Acceptable Methods Based Upon Current Knowledge For The Utilization Or Disposal Of Sludges From Publicly Owned Wastewater Treatment Plants

5221
AfTFPTABLE METHODS BASED UPON CURRENT
KNOWLEDGE FOR THE UTILIZATION OR DIS
TOSAL OF SLUDGES FROM PUBLICLY OWNED
WASTEWATER TREATMENT PLANTS.
800R80910
L
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON. D.C.
OFFICE OF
AIH AND WATER PROGRAMS
SUBJECT: Policy Statement on Acceptable Methods for the
Utilisation or Disposal of Sludges — ACTION MEMORANDUM
FROM:

TO:

THRU:

ISSUE
Acting Assistant Administrator for Air and Water Programs (AU-443)

The-Administrator
BACKGROUND
1. Statutory Basjs*..- ,
Of
treatri
Under Title JL o^tji^.Federal Uater Pollut1 oft"cbntrol P-ct A-n
1972 ("th^'Afet"), "the" Aa.iinistrator makes '9'C^vts fgs cqjsstruct
'
•on of
Undc-r Section 203-(<.i) of tha Act, each- i
for a grant
to the Ac':n1nistratcr for his approval, plans, s.r;,£(cri,f^catic»j5>, and e-.tl'-matos
for each proposed project Tor cho construction "6'r Vrba'cr.icnt works for
which a grant 'is applied. • <-., ;
> H'lV '-• '• 'f '• _ ';
Under Sscticn 201{d.),(-1) tho Adainistr.itor Bhal1Jfchcour2go waste
trcatnv^nt rr,anagon;eiit,whiG>f results in tlie cOiiotructicrj ^iv roveauo -pro-
ducing facilities jirqKding for th'a ul tlp.atc ^r';; postal- 'of sludge, that
will not rosi:H in 'e '' '"
In Section 2^(2}(A), tha tyi-w trca L.^-I i; uorks MnviU'dos. slto i?o-:uJr,i-
tion of uiio land i;nat viil bo on irri:>,'gru'i |Wt '•: of thsj trs?i.T-Kt process
or Is used for ultima to disposal or rosi^.-c-s rucuHincj frc-.i such v/or'
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Thus EPA Regional Administrators, in reviewing grant applications,
leed policy information on methods of sludge utilization or disposal v.'hlch
arc environmentally acceptable.

2• Previous Pol ic;/ Statements:

In October, 1970 the Council on Environmental Quality sent a report
to the President, entitled "Oce^n Durpinq - A National Policy." In that
report, the follovnnn statements v.'cro mace: ". . . The Council on Environ-' '
mental Quality reco.umends the following policies relating to specific types
of wastes currently being dumped in the ocean, in estuaries, and in the
Great Lakes:

Ocean dumping of undigested sewage sludge should be stopped as
soon as possible and no new sources allov;ed.

Ocean dumping of digested or other stabilized sludge should be
phased out and no nev; sources allowed. In cases in v/'nich
substantial facilities and/or significant connitments exist,
continued ocean dunging may be necessary until alternatives can
be developed and implemented. Gut continued ocean dumping
should be considered an interim rn.e-?.sur«. . .".

In accordance with the CEQ recommendation, an EPA interim policy
dated October 21, 1971, was issued to the Regional Administrators for
their guidance iu the grant making process. The interim policy pro-
hibited the issuance of grants for nev/ treatment facilities which would
dispose of sludge to the"ccean. Grants to existing facilities which
practices ocean disposal of sludge could not be made unless the practice
was discontinued before the completion of construction, viaivers were
allowed when cessation of ocean disposal could not be reasonably accomplished
within the construction time frame. Waiver requests had to ba accompanied
by a time schedule and plan of accion for phasing out ocean sludge disposal.

On September 29, 1972, the President's Water Pollution Control
Advisory Board, in its report "Ocean Disposal Practices and Effects,"
stated among its conclusions:

". ... the board 'has heard convincing evidence that the presence
of toxic substances, primarily cha heavy ratals, in municipal sewage
creates special problems in the ultimata disposal of the resulting sludge
from treatment plants. "Ihess substances lisva an adverse effect through
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their possible entry into the marina food chain when ultimate disposal
of sluclge is in the oo.j.n. Similarly, adverse effects follow from dis-
charges to the atr.osphere of these substances if incineration is selected
.as the method of sludge disposal. Even when sludge disposal is to land,,
the presence of these toxic rratcrials complicates the problem and Intro-
duces difficulties in the ultimate use of land. . .".

On October 23, 1972, the Marine Protection Research and Sanctuaries
Act was enacted. It is the stated purpose of this Act "... to regulate
the transportation of material from the United States for dumping into.
ocean waters . . ." "Material" is defined in the Act to include sewage .
sludge.

On April 5, 1973, the Environmental Protection Agency issued
"Interim Regulations Governing Transportation for Ouir.plng, and Dumping
of Material into Ocean l.'?ters". These state, in part, ". . . when
Title I of the Act becoires effective en April 23, 1973, it will generally
be unlawful to depart a port in the United States for the purpose of
dumping material in the oceans, or dumping material in the territorial
or contiguous zone of the United States, unless the person engaged in
sucli transport or dumping has first obtained a permit from EPA. . .".

On June 11, 1973, ti.e Environmental Protection Agency published
proposed "Standards of Perforwncc for tJev; Stationary Sources" to •
restrict air pollution emissions from seven source categories. Sewage
sludge Incinerators ware included in the coverage of these standards.

All of the reports, legislation, regulations, and standards material
cited ,above restrict wastev/ater treatment authorities concerning the
ultimate disposal of residues resulting from their wastewater treatment
process, without providing counsel as to the disposal methods which would
be environmentally sound, or- at least deemed acceptable. This has
created a serious situation of uncertainty and concern to those treat-
ment authorities, and to c-iwiro.'.inantalists.as a whole. If left unresolved,
this problem situation can only become v/orse, as the PL.92-500 require-
ments for universal secondary treatment produce greater quantities of sewage
sludge than are produced today. , , •

HORK GROUP

An EPA work group '.-.'as1 established to develop a positive Agency policy
concerning the disposal of slurige from publicly owned v;astovater treat-
ment plants. This group ultimately Included, representatives from the
Office of Air and Water Programs, Office of Research and Development,
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Office of Solid Waste Management Programs, Office of Toxic Substances,
Office of Planning and Evaluation, and Region III. In addition to the
E,PA representatives, Kr. Steffen Plehn of the Council on Environmental
Quality participated v/ith the v?ork group throrhout. Major assistance
was also provided by Dr. Thomas Hinesly, consultant to the Office of
the Under Secretary of the Army. Near the end of its work, the group
also received advice from representatives of the United States Depart-
ment of Agriculture and the Food and Drug Administration.

The Environmental Protection Agency draft policy statement concern- •
ing acceptable rr.ethods, based upon current knowledge, for the utilization
or disposal of sludges froa publicly owned wastewater treatment plants,
represents a product of the v/ork group.
Early In its deliberation, the v;ork group decided that its effort
should-be two-fold: (1) The c'svGlcpu.ent, for iiVMC-dioto practical usa,
of a sludge disposal policy which v;ould reflect current information
concerning the environmental soundness of various sludge disposal methods.
This policy would be used by Regional Administrators in the evaluation
of applications for Federal assistance to construct wasiiev:ater treatment
works, and (2) The development of a sludge policy which would identify
optimum sludge utilization or disposal technology. This policy v;ould
result from a sound federal research and development program specifically
designed for this purpose.
The work group is now engaged in designing the R&D program for
the optimum sludge method policy. It is expected that this design will
be completed when the coavronts on the proposed statement are received.
The design would, necessarily, coordinate the related activities of all
participating Federal agencies. Representatives of such agencies will
be included within the design'group.

SUKMARY OF POLICY STATEMENT

The policy statement for in-mediate use, based upon current knowledge,
is the subject of this memorandum (Tab A). This policy slatc'.nant describes
acceptable methods for the utilization or disposal of sludge from publicly
owned wastev/ater treatnont plants. It is divided into two essential.
parts; the first part describes methods in which the sludge is used to
serve a useful purpose beyond mere disposal, and the second part describes
methods which provide only for disposal. Both parts, of course, in-
clude only methods v.'hich arc envirotnranta'ily acceptable.
\ "•
? 'O.
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Methods which are not on the 11st are not acceptable, although
the policy statement provides for the Environmental Protection Agency
to encourage and assist in the development of new or advanced procedures.

In the policy statement, "Group I: Sludge Utilization Methods"
now Includes only one basic category. This category 1s recognized by
the statement: "Stabilization and subsequent land application for
agriculture, enhancement of parks , forests, and reclamation of poor or
damaged terrain, is an environmentally acceptable method for the utiliza-
tion of sludge". Stabilization and land application are further
defined in subsequent passages to this initial statement and special
precautions are stipulated for the protection of public health,'ground
water protection, controlling surface v;ater runoff, the choice of crops
suitable for sludge application, application rates, and monitoring.

"Group II: Sludge Disposal f^thods" includes sludgs .landfills
Involving mixed sludge and solid wastes and sludge incineration and
disposal of the resulting ash. Precautions are specified for protection
of public health, ground water protection, and confonnance to applicable
air pollution requirements.

Ocean disposal of sewage sludge is considered acceptable for treat-
ment works presently using this method whon rho s'inci(jr> irv»f»t.s thp criteria
specified by EPA in the ocean disposal regulations, l.'hsn the sludge
exceeds the criteria, ocean disposal will be psn.iittcd only on an Interim
basis and subject to an approved implementation plan to eliminate the
material. . .

TECHNICAL SUPPORT DOCUMENT

A Technical Support Document (Tab B) v/as prepared by the Work Group
to take advantage of unpublished information and smimarize the technical
basis for the contents of the policy statement.

The document is a compilation of material extracted from U.S.
Government publications, as well as material which is in the draft
stage. This document will not be published separately since it is a
suircnary and compilation of information which will be mode available
when the source documents are published.
s
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COORDINATION

The policy statement has been coordinated within EPA including
the Regions. Working level coordination has been accomplished with
other Federal agencies having direct input, such as the U.S. Depart-
ment of Agriculture and the Food and Drug Administration. Many changes
have been incorporated in the statement as a result of these reviews.
All substantive comments have been resolved with the exception of those
received Informally from the Office of Hazardous Materials Control (Tab C).
Unresolved issues are discussed subsequently.
• t
IMPACT OF THE, POLICY STATEi'.F.HT ' .• .

1. The impact will be most significant for land application.
After examining data on sludges from 180 sources it has been deternined
that men o Lhan 50 percent of the sources would not qualify, including
Milv.'aukeo's milorganite and Chicago's Fulton County. For this reason,
prbvision -was made for demonstration projects under carefully.defined
and monitored conditions where the sludge exceeds the limits given in
the policy statement.

2. Cost impact and energy impacts have not been included in this
analysis since the only criterion considered v;as environmental accept-
ability.
a „
SUMMARY OF MAJOR ISSUES

1. Should ZPA issue a policy statement on sludge?

It is recommended that EPA issue such a statement to provide guidance:
to EPA Regional Administrators. However limited our current infor-
mation, seme municipalities are making decisions in the near future
and cannot wait for ultimate or optimum solutions.

2. Should EPA include land application in the policy statement?

It 1s.recommended thit lend application be included. The alternatives
to Including land application are either to prohibit it entirely (which
would be contrary to the intent oP the Act) or to leave it up to the
Regional Administrators, vritn no guidnnca.

3. Should EPA fund land for application or disposal of sludge,
when there is no similar funding for municipal solid waste?
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It is noted that EPA funds such land in response to the Act. The
fact that thnre is no similar program for solid wastes does not alter.
the construction grant eligibility of land for ultimate disposition of
residues froni wastewaier treatment.

4. Should EPA delay issuing the policy statement until more infor- -
motion is available?

It is recoi/rnended that the staterr,ent not be delayed. The statanent ' .
is conservative and includes provisions for control monitoring. Addi-
tional substantive information on major subjects is not likely to be
available in the near tenn future, ar.d is considered to be at least 5 years
away, given the low levels of current research funding.

RECOMMENDATION

• It is '>-eccmrr>ended that "Acceptable Methods, Based Upon Current
Knowledge, for the Utilization or Disposal of Sludge from Publicly
Owned Treatment Plants" be approved for publication in the Federal .
Register as a proposed declaration of Environmental Protection Agency
policy. ,
CONCURRENCES
EG,

RO,

PH,

MM,
Kirk

Gren field

Aim .

Elkins
(Acting)
Concur
Concur
Concur
Concur
Approve:
Disapprove:
Date:
Nonconcur Date
Nonconcur Date
Nonconcur Date
Nonconcur Date
Prepare-' by ArWM:AW-447:sr.is:WAWhi ttington:P.-a: 1125:WSM-E:XCS976:2-20-74
7
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ENVIRONMENTAL PROTECTION AGENCY

Notice of Intent to Issue a Policy Statement
on Acceptable Methods for the
Utilization o*r Disposal of Sludges
Notice is hereby given that the Environmental Protection Agency
t

intends to issue a policy statement on Acceptable Methods, based upon

current knowledge, for the Utilization or Disposal of Sludges from

Publicly Owned Wastewater Treatment Plants. The policy statement is

contained in Appendix I to this notice. The purpose of the policy

statement is to provide guidance to Regional Administrators of the

Environmental Protection Agency in evaluating proposed sludge utiliza-

tion or disposal systems included in the design of publicly owned
o
. treatment works for which construction grant applications are made.

The policy statement was developed by an Agency work group with
«
substantial assistance provided by individuals from the Council on

Environmental Quality, the U.S. Department of Agriculture, the

Food and Drug Administration, and the Department of the Army.

For sludge disposal by sanitary landfill, incineration, and

ocean dumping, there are extensive criteria already available in

other EPA regulatory material. In general these criteria have
'7 ?'•
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been referenced in the policy statement with some modifications.

For sludge in sanitary landfills, reference is made to the

• EPA sanitary landfill guidelines. One additional requirement

is that there be a binding agreement for proper operation where

the sanitary landfill operator is not the grant applicant.
For sludge incineration, reference is nude to tiie EPA ntv/

source performance standards. Additional requirements have

been included based on previous work by the EPA Sludge Incinera-

tion Task Force.

o
Ocean disposal is strictly regulated by EPA, and the EPA

guidelines on the subject are referenced in the policy state-

'ment. In general, ocean disposal of sludge is not a desirable

practice and it is included in the policy statement only because

in some cases it 'may be acceptable on an interim basis.

The area with lear.t existing regulatory material is land

application of sludge. Accordingly, it V.MS necessary to provide

more detailed material on this subject.

The policy statement contains criteria for land application of

municipal sludges. The most difficult matter to resolve, ho./ever,
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was application to lands which are or could be used to grow

crops in the human food chain. For such applications, the

criteria in the policy statement are designed to protect

public health and preserve farmland resources. To insure com-

plete coverage, projects involving crops in the human food

chain will be reviewed by the Food and Drug Administration and .

the U.S. Department of Agriculture-

The Agency is aware that there are research and dennnstra-

tion efforts now underv/ay to define optimum methods for utiliza-

tion of municipal sludge. The present policy statement .is based

on current knowledge, and will be modified from time t;o time as

additional information becones available.

.Because of the wide interest in this subject, the Environmental
«

Protection Agency is soliciting comments on the proposed policy

statement. Interested persons should submit written consents,

views, or data to the Director, t-'unicipal Construction Division,

Office of Water'Program Operations, F.nvironmental Protection

Ayency, Washington, D.C. 20-160. All such co:r,:rjni cat ions re-

ceived prior to 60 days after publication of this notice in the

federal Register will be considered in developing the final policy

statement.
Russell F. Tr.iin

Administrator
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Appendix I •
U.S.. ENVIRONMENTAL PROTECTION AGENCY POLICY
Acceptable Methods ?J3asod Upon Current Knowl edge , for the Utj 1 izati on or
Disposal o f SI j f 1 o es F-on Pub 1 i civ Q-.-T'cd H^tcv'a her '!' rsa tir^n t Plants .
The treatment of waste-waters for pollutant removal produces
not only relatively clean water for discharge, but also a significant
quantity of residue material. For domestic sewage, treated in publicly
owned plants, this residue is essentially organic in nature, although
measurable quantities of metal, minerals, and other compounds are
invariably -also present. Where industrial Wostpwators are treated
together with domestic sewage, the potential is increased for addition-
al foreign materials in the resulting sludge. Further, pathogenic
-organisms in sewage may survive the wastewater treatment process and
be found in the residue.

Depending upon the ccnstitutenfc character of the v/astewater
treatment plant sludge, and the quantity involved, disposal of this
residue material can e;rt a significantly adverse impact on the
environment. It is essuntial for v/astev.'ater tre^tu^nt installations
to givs effective consideration to the proper disposal of sludge
produced as well as to che proper disposal of treated wastawater.
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\
The requirements of the Federal Water Pollution Control Act
i

A/nondments of 1972 provide an immediate emphasis to the need

for environmentally sound means for sludge disposal. The national

requirement for secondary treatment, to cite en example, vnll not

only produce a greater quantity of sludge than heretofore, but

will also result nationwide in greater and possibly rr.ore con-

centrated forms of foreign r.nterials present, in the sludge.

The disposition of wastewater treatment plant sludges is a

complex problem. It can involve simultaneously the air, land,

and water phases of the environment, encompassing such varied

considerations as public health, plant growth, and ground water

protection1, as well as pollution control. Regional Administrators

of the Environmental Protection Agency are faced with these

questions daily as they evaluate sludge disposal systems included

in the design of publicly-owned treatment works for which con-

struction grant applications are made. Even in consideration

of the still limited information available on the complex issue

of sludge utilisation uiid disposal, there remains.a need for an

Agency policy, defining a baseline of accc-ptjble sludge utilisation
j

or disposal practice.
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For the reasons cited above, a clear statement of environ-

mentally acceptable mathods for sludge utilization or disposal

is presented in this document. The roethods listed are based

upon current kric.-.'leoye. Mo attc.r.pi; is made to slate that the

listed n»thods are optinuni for sluJije utilization or disposal,

but rather to state that any adverse environmental impact

associated with each method can be tolerated n'f the site con-

ditions are suitable. A companion docurant is being developed

to guide Federal research and demonstration efforts for the

purpose of producing optimum technology for sludge utilization

or disposal procedures which minimize adverse environmental •
a
effects.

The list of currently acceptable methods is divided into,

two distinct parts, in.order of the priority of acceptance. The

first part has been established to include methods in v/hich the

sludge is utilized as a resource. The second part includes those

methods which are environmentally acceptable but In which the

sludga is not utilised for any beneficial purpose.
»

Methods vihich appear to have gr^at future premise, but which

have not been used In existing facilities, are not included in
\
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this list. As these methods are demonstrated in practical use,
and as supporting information is obtained, they will be added to
the list of acceptable methods. Because it is the policy of the
Environmental Protection Agency to encourage and, where possible,
assist in the develop/rant of new or advanced waste-water treatment
procedures, Federal grant funds tvcy be awarded for the construction
of sludge utilization or disposal facilities not on the list,
provided that infornation is presented by t>« grant applicant
sufficient, to allovi a determination that such facilities-would
meet applicable statutory and regulatory requirements.

Proper operation, maintenance, and monitoring of the sludge
utilization or disposal method are essential to ensure that ad-
verse environmental effects do not result. Grant applicants
must demonstrate that they will hove manager, operators, and
resources necessary to achieve and maintain the required performance
on a continuing basis.
The criteria in this policy stateir-ent are subject to confirm-
ation or revision based on future experience in the field. All.
users are encouraged to submit suggested revisions, data, and
information to the Director of the Municipal Construction Division,
Office of Uater Program Operations, Enviror,rental Protection Agency,
U.ishimjton, D.C. 204GO.
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Group I: Sludge Utilization Methods
1.' Stabilization and SubsequentLand Application for Agriculture,
Enhancement of Parks and Forests^ end Reclamation of Poor or
Daniaged Tor rain, is an environmentally acceptable method for .
the utilization of sludge.

•1 • Stabilization. Prior to land application, sludge r.jst be
stabilized to reduce public health hazards, as well as prevent
. nuisance conditions such as odors and insects. To be acceptable,
the stabilization method used must reduce influent volatiles
by at least 40 percent, and fecal coliform reduction must ex-
ceed 97 percent. In order to ensure nuisance odor conditions
do not occur, a higher degree of volatile reduction may be re-
quired (reference Figure 13, page 213, ASCE/WPCF Manual of Practice
• »
on Sewage Treatrrent Plant Design ,1959). Well designed and
operated anaerobic digestion is an acceptable method for sludge
stabilization. If anaerobic digestion is used, the sludge
must be maintained in the digester at a temperature of at least
30° C> with hydraulic capacity for at least 30 days. In well designed
and operated high rate digesters, the hydraulic capacity iray be
.reduced provided the performance requirements are met. Digested
/
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sludge can be further stabilized by various composting systems.
t
If composting is used, temperatures above 55°C must be reached
as a result of oxidative bacterial.action. After proper com-
posting the material must be cured in a stockpile for at least
30 days. It is emphasized that odor control is an extremely
important requirement, and the absence of objectionable odors
/
is highly dependent on adequate stabilization.

Aerobic stabilization, chemical stabilization [lime treatment,
etc.,], and heat stabilization methods may also be utilized,
' provided that assurance can be made, for the specific case,
that the public health factors and nuisance potential are no
greater than would be associated with anaerobic digestion or
composting. The specific numerical values for stabilization
as above may not apply to these alternative methods.

l.*2. Land Application. After stabilization, liquid digested-sludge
may be applied to the land by plow injection, or by ridgu and
furrow spreading. Dried or dcwatered stabilized sludge, or
composted material from digested sludge, may be spread upon the
land ar.d then incorporated into the soil by plowing, discing,
or a similar met hoi.
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Spray application of digested sludge to the land is acceptable
only when the transport of aerosols, beyond the boundaries of
the application area, is minimized through such means as the
use of low pressure sprays, or the use of spray nozzles located
close to ground level and directed downward.-
/
1. 3. Precautions.
1. 3. 1. Protection of pLiblic Health
1. 3. 1. Pathogens. Protecting the public health must be accomplished
• by either controlling public access to the site, or by reduc-
tion of pathogens in the sludge. Acceptable methods for re-
duction of pathogens in digested sludges include pasteurization
(30 minutes at 70°C), high p.! treatment with 11ms (pH greater
•a
than 12, for 3 hours), and long term storage for liquid digested
sludge (60 days at 20°C or 120 days at 4°C). Additional disinfec-
tion 1s not required for completely composted materials.-
1.3.1. 0. Application to Agricultural Lands
Application of sludge to agricultural lands which may be used
to grow crops must be carefully reviewed to ensure cropland
resources are protected and harmful contaminants do not enter
the human food chain.
/7
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Each project Involving application of sludge to lands which

may be used to grow crops must be reviewed by the U.S. Department

.of Agriculture. Additionally, when the crops will be in the

human food chain, the project must be reviewed by the Food and

Drug Administration. Regional Administrators should arrange
*
for the project facility plan to be reviewed by these agencies.

The report should provide sufficient Information for the rev lev/,

Including information on sludge treaonsnt, industrial users,

estimated sludge characteristics, the land application system,

expected crops or products, operating practices, and monitoring.

Work is underway by EPA, USDA, and FDA to define more precisely

the types of sludgas which can be used for land application.
4

In the interim, USDA has provided the following information:

Sludges not exceeding the maximum levels indicated

1n Table I may be applied to land which are or could

be used to grow crops in the human food chain
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Table 1

Interim maximum content of toxic elements for sludges .

to be applied to land which will ever grow crops In

the human food chain.
. «
4
Element Maximum Content • ' '
mg/kg dry sludge.

Cd 10

Cu 1000

Hg 10

HI 200

Pb 700

Zn 2000
o

Up to 150 percent of values listed 1n Table 1 may be

tolerated 1f an abatement program Is concurrently

offered -which will have the potential to reduce the

sludge contents to those listed.

No greater total amount of sludge p.:.\y be applied over

the life of the project than calculated by Equation 1

for the sludge and soil in question.

Equation 1 : Total quantity of sludge, tons por acre,
CUC (m^q/lOOq ungnifrnc^d soil) x "i.63 x 104
mqjn_ . 5Q) + 2 (Mgju_^ . 25) +8x (ry.NJ.
kg sJudga ' kg slucicja ' kg soil
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Equation 1 is based on limiting metal additions as Zn
(equivalent) to 5 percent of cation exchange capacity
(C£C) of the unamended soil to allow continued growth
of all crops at pli > 6.5. The modified Zn (equivalent)
1s used to correct for dilution of the soil by the in-
organic matter of sludge.

The sludge-amended soil must be at pM > 6.5 for at
least 2 years after sludge amendment.

In cases where sludye 1s applied to land which will
not be used to grow crops In the human food chain,
higher total applications may be allowed. In thosa
cases, 1t will be possible to adjust the pH and soil
conditions, or use specific crop species or varieties,
which will limit injury from and uptake of the con-
taminants (consult the Agricultural Research Service,
U.S. Department of Agriculture).

FDA has provided the following Information:

Regulations jxist to control the level of persistent
organic chemicals, such as pesticides and polychlorln-
ated biphenyls, in certain components of the food chain.
However, similar guid^l'nes have not at present been
10
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established for all trace elements 1n foods. When
standards are Implemented, those sludge applications
Involving _crops in the human food chain will have to
be adjusted to conform. Cd and Pb are of particular
concern and Hg, As, Se as well as persistent organics,
such as pesticides and PCB's could also be of concern
in municipal sludgo and 1n some crops grown in sludge-
treated soil.

Even though pathogen reduction methods are used, addi-
tional precaustions should be undertaken when sludge
1s used for agricultural purposes. Under certain con-
ditions, specific organisms may survive in the soil for
o
extended periods. Consequently, application of sludge
'for crops which may bo eaten raw by humans is not
acceptable. Sludge applied to crops which are cooked
or processed before consumption, to pastures, or crops
used for foraae should be negative for pathogens by
normally applied analytical procedures. Forage and
pasture crops should not be consumed by animals while
such crops are physically contaminated by sludge as
this could result in direct inaction by animals.
Grazing animals should not be ptv'mittr'd on pastures
before thorough removal of sludge by rain or similar
method.
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Where sludges are to be applied to the land, industrial users of

municipal wastewater treatment works should be required to pretreat

their wastewaters so as to minimize heavy metals and other chemical

contaminants from industrial sources (see Federal Guidelines: Pre-

treatment of Pollutants Introduced into Publicly Owned Treatment Works). .
11A
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Note, however, that quantities of these materials may also be present
In wastewaters usually considered of non-industrial origin. In
developing pretreatment programs, special attention must be given
to the disposal of sludges created or materials removed during the
pretreatmcnt process. Disposal of these materials must(be in an • •
i ,
environmentally sound manner.

The criteria in this section are based on limited Information and
admittedly tPA is conservative in defining a sludge -acceptable for. - ,-. -
land application. Other sludges may also be acceptable as demonstra-
tion projects, including some sludges which do not in every respect
fall within the above limits. Hoi/ever they can only be accepted
under certain carefully defined and "con trolled conditions.

The specific nature of the program to control non-con Forming
types of land application of sludges will vary, but usually will
Include monitoring, abatement procedures and perodic reporting.
An abatement program must be capable of accomplishing its objective
vrithln a reasonable time, but in no case ir.ore than 5 years from
the start.

Regional Administrators should work closely with grant applicants
desiring to utilize such sludge in land application projects. Technical
assistance t" resolvo specific questions is available at EPA Headquarters,
tha EPA NERC's, especially the Advanced H-iste Treatment Research
'Laboratory, and the USDA Agricultural Research Service.
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1. 3. 2. Ground Water Protection

The land application system shall be so designed that the

permanent ground waters (ground v/ater which is not removed from

the ground by an urrderdrain system or other mechanical means)

which are In the zone of saturation (where the water 1s not

held in the ground by capillary tension) that result from the

application of sludge will not exceed the chemical quality

or pesticides levels for raw or uncreated drinking water supply

sources in tho EPA Manual for Evaluating Public Drinking Water

• Suppltes as below (except as noted in Paragraph V. 3. 2. 4.):

I. 3. 2. 1. Chemical Quality:
Units of Maximum Alloy/able
Measurements ' Limits

Arsenic ' rr.g/1 0.1
Barium • m'g/1 1
Cadmium
Chloride mg/1 250
Chromium mg/1 0.05
Copper mg/1 1
Cyanide
Hourlde , " mg/1 1.1
Foaming Agents as Methylene Blue mg/1 0.5
Active Substances
Iron mg/1 0.3
Lead mg/1 0.05
Manganese mg/1 0.05
Mercury
Nitrate Nitrogen mg/1 10
Carbon Absorboblc Organlcs-Carbon; mg/1 0.3
Chloroform Cxtractable (CCE)

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Effluent standards for the following toxic pollutants have been
proposed pursuant to s 307(a) of tiie Act. These p7~oposed standards
are being considered a-t public hearings, and will be promulgated at
the conclusion of the hearings. Any effluent standards promulgated
for these pollutants under s 307(a) will bo takon into account when
the standards proposed herein are promulgated or revised:
Cadmuirn
Cyanide
Mercury
Aldrin and Dieldrin
DDT
Endrin . .
Toxaphene
V
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1. 3. 2. 2.
Carbon Absorbable Organics -
Carbon: Alcohol Extractable
Selenium
Silver
Sodium
Sulfate
Zinc

Pesticides:
Units of
mg/1
mg/1
mg/l
mg/l
\
J
Maximum .Allowable
Limits

1.5

0.01
0.05
270
250
5
Units of
Maximum Allowable
C o n c g nj:. r a t i on
Chlordane
Heptachlor .
Heptachlor epoxide
Heptachlor and Heptachlor
epuxide
Lindano

Organcphosphate and carbamate
insecticides3
mg/1
2,4-0
2,4,5-f
2,4,5-TP
mg/l
mg/l

mg/l
mg/l
mg/l
mg/l
mg/l
mg/l
0.01
0:02
0.02
9.02

0.1
0.5
0.1
V
0.005
0.2
terms of parathion
ent cholinesterase Inhibition.
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1. 3. 2: 3. Any public drinking water standards hereafter issued by EPA which

prescribe maximum allov/able limits or permissible concentrations

of chemicals, radfoactive materials, or pesticides shall apply

In lieu of those in Paragraphs 1. 3. 2. 1 and 1. 3. 2. 2.

1. 3. 2. 4. If the presently existing concentration of any parameter 1s

higher in the ground v:atcr than the levels allowed above,

then the use of a land application technique should not result

in an increase in the concentration of that parameter.

1. 3. 2. 5. The soil depth to fissured rock, highly permeable gravels, or

ground water shall ba sufficient to prevent ground v;ater degrada-
>
tion. Because minimum vertical distances arc so dependant upon

"in s-itu" soil conditions, a thorough investigation of soil and

hydrogeologic conditions [by a qualified geohydrologistj is

required for each site where sludge is to be applied to the land.

To prevent solubilization and migration of metal ions, the pM

of the combined soil and sludge should be above 6.5 at all times.

1. 3. 3. Control 1 i tig Su rf acpv Vh tor Runoff

Surface water runoff must be controlled to pr-vent contravention

of water quality standards v.'hich might be produced by the migration

of sludgr material Into receiving bodies of v;ater. Containment
X.7
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and controlled release of runoff from sludge application
areas, or effective erosion control methods, must be
.practiced as necessary. Technical advice on erosion control
js available from the Soil Conservation Service, U.S. Depart-
ment of Agricultura.

I. 3. 4. Crops Suitable for Sludge Application.
I. 3. 4. 1. Crops vary widely in their reaction to sludge enriched soils.
The particular crop species iray be adversely affected by trace
elements in the sludge. Additionally, the crop may take up
and concentrate certain of these trace elements, thereby
inhibiting future use of the harvested materials (particularly
in the human food chain). The reaction of a specific crop to
sludge application is extremely site dependent. Factors such
as soil type, pH ..moisture content, climate, and crop species
are important. For advice concerning crops which can be
satisfactorily grown in sludge enriched soils, the local re-
presentatives of the U.S. Department of Agriculture should be
consulted.
I. 3. 4. 2. To date the practice of sludge spreading in forests has been
limited, tlov/over, forests offer opportunities for beneficial
use of sludge to improve soil fertility and increase tree
x *
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growth. With most tree species nutrient uptake is small comr

pared to that of cultivated crops, however in the case of some

species, intensive culture operations for the production of

• «
wood fibre is possible. High application rates {in excess,

of about 15 tons of dry solids per year per acre) might re-

quire nitrogen removal to prevent nitrate pollution of ground-

water.

I. 3. 5. Application Rates.

I. 3. 5. 1. The sludge application rate per unit of acre must be managed

to ensure that environmental requirerr-ents are !t\it.

It is not possible to give a rate, or even an upper limit, which

would be universally applicable, since the limit varies widely

and must be determined for each site.

I. 3. 5. 2. Nitrogenous substances usually limit annual application rates.

The folios'/ing factors must be estimated.

?.. Total nitrogen balance ,including nitrogen applied, plant

uptake, loss through volatilization or denitrification , recycling
k»

from decaying plant matter, and potential for nitrate migration

to the ground v/ater.

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b. Quantity and persistance of ammonia compounds since
excess amounts are toxic to some seeds. Two weeks cessation •
of application before seeding has been adequate.

It is possible that lha presence in the sludg? of certain
salts, phosphorous compounds, metals, radionuclides and
other materials may also limit application rates in specific
instances. Each propsective land application should be
assessed on a case-by-case basis vnth consideration given
to both local sludge and soil characteristics.
1. 3. 5. 3. Sludge is generated relatively constantly throughout the
year. "The application rate must be harmonized with the crop
*
growing season. A mass balance is necessary to determine the
amount of sludge storage required, including an allowance for
climate conditions or other unusal conditions, during intervals
when the sludge is not applied to the land.

1. 3. 6. Monitoring
A plan must be developed and implemented to provide for adequate
monitoring of each land application site. Uhere application
rates will not exceed 5 dry tons/acre/year for liquid digested
sludge, or 50 dry tons/acre/year over a three year period for
17
3 6
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dried or dewatered sludge, the sits uxmitoring requirements
may be reduced,'considering the size of the site, and the
• potential for problems or adverse long term effects. This
- plan must bs specifically designed for applicable local con-
ditions, and is to include (but is not limited to):
a. Ground water observation wells, surface water, sludge,'
and soils: nrionitor for heavy metals, persistent organics,
pathogens, and nitrates.
b. Human food chain products grown 1n sludge aided soil:
heavy metals, persistent organics, and pathogens.

Group II: Sludge Disposal Methods
2. San itary Landf i 11 o f sludge containingjTO_freq moisture, either
separately or along with mixed municipal solid waste is an
environmentally acceptable method for the disposal of sludge.

2. 1. Stabilization
The sludge must bs stabilized as described for land application
- in order to prevent nuisance and reduce hazards to those working
in the area.
I. 2. La_nd_f11 'I Procedures
2. 2. 1. A sanitary landfill accepting sludge must be designed and operated
1n accordance with EPA Guidelines for land Disposal of Solid
10
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Wastes (40 CFR 241). While It is recognized that the Guide-
lines were developed for solid waste at Federal facilities,
a sanitary landfill accepting sludge must comply with all the
requirements and recommendations contained in the Guidelines.
i
2. 2. 2. If a sanitary landfill accepting sludge is not operated by
the waste water treatment authority, a written contract, or
binding agreement is required betv;een the wastewater treatment
authority and the operator of the sanitary landfill. Such
• binding agreeiDent shall include necessary assurances of
compliance with the requirements and recommendations of the
. ^Wb Owl dell nes (40 CFR 241).
2. 3. Precautions o •
2. 3. 1. Protection of Public Health
Sludge stabilization and the daily soil cover are generally
adequate protection from direct health hazards.-
2. 3. 2. Ground Water Projection
The. qround water underlying the sanitary landfill accepting
sludge must be protected against degradation, and the sanitary
19
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landfill must meet the ground water protection requirements .

2. 3. 3. Monitoring
A plan must be developed and implemented to provide for adequate
/
monitoring of each sanitary landfill accepting sludge. This
plan must be specifically designed for applicable local con-
ditions, and is to include:
a. Ground water observation wells tested for jiea_vy_metals,
persistent organics, pathogens, and nitrates.
b. Surface water monitoring tested for COD and total .
dissolved solids. Additional testing may be necessary if
it is determined'that leachate is entering surface waters.
3. SIgdge Incineration and Disposal .of the Resi.iltjng Ash is an
environmentally acceptable method for the disposal of sludge.
Incineration alone is a volume reduction method rather than
ultimate disposal. After incineration there remains ash,
either dry or in scrubber water, to be disposed of in a properly
operated sanitary landfill..
3. 1. Industrial wastewaters introduced into a municipal wastev/ater
treatment works, which practices sluciga incineration, must be
pretreated to reduce to a minimi;!?! the? amounts of he e/y metals
20
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radioactive materials and persistent organics such as pesticides
and polychlorinated biphenyls. In developing pretreatment
programs, special attention must be inade to the disposal of
. sludges created or materials removed during the pretreatment
, process. Disposal of these materials must be in an environ-
mentally sound manner.

3. 2. The emissions from the sludge incinerator must meet the EPA
Air pollution emission standards of performance contained in
the New Source Performance Standards for Sludge Incinerators
. (40 CFR 60). These emission limits are based on a venturi
scrubber, but any similan-equipiisnt which meets the standard
• is acceptable. Sludge incineration 1s knowi to vaporize any
mercury present in the incoming sludge. EPA is now investigating
the naed for a mercury standard for sludge incineration. If
such regulations are promulgated, sludge incineration will be
acceptable only if assurance can be made that mercury eir^m'ssion
limitations will be met, for the specific case. In the interim,
pretrea'tifisnt requirements should be imposed to eliminate
mercury in municipal wastewatcrs from industrial or institu-
•>
tional sources.
21
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3. 3. The incinerator must be so designed as to produce an operational
temperature of 1600° F and minimum residence time at that
temperature of 2 seconds or an equivalent combustion condition
which accomplishes the purpose of destroying organic com- • '
* . .
pounds, such as polychlorinated biphenols, for all combustion
gases generated during the combustion process.

3. 4. A plan must be developed and implemented to provide for adequate- -
monitoring of each sludge Incinerator. The stack gas emissions
from sludge Incinerators must be monitored to ensure compliance
. with 40 CFR 60. Additionally mercury 1n stack gas emissions
must be monitored and waste water from industrial users' must
be monitored if it is determined that, such users will be a sign-
ificant source of mercury in the municipal sludge.
j 4. Ocean Disposal of sewage sludge is .considered acceptable for
treatment works presently using this method v;hen tha sludge
-meets the criteria specified in 40 CFR 227. When the sludge
exceeds the criteria, ocean disposal will be permitted only
, on an interim basis and subject to £>n approved implementation
plan to eliminate the materials han-rful to the marine environment.
:. 1. The Kedcral Water Pollution Control Act Ai.x-ndrant of 1972 (PL 92-500)
and the Marine Protection, Research and Sancturaries Act of 1972
22
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'.t
(PL 92-532) have established a Federal program of marine
pollution abatement-and control. EPA has issued regula-
tions and criteria (40 CFR 220-227) to govern the disposal
of wastes to the marine environment, EPA controls such
disposal by a system of permits for the discharge, trans-
portation, and dumping of all waste materials into the'marine
environment (except for dredged material„ which is controlled
by the Corps of Engineers).

4, 2. Ocean disposal of sewage sludga is strictly controlled by EPA.
Currently EPA will approve only existing dumping sites presently
in use of the disposal of particular kinds of waste, unless
»
there is extremely strong evidence in favor of approval of
a new location.
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