavy metals. Any metals in the sludge
will be present in the compost in virtually the same
quantities although some metals and volatile organic
compounds may be driven off in the off-gas from a
heat-drying process. The distinction to be made
between quantity and concentration is that while
composting may cause the concentration of a
contaminant to change, because bulking agents have
been added and the moisture content has changed,
the quantity of a conservative contaminant will
remain essentially the same as a given mass of
sludge undergoes composting. The heavy metals and
other contaminants of concern in D&M sludge
products were discussed in Section 7.2
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Federal Regulations
The current regulations in 40 CFR 122.44(c)(2)
require sludge monitoring and reporting at a
frequency dependent upon the nature and effect of
the permittee's sludge use or disposal activities, but
at least once a year for every pollutant limited in the
permit. This means that if the permit contains a limit
for PCBs for example, the permittee, must monitor its
sludge at least annually for this pollutant.
Federal Guidance
The Sewage Sludge Interim Permitting Strategy
recommends annual monitoring of the 126 priority
pollutants as well as more frequent monitoring of the
pollutants for which numeric limits have been
proposed in the 40 CFR Part 503 Technical Sludge
Standards. For the reuse practice of distribution and
marketing, these proposed 40 CFR Part 503
pollutants are:
Arsenic
Cadmium
Chromium
DDT/DDE/DDD (total)1
Hexachlorobenzene
Lead
Mercury
PCBs
Toxaphene
Aldnn/Dieldrin
Benzo(a)pyrene
Chlordane
Copper
Heptachlor
Hexachlorobutadiene
Lindane
Nickel
Selenium
Zinc
1 DDT-2,2-Bis(chlorophenyl)-1,1,1 -tnchloroethane
DDE-1,1 -Bis(chlorophenyl)-2,2-dichloroethane
DDD-1,1 -Bis(chlorophenyl)-2,2-dichloroethane
It is suggested that heavy metals and toxic organics
be monitored initially in the sludge to determine the
suitability of the sludge for distribution and
marketing, and to decide if its use or distribution
should be restricted because of the concentration
levels of certain contaminants.
State Requirements
Ten States require sludge and/or sludge product
quality monitoring. Three States specify parameters
to monitor.
One State (Rhode Island) requires an annual EP
toxicity test on the sludge.
Two States specify monitoring frequency. California
bases sampling frequency on the size of the treatment
plant. Monthly monitoring of the compost is required
by Ohio. Each of the State monitoring programs for
distribution and marketing are described in Table
E7-5. State monitoring and reporting requirements
for sludge and compost are provided in Table E7-5.
Case-by-Case Recommendations
The contaminants listed below should be considered
in any sludge or sludge product quality monitoring
program.
Cadmium Nickel Cyanide Pathogens
Chromium Zinc PCBs Salmonella
Copper Nitrogen Sodium
Lead Phosphorus BOD
Mercury Potassium pH
Permit writers should require monitoring for limited
parameters in the sludge product rather than the
sludge used to make a product. Because of the limited
control over use of D&M products and, typically, the
frequent human contact with these materials,
monitoring should be required more frequently than
is generally recommended for other sludge practices.
7.5.2 Treatment Process Monitoring
Federal Guidance
During the composting process, temperatures should
be monitored regularly until temperatures recorded
in the compost (or off-gas from a heat-drying process)
exceed the level and duration required for adequate
pathogen destruction.
Oxygen should also be monitored periodically to
insure that aerobic conditions are maintained.
Operating parameters of other pathogen reduction
processes should also be closely monitored. Research
has shown pathogen regrowth to occur in compost
and drying facilities. This kind of a problem can be
taken care of by additional composting, covering of
the compost and additional monitoring of total
coliforms.
Four States have temperature monitoring
requirements. As noted in the previous discussion of
technologies and operating guidelines, temperature
monitoring is essential for composting and, of course,
heat drying. Temperature monitoring is necessary to
demonstrate compliance with the federal
requirements for Processes to Further Reduce
Pathogens (PFRP).
7.5.3 Soil Monitoring
State Requirements
Nebraska, which requires semiannual soil analysis
for leachate detection, was the only State to report a
soil analysis requirement.
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7.5.4 Reporting and Record Keeping
Federal Requirements
The recently promulgated revisions to the NPDES
permitting regulation (54 FR 18716) require the
permittee to report monitoring results with a
frequency dependent upon the nature and effect of
the sewage sludge use or disposal practice, but in no
case less than one year [40 CFR 122.44(i)(2)]. These
revisions also require that records of monitoring
required by the permit for the permittee's sewage
sludge use and disposal activities must be retained
for a period of at least 5 years [40 CFR 122.21(p)].
State Requirements
Fourteen States require some form of reporting and
record keeping. Most States require records detailing
who received the sludge, how much was received, and
what the intended uses were. Some States require
maintenance of all sludge and sludge product
analytical records. Oklahoma requires all quantity,
destination, quality, and use agreement records to be
held for 5 years.
Reporting frequency varies from State-to-State and
consists of monthly, quarterly, annual, and periodic
reporting schedules (See Table E7-5).
Case-by-Case Recommendations
POTWs should be required to report the amount of
product distributed in bulk form and in bags. Permit
writers should also consider requiring POTWs to
keep a log of persons or entities that receive more
than 10 cubic yards of material per month
(approximately the amount that would fill two large
dump trucks).
7.5.5 Product Labeling
Federal Guidance
At a minimum, labels for bagged sludge or sludge
products for D&M should specify the nitrogen,
phosphorus, and potassium content of the sludge or
sludge product as a percent of the sludge or sludge
product's total weight. The labels do not have to
specify the concentration of contaminants in the
sludge but should state that the information is
available upon request. The POTW (or retailer)
should also be required to provide this information
upon demand. The label should clearly state any
unacceptable uses of the D&M product and
recommend application rates. See Appendix C for
examples of D&M product labels.
State Requirements
Sixteen States require the labeling of D&M sludges.
A compilation of these requirements is listed below.
• Identify contents as a sludge product
• Provide an analytical identification of contents
(e.g., N, P, K, metals)
• Place any necessary warnings or cautions in an
obvious place
• List restrictions on use
• Recommend safe uses and application rates
West Virginia requires that the product be clearly
labeled to indicate that it is not recommended for use
in vegetable gardens.
Case-by-Case Recommendations
All bagged D&M products should be labeled. For
products that are marketed as fertilizers (e.g., heat-
dried sludge) rather than as soil conditioners (e.g.,
compost), labels should specify the nitrogen,
phosphorus, and potassium content of the product as
a percent of the total weight. If the product contains
concentrations of contaminants exceeding the
guidance for unrestricted distribution, the label
should state that the product should not be used on
vegetable gardens.
When writing a permit for a POTW that markets
sludge products that are not suitable for home
vegetable gardens (e.g., sludges with high levels of
metals and PCBs), the permit writer should consult
Tables 7-4 through 7-8. These tables show, for a given
sludge application rate and a given heavy metal
concentration, how many years a sludge product
could be applied before exceeding the guidance on
cumulative metal loadings to privately owned
cropland. Typical application rates and sample
calculations (for interpolating between the given
application rates and metal concentrations) are also
provided. If a sludge product contains contaminants
at levels that could potentially preclude future use of
the site as cropland after ten typical annual
applications, or a single application to establish a soil
(i.e., provide a nutrient base) followed by five years of
use at maintenance rates, the permit writer should
consider requiring that the label state:
"The manufacturer/distributor certifies that this
product meets the requirements specified under
federal regulations at 40 CFR Part 257 and has been
tested using U.S. EPA protocols. Where the user
desires to preserve future, private use of a site for
producing crops, this product should not be applied
more than times at a cumulative amount of
84
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Table 7-4
Metal
Cd
Ni
Metal
Cd
Ni
Metal
Cd
Ni
Metal
Cd
Ni
Years of Application in SI Units for Cadmium ;
Years of Sludge Application at:
1 tonnes/hectare of Heat-Dried Sludge
1 .7 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
8 12 25 55 83 166
83 125 250 555 833 1,666
Years of Sludge Application at:
6 tonnes/hectare of Heat-Dried Sludge
10 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
1 2 4 9 13 27
13 20 41 92 138 277
Years of Sludge Application at:
30 tonnes/hectare of Heat-Dried Sludge
50 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
0001 25
2 4 8 18 27 55
Years of Sludge Application at:
180 tonnes/hectare of Heat-Dried Sludge
300 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
000000
101349
ind Nickel
Years of Sludge Application at:
3 tonnes/hectare of Heat-Dried Sludge
5 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 2 4 8 18 27 55
Nl 27 41 83 185 277 555
Years of Sludge Application at:
15 tonnes/hectare of Heat-Dried Sludge
25 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 0 0 1 3 5 11
Ni 5 8 16 37 55 111
Years of Sludge Application at:
60 tonnes/hectare of Heat-Dried Sludge
100 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 000012
Ni 1 2 4 9 13 27
Years of Sludge Application at:
300 tonnes/hectare of Heat-Dried Sludge
500 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 000000
Ni 001125
Notes:
Composts typically contain 40-50% moisture by weight. This table assumes a 60% solids content, 0.5% total Nitrogen and a
weight of 28 pounds per cubic foot.
Heat-dried sludges may contain 5-10% moisture by weight. This table assumes a 100% solids content and 6.0% total Nitrogen.
Based on recommended application rates for Compgro, a widely available sewage sludge compost, typical compost application
rates are:
Lawn/Establish (one-time high rate application to build a fertile soil): 111 -332 tonnes product per hectare
(49-148 tons per acre)
Lawn/Maintenance: 28-55 tonnes product/hectare (12-25 tons/acre)
Ornamentals and Nursery Crops/Establish: 129-480 tonnes product/hectare (58-214 tons/acre)
Ornamentals and Nursery Crops/Maintenance: 18-37 tonnes product/hectare (8-16 tons/acre)
Based on recommended application rates for Milorganite, a widely available heat-dried sludge, typical application rates for heat-
dried sludge are:
Lawn Maintenance: up to 6 tonnes product/hectare (2.7 tons/acre-yr)
Ornamentals: up to 2.4 tonnes product/hectare (1.1 tons/acre-yr)
85
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Table 7-5 Years of Application in SI Units for Copper, Lead, and Zinc
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Years of Sludge Application at:
1 tonnes/hectare of Heat-Dried Sludge
1 .7 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (rng/kg)
5400 3600 2700 1800 1500 1000 900
23 34 46 69 83 125 138
92 138 185 277 333 500 555
23 34 46 69 83 125 138
Years of Sludge Application at:
6 tonnes/hectare of Heat-Dried Sludge
10 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
3 5 7 11 13 20 23
15 23 30 46 55 83 92
7 11 15 23 27 41 46
Years of Sludge Application at:
30 tonnes/hectare of Heat-Dried Sludge
50 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
01 12244
3 4 6 9 11 16 18
1 234589
Years of Sludge Application at:
1 80 tonnes/hectare of Heat-Dried Sludge
300 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
0000000
0011123
000001 1
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Years of Sludge Application at:
3 tonnes/hectare of Heat-Dried Sludge
5 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
7 11 15 23 27 41 46
30 46 61 92 111 166 185
15 23 30 46 55 83 92
Years of Sludge Application at:
1 5 tonnes/hectare of Heat-Dried Sludge
25 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
1 234589
6 9 12 18 22 33 37
3 4 6 9 11 16 18
Years of Sludge Application at:
60 tonnes/hectare of Heat-Dried Sludge
100 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
0001 122
1234589
0 1 12 2 4 4
Years of Sludge Application at:
300 tonnes/hectare of Heat-Dried Sludge
500 tonnes/hectare of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
0000000
0000111
0000000
Notes:
Composts typically contain 40-50% moisture by weight. This table assumes a 60% solids content, 0.5% total Nitrogen and a
weight of 28 pounds per cubic foot.
Heat-dried sludges may contain 5-10% moisture by weight. This table assumes a 100% solids content and 6.0% total Nitrogen.
Based on recommended application rates for Compgro, a widely available sewage sludge compost, typical compost application
rates are:
Lawn/Establish (one-time high rate application to build a fertile soil): 111 -332 tonnes product per hectare
(49-148 tons per acre)
Lawn/Maintenance: 28-55 tonnes product/hectare (12-25 tons/acre)
Ornamentals and Nursery Crops/Establish: 129-480 tonnes product/hectare (58-214 tons/acre)
Ornamentals and Nursery Crops/Maintenance: 18-37 tonnes product/hectare (8-16 tons/acre)
Based on recommended application rates for Milorganite, a widely available heat-dried sludge, typical application rates for heat-
dried sludge are:
Lawn Maintenance: up to 6 tonnes product/hectare (0.65 tons/acre-yr)
Ornamentals: up to 2.4 tonnes product/hectare (1.1 tons/acre-yr)
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Table 7-6 Years of Application in English Units for Cadmium and Nickel
Metal
Cd
Ni
Metal
Cd
Ni
Metal
Cd
Ni
Metal
Cd
Ni
Years of Sludge Application at:
3 lb/100 sq ft of Heat-Dried Sludge
5 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
5 8 17 37 56 113
56 85 170 379 568 1,137
Years of Sludge Application at:
15 lb/100 sq ft of Heat-Dried Sludge
25 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
1 1 3 7 11 23
11 17 34 75 113 227
Years of Sludge Application at:
60 lb/100 sq ft of Heat-Dried Sludge
100 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
0001 25
2 4 8 18 28 56
Years of Sludge Application at:
420 lb/100 sq ft of Heat-Dried Sludge
700 lb/1 00 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
600 400 200 90 60 30
000000
001248
Years of Sludge Application at:
5 lb/100 sq ft of Heat-Dried Sludge
8 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 3 5 10 22 34 68
Ni 34 51 102 227 341 682
Years of Sludge Application at:
30 lb/100 sq ft of Heat-Dried Sludge
50 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 0 0 1 3 5 11
Ni 5 8 17 37 56 113
Years of Sludge Application at:
150 lb/100 sq ft of Heat-Dried Sludge
250 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 000012
Ni 1 1 3 7 11 22
Years of Sludge Application at:
600 lb/100 sq ft of Heat-Dried Sludge
1,000 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 000000
Ni 000125
Notes:
Composts typically contain 40-50% moisture by weight. This table assumes a 60% solids content, 0.5% total Nitrogen and a
weight of 28 pounds per cubic foot.
Heat-dried sludges may contain 5-10% moisture by weight. This table assumes a 100% solids content and 6.0% total Nitrogen.
Based on recommended application rates for Compgro, a widely available sewage sludge compost, typical compost application
rates are:
Lawn/Establish (one-time high rate application to build a fertile soil): 225-680 Ib product per 100 sq ft
Lawn/Maintenance: 55-115 Ib product per 100 sq ft
Ornamentals and Nursery Crops/Establish: 266-982 Ib product per 100 sq ft
Ornamentals and Nursery Crops/Maintenance: 38-76 Ib product per 100 sq ft
Based on recommended application rates for Milorganite, a widely available heat-dried sludge, typical application rates for heat-
dried sludge are:
Lawn Maintenance: up to 12 Ib product per 100 sq ft-yr
Ornamentals: up to 5 Ib product per 100 sq ft-yr
87
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Table 7-7 Years of Application in English Units for Copper, Lead, and Zinc
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Years of Sludge Application at:
3 lb/100 sq ft of Heat-Dried Sludge
5 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/Kg)
5400 3600 2700 1800 1500 1000 900
11 17 23 34 41 62 89
46 69 92 138 166 250 277
23 34 46 39 83 125 138
Years of Sludge Application at:
15 lb/100 sq ft of Heat-Dried Sludge
25 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
1 123466
4 6 9 13 16 25 27
2 3 4 6 8 12 13
Years of Sludge Application at:
60 lb/100 sq ft of Heat-Dried Sludge
100 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
0001112
1 224477
0112234
Years of Sludge Application at:
420 lb/100 sq ft of Heat-Dried Sludge
700 lb/1 00 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
0000000
0000111
0000000
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Metal
Cu
Pb
Zn
Years of Sludge Application at:
5 lb/100 sq ft of Heat-Dried Sludge
8 lb/1 00 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
2 3 4 6 7 11 12
8 12 16 25 30 45 50
4 6 8 12 15 22 25
Years of Sludge Application at:
30 lb/100 sq ft of Heat-Dried Sludge
50 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
0011123
2 3 4 6 7 11 12
1 123356
Years of Sludge Application at:
150 lb/100 sq ft of Heat-Dried Sludge
250 lb/100 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
000001 1
0112345
0001 122
Years of Sludge Application at:
600 lb/100 sq ft of Heat-Dried Sludge
1 ,000 lb/1 00 sq ft of Composted Sludge
Concentration of Metal in D&M Product (mg/kg)
5400 3600 2700 1800 1500 1000 900
0000000
0000000
0000000
Notes:
Composts typically contain 40-50% moisture by weight. This table assumes a 60% solids content, 0.5% total Nitrogen and a
weight of 28 pounds per cubic foot.
Heat-dried sludges may contain 5-10% moisture by weight. This table assumes a 100% solids content and 6.0% total Nitrogen.
Based on recommended application rates for Compgro, a widely available sewage sludge compost, typical compost application
rates are:
Lawn/Establish (one-time high rate application to build a fertile soil): 225-680 Ib product/100 sq ft
Lawn/Maintenance: 55-115 Ib product/100 sq ft
Ornamentals and Nursery Crops/Establish: 266-982 Ib producViOO sq ft
Ornamentals and Nursery Crops/Maintenance: 38-76 Ib product/100 sq ft
Based on recommended application rates for Milorganite, a widely available heat-dried sludge, typical application rates for heat-
dried sludge are:
Lawn Maintenance: up to 12 Ib product/100 sq ft-yr
Ornamentals: up to 5 Ib product/100 sq ft-yr
88
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Table 7-8 Sample Calculations for Years of Application
Parameters
SI Unit Tables
English Unit Tables
1. Sludge loading rate
2. Parameter concentration
3. Parameter cumulative loading limit
4. Parameter deposition rate
5. Years of use at that rate
= (Site Life * Annual Loading)
1 tonne/hectare-yr
30 mg Cd/kg sludge
5 kg Cd/hectare
1 tonne/hectare-yr x 1000 kg sludge/tonne
x 0.0006 kg Cd/kg sludge
= 03 kg Cd/hectare-yr
5 kg Cd/ha * .03 kg Cd/ha/yr
= 166.66 > 166 yr
(rounded down to next integer)
3lb/100sqft-yr
30 mg Cd/kg sludge
5kg Cd/hectare
3 lb/100 sq ft x 0.45359 kg/lb
x 0.00003 kg Cd/kg sludge
= 0.000041 kg Cd/100 sq ft-yr
(5 kg/ha x ha/107640 sq ft)
* (.000041 kg Cd/100 sq ft-yr)
= 113.2 > 113 yr
(rounded down to next
integer)
_ tonnes per hectare ( tons per acre or
. pounds per 100 square feet)."
All D&M product labels should provide directions for
use and recommended application rates. Appendix C
contains a number of labels currently in use that
provide good information. In addition, permit writers
should consider requiring that labels include a
statement similar to the one below:
As with any fertilizer or soil conditioner, this
product should be used in a manner that will
prevent it from washing into sewer drains or
surface waters.
Any D&M product distributed to the public in bulk
form (i.e., not bagged) should be accompanied by a
flyer that contains the same information recom-
mended for D&M labels. The POTW should also take
measures to ensure that any redistributor or broker
of the D&M product meets these recommendations
for labels and flyers.
References
Chaney 1982. Fate of toxic substances in sludge
applied to cropland. International Symposium on
Land Application of Sewage Sludge, Tokyo, Japan,
1982.
EPA 1979. Process Design Manual for Sludge
Treatment and Disposal. U.S. Environmental
Protection Agency, EPA 625/1-79-011, September
1979.
EPA 1981. Land Application of Municipal Sewage
Sludge for the Production of Fruits and Vegetables: A
Statement of Federal Policy and Guidance. SW-905,
U.S. Environmental Protection Agency.
EPA 1984a. Environmental Regulations and
Technology: Use and Disposal of Municipal Waste
Water Sludge, U.S. Environmental Protection
Agency, EPA 625/10-84-003.
EPA 1984b. Sludge Composting and Improved
Incinerator Performance, EPA Seminar, Columbus,
Ohio, July 11 and 12, 1984. U.S. Environmental
Protection Agency, Municipal Environmental
Research Laboratory, Cincinnati, Ohio.
EPA 1985a. Summary of Environmental Profiles and
Hazard Indices for Constituents of Municipal Sludge;
Methods and Results, U.S. Environmental Protection
Agency (OWRS), July 1985.
EPA 1985b. Composting of Municipal Wastewater
Sludges. U.S. Environmental Protection Agency,
EPA 625/4-85-014,1985.
EPA 1987. State Requirements for Sludge
Management, U.S. Environmental Protection
Agency, Office of Municipal Pollution Control and
Office of Water Enforcement and Permits.
Washington D.C. (Revised 1987)
EPA 1989. Environmental Regulations and
Technology: Control of Pathogens in Municipal
Wastewater Sludge. U.S. Environmental Protection
Agency, EPA 625/10-89-006. October 1989.
MES 1984. Operations Manual for Sewage Sludge
Composting: Blue Plains Wastewater Treatment
Plant. Maryland Environmental Service, Annapolis
MD, 1984.
USD A 1984. Use of Sewage Sludge Compost as a Soil
Conditioner and Fertilizer for Plant Growth. U.S.
Department of Agriculture, Agricultural Information
Bulletin No. 464.1984.
89
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Chapter 8
Incineration
8.1 Introduction
Chapter 8 provides the permit writer with a
description of sludge combustion practices at POTWs,
and also summarizes federal requirements and
guidance and state requirements pertaining to
sludge incineration. The disposal of ash resulting
from incineration is not covered by this Guidance
Manual because ash is a solid waste that will
continue to be regulated under 40 CFR Part 257 (or
under 40 CFR Part 258, once promulgated, if disposed
of in a municipal landfill). Appendix E, Tables E8-1
through E8-3 present State requirements in more
detail.
Based on a recent EPA survey, 166 POTWs currently
own or operate sewage sludge incinerators in the
United States. While the aggregate human health
effects of sludge incineration appear to be low,
information gathered by EPA indicates that of the
methods employed to re-use or dispose of sludge,
incineration exposes the greatest number of people to
levels of pollutants that may, over many years of
exposure, lead to adverse health effects. Studies
performed in developing EPA's proposed technical
standards for sludge incineration indicate that about
140,000 people are exposed to theoretical Most
Exposed Individual Risks of 10-3 or greater. For this
reason, the Interim Permitting Strategy states that
incinerators should be considered a "priority" (i.e.,
Class I) for permitting purposes unless available
information shows no cause for concern.
A complexity immediately arises when permit
writers begin writing NPDES permits for POTWs
that incinerate the sewage sludge generated by
wastewater treatment. The Clean Water Act provides
the mandate for EPA to focus attention on potential
threats to public health and the environment (e.g.,
sludge incinerators) while the expertise in regulating
emissions from these sources rests with EPA, State or
local officials who work in programs that have
traditionally implemented the Clean Air Act. Reg-
ulating a POTWs incineration activities may be the
most difficult multi-media responsibility assigned to
the NPDES permit writer.
8.1.1 Permitting Responsibilities
Regulation of air emissions at the national level is
complex and often comprised of different
requirements under different programs covering
various pollutants, geographic areas, and industries.
Sludge permit writers should work with State and
regional air management authorities to ascertain
which, if any, air emissions limits apply to the
POTWs' incinerators. In some cases sewage sludge
incinerators may not be permitted. This will depend
on the facility's age. Any incinerator which began
operation before the air regulations were
promulgated is not required to have a permit unless
it is planning major modifications. In addition, many
of the early incinerator permits do not contain
emission limits or operation requirements. Whether
emissions are formally limited through an air permit
or not, NPDES permit writers are responsible to
ensure that the ultimate disposal of sewage sludge is
carried out in a manner that does not pose risks to
public health and the environment. This will require
considerable flexibility and coordination between
offices of water and air regulation to establish
institutional arrangements to address sludge
incineration. At a minimum, for Class I POTWs, the
NPDES permit writer should:
• Identify in the documentation accompanying the
NPDES permit for a POTW that uses sludge
incineration, the existing federal and State
requirements for sludge incineration that apply
to the facility, or reference the air permit
containing such requirements; and
• Consider writing additional recommended
conditions into the permits for these POTWs (e.g.,
as suggested in this guidance). Air Office officials
should be consulted when incorporating any of
these recommendations. Arrangements between
Air Office and Water Office personnel will need
to be made for monitoring compliance with these
conditions. (For a list of appropriate contacts, see
Appendix B.)
• If, through consultation with the Air Office
officials, a problem is identified with incinerator
emissions and this problem is a result of sludge
91
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quality, pollutant-specific numerical limits may
be developed with support from the Air Office and
incorporated in the NPDES permit.
8.2 Incineration Technology
Incineration is the complete combustion of materials
in a single step in the presence of oxygen.
Incineration is the most commonly used combustion
operation for destruction of wastewater sludge.
Approximately 20 percent of POTW sludge is
disposed of via sludge incineration. There are no
federal regulations specifying the type of incinerator
that must be used to incinerate sewage sludge.
However, the State of Kansas requires a multi-
chamber system and Rhode Island requires multi-
chamber, multi-hearth, fluidized-bed, or a cyclonic
furnace.
The most common types of furnaces currently used
for sludge incineration are the multiple-hearth
furnace and the fluidized-bed furnace. Although a
few electric-infrared furnaces have also been
installed, the multiple-hearth furnace is the most
widely used design, accounting for 75 to 80 percent of
the sludge furnaces in operation today in the United
States. Fluidized bed furnaces and electric-infrared
furnaces account for approximately 16 and 4 percent,
respectively, of the sludge furnaces installed in the
United States (EPA, 1985a). Two other methods -
starved-air combustion and co-incineration — are
much less commonly used in the United States.
Electric-Infrared Furnace
The electric-infrared furnace is a horizontally
oriented, rectangular steel shell containing a moving
horizontal, woven-wire belt. Sludge is fed into the
electric-infrared furnace through a feed hopper that
discharges onto the woven-wire belt. The layer of
sludge moves under the infrared heating elements,
which provide supplemental energy for the drying
process. Combustion airflow is countercurrent to the
sludge flow, and ash is discharged from the end of the
belt to the ash handling system.
Co-Incineration
Co-incineration is the burning of municipal sludge
and refuse together. Only about one percent of the
sludge incinerators in operation today are operated in
a co-incineration mode. Co-incineration facilities
may be subject to current federal regulations for
sludge incineration, refuse incineration, and co-
incineration depending on the relative amounts of
material incinerated. In general, permit writers
should defer to air office officials in developing co-
incineration permit conditions.
Starved Air Combustion
In starved-air combustion, sludge is burned in a two-
step process. In the first step, the volatile portion of
the sludge is burned out leaving an ash, but there is
insufficient oxygen to combust all of the gaseous
compounds pyrolyzed out of the sludge. In the second
step, combustion of these gases is completed in an
afterburner chamber.
Multiple-Hearth Furnace
The multiple-hearth furnace is a vertically oriented,
refractory-lined, steel cylinder containing a series of
horizontal brick hearths, one above the other, and an
air-cooled vertical shaft equipped with radial arms
cantilevered over the hearths. Sludge is fed at the top
of *;he furnace and sequentially scraped by plow-like
blades mounted on the center-shaft arms across each
hearth before dropping to the hearth below. The
countercurrent flow of rising exhaust gases and
descending sludge provides effective drying and
combustion of the sludge.
Fluidized-Bed Furnace
The fluidized-bed furnace is a vertically oriented,
refractory-lined steel cylinder that contains a sand
bed that, at rest, sits upon a base plate equipped with
an array of fluidizing air diffusers. Air is injected into
the furnace through the diffusers at a pressure of 3 to
5 psig to lift and fluidize the sand. The sludge feed is
either above or directly into the bed. Ash is carried
out the top of the furnace with the exhaust gas.
8.2.1 Definitions
Provided below are some definitions which may
clarify some of the process-specific terminology.
Afterburner - pollution control equipment designed
to burn hydrocarbons which have escaped the
incineration process. Sometimes the upper hearth of
a multiple hearth incinerator can be used in lieu of
additional equipment.
Excess Air - the process of incineration depends on
having enough excess oxygen to interact with the
organic matter so that complete combustion will
result. Excessive amounts of oxygen cause
unnecessarily high gas velocities thereby increasing
particulate emission.
Feed Rate - flow of dewatered sludge into the
incinerator. Monitoring sludge feed rate
continuously allows for more efficient incineration
operation. A large increase in feed rate causes the
combustion zone of the multiple hearth furnace to
drop to a lower hearth and causes increased gas flow
with increased particle emissions. A large decrease
92
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raises the combustion zone to a higher hearth which
reduces residence time and increases the emission of
unburned hydrocarbons.
Off gas - exit or exhaust gas from the incineration
process.
Recombustion - the process to remove the products of
incomplete combustion or the unburned
hydrocarbons from the off-gas of the incinerator.
Afterburners function as recombustion chambers.
8.3 Current Regulatory Requirements
The existing federal regulations related to sludge
incineration are summarized below. It should be
noted that State agencies can, and in some cases do,
have requirements more stringent than the
minimum federal requirements.
8.3.1 New Source Performance Standards
(NSPS) (40 CFR Part 60)
EPA's Office of Air and Radiation or its counterpart
programs in the States enforce the NSPS. Revised
New Source Performance Standards were
promulgated by EPA on October 6, 1988 (53 FR
39412).
Any incinerators that burn municipal sludge and
that commenced construction or modification after
June 11, 1973 are subject to NSPS. The rate of
particulate discharge cannot exceed 1.30 pounds of
particulates per ton (0.65 g/kg) of dry sludge feed and
the gas discharged cannot exhibit more than 20
percent opacity (40 CFR Part 60 Subpart O). These
requirements apply, even to co-incineration facilities,
if the facility burns wastes containing more than 10
percent sewage sludge (dry basis) or charges more
than 1,000 kg (2,205 Ib) per day municipal sewage
sludge (dry basis).
Co-incineration of sludge and municipal refuse in
incinerators with a charging rate greater than 50
tons per day (45 metric tons/day) and with municipal
refuse constituting 50 percent or more of the charge
that commenced construction or modification after
August 17, 1971, cannot emit more than 0.08 grains
of particulates per dry standard cubic foot (0.18
g/dsm3 dry) corrected to 12 percent carbon dioxide
(Subpart E).
8.3.2 National Emissions Standards for
Hazardous Air Pollutants (NESHAPs) (40
CFR Part 61)
EPA's Office of Air and Radiation or its counterpart
programs in the States enforce the NESHAPs.
NESHAPs regulate mercury and beryllium. Any
operation that burns or dries wastewater sludge
cannot discharge more than 3,200 grams of mercury
per 24-hour period (Subpart E). Incinerators that
process beryllium containing waste shall not emit
over 10 grams of beryllium over a 24-hour period
(Subpart C).
It should be noted that the analytical detection limit
for Be is 0.2mg/l. Thus the limit of 10 g/day is only
detectable if the flow into the incinerator is less than
13.2 mgd. For higher flows non-detectable levels
would not ensure compliance. The analytical
detection limit for Hg is also 0.2mg/l. Thus the 3,200
g/day limit is detectable in all flows under 4,277 mgd,
which ensure detection at all currently operating
sewage sludge incinerators.
8.3.3 Toxic Substances Control Act (TSCA)
EPA's Office of Pesticides and Toxic Substances is
responsible for enforcing requirements for
incineration of sludge containing greater than 50
mg/kg PCBs. Incinerators burning sludges with PCB
concentrations greater than 50 mg/kg must be
approved by the Regional Administrator or Assistant
Administrator for Pesticides and Toxic Substances.
Incinerators for sewage sludges containing over 50
mg polychlorinated biphenyls (PCBsVkg dry sludge
solids must comply with the specific design and
operational requirements of the Toxic Substances
Control Act (TSCA).
8.3.4 National Ambient Air Quality Standards
(NAAQS) and State Implementation Plan
(SIPs) (40 CFR Part 50)
The National Ambient Air Quality Standards
(NAAQS) in 40 CFR Part 50 establish threshold
levels for air pollutants which pose the greatest
overall threat to air quality. The "criteria pollutants"
include ozone, carbon monoxide, airborne particu-
lates, sulfur dioxide, lead, and nitrogen oxides (See
Table 8-1). For these pollutants, the regulations set
primary standards to protect human health (See
Table 8-2) and secondary standards to protect
"welfare" (crops, livestock, vegetation). The Clean
Air Act (CAA) requires each State to develop a State
Implementation Plan (SIP) for attainment of the
standards. For those areas which are already meeting
NAAQS, the implementation plans must include a
program for Prevention of Significant Deterioration
(PSD).
For those areas that are not in attainment for one or
more of the criteria pollutants, SIPs provide for
emission controls, transportation controls, source
monitoring, ambient air quality monitoring, and
procedures for review and approval of new sources of
air pollution prior to construction. Sewage sludge
incineration emissions may be limited under a SIP if
that incinerator is identified as a major source of the
pollutant for which the area is in non-attainment.
93
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Table 8-1
Pollutant
National
Carbon Monoxide
Ambient Air Quality Standards*
Averaging Time
8 hr
ihr
Primary Standard
10 mg/m3 (9 ppm)
40 mg/m3 (35 ppm)
Secondary Standard
-
Measurement Method
Nondispersive infrared
spectroscopy
Nitrogen Dioxide
Sulfur Dioxide
Suspended paniculate
matter
Ozone
Lead
Annual average 100 ug/m3 (0.053 ppm)
80 ng/m3 (0.03 ppm)
365 iig/m3 (0.14 ppm)
Annual average
24 hr
3 hr
Annual geometric mean
24 hr
1 hr
3 months
75 u,g/m3
260 u,g/m3
235 ug/m3 (0.12 ppm)
1.5 jag/m3
Same
i,300iig/m3 (0.5 ppm)
60 ug/m3
150 ng/m3
Same
Same
Colorimetric using NaOH
Pararosaniline method
High-volume sampling
Chemiluminescent
method
* Standards, other than those based on annual average or annual geometric average, are not to be exceeded more than once a year.
Note: National primary ambient air quality standards define levels of air quality which the Administrator judges are necessary, with an
adequate margin of safety, to protect the public health. National secondary ambient air quality standards define levels of air quality which the
Administrator judges necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. (40 CFR 50.2)
Table 8-2
Air Quality
Level
Significant
harm
Emergency
Warning
Alert
NAAQS
50 % Of
NAAQS
Health Effects of
TSP SO2
(24-hr), (24-hr),
ug/m3 ug/m3
1,000 2,620
875 2,100
625 1 ,600
375 800
260 365
75b 80b
0 0
Air Pollutants
Pollutant Levels
CO 03
(8-hr), (1 -hr),
mg/m3 ug/m3
57.5 1,200
40.0 1 ,000
34.0 800
17.0 400«
10.0 240
5.0 120
0 0
N02(1- Health
hr), Effect
ug/m3 Descriptor General Health Effects
3,750 Premature death of ill and
elderly. Healthy people will
experience adverse
symptoms that affect their
normal activity
Hazardous
3,000 Premature onset of certain
diseases in addition to
significant aggravation of
symptoms and decreased
exercise tolerance in
healthy persons.
2,260 Significant aggravation of
symptoms and decreased
Very exercise tolerance in
unhealthful persons with heart or lung
disease, with widespread
symptoms in the healthy
population.
1 , 1 30 Mild aggravation of
symptoms in susceptible
Unhealthful persons, with irritation
symptoms in the healthy
population
a
Moderate
a
Good
0
Cautionary Statements
All persons should remain
indoors, keeping windows
and doors closed. All
persons should minimize
physical exertion and avoid
traffic
Elderly and persons with
existing diseases should
stay indoors and avoid
physical exertion. General
population should avoid
outdoor activity.
Elderly and persons with
existing heart or lung
disease should stay indoors
and reduce physical
activity
Persons with existing heart
or respiratory ailments
should reduce physical
exertion and outdoor
activity
a No index values reported at concentration levels below those specified by "Alert Level" criteria
b Annual primary NAAQS.
c 400 ug/m3 was used instead of the O3 "Alert Level" of 200 jig/m3.
94
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8.3.5 New Source Review Standards (NSRS)
(40 CFR 51.160)
The new Source Review Standards require a
preconstruction review of all new construction of or
modification to stationary sources to determine if the
source will meet all applicable emission require-
ments of the SIPs and the EPA's Emission Offset
Policy. If the permit writer finds the POTW is
planning new construction or modification to an
incinerator, the air office should be consulted
immediately. 40 CFR 51.160 and Appendix S of 40
CFR Part 51 contain additional information on the
New Source Review Standards.
8.3.6 Prevention of Significant Deterioration
(PSD) (40 CFR 52.21)
The purpose of EPA's Prevention of Significant
Deterioration (PSD) program is to preserve the air
quality of areas currently attaining NAAQS. PSD
review is the responsibility of the Office of Air and
Radiation or its counterpart office in the States. The
PSD regulation applies to sewage sludge incinerators
constructed or modified after August 7, 1977 if the
incinerator emits 250 tons per year or more of any
pollutant subject to regulation under the CAA. Any
stationary source capable of emitting 250 tons per
year or more of any regulated air pollutant is defined
as a major stationary source. In addition, particular
stationary sources (e.g., municipal incinerators
capable of charging more than 250 tons of refuse per
day) which have the potential to emit 100 tons per
year or more of any regulated air pollutant are
defined as a major stationary source and subject to
PSD review.
Major stationary sources undergoing modifications
that would result in a significant increase in
emissions of any of the pollutants listed in Table 8-3
would also be subject to PSD review.
PSD requirements for major stationary sources
include:
• Installing Best Available Control Technology for
each pollutant subject to regulation under the
CAA if the source would have the potential to
emit that pollutant in significant amounts.
• Demonstrating that the allowable emissions
would not cause or contribute to air pollution in
violation of air quality regulations.
8.4 Characteristics of Sludges Suitable
for Incineration
The properties of sludges suitable for incineration
include an adequately high concentration of
combustible material, a low moisture content, and a
Table 8-3 Levels of Net Emissions Increase that Qualify as
Major Modifications Requiring PSD Review
• Carbon monoxide: 100 tons per year (tpy)
• Nitrogen oxides: 40 tpy
• Sulfur dioxide: 40 tpy
• Paniculate matter: 25 tpy
• Ozone: 40 tpy of volatile organic compounds
• Lead: 0.6 tpy
• Asbestos: 0.007 tpy
• Beryllium: 0.0004 tpy
• Mercury: 0.1 tpy
• Vinyl Chloride: 1 tpy
• Fluorides: 3 tpy
• Sulfunc Acid Mist: 7 tpy
• Hydrogen Sulfide (H2S): 10 tpy
• Total Reduced Sulfur (including H2S): 10 tpy
• Reduced Sulfur Compounds (including H2S): 10 tpy
low concentration of non-combustible contaminants
such as certain heavy metals.
8.4.1 Pollutant Concentration Limits for Sludge
Feed and Air Emissions
Few regulations under the CAA specify sludge
quality conditions; most address air emission levels.
This sub-section provides a listing of specific
pollutants along with their current federal emissions
or ambient air concentration limits (if any), and any
general guidance and discussion of contaminant
limits from federal literature. Limits for specific
States (if any) are tabulated in Appendix E, Tables
E8-1 and E8-2.
In sludge incineration, the fate of heavy metals and
chemical compounds depends largely on their ability
to associate with small particles. Volatile elemental
metals include Hg, Cd, Pb, As and Zn. These may be
emitted at concentrations higher than the average of
the bulk sludge ash if furnace temperatures are set
too high.
EPA's Office of Air and Radiation or designated State
agencies administer five regulatory programs that
may limit sewage sludge incinerator emissions:
National Ambient Air Quality Standards (NAAQS)
(40 CFR Part 50), NSPS (40 CFR Part 60), New
Source Review Standards (40 CFR 51.160),
NESHAPS (40 CFR Part 61) and Prevention of
Significant Deterioration (PSD) (40 CFR 52.21).
Permit writers should consult with the officials
responsible for these programs and should identify in
the NPDES permit documentation any requirements
imposed on a municipal sludge incinerator.
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Federal Regulations
The only required pollutant concentration (or
pollutant characteristic) limits for incinerated
sewage sludges are: 1) the sludge shall not be a
hazardous waste; and 2) the sludge shall not contain
more than 50 ppm (mg/kg) of PCBs unless it is
burned in an incinerator approved by EPA to burn
PCBs. The federal emissions limits and/or ambient
air quality standards are described below. Table 8-4
presents an outline of contaminant concentrations in
the federal regulations.
Beryllium
Incinerators that process beryllium-containing waste
shall not emit over 10 grams of beryllium over a 24-
hour period. Beryllium-containing waste is defined
as material contaminated with beryllium and/or
beryllium compounds used or generated by extraction
plants, ceramic plants, incinerators or propellant
plants that process beryllium ore, beryllium oxide, or
beryllium alloys, or by machine shops that process
beryllium, beryllium oxides, or any alloy when such
alloy contains more than 5 percent beryllium by
weight (40 CFR Part 61 Subpart C).
Facilities may request a variance from this
requirement provided that at least 3 years of data are
available to demonstrate that the future ambient
concentrations of beryllium in the vicinity of the
stationary source will not exceed 0,01 ug/m3,
averaged over a 30-day period. (40 CFR 61.32(b)).
Carbon Monoxide
Emissions should not cause ambient concentrations
of carbon monoxide in the vicinity of the stationary
source to exceed the NAAQS of 10 mg/m3 on an 8-
hour average and 40 mg/m3. 1-hour average.
Additionally, New Source Review Standards or PSD
may apply to large facilities.
Lead
Emissions of lead should not cause ambient
concentrations of lead in the vicinity of the stationary
source to exceed the NAAQS of 1.5 ug/m3, averaged
over a calendar quarter. Additionally, New Source
Review Standards or PSD may apply to large
facilities.
Mercury
Subpart E of the NESHAPs states that sludge
incinerators, sludge dryers, or combinations of these
facilities shall not emit more than 3,200 grams of
mercury in a 24-hour period. Unless a waiver of
emission testing is obtained under the general
NESHAP waiver provisions (40 CFR 61.13), each
owner or operator shall determine mercury emission
concentrations within 90 days of start-up (existing
sources were required to make the determination
within 90 days of the rule's effective date in 1975).
Table 8-4 Federal Concentration Units for Contaminants*
Beryllium
Emissions
Limit of
10 g per
24-hr period.
Lead Mercury Opacity
Ambient Air Emissions Emissions
Limit of Limit of Limit of
1 .5 ug/m3 3,200 g per 20 percent
averaged 24-hr period, opacity.
over a
calendar
quarter.
Particulates
Emissions
Limit of
0.65 g/kg dry
sludge feed.
Ambient Air
Limit of
75 u.g/m3
(annual
geometric
mean).
260 iig/m3
(24-hr
average.)
Sulfur
Dioxide
Ambient Air
Limit of
80 ug/m3
(annual
average).
365 ug/m3
(24-hr
average.)
Carbon
Monoxide
Ambient Air
Limit of 10
mg/m3
(8-hr
average).
40 mg/m3 (1-
hr average).
Nitrogen
Dioxide
Ambient Air
Limit of
100 iig/m3
(annual
average).
Ozone
Ambient Air
Limit of
235 ug/m3
(1-hr
average).
* Major stationary sources may also be subject to New Source Review Standards or Prevention of Significant Deterioration Regulations (see
Section 9.1.2).
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The determination shall be made either by stack gas
sampling or by a calculation based on sludge-feed
sampling where it is assumed that all mercury in the
sludge is volatilized.
Operators of incinerators with mercury emissions
exceeding 1,600 grams/day are required to monitor or
calculate mercury emissions annually. Prior to any
changes in operation that would potentially increase
emissions above that determined by the most recent
source test, a new emissions level must be estimated
by calculation and the results reported to the
Administrator.
metric tons/day) and with municipal refuse
comprising 50 percent or more of the charge cannot
discharge more than 0.08 grains of particulates per
dry standard cubic foot (0.18 g/dsm3) corrected to 12
percent carbon dioxide (40 CFR Part 60, Subpart E).
Emissions should not cause ambient concentrations
in the vicinity of the stationary source to exceed the
NAAQS of 75 ug/m3 annual geometric mean and 260
ug/m3 24-hour average. Additionally, New Source
Review Standards or PSD may apply to large
facilities.
Nitrogen Oxides
Emissions should not cause ambient concentrations
of nitrogen dioxide in the vicinity of the stationary
source to exceed the NAAQS of 100 ug/m3 annual
average. Additionally, New Source Review
Standards or PSD may apply to large facilities.
Opacity
Gas discharged from incinerators that burn
municipal wastewater sludge shall not have more
than 20 percent opacity. Where the presence of
uncombined water is the only reason for failure to
meet the 20 percent opacity limit, such failure shall
not be a violation of this requirement (40 CFR Part
60, Subpart O).
Ozone/Photochemical Oxidants
Emissions should not cause ambient concentrations
of ozone in the vicinity of the stationary source to
exceed the NAAQS of 235 ug/m3 1-hour average.
Additionally, New Source Review Standards or PSD
may apply to large facilities.
Particulates
Particulates discharged from incinerators that burn
municipal wastewater sludge cannot occur in excess
of 1.30 pounds per ton dry sludge input (0.65g/kg dry
sludge input) (40 CFR Part 60, Subpart O). The
standard applies to sludge incinerators that have
been constructed or modified after June 11, 1973.
During start-up of operations, incinerator operators
must demonstrate compliance with the standard.
Incinerator operators must also install, calibrate,
maintain, and operate a flow measuring device that
can be used to determine the mass or volume of
sludge charged to the incinerator. The flow
measuring device shall have an accuracy of plus or
minus 5 percent over its operating range. For more
information, consult Subpart A of the NSPS (40 CFR
Part 60).
Co-incineration of sludge and municipal refuse with
a charging rate greater than 50 tons per day (45
Polychlorinated Biphenyls (PCBs)
Incinerators that burn sludges containing more than
50 mg PCBs/kg dry sludge solids shall comply with
40 CFR 761.70. This regulation has very strict
emission requirements and must be consulted if the
permit writer needs to incorporate these
requirements in the NPDES permit. The appropriate
air regulatory authority should be consulted first.
Sulfur Oxides
Emissions should not cause ambient concentrations
of sulfur dioxide in the vicinity of the stationary
source to exceed the NAAQS of 365 ug/m3 24-hour
average and 80 ug/m3, annual average. Additionally,
New Source Review Standards or PSD may apply to
large facilities.
Federal Guidance
Arsenic
In the EPA listing of hazard indices to assess human
toxicity/cancer risk resulting from the inhalation of
incinerator emissions, one of the compounds that
posed the highest increase in human health risk was
arsenic (EPA, 1985b). If there is reason to believe
that there is arsenic in the sewage sludge that is to be
incinerated, the permit writer should consult with
the appropriate Air Office to determine the type of
controls needed.
Cadmium
In the EPA listing of hazard indices to assess human
toxicity/cancer risk resulting from the inhalation of
incinerator emissions, one of the compounds that
posed the highest increase in human health risk was
cadmium (EPA, 1985b). If there is reason to believe
that cadmium is present in the sewage sludge to be
incinerated, the permit writer should consult with
the appropriate Air Office to determine the type of
controls needed.
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Chromium
In the EPA listing of hazard indices to assess human
toxicity/cancer risk resulting from the inhalation of
incinerator emissions, one of the compounds that
posed the highest increase in human health risk was
hexavalent chromium (EPA, 1985b). If there is
reason to believe that there is chromium in the
sewage sludge that is to be incinerated, the permit
writer should consult with the appropriate Air Office
to determine the type of controls needed.
Vinyl Chloride
Although vinyl chloride limits in 40 CFR Part 61 do
not presently apply to wastewater sludge
incinerators, it is noteworthy that this regulation
limits the vinyl chloride exhaust gas emissions to 10
ppm for vinyl chloride plants, polyvinyl chloride
plants, and ethylene dichloride plants.
State Requirements
No State reported any specific maximum sludge
contaminant concentrations above which
incineration would not be allowed. All reported State
requirements addressed emission levels. Most State
emissions standards for sewage sludge incinerators
simply repeat the federal requirements. However, a
few individual States have set other emission
standards. State standards are listed in Appendix E,
Table E8-1.
Beryllium
New Jersey and New Hampshire report a beryllium
emissions limit.
range from 0.08 to 4.6 grains/dry standard cubic foot
(DSCF) (0.005 to 0.3 grams/DSCF), 1.3 Ib/ton dry
sludge input, 2 lb/100 Ib refuse, a limit of 0.5
Ib/million BTU heat output, and a range of 0.2 to 0.1
percent of the charging rate.
8.4.2 Sludge Physical Properties
Federal Regulations
There are no current federal regulations regarding
the physical properties of sludges suitable for
incineration.
Percent Combustible Solids
Federal Guidance
The combustible content of the sludge affects the
amount of fuel required for incineration. With higher
combustible content less fuel and/or dewatering are
required and less material remains for final disposal.
Because wastewater sludge typically has an
adequately high percent of combustible solids and a
high heat content per unit weight of combustibles,
the limiting factor in fuel consumption is the
moisture content of the sludge.
State Requirements
There are currently no State regulations governing
percent combustible solids.
Carbon Monoxide
Illinois and Missouri report a carbon monoxide limit.
Mercury
Georgia, Kentucky, New Jersey and Tennessee were
the only States that reported requirements for a
mercury limitation (all reported a 3,200 grams
mercury per day limit).
Opacity
The States of Alaska, Delaware, Georgia, Iowa,
Kentucky, New York, Ohio, Oklahoma, and
Wisconsin reported a 20 percent opacity limit as a
State regulation.
Particulates
Many States have limits for particulates. However,
the reported limits vary both numerically and in the
specified units. For example, reported State limits
Moisture Content and Dewatering
Federal Guidance
Efficient dewatering is essential prior to sludge
incineration to avoid high costs for supplemental
fuel. Sludge typically must be dewatered to between
25 and 35 percent solids to approach autogenous (self-
sustaining) combustion. Higher solids levels are
needed for autogenous combustion when the
concentration of ash (or inert conditioners such as
lime, ferric chloride, or recycled ash) is high. The
incineration of low percent solids sludge could
require large amounts of expensive supplemental
fuel. It is important to avoid fluctuations in moisture
content. An equalization chamber in front of the
incinerator would help with moisture content and
feed rate fluctuations.
State Requirements
The States of Kentucky and New Jersey reported
requirements for sludge dewatering.
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8.5 Operating Conditions and
Management Practices
As stated in the Sewage Sludge Interim Strategy,
permit writers should consider any POTW that
incinerates its sludge a Class I POTW for permitting
purposes unless after considering the following
factors, a BPJ determination can be made that the
incinerator emissions pose no threat to human health
and the environment. The factors to consider are:
POTW sludge quality, the compliance history of the
incinerator, height of the incinerator stack, whether
there are tall buildings in the vicinity of the
incinerator that may cause a downwash of emissions,
whether any features of the surrounding geography
are high enough in relation to the stack to cause the
emissions plume to contact the ground near the
incinerator, and the population density downwind
from the incinerator in the direction(s) that
prevailing winds blow.
Permit writers should request the assistance of air
office officials when evaluating the potential risk
posed by incinerators. Permit writers should also
work closely with air office officials to determine the
appropriateness of the following operation conditions
at a particular incinerator. Arrangements between
air office and water office personnel will need to be
made for monitoring compliance with conditions
placed into NPDES permits.
Following is a description of various operation
conditions and management practices relevant to
incineration. The first section covers federal and
State requirements and recommendations. The
second section describes operating parameters
specific to particular technologies and highlights the
differences in operating efficiencies between the
different technologies. The third section describes the
different types of emission control technologies.
8.5.1 General Operating Conditions and
Management Practices
Emissions from a sludge incinerator vary depending
on the type of incinerator technology. Other factors
effecting emissions include (1) physical properties of
the sludge as described in Section 8.4.1 of this
manual, (2) the sludge feed rate (3) temperature
profile of the incinerator, particularly the combustion
and exhaust temperatures, (4) the amount of excess
air used for incineration, (5) combustion efficiency
and residence times, (6) operator control, and (7) the
type and operation of emissions control system.
Appropriate regulation of each of these parameters
minimizes the impact of sewage sludge incineration
on public health and the environment.
Federal Guidance
Sludge Feed Rate
A constant sludge feed rate is desirable because
changes in feed rate can cause smoke or increase
emissions. Loadings of wastewater skimmings, scum,
grease and other materials with a high heat content
should be equalized to minimize high-temperature
excursions and pockets of oxygen-deficient
combustion within the furnace. Equalization
chambers added in front of the incinerator will
smooth out fluctuations in feed rate.
Permit writers should consider requiring POTWs
that use incinerators to minimize fluctuations in
sludge feed rate. These POTWs should be required to
report 25 percent or greater variations in sludge feed
rate in a one-hour period excepting start-up and shut-
down of the incinerator. The purposes of reporting
large fluctuations in feed rate are: (1) to focus
operator attention on an important parameter that
can affect the proper setting of other operating
parameters; and (2) to focus EPA's compliance
monitoring resources on incinerators that are
operated in a way that has the potential to increase
emissions.
Combustion Temperature
A minimum combustion temperature of
approximately 1,300 to 1,400°F is adequate for
oxidation of high molecular weight organics, and a
maximum temperature of about 1,800°F is often
necessary to limit ash melting and damage to
refractories. It has been observed that high
temperatures lead to increased emissions of metals.
Operation of a fluidized-bed furnace at a combustion
temperature of 980°C (1,800°F) is reported to
normally produce 200 to 400 percent more emissions
than operation at 760°C (1,400°F) (EPA, 1985a),
although it should be noted that most fluidized-bed
furnaces are operated at 1,500-1,600°F to avoid bed
defluidization. Combustion temperature in
particular affects the amount of NOx, CO, and
hydrocarbons emitted. Loadings of high heat content
material such as wastewater skimmings, scum, and
grease should be controlled to minimize high
temperature excursions and localized oxygen
deficiency.
Most, if not all POTWs operating sludge incinerators
monitor combustion zone temperature. Permit
writers should consider requiring POTWs (1) to
operate within a combustion zone temperature range
of 1,350 to 1,650°F, and (2) to report periods when
combusting zone temperatures exceeded 1,625°F or
fall below 1,375°F, excepting start-up and shut-down.
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Excess Air
It is critical to supply enough air to ensure complete
combustion; it is also important to limit the amounts
of excess air. When large quantities of excess air are
used, the resulting high gas velocities are believed to
increase the total amount of suspended particulates
in the exhaust gas. Supplemental fuel requirements
are also needed to heat excess air. Consequently,
operators often go to the other extreme and do not
provide enough excess air for complete combustion.
Conventional sludge incineration systems typically
use 20 to 150 percent excess air above the theoretical
amount needed for oxidation because it is virtually
impossible to ensure complete and even mixing of air
and sludge (EPA, 1984). However, with careful
operation, excess air flows can range from 20 to 45
percent for fluidized-bed furnaces, and 29 to 70
percent for electric-infrared furnaces (EPA,1985c).
Multiple-hearth furnaces typically require higher
levels of excess air, depending on how carefully they
are operated.
Combustion Efficiency
Combustion efficiency measurement is one way to
monitor and report upon proper incinerator operation
where frequent sampling for the specific contaminant
is not feasible. Combustion efficiency (calculated by
dividing the concentration of carbon dioxide by the
sum of the concentrations of carbon dioxide and
carbon monoxide in the off-gas) is a measure of the
percentage of completion of oxidation.
EPA requires a combustion efficiency of 99.9 percent
Tor hazardous waste incinerators burning over 50
ppm PCBs (40 CFR 761.70). However, this
permitting approach has not been applied to sewage
sludge incinerators, and the correlation between
combustion efficiency as described above and
destruction of certain pollutants in sewage sludges is
not well established.
Operator Training and Controls
One of the most important factors in achieving and
maintaining a low rate of emissions from a sludge
incinerator is having an experienced, well-trained,
conscientious operator attend to the incinerator at all
times that the incinerator is running. Depending on
the composition of the sludge (volatile solids and
moisture content), which can vary by hour, day, or
season, an operator may need to adjust the
temperature regime within the incinerator and the
amount of excess air used.
Permit writers should consider writing a condition
requiring that an experienced, well-trained,
competent operator attend to the incinerator at all
times that the incinerator is on line. Also important
for achieving and maintaining low emissions is the
ability of the operator to adject parameters within the
combustion process. Permit writers should consider
writing a condition requiring that the proper controls
be provided.
Emission Controls
Approximately 20 pounds of uncontrolled
particulates per ton of sludge and 0.0038 pound of
particulates per gallon of fuel oil are generated in
multiple-hearth furnaces. The Federal New Source
Performance Standard of 1.30 pounds of particulates
per dry ton of sludge (0.65 g/kg) can be met with
modern high energy wet scrubbers, such as the
venturi. Removal efficiency in scrubbers is a direct
function of particle size and the pressure drop across
the scrubber system, although some further gains in
collection efficiency are claimed for some specific
hardware configurations. For a pressure drop in
excess of 30 inches of water, scrubbers will remove
over 99 percent of particulates larger than 1 micron.
General guidelines for emissions control equipment
include:
• Use after-burners where necessary to satisfy
strict carbon monoxide and unburned
hydrocarbon emission limitations.
• Specify a minimum pressure drop across the
scrubber system (e.g., 30 inches or greater
pressure drop for a venturi impingement tray
water scrubber system) if exceptional control
levels for particulates are desired.
• Specify a maximum air/cloth ratio for fabric filter
baghouses (such as the 3.0 maximum ratio
specified for the Hyperion Energy Recovery
System in Los Angeles, CA; EPA, 1985a) if
exceptional emission control levels are sought. As
above, one should consider the alternative of
performance specifications.
Emission control equipment at existing incinerators
subject to the NSPS for particulates and opacity
should be operated so as to maintain the operating
conditions (e.g., pressure drop for scrubbers, air/cloth
ratio for fabric filters) during the facility's
compliance determination test-burn. If emission
control equipment is in place at older incinerators not
subject to NSPS, a permit condition should be written
requiring the POTW to maintain and operate the
equipment so as to optimize particulate removal
efficiency. For POTWs planning to use new
incinerators, language should be inserted which will
allow reopening the permit after the start-up
compliance determination. Emission control equip-
ment operating parameters maintained during start-
up would then be mandated as a condition in the
permit.
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Table 8-5 suggests a pattern of sludge incinerator
operating parameters that should minimize the
emission of heavy metals, soot, and odorous/
undesirable organic compounds. The most important
theme is the maintenance of a high degree of stability
of conditions coupled with reasonable sensitivity to
the key stoichiometric and temperature criteria that
provide a suitable combustion environment to
minimize both generation and emission (survival) of
organic compounds. This must be recognized by both
POTW management and operational personnel as a
plant problem/challenge, not just a furnace problem.
Close attention must be paid to tight and insightful
control of all aspects of the wet end of the process
train in order to deliver the constancy in rate and
material (let alone superior performance in
dewatering to minimize fuel usage) needed for good
furnace operation. Thus, cooperation among the
operators of almost all aspects of the plant and the
incinerator is a critical ingredient in successful,
minimum cost, and low emission sludge incineration
systems.
Table 8-5 Summary of Suggested Incinerator Operating
Guidelines
Parameter
Feed solids
content
Feed rate
Temperature
Oxygen
content of
exhaust
gases
Scrubber
pressure drop
Burning Zone
Goal
keep it
constant
keep it steady
keep it steady
keep it high
keep it low
keep it low
keep it high
keep it high
keep it steady
Reason
stabilize energy
balance in system
stabilize system
stabilize process
to burn organics
to minimize metal
volatilization
reduce fuel
consumption
assure oxygen for
combustion
collect fine
participates
stabilize system
Tolerance
within 2%
of avg.
within 10%
of avg.
within 50 °F
>1,400°F
< 1,600 °F
<10% Oz
> 7% 02
aVabove
where
compliance
tested
1 hearth
Storage Requirements
Sufficient sludge storage should be provided to allow
for a constant feed rate to the incinerator and to allow
for an adequate amount of down-time for repairs and
preventive maintenance.
Ash Disposal
Approximately 7 million dry tons of sludge are
generated by U.S. municipal wastewater plants each
year. More than 1.3 million tons of this sludge are
incinerated, resulting in about 400,000 tons of ash
that must be disposed of in an environmentally
acceptable manner (EPA, 1985a). Ash is a solid waste
that should be disposed of in accordance with the
requirements of 40 CFR Part 257 (Appendix D).
Permit writers should consider writing such a
requirement into the permit.
State Requirements
Combustion Temperature
Four States have minimum temperature require-
ments. Specific information was not provided by
Connecticut or Iowa, but Georgia requires 800°F
Primary Temperature and 1,500°F Secondary and
Nevada requires 1,400°F for not less than 0.3 seconds.
Combustion Residence Time
The State of Nevada requires not less than 0.3
seconds at 1,400°F, and Connecticut reported an
unspecified minimum combustion residence time
requirement.
Emission Controls
The States of Maryland, Nevada, New Hampshire,
New Jersey, Ohio, Oklahoma, South Carolina,
Virginia, Washington, Rhode Island, and Tennessee
impose special requirements relative to emission
controls; some specify that minimum air pollution
control techniques such as "Best Available Control
Technology" must be applied. This approach may be
particularly appropriate where certain pollutant
emission levels are expected to be a problem (i.e.,
when the sludge has high concentrations of the more
volatile metals such as mercury, cadmium, lead, or
zinc which may be emitted at concentrations higher
than the average of the bulk sludge ash if furnace
temperatures are set too high).
Management Practices
State agencies report a number of management
practices in addition to the incineration and pollution
control guidelines previously discussed. These
management practice requirements and/or guide-
lines are summarized below and in Table E8-2.
Management practices required by just one or two
States are presented in page four of Table E8-2.
States with no reported management practices are
omitted from Table E8-2. Prohibited sludge
incineration practices that were reported by various
States are summarized in Table 8-6.
/Access Control
The States of New Hampshire, Oregon, and
Wisconsin reported minimum requirements for
access control, such as fences and gates.
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Table 8-6 Prohibited Sludge Incineration Practices
State Incineration Practice
Massachusetts Open burning prohibited
Maine Open burning prohibited at landfills serving
over 1,000 persons
Tennessee Incineration prohibited without permit
Indiana Open burning prohibited
Kansas Open burning prohibited
Nebraska Open burning prohibited without license
Colorado Open burning prohibited at landfills without
permit
Idaho Open burning prohibited
Source: EPA 1987
temperature should be lowered or the feed rate
should be changed. Exhaust gas temperatures should
be maintained at less than 900°F (482"C) to prevent
distillation of odorous greases and tars from the
drying solids. Multiple-hearth furnaces may require
afterburners (simple combustors used to oxidate
organic compounds not destroyed in the primary
incinerator chamber) in cases where there are very
stringent emission limitations for unburned
hydrocarbons (EPA, 1979). Where there is concern
about organics emissions (e.g., large loadings of
industrial organics), sludge may be added to the third
hearth of a multiple-hearth furnace, and the top two
hearths may be used as an afterburner.
Air Monitoring
Nine States reported some requirements for air
monitoring. Current federal requirements and
further discussion of potential monitoring
requirements are presented later in this section.
Air Modeling
Air modeling may be desirable for large facilities or
facilities that may pose a particular hazard. The
State of New Jersey (the only State to require air
modeling) is reported to require air modeling for
carbon monoxide, SO2, NC>2, total suspended
particulates, lead, and VOCs.
Air Turbulence
Increases in air turbulence allow higher levels of
pollutant emissions to be assimilated through
dispersion. However, providing for the effect of air
turbulence in permit language may not be possible
except in locations where detailed air modeling is
required. Iowa was the only State that reported a
requirement for addressing air turbulence.
Fluidized-Bed Furnace
Federal Guidance
The quantity of excess air supplied to a fluidized-bed
furnace is typically in the range of 20 to 45 percent.
The correct amount of airflow is critical with a
fluidized-bed furnace. Airflow must be sufficient to
expand the bed by the appropriate amount, provide
uniform distribution of fuel and air, and provide the
desired amount of excess air to ensure complete
combustion. The fluidized-bed furnace operates at
lower excess air rates than typically required for
multiple-hearth furnaces. Normal operation of the
fluidized-bed furnace produces exhaust temperatures
in excess of 1,400°F (760°C). Because the exhaust
gases are exposed to this temperature for several
seconds, carbon monoxide and unburned hydrocarbon
emissions are usually very low, even without the use
of an afterburner (EPA, 1979). However, more
particulates must be removed by the emission control
devices of fluidized-bed furnaces because ash is
removed from the flue gas, unlike the multiple-
hearth and electric-infrared furnaces where ash is
removed from the combustion chamber.
Site Development Plans
Twelve States reported requirements for site
development plans.
8.5.2 Operating Guidelines for Specific
Incineration Technologies
Multiple-Hearth Furnace
Federal Guidance
Multiple-hearth furnaces are typically operated with
high levels (100 percent or more) of excess air to
encourage complete combustion. If the flame of
combustion is creeping up the hearths, the
Electric-Infrared Furnace
Federal Guidance
In electric furnaces, the sludge is not stirred or mixed
during incineration, and the particulate loading to
the emissions control system is typically much lower
than for fluidized-bed furnaces and somewhat lower
than for multiple-hearth furnaces.
Excess airflows for electric-infrared furnaces
typically range from 29 to 70 percent (EPA, 1985a).
Since electricity is used to provide the supplemental
energy, no fuel is burned in the primary furnace
although fuel is often burned in a post-furnace
afterburner.
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Starved-Air Combustion
8.5.3 Guidelines for Pollution control Systems
Federal Guidance
In starved-air combustion, the amount of air in the
furnace is less than the theoretical requirement for
complete combustion (30 to 90 percent of the
stoichiometric requirement). This makes starved-air
combustion a fuel-efficient operation. When a
starved-air combustion multiple-hearth furnace is
combined with an afterburner, an overall excess air
rate of 25 to 50 percent can be maintained, as
compared with excess air rates of more than 100
percent for conventional multiple-hearth incin-
erators with an afterburner (EPA, 1984).
It has been demonstrated that starved-air
combustion is an effective method for burning sludge
in a furnace, but it is still a relatively new technology
that is not widely practiced.
Co-incineration
Federal Regulations
Co-incineration facilities may be subject to current
federal contaminant regulations for sludge
incineration, refuse incineration, and co-incineration
depending on the amounts of material incinerated.
Some co-incineration facilities may also be subject to
Subpart D-(b), NSPS for industrial boilers. No
specific management practices are currently
regulated. In general, unless the proportion of sludge
to other material fed to a co-incineration facility is
very high, permit writers should defer to the Air
Office.
Federal Guidance
Only about one percent of the sludge incinerators in
operation today are operated in a co-incineration
mode, where wastewater sludge is burned with
municipal refuse. Problems encountered have been
related to the different storage requirements of the
two "fuels" (wastewater sludge odor/septic problems)
and to the different design requirements for the
handling and incineration equipment (municipal
refuse may require equipment that can handle large
objects, rags, wires, etc. without clogging excessively
and "hot" loads of plastics and paper without having
excessive temperature excursions). However, there
are potential benefits from co-incineration, such as
reduced sludge dewatering requirements and
reduction of municipal refuse volume.
Federal Regulations
If the sludge contains more than 50 mg PCBs/kg of
dry sludge solids then pollution control devices for
hydrochloric acid emissions are required under
TSCA.
Federal Guidance
There is a considerable amount of federal guidance on
pollution control systems as presented in the
subsequent sections. These pollution control devices
are required to attain emission limitations. Descrip-
tions of the various emission control technologies are
presented below, followed by guidelines for these
pollution control technologies.
Wet Scrubbing Systems
The venturi scrubber with an impingement tray is
one of the most common types of exhaust gas
scrubbers. The exhaust gas is cooled with water and
then passes into a venturi section where particles are
removed from the gas stream by a fine mist of water.
The exhaust gas is then passed through a flooded
elbow, an impingement tray separator, and a
demister to separate the liquid containing the
particles from the gas.
Scrubbing water can be recycled, and supplemented
with make-up water. Waste scrubbing water from a
multiple-hearth furnace is normally recycled into the
main process train in a wastewater treatment plant.
An appreciable amount of volatile compounds or
metals such as Cd, Pb, and Zn may be concentrated in
the scrubber wastewater and caution should be
exercised in recycling and/or disposing of this waste
stream. Scrubbing water with a fluidized-bed furnace
contains large amounts of ash and is normally
treated and sent to an ash lagoon.
The efficiency of scrubbers for particulate removal is
related to the pressure drop across the particulate
removal equipment. Most incinerators now use a
venturi impingement tray water scrubber that
develops 30 inches or greater of water pressure drop
across the system (EPA 1985a). Scrubber pressure
drop typically falls in the range of 15 to 45 inches of
water.
Wet scrubbing systems have the advantage of cooling
the exhaust gases. Flue gas cooling and wet
scrubbing are effective in removing condensible
particulates. Subcooling below the saturation vapor
temperature in the scrubber system will remove
substantial amounts of water from the flue gas and
aid in steam plume suppression. Cooling the flue
gases will also increase removal of polar gas
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molecules that can be expected to dissolve in the
water phase (EPA 1985a).
The EPA has evaluated the results of tests on nine
sludge incinerators with wet scrubbing systems in
which the following metals were monitored:
cadmium, iron, nickel, lead, chromium, silver,
copper, manganese, zinc, and arsenic (EPA 1985a).
The findings of this investigation (reported in 1981,
but not published) restated the findings of an earlier
EPA task force that concluded in 1972 that "properly
operated incinerators produce acceptable stack
emissions of particulate matter, nitrogen oxide,
sulfur oxides, and odor" (EPA 1972). Only one of the
eight incinerators significantly exceeded EPA's new
source performance standard for particulates of 0.65
g of particulates per kg of dry sludge solids feed.
Scrubbers showed very good removal for particulates
larger than 1 micron diameter. However, efficiencies
ranged from 50 to 90 percent for the 0.1 to 1 micron
range. The level of heavy metal discharges to the
atmosphere was found to be insignificant when com-
pared to ambient atmospheric concentrations unless
the incinerators operated at very high (1,700°F)
temperatures where losses of the more volatile
metals (Pb, Cd, As) increase markedly. Removal of
the metals corresponded somewhat to the removal of
particulates. Silver, zinc, cadmium, lead, and presu-
mably arsenic had relatively high concentrations in
the fine particulate fraction of 0.1 to 1 microns, which
was believed to account for their lower removal
efficiencies in the scrubbers (EPA 1985a).
Filters
In the EPA evaluation of nine sludge incinerators
discussed previously, it was suggested that the use of
a 0.1 micron filter downstream of the wet scrubbers
would assure virtually complete collection of metals
except mercury (EPA 1985a). The fabric filter
baghouse at the Hyperion Energy Recovery System,
Los Angeles, CA, was reported to exhibit particulate
reductions to less than 0.005 grams/m3 (0.002
grains/DSCF) using a maximum air/cloth ratio of 3.0.
Dry Scrubber Systems and Electrostatic Precipitators
Neither dry scrubbers or electrostatic precipitators
are commonly used on sludge incinerators. A
multiclone is a typical dry scrubber system that may
precede a fabric filter baghouse. Electrostatic
precipitators achieve considerable removal of
particulates by ionizing the particles between two
large charged plates (configured like an electric
capacitor). The ionized particles migrate to the
oppositely charged plate and the fall out of the
exhaust gas. The exhaust gas must be cooled to 250°C
(480°F) prior to entering the electrostatic
precipitators (EPA 1985a).
Stack Height
Adequate stack height assures dispersion of the
exhaust plume by avoiding capture of the stack
discharge in the downwash eddy downwind of
structures. "Good Engineering Practice stack height"
is defined in 40 CFR 51.1 as the greater of:
• 65 meters, measured from the ground level
elevation at the base of the stack;
• The height of nearby structure(s) measured from
the ground-level elevation at the base of the stack
plus 1.5 times the lesser dimension (height or
projected width of nearby structures); or
• The height demonstrated by an approved fluid
model or a field study which ensures that the
emissions from a stack do not result in excessive
concentrations of any air pollutants as a result of
atmospheric downwash, wakes, or eddy effects
created by the source itself, nearby structures, or
nearby terrain features.
8.6 Monitoring, Reporting, and Record
Keeping
8.6.1 Monitoring
Federal Regulations
The current NPDES regulations require sludge
monitoring at a frequency dependent upon the nature
and effect of the permittee's sludge use and disposal
activities but at least once a year for every pollutant
limited in the permit. This means that if the permit
contains a limit for mercury, the permittee must be
required to monitor sludge at least annually for this
pollutant.
Particulates and Opacity
The monitoring requirements for particulates and
opacity from Subpart O of the NSPS (40 CFR Part 60)
are:
Install, calibrate, maintain, and operate a flow
measuring device which can be used to determine
the mass or volume of sludge charged to the
incinerator. The flow measuring device shall
have an accuracy of plus or minus 5 percent over
its operating range.
Provide access to the sludge charged so that a
well-mixed representative grab sample of the
sludge can be obtained.
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• Use the test methods and procedures in Appendix
A of 40 CFR Part 60 to demonstrate compliance
with the limitations on particulates and opacity.
• The required frequency of monitoring is
presently just a one-time analysis during system
start-up.
A one-time stack test for particulate emissions is all
that is required for particulates and opacity at
present due to the interference of uncombined water
in the determination of opacity.
Opacity
It is desirable to require facilities to monitor opacity
to allow the plant staff to better track and control
incinerator performance.
Mercury
Monitoring requirements for mercury from 40 CFR
Part 61 Subpart E are as follows:
• Unless a waiver of emission testing is obtained
under 40 CFR 61.13, each sludge incinerator
owner or operator shall test mercury
concentrations within 90 days of start-up. The
test shall either be stack gas sampling or sludge-
feed sampling as described in 40 CFR Part 61
Subpart E.
• The required frequency of monitoring per 40 CFR
Part 61 is the one-time stack gas analysis within
90 days of system start-up plus annual
monitoring of mercury emissions or sludge
concentration for sources for which mercury
emissions exceed 1,600 g/day, demonstrated
either by stack sampling according to 40 CFR
61.53 or sludge sampling according to 40 CFR
61.54, which assumes all mercury in the sludge is
volatilized.
Beryllium
Monitoring requirements for beryllium from 40 CFR
Part 61 Subpart C are as follows:
• Unless a waiver of emission testing is obtained
under 40 CFR 61.13, each owner or operator of a
facility incinerating a waste containing
beryllium shall test beryllium concentrations
within 90 days of start-up. The emissions test
shall be performed according to Method 104 or
Method 103 of Appendix B of 40 CFR Part 61.
• The required frequency of monitoring per 40 CFR
Part 61 is the one-time stack analysis within 90
days of system start-up, then every 30 days at an
air sampling site located in such a manner as is
calculated to detect maximum concentrations in
the ambient air.
The requirements for beryllium monitoring apply
only to facilities receiving waste from plants which
process beryllium, beryllium ore, beryllium oxide,
beryllium alloys, or beryllium-containing waste.
Polychlorinated Biphenyls (PCBs)
Incinerators that burn sludges containing more than
50 mg PCBs/kg of dry sludge solids must comply with
the monitoring requirements of 40 CFR 761.70.
Operating Parameters
Revisions to 40 CFR Part 60 require the monitoring
of a number of key operating parameters. They
require all sludge facilities subject to NSPS to:
• Continuously monitor and maintain records of
sludge feed rate, temperature profile of the
incinerator, excess air levels/oxygen content of
the exhaust gas and pressure drop across the
emission control device, and daily monitoring of
the moisture and volatile solids content of the
sludge being incinerated; or
Continuously monitor and maintain records of
the incinerator exhaust gas volumetric flow rate
and the pressure drop across the emissions
control device.
If the values of these parameters then deviate
significantly from their values during the initial
testing for particulates, the facility would be
required to report the deviation.
• Initially test the sludge total solids content,
volatile solids content, and metals concentrations
(arsenic, cadmium, chromium, copper, lead,
nickel, selenium, and zinc) by grab samples.
• Testing of metals content (arsenic, cadmium,
chromium, copper, lead, nickel, selenium, zinc,
beryllium, and lead) in emissions (in addition to
the present initial testing of particulate content
of emissions).
• Performance tests of monitoring devices after
they are installed.
Federal Guidance
The Sewage Sludge Interim Strategy recommends
that for Class I facilities, the permit should require
an annual priority pollutant scan and more frequent
monitoring of the pollutants limited in the proposed
sludge regulations (40 CFR Part 503). These pollu-
tants are: arsenic, beryllium, cadmium, chromium,
lead, mercury, nickel and total hydrocarbons. Some
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of the factors permit writers should use in
determining frequency of monitoring includes size,
compliance history, influent, industrial users,
population density and sensitivity of ecosystems
surrounding incinerator.
State Regulations
The reported State-by-State monitoring
requirements are summarized in Table E8-3. States
with no reported monitoring requirements are
omitted from Table E8-3. Monitoring and reporting
requirements are broken out in Table E8-3 into five
categories: emissions, sludge, ash, sludge feed rate,
and incinerator temperature. Of the 16 States
included in Table E8-3,10 have monitoring/reporting
requirements for stack emissions, 9 monitor the
sludge itself, 2 monitor the ash, 3 monitor the
incinerator temperature, and 2 monitor the sludge
feed rate.
Case-by-Case Recommendations
On a case-by-case basis, permit writers should
consider requiring POTWs that use incinerators to
conduct the same monitoring as is required under
NSPS, if such monitoring is deemed necessary to
protect public health and the environment from
incinerator emissions.
Any deviations of parameters for which monitoring is
required should be reported as such at the same times
that the facility is required to submit Discharge
Monitoring Reports (DMRs) to the State or to EPA.
8.6.2 Reporting and Record Keeping
Federal Regulations
The recently promulgated revisions to be NPDES
permitting regulations (54 FR 18716) require that
the permit contain a requirement that the permittee
report monitoring results with a frequency
dependent upon the nature and effect of the sewage
sludge use or disposal practice but in no case less
than once a year (40 CFR I22.44(i)(2)). The
regulations also require that records pertaining to
the POTWs sludge use and disposal activities (as set
forth in 40 CFR 501.15(2)) be retained for 5 years (40
CFR 122.21(p)).
The current federal reporting requirements for
particulates, mercury, beryllium, and PCBs are
discussed below.
Particulates
The owner or operator must provide the
Administrator at least 30 days prior notice of the
start-up performance test and furnish the
Administrator a written report of the results of the
performance test.
Mercury
The Administrator shall be notified at least 30 days
prior to the stack emission test required within 90
days of start-up. The samples from this test must be
analyzed and mercury concentrations determined
within 30 days after this test. All determinations
must be reported to the Administrator by a registered
letter dispatched before the close of the next business
day following such determination.
A new emissions level must be estimated by
calculation and the results reported to the Admin-
istrator prior to any changes in operation that would
potentially increase emissions above that determined
by the most recent source test.
Facilities required to perform sampling at least once
per year shall have the samples from each test
analyzed and mercury concentrations determined
within 30 days after the test, and all determinations
shall be reported to the Administrator by a registered
letter dispatched before the close of the next business
day following such determination.
Beryllium
The Administrator shall be notified at least 30 days
prior to the stack emission test required within 90
days of start-up. The samples from this source test
shall be analyzed and beryllium concentrations shall
be determined within 30 days after this test. All
determinations shall be reported to the Administra-
tor by a registered letter dispatched before the close
of the next business day following such deter-
mination. Beryllium air sampling site test results are
to be reported every 30 days.
Polychlorinated Biphenyls (PCBs)
Incinerators that burn sludges that contain more
than 50 mg PCBs/kg of dry sludge solids must comply
with reporting and record keeping requirements of 40
CFR 761.70. Permit writers should consult with the
Office of Pesticides and Toxic Substances.
Revisions to 40 CFR Part 60 require reporting of the
following performance test data every six months:
• Every period of 15 minutes or more for which the
pressure drop of the emissions control device falls
below a specified value.
• Every period of 1 hour duration or more when
oxygen content of the exhaust gas exceeds 10
percent (wet basis) and the corresponding one
hour average oxygen content of exhaust gases.
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• Incinerators achieving compliance with the New
Source Performance Standards in a performance
test with over 10 percent oxygen in the exhaust
gas would be allowed to reach oxygen contents 3
percent above that of the most recent
performance test on a one-hour average before
the exceedance must be reported.
• Facilities monitoring pollution control device
pressure drop, oxygen content of exhaust gases,
and temperature profiles would report for each
day there is a decrease in pollution control device
pressure drop or increase in content of oxygen in
exhaust gas, report temperature profiles, sludge
feed rate, fuel use averaged over an 8-hour
operating period, and moisture and volatile solids
content of the sludge samples. Facilities
monitoring pollution control device pressure drop
and exhaust gas flow rate would report for each
day there is a decrease in scrubber pressure drop
or increase in exhaust gas flow. The report would
include hourly average pressure drop and hourly
average exhaust gas volumetric flowrate for the
entire day either violation occurred.
State Requirements
The State of Connecticut requires reporting for
particulates, SO2, NC>2, CO, and hydrocarbons. The
State of Georgia requires reporting for particulates,
SC-2, NC-2, CO, ozone, and hydrocarbons. The State of
Tennessee requires reporting for beryllium, lead,
mercury, vinyl chloride, and "others". The States of
New Hampshire, Oregon, and Iowa also noted
reporting requirements. The State of Kentucky
requires reporting for mercury if emissions or sludge
analysis is greater than 1,600 g/d. The State of
Maryland requires a permit from Air Management
Administration and Waste Management. The State
of Missouri requires performance testing with
representative samples of material to be burned. The
State of New Jersey requires modeling for risk
assessment of arsenic, chromium, cadmium and
nickel.
References
EPA 1972. Sewage Sludge Incineration, U.S.
Environmental Protection Agency, R2-72-040,
Washington, B.C., August 1972,95p.
EPA 1979. Process Design Manual for Sludge
Treatment and Disposal, Technology Transfer Series,
U.S. Environmental Protection Agency 625/1-79-011,
Cincinnati, OH, September 1979,1135p.
EPA 1984. Environmental Regulations and
Technology: Use and Disposal of Municipal Waste
Water Sludge, U.S. Environmental Protection
Agency 625/10-84-003, Cincinnati, OH, 1984.
EPA 1985a. Municipal Wastewater Sludge
Combustion Technology, U.S. Environmental
Protection Agency 625/4-85-015, Cincinnati, OH,
1985.
EPA 1985b. Summary of Environmental Profiles and
Hazard Indices for Constituents of Municipal Sludge:
Methods and Results, U.S. Environmental Protection
Agency Office of Water Regulations and Standards,
July 1985.
EPA 1987. State Requirements for Sludge
Management, U.S. Environmental Protection
Agency, Office of Municipal Pollution Control and
Office of Water Enforcement and Permits. (Revised
1989.)
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Chapter 9
Surface Disposal
9.1 Introduction
EPA has identified approximately 2,400 POTWs that
use surface disposal sites (54 FR 5946). Currently,
these sites are regulated by 40 CFR Part 257 as solid
waste disposal facilities or practices. Like the other
use and disposal options discussed in this manual,
surface disposal was identified as one of the options
needing regulation under 40 CFR Part 503. The
proposed 40 CFR Part 503 defines surface disposal as
an area of land on which only sewage sludge is placed
for a period of one year or longer. This disposal
practice includes sludge lagoons and stockpiles. The
agency further decided to regulate surface disposal
because when these practices are employed for more
than just temporary storage, they pose threats to
public health and the environment that are similar to
those arising from improperly managed monofills.
For purposes of classification as surface disposal,
sludge lagoons are impoundments where liquid
sludge is placed. Sludge lagoons, by definition, are
not a part of the wastewater treatment train. They do
not include stabilization ponds or final polishing
ponds. The sludge use and disposal regulations are
not intended to regulate wastewater treatment.
Figure 9-1 illustrates the difference between a
wastewater treatment lagoon and a sludge lagoon.
Sludge stockpiles are frequently little more than
above-ground piles of relatively dry sludge.
Sometimes these stockpiles have impervious surfaces
under the sludge. They may or may not have run-off
control structures. Sludge may be stored in piles
temporarily before final disposal or indefinitely.
If improperly managed, surface disposal sites can
contaminate surface water via run-off or washout
during storms. Surface disposal practices contamin-
ate ground water by leaching through the soil. As
lagoons dry out, the seal formed by the bottom layer
of sludge may crack and pollutants may migrate.
These practices can also cause public health and
safety hazards. Decomposition of unstabilized sludge
can create explosive atmospheres. Unstabilized
sludge also causes vector attraction which can
increase transmission of disease and pose a bird
hazard to airports near surface disposal sites. It is
because of these potential problems that surface
disposal operations need to be regulated if the sludge
is left for more than one year.
Because most surface disposal sites were developed as
a temporary or stop-gap sludge storage/disposal
facility, EPA does not consider them to be environ-
mentally acceptable solutions for ultimate disposal.
The use of these practices for more than short-term
storage should be discouraged, particularly by
POTWs with sludges that contain significant levels
of contaminants. In some circumstances, the permit
writer should also consider evaluating the effects of
surface impoundments where sludge is stored for less
than one year. Situations in which a review might be
appropriate include lagoons that are continually
replenished and almost always filled with sludge,
where sludge quality is generally poor, or where site
conditions are conducive to migration of contam-
inants from the lagoon. Sludge storage piles also have
the potential for adverse effects.
This chapter summarizes the tools available to the
permit writer for regulation of surface disposal
practices. It discusses sludge quality and facility
operation and management practices. For each topic,
federal regulations and State requirements are
identified. Additional guidance is provided for
development of case-by-case permit conditions for
Class I sludge management facility permits.
9.2 Characteristics of Sludges Suitable
for Surface Disposal
9.2.1 Sludge Pollutant Concentration Limits
Federal Regulations
There are currently no federal regulations limiting
specific contaminants in sludge that is placed in sur-
face impoundments. Two federal regulations identify
characteristics which require special treatment of
sludge: (1) if the sludge contains concentrations of
PCBs equal to or greater than 50 ppm, provisions of
the Toxic Substances Control Act (40 CFR Part 761)
apply; and (2) if the sludge is a hazardous waste it
must be disposed of in accordance with RCRA
Subtitle C. See Section 5.4 for a brief description of
tests used to certify that sludge is not a hazardous
waste.
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a) Wastewater
Treatment
Lagoon
Settled Sludge •
Effluent
— Settled Sludge
Initial Treatment Lagoon
Polishing Pond
b) Sludge
Storage/
Disposal
Lagoon
Sludge Lagoon
Figure 9-1. Comparison of wastewater lagoon and sludge lagoon.
State Requirements
One State, New Hampshire, prohibits the mixing of
hazardous, toxic, or oily waste with sludge in a sludge
lagoon.
9.2.2 Sludge Physical Properties
Federal Regulations
There are currently no federal regulations with
regard to sludge physical properties.
State Requirements
Six States have regulations addressing physical
properties for stockpiled sludge: Connecticut and
Wyoming require sludge dewatering; Minnesota
allows liquid sludge storage at municipally
controlled sites; Nebraska allows the stockpiling of
sludge with greater than 60 percent solids; New
Hampshire requires sludge dewatering to at least 20
percent solids; and Vermont requires stockpiled
sludge to have at least 15 percent solids.
9.3 Operating Conditions and
Management Practices
Required Permit Conditions
As mentioned above, the existing federal regulations
that apply to sludge lagoons and stockpiles are set
forth in 40 CFR Part 257. These regulations are
summarized in Table 5-1. The permit writer should
consult the text of the rule for details and definitions
(see Appendix D). As minimum federal permit
conditions for sludge, the permit writer should write
into the permit or reference these existing federal
requirements for Class I POTWs that hold sludge in
lagoons or stockpiles for more than one year. Rather
than simply reference the 40 CFR Part 257
standards, permit writers should reference a valid
solid waste permit for the facility that includes these
standards, if one exists. The permit writer should be
aware that many federal regulations apply to the
initial siting rather than operation of the surface
disposal facility. There may be some cases where the
permit writer will need to require the POTW to
identify an alternate sludge use or disposal option
because the current option violates the federal
regulations.
9.3.1 Floodplain Restrictions
Federal Regulations
Federal regulations (40 CFR 257.3-1) do allow the
location of sludge lagoons in the floodplain, provided
they do not restrict the base (100-year) flood, reduce
the temporary water storage capacity of the
floodplain, or result in the washout of solid waste to
the extent that a hazard would be posed to human
health, wildlife, or water resources.
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State Requirements
As shown in Appendix E, Table E9-1, 24 States have
regulations addressing sludge lagoons/stockpiles in
floodplains. Thirteen States prohibit sludge lagoon/
stockpile siting within the 100-year floodplain. Two
States have restrictions based upon the 25-year and
10-year flood line. Twenty-two States require some
kind of controls on surface flow, usually by the use of
dikes or berms (see Appendix E, Table E9-1).
Minnesota. Minnesota provides for a variance if there
is run-off control at the facility.
Case-by-Case Recommendations
The appropriate distance to surface water is a site-
specific determination. A minimum distance of 100 ft
between the lagoon or stockpile and surface water is
recommended, provided adequate run-on and run-off
controls are in place.
Case-by-Case Recommendations
Surface disposal operations pose a variety of
problems during flood conditions. Sludge lagoons
which utilize some of the storage capacity of the
floodplain may increase the velocity of the flood
which may in turn cause greater damage down-
stream. Sludge stockpiles are especially vulnerable
to washout. Whenever possible, surface disposal sites
should not be located in a floodplain. If they are,
structures to prevent run-on and run-off should be
constructed to eliminate the threat of washout of
sludge during a flood. These structures should be
sufficient to control and divert the 24-hour 25-year
storm.
9.3.2 Surface Water Protection
Federal Regulations
Federal regulations (40 CFR 257.3-3) require that the
facility shall not cause a discharge of pollutants to
surface waters that is in violation of the National
Pollutant Discharge Elimination System (NPDES)
under Section 402 of the Clean Water Act, as
amended. Discharges from sludge lagoons to waters
of the U.S. must have NPDES permits. If run-off from
a sludge stockpile constitutes a point source
discharge, the stockpile must also have a NPDES
permit. In addition, a facility shall not cause a
discharge of dredged or fill material that is in
violation of the requirements under Section 404 of
the Clean Water Act, as amended. Lastly, a facility or
practice shall not cause non-point source pollution of
waters that violates applicable legal requirements
implementing an area-wide or Statewide water
quality management plan that has been approved by
the EPA Administrator under Section 208 of the
Clean Water Act, as amended.
State Requirements
Based on a summary of State requirements for sludge
use and disposal, there do not appear to be any State
regulations or guidance on the discharge of
pollutants from sludge lagoons beyond the normal
NPDES requirements. Nine States have minimum
requirements for the distance to surface waters
ranging from 50 feet in Virginia to 1,000 feet in
9.3.3 Ground Water Protection
Federal Regulations
40 CFR 257.3-4 requires that a facility or practice not
contaminate an underground drinking water source
beyond the solid waste boundary. The solid waste
boundary is the outermost perimeter of the solid
waste as it would exist at completion of the disposal
activity.
Contamination is defined as introducing a substance
that would cause the concentration of that substance
in the ground water to exceed the Maximum
Contaminant Level (MCL) specified in Appendix I of
40 CFR Part 257, or to increase the concentration of a
substance already exceeding the maximum
contaminant level specified in Appendix I.
See Appendix D of this document for the maximum
contaminant levels specified in Appendix I of 40 CFR
Part 257.
State Requirements
Several States indicated that soil type had some
importance for the operation of sludge disposal
facilities. To protect ground water, Connecticut and
Wyoming both require an analysis of soil type;
Maryland requires a soil with low to moderate
permeability, or a soil that will be sealed by
biological activity underlying the lagoon. Soil type
requirements for Maine are rated by slope,
permeability, flooding, drainage, and depth to
bedrock.
Twelve States require minimum depths to ground
water (see Appendix E, Table E9-2): 2 feet (Maryland
and Wyoming); 3 feet (North Carolina); 4 feet
(Massachusetts and Nevada); 5 feet above highest
anticipated ground water level (New York and
California); 6 feet (Vermont); and 10 feet to annual
high water level (Colorado). Minnesota requires 8-
inches of water holding capacity above the seasonal
high water table. South Carolina requires a
consideration of hydrogeologic conditions in the
design of a storage lagoon.
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Twenty-five States have regulations addressing the
need for liners for sludge lagoons (Appendix E, Table
E9-1). Ten States require some form of leachate
collection. Minnesota waives loading and
permeability requirements if leachate collection is
employed.
Case-by-Case Recommendations
Many factors need to be considered with regard to
ground water protection when siting a lagoon or
stockpile. Stockpiles should be located on an
impervious surface. Permit writers should evaluate
whether sludge lagoons should have liners or
leachate collection systems. Important factors to
consider are sludge quality, distance to drinking
water wells, depth to ground water, ground water
flow direction and velocity, aquifer classification
based on the EPA Ground Water Protection Strategy
(see Chapter 6), and underlying soil type and
permeability. Permit writers should seek the advice
of an experienced engineer/hydrologist.
A minimum soil buffer (or overburden) of 4 feet is
recommended between the bottom of any lagoon or
stockpile and the seasonal annual high ground water
table. Some of the important factors to consider in
determining whether depth to ground water is
appropriate are sludge quality, the presence/absence
of liners or leachate collection systems, the
permeability of the soil buffer, and the value of the
ground water underlying the facility.
While lagoons may be theoretically self-sealing, in
practice they are an unreliable means of isolating
contaminants from the environment. If a lagoon is
allowed to dry out, the seal formed in the bottom
layer of a sludge lagoon could crack. If the lagoon is
subsequently refilled, those cracks could allow the
migration of sludge contaminants into the ground
water. For this and many other reasons, sludge
lagoons are not considered to be an environmentally
acceptable solution for ultimate disposal, and the use
of lagoons for more than short term storage should be
discouraged, particularly for for POTWs with sludges
that contain significant levels of contaminants. The
permit writer will have to evaluate lagoons on a case-
by-case basis taking into consideration such factors
as 1) the thickness of the bottom seal and the
likelihood of drying and cracking, 2) soil properties
and their influence on contaminant migration, and 3)
the properties of the sludge itself.
aircraft, or within 5,000 feet of any airport runway
used only by piston-type aircraft shall take steps to
avoid a bird hazard to aircraft.
State Requirements
Buffer zones are required in many States to protect
surface water, ground water, and public safety. State
requirements for buffer zones fall into four areas:
distance to surface water, distance to the nearest
dwelling, distance to wells, and distance to property
lines.
As was described in section 9.3.2, nine States have
minimum requirements for the distance to surface
water. Nineteen States have a requirement for a
minimum distance to the nearest dwelling. Five
States require a minimum of 500 feet and six States
require a minimum of 1/4 mile to the nearest
dwelling. Other State requirements are included in
Appendix E, Table E9-1.
Five States require minimum distances to the
nearest well ranging from 300 feet in Maine to 2,500
feet in Massachusetts. Two States, Massachusetts
and Arizona, specify greater distances from public
drinking water wells than from private wells due to
the increased size of the cone of depression during
withdrawal. One State requires the consideration of
local water supply wells in the sludge lagoon design.
These State requirements are summarized in
Appendix E, Table E9-1.
Five States require setbacks from the property line
ranging from 25 to 375 feet. These State require-
ments are summarized in Appendix E, Table E9-1.
Case-by-Case Recommendations
In the absence of appropriate State requirements, the
following minimum buffer zones from lagoons and
stockpiles are recommended:
• Nearest Dwelling - 500 feet
• Nearest Drinking Water Well - 1,000 feet. The
appropriate distance to the nearest water well
will depend on site specific factors including
those discussed in the section on liners, depth to
ground water, and ground water monitoring.
• Property Line - 50 feet
9.3.5 Access Control
9.3.4 Buffer Zones
Federal Regulations
Federal regulation regarding buffer zones is found in
40 CFR 257.3-8. This regulation requires any facility
or practice dispensing of putrescible wastes that is
within 10,000 feet of a runway used by turbojet
Federal Regulations
Federal regulation regarding access to a sludge
disposal area is found in 40 CFR 257.3-8. These
requirements state that a facility or practice shall not
allow uncontrolled public access that would expose
the public to potential health and safety hazards at
the site. Unless prescribed by State requirements,
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specific measures for access restriction should be
determined on a case-by-case basis.
State Requirements
Eleven States seek to control access to a site by the
required use of fencing, locks, gates, and/or signs (see
Appendix E, Table E9-2).
Case-by-Case Recommendations
Access control measures (e.g., fences, gates, locks,
and signs) should be imposed based on the population
density of the surrounding area.
9.3.6 Pathogen and Disease Control
Federal Regulations
To protect the public health, federal regulations in 40
CFR 257.3-6 require that a facility or practice
minimize the on-site population of disease vectors
through the periodic application of cover material or
other appropriate techniques. Although cover
material would not be appropriate for a lagoon, other
techniques such as sludge stabilization might be
appropriate in order to reduce the presence of disease
vectors at the facility.
State Requirements
No State requirements were noted in regard to the
control of disease vectors. However, Connecticut and
Colorado require stabilization of sewage sludge that
will be stored or disposed of in lagoons or stockpiles.
9.3.7 Air Quality Control
Federal Regulations
Federal regulation 40 CFR 257.3-7 prohibits the open
burning of sludge. This would not be a concern for a
sludge lagoon.
State Requirements
Only three States, New York, Virginia and
Minnesota, place restrictions on air pollution from
lagoons. Although no specific information was
provided, these restrictions probably pertain to the
control of odors.
9.3.8 Endangered Species Protection
Federal Regulations
Federal regulation 40 CFR 257.3-2 prohibits the
establishment of a sludge lagoon that will cause or
contribute to the taking of any endangered or
threatened species of plant, fish, or wildlife (See
Table 6-1 and Appendix D). In addition, the facility or
practice may not cause the destruction or adverse
modification of the critical habitat of endangered or
threatened species as identified in 50 CFR Part 17.
9.3.9 Explosive Gases
Federal Regulations
Federal regulation 40 CFR 257.3-8 requires that the
concentration of explosive gas not exceed 25 percent
of the lower explosive limit for the gases in facility
structures (excluding gas control or recovery system
components) or 100 percent of the lower explosive
limit for the gases at the property boundary.
Accumulation of explosive gases are not usually a
problem at open-air surface disposal sites.
Case-by-Case Recommendations
If there is a potential for generation of explosive
gases, the permit writer should require monitoring
and the development of a safety action plan for
responding to unsafe levels of explosive gases in the
atmosphere.
9.3.10 Other Sludge Lagoon Restrictions
State Requirements
Other State restrictions of sludge lagoons not covered
in the preceding sections are described below.
Three States require a minimum freeboard for sludge
lagoons. Seven States require a site development
plan. Two States require sludge stabilization or
pathogen control. Two States have a loading limit.
Five States require a closure plan. Six States require
the emptying or inspecting of the sludge lagoons. Six
States have miscellaneous requirements that are
shown in Appendix E, Table E9-1.
Case-by-Case Recommendations
• If an existing or future sludge lagoon or stockpile
is going to be used for ultimate disposal,
development of a closure plan is recommended.
The closure plan should address access
restriction, .cover, and ground water monitoring
requirements (see 40 CFR Part 257, Appendix I,
for contaminants recommended for monitoring).
Sludge lagoons and stockpiles should be
discouraged as ultimate disposal practices.
• Minimum freeboard: The sidewall of the lagoon
should always extend at least two feet above the
level of sludge/supernate in the lagoon.
• Sludge stored for more than one year in
stockpiles should be stabilized by one of the
sludge stabilization processes described in
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Chapter 2.0. Where odor is a concern (i.e., in
populated areas), sludge that is stockpiled or
stored in a lagoon should be stabilized regardless
of the amount of time it is stored.
9.4 Monitoring, Reporting, and Record
Keeping
9.4.1 Monitoring
Federal Regulations
The current regulations require sludge monitoring
and reporting at a frequency dependent upon the
nature and effect of the permittees' sludge use or
disposal activities, but at least once a year for every
pollutant limited in the permit. For example, if the
permit contains a limit for PCBs, the permittee must
monitor its sludge at least annually for this pollutant
(40CFR122.44(c)(2)).
Eighteen States require ground water monitoring
(see Appendix E, Table E9-2). Eight States have some
sort of conditional ground water monitoring require-
ment. Vermont requires monitoring of specific
parameters. Maryland sets specific site requirements
for monitoring wells.
Case-by-Case Recommendations
Based on a review of site conditions, permit writers
should consider requiring installation of properly
sited upgradient and downgradient ground water
monitoring wells for those sludge lagoons with the
potential for contaminating valuable aquifers. The
important factors to consider are listed above under
the liner and depth-to-ground water paragraphs. See
Section 5.4 for more information on assessing the
need for ground water monitoring systems and on
appropriate system designs.
Federal Guidance
For Class I sludge management facilities the Sewage
Sludge Interim Permitting Strategy recommends
annual monitoring of the 126 priority pollutants, as
well as more frequent monitoring of the pollutants
for which numeric limits have been proposed in the
40 CFR Part 503 technical sludge standards. For
surface disposal sites, these pollutants include:
Arsenic
Dimethyl nitrosamine
Benzene
Benzo(a)pyrene
Bis(2-ethylhexyl)phthalate
Cadmium
Copper
OOT/DDE/DDD (Total)*
Lead
Lmdane
Mercury
Nickel
Polychlormated Biphenyls
Toxaphene
Trichloroethylene
DDT-2,2-Bis(chlorophenyl) -1,1,1 -tnchloroethane
DDE-1,1-Bis(chlorophenyl)-2,2-dichloroethene
DDD-1,1 -Bis(chlorophenyl)-2,2-dichloroethane
State Requirements
As shown in Appendix E, Table E9-2, State
monitoring and reporting requirements can be
divided into the following categories: sludge
monitoring, ground water monitoring, surface water
monitoring, and reporting.
Eleven States require sludge monitoring. Three
States, Colorado, Illinois, and Wisconsin, require
annual monitoring. One State, Connecticut, requires
monitoring of metals, PCBs, and pathogens.
Maryland, Virginia, New Hampshire, New Jersey,
Missouri and Wyoming also have sludge monitoring
requirements.
9.4.2 Reporting and Record Keeping
Federal Regulations
The recently promulgated revisions to the NPDES
permitting regulations (54 FR 18716) require that
the permittee report monitoring results with a
frequency dependent upon the nature and effect of
the sewage sludge use or disposal practice, but in no
case less than once a year (40 CFR 122.44(i)(2)).
These regulations also require that records of any
monitoring information which is required by the
permit must be retained for at least five years.
State ftequ/rements
Thirteen States require reporting of some type for
sludge lagoons. Iowa requires reporting for
permanent lagoons only. Two States require a
quarterly summary of management records. Other
State reporting requirements can be found in
Appendix E, Table E9-2.
References
EPA 1986. U.S. Environmental Protection Agency,
Subtitle D Study, Phase I Report, October 1986.
EPA 1987. U.S. Environmental Protection Agency,
State Requirements for Sludge Management, U.S.
Environmental Protection Agency, Office of
Municipal Pollution Control and Office of Water
Enforcement and Permits, Washington, D.C., 1987
(Revised 1989).
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Appendix A
Sewage Sludge Interim Permitting Strategy
The attached "Sewage Sludge Interim Permitting Strategy" (Interim Permitting Strategy)
describes EPA's plans to help ensure the safe use and disposal of sewage sludge prior to the
promulgation of technical sludge standards. This Interim Permitting Strategy implements Section
406 of the Water Quality Act of 1987, P.L. 100-4 (codified at Section 405 (d)(4) of the Clean Water
Act), which provides that, prior to promulgation of sludge technical standards, EPA must "impose
sludge conditions in (NPDES) permits issued to (POTWs)... or take such other measures as the
Administrator deems appropriate to protect public health and the environment from any adverse
effects which may occur from toxic pollutants in sewage sludge." The Interim Permitting Strategy:
• Discusses how to identify priority facilities for sludge permitting and basic permit
requirements;
• Describes the permit writers' guidance document for writing interim sludge conditions;
• Describes EPA/State coordination of interim sludge permitting activities; and
• Provides model documents for use in implementing the Interim Permitting Strategy
(boilerplate permit language and State/EPA agreements, etc.)
A copy of the Interim Permitting Strategy document, including Attachments, can be obtained
from the Permits Division (EN-336), 401 M Street S.W., Washington B.C. 20460. For further
information concerning the strategy, contact Rick Brandes (202) 475-9537.
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INDEX
SEWAGE SLUDGE INTERIM PERMITTING STRATEGY
STATEMENT OF POLICY
I. INTRODUCTION
II. GENERAL REQUIREMENTS FOR ALL POTW PERMITS
III. CASE-BY-CASE CONDITIONS FOR CLASS 1 POTWS
IV. STATE AND EPA COORDINATION ON INTERIM SLUDGE PERMITTING
ATTACHMENTS:
1. Boilerplate Revisions for Sludge
2. Expired and Expiring Permits for Pretreatment POTWs
3. All Sludge Incinerators
4. Pollutants Proposed to be Limited in 40 CFR Part 503
5. Model Certification of EPA Approval of State-Issued
Sludge Permits
6. Model EPA "Sludge Rider" to a State-Issued Permit
7. Model State/EPA Sludge Agreement
8. Clean Water Act Section 405, as amended by the
Water Quality Act of 1987
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SEWAGE SLUDGE INTERIM PERMITTING STRATEGY
STATEMENT OF POLICY
In order to implement the requirements of Section 405(d)(4) of
the Clean Water Act, it is EPA policy that:
1. All NPDES permits issued or reissued to POTWs after February
4, 1987 shall at a minimum: require that the permittee
comply with all existing federal regulations governing the
use and disposal of sewage sludge, and with applicable 40
CFR Part 503 Standards for the Use and Disposal of Sewage
Sludge when promulgated; contain a statement that upon
promulgation of 40 CFR Part 503 the permit may be reopened
and modified or revoked and reissued to incorporate
applicable requirements of 40 CFR Part 503; and require that
the permittee notify the permit authority of any significant
change in its sludge use or disposal practices.
2. Priority POTWs for the purposes of interim sludge permitting
are "Class 1 sludge management facilities," defined as POTWs
1) that are required to have pretreatment programs, or 2)
that have any other known or suspected problems with their
sludge. Sludge incinerators are presumed to have "known or
suspected problems" unless available information shows no
cause for concern.
3. All NPDES permits issued to priority POTWs after February 4,
1987 shall contain, in addition to the minimum conditions in
Paragraph 1, additional conditions developed on a case-by-
case basis to ensure protection of the public health and
environment.
4. Permit writers should use EPA's "Guidance for Writing Case-
by-Case Permit Requirements for Municipal Sewage Sludge" for
developing case-by-case permit conditions for priority
POTWs.
5. All permits issued or reissued to POTWs should contain
sludge monitoring requirements in accordance with the Sewage
Sludge Interim Permitting Strategy.
6. States are encouraged to participate to the fullest extent
possible in interim sludge permitting.
7. The proposed 40 CFR Part 503 numeric limits for the use and
disposal of sewage sludge should not be relied on for
developing interim permit conditions, because these numeric
limits may change as a result of public comment or peer
review. However, other information and methodologies found
in the proposed Part 503 rule and preamble, and its
Technical Support Documents, may be used if the permit
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writer determines their appropriateness for the sludge
practice at issue.
8. states may obtain formal approval of their sludge programs
prior to promulgation of the Part 503 standards. They may
also elect to participate in interim permitting through
agreements with their EPA Regional offices, pursuant to the
Sewage Sludge Interim Permitting Strategy.
9. Where the State is issuing sludge permits pursuant to an
agreement with the EPA Regional office, the Region will
review all permits issued to priority facilities to
determine if the permit meets CWA requirements. If the
permit satisfies the CWA, the Region shall so certify and
attach the certification to the permit.
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INTRODUCTION
Section 405 of the Clean Water Act embodies Congress*
concern with the environmental threats posed by unsafe sewage
sludge use and disposal. Congress re-emphasized its concern in
1987 by amending this section to require EPA to develop detailed
technical standards for sludge use and disposal that would be
adequate to protect public health and the environment from sludge
pollutants. The technical standards (to be codified at 40 CFR
Part 503) will, when promulgated, identify pollutant levels of
concern in sludge for the major use and disposal methods.
However, before the standards are finalized, we need a program to
identify and address potential problems that nay be caused by
contaminated or improperly disposed sludge, and to prepare for
the implementation of the standards.
In the 1987 amendments to the Clean Water Act Congress
recognized the need to take immediate action to regulate sludge.
CWA Section 405(d)(4), as amended, requires that prior to the
sludge standards, EPA must "impose sludge conditions in [NPDES]
permits issued to [POTWs] ... or take such other measures as the
Administrator deems appropriate to protect public health and the
environment from any adverse effects which may occur from toxic
pollutants in sewage sludge.1* Thus, the amendments direct EPA to
protect the environment from unsafe sludge, and initiate sludge
permitting. This phase of the program, which began with passage
of the Water Quality Act on February 4, 1987, is referred to as
the "interim" sludge program and is the primary subject of this
Strategy.
The Act establishes a two-phase approach to regulating
sludge use and disposal. The first phase, interim implementa-
tion, commenced with the passage of the amendments. The second
phase, long-term implementation, begins with final promulgation
of the first round of the technical standards. Those standards
are to identify toxic pollutants of concern in sewage sludge, and
specify numerical pollutant limits and management practices for
sludge to ensure environmentally-sound use and disposal. The
Clean Water Act requires that users and disposers of sewage
sludge comply with the standards within one year from promulga-
tion (two years if construction is required). The Act also
requires that the standards be incorporated into permits issued
to POTWs and other treatment works treating domestic sewaqe. The
proposed standards were published on February 6, 1989 at 54 FjJ
5746; final regulations are scheduled to be promulgated in
October 1991.
The purpose of interim implementation is to establish a
program for long-term implementation, and to ensure that the
environment is protected from improper sludge use and disposal
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prior to promulgation of the technical standards. This Strategy
provides the details of implementing the interim phase. The
requirement to take immediate action to regulate sludge use and
disposal takes on critical importance since technical regulations
are not scheduled to be promulgated until 1991.
This document explains EPA's approach to sludge permitting
prior to issuance of the technical standards. To best achieve
the objectives of the Clean Water Act, the interim program
utilizes existing experience, expertise, and permitting processes
to focus permitting efforts on the facilities which, on the basis
of available information, are thought to present greater risk.
There are three principal components to the Interim Strategy:
1. Ml NPDES permits issued to POTWs after February 4,
1987 are to contain certain basic requirements for
managing sludge. Many of these requirements were
included as part of the Nay 2, 19*9 Sludge State
Program and Permitting Final Rule.
2. For certain "priority" ("Class 1") POTffs, additional
permit conditions developed on a case-by-case basis are
needed to satisfy CWA Section 405(d)(4).
3. Permits containing sludge conditions are to be issued
by EPA, or by a state pursuant to a State/lFA
agreement, or by a State program that has beea approved
pursuant to 40 CFR Parts 123 or soi, as appropriate.
Part II of this Strategy identifies pernit conditions that
are to be included in all POTHs1 NPDES permits as they are
reissued. The most significant change in the final Interim
Strategy from the draft that was made available for public
comment in a May 31, 1988 Federal Register notice is the
discussion of standard permit requirements. The Sludge State
Program and Permitting Requirements Final Rule, among other
things, codifies the interim requirements of CWA Section
405(d)(4), and establishes standard requirements and application
deadlines for including sludge conditions in all POTW permits.
Thus, many of the permitting provisions in the draft Interim
Strategy are now regulatory requirements. Part II describes the
new requirements, additional recommendations, and sludge
monitoring provisions.
A discussion of "Class 1" POTWs and the development of
additional, case-by-case conditions for these facilities is found
in Part III.
Part IV discusses State/EPA coordination on sludge permit
issuance during this interim period. Many States currently have
sludge permit programs. One of the objectives of this Interim
Strategy is to build on these existing programs as much as
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possible, while meeting the requirements of the Act. The purpose
of this is to take advantage of the State experience and
expertise in sludge control and reduce redundant and unnecessary
permitting. Thus, where a State has a sludge permitting program
in place but is not yet seeking formal approval, the Strategy
provides for CWA Section 405(d)(4) interim permitting under a
State/EPA Agreement. These agreements should be in place by
December 30, 1989.
In summary, EPA and the States need to begin immediately to
identify and address potential sludge problems, to lay the
foundation for an effective permitting program that protects the
environment and promotes resource recovery* EPA's statutory
responsibility to take interim measures with respect to sludge
requirements for POTWs became effective upon enactment of the
Water Quality Act on February 4, 1987. This Strategy is designed
to carry out these objectives as quickly as possible, focusing on
the facilities of concern and building on existing experience and
expertise. Throughout the interim period, the Office of Water
Enforcement and Permits (OWEP) will be providing additional
information and guidance on sludge program implementation through
permits. OWEP is currently providing both technical guidance and
contractor assistance to Regions and NPDES States to conduct
permit writing. OWEP also has been holding permit writers
workshops for the Regions and States on developing interim permit
conditions. Implementation of this Strategy not only enables EPA
and the States to carry out the immediate responsibilities under
the Act to protect public health and the environment, but also
furthers the objectives of facilitating compliance with the
technical standards when promulgated and approving State programs
to carry out the requirements of Section 405.
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II
GENERAL REQUIREMENTS FOR ALL POTW PERMITS
This Part describes the requirements for sludge permitting
that were promulgated on May 2, 1989 (54 IB 18716) and became
effective on June l, 1989. These regulations, called the sludge
State program and permitting regulations, among other things
codify the requirements for interim sludge permitting in CWA
Section 405(d)(4). (Sjje. §122.l(g) (5)). In addition, this Part
contains some additional recommendations for standard interim
conditions for all POTWs. (Part III discusses additional permit
conditions for "Class 1" facilities.)
All reissued POTW permits must include some general
requirements for sludge use and disposal, whether or not the
facility needs additional case-by-case limits. These are the
minimum provisions necessary to begin permit coverage of sludge
use and disposal practices in anticipation of the long-term
program, and to enable sufficient oversight of these activities
in the interim. Most of these provisions are now required
specifically by regulation. See 54 ££ 18716 (May 2, 1989). The
four primary areas each permit must address are: compliance with
existing requirements; reopening the permit when the 503
regulations are promulgated; notification of change in sludge
practices; and sludge quality monitoring. Attachment 1 contains
a list of NPDES boilerplate conditions revised to include sludge
conditions in accordance with the May 2, 1989 final rule,
establishing new sludge permitting requirements.
Application Deadline
Section 122.21, which contains the NPDES permit application
requirements, was revised by the May 2, 1989 notice to include
permit application deadlines and application requirements for
sludge. Under §122.21(c)(2), all POTWs with NPDES permits must
submit information (including: sludge production, sludge use and
disposal practices, and existing information on sludge quality,
as set forth in S501.15(a)(2)) with their application for NPDES
permit renewal, or 120 days after promulgation of the technical
sludge standard*, whichever occurs first. (All other "treatment
works treating domestic sewage" do not need to submit an
application for sludge permit coverage until 120 days after
promulgation of applicable sludge technical standards, unless
requested by the permit authority where necessary to protect
public health and the environment. fl22.21(c)(2)(ii).)
Boilerplate Conditions
The first standard permit condition is a compliance
provision: the permit must require the POTW to comply with all
existing requirements for sludge use and disposal.
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§122.44(b)(2). For example, a POTW that applies its sludge to
land is subject to the applicable requirements of 40 CFR Part
257. This compliance must be required in the permit and
monitored by permit oversight.
Permit writers should ascertain the existence of any other
permit governing the facility's sludge use or disposal practices
before developing sludge conditions for the NPDES permit, whether
the facility is a priority or not. Under the new regulations,
applicants are required to submit a list of other permits
governing their sludge management activities issued or applied
for under other laws (§122.21(d)(3)(ii); §501.15(a)(2)(v)). For
example, an incinerator may currently be subject to a permit
under the Clean Air Act, a landfill under a RCRA permit, or the
facility may be subject to a State permit. If these are adequate
to satisfy Section 405(d), the NPDES permit need only reference
the other permit, and add any additional requirements if
necessary to protect public health and the environment. Also, in
the course of developing the other permit, the permitting agency
may have information on the sludge quality or use and disposal
practices that may save the NPDES permit writer considerable time
and effort.
This compliance provision also requires compliance with the
sludge technical standards by the deadlines established in those
standards. This provision restates (and puts the permittee on
notice of) the CWA Section 405 requirement that users and
disposers of sewage sludge comply with the technical standards
for sludge use and disposal by the statutory compliance deadlines
(i.e., within one year after promulgation of the standards, or
within two years if the standards require construction), even if
the permit has not been modified to include such requirements.
See §122.41(a)(1). Any "permit-as-shield" provision in the
permit also should be revised to indicate that compliance with
"interim" permit conditions does not excuse noncompliance with
subsequently promulgated technical sludge standards. See §122.5.
Another permit condition is a reopener clause, which
authorizes reopening a permit to include technical standards if
the technical standards are more stringent or more comprehensive
than the conditions in the permit. See §122.44(b)(2) and (c)(4).
This enables, but does not require, reopening the permit if the
permit writer feels it is necessary to encorporate final Part 503
requirements. Consistent with the sludge State program and
permitting regulations, reopening the permit when the technical
standards are promulgated is discretionary with the permitting
authority, not mandatory. Thus, the permitting authority will
have flexibility to establish permitting priorities for
implementing the technical standards. OWEP anticipates issuing
additional guidance on this subject when Part 503 is promulgated.
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The reopener provision notifies the permittee of future
legal obligations under the Act, and of the potential need to
modify the permit to incorporate Part 503 requirements once they
are promulgated. The reopener provision also enables the
permitting authority to develop permit conditions to assure
compliance with the technical standards by the deadlines
established in Section 405(d)(2) of the CWA. Revisions to
§122.62(a)(7) now specifically authorize permit modifications
pursuant to the reopener provision. The statement of basis or
fact sheet for the permit should include a reference to the
compliance provision and any other provisions that are in the
permit to implement Section 405.
A notification provision, now codified in revisions to
§122.41(1)(1)(iii), must be included in all reissued permits.
This requires the permittee to give notice to the permitting
authority when a significant change in the sludge use or disposal
practice occurs (or is planned) that could require permit
modification under 40 CFR 122.62(a)(1). The permittee need not
notify the permit authority of every change, however slight, to
its sludge use and disposal activities. However, a change in the
POTW's sludge disposal methods, for example from landfilling to
land application, is certainly significant as it could be cause
for permit modification. Notice of, and possible permit
modification for, new use or disposal sites not previously
identified to the permitting authority (except land application
sites covered by an approved land application plan) is also
required (§122.41(1)(i)(iii)).
In addition to the standard sludge boilerplate conditions
described above, (see Attachment 1 for permit language), the
preamble to the recent revisions to the Part 122 regulations
explains that many of the standard permit conditions that apply
to effluent discharge activities will also apply to sludge us*
and disposal activities («.g., duty of proper operation and
maintenance; entry and inspection duties). Conversely, a few of
the Part 122 regulations have been revised to limit their
applicability only to effluent discharge activities (e.g., the
"anti-backsliding" provision in §122.41(1)). Additionally,
several provisions remained unchanged because the existing
language was sufficient to include or exclude sludge use and
disposal activities, as appropriate. The preamble discussion at
54 FR 18743 explains which provisions apply and do not apply to
sludge activities. Permit writers should make revisions to the
standard boilerplate conditions consistent with the revised
regulations.
Monitoring Conditions
Another important component of interim permitting is sludge
quality monitoring. Sludge monitoring to establish baseline data
on each facility for future permit requirements is especially
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critical as most interim permits,- at least in the beginning, will
contain few, if any, concentration limits for pollutants in
sludge (and therefore, compliance monitoring will yield only
limited information) . Thus it is important for fulfilling the
statutory requirement to protect public health and the
environment that the permit writer have current information on
pollutant concentrations, to alert the permit writer as to
excessive loadings that may make a given sludge use or disposal
method unsafe.
The regulations now require sludge monitoring and reporting
at a frequency dependent on the nature and effect of the per-
mittee's sludge use or disposal activities, but at least once a
year (S122.44(i) (2) ) . This means that where the permit contains
pollutant Units (e.g., the permit to a POTW that applies its
sludge to land must contain the 40 CFR Part 257 limits for
cadmium and PCBs, and pathogen requirements), the permit must
require the permittee to sample and analyze those pollutants at
least once a year. Beyond compliance monitoring, the regulations
do not specify which pollutants in sludge must be monitored in
the interim before promulgation of the technical standards.
Similarly, the sludge application requirements do not specify
standard monitoring results which must be submitted for permit
issuance (although they do require applicants to submit all
available data) .
Because the regulations only require compliance monitoring,
and because compliance monitoring, given the fact that few
permits are likely to contain pollutant limits, will not yield
enough information, the permit writer should require monitoring
of additional pollutants, based on his/her best professional
judgment. In some cases the permit may already require sludge
sampling and analysis, and the permit writer may have • good idea
as to the quality of the sludge and the levels of pollutants it
contains. In the absence of such information, EPA recommends
that at a minimum, the permit writer include the following
monitoring requirements in the permit:
o For class 1 POTWs. an annual scan of the 126 priority
pollutants, and more frequent monitoring of the
pollutants for which numeric limits have been proposed
for the POTW's particular use or disposal practice in
the proposed Part 503 regulations (see Attachment 4) .
For non-Class 1 POTWs wftfch. industrial users, a priority
pollutant scan at the time of permit application, and
annual monitoring of the pollutants for which numeric
limits have been proposed for the POTW's particular use
or disposal practice in the proposed Part 503
regulations (see Attachment 4).
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o For non-Class 1 POTWs with no industrial users, annual
monitoring of six metals: cadmium, copper, chromium,
lead, nickel, and zinc.
Of course, monitoring requirements would be tailored to the
particular POTW and would take into consideration site-specific
factors, such as the types of industrial wastes the POTW
receives. At the discretion of the permit authority, if a
pollutant is not detected or is detected at low levels that
clearly show no cause for concern after repeated tests, future
testing for those pollutants need not be required unless a change
occurs at the POTW.
The reason for monitoring for the pollutants proposed to be
limited in the Part 503 proposed rules is so the POTW and the
permit authority will have sufficient information on sludge
quality with regard to those pollutants when the Part 503 rules
are finalized. This is particularly important in light of the
one-year compliance deadline mandated by the Clean Water Act.
(Note that once the Part 503 regulations are promulgated,
monitoring parameters will be governed by those rules (and 40 CFR
Part 122.44(i)(2)). The Guidance for Writing Case-by-Case Permit
Conditions for Municipal Sewage Sludge (described in Part III)
contains further recommendations for developing conditions for
additional baseline monitoring for pollutants of concern and
compliance monitoring for each major use and disposal practice.
(A list of the pollutants proposed to be regulated in 40 CFR Part
503, by use or disposal method, is provided in Attachment 4.)
This Strategy recommends that non-Class 1 POTWs with no
industrial users at a minimum sample for six metals that are
commonly found in sewers at significant levels due to commercial
and domestic discharges to the treatment works. If the permit
writer has pre-existing data on the sludge quality of the
facility that shows no cause for concern with particular
pollutants for that POTW's sludge practices (i.e., routine
readings of particular pollutants which are very low or not
detected), monitoring for that pollutant does not need to be
continued unless there is a change at the POTW. Another
exception is for POTWs that use wastewater stabilization lagoons
as the sole treatment process. For these facilities, where the
sludge will not be removed from the lagoon during the permit
term, the permit need not contain any sludge monitoring
provisions unless the permit writer determines they are needed.
(If such permit does not require monitoring, it should contain a
requirement that the permittee notify the permit authority if it
happens that the sludge is pumped out of the lagoon within a one-
year period.)
The permit should also specify appropriate sampling
protocols. To develop these requirements, permit writers are
directed to two sources. The first is entitled "POTW Sludge
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Sampling and Analysis Guidance Document," EPA, Office of Water
Enforcement and Permits, 1989. This document is designed to
provide information on the sampling and analysis of municipal
sewage sludge, and contains discussions of procedures and
protocols, and current developments on specific topics such as
pathogen equivalency determinations. The second document is
entitled "Sampling Procedures and Protocols for the National
Sewage Sludge Survey," EPA, Office of Water Regulations and
Standards, 1988. The sampling procedures and protocols included
in this document were compiled specifically for the National
Sewage Sludge Survey, which the Agency has initiated to gather
additional information on the pollutants in sewage sludge to
support the Part 503 rulemaking.
The permit also should specify the acceptable analytical
methods. A notice published at 53 £B 39133 (October 5, 1988)
lists all pollutants, and the methods used to analyze them, that
were tested in the national sewage sludge survey. The question
of appropriate analytical methods for determining pollutant
concentrations in sewage sludge has been an ongoing one. Methods
624 and 625, found in 40 CFR Part 136, are essentially adapted
from wastewater analytical methodologies. These methods have
been in longer use and thus are more widely available. EPA's
newer isotope dilution, gas chromatography/mass spectrometry
(GC/MS) methods 1624 and 1625 have been developed specifically
for sewage sludge. The permit writer may specify these methods
or other EPA-approved methods, or methods that are deemed
comparable based on their precision, accuracy, lab availability,
interlab variability, and the level of detection needed to
monitor compliance.
Most of the general monitoring and recordkeeping require-
ments in Part 122 apply to sludge monitoring and recordkeeping
(e.g., §§122.41(j) and 122.48). There are two important
differences, however. First, the regulations do not currently
prescribe specific monitoring reporting forms. Instead, the
permitting authority has discretion to determine an appropriate
form (§122.41(1) (4) (i)) , which should be specified in the permit.
Second, the record retention time for sludge records is five
years, rather than the three-year period that applies to effluent
discharge recordkeeping. (§122.2l(p) and §l22.41(j) (2)) . (The
rule provides a longer record retention time for sludge because
of the need to track cumulative loadings for metals in sludge
that is applied to land over a longer period. The five-year
record retention time will enable this information to be "carried
over" when the permit is reissued.)
In sum, to fulfill the objectives that Congress has
established in Section 405 (d) , we must begin as soon as possible
to establish permit requirements for sludge. All POTW permits
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must include compliance provisions, notification language, and
monitoring requirements as described above and specified in the
regulations, and should include sludge quality monitoring as set
forth in this Strategy. In addition, case-by-case permit
requirements will need to be developed as appropriate. This is
discussed in Part III.
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Ill
CASE-BY-CASE CONDITIONS FOR CLASS 1 POTWS
The previous section discusses basic permit requirements for
all NPOES permits issued or reissued to POTWs after February 4,
1987. There are situations, however, where more comprehensive,
site-specific permit coverage may be warranted. This may mean
more frequent monitoring or other site-specific conditions such
as management practices or numeric limitations developed on a
case-by-case basis. This gives rise to two questions: which
POTWs should receive more comprehensive permit coverage during
this interim period, and what should be included in the permits
issued to such facilities.
Identifying Permitting Priorities; Class 1 Sludge Management
Facilities
A major purpose of requiring case-by-case sludge limits only
for certain POTWs is to target available resources for sludge
permitting on critical sites. In earlier versions of this
Strategy, which generally referred to POTWs with known or
suspected problems with sludge quality or use/disposal practices,
or those warranting more comprehensive sludge permit condition*
for other reasons. The draft Strategy suggested that
pretreatment POTWs, POTWs incinerating their sludge, POTWs using
or disposing of sludge in ecologically-sensitive areas such as
estuaries, and new POTWs should be evaluated closely to determine
if th"ey should be included in the priority category.
The recently promulgated sludge management regulations also
identify a group of POTWs targeted for closer oversight because
of the greater potential for their sludge use and disposal to
adversely affect public health or the environment. These are
called "Class I sludgs management facilities." Thus, this
definition and the earlier "priority* POTW designation serve
similar purposes and are based on the same rationale. To
facilitate long-term implementation, "Class I sludgs management
facilities* will be presumed to need case-by-case sludge interim
limits (i.e., they should be considered permitting priorities),
unless the permitting authority determines, based on information
about th« facility's sludgs quality and use or disposal
practices, that ths sludge is adequately controlled already. In
this Strategy, the terms "priority" and "Class 1" facility are
used interchangeably.
A Class I sludge management facility is defined as:
...any POTW identified under 40 CFR 403.8(a) as being
required to have an approved pretreatment program
(including such POTWs located in a State that has
sleeted to assume local program responsibilities
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pursuant to 40 CFR 403.10(e)) and any other treatment
works treating domestic sewage classified as a Class I
sludge management facility . . . because of the
potential for its sludge use or disposal practices to
adversely affect public health and the environment.
Pretreatment POTWs were included in the definition of "Class I
sludge management facility" in response to numerous requests for
more specificity in defining priorities. In addition, the same
factors that determine whether a POTW should be required to
develop a local program (i.e., size, industrial users subject to
pretreatment standards, or necessary to prevent pass-through or
interference with the POTW's operations) also suggest that
sludges from pretreatment POTWs have a greater potential for
having significant impacts on public health and the environment.
"Class I sludge management facility" also includes other
treatment works with known or potential sludge problems. In
assessing the risks associated with the various sludge use and
disposal options, EPA has found that the potential risk levels
are highest for incinerators. In addition, in a recent Agency
study of comparative risks, sewage sludge incinerators were
identified as one of the potentially nor* harmful sludge use and
disposal practices. Overall, the risk was assessed to be in the
middle range in comparison to other environmental problems. See
"Unfinished Business: A Comparative Assessment of Environmental
Problems," U.S. EPA, Office of Policy, Planning and Evaluation,
February 1987. Because of this, POTWs using incineration should
be presumed to need case-by-case sludge permit limits, unless the
permit writer has information demonstrating that there is no
cause for concern. (Note: Most POTWs incinerating their sludge
are also pretreatment POTWs. Therefore, only those POTWs using
incineration which are not required to have pretreatment programs
will need to be considered additionally. See Attachment 3.)
Attachment 2 contains listings of pretreatment permits that
have expired or expire in FY89 and FY90. A separate listing
shows the POTWs that incinerate their sludge and gives the
expiration dates for the NPDES permits.
Other POTWs may have known or potential sludge use and
disposal problems. A POTW in non-compliance with existing
federal regulations (e.g., 40 CFR Part 257) is one example. When
the NPDES permit is due to be reissued, the permitting authority
will need to make a determination whether the facility will need
case-by-case limits. Case-by-case limits should not be rejected
simply because the permitting authority has no knowledge of any
sludge problems. Instead, the permit writer should take
reasonable steps to ascertain the nature of the facility's sludge
and sludge disposal practices. Under the May 2, 1989 sludge
management regulations, POTWs are required to submit basic
background information and available monitoring results on their
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sludge and use and disposal methods with their NPDES permit
renewal application. 40 CFR I22.21(c)(2). Other available
information also should be examined, such as pretreatment audit
reports and investigations into interference problems at the
POTW, to see if any problems with sludge have been identified.
Also, POTWs conducting sludge use or disposal in ecologically
sensitive areas, such as estuaries, may warrant more
comprehensive sludge permit conditions beyond the basic
boilerplate and monitoring requirements.
Permits issued to POTWs with new sludge treatment facilities
should also be carefully considered for development of case-by-
case sludge conditions. Although known problems may not exist,
preventing problems through careful controls at new facilities is
generally easier for both the permitting authority and permittee
than taking remedial action after a problem has developed.
(Note: this paragraph does not refer to situations where a POTW
has switched to another existing facility/ for example/ to a
different monofill, but rather, refers to treatment facilities
that are newly constructed.)
One commenter on the draft strategy suggested that the nine
sewerage authorities in New York and New Jersey that dispose of
their sewage sludge in the ocean should also be identified as a
"priority11 for interim sludge permitting. The Marina Protection/
Research and Sanctuaries Act of 1972 (MPRSA) regulates ocean
disposal, and prohibits ocean dumping without a permit issued
pursuant to MPRSA. In November 1988, Congress passed the Ocean
Dumping Ban Act, amending MPRSA. Among other things, the purpose
of this Act is to terminate the ocean-dumping of sewage sludge by
December 1991. The significance of this legislation for the
implementation of'Section 405 of the CWA is that after December
31, 1991, it will be unlawful to dispose of sewage sludge in the
ocean, and those POTWs that currently ocean-dispose of their
sewage sludge will have to develop land-based sludge management
alternatives, which will be subject to the jurisdiction of
Section 405 of the Clean Water Act. Prior to the termination of
dumping, State and Regional NPOES and sludge permit writers
should work with the POTWs and MPRSA authorities to identify the
quality of the sewage sludge and assist the POTWs in developing
land-based sludge use or disposal methods. This involvement is
not for purposes of regulating the practice of ocean disposal,
which will be effected through the MPRSA permit process, but
rather, to assist the facility in implementing land-based
disposal methods that will meet the requirements of CWA Section
405.
Case-bv-Case Permit Conditions
To assist permit writers in developing more comprehensive
permit conditions for Class 1 facilities, EPA has developed a
"Guidance for Writing Case-by-Case Permit Requirements for
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Municipal Savage Sludge" ("CbC Guidance"). The purpose of the
guidance is to assist permit writers in developing appropriate
permit conditions for sludge and EPA permit writers in reviewing
State permits issued to Class l POTWs.
As stated earlier, the most important task for the interim
period is to ensure that existing requirements are written into
permits. Use of the CbC Guidance ensures that existing
applicable federal and State requirements are incorporated into
permits issued to Class 1 POTWs. Its use should help to promote
timely compliance with the Part 503 sludge regulations when
issued, by those POTWs most likely to cause adverse effects from
pollutants in sewage sludge. (The Part 503 sludge regulations
will require compliance within one year fro* promulgation.) In
addition, compliance with the monitoring requirements specified
will provide information on sludge quality and the use and
disposal practices at the POTW, and help to identify potential
problems .
As a "best professional judgment" guidance document, the CbC
Guidance presents: 1) a compilation of existing federal and state
requirements for sludge; 2) existing guidance; and 3) recommenda-
tions for permit writers to consider writing into permits on a
case-by-case basis using their best professional judgment. The
CbC Guidance sets forth existing requirements for each of the
major sludge use and disposal practices. Additionally, the
Guidance contains recommendations for further permit conditions.
In general these, recommendations consist of management practices,
although some recommended numeric limits are given, based on
existing guidance. The CbC Guidance states that EPA permit
writers must write existing federal sludge requirements into
NPDES permits or incorporate them by reference to other permits.
The Guidance may be used by Regional and State permit
writers to assist them in arriving at appropriate permit limits
for priority facilities, and by the Regions in reviewing State-
issued permits. The fact sheet or statement of basis
accompanying the permit must explain the basis for arriving at
the sludge requirements. EPA and States may take further action
beyond what may be specified in the guidance, where appropriate
to protect public health and the environment where particular
problems are) identified and a basis for the requirements is
established.
^*Hpj Conditions and the Proposed 503 Standards. EPA
recently proposed technical standards for the use and disposal of
sewage sludgs (54 PR 5746; February 6, 1989). This rulemaking is
being developed to meet the requirement in Section 405(d) that
EPA promulgate regulations identifying sswags sludgs use and
disposal methods and concentrations of pollutants that interfere
with each method. The proposed Part 503 regulations address
sswags sludgs incinsration, land application, landfill ing,
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distribution and marketing, and surface disposal. EPA has also
developed technical support documents for each method.
The Interim Strategy and the CbC Guidance are designed
primarily for use before issuance of the final technical
standards. The focus of the interim program is on identifying
and addressing, through permits, existing or potential problems
with sludge use or disposal, in the absence of promulgated
technical standards. In developing permit limits for POTWs in
the interim, the primary source of information for permit writers
should be the Case-by-Case Guidance. Information from other
sources, of course, may be considered and evaluated by the permit
writer in the exercise of his or her best professional judgment.
These include, for example, the proposed 503 rule and preamble,
its technical support documents, and available information from
the National Sewage Sludge Survey.
The proposed 503 standards are currently undergoing public
comment and peer review. These processes, as well as the results
of the National Sewage Sludge Survey may result in final
standards that are significantly different from the proposal. In
light of these circumstances, reliance on the proposed standard*
should be limited. The permit writer should not rely on the
proposed numeric limits in developing case-by-case sludge
conditions unless the permit writer can independently establish
the appropriateness of such conditions based on the circumstances
of the particular sludge practice at issue. As previously noted,
any sludge conditions, other than those based on existing
regulations, must have a sound technical basis explained in the
fact sheet that accompanies the permit.
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STATE AND EPA COORDINATION ON INTERIM SLUDGE PERMITTING
EPA seeks to encourage States with existing, effective
sludge management programs to carry out the program for
implementing interim sludge permitting under the CWA to the
extent that they are willing and able to do so. This Part
describes the minimum requirements necessary for State interim
permitting, and the procedures for establishing State/EPA
coordination in the permitting process.
EPA interprets CWA Section 405(d)(4) to allow state/EPA
coordination, whereby States with existing effective sludge
management programs could carry out interim sludge permitting.
This is beneficial for the national sludge program because States
with effective programs are more likely to know which particular
facilities or practices may be causing problems. Moreover,
involving States now serves the dual purpose of minimizing
disruption to existing State programs and reducing duplication of
effort by EPA and the States.
The sludge State program and permitting regulations,
promulgated on May 2, 1989, provide for formal submission of
State sludge programs for review and approval by EPA. States
may, but do not need to, seek formal approval, pursuant to the
May 2, 1989 rules, during the interim phase to carry out interim
and long-term permitting. They may also opt to rely on more
informal arrangements with the EPA Regions, as this Part
explains. States that are not yet seeking formal approval are
encouraged to use this interim period to evaluate their programs
in light of the requirements for approvable sludge state programs
to identify areas where their programs may need to be changed or
augmented in order to be approved.
Establishing State/EPA Coordination
The 1987 CWA amendments give EPA the flexibility to rely on
State sludge management activities to carry out the objectives of
the Act for interim sludge requirements. Where the; State chooses
to participate in the interim program through an agreement, the
Agency will take steps to ensure that any measures are adequate
to protect public health and the environment by overseeing Stats
efforts. To accomplish this, this Strategy adopts a two-pronged
approach which targets facilities of concern for oversight.
For all NPDES POTWs that are defined as Class 1, the Region
will review the sludge requirements in each State-issued permit
(or other individual control mechanisms) to make sure they
incorporate existing federal requirements and meet the objectives
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of the Clean Water Act. The CbC Guidance is intended to assist
the Regions in this review. The'review of the sludge conditions
could be built into the Region's process for reviewing State
permits issued to NPDES majors.
Section 405(d)(4) authorizes only the Administrator to
impose conditions in NPDES permits or take other appropriate
measures. Thus, to be recognized under Section 405(d)(4),
conditions imposed by States must be approved/adopted by EPA. To
accomplish this, three steps are required. First, a state which
issues a Class 1 permit would state in the public notice of the
draft permit that the permit (or facility-specific plan) will
contain sludge requirements to implement the requirements of
Section 405 of the CWA and therefore will be federally
enforceable pursuant to Section 309 of the Act. Second, the
Region must review the permit and determine whether it satisfies
the requirements of the interim program. Finally, the Region
must affirmatively approve the permit by issuing a letter or
certification to the State permitting agency. This written
documentation of EPA approval should also be attached to the
permit. (A sample certification letter is in Attachment 5.)
Following these steps should enable EPA to take action to enforce
interim sludge requirements in these permits where appropriate
(e.g., joint enforcement actions with the State, cases of
national significance, etc).
The public notice and permit-by-permit EPA approval
requirements applicable to permits for Class 1 POTWs will not be
required for non-Class 1 POTW permits. However, for interim
implementation purposes, a State must be able to impose the
minimum requirements for these other permits set out in Part II.
EPA will also oversee the State's activities in imposing the
minimum requirements on non-Class 1 permits. However, oversight
will not be required on a permit-by-permit, or individual POTW,
basis, but may be accomplished through other means, such as
periodic file or permit reviews and annual program reviews.
B. State Eligibility
Any State with an effective sludge permitting program may
participate in the implementation of interim sludge requirements,
regardless of that State's NPDES participation or status. In
seeking State involvement, EPA will need to determine the extent
to which the State is willing and able to implement this Strategy
for carrying out the responsibilities created by Section
405(d)(4). State participation should be encouraged to the
maximum extant possible. Where States either cannot (for
example, because they lack legal authority) or will not partici-
pate, EPA will remain responsible for imposing sludge require-
ments. Where the state will not undertake sludge permitting and
EPA is the NPDES permitting authority, the EPA permit writer
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would simply include sludge requirements in the reissued NPDES
permit. Where the State has NPDES authority, EPA would issue a
"sludge rider" to the State-issued NPDES permit or issue a
separate Section 405 sludge permit. (Attachment 6 contains a
model EPA "sludge rider".) Wherever possible, State and EPA
sludge permitting activities should be coordinated to assure
consistency and minimize duplication of efforts. (See, for
example, 40 CFR 124.4 on joint permitting procedures.) In most
cases, interim implementation will require the combined efforts
of States and EPA Regional Offices to protect the environment
adequately and put an effective sludge program in place. The
degree of participation will likely vary from State to State.
States need not assume full responsibility for interim permitting
in order to participate. For example, a State may currently
regulate only one disposal practice. In that case, the State
could agree to cover interim sludge permitting for that
particular practice, and EPA would issue permits for the other
use and disposal practices.
C. Procedures for Establishing State/EPA Coordination
Establishing State/EPA coordination in interim permitting
involves two steps: (1) the state must identify the extent to
which it is able and willing to participate; and (2) the State
and the Region would execute an agreement establishing the
responsiblities of EPA and the State in the interim sludge
permitting process.
Regional offices should contact each State about its
capacity to undertake interim implementation activities.
Execution of an agreement will be necessary with any State
that agrees to participate. This agreement could be part of
the Section 106 planning process or any other appropriate vehicle
that defines EPA/State roles in program implementation.
(1) State's Declaration
Initially, the state should identify the capacity of its
existing program to regulate the sludge use and disposal
practices of its POTWs in comparison to the minimum requirements
established in the CbC Guidance and Parts II and III of this
Strategy. Generally, EPA will rely on the State's declaration of
its capacity (i.e., resources and legal authority to impose and
enforce interim sludge requirements). As noted above, a State
need not assume full responsiblity for all sludge permitting in
order to participate. For example, a State may currently
regulate only land application of sludge. The State could agree
to be responsible for permitting only the POTWs which use this
disposal method now. Later, if the State's program expands to
include regulation of other disposal options, it could expand its
role in interim implementation. EPA will encourage States that
cannot assume full sludge permitting immediately to increase
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their permitting capabilities over time. Where a POTW uses more
than one disposal option and the State does not regulate all
options, EPA must "fill in the gaps" either by issuing a sludge
rider to the State-issued permit (see Attachment 6) or a separate
Section 405 permit. if known in advance, this specific situation
should be addressed in the State/EPA sludge agreement.
(2) State EPA Sludae Agreement
After the State has expressed its willingness to participate
in interim implementation, the Region should enter into an
agreement with the State establishing their respective responsi-
bilities for interim implementation of sludge requirements,
especially permitting responsibilities and information exchange
between the State and the Region. The agreement also may include
provisions about other aspects of EPA-State coordination of
sludge management activities as well (e.g., coordination of
inspections and enforcement actions). The agreement may be
flexible in many respects, but it should clearly identify
permitting responsibilities of the State and EPA in establishing
sludge requirements.
The agreement may be an annual workplan negotiated as part
of the Section 106 process, but the Region and State should
consider documenting longer term understandings for development
of a full State program with EPA's assistance. The agreement may
be executed as a revision to an existing agreement or as a
separata agreement. In NPDES States, revisions to the NPDES
Memorandum of Agreement (MOA) may also be necessary if it
conflicts with any of the provisions described below. Also, if
the MOA waives EPA review of minor POTW permits, this waiver
would have to be modified to facilitate review of permits for
minor POTWs which are classified as Class 1 permits for sludge
purposes and thus require EPA review. See fl23.24(d).
The State/EPA sludge agreement should include provisions to
address the following:
o Identification of the POTW permits the State will be
responsible for, those EPA will be responsible for,
and those for which EPA and the state will assume
joint responsibility;
o For permits for which EPA assumes responsibility, a
description of how the Region will issue the sludge
permit (i.e., by issuing a "sludge rider" to the State-
issued NPDES permit, through joint issuance of the
permit or by issuing a separate EPA NPDES sludge
permit);
o Provisions for joint issuance of permits, where
appropriate;
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o Provisions for EPA review and comment on all Class 1
permits drafted by the State, and agreement that if EPA
determines that State limits are not adequate in any
specific case, EPA will issue a "sludge rider11 or separate
sludge permit to the POTW;
o For sludge Class I permits with sludge conditions the
State issues, agreement by the State to include in the
public notice of the draft permit, in addition to other
information that may be required by State or federal
requirements, a statement that the draft permit includes
conditions implementing interim sludge requirements
pursuant to Section 405(d) of the CWA and, therefore, will
be federally enforceable pursuant to Section 309 of the
CWA after review and approval by EPA (see Attachment 7 for
language);
o State's agreement to include in permits issued to non-
Class 1 POTWs the minimum conditions described in the
"Sewage Sludge Interim Permitting Strategy";
o Provisions that establish the State's compliance
monitoring and enforcement activities for the permits it
agrees to issue (See Attachment 7);
o An agreement to share, upon request, the results of
any sludge monitoring activities (e.g., self-monitoring
and inspection reports);
o Provisions that recognize that the agreement is not
a substitute for formal program approval and that
EPA approval of the State sludge program will be
needed for purposes of long-term implementation (i.e.,
after final promulgation of the Part 503 technical
criteria, which is scheduled for 1991); and
o Any agreements concerning activities to build up the
State program in preparation for obtaining formal
program approval.
A modal State/EPA sludge agreement is found in Attachment 7.
Even when a State with an existing sludge management program
does not actively participate in interim permitting, EPA permit
writers should look to the State as a valuable resource and
consider adopting by reference existing State permits and/or
requirements. As with State requirements affirmatively approved
by EPA, including State requirements in the NPDES permit means
that EPA is adopting those requirements as its own and therefore
must be be prepared to enforce and defend them.
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D. Timetable
It is crucial that Regions and States begin now to work out
the details for establishing State participation in interim
implementation. The State/EPA sludge agreements should be
executed as soon as possible, but no later than December 31,
1989. A copy of any agreements should be sent to the Cynthia
Dougherty, Director, Permits Division, Office of Water
Enforcement and Permits.
139
-------
Appendix B
Regional and State Air, Solid Waste, Ground Water, and Sludge Contacts
141
-------
Regional and State Sludge Coordinators
Region State
1
CT
ME
MA
NH
Rl
VT
II
NJ
NY
PR
VI
III
DE
DC
MD
PA
WV
VA
IV
AL
FL
GA
KY
MS
NC
SC
TN
V
IL
IN
Ml
MN
OH
Wl
Name FTS Number
Thelma Hamilton 8-835-3569
Warren Herzig
Brian Kavenah
Dennis Bunn
Richard Flanders Jr.
Chris Campbell
George Desch
An Harris 8-264-4707
Helen Pettit-Chase
Richard Hammond
Eva Hernandez
Leonard G. Reed
Edward Ambrogio 8-597-4491
Ronald E. Graeber
James R. Collier
William E. Chicca
Stephen Socash
Clifton Browning
Cal M. Saywer
A.L. Willet
Vince Miller 8-257-4491
Cliff Evans
Tom Connary
Mike Thomas
Arthur S. Curtis Jr.
Glen Odoms
Allem Wahab
Arthur Mouberry
George (Mike)Caughman
David Thompson
Bob Slayden
Bob Odette
JohnO'Grady 8-353-1938
Al Keller
Pat Carroll
Dale Brockway
Steven Stark
Stuart M. Blydenburgh
John Melby
Robert Stemdorf
Phone Number
617-565-3569
203-566-8652
207-582-8740
617-556-1130
603-271-3571
401-277-3961
802-244-8744
212-264-4707
609-984-4429
518-457-2051
809-723-0733
809-774-3320
215-597-4491
302-736-5731
202-767-7370
301-631-3318
717-787-1749
304-348-2108
804-786-1755
804-367-6136
404-347-4491
205-271-7816
904-488-4524
404-656-7400
502-564-4310
601-962-5171
919-733-6900
919-733-5083
803-734-5300
803-734-5289
615-741-0633
615-741-7883
312-886-6090
217-782-1696
317-232-8736
517-373-8751
612-296-7169
614-644-2001
608-267-7666
608-266-0449
(Continued)
142
-------
Regional and State Sludge Coordinators (Continued)
Region
VI
VII
VIII
IX
X
State
AR
LA
NM
TX
IA
KS
MO
B
CO
MT
ND
SD
UT
WY
AZ
CA
HI
NV
AL
ID
WA
OR
Name
Stephanie Kordzi
Mike Hood
Bob Marken
Ken Fledderman
Bijan Sharafkhani
Cordelia Snow
Milton R. Rose
T.A. Outlaw
John Dunn
Darrell McAllister
Rodney Geisler
Ken Arnold
Rudy Fielder
Robert Brobst
Phil Hegeman
Scott Anderson
Jeff Hauge
Dave Templeton
Kiran Bhayani
Mike Hackett
Lauren Fondahl
Barry Abbot
Archie Matthews
Dennis Tuland
Robert Carlson
Dick Hetherington
Glenn Miller
Dick Markum
Al Murrey
Robert Braem
Al Hanson
Ed O'Brien
Mark Ronayne
FTS Number Phone Number
8-255-7175 214-655-7175
501-562-8910
501-661-2632
504-342-1216
504-342-1216
505-827-2808
512-463-8513
512-458-7271
8-276-7094 913-551-7094
515-281-8869
913-296-5527
314-751-6624
409-471-4239
8-330-1654 303-293-1654
303-331-4564
406-444-2406
701-224-2354
605-773-3151
801-538-6146
307-777-7781
8-465-2199 415-566-3910
602-257-6989
916-322-4507
808-548-6769
702-885-4670
8-399-1941 206-442-1941
907-465-2671
970-465-2611
208-334-5860
208-334-5860
206-438-7266
206-459-6059
503-229-6442
143
-------
Appendix C
Distribution and Marketing Labels and Instructions
145
-------
Net Weight it KUogramc (I *«.)
NATURAL ORGANIC
FERTILIZER
Milorganite
6-2-0
Activated Sewage Sludge
Read directions carefully before using
For use on lawns, shrubs
and ornamentals only
Long lasting, will not burn
The Golf Course Choice"
PACKAGED 8V
SUNNILANO CORP.
SANFORD. FLORIDA 32771
146
-------
Read directions carefully before using
NATURAL ORGANIC
FERTIUZER
Milorganite
Activated Sewage Sludge
1.3 KMgnm Net WtigM .
•Harpe* Me Ntfwal OffMte Nrtfe*
Aettated Sewage Stodge S-t-0
Bianirteed Anafirife
Total Nitrogen ...................
5.5S Water fotoM* Ma-ifoH
0.5% Water Sohjbio Wree*
AnHaMe Phosphoric Add (Mi) ..... t.tft
Iroa(Fe)
Milwaukee
4J»
Directions for use
Milorganite is an p»xce!'ent tort-:• .-<•'
for turfgrasses ana .ea'y or • •. i.en
tals F'owering plants mi. -eguire
supplemental phospnat<> , d potasr
in some soils
NOTICE: Milorganite should not be
used on vegetables due to possible
uptake of the heavy metal cadmium
When home grown vegetables make
up • large portion of the annual diet
over a period of many years, cadmium
may accumulate in the kidneys,
resulting in possible dysfunction.
LAWNS
To assure an impressive start towara
dense, healthy turf apply the :on
tents of this bag to 170 square lent
Oo tnis by applying Milorganite n
IWO directions with the spreide.* v "je
°09tr. The results will provide /ear
iong feeding.
Golf courses use half rates, but m
two applications. This is done by set
ting the spreader to the largest ouen-
"HJ ano apply carefully in one direc
Jjon. This bag will then cover about
" 'o 425 square feet
I Mason grasses respond nest to
sijrnmer feeding Another ac
1 just before freezing assures
ajY spring greenijp without ex-
"^ Qrruiitk
lor
'ike bermudas,
hd early far
"« ,/r.^"l:i"s' 'ODhcat-ons shoulo
it is done, some of 'he
nu'nents are held ''n '^srjf.«- •_" >^»>
nj*t growing season sc M'loigamr-
&: aivr'S oecome progressively oet-
-t"r Mii^ryamte «'ii -ot burn the 'urf
S: • .i^vsr needs 'o oe watered m
Lawn Spreader Settings
^or Spring. Fail jnrf Winter Use
"iqnest Quality
Spmner Spruader
*'«• ggtn
ijuiner Spreader
•. .. -.- in« ,»•<••*«
cor Summer Application
Spinner Spreader
Drop Spreader
...
Drop Spreader
«'J
Drop Spreader
<9
ORNAMENTALS
iuu'iv i' ^ to 5 'bs per 100 souare
'"et. Scatter uni'orinty on trie surface
f'l .vork i'Ho the soil surface.-
A j ib -o»'ee can ho'ds 5 it»- °'
TREES
U-^e 5 'c '0 'bs 'o' each
j.^jiuter at -rhest heigtlt
to 2 'nch diameter hoie*^
deep, spaced 2
"om the trunk to oe/Oi
spread of branches.
nd
out*«
147
-------
v/vr
RE-POTTIH6 SOU MEDIA
NO CHEMICALS!
AN ORGANIC - NATURAL -
POTTING SOIL
WHY USE EKO-compost?
EKO-KOMfOST, INC. l« using wasta mat«rf*U to maka a
haalthiar and mora baautiful world. EKO-eompost U a eon-
eantratad KE-POTTINd SOIL MEOUprawttd (ram waata
•utarlate Wood wasta*, (soltwaod and hardwood aaw
dusts, ahraddad bark, planara d«*t, woodcMps); Munich
paUlgaalad sawaga cludga; Tanfcaga: an^ Gnnlta dust
Altar mixing, a apadal MologleaMy'contfTllad^procass
(Naw World 4 Europaan TadwotogytVnakaa thaa* (ormar
IngradlaAU kite a avparlar eompoat at ili F 0«gra««.
NET WEIGHT
8qts.
•FOKMULA AND MOCCS3.
FAMILY TMAOCSECKCT
148
-------
INSTRUCTIONS TO USE
EKO-compost*
RE-POTTING SOIL MEDIA
•EKO-compost is a CONCENTRATED SOIL MEDIA,
therefore, you can use the old root-ball ot your plant.
RE-POTTING: 1. Use a larger pot, line it with at least one inch ot EKO-compost on
all sides and at the bottom.
2. Place the root-ball of your plant into the EKO-compost-linec" pot.
Tamp it down firmly.
3. Top-dress with at least one inch thick layer of EKO-compost.
4. Water the plant thoroughly, and as settling occurs, add more
EKO-compost.
TOP-DRESS WITH EKO-compcst
••—POT
EKO-compost
POTTING: For new plants use only Vj EKO-compost. Other half can be a
combination of your own garden soil, sand, perlite, and vermicu-
lit*.
SEEDBEDS: Same as potting above. Or blend V2 EKO-compost with an;
other commercial potting mix.
TOP-DRESSING: Always top-dress existing or newly potted or re-ported plarrtf
with EKO-compost. Repeat twice a year.
CARE FOR THE UNOSI^COMPOaT>PI««sc keep EKO-composr b«g> tlghtf/
closed af tor each use.
OTHER FINE EKO-compost PRODUCTS: Look for the 20 and 40 lb. EKO-compcst
bags at your favorite store!
149
-------
For All
Container
Planting
Indoor FoIiage«Hanging Baskets*Flowering Plants:
i
-------
HORTICULTURAL POTTING MIXES
Recognizing that no one potting mix can satisfy the needs of ail plants,
Kellogg has developed a line of horticultural potting soil products.
These scientifically developed mixes provide the proper planting
medium tor most plants tended by gardening enthusiasts. The
following mixes are complete, nothing need be added, and can be
used for indoor or outdoor containers.
POTTING SOIL—this general purpose potting soil can be used for
indoor foliage plants, patio containers, color plants in window boxes,
hanging baskets and other containers.
AFRICAN VIOLET MIX—this soil mix retains the much needed
moisture and nutrients required by these popular flowery plants.
ORCHID MIX—this special mix provides the ideal soil environment
for growing terrestrial orchids such as cymbidiums.
POTTING SOIL
KELLOGG POTTING SOIL is a mixture ol materials which provide an ideal soil environment
tor growing plants in containers. Plants need a medium that is porous, yet absorbent lor
holding moisture, air and nutrients. POTTING SOIL can be used lor indoor foliage plants, pano
containers, color plants in window boxes, hanging baskets and other containers.
DIRECTIONS
Select I container (hit
will allow 'or ample (pact
'or root growth Carefully
remove plant from ill
cutting container.
Set the plant on a 'aw
ol Kellogg • Polling Soil
Th« lop Ol tne roou Shou
be oelow the rim ol me
container to allow lor
watering.
Fmith filling with Kellogg't
•otttng Sou to me too o'
me plant t rootball Tamp
firmly to exclude large air
pocKtti.
water iho'Suj1"/ j-'-i
water drains ''0^
-------
KELLOGG'S NITROHUMUS
1 1/2 Cubic Feet
KELLOGG'S NITROHUMUS»
Soil Conditioner
KELLOGG'S NITROHUMUS is one of the most widely used products
in the lawn and garden industry in the Southwest. It is an all
purpose soil conditioner used to improve the physical properties
of soils. Results from using this material are increased
workability, aeration and drainage of clay soils and increased
water and nutrient retention of sandy soils.
Bedding Plants,
Ground Covers, Bulbs
Cover planting beds with 1/2
to 1 inch of NITROHUMUS.
(1 1/2 CF covers 20 to 40
sq. ft.). Rototill or spade
to a depth of 6 to 8 inches
or use 1 cup per individual
plant or bulb mixed into
the planting hole.
Soil Preparation
Lawns:
Use 1 1/2 CF of NITROHUMUS
and one 3 CF of KELLOGG
REDWOOD COMPOST for each
to to 100 sq. ft. Rototill
or spade into the top 4
to 6 inches of soil.
Top Dressing
Making Compost
Cover newly planted seed
with NITROHUMUS at the rate
of 1 1/2 CF per 150 sq. ft.
Keep moist until lawn is
established.
Add 1 to 2-inch layers of
NITROHUMUS to compost heaps
to increase the rate of
producing usable compost.
Ingredients: Composted, Centrifuged Sewage Sludge and Forest Products
Total Nitrogen 0.5%
KELLOG SUPPLY, INC.
Carson, California 90745
Product of U.S.A.
152
-------
KELLOGG'S AMEND
2 Cubic Feet
KELLOGG'S AMEND®
Vegetable and Flower Planting Mix
Enjoy the fruits of growing a successful garden through the use
of KELLOGG's AMEND. This fully composted blend of organic
materials improves water penetration and drainage and reduces
compaction of soils. KELLOGG'S AMEND HELPS MAKE HARD CLAY
SOILS SOFT and sandy soils retain moisture and nutrients.
KELLOGG'S AMEND is used for planting vegetables, flowers, ground
covers and bedding plants.
VEGETABLE PLANTING
FLOWER GARDENS
AND BEDDING PLANTS
Spread one bag of KELLOGG's
AMEND and 1/2 Ib. of KELLOGG's
KARE for Tomatoes and Vegetables
for each 15 to 20 square feet.
Rototill or spade to a
depth of 6 to 8 inches,
assuring adequate mixing.
Water lightly after planting
and daily during establishment.
Spread one bag of KELLOG'S
AMEND and two cups of
KELLOGG'S KARE for Roses
and Flowers for each 25
sq. ft.
Spade to a depth of 6 to 8
inches, assuring adequate
mixing.
Water after planting and
daily during establishment.
Apply a 1 to 2 inch layer
of GROMULCH after planes
are established.
GROUND COVERS
Spread a minimum of one
bag of KELLOGG'S AMEND
and 4 cups of KELLOGG'S
KARE for Blooming Plants
per 50 square feet.
Spade
to 8"
hole.
to a depth of 6"
at each planting
Water after planting and
daily during establishmen"
153
-------
INDIVIDUAL PLANTS Prepare a mixture of 1/2
KELLOGG'S AMEND and 1/2
soil from the planting hole.
Form a watering basin around
the base of the plant after
planting.
Water thoroughly and daily
during establishment.
INGREDIENTS: Rice Hulls and Nitrohumus (Composted, Centrifuged,
Sewage Sludge and Forest Products)
KELLOGG SUPPLY, INC
Carson, California 90745
Product of U.S.A.
154
-------
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158
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Appendix D
40 CFR Part 257 - Criteria for Classification of Solid Waste Disposal
Facilities and Practices
159
-------
PART 257—CRITERIA FOR CLASSIFI-
CATION OF SOLID WASTE DISPOS-
AL FACILITIES AND PRACTICES
Sec.
257.1 Scope and purpose.
257.2 Definitions.
257.3 Criteria for classification of solid
waste disposal facilities and practices.
257.3-1 Floodplalns.
257.3-2 Endangered species.
257.3-3 Surface water.
257.3-4 Ground water.
257.3-5 Application to land used for the
production of food-chain crops (Interim
final).
257.3-6 Disease.
257.3-7 Air.
257.3-6 Safety.
257.4 Effective date.
APPENDIX I
APPPENDIX II
AUTHORITY: Sec. 1008(a)(3) and sec.
4004(a). Pub. L. 94-580. 90 Stat. 2803 and
2815 (42 U.S.C. 6907(a)(3) and 6944(a»; sec.
405(d). Pub. L. 95-217, 91 Stat. 1606 (33
U.S.C. 1345(d)>.
SOURCE 44 FR 53460. Sept. 13. 1979.
unless otherwise noted.
§ 257.1 Scope and purpose.
(a) These criteria are for use under
the Resource Conservation and Recov-
ery Act (the Act) in determining
which solid waste disposal facilities
and practices pose a reasonable proba-
160
-------
§ 257.2
40 CFR Ch. I (7.L85 Edition)
bility of adverse effects on health or
the environment. Unless otherwise
provided, these criteria are adopted
for purposes of both Section
1008(a)(3) and Section 4004(a) of the
Act.
(1) Facilities failing to satisfy crite-
ria adopted for purposes of Section
4004(a) will be considered open dumps
for purposes of State solid waste man-
agement planning under the Act.
(2) Practices failing to satisfy crite-
ria adopted for purposes of Section
1008(a)<3) constitute open dumping.
which is prohibited under Section 4005
of the Act.
(b) These criteria also provide guide-
lines for sludge utilization and dispos-
al under Section 405(d) of the Clean
Water Act, as amended. To comply
with Section 405(e) the owner or oper-
ator of any publicly owned treatment
works must not violate these criteria
in the disposal of sludge on the land.
(c) These criteria apply to all solid
waste disposal facilities and practices
with the following exceptions:
(1) The criteria do not apply to agri-
cultural wastes, including manures
and crop residues, returned to the soil
as fertilizers or soil conditioners.
(2) The criteria do not apply to over-
burden resulting from mining oper-
ations intended for return to the mine
site.
(3) The criteria do not apply to the
land application of domestic sewage or
treated domestic sewage. The criteria
do apply to disposal of sludges gener-
ated by treatment of domestic sewage.
(4) The criteria do not apply to the
location and operation of septic tanks.
The criteria do, however, apply to the
disposal of septic tank pumpings.
(5) The criteria do not apply to solid
or dissolved materials in irrigation
return flows.
(6) The criteria do not apply to In-
dustrial discharges which are point
sources subject to permits under Sec-
tion 402 of the Clean Water Act, as
amended.
(7) The criteria do not apply to
source, special nuclear or byproduct
material as defined by the Atomic
Energy Act, as amended (68 Stat. 923).
(8) The criteria do not apply to haz-
ardous waste disposal facilities which
are subject to regulation under Sub-
title C of the Act,
(9) The criteria do not apply to dis-
posal of solid waste by underground
well injection subject to the regula-
tions (40 CFR Part 146) for the Under-
ground Injection Control Program
(UICP) under the Safe Drinking
Water Act. as amended, 42 U.S.C. 3007
et seq.
[44 FR 53460, Sept. 13, 1979. as amended at
46 FR 47052. Sept. 23. 1981]
0 257.2 Definitions.
The definitions set forth in Section
1004 of the Act apply to this part. Spe-
cial definitions of general concern to
this part are provided below, and defi-
nitions especially pertinent to particu-
lar sections of this part are provided In
those sections.
"Disposal" means the discharge, de-
posit, injection, dumping, spilling.
leaking, or placing of any solid waste
or hazardous waste into or on any land
or water so that such solid waste or
hazardous waste or any constituent
thereof may enter the environment or
be emitted into the air or discharged
into any waters, including ground
waters.
"Facility" means any land and ap-
purtenances thereto used for the dis-
posal of solid wastes.
"Leachate" means liquid that has
passed through or emerged from solid
waste and contains soluble, suspended
or mlscible materials removed from
such wastes.
"Open dump" means a facility for
the disposal of solid waste which does
not comply with this part.
"Practice" means the act of disposal
of solid waste.
"Sanitary landfill" means a facility
for the disposal of solid waste which
complies with this part.
"Sludge" means any solid, semisolid.
or liquid waste generated from a mu-
nicipal, commercial, or industrial
wastewater treatment plant, water
supply treatment plant, or air pollu-
tion control facility or any other such
waste having similar characteristics
and effect.
"Solid waste" means any garbage,
refuse, sludge from a waste treatment
plant, water supply treatment plant,
161
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Environmental Protection Agency
or air pollution control facility and
other discarded material, including
solid, liquid, semlsolid, or contained
gaseous material resulting from indus-
trial, commercial, mining, and agricul-
tural operations, and from community
activities, but does not include solid or
dissolved materials in domestic
sewage, or solid or dissolved material
in irrigation return flows or industrial
discharges which are point sources
subject to permits under Section 402
of the Federal Water Pollution Con-
trol Act, as amended (86 Stat. 880). or
source, special nuclear, or byproduct
material as defined by the Atomic
Energy Act of 1954, as amended (68
Stat. 923).
"State" means any of the several
States, the District of Columbia, the
Commonwealth of Puerto Rico, the
Virgin Islands. Guam, American
Samoa, and the Commonwealth of the
Northern Mariana Islands.
(44 FR 53460. S«pt. 13, 1979: 44 FR 58910,
Oct. 12, 1979]
§ 257.3 Criteria for classification of solid
waste disposal facilities and practices.
Solid waste disposal facilities or
practices which violate any of the fol-
lowing criteria pose a reasonable prob-
ability of adverse effects on health or
the environment:
§257.3-1 Floodplaiiu.
(a) Facilities or practices in flood-
plains shall not restrict the flow of the
base flood, reduce the temporary
water storage capacity of the flood-
plain, or result in washout of solid
waste, so as to pose a hazard to human
life, wildlife, or land or water re-
sources.
(b) As used in this section:
(1) "Based flood" means a flood that
has a 1 percent or greater chance of
recurring in any year or a flood of a
magnitude equalled or exceeded once
in 100 years on the average over a sig-
nificantly long period.
(2) "Floodplain" means the lowland
and relatively flat areas adjoining
Wand and coastal waters, including
flood-prone areas of offshore islands,
which are inundated by the base flood.
(3) "Washout" means the carrying
*way of solid waste by waters of the
base flood.
§ 257.3-3
[44 FR 53460. Sept. 13. 1979; 44 FR 54708.
Sept. 21.19791
0 257.3-2 Endangered species.
(a) Facilities or practices shall not
cause or contribute to the taking of
any endangered or threatened species
of plants, fish, or wildlife.
(b) The facility or practice shall not
result in the destruction or adverse
modification of the critical habitat of
endangered or threatened species as
identified in 50 CFR Part 17.
(c) As used in this section:
(1) "Endangered or threatened spe-
cies" means any species listed as such
pursuant to Section 4 of the Endan-
gered Species Act.
(2) "Destruction or adverse modifica-
tion" means a direct or indirect alter-
ation of critical habitat which appre-
ciably diminishes the likelihood of the
survival and recovery of threatened or
endangered species using that habitat.
(3) "Taking" means harassing, harm-
ing, pursuing, hunting, wounding, kill-
ing, trapping, capturing, or collecting
or attempting to engage in such con-
duct.
§ 257.3-3 Surface water.
(a) For purposes of Section 4004(a)
of the Act, a facility shall not cause a
discharge of pollutants into waters of
the United States that is in violation
of the requirements of the National
Pollutant Discharge Elimination
System (NPDES) under Section 402 of
the Clean Water Act. as amended.
(b) For purposes of Section 4004(a)
of the Act, a facility shall not cause a
discharge of dredged material or fill
material to waters of the United
States that is in violation of the re-
quirements under Section 404 of the
Clean Water Act, as amended.
(c) A facility or practice shall not
cause non-point source pollution of
waters of the United States that vio-
lates applicable legal requirements im-
plementing an areawide or Statewide
water quality management plan that
has been approved by the Administra-
tor under Section 208 of the Clean
Water Act, as amended.
(d) Definitions of the terms "Dis-
charge of dredged material", "Point
source", "Pollutant". "Waters of the
United States", and "Wetlands" can be
162
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§ 257.3-4
40 CFR Ch. I (7-1-85 Edition)
found in the Clean Water Act, as
amended. 33 U.S.C. 1251 et seq., and
Implementing regulations, specifically
33 CFR Part 323 (42 PR 37122, July
19, 1977).
[44 FR 53460. Sept. 13. 1979, as amended at
46 FR 47052. Sept. 23, 1981]
§ 257.3-4 Ground water.
(a) A facility or practice shall not
contaminate an underground drinking
water source beyond the solid waste
boundary or beyond an alternative
boundary specified in accordance with
paragraph (b) of this section.
(bXl) For purposes of Section
1008(a)(3> of the Act or Section 405(d)
of the CWA, a party charged with
open dumping or a violation of Section
405(e) may demonstrate that compli-
ance should be determined at an alter-
native boundary in lieu of the solid
waste boundary. The court shall estab-
lish such an alternative boundary only
if it finds that such a change would
not result in contamination of ground
water which may be needed or used
for human consumption. This finding
shall be based on analysis and consid-
eration of all of the following factors
that are relevant:
(i) The hydrogeological characteris-
tics of the facility and surrounding
land, including any natural attenu-
ation and dilution characteristics of
the aquifer;
(ii) The volume and physical and
chemical characteristics of the leach-
ate:
(ill) The quantity, quality, and direc-
tion of flow of ground water underly-
ing the facility;
(iv) The proximity and withdrawal
rates of ground-water users;
(v) The availability of alternative
drinking water supplies;
(vl) The existing quality of the
ground water, Including other sources
of contamination and their cumulative
impacts on the ground water;
(vil) Public health, safety, and wel-
fare effects.
(2) For purposes of Sections 4004(a)
and 1008(a)(3), the State may estab-
lish an alternative boundary for a fa-
cility to be used in lieu of the solid
waste boundary only if it finds that
such a change would not result in the
contamination of ground water which
may be needed or used for human con-
sumption. Such a finding shall be
based on an analysis and consideration
of all of the factors identified in para-
graph (b)(l) of this section that are
relevant.
(c) As used in this section:
(1) "Aquifer" means a geologic for-
mation, group of formations, or por-
tion of a formation capable of yielding
usable quantities of ground water to
wells or springs.
(2) "Contaminate" means introduce
a substance that would cause:
(1) The concentration of that sub-
stance in the ground water to exceed
the maximum contaminant level speci-
fied in Appendix I. or
(ii) An increase in the concentration
of that substance in the ground water
where the existing concentration of
that substance exceeds the maximum
contaminant level specified in Appen-
dix I.
(3) "Ground water" means water
below the land surface in the zone of
saturation.
(4) "Underground drinking water
source" means:
(i) An aquifer supplying drinking
water for human consumption, or
(ii) An aquifer in which the ground
water contains less than 10,000 mg/1
total dissolved solids.
(5) "Solid waste boundary" means
the outermost perimeter of the solid
waste (projected in the horizontal
plane) as it would exist at completion
of the disposal activity.
[44 FR 53460. Sept. 13, 1979, as amended at
46 FR 47052, Sept. 23. 1981]
§ 257.3-5 Application to land used for the
production of food-chain crops (inter-
im final).
(a) Cadmium. A facility or practice
concerning application of solid waste
to within one meter (three feet) of the
surface of land used for the produc-
tion of food-chain crops shall not exist
or occur, unless in compliance with all
requirements of paragraph (a)(l) (1)
through (ill) of this section or all re-
quirements of paragraph (a)(2) (i)
through (iv) of this section.
(1X1) The pH of the solid waste and
soil mixture is 6.5 or greater at the
time of each solid waste application,
163
-------
Environmental Protection Agency
§ 257.3-5
except for solid waste containing cad-
mium at concentrations of 2 mg/kg
(dry weight) or less.
(ii) The annual application of cadmi-
um from solid waste does not exceed
0.5 kilograms per hectare (kg/ha) on
land used for production of tobacco,
leafy vegetables or root crops grown
for human consumption. For other
food-chain crops, the annual cadmium
application rate does not exceed:
Preaent
July 1, 1
Thrw period
to June 30 1984 .
994 to Dec. 3t. 1966
ig Jan. 1, 1987
Annual Cd
application
rate (kg/
ha)
2.0
1.25
O.S
(ill) The cumulative application of
cadmium from solid waste does not
exceed the levels in either paragraph
(aXIXiiiXA) of this section or para-
graph (aXlHiiiXB) of this section.
(A)
SoU cation exchange capacity
(meq/IOOg)
leaa than 5 ...
5 to 15 _
Mora than 15
Maximum cumulative
application (kg/ ha)
Back-
ground soil
pH less
than 6.5
5
5
5
Back-
ground soil
pH more
than 6.5
5
10
20
(B) For soils with a background pH
of less than 6.5. the cumulative cadmi-
um application rate does not exceed
the levels below: Provided, That the
pH of the solid waste and soil mixture
is adjusted to and maintained at 6.5 or
greater whenever food-chain crops are
grown.
Sott cation exchange capacity (maq/100g)
Lesa than 5 _
5 to 15
More than 15
Maximum
cumulative
application
(kg/ ha)
5
10
20
(2X1) The only food-chain crop pro-
duced Is animal feed.
(ii) The pH of the solid waste and
soil mixture is 6.5 or greater at the
time of solid waste application or at
the time the crop Is planted, whichev-
er occurs later, and this pH level is
maintained whenever food-chain crops
are grown.
(ill) There is a facility operating
plan which demonstrates how the
animal feed will be distributed to pre-
clude ingestion by humans. The facili-
ty operating plan describes the meas-
ures to be taken to safeguard against
possible health hazards from cadmium
entering the food chain, which may
result from alternative land uses.
(Iv) Future property owners are noti-
fied by a stipulation In the land record
or property deed which states that the
property has received solid waste at
high cadmium application rates and
that food-chain crops should not be
grown, due to a possible health
hazard.
(b) Polychlorinated Biphenyls
(PCBs). Solid waste containing concen-
trations of PCBs equal to or greater
than 10 mg/kg (dry weight) is Incorpo-
rated into the soil when applied to
land used for producing animal feed.
including pasture crops for animals
raised for milk. Incorporation of the
solid waste Into the soil is not required
if it is assured that the PCB content is
less than 0.2 mg/kg (actual weight) in
animal feed or less than 1.5 mg/kg (fat
basis) in milk.
(c) As used In this section:
(1) "Animal feed" means any crop
grown for consumption by animals,
such as pasture crops, forage, and
grain.
(2) "Background soil pH" means the
pH of the soil prior to the addition of
substances that alter the hydrogen ion
concentration.
(3) "Cation exchange capacity"
means the sum of exchangeable ca-
tions a soil can absorb expressed in
milli-equivalents per 100 grams of soil
as determined by sampling the soil to
the depth of cultivation or solid waste
placement, whichever is greater, and
analyzing by the summation method
for distinctly acid soils or the sodium
acetate method for neutral, calcareous
or saline soils ("Methods of Soil Anal-
ysis, Agronomy Monograph No. 9." C.
A. Black, ed., American Society of
Agronomy, Madison. Wisconsin, pp
891-901. 1965).
164
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§ 257.3-6
40 CFR Ch. I (7.L85 Edition)
(4) "Food-chain crops" means tobac-
co, crops grown for human consump-
tion, and animal feed for animals
whose products are consumed by
humans.
(5) "Incorporated Into the soil"
means the injection of solid waste be-
neath the surface of the soil or the
mixing of solid waste with the surface
soil.
(6) "Pasture crops" means crops
such as legumes, grasses, grain stubble
and stover which are consumed by ani-
mals while grazing.
(7) "pH" means the logarithm of the
reciprocal of hydrogen ion concentra-
tion.
(8) "Root crops" means plants whose
edible parts are grown below the sur-
face of the soil.
(9) "Soil pH" is the value obtained
by sampling the soil to the depth of
cultivation or solid waste placement,
whichever is greater, and analyzing by
the electrometric method. ("Methods
of Soil Analysis, Agronomy Mono-
graph No. 9," C.A. Black, ed., Ameri-
can Society of Agronomy. Madison,
Wisconsin, pp. 914-926, 1965.)
(44 FR 53460, Sept 13, 1979; 44 FR 54708,
Sept. 21, 19791
§ 257.3-6 Disease.
(a) Disease Vectors. The facility or
practice shall not exist or occur unless
the on-slte population of disease vec-
tors is minimized through the periodic
application of cover material or other
techniques as appropriate so as to pro*
tect public health.
(b) Sewage sludge and septic tank
pumpings (Interim Final). A facility
or practice involving disposal of
sewage sludge or septic tank pumpings
shall not exist or occur unless in com-
pliance with paragraphs (b) (1), (2) or
(3) of this section.
(1) Sewage sludge that is applied to
the land surface or Is incorporated
into the soil is treated by a Process to
Significantly Reduce Pathogens prior
to application or incorporation. Public
access to the facility is controlled for
at least 12 months, and grazing by ani-
mals whose products are consumed by
humans is prevented for at least one
month. Processes to Significantly
Reduce Pathogens are listed in Appen-
dix II, Section A. (These provisions do
not apply to sewage sludge disposed of
by a trenching or burial operation.)
(2) Septic tank pumpings that are
applied to the land surface or incorpo-
rated into the soil are treated by a
Process to Significantly Reduce
Pathogens (as listed in Appendix II
Section A), prior to application or In-
corporation, unless public access to
the facility is controlled for at least 12
months and unless grazing by animals
whose products are consumed by
humans is prevented for at least one
month. (These provisions do not apply
to septic tank pumpings disposed of by
a trenching or burial operation.)
(3) Sewage sludge or septic tank
pumpings that are applied to the land
surface or are incorporated into the
soil are treated by a Process to Fur-
ther Reduce Pathogens, prior to appli-
cation or incorporation, if crops for
direct human consumption are grown
within 18 months subsequent to appli-
cation or incorporation. Such treat-
ment Is not required if there is no con-
tact between the solid waste and the
edible portion of the crop; however, in
this case the solid waste is treated by a
Process to Significantly Reduce
Pathogens, prior to application; public
access to the facility is controlled for
at least 12 months; and grazing by ani-
mals whose products are consumed by
humans is prevented for at least one
month. If crops for direct human con-
sumption are not grown within 18
months of application or incorpora-
tion, the requirements of paragraphs
(b) (1) and (2) of this section apply.
Processes to Further Reduce Patho-
gens are listed in Appendix II. Section
B.
(c) As used in this section:
(1) "Crops for direct human con-
sumption" means crops that are con-
sumed by humans without processing
to minimize pathogens prior to distri-
bution to the consumer.
(2) "Disease vector" means rodents,
flies, and mosquitoes capable of trans-
mitting disease to humans.
(3) "Incorporated into the soil"
means the injection of solid waste be-
neath the surface of the soil or the
mixing of solid waste with the surface
soil.
(4) "Periodic application of cover
material" means the application and
165
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Environmental Protection Agency
§ 257.3-8
compaction of soil or other suitable
material over disposed solid waste at
the end of each operating day or at
such frequencies and in such a manner
as to reduce the risk of fire and to
Impede vectors access to the waste.
(5) "Trenching or burial operation"
means the placement of sewage sludge
or septic tank pumplngs in a trench or
other natural or man-made depression
and the covering with soil or other
suitable material at the end of each
operating day such that the wastes do
not migrate to the surface.
[44 FR 53460, Sept. 13. 1979: 44 FR 54708.
Sept. 21. 19791
§257.3-7 Air.
(a) The facility or practice shall not
engage in open burning of residential.
commercial. Institutional or industrial
solid waste. This requirement does not
apply to infrequent burning of agricul-
tural wastes in the field, silvlcultural
wastes for forest management pur-
poses, land-clearing debris, diseased
trees, debris from emergency clean-up
operations, and ordnance.
(b) For purposes of Section 4004(a)
of the Act, the facility shall not vio-
late applicable requirements developed
under a State Implementation Plan
(SIP) approved or promulgated by the
Administrator pursuant to Section 110
of the Clean Air Act, as amended.
(c) As used in this section "open
burning" means the combustion of
solid waste without (1) control of com-
bustion air to maintain adequate tem-
perature for efficient combustion. (2)
containment of the combustion reac-
tion in an enclosed device to provide
sufficient residence time and mixing
for complete combustion, and (3) con-
trol of the emission of the combustion
products.
[44 FR 53480. Sept. 13. 1979; 44 FR 54708.
Sept. 21. 1979. as amended at 48 FR 47052.
Sept. 23. 1981]
§257.3-8 Safety.
(a) Explosive gases. The concentra-
tion of explosive gases generated by
the facility or practice shall not
exceed:
(1) Twenty-five percent (25%) of the
lower explosive limit for the gases In
facility structures (excluding gas con-
trol or recovery system components);
and
(2) The lower explosive limit for the
gases at the property boundary.
(b) Fires. A facility or practice shall
not pose a hazard to the safety of per-
sons or property from fires. This may
be accomplished through compliance
with 9 257.3-7 and through the period-
ic application of cover material or
other techniques as appropriate.
(c) Bird hazards to aircraft A facili-
ty or practice disposing of putrescible
wastes that may attract birds and
which occurs within 10.000 feet (3.048
meters) of any airport runway used by
turbojet aircraft or within 5,000 feet
(1,524 meters) of any airport runway
used by only piston-type aircraft shall
not pose a bird hazard to aircraft.
(d) Access. A facility or practice shall
not allow uncontrolled public access so
as to expose the public to potential
health and safety hazards at the dis-
posal site.
(e) As used in this section:
(1) "Airport" means public-use air-
port open to the public without prior
permission and without restrictions
within the physical capacities of avail-
able facilities.
(2) "Bird hazard" means an increase
in the likelihood of bird/aircraft colli-
sions that may cause damage to the
aircraft or injury to its occupants.
(3) "Explosive gas" means methane
(CHJ.
(4) "Facility structures" means any
buildings and sheds or utility or drain-
age lines on the facility.
(5) "Lower explosive limit" means
the lowest percent by volume of a mix-
ture of explosive gases which will
propagate a flame in air at 25'C and
atmospheric pressure.
(6) "Periodic application of cover
material" means the application and
compaction of soil or other suitable
material over disposed solid waste at
the end of each operating day or at
such frequencies and in such a manner
as to reduce the risk of fire and to
impede disease vectors' access to the
waste.
(7) "Putrescible wastes" means solid
waste which contains organic matter
capable of being decomposed by micro-
organisms and of such a character and
166
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§ 257.4
40 CFR Ch. I (7.145 Edition)
proportion as to be capable of attract-
ing or providing food for birds.
8 257.4 Effective date.
These criteria become effective Oc-
tober 15.1979.
APPENDIX I
The maximum contaminant levels promul-
gated herein are for use In determining
whether solid waste disposal activities
comply with the ground-water criteria
(1257.3-4). Analytical methods for these
contaminants may be found In 40 CFR Part
141 which should be consulted In Its entire-
ty.
1. Maximum contaminant levels for inor-
ganic chemical*. The following are the max-
imum levels of inorganic chemicals other
than fluoride:
Contaminant
Arsenic
Barium
Cadmium
Lead _
Mercury
Nitrate (a» N)
Selenium
Silver ..
Level
(milligrams
per liter)
0.05
1
0.010
005
0.05
0.002
10
0.01
0.05
The maximum contaminant levels for flu-
oride are:
Temperature ' degrees
Fahrenheit
53.7 and below
53 6 to 58 3 . . . .
56.4 to 63 8
$3.9 to 706
70.7 to 792 .
79.3 to 905 _.
Degrees Celsius
12 and below
12 1 to 146
14.7 to 176
17.7 to 21 4
21 5 to 26 2
26 3 to 32 5
Level
(milligrams
per liter)
2.4
22
2.0
1.8
1.6
1.4
'Annual average of the maximum datfy air temperature.
2. Maximum contaminant levels for or-
ganic chemicals. The following are the max-
imum contaminant levels for organic chemi-
cals:
Undane (1,2.3.4,S,6-Hexacntorocycio-
hexane, gamma isomer
Methoxychtar (1.1.1-Tnchloro-2.2-o» (p.
iiielhojcypheriyt) ethane)
Toxaphene (C,.H,.CX-Tec*irwcal cntannated
camphene, 67 to 69 percent chtonne)—
(b) CNorophenoxya:
2.4-O (2.4-OicntaropnenoKy.Bcetic aod)
2.4,5-TP Sftvrn (2.4.5-ThcNorophan. oxy-
propxxnc acid)...._ _._____«._..
Level
(mAgrams
per liter)
0004
0.1
0.005
0.1
0.01
3. Maximum microbiological contaminant
levels. The maximum contaminant level for
coliform bacteria from any one well Is as fol-
lows:
(a) using the membrane filter technique:
(1) Four coliform bacteria per 100 milllli-
ters If one sample is taken, or
(2) Four coliform bacteria per 100 milllli-
ters in more than one sample of all the sam-
ples analyzed in one month.
(b) Using the five tube most probable
number procedure, (the fermentation tube
method) In accordance with the analytical
recommendations set forth in "Standard
Methods for Examination of Water and
Waste Water", American Public Health As-
sociation. 13th Ed. pp. 662-088. and using a
Standard sample, each portion being one
fifth of the sample:
(1) If the standard portion Is 10 millillters.
coliform In any five consecutive samples
from a well shall not be present in three or
more of the 25 portions, or
(2) If the standard portion is 100 mllllli-
ters. collfonn in any five consecutive sam-
ples from a well shall not be present In five
portions in any of five samples or In more
than fifteen of the 25 portions.
4. Maximum contaminant levels for
radium-228, radium-228, and gross alpha
particle radioactivity. The following are the
maximum contaminant levels for radium-
228, radium-228. and gross alpha particle ra-
dioactivity:
(a) Combined radium-228 and radlum-
228-5 pCl/1;
(b) Gross alpha particle activity (including
radlum-226 but excluding radon and urani-
um)—15 pCi/1.
APPENDIX II
(a) Chlorinated hydrocarbons:
Endrln (1,2,3.4f10.10-Hexachkxo-e.7-«poxy.
1.4.4a,5.e.7.8,8a-octahydro-1,4-«ndo.
endo-5.8-<*methano naphthalene)
Level
(milligrams
per liter)
0.0002
A. Processes to Significantly Reduce
Pathogens
Aerobic digestion: The process is conduct-
ed by agitating sludge with air or oxygen to
maintain aerobic conditions at residence
tunes ranging from 60 days at 15* C to 40
167
-------
Environmental Protection Agency
days at 20' C. with a volatile solids reduc-
tion of at least 38 percent.
Air Drying: Liquid sludge Is allowed to
drain and/or dry on under-drained sand
beds, or paved or unpaved basins In which
the sludge Is at ft depth of nine Inches. A
minimum of three months Is needed, two
months of which temperatures average on a
daily basis above 0* C.
Anaerobic digestion: The process is con-
ducted in the absence of air at residence
times ranging from 60 days at 20' C to 15
days at 35' to 55' C, with a volatile solids re-
duction of at least 38 percent.
Composting: Using the wtthin-vessel.
static aerated pile or windrow composting
methods, the solid waste is maintained at
minimum operating conditions of 40* C for 5
days. For four hours during this period the
temperature exceeds 55* C.
Lime Stabilization: Sufficient lime is
added to produce a pH of 12 after 2 hours of
contact.
Other methods: Other methods or operat-
ing conditions may be acceptable If patho-
gens and vector attraction of the waste
(volatile solids) are reduced to an extent
equivalent to the reduction achieved by any
of the above methods.
B. Processes to Further Reduce Pathogens
Composting: Using the withln-vessel com-
posting method, the solid waste is main-
tained at operating conditions of 55' C or
greater for three days. Using the static aer-
ated pile composting method, the solid
waste Is maintained at operating conditions
of 55* C or greater for three days. Using the
windrow composting method, the solid
waste attains a temperature of 55* C or
greater for at least 15 days during the com-
posting period. Also, during the high tem-
perature period, there will be a minimum of
five turnings of the windrow.
Heat drying: Dewatered sludge cake Is
dried by direct or Indirect contact with hot
gases, and moisture content is reduced to 10
percent or lower. Sludge particles reach
temperatures well In excess of 80* C, or the
wet bulb temperature of the gas stream in
contact with the sludge at the point where
it leaves the dryer is in excess of 80* C.
Heat treatment Liquid sludge is heated to
temperatures of 180* C for 30 minutes.
Thermophilic Aerobic Digestion: Liquid
sludge is agitated with air or oxygen to
maintain aerobic conditions at residence
times of 10 days at 55-60* C, with a volatile
solids reduction of at least 38 percent.
Other methods: Other methods or operat-
ing conditions may be acceptable if patho-
gens and vector attraction of the waste
(volatile solids) are reduced to an extent
equivalent to the reduction achieved by any
of the above methods.
Any of the processes listed below. If added
to the processes described in Section A
Part 260
above, further reduce pathogens. Because
the processes listed below, on their own, do
not reduce the attraction of disease vectors.
they are only add-on in nature.
Beta ray irradiation: Sludge Is Irradiated
with beta rays from an accelerator at dos-
ages of at least 1.0 megarad at room temper-
ature (ca. 20* C).
Gamma ray irradiation: Sludge Is irradi-
ated with gamma rays from certain isotopes.
such as "Cobalt and "'Cesium, at dosages
of at least 1.0 megarad at room temperature
(ca. 20* C).
Pasteurization: Sludge is maintained for
at least 30 minutes at a minimum tempera-
ture of 70' C.
Other methods: Other methods or operat-
ing conditions may be acceptable if patho-
gens are reduced to an extent equivalent to
the reduction achieved by any of the above
add-on methods.
168
-------
Appendix E
State Requirements and Guidance for Sludge Use and Disposal
169
-------
Table E5-1. Landfilling - Sludge Treatment/Management
State
Alabama
Alaska
Arkansas
California
Colorado
Connecticut
Florida
Georgia
Idaho
Illinois
Iowa
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Missouri
Nebraska
New Hampshire
New Jersey
New Mexico
New York
North Carolina
Ohio
Oklahoma
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
Tennessee
Texas
Sludge Dewatenng
Yes
> 1 0% solids
>30% solids
20% solids if primary sludge
15% solids if secondary or mixture of sludge
Yes: case-by-case
For codisposal
Yes
Solids content >15%
For some landfills
> 75% solids
Yes - no free water
No free liquids
Minimum 20% solids
No free liquids - may mix with soil and retest
>18% solids
No free water
Special approval needed to take sludge containg moisture.
If moisture >60%: lagoon storage required.
Minimum 20% solids
>20%
Yes
To 20% sohds
Yes, minimum 20%, no codisposal
with solid waste after 3/1/89
Yes
No free liquids unless leachate collected and mixed with
bulking material
Pass filter test
Yes
Must be > 1 5% solids
Minimum 20% solids
1 5% minimum solids
(trench and fill in sludge-only landfill)
Sludge Stabili2atlon
Yes
Yes
No raw sludge or septage
Yes
Yes
Yes
Yes - PSRP
Special handling required if not stabilized
Yes
No
Yes
Yes
Yes
Yes, to the point that the material, while cohesive
and viscous, slowly flows or loses its shape when
unconfined, and does not readily release liquids
under normal conditions
Raw sludge must be disposed of remotely
Yes
Yes
Not meet hazardous waste criteria
Yes
Yes
Requires special handling if not stabilized
170
-------
Table E5-1. Landf illing - Sludge Treatment/Management (Continued)
State
Utah
Virginia
Virgin Islands
Washington
West Virginia
Wyoming
Sludge Dewatenng
Sludge with no free moisture placed on the working face
and covered with municipal solid waste
>20% solids; minimum of 6:1 solids:sludge ratio
Pending
15-20% for fill above surface; 1:1 sludge:soil ratio
Must have > 30% solids
Yes - no free or standing water
Sludge Stabilization
Yes
Yes
171
-------
Table E5-2. Landftiling - Site Specific Considerations
State
Alabama
Alaska
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kentucky
Maine
Massachusetts
Michigan
Distance to
Surface Water
Yes
Case-by-case
determination
100ft
200ft
250-1000 ft
300ft
2-yr variances
permitted
If not drinking water
supply, case-by-
case decision
100ft
Depth to
Ground Water
5ft
Minimum 5 ft above
highest anticipated
GW elevation
Minimum 5 ft to
maximum high water
table
20 inches from annual
seasonal high GW
level
Minimum of 5 ft
depending on soil type
10ft
4 ft to GW
2 ft to bedrock
Minimum 5 ft above
seasonal high water
table and bedrock
4 ft from bottom of
secondary liner
4 ft for Type III sites
10 ft for certain Type
II soil sites
12 ft for Type II lined
sites/top cover
Soil Type
Yes
Yes
Yes
Yes
Site specific
Permeability 0.2-20
in/hr
Yes
Clay characteristics
Floodplain
Restrictions
Yes
Yes
Designed,
constructed, operated,
maintained to prevent
washout. Diversion
structures.
Sites prohibited in
floodplams
Cannot restrict flow of
base flood or cause
washout - no specific
prohibition
Yes
Yes
Allowed only with
approval
Not in 1 00-yr
floodplain
Can't be situated in a
floodplain
Not within 10-yr
floodplain
Prohibited on
floodplain
Prohibited within 100-
year floodplain
Type II landfills not in
floodplain
(some exceptions)
Buffer Zones/
Nearest Dwelling/
Distance to Wells
50 ft to site boundary
Nearest dwelling - yes
1 ,000 ft to wells
Nearest dwelling - yes
1 ,000 ft to jet airport runway
5,000 ft for propeller
500 ft to nearest well
1 00 ft to site boundary
1/2 mi to private well
2 mi to public well
100 ft with permission
1 00-300 ft with vegetative
screen
Nearest dwelling 600 ft
1000 ft to wells
500 ft to nearest dwelling
250-1000 ft to wells and
dwellings
1 00 ft to public roads and
property lines
1000 ft to residences, wells,
springs
Buffer zone: case-by-case
determination
300 ft to existing dwelling
1 00 ft from property line
172
-------
Table E5-2. Landfilling • Site Specific Considerations (continued)
State
Mississippi
Missouri
Montana
Nevada
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oklahoma
Oregon
Distance to
Surface Water
100 ft
Yes
100ft
50ft
200 ft except by
means of a waiver
granted by Ohio
EPA director
1 00 ft to streams or
other water bodies
Depth to
Ground Water
10-15 ft
To be proposed -
Currently
case-by-case
10-20 ft minimum
4ft
6 ft to seasonal high
water table
Yes
5 ft to seasonal high
water table and 1 0 ft
to bedrock
4ft
>5ft
Depth to seasonally
high ground water;
also > 3 ft
recompacted clay liner
plus a synthetic liner
5 ft to seasonal high
water table
Soil Type
Percolation rate
cannot exceed 1 .5
in/hr
Yes
Estimate CECs
Yes
Soil scientist
recommendation
required
Suitable cover
material incl. loam,
sandy loam, silty
loam, clay loam, sil-
ty clay or other
demonstrated mat-
erials which are
non-putresible,
having a low per-
meability to water,
good compacts-
bility, cohesiveness,
and relatively
uniform texture
Floodplain
Restrictions
Yes - Protect from
1 00-yr flood by levees
20-yr rainfall design;
dikes to protect facility
from 1 00-yr flood
Cannot be located in
1 00-yr floodplam
Discouraged but not
specifically prohibited
Yes
Yes
Prohibited unless
protected from
flooding
Cannot restrict 1 00-yr
flood/reduce
temporary water
storage capacity
Prohibited in a
regulatory floodplain
except by means of a
waiver granted by
Ohio EPA director
1 00-year flood
Facility cannot restrict
flow of base flood, etc.
Buffer Zones/
Nearest Dwelling/
Distance to Wells
50 ft to property line; 2 mi
to jet airport; 1 mi to
propeller airport
50 ft from property line;
greater - case-by-case
Distance to roads- 100 ft
No occupied building
within 500 ft
Nearest dwelling:
- 1/4 mile Class I
- 1/2 mile Class II
- 3/4 mile Class III
Private well or nearest
dwelling: 300 ft
Community wells: 500 ft
Municipal well: 1000 ft
Property line: 50 ft
Public road: 100ft
Yes
10,000 ft to jet airport
5,000 ft to piston airport
10,000 ft from airport
50 ft from property line
500 ft from private wells
500 ft from nearest dwelling
1 ,000 ft from a water well in
existence on the date the
plans were received by the
Ohio EPA except by means
of a waiver granted by Ohio
EPA director
Case-by-case for nearest
dwelling
250 ft to private wells
660 ft to public wells
500 ft to nearest dwelling
200 ft to wells
173
-------
Table E5-2. Landfilling - Site Specific Considerations (continued)
State
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
Distance to
Surface Water
1 00 ft to streams
Case-by-case
determination
200 ft and not in a
water supply
watershed
500ft
100ft
Yes
1 ,000 ft to a lake
300 ft to a river
500 ft including
wells and other
sources of drinking
water
Depth to
Ground Water
8 ft beneath liner
system
4 ft to highest water
table or liner
Yes
10 ft from level of
landfill to seasonal
high water table
5 ft to maximum
seasonal water table
4 ft "generally"
Soil Type
Yes
Case-by-case
Yes
Soil sampling:
Cd, Cu, Pb, Se, Zn,
Cr, N, Fe, Mn
Yes
Yes
Determine
loading
Maybe
Yes;
case-by-case
Floodplain
Restrictions
1 00-year flood
Designed, constructed
to prevent washout;
diversion structure
100-yr floodplain
Cannot be in a 1 00-yr
floodplain
Not subject to flooding
Not in 1 00-year
floodplain
Cannot be in a
floodplain
Prohibited
Yes
Prohibited
Prohibited on
floodplain
Buffer Zones/
Nearest Dwelling/
Distance to Wells
1/4 mi upgradient, 300 ft
downgradient to surface
water
Case-by-case distance to
well determination
1,000 ft to wells
400 ft to any non-site
building
200 ft from property
line to landfill
1,000 ft to wells
Minimum 300 ft to
property line
200 ft to nearest dwelling
500 ft to wells
1000 ft
"Adequate"
Private property - 100 ft
Highway or park - 1 ,000 ft
Airport - 10,000 ft
Wells - 1 ,200 ft
500 ft from wells and other
drinking water supplied
174
-------
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176
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•actices (continued)
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178
-------
Table E5-4. Landfilling - Monitoring and Reporting
State
Alabama
Alaska
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Reporting
Requirements
Yes
Yes
Verification monitoring
program. Records on
volume and type of
waste received.
Sludge considered
"specific waste"
Needs some special
handling/reporting
Quarterly water
quality data
Quarterly reports
Yes, specified in
sludge management
plan
Semi-annual report
Yes
Sludge considered
"special waste;" has
special
handling/reporting
Source of sludge, site
background, etc.
Yes
Yes
Ground Water
Monitoring
Yes
4 wells per permit
Monitor:
water elevation,
temperature,
electrical
conductance, pH
Wells
Yes - various factors
required for new sites
pre-development
Wells or other
monitoring devices
may be required on
case-by-case basis;
not normally required
if applied at
agronomic rate
Conductivity, nitrates,
COD, others as
appropriate
Yes
May be required
Case-by-case
depending on
hydrogeologic data
Minimum 4 wells per
site
Yes
Annual samples
1 well upgradient and
2 wells downgradient
Surface Water
Monitoring
Per permit
Required in waste
management units
(Class II)
Yes
May be required
Case-by-case
depending on
hydrogeologic data
Yes
Sludge Quality
Monitoring
Yes
Chemical analysis
required for hazard
classification
Yes
For hazard classification
Nutrients, metals
Yes - E.P. toxicity
Site Development
and Closure Plans
Yes - Development
and Closure
Yes - Development
Design report and
operations plan
Closure and post-
closure plan (if
necessary)
Show facility design
and background
conditions
Must analyze soil type
and GW flow
Completed fill: mm.
2% slope
Yes - Development
and closure
Site development
operational plan and
closure plan required
Yes - Development
Yes - Development
and closure
For construction
(development)
Site development plan
Development:
geological input, soils,
zoning laws, storage
capacity.
Closure: vegetation
Development and
closure plans
179
-------
Table E5-4. Landfilling - Monitoring and Reporting (continued)
State
Maine
Maryland
Massachusetts
Michigan
Mississippi
Missouri
Montana
Nevada
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oklahoma
Reporting
Requirements
Maintain operations
manual
Quantity per month,
% capacity used,
projected date to
reach capacity
Yes
Burial site must meet
sanitary landfill
requirements
Upon request
Disposal rate (vol)
and percent solids;
quarterly reporting
Name, volume,
source, analysis,
method, del/mixing
Yes
As specified
Daily log of operations
Daily log of operation
and waste received
submitted monthly
Ground Water
Monitoring
Minimum of 3
sample points
Proposed program
Case-by-case basis
Hydrogeological study
as part of
application process
Quarterly monitoring
Yes, site-specific
Propose in plan
Case-by-case
May be required
Yes
Minimum of 4 wells:
3 downgradient;
1 upgradient
Depending on facility
characteristics
Hydrogeologic study,
well installation, and
monitoring are
required.
1 well upstream
2 wells downstream
in GW formation
Surface Water
Monitoring
Minimum of 2 sample
points
Proposed program
To assess adequacy
of leachate and
runoff control
NPDES permit and
monitoring stormwater
and leachate
Case-by-case
May be required
Yes
Establish baseline
conditions and
monitor if facility leaks
Yes, depending on
facility characteristics
Case-by-case
Yes
Sludge Quality
Monitoring
As needed. Also pre-
application (% solids,
pH, N, ammonia,
nitrate, metals, PCB,
etc.) Before acceptance
(dry weight cone, or %
as APPR)
Comply with 40 CFR
257 site specific
monitoring
Initial: solids, nutrients,
metals, other toxics
Follow-up: based on
quality, use
> 1 mgd: 3 times/yr
< 1 mgd: 1 time/yr
for metals, solids, pH, N
Yes
EP toxicity test
Verify that it is non-
hazardous
Site-specific
Case-by-case
Prefer weights of dry
solids, volume is
acceptable
Site Development
and Closure Plans
Development plan
Closure within 60
days after active use
ends
Development plan -
description and
operating plan
Development plan
Closure: special burial
and terminate sludge
application when
heavy metals = 0.5
max. LVL
Development plan
Closure plan
Development plans
required, no
closure plans
Development plan
Development:
provisions for winter
storage required
Yes
Operating plan
Closure plan
Development plan
Closure plan: not as
such, closure
procedures specified
Development plan:
operational pro-
cedures and detailed
plans are required as
part of landfill permit
Closure plan: required
as part of landfill
permit to install
application
Development plan
Closure plan
180
-------
Table E5-4. Landfilling - Monitoring and Reporting (continued)
State
Oregon
Rhode Island
South Carolina
Tennessee
Texas
Utah
Vermont
Virginia
Virgin Islands
Washington
West Virginia
Wisconsin
Wyoming
Reporting
Requirements
Co-disposal approval
required
Yes
Yes
Periodic
Monitoring
recommended
Volume disposed of at
solid waste facility
Volume disposed of at
solid waste facility
Ground-Water
Monitoring
May be required
Yes - number of
monitoring wells
approved by director
Yes
Yes
Annual: Na, Cl, Fe,
Mn, SO4, phenol
Monitoring wells
required on all sites
Sampling: 4 times/yr
Yes, for landfill
Plan for GW and for
pollution control
To be established
May be required
Yes
Case-by-case
Surface-Water
Monitoring
May be required
Yes
Case-by-case
May be required
Sludge Quality
Monitoring
Comply with
40 CFR 257
Semi-annual sampling:
Cd, Cu, Pb, Se, Zn, N
% solids, pH, nutrients,
heavy metals
Yes
Must be demonstrated
non -hazardous and non-
mfectious
Yes
Site Development and
Closure Plans
Closure permit
including plan/financial
assurances, etc.
Site development and
operating plan
Closure plan:
monitoring/funding
Site development plan
Master plan for site
and area
Site development plan
Closure plan
Approved sanitary
landfill
Site development plan
Closure plan
Approved sanitary
landfill
Yes and closure
Closure plan
Site development plan
181
-------
Table E5-5. Land!illing - Other State Management Practice Requirements
State
Alabama
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Mississippi
Missouri
New Hampshire
New York
North Carolina
Oklahoma
Rhode Island
Vermont
Virginia
Washington
Management Practice
Other - RCRA Standards
Landfill Note: Cannot be disposed of in Class 3 or 4 permitted landfill without prior approval
Types of Landfills - Class 1: Liquid and Solid Hazardous Waste
Types of Landfills - Class II: Undewatered sludge (land treatment units)
Types of Landfills - Class III: Dewatered sludge and acceptable incinerator ash
No co-disposal without county approval
Leachate Testing - Analysis required
Compaction - Solid waste must be spread and compacted in layers not exceeding 2 ft depths
Leachate Testing - Implied; Zoning Conformance - Yes
Other - Soil geology analysis and hydrologic analysis
Plant sampling/crop: case-by-case
Soil sampling/ monitoring: case-by-case specified in management plan
Compaction - Maximum 2 ft depth
Note - 40 CFR Part 257 Regulations
Operation prohibited unless permit issued specifically for sludge
Record keeping - amount of waste disposal; Leachate Testing - Yes
Air Monitoring - Daily checks for odors, monthly checks for amines, chlorinated hydrocarbons
Leachate Testing - Monitoring wells measure effect of control system used
Other - handling site 1 000 •*• ft away from airport runways
Equipment - Must be able to handle sludge
Note - Satisfy all conditions of COMAR 10.17.1 1
Odor Control - Not excessive or persistant
Permits - Operate in compliance with valid refuse disposal permits
Co-disposal regs. Monofill guidelines. Double liner required
Deed record - Use as a landfill
Deed Record - Record of contents and need for continued maintenance
Application rate - one-time application not to exceed 20 tons/acre for reclamation.
Codisposal - 4:1 ratio refuse to sludge; not < 3:1
Lift height 1 0 ft maximum
Record keeping, deed recording, and routine sludge analysis
Compacting - layers not to exceed 2 ft after compaction
Co-disposal - Approval required
Preferred Method - By shallow trench; Watershed Limits - No landfill allowed in Class A watershed
Loading limits - 1 :6 sludge to solid waste ratio, other - solid waste management regulations
Loading Limits - 1 :4 to 1 :5 sludge:sohd waste ratio; moisture < 40%
182
-------
Table E5-5. Landfllling - Other State Management Practice Requirements (continued)
State
West Virginia
Wisconsin
Wyoming
Management Practice
Design/construction/OPR-EPA's process design manual - municipal sludge landfills
Loading limits - sludge < 30% of waste landfilled, unless it is a dedicated landfill
Standards - 40 CFR 257
Leachate Testing - Yes
No landfills in wetlands, critical habitat
Fire Protection - Fire lanes and other forms of fire protection
183
-------
Table E5-6. Landfllllng - Sludges Containing Radionuclldes
Sludge Quality
< 2 pCi/g
< 5 pCi/g
> 2 and s 50 pCi/g
> 5 and < 50 pCi/g
> 50 pCi/g
Illinois
226Ra and 228Ra Combined
May be disposed of at lEPA-permitted landfill
Sludge disposed of in isolated area
lEPA-permitted landfill
1 0 ft uncontaminated cover
Radon gas protection
Extra precautions;
IONS approval
Wisconsin
226Ra Only
May be disposed of at WDNS - licensed landfill
-
Sludge disposed of in isolated area
Sanitary landfill requires approval of WONR and
WDHSS and leachate collection
1 0 ft uncontaminated cover
Radon gas protection
Mix waste and sludge to < 5 pCi/g
Case-by-case
184
-------
Table E6-1. Land Application - State Multi-Grade Sludge Contaminant Concentration Limits
Region
2
7
2
7
5
7
7
8
1
7
3
3
1
10
5
1
1
7
1
2
8
3
9
8
3
10
1
3
4
2
5
7
1
1
1
2
2
3
3
1
7
State
NJ
MO
NJ
IA
Ml
MO
MO
WY
MA
MO
VA
WV
MA
WA
Ml
ME
NH
IA
Rl
NJ
SD
VA
CA
CO
MD
OR
VT
WV
FL
NJ
Ml
IA
MA
ME
NH
NJ
NY
PA
VA
VT
MO
Contaminant
Aldnn
Aluminum
Arsenic
Beryllium
Boron
Cadmium
Median
Mode
Chlordane
Chromium
Median
Mode
Cobalt
Contaminant Limit (mg/kg)
Grade 1 Sludge
0.1
20,000
10
50
<100
450
450
1.25
<300
500
100
100
<2
2
<5
10
10
15
15
20
20
20
25
25
25
25
25
25
30
20
25
0.10
<50
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
250
Grade 2 Sludge
0.1
-
10
-
100-2000
-
.
<300
-
-
<25
.
5-125
-
-
-
-
-
-
-
.
70
.
-
-
100
65
N/A
010
50-5000
-
1,000
-
-
1,000
-
1,000
1,000
Grade 3 Sludge
0.1
10
-
>2000
-
-
>300
.
-
-
>25
>125
-
-
-
-
-
125
-
-
100
113
125
> 5,000
-
1,000
-
-
-
-
-
-
-
1,000
N/A
-
Grade 4 Sludge
.
-
-
-
-
_
-
.
-
-
.
-
-
-
.
-
-
-
-
-
-
-
-
.
-
-
-
-
-
-
-
-
-
-
185
-------
Table E6-1. Land Application - State Multi-Grade Sludge Contaminant Concentration Limits (continued)
Region
5
2
8
8
10
4
7
1
3
1
1
2
3
1
3
1
3
2
7
2
7
2
2
1
5
1
g
1
1
8
4
7
3
2
10
3
8
6
8
3
3
1
3
2
2
7
7
State
Ml
NJ
CO
UT
OR
FL
IA
MA
MD
ME
NH
NY
PA
Rl
VA
VT
WV
NJ
MO
NJ
MO
NJ
NJ
Rl
Ml
MA
CA
ME
NH
CO
FL
IA
MD
NY
OR
PA
SD
TX
UT
TX
VA
VT
WV
NJ
NJ
MO
MO
Contaminant
Copper
Median
Mode
Dieldnn
Dioxin
Endrin
Fluoride
Heptachlor
Heptachlor Epoxide
Lead
Median
Mode
Lindane
Lithium
Manganese
Contaminant Limit (mg/kg)
Grade 1 Sludge
<250
600
625
625
800
900
,000
,000
,000
,000
,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
0.10
0.001
0.10
4,000
0.10
0.10
5
<250
300
500
700
700
1,000
< 1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
1,000
2,400
1,000
1,000
0.10
500
2,500
Grade 2 Sludge
250-2000
1,200
1,650
1,650
.
3,000
-
1,000
.
-
-
-
-
-
.
-
-
1,425
1,650
0.10
-
0.10
-
0.10
0.10
_
250-2000
1,000
-
-
-
2,500
1,500
-
-
-
-
.
-
-
2,500
-
-
4,800
2,000
2,500
0.10
-
-
Grade 3 Sludge
> 2,000
.
3,125
3,125
.
3,000
-
1,000
.
.
-
-
.
-
-
-
3,000
3,125
-
-
-
-
-
_
> 2,000
1,000
-
-
5,000
> 1,500
-
-
-
-
-
-
-
5,000
-
-
-
-
-
2,000
5,000
-
-
-
Grade 4 Sludge
_
-
-
-
-
-
-
-
_
-
-
-
-
.
-
-
-
-
.
-
.
-
-
-
-
-
-
-
-
-
-
-
186
-------
Table E6-1. Land Application - State Multi-Grade Sludge Contaminant Concentration Limits (continued)
Region
5
1
7
1
3
1
1
2
2
3
8
3
1
3
7
2
2
1
5
3
7
5
4
10
7
1
3
1
1
2
3
1
3
1
3
8
8
2
7
2
2
2
7
2
State
Ml
Rl
IA
MA
MD
ME
NH
NJ
NY
PA
SD
VA
VT
WV
MO
NJ
NJ
MA
Ml
VA
MO
Ml
FL
OR
IA
MA
MD
ME
NH
NY
PA
Rl
VA
VT
WV
CO
UT
NJ
MO
NJ
NJ
NJ
MO
NJ
Contaminant
Mercury
Median
Mode
Methoxychlor
Mirex
Molybdenum
Median
Mode
Nickel
Median
Mode
Organics
P, Pi-DDE
P, P'-DDT
P, P'-TDE (ODD)
Pesticides
Phenols
Contaminant Limit (mg/kg)
Grade 1 Sludge
<2
5
10
10
10
10
10
10
10
10
10
10
10
15
500
10
10
0.25
0.25
10
<10
20
40
20
10
<25
100
100
200
200
200
200
200
200
200
200
200
200
200
250
250
625
200
200
1
0.25
0.25
0.25
10
22
Grade 2 Sludge
2-10
-
-
10
-
-
-
10
-
.
.
-
.
-
-
10
10
025
0.25
10
10-50
-
20
N/A
25-1000
500
-
200
-
-
-
-
-
.
-
.
-
650
650
1,250
500
200/650
-
0.25
0.25
0.25
-
22
Grade 3 Sludge
>10
-
-
10
-
.
-
-
.
-
-
-
10
10
-
-
10
>50
-
-
30
N/A
> 1,000
500
-
-
200
-
-
-
-
-
-
-
-
1,250
1,250
-
750
1,250
-
-
-
-
-
-
Grade 4 Sludge
-
-
-
-
-
-
-
.
.
-
-
.
-
-
-
-
-
-
-
.
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
.
-
-
-
-
-
-
187
-------
Table E6-1. Land Application - State Multi-Grade Sludge Contaminant Concentration Limits (continued)
Region
8
5
5
7
2
5
3
1
6
3
9
a
8
10
5
4
3
1
7
4
1
2
6
1
8
5
4
5
2
1
5
2
8
8
4
7
1
10
1
3
1
3
2
3
1
3
State
WY
IL
Ml
MO
NJ
Ml
VA
MA
TX
PA
CA
CO
UT
AK
IN
KY
MD
ME
MO
MS
NH
NY
OK
Rl
SD
MN
SC
Wl
NJ
NH
Ml
NJ
CO
UT
FL
IA
ME
OR
Rl
VA
MA
MD
NY
PA
VT
WV
Contaminant
Selenium
Median
Mode
Total PCBs
Median
Mode
Toxaphene
Zinc
Median
Mode
Contaminant Limit (mg/kg)
Grade 1 Sludge
0.2
4
10
80
7
None
0.5
<1
1
2
2
3
5
5
5
10
10
10
10
10
10
10
10
10
10
10
10
50
50
50
10
10
1
200
<750
1,200
1,250
1,250
1,800
2,000
2,000
2,000
2,000
2,000
2,500
2,500
2,500
2,500
2,500
2,500
2,000
2,500
Grade 2 Sludge
_
-
10-80
-
0.5
1-10
-
-
-
.
.
10
10
.
-
-
-
-
-
-
.
-
-
-
-
-
-
-
10
10
1
.
750-5,000
2,400
3,325
3,325
10,000
-
-
.
-
2,500
-
.
-
2,875
3,325
Grade 3 Sludge
.
-
>80
-
_
>10
-
-
-
.
-
10
10
-
-
-
-
-
-
-
-
.
-
.
-
.
10
10
-
.
> 5,000
-
6,250
6,250
10,000
-
-
-
-
-
2,500
-
-
.
-
-
5,625
6,250
Grade 4 Sludge
_
.
-
.
-
-
.
.
-
-
.
-
-
-
-
-
-
-
.
-
.
-
-
-
_
> 5,000
-
-
-
-
-
-
-
-
-
188
-------
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-------
Table E6-4. Land Application • Monitoring and Reporting
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Delaware
Florida
Georgia
Idaho
Illinois
Sludge
Monitoring
Analysis must be
done 1 mo prior to
application - most
contaminants
Yes - preapplication
Cd, Pb, Zn, Cu, Ni,
PCB, Total N,
solids. Frequency
dependent on size of
treatment plant.
Total N, organic N,
NH4, NO3, pH, K,
conductivity, As, Al,
Cd, Cr, etc.
Every 3-12 mo
depending on facility
size - metals, solids,
nutrients
Annually for pH, %
vol. in solids, Pb, Cd
PCB, P, Cd, Cu, Ni,
Zn
% solids, vol. solids
and acids, various
metals initially then
plant size determines
frequency (monthly-
annual)
Reporting
Requirements
Monthly report of
record of applications
at each site (quality
and quantity)
Analyses, operating
record
Monitoring results
every 6 mo. Amount
applied and
locations.
Annual reports;
Analysis must be
submitted quarterly
Record keeping -
amount applied,
when, etc.
Amount applied,
changes in water
quality, use of
harvested crops
Monthly to annual
reports depending
on plant size
Plant
Sampling/Crop
Monitoring
Plant tissue
monitoring
Biennially for
metals
May be
required
Soil Sampling/
Monitoring
Fields sampled prior
to application
Preapplication and
annual monitoring
Yes
CEC = 5-15;soil
pH>6.5 or use lime;
test before appl. and
6 mo and 1 yr after
Ground
Water
Monitoring
Yes
Per permit
If sludge applied
less than 40 ft to
ground water,
wells in the
vicinity of the
fields are sam-
pled at 6-mo
intervals for
metals, total
coliform and
nitrates. Not
required if sludge
applied in
accordance with
sludge
guidelines.
Identify annual
high ground
water level;
monitor if level
< 10 ft below
ground
Monitoring wells
or other devices
must be installed
as required by
permit
Depth to water
table
Dedicated sites
Baseline and
during project life
- N, metals,
organics, pH,
fecal coliform
May be required
Surface
Water
Monitoring
Per permit
If there are water
quality standards
violations
Case -by-case
Baseline and
during project life
- N, metals,
organics, pH,
fecal coliform
204
-------
Table E6-4. Land Application - Monitoring and Reporting (continued)
State
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massa-
chusetts
Michigan
Sludge
Monitoring
% solids, NH4, NO3,
Total N, P, K, Pb,
Zn, Cu, Cd, Ni,
PCBs
N, P, K, As, Cd, Cr,
Cu, Hg, Ni, Pb, Zn
Cd, Cu, Pb, Ni. Zn,
Cr, As, Se, P
POTW<1 mgd -
1x/yr
POTW>1 and <2
mgd - 2x/yr
POTW>2and <10
mgd - 4x/yr
POTW>iOmgd-
ix/mo
Semiannual, pH,
CEC, N, salts,
organic matter,
sludge/soil mix
Nutrients, metals,
micronutrients,
others (N) initial
Quarterly dioxin
testing during first
year for POTWs
> 25 mgd. POTWs
required to enact
individual pretreat-
ment program,
POTWs containing
pulp, paper, tannery,
textile-related addns
to wastewater inputs
As needed. Also
preapplication (%
solids), pH, N,
ammonia, nitrate,
metals, PCS, etc.
1 -6 mo intervals
Nutrients, pH, %
solids, metals,
PCBs, based on
industrial input,
within 2500 ft Of
water supply,
monitoring for
organics required
Initial: solids,
nutrients, metals,
other toxics
Follow-up based on
quality, use
Reporting
Requirements
Annual report of
weekly application
rates and site
conditions
Long-range plan
required
Deed record -
regarding Cd
application
Annual report of all
records
Annual (test results),
land area, etc.
Monthly, quarterly, or
yearly. Analysis, lime
additions,
distribution, etc.
Amount, where
applied, amount of
lime. As required.
Annual, not for Type
I sludge, also deed
notice - Type II and
III sludge/septage
Monthly - by
municipality; sludge
quality, amount,
application rate,
fertilizer required
Plant
Sampling/Crop
Monitoring
Analysis of
plant tissue
maybe
required for
some sites
Generally not
required
Soil Sampling/
Monitoring
Pre-application,
annual if pH < 6.5
Annual monitoring
Analysis for
background level of
Cd, Cr, Pb, Hg, Ni,
Zn. Standard soil
test before each
application
Yes - P, Cd, Cr, Cu,
Pb, Ni, Hg, Zn, PCB
Annually
Ground
Water
Monitoring
May be required
Geological data
assessed;
specific
parameters
measured
As required
Depth may
require
monitoring
No - but
hydrological
study may be
required
Surface
Water
Monitoring
Yes
25 ft to property
lines and public
roads
As required
Not under
normal
circumstances
205
-------
Table E6-4. Land Application - Monitoring and Reporting (continued)
State
Minnesota
Mississippi
Missouri
Nebraska
Nevada
New
Hampshire
New Jersey
New Mexico
New York
North
Carolina
Sludge
Monitoring
Annually, based on
facility size.
Metals, PCBs,
nutrients, solids.
PCB more frequent
Yes - when Cd not
the mam
contaminant
Sludge and soil
characteristics, and
volume applied
Solids, N, P, metals,
Zn, Cd, Ni, Cu, Cr,
etc.. Report to
application for major
facilities
Nutrients, VOC's, %
solids, pH, metals
> 1 mgd 3 x/yr
< 1 mgd 1x/yr
Yes
Cd, Cu, Pb, Ni, Zn,
Cr, Hg, benzene,
PCB, nitrogen
series, K, P, pH, tot.
solids, tot. volatile
solids
Solids, metals, N, P,
K, pH, EP, toxicrty
and vol. for new &
renewable applic.
Reporting
Requirements
Annual report on
amounts of Cd, Zn,
Pb, Ni, Cu, N.
Composition, soil
test, location,
amount, N appl.
limits, vegetation
grown.
Permanent record of
volume (rate) and
location.
Tissue monitoring of
vegetation.
Deed record -
amount of PCBs and
Cd applied.
Daily records: %
solids, volume,
location.
Annual report
Annually at minimum
for major facilities
Case-by-case
Yes
Ground water
discharge plan
required
Annual report;
sludge soil quality
data, crop grown,
loading rate
Monthly for vol.,
metals, and nutrients
Plant
Sampling/Crop
Monitoring
Dedicated sites
No
Case-by-case
Yes
Soil Sampling/
Monitoring
Texture, organic
matter, P, K, pH, soil
conductivity to be
done before each
season.
Halt appl. if soil
conductivity > 4
millimhos/cm by
soluble salt test.
Annual soil sampling
for metals, nutrients
pH, CEC prior to
application and
every 4-5 yr.
Nutrients - annual
unless > 2 t/yr.
Yes, for some
facilities, mainly for
nitrates
Yes; pH, lime,
organics
Yes
N, K, P, Ph, Cd, Cu,
Cr, Hg, Ni, Pb, Zn
Prior to application
for pH & CEC
Ground
Water
Monitoring
Mm. of 6 wells.
Semiannual
sampling unless
facility meets all
requirements for
landspreadmg
sites
As required
Dedicated sites
Yes, but only
one facility
May be required
Where repeated
applications
made
As required
In some cases
As required
Surface
Water
Monitoring
At discretion of
director
Only regulated in
some cases
May be required
Yes
As required
In some cases
206
-------
Table E6-4. Land Application • Monitoring and Reporting (continued)
State
Ohio
Oregon
Rhode Island
South
Carolina
South Dakota
Tennessee
Texas
Vermont
Sludge
Monitoring
Yes
Pb, Zn, Cu, Ni, Cd,
N (total, N03, NH3),
P, K, pH, solids.
Frequency
dependent on plant
EP toxicity and
metals (annually)
Most contaminants
monitored and
annual EP toxicity
test done. Must be
non-hazardous
Annual monitoring of
% solids Ph, N,
NH3, N03, Zn, Cu,
Ni, Pb, Cd, Hg, Cr,
PCBs, Se, Mg, Fe,
persistent organics
(pesticides)
pH, solids, N, P, K,
Cu, Zn, Pb, Ni
Cd, Cu, Pb, Ni, Zn,
N, K, PCB
Requires analysis for
% solids, pH, nu-
trients, and heavy
metals. PCB testing
for proposed land
application uses; re-
quires certification of
sludge management
- includes public
participation in
application process.
Reporting
Requirements
Sludge, soil and GW
& SW runoff may be
required on case-by-
case basis, plant
analysis not
generally required
when acceptable
sludge is applied at
agronomic rates;
rates applied; water
quality, total applied.
Quantity and type -
monthly
DMR rules require
periodic sampling of
sludge quality
Periodic review
Annual: sludge/soil
monitoring data,
application data
Plant
Sampling/Crop
Monitoring
Not generally
required for
acceptable
sludge applied
at agronomic
rates
None
Soil Sampling/
Monitoring
pH, CEC, metals,
etc.
Initial and follow-up
depending on sludge
quality
Type & pH
before application;
stop application if
sol. salts > 4
millimhos/cm
Test for N, pH (6.5-
7.5) metals.
Monitoring - yes.
Ground
Water
Monitoring
Yes
Case-by-case.
Test wells where
sludge applied in
excess of agro-
nomic rates or
where high
ground-water
tables are sus-
pected annually
to assume
sludge siting cri-
teria can be met
at the time of
sludge land
application
Yes, as required
One upstream
and two
downstream
wells
Case-by-case
May be required
Especially at
long-term sites;
sampling spring
and fall
Surface
Water
Monitoring
Yes
Yes - continuous
Yes
Case-by-case
May be required
207
-------
Table E6-4. Land Application - Monitoring and Reporting (continued)
State
Virginia
Washington
West Virgina
Wisconsin
Wyoming
Sludge
Monitoring
Composition
analysis done based
on the size
N, metals
At least annually
Nearly everything
monitored; see
contaminants (or can
be required)
Reporting
Requirements
Monthly, quarterly, or
annually, depends on
size
N, Cd, Cu, Ni, Pb,
Zn: Ib/ac
Plant
Sampling/Crop
Monitoring
Yes, for annual
application
Soil Sampling/
Monitoring
pH, metals, CEC,
texture, etc.
As needed before
application and
every 3 years at
site, for N, Ph, P, K,
CEC
Ground
Water
Monitoring
Yes
As needed
Yes
Surface
Water
Monitoring
Yes, for annual
application and
storage lagoon
208
-------
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216
-------
Table E6-6. Land Application • Other State Management Practice Requirements
State
Alabama
Alaska
Florida
Illinois
Indiana
Kentucky
Louisiana
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Management Practice
Reference to Part 257
Cover - Immediate
Technical Criteria/Compost -
Disposal, Chapter 12
Site monitoring -
EPA-625/1 -79-01 1 , Process Design Manual for Sludge Treatment and
adopted by reference. Some difference in grades 1 and 2 required.
sites < 5 yrs & with sludge with minimal industrial waste loads
Storage - Minimum 90-day capacity
Registration
Deed record - Re: cadmium application
- Registered landfarming facilities, operator's certification
QC System - Conformance of incoming waste with permit
Other - 200 ft distance to drinking water
Truck washing
Sludge Classification: I - can be used sold, distributed without approval; II - can be used, sold, distributed only
with prior department approval; III - same as II but cannot be used to grow food chain crop
Sound Agricultural Practice - For example, avoid soil compaction
Storage - Field storage must be less than 7 days unless covered and provided with seepage barrier
Facility Design Criteria - Yes
Siting operational criteria - yes
217
-------
Table E6-6. Land Application - Other State Management Practice Requirements (continued)
State
Missouri
Montana
Nebraska
New York
Ohio
Rhode Island
South Carolina
South Dakota
Tennessee
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Management Practice
Reference to Part 257 and State exceptions for remote sites and restricted access in lieu of PSRP
Reduced requirements for rates < 2 dry t/yr
Dedicated sites not recommended but considered
Other - septage regs only
Notify state and complete questionnaire
Sound agronomic practice, specific calculation methods
Storage facilities - 6 mo mm. if used
Compost Exemption - Class 1 Composted sludge does not require site inspection/authorization, Class II
composted sludge may require site inspection/authorization
Contract - permitted, sludge permit issued to treatment plant owner
Land owned/leased/contracted/used by generator for disposal
Odor Control - Per air and H.M. APC Reg. 17
Geologic Evaluation - Application
Sludge qualification - must be nonhazardous
Dedicated sites not recommended but will be considered
Equipment - vehicles should have deflection plates
Soluble salt - stop appl. if >4 millimhos per cm
Dedicated sites -may not apply as to approval - case-by-case
Contract between entity and hauler/user
Watershed restriction - Class A watershed - land application not allowed
Sludge Classification: Class A - stabilized only, max application 1 5 dt/ac, must be classified as nonhazardous,
storage 60 days, uniform application, approval of sludge management plans and O&M for storage, others - VA
sewage regulations; or Class B - raw, partially stabilized; only A suitable
Odor Control - As needed
Equipment - Use high flotation tires
Odor Control - Yes
218
-------
Table E6-7. Land Application - State Prohibitions
State
Alaska
Arkansas
Connecticut
Delaware
Florida
Kentucky
Maine
Maryland
Massachusetts
Minnesota
Mississippi
Missouri
New Hampshire
New Jersey
New York
Oklahoma
Oregon
Rhode Island
Texas
Utah
West Virginia
Wisconsin
Prohibition
Permafrost problem
Prohibited on produce crops, home gardens, recreations areas, "etc."
No home garden use of sludge products
No application to tobacco crop lands
No use where human contact possible, buffer 200 ft
No raw sludge application.
Not on slopes > 12%
Not over "significant aquifers" without variance
No sewage on tobacco
Must not apply Type II or III sludge unless in compliance, no Type III for food chain crop
Prohibited on land, good nghts-of-way, wetlands, etc.
No raw sludge application
Not recommended for gardens or vegetable crops.
One year restricted access for grazing lactacting dairy cows
Application to dairy land not recommended. Raw sludge not recommended on vegetable/root crops.
Sludge may not be applied to wetlands
Not allowed on food crops for direct human consumption
Storage at site not permitted
Land application of sludge to fruits/vegetables prohibited. Some land application of raw and
septage occurs on both silvicultural and pasture sites which are managed according to site-
specific criteria authorization & letter from DEQ.
lime stabilized
and product-
Not allowed on human food crops
May not apply without registering the site
Raw sludge not permitted unless specifically authorized
Raw septage not allowed
No raw sludge, no landspread in wetlands or areas subject to flooding
219
-------
Table E6-8. Land Reclamation - Management Practices
State
Management Practice
Arkansas
Sludge Monitoring - Pre-application
Soils Analysis - Pnor to application and annually
Site Development Plan - Waste management plan
Access Control - Public 1 year, fence/signs, no human contact for 30 days
Crop Use Limits - No food chain for 1 year, no use on home gardens/vegetables
California
Incorporation - 48 hr
Sludge Stabilization - Yes
Access Control -12 mo
Loading Limits - Metals, pathogens if might be used for food chain crops, same as land application
Delaware
Cover - Not less than 30% revegetation
Crop use limits - No harvest for food chain 2 yrs
Incorporation - 24 hrs
Seasonal limits - Snow, frozen or saturated land, no application
Oct 15 - April 15 unless cover crop is established
Soil testing for agricultural land
Florida
Distance to Surface Water - 500 ft
Slope/Grade - Yes
Mining Law - Must be in compliance if applicable
Revegetate Area - Must plant turf, grow grass after 3 mo cessation
Nearest Dwelling - 500 ft
Access Control - Yes
Surface Water Monitoring - if violations
Runoff Control - Yes
Loading Limits - 30 dry t/ac/yr, lifetime metal accumulation Ilimit = 10% for 2 yr
Crop Use Limits - no human food chain
Idaho
Similar to land application rates, case-by-case, consider future land loading
Illinois
Reporting Requirements - Annual Operating Report - Amount, use of crops, analysis
Buffer Zones - Yes
Mining Law Compliance - Yes
Plant Tissue Monitoring - Applicant propose
Soil Monitoring - Applicant propose
Site Development Plan - Site characteristics
Nearest Dwelling - Yes
Surface Water Monitoring - Applicant propose
Ground-water Monitoring - Applicant propose
Loading Limits - N, metals, propose in application
Maryland
Erosion - Sediment erosion control provisions are required
Sludge Monitoring - As required, sludge analysis - for application for permit (same as land application, e.g., as
needed and pre-application for percent solids, pH, N, ammonia, nitrate, metals, PCB, "etc."
Loading Rate - > 50 t/ac may be allowed
Incorporation - Unless PFRP and approved
Even spreading, marked areas, truck cleaning
Record Keeping - Yes
pH Levels - Adjustment to 6.5 if <6.5
Site Development Plan - Operational
Access Control - 12 mo unless PFRP
Surface Water Monitoring - As required
Ground Water Monitoring - As required
Loading Rates - Sludge: 50 dry t/ac; metals: same as land application (e.g., Cd, Cu, Ni, Pb, Zn, N - agronomic
rate, Ib/ac depends on CEC, N or metals lesser)
Crop Use Limits -1 mo: grazing animal for human use unless PFRP; 3 yr: direct human consumption crops
New Hampshire
Slope/Grade - Max. 8%
Reporting Requirement - State approval regulations
Runoff Control - Vegetative cover at time of application required unless incorporate
Loading Limits - Max. 15 dry t/ac/yr
Seasonal Limits - No application when the ground is frozen or snow-covered, or during wet periods
Crop Use Limits - Cannot be used for feed/grain for human consumption for 2 yr after application
New Jersey
No NJPDES permit if compost used (site info sheet/approval letter)
Soil Monitoring - Every 4 yr if sludge (not compost) is used
Loading Rate can be > nutrient requirements of proposed vegetation (case-by-case)
220
-------
Table E6-8. Land Reclamation - Management Practices (continued)
State
North Carolina
Pennsylvania
South Carolina
Texas
Washington
Management Practice
Loading rates - 50 dry tons/acre, cumulative metals or same as land application and is CEC-dependent, soil
pH is maintained at 6.5 and limited to one-time application
Sludge Monitoring - Moisture, N, P, K, BOD, pH, Cyanide, Na, metals, toxics, pathogens
Distance to Surface Water - 100 ft, 300 ft for water supplies
Distance to Bedrock Outcrops - 25 ft
Distance to Property Line - 50 ft
Incorporation - 24 hr
Pollution Control - No ground-water/surface water pollution
Site Development Plan - Revegetation plan
Nearest Dwelling 300 ft
Surface Water Monitoring - May be required
Ground Water Monitoring - May be required
Soil Type - pH adjusted to 6.5 by second year, maintain for 2 yr after application
Loading Limits - Metals (DER guidelines), 60 dry t/ac and 1 in/wk, prevent ponding
Seasonal Limits - No application in rain, snow, frozen, or saturated periods
Sludge application only once, site suitability investigated
Access control - yes: application methods - specified for liquid vs. dewatered
Buffer zone - 200 ft to site boundary: crop use limits - no human food chain unless approved:
Ground-water Monitoring - Unsaturated zone plan & ground-water monitoring semiannually
Runoff control - application rates to prevent
Seasonal limits - not when frozen below plow line
Sludge monitor - initial (metals, pesticides, chemicals) and semi-annually (N, Cd, Cu, Cr, Pb and Zn)
Sludge stabilization - unless approved otherwise
Soil monitoring - core, pore water
Sludge Monitoring - Pesticides, As, Ba, Cd, Cr, Pb, Hg, Se, Ag, PCB
Permits - Solid waste local jurisdiction, SMCRA, RCRA, Washington Surface Mining Act
Surface- and Ground-water Monitoring - N, P, coliform, and other potentially harmful elements - up and down
gradient
Table E6-9. Forest Application Management Practices
State
Management Practice
Arizona
Approval necessary, case-by-case
Ohio
Loading Limits - Case-by-case
Plant Monitoring - Advisable at dedicated sites
Seasonal Limits - Case-by-case
Ground-water Monitoring - Case-by-case
Washington
Distance to Surface Water - 200 ft
Depth to Ground Water - > 2 ft (seasonal water table)
Loading Rate - For N
At least 2 ft depth to impermeable soil
Slope - less than 30-40 percent
Watershed Type - Not existing or planned public water supply watershed
Sludge Dewatering - 3% for shallow water table or poor drainage
Soil Type - Silty clay loam, clay loam, excessively permeable soil unsuitable
Floodplain Restrictions - Yes
221
-------
Table E6-10. Land Treatment Management Practices
State
Texas
Management Practice
Sludge Monitoring - Initial (metals, pesticides, chemicals) and semi-annually (N, Cd, Cu, Cr, Pb, Zn)
Application Methods - Specified for liquid vs. dewatered
Buffer Zone - 200 ft to site boundary
Sludge Stabilization - Unless approved otherwise
Access Control - Yes
Ground Water Monitoring - Unsaturated zone plan and ground-water monitoring semiannually
Runoff Control - Application rates to prevent
Seasonal Limits - Not when frozen below plow line
Crop Limits - No human food chain unless approved
Table E6-11. Land Ap
dicatlon • Sludges Containing Radlonuclides
Sludge Quality
< 2 pCi/g sludge
> 2 pCi/g
< 50 pCi/g
> 50 pCi/g
Illinois
-
Limit soil increase to 0.1 pCi/g
Limit soil increase to 0.1 pCi/g
IEPA and Illinois Dept of Nuclear Safety review
Limit radon gas emission to less than 5 pCi/m2/s
Wisconsin
No special requirements for 2Z6Ra
Limit soil 226Ra to 2 pCi/g
No winter application
Cannot grow tobacco
Incorporation/Injection
Soil pH 6.5 - 7.3
Mm soil CEC 10 meq/100 g
Min soil clay content 18%
Mm soil organic content 12 tons/ac
-
222
-------
Table E7-1. Distribution and Marketing • State Contaminant Concentration Limits (ppm)
State
California
Maine
Maryland
Massachusetts
New Hampshire
New Jersey
New YorK
Ohio
South Carolina
Texas
Utah
West Virginia
Wisconsin
Number
Range
Mode
Cadmium
50
10
12.5
2
10
40
25
12.5
20
25
25
30
10
13
2-50
10/25
Copper
1,000
500
1,000
1,000
1,200
1,000
500
700
1,000
625
900
11
500-1,200
1,000
Lead
500
700
500
300
700
4,800
1,000
1,000
650
500
500
1,000
250
13
250-4,800
500
Mercury
10
5
10
10
10
10
5
5
8
5-10
10
Nickel
200
100
200
200
1,250
200
100
150
200
200
200
11
100-1,250
200
Total PCBs
2
10
5
2
10
0.5
10
5
10
2
2
2
12
0.5-10
2
Zinc
1,250
2,500
2,000
2,400
2,500
1,000
1,525
2,000
1,250
1,800
10
1,000-2,500
1,250-2,500
223
-------
Table E7-2. Distribution and Marketing - State Management Practice Requirements
State
Alabama
California
Hawaii
Illinois
Maine
Maryland
Missouri
Nebraska
Nevada
New Hampshire
New Jersey
New York
Ohio
Oklahoma
Pennsylvania
Rhode Island
South Carolina
Tennessee
Texas
Pathogen
Control
Resulting residue
from composting
should be non-
pathogenic
Yes
PSRP/PFRP
Digested sludge must
be used
PFRP
PFRP
PFRP
None
For composting
PFRP; crop use
control - not for use
on food. pH>6.5.
Limited to PFRP
PFRP Minimum
PFRP
Detailed chemical
analysis required
before disposal
PFRP (40 CFR 257)
PFRP
PSRP/PFRP
PSRP min.; PFRP for
uncontrolled uses
Runoff
Control
For composting facilities
Yes
NPDES permit for
composting facilities
None
May be required
Yes
No
Yes
Yes
Buffer Zones/
Acces Control
Yes
300 ft for residences,
wells, surface waters,
50 ft to intermittent
streams, 25 ft to prop-
erty line & public roads
Yes
No
For compost plant:
- 500 ft to prop, line
- 1 ,000 ft to road
Yes
50 ft site-specific use
only
50 ft to property line
25 ft to drainage swale
400 ft to nearest
dwelling. Access
control.
Yes
Access control for 1 2
mo after appl.
Temperature
Monitoring
None
Required for
composting
Yes
Yes
Storage
Restricted
Impervious pad
Yes
None
30 days
May be required
Minimum total detention time
of 50 days
Temporary storage to be
provided by generator
224
-------
Table E7-2. Distribution and Marketing • State Management Practice Requirements (continued)
State
Utah
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Pathogen
Control
PSRP/PFRP
3CFU/100mlfor
salmonella;
PSRP/PFRP
PSRP/PFRP
PFRP
PFRP
Runoff
Control
Max slope 12%; 6% if
frozen
Yes
Slope < 20-30%
Yes
Buffer Zones/
Acces Control
Nearest dwelling
1 ,000 ft from open
screening appl.
Temperature
Monitoring
Yes, for
composting
Storage
60 days
225
-------
Table E7-3. Distribution and Marketing - State Site-Specific Requirements
State
Arkansas
Illinois
Maine
Maryland
Missouri
Nebraska
New Hampshire
New Jersey
New York
Ohio
Pennsylvania
Loading
Limits
For public
distribution:
< 1 0 dry t/ac;
Cd<25 mg/kg
N requirements of
crops; Cd, Cr, Cu,
Ni, Zn - 10% of
cumulative land ap-
plication limit per yr;
other parameters
for pretreatment city
None
Site-specific
approval if
mechanically
applied CD < .5
kg/ha/yr<10d~F7ac
Site approval
necessary if >100
cu yd to be used;
2 cu yds/yr/person
Crop Use
Limits
Prohibited on produce
crops, home gardens,
recreational areas,
etc.
Recommend against
use for leafy/root
crops
If >45% Fe (dry
weight) label prohibits
use on pasture
No appl. to raw crops.
Wait 30 days after
appl. for harvest. Appl.
to vegetable/
home gardens not
recommended unless
composted.
None
Not for home
vegetable garden use
Site-specific
requirements for
unlicensed material
Class I: public dist
Class II: non-food
chain crops
Give away approval
requires management
plan if > 1/2 dry
tons/yr
Class I: compost none
Class II: non-food
chain
Class III: approval/mgt
plans
Ground Water
Protection
Impervious pad,
leachate
collection -
includes
treatment
Groundwater
monitoring at
dedicated sites
None
Monitoring may
be required
Yes, site-
specific
requirements
for unlicensed
material
Impermeable
base with
leachate
collection
Distance to
Surface Water
200ft
Not allowed on
floodplams
25 ft drainage
ditch, 50-300 ft
to stream
depends on
stream
classification
None
100ft
Specific use
only
200ft
Distance to
Wells
200ft
depending
on geology
and type of
well
150-300 ft
depends
on geology
and well
construc-
tion
None
100ft
municipal,
300ft
private,
500ft
community
Site-
specific
require-
ments
200ft
Other
Soil Analysis
Semi-annual
leachate
detection
No use or
stockpiling on
saturated,
frozen, or
snow-covered
ground
Lime, limestone
or equiv -
10% (drywt.)
for bagged
compost for
resale
226
-------
Table E7-3. Distribution and Marketing - State Site-Specific Requirements (continued)
State
Rhode Island
Texas
Utah
Virginia
Wisconsin
Washington
Loading
Limits
Yes, figures given
are for uncoltrolled
use
Site approval
necessary if > 1 00
cubic yds to be
used
Cd: 5-20 kg/ha
cumulative on food
chain crops
Crop Use
Limits
Not to be used with
human consumption
crops. Grazing after
1 2 mo (on controlled
areas).
No appl. to
crops/fruits/vegetabfes
unless pathogen-free
Use in home gardens
prohibited
Cannot be used on
certain crops
Unless metals low, not
recommended for food
chain crops
Ground Water
Protection
Ground water
monitoring,
leachate
collection and
treatment
Ground and
surface water
monitoring
required if
stockpile on
ground water
surface
Distance to
Surface Water
200 ft and not
in a water
supply
watershed
50-200 ft
50ft
Distance to
Wells
1,000ft
private well
(also, mm.
4 ft to
ground
water)
300 ft to a
water
supply
(also, 5 ft
mm. to
ground
water)
100 ft
Other
Floodplain
restrictions
Air pollution
control - odors
Soil type -
infiltration
capacity to
prevent
overland flow
227
-------
Table E7-4. Distribution and Marketing - State Sludge Treatment/Management Requirements
State
California
Illinois
Massachusetts
New Jersey
New York
Ohio
Texas
Utah
Virginia
Sludge Dewatenng
Yes
Only dry sludge may be distributed to the public
Product should be 60% solids by completion
Must be in cake form for giveaways
Maximum 10% moisture for home use; 65% for
commercial use
Dried for public distribution
Must be in compost form for giveaways
Sludge Stabilization
Yes
Yes
Yes
Yes
Yes
PFRP
228
-------
Table E7-S. Distribution and Marketing - State Monitoring and Reporting Requirements
State
California
Illinois
Maryland
Massachusetts
Missouri
Nebraska
Nevada
New Hampshire
New Jersey
New York
Quality Monitoring
Monitor sludge for Cd,
Pb, Cu, Ni, N, PCB,
total N, solids;
frequency depends on
size of plant
Yes
As requested, pre-
permit
Metals and organics
None
No grit, screenings, or
grease allowed
Compost testing,
variable frequency
(sludge by generator)
Metals & PCBs,
analysis of product
frequency depends on
amount of sludge;
compost & sludge
testing, variable
frequency
Reporting and
Record Keeping
Representative
samples collected/
analyzed for suitability
Yes
"Regulator" keep all
tests and distribution
records
Recordkeeping -
annually: who, how
much, etc.
Generator - annually:
who, how much.
User - annually: sites
applied, amount,
crops, etc.
Case-by-case
None
Record of users and
quantities taken
Analytical results,
temperature,
distribution, etc.
Quality and process
data and distribution
Product Labeling
Show nature of
contents with warning
at obvious place
Information sheets for
public distribution
Instructions. Identify.
May require
restrictions and
cautions.
"Approval of
suitability" for specific
use, warning if > 10
ppm molybdenum ;
>300 ppm of boron
could cause
phytotoxicity
Type I & ID, use
instructions
Type ll/lll: analysis,
results, amt, notice
legal use
If to be used on
vegetable/garden
crops, restriction on
metals/organics
None
No
Yes, per NJ comm.
fertil. soil cond. act,
1 970, condition of
use, generally dist.
only
Yes
Legal Releases
Contracts necessary
where producer does
not control use
To prove receipt of
sludge information for
users > 25 cu yd
Over 1 500 dry tons per
year requires permit by
brokers
Land appl certificate for
use of Type ll/lll
Solid waste permit,
fertilizer permit, and
NPDES permit
None
Only requirement is that
public knows origin of
sludge
Not for home garden
use - acknowledge
contents
Site Development and
Operational Plan
Solid waste permit,
site development and
operation
No
Yes
Design and operating
plan for composting
Operational plan
229
-------
Table E7-5. Distribution and Marketing - State Monitoring and Reporting Requirements (continued)
State
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
Texas
Utah
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Quality Monitoring
For sludge, monitor:
moisture, N, P, K,
BOD, pH, CN, Na,
metals, toxics,
pathogens, PCBs
EP toxicity yearly and
appendix VI items for
cured compost
Required for
composting product
Reporting and
Record Keeping
Monthly analysis for
compost, who
received the compost
& giveaway sludge;
monthly for compost
(analysis/quantity) per
NPDES permit for
giveaway
For 5 yr - date,
amount, where
shipped, use
agreements, quality,
etc.
Periodic. Who has
received it > 1 t/time
Annual summary of
operatons
Distribution and
intended use
Volume sold -
commercial vs.
domestic users, in-
state vs. out-of-state.
Finished product -
pathogens,
contaminants, total N,
moisture, distribution,
users.
Product Labeling
Generator to inform
user of quality, safe
uses, etc.
Origin must be
revealed
Instruction sheet
describing material
appl. rates,
recommended uses,
prohibited uses
Instructions on use,
rates, and identify as
sludge. Sellers must
include restrictions,
recommend on uses.
Yes
User information on
use restrictions and
misuse warnings
N, P, K, if sold as
fertilizer
Must clearly indicate
that product is not
recommended for
vegetable gardens.
Analytical
identification.
Use instructions
Legal Releases
Agree to use sludge
according to regulations
Permit for treatment
plant
Site Development and
Operational Plan
Management plan for
all Type III compost
and giveaway dry
sludge exceeding 1/2
dry tons/yr to any
person
Operating plan.
Closure plan -
monitoring and
funding.
Composting evaluated
on case-by-case
basis
Yes
230
-------
Table E8-1. Incineration • Allowable Contaminant Levels in Exhaust Emissions
State
Alaska
Arizona
Connecticut
Delaware
Florida
Georgia
Illinois
Indiana
Iowa
Kansas
Kentcuky
Louisiana
Maryland
Michigan
Minnesota
Mississippi
Missouri
Nevada
New Hampshire
New Jersey
New York
Be
Yes
I0g/d
Hg
3200
g/24 hrs
3200
g/dT
3,200
g/d
Opacity
(%)
<20
20
20
20
Max 20
20
Particulates
0.65 g/kg dry sludge input
0.1 gram/SDCF
0.08 grain/SCF
New - 0.65 g/kg dry sludge
input; Existing - 0.2-5.0 Ib/hr
depending on charging rate
(1,000-3,000 Ib/hr)
0.1 gram/cu ft (Existing > 75
t/d);0.08 grain/DSCF
(New>50t/d)
Existing -0.2 lb/100 net
sludge.
New-1 .3 Ib/ton dry sludge
0.08 grain/SCF (A 12% C02)
for < 60,000 Ib/hr.
0.1 grain/SCF - other.
< 0.65 g/kg dry sludge input
0.i-0.3g/DSCF
0.65 g/kg dry sludge input
0.2 lb/1 ,000 Ib gas
Regs for sludge incineration
incomplete
0.2 gram/SDCF
0.2 grain/DCF exhaust gas
0.3 if >200 Ib/hr
3 Ib/t dry refuse if < 2,000
Ib/hr
0.1 grain/DSCF @ 12% CO2
0.2-110 Ib/hr depending on
charging rate
SO2
1.2
CO
500 ppm (@
50% excess
air) > 2,000
Ib/hr refuse
12%
Comments
Flow measurement
NSPS adopted by reference
40 CFR 60 subpart E
PSD regs may apply (Pb 0.6
t/yr NSPS)
Open burning prohibited
Open burning prohibited
Open burning prohibited
Per APC Iowa
Meet all air quality control
regs and guidelines
Particulates, regs for sludge
incineration incomplete
Comply with NAC 445.430
to 445.846
231
-------
Table E8-1. Incineration - Allowable Contaminant Levels in Exhaust Emissions
State
Ohio
Oklahoma
Pennsylvania
Rhode Island
South Carolina
Tennessee
Virginia
Wisconsin
Be
Hg
3,200
g/24 hr
Opacity
(%)
20
20
<500 Ib/hr
no permit
req.; exemp-
tion also pos-
sible if metals
levels met
Particulates
2 lb/100 Ib refuse < 100 t/hnl
lb/100lb >100t/hr
Conform to prevailing state
and local regulations
1 .3 Ib/t dry sludge input
0.5 lb/106 Btu heat input
0.2% of charging rate if
< 2,000 Ib/hr, 0.1% if > 2,000
Ib/hr
1.3 Ib/t input
SO2
CO
Comments
Exemption if part of WWTP
not regulated/
licensed separately
Conform to State/local regs
PSD limits may apply
Meet APC requirements
< 500 Ib/hr no permit
required; exemption also
possible if metals low
232
-------
Table E8-2. Incineration • Management Practices
State
Alabama
Arizona
Arkansas
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Iowa
Kentcuky
Louisiana
Maine
Maryland
Emissions Control
Must meet all air
quality control
regs/guidelines
Minimum
Temp./Time
Mm. temp.
Min. time
800 °F Primary
temp; 1,500°F
Secondary
Min. temp.
Air Monitoring
Yes
Hg - Yearly if Hg
emission > 1,600
g/d
See Chapter 2,
Regs/Rules
203-E
Hg - Iowa
Pollution Control
Rules
Hg if emissions or
sludge analysis
> 1,600 g/d
Ash Disposal
Sanitary Landfill
Plans for disposal
needed
Yes
In proper landfill
Prevent odor/dust
nuisance
Yes
Permitted at
facility
Site Development
Plan
Solid waste unit
approves site
development and
operational plans;
air quality
approves stack
emissions
standards
Operating plan,
site description, to
prevent health
hazards, envr.
degradation or
health nuisance
Other
Open burning in
LFs prohibited
without permit
Leachate
collection - meet
WQS
design/operation
by 17-2 & 17-3
facility;
runoff control •
yes;
surf. wat. monit -
yes
No open burning
Air turbulence
controls
Sludge
dewatering,
drying
Open burning
prohibited at LFs
serving >1000
persons
233
-------
Table E8-2. Incineration - Management Practices (continued)
State
Missouri
Nebraska
Nevada
New Hampshire
New Jersey
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Emissions Control
Mm. air pollution
technology. Must
use best available
technology at
time of
construction/modif
ication
Yes
State-of-the-art
required
Prevent odor
nuisance, best
available control
technology for
new sources
20% visible
emissions
Minimum
Temp./Time
1,400°F for not
less than 0.3 sec
Air Monitoring
Yes
Preconstruct. If
existing data
inadequate, stack
tests, continuous
monitoring of O2,
CO,
hydrocarbons;
mm O2
concentrations:
4% fluidized bed
Ash Disposal
Special waste
landfill permit or
NPDES permit
If on an approved
land disposal site
Sampling and
analysis of ash
composition
Landfill analyzed
for hazardous
material/nature
Approved sanitary
landfill, deed
shows use of Cd.
pH>6.5 unless
Cd < 2 mg/kg.
PCB<10 mg/kg
unless meet 40
CFR 257
requirements.
Solid waste regs
Cd, Ni, Pb, Cu,
Zn - max. loading
rate
Dept. approved
Site Development
Plan
Yes
Yes
Case-by-case
basis
Closure plan
procedures
specified
Yes
Other
Permits
Ash may be land-
applied if non-
toxic
Open burning
without license
prohibited
Access control
Runoff control
Vector control
Distance to
surface water-
200 feet; leachate
control;
sludge dewatering
Permits
Air and
wastewater
permits may be
issued together
Access control -
fences/locks
Runoff control -
divert surface
drainage
234
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Table E8-2. Incineration - Management Practices (continued)
State
Rhode Island
South Carolina
Tennessee
Texas
Virginia
Washington
Wisconsin
Wyoming
Emissions Control
Treat exhaust
gases for
organics/
participates
.5 Ib/million BTU
heat input
Mm. air pollution
control for Be,
lead, Hg, vinyl
chloride, "others"
PSD limits
Meet ARC
requirements
Min. air pollution
technology -
conform to
ORA/VA stds
(1 0/28/72) (DE-
72-21 sec 1 73-
301-350)
Minimum
Temp./Time
Air Monitoring
Be, Pb, Zn, vinyl
chloride, "others"
Not to exceed
design emission
limits
Ash Disposal
"In a sanitary
manner"
Buried/spread on
land, approved by
DOH and WCB -
Not for landfill
disposal
Approved sanitary
landfill
Mass/volume -
licensed solid
waste disposal
facility
Site Development
Plan
Area and facility
plan
Operating plan.
Trial burns.
Waste analysis.
Yes
Yes
Other
Closure plan
Water control - all
drains and
process water to
WWT plant
Access control
235
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Table E8-3. Incineration • Monitoring and Reporting
State
Connecticut
Delaware
Georgia
Iowa
Kentucky
Maryland
Michigan
Missouri
New Hampshire
New Jersey
Oregon
Pennsylvania
Tennessee
Texas
Washington
Wisconsin
Emissions
CO, hydrocarbons,
NO2, particulates, S02
CO, hydrocarbons,
NO2, particulates, S02,
ozone
Reporting
Hg if emissions or
sludge analysis
> 1 ,600 g/d
Valid permit from Air
Management Admin.
and Waste
Management
Performance testing
with representative
sample of material to be
burned
State regs/guidelines
Modeling for risk
assessments for
arsenic, Cr, Cd, Ni
As DEQ requires
Lead, Hg, Be, vinyl
chloride, "others"
Sludge
Hg
Sludge monitoring
Sludge monitoring (%
solids, pH, N, NH3, NO3>
metals, PCBs, "etc."
Sludge monitoring same
as land applic. perhaps
annually
Sludge monitoring
Monitor sludge for
suitability to incinerate
Sludge analysis for
wastes that create
specific environmental
problems
Sludge monitoring -
verify that it is non-
hazardous
Sludge monitoring - mass
or volume
Ash
Monitoring depends
on disposal method
Analysis of ash
composition
Sludge Feed Rate
Yes
Yes
Incinerator
Temperature
Monitor
Required
Chamber
temperatures
(continuous)
236
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Closure pla
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Ultimate disposal
agoons covered with
mm. 2 ft cover after
sludge removed;
losure plan required
Closure plan
required; screening
equired; gas venting
require
monitori
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requi
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p, plan
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242
-------
Table E9-2. Lagoons and Stockpiles - State Monitoring and Reporting Requirements
State
Colorado
Connecticut
Delaware
Georgia
Illinois
Iowa
Louisiana
Maine
Maryland
Michigan
Missouri
New Hampshire
New Jersey
New York
North Carolina
North Dakota
Ohio
Oregon
South Dakota
Vermont
Virginia
Washington
Wisconsin
Wyoming
Sludge Monitoring
Annually (min.)
Metals, PCBs, pathogens
Annually, at time of lagoon
cleanout
As per land application
license
Same as land application -
pre-permit
Prior to final disposal
POTW > 1 mgd 3x/yr
POTW<1 mgd tx/yr
Yes
Yes
Annual, per permit
Yes
Ground Water Monitoring
Quarterly
Yes
Mm 3 wells (one upgradient)
- may be waived for above-
ground manufacture facilities
If in areas of porous soils or
rock fissures
Yes
2 down, 1 upgradient
Hydrological study as part of
application process
Case-by-case
Yes - lagoons
No - stockpiles
May be required
Required minimum: one well
upgradient, two
downgradient
Case-by-case
Case-by-case basis for
lagoons
If high water table
May be required if shallow
ground water or permeable
soils
pH, conductance, chlorides,
nitrates, metals
Yes
Yes
Surface Water Monitoring
Yes
NPDES permit
Compliance with RSA
149.8,111
May be required
When required by
department
Yes
Yes
As required
Reporting Requirements
Yes
Only for new requirements,
not for existing
Only for permanent lagoons
Summary of management
records quarterly
Permits and closure plans
POTWs must inform sludge
users of quality changes.
Site approval from BSWM
required. Site planning
required.
Yes
Annual report required
Yes
NPDES
As DEQ requires
Quarterly
Operations report
243
U.S. GOVERNMENT PHNTNG OFFICE: 1990-261-069/24136
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