&EPA
                       United States
                       Environmental Protection
                       Agency
                                 Office of Health and Environmental
                                 Assessment
                                 Washington, DC 20460
                       Research and Development
                                 EPA/600/S6-90/001  Sept. 1990
Project Summary

Development  of Risk
Assessment  Methodology for
Surface  Disposal of Municipal
Sludge
                        This is one of a series of reports
                      that  present  methodologies  for
                      assessing the potential  risks  to
                      humans or other organisms from the
                      disposal or reuse of municipal
                      sludge.  The sludge management
                      practices addressed by this series
                      include land application practices,
                      distribution and marketing programs,
                      landfilling, surface  disposal,
                      incineration  and ocean  disposal. In
                      particular, these reports  provide
                      methods for evaluating potential
                      health and environmental risks from
                      toxic chemicals that may be present
                      in sludge. This document addresses
                      risks from chemicals associated with
                      surface disposal of municipal sludge.
                      These proposed risk  assessment
                      procedures are designed as tools to
                      assist  in the  development  of
                      regulations for sludge  management
                      practices.  The procedures  are
                      structured to allow calculation  of
                      technical  criteria for  sludge
                      disposal/reuse options based on the
                      potential for  adverse health  or
                      environmental impacts.   The criteria
                      may address management practices
                      (such as site  design  or process
                      control specifications), limits on
                      sludge disposal rates or limits on
                      toxic chemical concentrations in the
                      sludge.
                        This  Project  Summary  was
                      developed by EPA's Environmental
                      Criteria  and Assessment Office,
                      Cincinnati,  OH,  to  announce key
                      findings of the reseach project that is
                      fully documented in a separate report
                      of the same  title (see Project Report
                      ordering information at back).
                                 Introduction
                                   This document addresses health and
                                 environmental  risks associated with
                                 human and non-human exposure to
                                 chemical contaminants in sludge from the
                                 surface disposal of municipal sludge, and
                                 explains  the  development of  a
                                 methodology by which criteria for sludge
                                 surface disposal may be derived.  The
                                 term "surface  disposal" refers  to the
                                 permanent disposal or long-term storage
                                 of  sludge in  uncovered  lagoons  or
                                 impoundments.   Included  in  the
                                 methodology are facilities at which
                                 sludge  accumulates and is  stored for
                                 long periods as a result of the  use of
                                 lagoons for wastewater treatment.  A
                                 lagoon or impoundment is an earth basin
                                 used to deposit untreated or digested
                                 sludge. Anaerobic and aerobic digestion
                                 stabilize organic solids  in untreated-
                                 sludge  lagoons.  Stabilized solids settle
                                 and accumulate at the  bottom  of the
                                 lagoon.
                                   No national  survey  has yet been
                                 calculated  to identify the  number  of
                                 plants  using surface disposal or  to
                                 estimate the volumes of sludge stored or
                                 disposed in this manner.  However, 679
                                 plants participating in the  1986  Needs
                                 survey  reported using forms of sludge
                                 treatment  and  disposal other than
                                 landfilling,  distribution and marketing,
                                 land application, incineration" and ocean
                                 disposal. Some of these plants may have
                                 engaged in practices that fit the definition
                                 of surface  disposal.  Furthermore, 727
                                 plants reported  having sludge lagoons,
                                 although some of these may have been
                                 used for temporary storage or treatment
                                 and are thus not included in the surface
                                 disposal definition.

-------
Types of Impoundments
  The impoundments to be  considered
in this document can be categorized into
three groups: lagoons  for  long-term
storage, lagoons for permanent disposal,
and  wastewater treatment lagoons  in
which sludge is stored for  long periods.
Each of these types of  facilities  is
discussed briefly below.
  Wastewater  treatment  plants may
store sludge from primary, secondary, or
tertiary treatment processes  in lagoons,
with  the intention of later exhuming  the
sludge for  ultimate reuse or  disposal
elsewhere.   In  most cases, sludge  is
periodically removed from the  facility,
although the frequency of such removal
will vary among facilities.
  Long-term sludge storage may serve a
number of purposes. Sludge storage may
be an integral part of a plant's  overall
sludge management plan.  For  example,
sludge may be stored in impoundments
over the winter until  weather conditions
permit land  application.   Storage  of
sludge will  also tend to decrease water
content, thereby decreasing hauling costs
when  the  sludge  is  exhumed  for
permanent  disposal elsewhere.  Smaller
plants  may store sludge to  accumulate
quantities  that can  be  practically
disposed   or reused.    Storage
impoundments may  also  be  used
intermittently, in emergency situations,
when  normal  sludge  management
operations are overwhelmed.
   Although they  are  not  technically
"disposal"  facilities,  lagoons for long-
term storage  of  sludge have  been
included in methodologies for deriving
criteria  for "surface  disposal"  for two
reasons.  First, this practice may pose
health and  environmental risks as severe
as or worse than  those associated with
permanent disposal.   Second,  future
plans for removing sludge from "storage"
impoundments may be uncertain.   As
economic  or  regulatory  conditions
change, plans for the  removal of sludge
from "temporary"  impoundments have
also been  known  to change. Since the
ultimate  fate of sludge stored  in such
impoundments cannot be known with
certainty, analysis of risks associated with
their continued or permanent existence is
appropriate.
   In certain  cases, sludge  may  be
deposited  in  on-site impoundments
without further planning  for  removal.
Permanent surface disposal  may be the
only practical disposal option for plants
that have accumulated  very  large
quantities of sludge onsite over a number
of years. It may also become  the de facto
disposal method for  plants that fail to
identify satisfactory final disposal options
for the sludge currently stored in lagoons.
Wastewater treatment  lagoons are  often
used  by small  wastewater treatment
facilities because they are less expensive
than alternative treatment processes.
Because such lagoons typically receive
relatively low volumes of  wastewater,
they can accumulate sludge in a bottom
layer for years (or even decades) before
it begins to  interfere  with the treatment
process. Although the main  purpose of
these lagoons  is  to  treat wastewater
before discharge, the  lagoons also  serve
as long-term storage for the sludge, and
may fall within  the definition of surface
disposal of  sludge.   In  addition, the
lagoons are  sometimes aerated, leading-
to increased  volatilization  of sludge
contaminants

Assumptions Used in Risk
Assessment
   The  purpose of a sludge storage or
disposal impoundment influences the
manner in which the sites are managed.
For example,  sludge  in impoundments
used for storage between land application
seasons will  be emptie'd more frequently
than sludge  from wastewater treatment
lagoons at small plants. All of the surface
disposal practices  described here pose
potential risks from   human  and non-
human  exposure.  Each  practice also
possesses unique features that affect its
associated  risks.  Long-term  storage
impoundments  undergo periodic sludge
removal, which may increase or decrease
movement of sludge  contaminants into
the environment.   Permanent disposal
impoundments  might  present  risks
through future land uses of the disposal
site (although  these risks  are not
considered by the present methodology).
There  follows  a  brief  listing  ~6T
assumptions  used for estimating risks
from  these sludge  management
practices:
   1.    Sludge storage  or  disposal
        occurs on plant  property, and
        the  public has no  access  to the
        affected areas.
   2.    Sludge  impoundments will be
        required to have berms, dikes or
        other surface  runoff controls that
        effectively eliminate significant
        risks of exposure from flooding
        or accidental releases.
   3.    Periodic removal  of sludge from
        long-term storage lagoons  allows
        their  continuous  use  over
        extended periods of time.
   4.   Sludge that accumulates in long-
        term  storage  or  wastewater
        treatment  lagoons  is  removed
        prior to plant closure, and  before
        any conversion of  the land to
        other uses can take place.
   5.   Sludge deposited in permanent
        disposal  lagoons  is   never
        exhumed.

 Conditions Affecting Risk
   A number of environmental conditions
 and management  practices affect the
 risks posed by  long-term sludge storage
 impoundments. Management  or  design
 requirements can  be developed,  based
 on an evaluation of the following factors,
 to minimize risks from surface disposal:

   1.   Concentrations of contaminants
        in the  sludge will influence the
        magnitude of risk posed by long-
        term  sludge  storage  or
        permanent disposal.
   2.   Physical characteristics, such as
        distance to  groundwater  and
        surface water,  soil  type  and
        other geohydrologic features of
        the site, and  proximity to  human
        or non-human  populations will
        influence the rate of migration of
        contaminants  and the potential
        for exposure.
   3.   The length of time  sludge is
        stored (i.e.,  the frequency of
        sludge  removal  from  the
        impoundments) may  affect the
        mobility of sludge contaminants.
        Frequent removal may decrease
        the  length  of time sludge
        contaminants  are available  for
        leaching, but could also  disturb
        the underlying stabilized  sludge
        layer  that  may   inhibit
        contaminant  movement from
_..._,.,  ——unlined impoundments.    •-   —
   4.   The use  of synthetic or  clay
        liners will  reduce the potential
        for contaminant movement into
        groundwater.
   5.   The use of  berms  and  proper
        siting  can  reduce  risks
        associated with surface  runoff
        and flooding.
   6.   For permanent disposal facilities,
        restrictions on future access and
        land use through a notice in the
        deed may be required once the
        facility  is  closed  in  order to
        prevent inadvertent direct  human
        contact with  disposed  sludge.
        Alternatively, the sludge disposal
        area may  be encapsulated at
        closure in order to prevent future

-------
        direct contact with sludge if land
        is converted to another use.
   7.    Aeration of wastewater treatment
        lagoons  will   affect  the
        volatilization  and  biodegradation
        rates of the  organic  sludge
        contaminants.
   Improper management practices at a
particular facility can result in additional
risks to human health or the environment;
the methodology presented here does
not include techniques for assessing risks
associated  with  such  practices.
Differences in potential risk associated
with siting  of surface disposal  facilities
are considered  by the methodologies
insofar as they can be represented by the
input parameters  required for model
calculations.

Summary
   The methodology  presented in this
document is  designed  to  derive criteria
for lagoons  used  for  both  long-term
storage  and  permanent  disposal  of
sludge.   The methods are intended  to
apply to all types of municipal wastewater
sludges, regardless  of the  extent  of
industrial  contribution to  the  treated
wastewater, and regardless of the type of
wastewater treatment  processes that
generate the  sludge.  Risks from these
surface  disposal facilities can  occur
through a variety of pathways of  potential
human and non-human exposure.  This
document  discusses the  selection  of
pathways  for  inclusion   in  this
methodology, and  the  identification  of
"most exposed  individuals" and  "most
exposed  populations"  at  greatest risk
through  each pathway, and provides  a
detailed discussion  of   methods  for
assessing  potential risks  and  deriving
criteria for  the three  exposure pathways
thought  to  be of  most  concern:
groundwater, surface water, and air.
                                                                            it\). S. GOVERNMENT PRINTING OFFICE: 1990/748-012/20111

-------
   Norman Kowal is the EPA Project Officer (see below).
   The complete report, entitled "Development of Risk Assessment Methodology
        for Surface Disposal of Municipal Sludge," (Order No. PB 90-261 561/AS;
        Cost: $31.00, subfect to change) will be available only from:
            National Technical Information Service
            5285 Port Royal Road
            Springfield, VA 22161
            Telephone: 703-487-4650
   The EPA Project Officer can be contacted at:
            Environmental Criteria and Assessment Office
            U.S. Environmental Protection Agency
            Cincinnati, OH 45268
United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
Official Business
Penalty for Private Use $300

EPA/600/S6-90/001

-------