v-xEPA
United States
Environmental Protection
Agency
Office of Wastewater Enforcement
and Compliance, Office of Water
Washington, DC 20460 November 1991
Guidance for NPDES
Compliance Inspectors
Verifying Compliance
with Sludge Requirements
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GUIDANCE FOR NPDES INSPECTORS:
VERIFYING COMPLIANCE WITH SLUDGE REQUIREMENTS
November 1991
Submitted to:
U.S. Environmental Protection Agency
Office of Water Enforcement and Permits
401 M Street, SW
Washington, DC 20460
Submitted by:
Science Applications International Corporation
7600-A Leesburg Pike
Falls Church, VA 22043
EPA Contract No. 68-C8-0066, WA Nos. C-2-6 (E) and C-3-6 (E)
SAIC Project Nos. 1-834-03-606-01 and 1-834-03-2156-001
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ACKNOWLEDGEMENTS
This document was prepared under the technical direction of Lee Okster, Enforcement Division,
Office of Water Enforcement and Permits, U.S. EPA. Assistance was provided to EPA by Science
Applications International Corporation of McLean, Virginia, under EPA Contract No. 68-C8-0066.
Susan Moore led the SAIC effort under Work Assignment Nos. C-l-11 (P), C-l-41 (P), C-2-6 (P),
and C-3-6 (P). The principal authors are Lee Okster, Susan Moore, and Mark Klingenstein.
EPA's objective in developing this document was to provide guidance to NPDES inspectors for
conducting inspections of facilities which have sludge conditions established in their NPDES permit.
Special thanks are also extended to the review team for their time and effort to ensure that this
document was as useful as possible. This review team included Bob Brobst, Sludge Coordinator for
EPA Region 8; John O'Grady, Sludge Coordinator for Region 5; Robert Heiniger, Solid Waste
Enforcement Division, Maryland Department of the Environment; Anne Lassiter, Mark Charles, and
Robert Bastian of the Office of Wastewater Enforcement and Compliance, U.S. EPA; Dianne
Stewart, Jessica Kaplan, Mary Waldron, Bob Linett, and Ruth Much of SAIC.
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TABLE OF CONTENTS
Page
1. INTRODUCTION 1-1
Background on the Interim Sludge Program 1-1
Scope of Inspection Activities in the Interim Period 1-3
Purpose and Use of This Manual 1-4
Incorporation of Sludge Into NPDES Inspections 1-5
2. REPORTING AND RECORD-KEEPING 2-1
Introduction 2-1
Evaluation Procedures 2-2
Checklist 2-8
3. FACILITY SITE REVIEW 3-1
Inspection of Solids Handling Unit Processes 3-1
Sludge Management Issues 3-1
Checklist 3-5
4. SAMPLING AND LABORATORY QUALITY ASSURANCE 4-1
Sampling Procedures and Techniques 4-1
Laboratory Analysis and Quality Assurance 4-7
Checklist 4-10
APPENDIX
APPENDIX A - BIBLIOGRAPHY
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LIST OF TABLES
Page
2-1 Records Relevant for Sludge Operations 2-3
2-2 Operating Records for Specific Unit Processes 2-4
2-3 Cadmium Loading Limits for Fields on Which Tobacco or Food Chain
Crops are Grown 2-6
2-4 Operating Parameters for Achieving Pathogen Reduction 2-7
3-1 Sludge Handling Process Evaluation 3-2
4-1 Sludge Sampling Points 4-3
4-2 Sludge Flow Measurement Devices 4-4
4-3 Containers, Preservation, Holding Times, and Minimum Sample Volumes 4-5
4-4 Recommended Preparation Technique for Elemental Analysis of
Sludge Samples 4-9
111
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LIST OF ACRONYMS
Acronym
BOD
CEC
CEI
CFR
CSI
CWA
DI
DMR
DO
EPA
g
HA
H2S04
HC
HC1
HNO3
kg/ha
meg/100 g
ml
NA2S2O3
NESHAP
NPDES
O&M
OW
Term
Biochemical Oxygen Demand
Cation Exchange Capacity
Compliance Evaluation Inspection
Code of Federal Regulations
Compliance Sampling Inspection
Clean Water Act
Diagnostic Inspection
Discharge Monitoring Report
Dissolved Oxygen
U.S. Environmental Protection Agency
gram
Hydrogen peroxide
Sulfuric acid or sulfate
HC - Hydrocarbon
Hydrogen chloride
Nitric acid -"
Kilograms per hectare
milli-equivalents per 100 grams
milliliters
Sodium thiosulfate
National Emissions Standards for Hazardous Air Pollutants
National Pollutant Discharge Elimination System
Operation and Maintenance
Office of Water
IV
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LIST OF ACRONYMS (CONTINUED)
Acronym
PAI
PCB
PFRP
POTW
PSRP
QA/QC
QA
QC
RI
SOUR
TCDD
TS
TSS
TVS
VSR
Term
Performance Audit Inspection
Polychlorinated Biphenols
Process to Further Reduce Pathogens
Publicly Owned Treatment Works
Process to Significantly Reduce Pathogens
Quality Assurance/Quality Control
Quality Assurance
Quality Control
Reconnaissance Inspection
Specific Oxygen Uptake Rate
2, 3, 7, 8 tetrachloro-p-dioxin
Total Solids
Total Suspended Solids
Total Volatile Solids
Volatile Solids Reduction
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1. INTRODUCTION
Background on the Interim Sludge Program
Section 405 of the Clean Water Act (CWA) mandates the development of a Federal sludge
management program. This mandate requires the U.S. Environmental Protection Agency (EPA) to
focus sludge management efforts on three key activities. The first activity is the development of
regulations governing the issuance of Federal permits to treatment works for the disposal of sewage
sludge. In response, EPA developed two permitting mechanisms, the National Pollutant Discharge
Elimination System (NPDES) Sewage Sludge Permit Regulations and the State Sludge Management
Program Requirements Final Rule [40 Code of Federal Regulations (CFR) Parts 122, 123, 124, and
501]. These rules, promulgated on May 2, 1989, provide the legal and programmatic framework for
a National sludge use and disposal program by establishing the requirements and procedures for
addressing sludge management in Federal permits issued by EPA or an approved State. Under the 40
CFR Part 501 rule, States that are granted approval to administer the sludge program have the option
of issuing sludge permits under authorities outside of the NPDES program. Therefore, once States
are approved to administer the sludge program and begin to issue sludge permits, the inspector must
be aware of the possibility that the permit mechanism which imposes the requirements for sludge
management could be outside of the NPDES program.
The second activity mandated is the development of regulations establishing standards for the
final use and disposal of sewage sludge. These technical sludge regulations were proposed on
February 6, 1989, in 40 CFR Part 503, and are scheduled to be promulgated in early 1992. The final
activity mandated is the imposition of sludge conditions in permits issued to Publicly Owned
Treatment Works (POTWs) prior to the promulgation of the 40 CFR Part 503 technical sludge
regulations.
In September 1989, the Office of Water (OW) issued the final Sewage Sludge Interim
Permitting Strategy. This strategy outlines EPA's policies for implementing the requirements of
CWA Section 405(d) in the period prior to the promulgation of the final technical sludge regulations.
It centers around the requirements for sludge management that are to be imposed in NPDES permits
issued to POTWs. To implement the requirements of Section 405(d)(4) of the CWA, the strategy
requires that:
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All NPDES permits issued to POTWs must require that the permittee comply with all
existing Federal regulations governing the use and disposal of sewage sludge
All permits must contain a reopener clause to be used on promulgation of the 40 CFR Part
503 technical regulations to incorporate these requirements into the permit
The permittee must notify the permitting authority of any significant change in its sludge use
or disposal practice
All permits must contain sludge monitoring requirements
All permits issued to Class I POTWs1 must contain additional conditions developed on a
case-by-case basis.
The Interim Strategy and the 40 CFR Parts 122, 123, 124, and 501 rules establish the policy and
regulatory framework for managing sludge prior to the promulgation date of the technical sludge
regulations.
This guidance establishes the framework for conducting inspections of facilities with sludge
requirements established in accordance with the existing regulations and the Interim Strategy. Once
the 40 CFR Part 503 regulations are promulgated, facilities will be given 1 year to comply with the
standards for final use or disposal set forth in the rule (or 2 years if construction is required to
comply). Until the compliance date of the 40 CFR Part 503 rule, the scope of sludge management
and EPA or State inspections will be dictated by the conditions established under the existing
regulations and the Interim Strategy. Therefore, even after promulgation of 40 CFR Part 503, this
guidance will be useful in assisting the inspector, since the compliance date for the technical standards
is not until 1 year after promulgation of 40 CFR Part 503.
'40 CFR 122.2 Class I sludge management facility means 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 elected to assume local program responsibilities pursuant to 40 CFR 403.10(e)] and
any other treatment works treating domestic sewage classified as a Class I sludge management facility
by the Regional Administrator, or in the case of approved State programs, the Regional Administrator
in conjunction with the State Director, because of the potential for its sludge use or disposal practices
to adversely affect public health and the environment.
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Scope of Inspection Activities in the Interim Period
During the interim sludge program, inspectors will be required to verify compliance with the
following general activities:
• Sludge monitoring, record-keeping, and reporting
• Sludge treatment operations
• Sludge sampling and laboratory Quality Assurance (QA).
During the interim period, NPDES inspectors will not be required to conduct an in-depth
compliance assessment of sludge final use and disposal practices when such practices occur away
from the treatment plant. In situations where final use and disposal requirements have been
established in the facility's NPDES permit (e.g., annual and cumulative pollutant loading rates) and
the activity is offsite, the inspector must verify compliance with those requirements through a records
review at the facility. In addition, during the interim period, the inspector will not be required to
sample the sludge to determine compliance with permit conditions. However, the inspector always
has the option of conducting sampling if it is deemed necessary to evaluate the performance of the
permittee.
EPA intends to focus sludge inspection activities during the interim period on those aspects of
sludge management which can easily be evaluated during an existing NPDES compliance or
pretreatment inspection. Inspectors will rely on an evaluation of sludge treatment operations, the
observation of onsite sludge storage and disposal activities, and the review of sludge monitoring and
disposal records, to identify actual and potential noncompliance with sludge requirements. EPA
encourages inspectors to document compliance or noncompliance with sludge final use or disposal
requirements when these activities occur onsite.
EPA recognizes that the incorporation of sludge conditions into NPDES permits involves
additional compliance monitoring and enforcement responsibilities for EPA Regions and approved
States. Verifying compliance with applicable permit requirements related to sludge, however, is
essential to implementing the sludge program effectively. The existing NPDES compliance
inspections are the best vehicles for evaluating compliance with sludge permit conditions; and,
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therefore, training NPDES inspectors to evaluate the permittee's sludge treatment, monitoring,
sampling, record-keeping, and reporting activities is critical to the success of the sludge compliance
monitoring and enforcement program.
Purpose and Use of This Manual
The purpose of this guidance document is to assist NPDES inspectors in conducting a
verification of compliance with permit requirements applicable to sludge in the interim period prior to
the compliance date of the 40 CFR Part 503 regulations. This document supplements the existing
guidance for conducting NPDES inspections (EPA's 1988 NPDES Compliance Inspection Manual)
with additional information on verifying sludge record keeping and reporting; conducting a facility
site review of sludge treatment activities; and evaluating sludge sampling procedures to verify the
permittee's compliance with sludge management requirements.
In addition, a short checklist is provided at the end of each chapter which should be used to
guide the inspector during his/her evaluation of various sludge management activities. These
checklists should be used in conjunction with the checklist questions found in the NPDES Inspection
Manual. The NPDES compliance inspector should consult the NPDES manual and this guidance
when preparing to conduct an inspection at a POTW that has sludge conditions incorporated into its
NPDES permit. On completion of the inspection, the inspector should complete the checklist at the
end of each chapter and include these findings in the final inspection report.
Chapter 2 examines the permittee's monitoring, record-keeping, and reporting requirements,
and establishes systematic procedures for verifying compliance with those requirements. Chapter 3
provides information on evaluating the sludge treatment train, including the Operation and
Maintenance (O&M) of sludge handling equipment. A basic discussion on assessing sludge
management procedures is also included. Chapter 4 presents information on sampling procedures and
analytical techniques for sludge, as well as a discussion on laboratory QA as it relates to sludge
analysis.
In addition to this guidance, an accompanying technical reference document (EPA's 1991
Guidance for NPDES Compliance Inspector: Evaluation of Sludge Treatment Processes) presents a
detailed examination of sludge unit processes. This technical reference also contains extensive
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technical checklists which summarize the most critical elements of sludge thickening, stabilization,
conditioning, dewatering, and disinfection. This detailed technical guidance is provided separately to
acquaint water inspectors with the techniques used in processing and handling sludge. This technical
understanding of the sludge treatment train is essential for conducting thorough and informed sludge
inspections.
Incorporation of Sludge Into NPDES Inspections
EPA currently uses several types of inspections to evaluate compliance with various NPDES
program requirements. The evaluation of sludge management activities should be incorporated into
the existing inspection structure in the interim period so that inspection resources can be used most
efficiently. The inspector can identify and investigate problems that might contribute to
noncompliance with sludge requirements during any inspection site visit [e.g., during a Compliance
Sampling Inspection (CSI) or a Diagnostic Inspection (DI)]. However, the Compliance Evaluation
Inspection (CEI) and the Performance Audit Inspection (PAI) are the most likely vehicles for
evaluating compliance with sludge requirements. The NPDES inspector should use one of these
vehicles when conducting his/her evaluation of sludge management activities, but may use any of the
existing NPDES inspections when evaluating sludge requirements (e.g., the CSI may be used if the
inspector decides that sampling is necessary to determine compliance with applicable requirements).
Generally, during the Interim Period, the inspector will only be evaluating compliance of the
permittee's sampling and analysis activities. The inspector is not required to conduct sludge sampling
to determine compliance with permit conditions, but he/she always has the option of conducting
sampling if it is deemed necessary to evaluate the performance of the facility. The inspector,
however, must be able to evaluate the facility's self-monitoring process. Therefore, Chapter 4
discusses sludge sampling procedures and analytical techniques in detail so that the inspector is able to
determine if a facility is appropriately sampling and analyzing its sludge.
The CEI is a nonsampling inspection designed to verify permittee compliance with applicable
permit self-monitoring requirements and compliance schedules. This inspection involves record
reviews and cursory visual observations, as well as examinations and evaluations of the wastewater
treatment facility, its effluent, and receiving waters. The CEI forms the basis for all other types of
inspections except the Reconnaissance Inspection (RI). The inspector has historically looked at sludge
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treatment as part of the CEI because of its effect on wastewater treatment. This evaluation of sludge
treatment should be expanded to include a review of sludge monitoring, reporting, and record
keeping, and a more comprehensive evaluation of the O&M of sludge treatment processes, to evaluate
compliance with sludge permit requirements. Chapters 2 and 3 of this document provide guidance on
addressing sludge compliance through the CEI inspection vehicle.
The PAI is an in-depth evaluation of the permittee's self-monitoring program. As with a CEI,
the inspector makes a cursory visual observation of the treatment facility. The focus of the PAI,
however, is to verify the permittee's reported data through a records check and evaluation of the
permittee's sludge sampling and analytical procedures. In a PAI, the inspector observes the
permittee's self-monitoring process from sample collection and flow measurement, through laboratory
analyses, data work-up, and reporting. The inspector often leaves a check sample for the permittee to
analyze, but does not perform independent sample collection and analyses. The PAI may be
expanded to evaluate compliance with sludge monitoring requirements, as outlined in Chapter 4.
As with any NPDES inspection, the potential for enforcement through litigation should be
uppermost in the inspector's mind in all inspection activities, including sludge inspections. Therefore,
collecting and documenting the evidence needed to substantiate suspected sludge violations is also a
core inspection activity. The rules governing the admissability of evidence for the sludge component
of the inspection are the same as the rules for wastewater evidence collection and handling. The
NPDES inspector should already be familiar with the rules of evidence from the wastewater program,
and should apply those rules when conducting the sludge inspection.
An inspection checklist is an essential field tool for documenting that all necessary information
has been collected. Inspection checklists are included as part of this guidance document. However.
sludge permits may contain additional sludge permit conditions, based on case-by-case considerations.
that are not included on the checklist. The inspector should identify additional permit requirements
and verify compliance with these conditions as well. To accomplish this, it is recommended that the
inspector expand the checklist, if necessary, to ensure that it is specific to the NPDES permit and the
sludge final use or disposal activity. Additional blank question lines have been included at the end of
each checklist to allow the inspector to customize questions. The inspector should complete the
checklist at the end of each chapter to evaluate compliance with sludge permit conditions and should
incorporate his/her findings and conclusions in the final inspection report prepared for the facility.
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2. REPORTING AND RECORD-KEEPING
Introduction
Section 308 of the CWA provides Federal inspectors with general authority to verify a
permittee's compliance with reporting and record-keeping requirements. The existing sludge
regulations and the Interim Strategy require permittees to maintain records and periodically report on
the nature of the sludge produced at the facility. The facility's NPDES permit (or State-issued permit
under 40 CFR Part SOI) should establish the sludge reporting and record-keeping conditions required
by regulation or the Interim Strategy. An evaluation of these requirements should be conducted at all
permitted facilities to determine compliance with these record-keeping and reporting requirements.
The procedures listed below should be used for these routine inspections. If suspected violations are
uncovered during the routine evaluation, a more intensive investigation should be conducted.
During the interim sludge implementation period, the inspector will conduct file and record
reviews to determine compliance with established permit conditions. In this records review process,
the evaluation of compliance with sludge record-keeping requirements should consider:
• Is all required information available for review?
• Are all regulated pollutants and sludge use and disposal practices addressed?
• Is all sludge information current?
• Are sludge records maintained for at least 5 years from the effective date of the regulation?
• Does the information contained in sludge records support the data submitted to the
permitting authority?
• Do the records indicate areas needing further investigation?
The inspector should also identify whether violations of sludge-related permit requirements
(e.g., concentration limits and/or management practices) have been reported, as required by the
permit. Finally, the inspector should verify that the permittee has notified EPA of any changes to
sludge use or disposal practices.
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Evaluation Procedures
The inspector should first review the permit and fact sheet and list all sludge record-keeping
requirements. Table 2-1 is a list of records which may be relevant for sludge. This list is
supplemented by Table 2-2, which describes records relevant to the operation of specific sludge
treatment unit processes. Throughout the inspection, the facility's operations should be compared
with the permit conditions to verify that required permit activities for sludge are correct, current, and
complete.
If the facility's sludge is ultimately land-applied, 40 CFR Part 257 imposes specific
requirements on documentation. For example, the POTW must be able to provide evidence that the
annual and cumulative loading limits for cadmium have not been exceeded. These existing limits are
listed in Table 2-3. The inspector should also check for any applicable State regulations on additional
limits. The inspector must verify that the permittee maintains adequate records necessary to evaluate
compliance with the annual and cumulative loading rates derived from either 40 CFR Part 257 or
State regulations required by the NPDES permit. In addition, 40 CFR Part 257 specifies pathogen
reduction requirements (which are summarized in Table 2-4). The operating records of the facility
must indicate whether the process parameters for meeting the pathogen reduction requirements have
been satisfied. [NOTE: When the 40 CFR Part 503 regulations are promulgated, the pathogen
reduction requirements may be different than those outlined in Table 2-4. Therefore, after the
promulgation of 40 CFR Part 503, the inspector should review the requirements in the regulation and
compare them with the procedures presented in Table 2-4].
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TABLE 2-1. RECORDS RELEVANT FOR SLUDGE OPERATIONS
SLUDGE USE/DISPOSAL RECORDS
• Volume
• Type of use and/or disposal options used
• Use/disposal sites
• Loading rates of limited parameters (e.g., cadmium) at each land-application site
SLUDGE OPERATING RECORDS
• Daily operating log
• Equipment maintenance scheduled and completed
• Detention time, operating temperature, or pH to evaluate pathogen reduction
SLUDGE MONITORING RECORDS
• Constituents/pollutants in sludge
• Mass of sludge generated and disposed of (in dry metric tons per year)
SLUDGE SAMPLING AND ANALYTICAL DATA
Dates, times, and locations of sampling
Sampling protocols and analytical methods
Results of analyses
Dates and times of analyses
Name(s) of analysis and sampling personnel
SLUDGE LABORATORY RECORDS
• Calibration and maintenance of equipment
• Laboratory bench sheets or logs and calculations
Quality Assurance/Quality Control (QA/QC) records
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TABLE 2-2. OPERATING RECORDS FOR SPECIFIC UNIT PROCESSES
THICKENING PROCESSES
Gravity Thickening
• Overflow volume
• Influent flow
• Percent solids
- Sludge feed
- Thickened sludge
- Overflow
• Sludge blanket depth
Dissolved Air Flotation
• Sludge feed rate
• Recycle flow
• Daily operating time
• Percent solids
- Sludge feed
- Thickened sludge
- Subnatant
Floating sludge depth
Air flow rate
Retention tank pressure
Percent solids capture
Detention time
Air to solid ratio
Centrifuge
• Influent sludge flows
• Volume cake produced
• Percent solids
- Sludge feed
- Centrate
- Sludge cake
• Daily operating time
STABILIZATION PROCESSES
Aerobic Digestion
Air supply
Solids retention time
Temperature
DO level
PH
Feed sludge
- TS, TVS, andpH
- Flow rate
• Digested sludge
- SOUR
- TS, TVS, andpH
- Flow rate
• Supernatant
- Flow rate and BOD
- TSS and pH
Anaerobic Digestion
Detention time
Temperature
Ph and alkalinity
Gas production and quality
Volatile acids
Feed sludge
- TS, TVS, and pH
- Flow rate
• Digested sludge
- TS, TVS, and pH
- Flow rate
• Supernatant
- Flow rate and BOC
- TSS and pH
• Cleaning frequency
Incineration
Operating schedule
Sludge feed
- Solids content
- Feed rate
- Volatile solids
Combustion temperature
Sludge residence time
Fuel flow
Off-gas oxygen content
Air feed rate
Emission control equipment
- Pressure drop
Type of fuel
Volume of ash produced
Stack gas monitoring
Wet Air Oxidation
Temperature
• Pressure
• Detention time
• Sludge feed
- Percent solids
- Volatile solids
- Feed rate
• End product volatile solids
Heat Treatment
Temperature/time
• Pressure
• Feed sludge
- TS and TVS
- Flow Rate
- Percent solids
Composting
Oxygen concentration
• Temperature and time
• Turning frequency
• Percent sludge solids
• Type and amount of bulking
agent(s)
• Header pressure
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TABLE 2-2. OPERATING RECORDS FOR SPECIFIC UNIT PROCESSES (Continued)
CONDITIONING PROCESSES
Chemical Conditioning/Stabilization
• Chemical types and dosage
• Mixing
• pH
Vacuum Filter
• Sludge feed
- Total solids
• Sludge cake
- Total solids
• Filtrate
- Flow
- BOD
- TSS
• Maintenance
• Spare parts
DEWATERING PROCESSES
Pressure Filter
• Sludge feed percent
solids
• Sludge cake percent
solids
• Volume of sludge
processed
• Cycle length
• Volume conditioning
chemicals
• Filtrate
- Flow
- BOD
- TSS
Belt Filter Press
• Loading rate
• Operating speed
• Feed slurry
- Total solids and flow
• Dewatered sludge
- Total solids
- Flow
• Filtrate and wash water
- BOD and SS
- TSS and flow
• Preventive maintenance
• Polymer
Drying Bed
• Sludge loading rate
• Quantity in bed
• Depth of sludge in bed
• Date deposited
• Detention time
• Ambient temperature
• Drying bed construction
(i.e., lined)
• Undertrain destination
• Percent solids of the sludge feed
and of the dewatered sludge
Drying Lagoons
• Sludge loading rate
• Percent solids
- Sludge
- Decant
Quantity in lagoon
Depth in lagoon
Date deposited
Drying time
Rainfall
Heat Drying
• Operating schedule
- Startup
- Shut down
• Sludge feed rate
• Percent solids
- Sludge feed
- Dewatered sludge
• Fuel consumption
• Air flow
• Drying temperature
• Detention time
• Stack gas monitoring
- Oxygen
- Particulates
- Carbon monoxide
- Carbon dioxide
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TABLE 2-2. OPERATING RECORDS FOR SPECIFIC UNIT PROCESSES (Continued)
DISINFECTION PROCESSES
Electron Irradiation Gamma Irradiation
• Sludge feed rate
• Electron dosage
• Temperature
• Sludge feed rate
• Gamma ray source
strength
LEGEND
DO - Dissolved Oxygen
TS - Total Solids
TVS - Total Volatile Solids
BOD - Biochemical Oxygen Demand
SS - Suspended Solids
SOUR - Specific Oxygen Uptake Rate
TABLE 2-3. CADMIUM LOADING LIMITS FOR FIELDS ON WHICH
TOBACCO OR FOOD-CHAIN CROPS ARE GROWN
ANNUAL LOADING RATE-The annual application of cadmium from sludge must not exceed 0.5
kilograms per hectare (kg/ha).
CUMULATIVE LOADING RATE-The cumulative application of cadmium from sludge must not
exceed the values listed below, which depend upon the Cation Exchange Capacity (CEC) and pH of
the soil.
SOIL CEC
(meg/100 g)*
< 5
5-15
> 15
MAXIMUM CUMULATIVE APPLICATION (kg/ha)
BACKGROUND SOIL
pH < 6.5 pH > 6.5
5
5
5
5
10
20
*milli-equivalents per 100 grams
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TABLE 2-4. OPERATING PARAMETERS FOR ACHIEVING PATHOGEN REDUCTION
Sludge
Treatment Process
Aerobic digestion
Anaerobic digestion
Heat treatment
Wet air oxidation
Incineration
Composting
Lime stabilization
Air drying beds
Heat drying
Electron and gamma
ray irradiation
Pasteurization
Process to Significantly
Reduce Pathogens (PSRP)*
60 days at 15°C
40 days at 20°C
Volatile Solids Reduction (VSR) of at
least 38 percent
60 days at 20°C
15 days at 35 - 55°C
VSR of at least 38 percent
N/A
N/A
N/A
5 days at 40°C
Temperature must exceed 55 °C for 4
hours
pH of 12 after 2 hours of contact
At least 3 months with sludge piled to a
maximum depth of 23 cm/9 in.
Temperatures must average above 0°C on
a daily basis for 2 months
N/A
N/A
N/A
Process to Further Reduce
Pathogens (PFRP't**
10 days at 55 - 60°C; VSR of at
least 38 percent
N/A
180°C for 30 minutes
Must reduce pathogens to level
equivalent to other PFRPs
Must reduce pathogens to level
equivalent to other PFRPs
Vessel-3 days at 55 °C
Static aerated pile-3 days at 55°C
Windrow-15 days at 55°C with a
minimum of 5 turnings of pile
N/A
N/A
Sludge temperature > 80°C
Moisture content reduced to 10
percent
Dosage at least 1.0 megarad at
room temperature (20°C) (used in
conjunction with PSRPs, which
reduce volatile solids)
70°C for 30 minutes (used in
conjunction with PSRPs, which ,
reduce volatile solids)
*PSRPs reduce, but do not eliminate, pathogens. PSRPs typically achieve a 90 percent reduction in virus and
bacteria.
**PFRPs reduce pathogens to below detectible levels.
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SUPPLEMENTAL CHECKLIST QUESTIONS FOR SLUDGE
VERIFICATION, RECORD KEEPING, AND REPORTING EVALUATION CHECKLIST
A. PERMIT VERIFICATION
Yes No N/A 1. Notification is given to EPA/State of new or different sludge disposal method?
Yes No N/A 2. Accurate records of sludge volume are maintained, when appropriate?
Yes No N/A 3. Each sludge use or disposal practice is permitted?
Yes No N/A 4. Number and location of disposal sites/activities are as described in the permit or fact
sheet?
Yes No N/A 5. Monitoring and analyses are performed more often than required by the permit?
Yes No N/A If so, results are reported in the permittee's self-monitoring report?
B. RECORD-KEEPING AND REPORTING EVALUATION
Yes No N/A 1. Self-monitoring data are available for all regulated pollutants (annual and cumulative
loading)?
Yes No N/A 2. Records are available for all use or disposal practices?
Yes No N/A 3. Unit operation records verify compliance with pathogen reduction requirements, when
appropriate (as per 40 CFR Part 257)?
Yes No N/A 4. Self-monitoring is conducted at the frequency specified in the permit, at a minimum at
least once a year?
Yes No N/A 5. Facility reports sludge monitoring data at the frequency specified in the permit?
Yes No N/A 6. Sludge records are maintained for at least 5 years?
Yes No N/A 7. Sludge data are reported on Discharge Monitoring Report (DMR) or approved form?
Yes No N/A 8. Sludge records are adequate to assess compliance with annual and/or cumulative pollutant
loading rates or other established permit limits?
Yes No N/A 9.
Yes No N/A 10.
NOTES:
2-8
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3. FACILITY SITE REVIEW
Inspection of Solids Handling Unit Processes
To evaluate compliance with applicable sludge requirements, the inspector should fully
understand the sludge treatment processes used at the facility and how each process fits into the
overall treatment scheme. Sludge processing arguably poses the greatest challenges in wastewater
treatment from the standpoints of design, operation, and maintenance. Typically, solids handling
accounts for between 30 and 40 percent of the capital costs, SO percent of the operating costs, and 90
percent of the operational problems at sewage treatment plants. These problems can not only prevent
compliance with applicable Federal or State sludge disposal regulations, but can also contribute to a
treatment plant's noncompliance with its NPDES permit effluent limits.
When conducting the walk-through visual inspection of the facility, the inspector should be
aware of, and look for, physical conditions that are indicative of potential or existing problems.
Some of the more common indicators of potential problems are listed in Table 3-1. The presence of
these conditions may warrant a more in-depth inspection of the sludge treatment processes. A
checklist is provided at the end of this chapter to assist the inspector during the facility site review.
The questions on this checklist are sludge-specific and should be asked in conjunction with the
Facility Site Review checklist questions found in EPA's 1988 NPDES Compliance Inspection Manual.
In addition, many of the questions in the NPDES checklist relate to the overall operation of the
facility and, therefore, can also be applied to sludge evaluations (e.g., treatment units properly
operated and maintained). The accompanying technical reference document provides detailed
guidance on evaluating the proper O&M of individual sludge treatment unit processes as well as
checklists which correspond to the technical discussion.
Sludge Management Issues
The inspector should determine if the facility is operating its sludge treatment and disposal
processes in a manner consistent with the requirements established in its NPDES permit. If the
inspector discovers conditions at the facility which threaten public health or the environment (e.g.,
contaminating ground water or surface water, exposing the public to pathogens or disease vectors, or
compromising public safety), the inspector should inform the permit writer so that the problems can
be addressed through a permit modification or when the permit is reissued. For more information on
existing Federal and State requirements, refer to EPA's 1990 Case-By-Case Guidance Manual.
3-1
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TABLE 3-1. SLUDGE HANDLING PROCESS EVALUATION
GENERAL INDICATORS
• Inadequate sludge removal from clarifiers or thickeners
• Substantial down-time of sludge treatment units/solids handling
• Sludge disposal inadequate to keep treatment system hi balance
• Mass balance (i.e., ratio of sludge wasted over a 12-month period by the facility compared
to a typical facility - should be 0.65-0.85 pounds of sludge per pound of BOD removed)
SLUDGE THICKENING
• Sludge decant or return flows high in solids*
• Thickened sludge too thin
• Fouling of overflow weirs on gravity thickeners
• Air flotation skimmer blade binding on beaching plate
SLUDGE ANAEROBIC DIGESTION
Sludge heater inoperative*
Supernatant exuding a sour odor from either primary or secondary anaerobic digester*
Inadequate gas production
Mechanical or gas mixers inoperative
Floating cover of anaerobic digester tilting
Gas burner inoperative
pH problems
SLUDGE AEROBIC DIGESTION
Excessive foaming in tank*
Objectionable odor in aerobically digested sludge*
Insufficient DO in digester
Digester overloaded
Clogging of diffusers in digester
Mechanical aerator failure in digester
Inadequate supernatant removal
'Indicates serious problems with the sludge handling process
3-2
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TABLE 3-1. SLUDGE HANDLING PROCESS EVALUATION (Continued)
SLUDGE DRYING BEDS/LAGOONS
• Dry sludge stacked around drying beds where runoff may enter
navigable waters*
Broken dikes between sludge drying lagoons*
Poor sludge distribution on drying beds
Vegetation in drying beds (unless they are reed beds designed to have plants assist in the
drying process)
Inadequate drying time on drying beds
Dry sludge remaining on drying beds
Objectionable odor from sludge lagoon
Unlined sludge lagoons (determined through liner specifications or interview with plant
personnel)
SLUDGE DEWATERING
• Excessive solids present after dewatering filtrate
• Inadequate dryness of sludge cake
• Sludge build-up on belts, rollers, or conveyors of dewatering equipment
• Insufficient run time for sludge dewatering equipment
SLUDGE DISPOSAL
Sludge constituents not analyzed before disposal
Sludge not transported in appropriate approved vehicle
Objectionable odors generated at sludge disposal site
Inadequate runoff control at landfill or land application sites
Inadequate coverage of sludge in subsurface injection system
Slow drying of soil-sludge mixture in subsurface injection system
Sludge ponding at land application sites
Inadequate burial of sludge at landfill site
Liquid sludge (i.e., less than 8-15 percent solids) applied to landfill site (or sludge fails paint
filter test)
Excessive erosion at sludge sites
Sludges disposed of onsite in nonpermitted sites (landfills, surface impoundments, or land
application units) according to Federal, State, or local regulations
Sludge lagoons full; overflowing sludge back to plant or natural drainage
^Indicates serious problems with the sludge handling process
3-3
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Many large-scale operations are conducted outside, such as sludge drying, composting,
temporary and long-term storage, and loading and hauling. Inspectors should note these outside
operations' exposure to rainfall and runoff collection and treatment methods. If storm-water-
collection devices have been constructed, the inspector should evaluate the performance and
maintenance of these devices as well as their design capacity (e.g., the 10-year 24-hour storm event
or the 25-year 24-hour storm event). Visual observations can detect obvious problems that may
contribute to the contamination of surface water or ground water such as erosion, breaches of dikes or
beams, or cracks in the concrete or asphalt. The inspector should inquire as to whether the capacity
of the collection devices have ever been exceeded during any storm event.
The inspector should also verify that the permittee has adequate storage capacity for its sludge in
the event that its preferred disposal method is interrupted for any reason (e.g., noncompliance with
cumulative loading rates on the land application site). There are no Federal requirements specifying a
minimal storage capacity; the appropriate capacity will vary depending on the amount of sludge
generated and the facility's use or disposal option(s). Some States have developed storage capacity
requirements. If the permittee cannot dispose of its sludge in the preferred manner, it should have
either adequate storage capacity for its sludge or clearly established plans for alternative methods of
disposal.
The sludge loading area should be inspected to determine how the sludge is being hauled or
transported. The inspector should note the size of the truck loads and the number of truck loads
hauled over a 1-day period (or another time period). These figures are useful to the inspector in
verifying the POTW's records and reports on the volume of sludge generated and disposed of.
3-4
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SUPPLEMENTAL CHECKLIST QUESTIONS FOR EVALUATING SLUDGE PROCESSES
DURING A FACILITY SITE REVIEW
Yes No N/A 1. Sludge process control parameters maintained as appropriate?
Yes No N/A 2. Adequate equipment redundancy (e.g., back-up units)?
Yes No N/A 3. Adequate sludge storage capacity?
Yes No N/A 4. Contingency plan for sludge disposal practice?
Yes No N/A 5. Solids handling operation adequate to manage volume of sludge?
Yes No N/A 6.
Yes No N/A 7.
NOTES:
3-5
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4. SAMPLING AND LABORATORY QUALITY ASSURANCE
The sludge inspection should evaluate the nature, scope, and adequacy of sludge sampling and
analysis conducted by the permittee at a NPDES facility. The most likely, existing inspection vehicle
for conducting this evaluation is the PAI, since it involves a detailed assessment of the permittee's
self-monitoring activities, including sample collection and laboratory analysis. The findings of the
sampling and laboratory QA review should be summarized and included in the final inspection report
for the facility.
Sampling Procedures and Techniques
The inspector's evaluation of the permittee's sludge sampling procedures will address similar
criteria as those evaluated in the context of wastewater sampling. The sampling procedure elements
that should be evaluated during the inspection include:
• Sample collection techniques
- Selection of representative sampling sites
- Sample types
- Sample volume
- Sample containers.
• EPA sample identification methods.
• Sample preservation and holding time.
• Chain-of-custody and shipment of samples.
• Quality Control (QC)
Duplicates
- Blanks.
• Data handling and reporting.
A detailed discussion on evaluating these elements can be found in Chapter 5 of EPA's 1988
NPDES Compliance Inspection Manual. While many of these elements are evaluated using the same
criteria regardless of the media being sampled, sludge sample collection techniques and sample
4-1
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preservation are different. The inspector should refer to EPA's 1989 POTW Sludge Sampling and
Analysis Guidance Manual for detailed information regarding sludge sampling procedures. Tables
from this document that summarize appropriate sample locations; flow measurement devices; and
sample containers, preservation techniques, holding times, and minimum volumes have been
reproduced as a quick reference for the inspector. These tables are labeled 4-1, 4-2, and 4-3,
respectively. In addition to these references, a few special sludge sampling considerations are
described below.
The equipment used to collect sludge samples is different than that used to collect wastewater
samples. The automatic composite samplers used to collect wastewater cannot be used to collect
sludge samples because the high solids content of the sludge fouls the tubing. The type of equipment
used to collect samples of soil or other solid waste material is more appropriate for the collection of
sludge samples. Stainless steel buckets, trowels, and augers are typically used to collect solid sludge
cake. Graduated glass or plastic pitchers or cylinders, or plastic or stainless steel buckets are used to
collect liquid sludge samples.
If the permit does not identify a specific sludge sampling location, the inspector must select
one. EPA's 1989 POTW Sludge Sampling and Analysis Guidance Manual states that for purposes of
enforcement, sludge samples must come from the treatment unit process immediately prior to sludge
disposal or end use. Often, the last unit process is one of the dewatering processes described in the
accompanying technical guidance. Table 4-1, from EPA's 1989 Sampling and Analysis Guidance
Manual, suggests appropriate sampling points for a variety of unit processes.
Obtaining a representative sample of sludge is difficult when the sludge is not flowing through
a pipe or along a conveyer. To obtain a representative sample of sludge from a sludge bed or lagoon,
a compost pile, or a truck, several samples have to be taken from various places in the pile and
"combined" to make a representative sample. This composite of grabs should not be confused with a
normal composite sample. A normal composite sample is a series of grabs weighted by time or flow
collected to be representative of changes occurring in the wastestream over a specific time period
(e.g., 24 hours or 7 days).
4-2
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TABLE 4-1. SLUDGE SAMPLING POINTS
SLUDGE TYPE
Anaerobically
digested
Aerobically
digested
Thickened
Heat treatment
Dewatered, dried,
composted, or
thermally reduced
Belt filter press,
centrifuge, or vacuum
filter press
Sludge press
SAMPLING POINT
Sample from taps on the discharge side of positive
displacement pumps.
Sample from taps on the discharge lines from pumps. If
batch digester is used, sample directly from the digester. Two
cautionary notes regarding this practice:
• If aerated during sampling, air entrains in the sample. Volatile
organic compounds may purge with escaping air.
• When aeration is shut off, solids separate rapidly in well-digested
sludge.
Sample from taps on the discharge side of positive
displacement pumps.
Sample from taps on the discharge side of positive displacement
pumps after decanting. Be careful when sampling heat treatment
sludge because of:
• High tendency for solids separation
• High temperature of samples (frequently >60°C) can cause
problems with certain sample containers due to cooling and
subsequent contraction of entrained gases.
Sample from material collection conveyors and bulk
containers. Sample from many locations within the
sludge mass and at various depths.
Sample from sludge cake discharge chute.
Sample from storage bin; select four points within the (plate and
frame) storage bin, collect equal samples from each point, and
combine them to form a grab sample of the total storage bin.
4-3
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TABLE 4-1. SLUDGE SAMPLING POINTS (Continued)
SLUDGE TYPE
Drying beds
Compost piles
SAMPLING POINT
Divide bed into quarters, grab equal samples from the center of each
quarter, and combine them to form a grab sample of the total bed.
Each grab sample should include the entire depth of the sludge (down
to the sand).
Sample directly from front-end loader or other conveyance device as
the sludge is being loaded into trucks to be hauled away.
TABLE 4-2. SLUDGE FLOW MEASUREMENT DEVICES
APPLICATION
Stabilized sludge
Thickener
Dewatering
Drying
composting
thermal reduction
MEASUREMENT MEANS
Venturi
Flow tube
Magnetic meter
Positive displacement pump
Magnetic meter
Positive displacement pump
Belt press scales (if belt presses are used)
Bulk container or truck scales
4-4
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TABLE 4-3. CONTAINERS, PRESERVATION, HOLDING TIMES, AND MINIMUM SAMPLE VOLUMES*
PARAMETER
Inorganic Compounds
WIDE-MOUTHED MAXIMUM MINIMUM
CONTAINER PRESERVATIVE** HOLDING TIME** SAMPLE VOLUME***
Asbestos
Metals
Chromium VI
Mercury
Other metals
Organic Compounds
f" Extractables (including
phthalates, nitrosamines,
nitroaromatics, isophorone,
polynuclear aromatic HC,
haloethers, chlorinated
HC, and TCDD)
Extractable (phenols)
Purgeables (halocarbons
and aromatics)
P
P,G
P,G
P,G
G, teflon-
lined cap
P, dioxin
and furan only
G, teflon-
lined cap
G, teflon-
lined septa
None
Cool, 4°C,
HNO3topH<2
HNO3topH<2
Cool, 4°C,
0.008% NajSA****
Cool, 4°C,
H2S04topH<2,
0.008% NajSA****
Cool, 4°C,
0.008% Na2SA,****
None
24 hours
28 days
6 months
7 days"
40 days8
7 days"
40 days8
7 daysw/0
14 days in
2,000 milliliter
300ml
500ml
1,000ml
1,000ml
1,000ml
>20ml
l:lHCltopH2 darkness
-------
TABLE 4-3. CONTAINERS, PRESERVATION, HOLDING TIMES, AND MINIMUM SAMPLE VOLUMES* (Continued)
PARAMETER
Purgeables
(acrolein and acrylonitrile)
Pesticides and
Polychlorinated Byphenols (PCBs)
WIDE-MOUTHED MAXIMUM MINIMUM
CONTAINER PRESERVATIVE** HOLDING TIME** SAMPLE VOLUME***
G, teflon-
lined septa
G, teflon-
lined septa
Cool, 4°C,
0.008% Na&Q,,**** 14 days
adjust pH to 4 or 5
Cool, 4°C,
0.008%
adjust pH to 6-9
7 days"
40 days"
>20ml
1,000ml
*40 CFR Part 136
**Holding time commences on addition of the sample to the sampling container. Shipping of pre-preserved containers to the sample sites may
be regulated under DOT hazardous materials regulations. Shipping of preserved samples to the laboratory is generally not regulated as a
hazardous material.
***Varies with analytical method. Consult 40 CFR Part 136.
****Should be used in the presence of residual chlorine.
"After extraction. LEGEND
"Before extraction.
w/0Without pH adjustment.
P -
G -
Plastic (polyethylene)
Glass (non-etched Pyrex)
HNO3 Nitric acid
Sodium thiosulfate
Sulfuric acid or salfate
Hydrogen chloride
Hydrocarbon
H2SO4
HC1
HC
TCDD 2, 3, 7, 8 tetrachloro-p-dioxin
-------
Preserving samples of solid sludge is not usually done in the field because it is difficult to
thoroughly mix the preservative throughout the sludge sample. It is best to preserve sludge samples
which are high in solids at the laboratory. Preservatives can be added to liquid sludge samples in the
field as long as the samples are well mixed in the sampling bucket or container after the preservatives
have been added. Appropriate sludge sample preservation techniques are outlined in Table 4-3.
Laboratory Analysis and Quality Assurance
During a PAI, the inspector is already conducting an in-depth evaluation of the permittee's
laboratory analytical techniques and QA/QC procedures. The following elements are evaluated during
this inspection:
• Permittee sample handling procedures in the laboratory
• Laboratory analysis techniques
- Permittee laboratory analytical procedures (40 CFR Part 136 or other methods established
in the permit)
- Laboratory services
- Instruments and equipment
- Supplies
• QA/QC
- Precision and accuracy of the measurement process
- Data handling and reporting
- Sludge records retention (for 5 years)
- Personnel qualifications.
Again, many of these elements are evaluated according to the same criteria regardless of the
sample being analyzed. The inspector is referred to Chapter 8 of EPA's 1988 NPDES Compliance
Inspection Manual and 1990 NPDES Compliance Monitoring Inspector Training Module on
Laboratory Analysis for general guidance on inspecting the permittee's laboratory procedures. There
are some differences in sample preparation and analytical techniques for sludge with which the
inspector should be familiar.
4-7
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In conducting the sludge component of the PAI, the inspector should closely evaluate the
permittee's sample preparation procedures. The sludge matrix is more complex and variable than the
wastewater matrix; therefore, the laboratory's development of sample preparation techniques is of
particular concern. Table 4-4, reproduced from EPA's 1989 POTW Sludge Sampling and Analysis
Guidance Manual describes recommended sample preparation for elemental analysis of sludge
samples. The inspector should review the discussion on sample preparation and analytical methods in
EPA's 1989 POTW Sludge Sampling and Analysis Guidance Manual.
The NPDES permit can require the permittee to analyze sludge for conventionals, inorganic
pollutants, metals, and pathogens (depending on the ultimate sludge disposal practice). For example,
sludge that is going to be land applied will be analyzed for constituents such as cadmium and nitrogen
to determine the appropriate application rate. Sludge that is incinerated would be analyzed for
mercury because of its volatility to determine compliance with the Federal National Emissions
Standards for Hazardous Air Pollutants (NESHAP) emission standard for municipal sewage sludge
incinerators (see 40 CFR Part 61). In many instances, the analytical methods for these parameters
will not be the same as those used for the analysis of wastewater because of the different, more solid,
sludge matrix. While for some pollutant parameters the final analytical procedure may be the same,
the sample preparation and clean-up procedures used prior to running the liquid analytical test will
certainly be different. The inspector should refer to EPA's 1989 POTW Sludge Sampling and
Analysis Guidance Manual and the references listed in the bibliography for detailed information on
the analytical techniques specific to the identification of constituents in sludge.
4-8
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TABLE 4-4. RECOMMENDED PREPARATION TECHNIQUE FOR ELEMENT ANALYSIS
OF SLUDGE SAMPLES
METHOD 30502
• Mix the sample thoroughly to achieve homogeneity. For each digestion procedure, weigh
to the nearest 0.01 gram (g) and transfer a 1.00 to 2.00 g (on a dry weight basis) portion
of the sample to a conical beaker.
• Add 10 ml of 1:1 HNO3, mix the slurry, and cover with a watch glass. Heat the sample to
95°C and reflux for 10 to 15 minutes without boiling. Allow the sample to cool, add 5 ml
of concentrated HNO3, replace the watch glass, and reflux for 30 minutes. Repeat this last
step to ensure complete oxidation. Using a ribbed watch glass, allow the solution to
evaporate to 5 ml without boiling, while maintaining a layer of solution over the bottom of
the beaker.
• After Step 2 has been completed, and the sample has cooled, add 2 ml of Type II water and
3 ml of 30 percent H2O2. Cover the beaker with a watch glass and return the covered
beaker to the hot plate for warming and for starting the peroxide reaction. Care must be
taken to ensure that losses do not occur due to excessively vigorous effervescence. Heat
until effervescence subsides, and then cool the beaker.
• Continue to add 30 percent lLf)2 in 1-ml aliquots while warming, until the effervescence is
minimal or until the general sample appearance is unchanged.
NOTE: Do not add more than 10 ml (total) of 30 percent
H2O2 - Hydrogen peroxide
HNO3 - Nitric acid
"Test Methods for Evaluating Solid Waste: Volume 1A" SW-846 3rd Edition, November
1986. Chapter 3, pp. 3050-1, 5.
4-9
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SUPPLEMENTAL CHECKLIST QUESTIONS FOR
SLUDGE SAMPLE INSPECTION
A. PERMITTEE SLUDGE SAMPLING EVALUATION
Yes No N/A 1. Sludge samples are taken at locations specified in the permit?
Yes No N/A 2. Sludge sample locations are appropriate for obtaining representative samples?
Yes No N/A 3. Sampling and analysis are conducted for parameters specified in the permit?
4. Sample collection procedures
Yes No N/A a. Adequate sample volumes are obtained?
Yes No N/A b. Proper preservation techniques are used?
Yes No N/A c. Containers conform to 40 CFR Part 136?
Yes No N/A d. Samples analyzed in the appropriate time frames in accordance with
40 CFR Part 136?
B. SAMPLING INSPECTION PROCEDURES AND OBSERVATIONS
Yes No N/A 1. Sample is refrigerated subsequent to compositing?
Yes No N/A 2. Sample is split with the permittee?
Yes No N/A 3. Chain-of-custody procedures are employed?
Yes No N/A 4. Samples are collected in accordance with the permit?
Yes No N/A 5.
Yes No N/A 6.
NOTES:
4-10
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APPENDIX A
BIBLIOGRAPHY
-------
BIBLIOGRAPHY
I. GENERAL
Clark, J.W., Wiessman, W., Hammer, M., Water Supply Pollution Control. (Harper and Row
Publishers, 1977).
Gulp, G.L., and Folks Heim, N. Field Manual for Performance Evaluation and Troubleshooting at
Municipal Wastewater Treatment facilities. U.S. Environmental Protection Agency, 430/9-78-001, Jan.
1978.
Advanced Waste Treatment - Field Study Training Program. U.S. Environmental Protection Agency,
1987.
Operations Manual. Sludge Handling and Conditioning. Office of Water Program Operation, U.S.
Environmental Protection Agency, 430/9-78-002, Feb. 1978.
Process Design Manual for Sludge Treatment and Disposal. Municipal Environmental Research
Laboratory, U.S. Environmental Protection-Agency, 625/1-79-011 Sept. 1979.
Process Design Manual for Suspended Solids Removal. U.S. Environmental Protection Agency, 625/1-75-
0032, Jan. 1975.
Hinrichs, D.J., Inspectors Guide for Evaluation of Municipal Wastewater Treatment Plants. U.S.
Environmental Protection Agency, 430/9-79-010 April 1979.
Steel, E.W., McGhee, T.J., Water Supply and Sewerage. (McGraw-Hill Book Company, 1979).
Draft Guidance for Writing Case-by-Case Permit requirements for Municipal Sewage Sludge. Office of
Water Enforcement and Permits, EPA, June 1988.
Summary of Environmental Profiles and Hazard Indices for Constituents of Municipal Sludge. Office of
Water Regulations and Standards, EPA, July 1985.
Use and Disposal of Municipal Wastewater Sludge. Intra-Agency Sludge Task Force, EPA 625/10-84-
003, September 1984.
Overview of Sewage Sludge and Effluent Management. Office of Technology Assessment, U.S.
Congress, C/R-36b/#10, March 1986.
Evaluation of Sludge Management Systems. Office of Water Program Operations, EPA 430/9-80-001,
MCD-61, February 1980.
Municipal Sludge Management: EPA Construction Grants Program. Office of Water Program
Operations, EPA 430/9-76/009, April 1976.
A-l
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Municipal Sludge Management: Environmental Factors. Office of Water Program Operations, EPA
430/9-77/004, October 1977.
Metcalf and Eddy Inc., Wastewater Engineering: Treatment Disposal/Reuse. (McGraw-Hill Book
Company, 1979).
H. SAMPLING SLUDGE QUALITY
Draft POTW Sludge Sampling and Analysis Guidance Document. Office of Water Enforcement and
Permits, EPA, July 1989.
Sampling Procedures and Protocols for the National Sewage Sludge Survey. Office of Water Regulations
and Standards, EPA, August 1988.
Analytical Methods for the National Sewage Sludge Survey. Office of Water Regulations and Standards,
EPA, August 1988.
HI. PATHOGENS
Control of Pathogens in Municipal Wastewater Sludge. Center for Environmental Research Information,
EPA 625/10-89/006; September 1989.
Pathogen Risk Assessment Feasibility Study. Office of Research and Development, EPA 670/2-73/098,
December 1973.
IV. LAND APPLICATION
Land Application of Municipal Sludge. Municipal Environmental Research Laboratory, EPA 625/1-
83/016, October 1983.
Application of Sewage Sludge to Cropland. Office of Water Program Operations, EPA 430/9-76/013,
November 1976.
Applications of Sludge on Agricultural Land. Municipal Construction Division, Office of Research and
Development, EPA 600/2-78/13Ib, June 1978.
Land Treatment of Municipal Wastewater. EPA Center for Environmental Research Information, EPA
625/1-81-013, October 1981.
Sewage Disposal on Agricultural Soils: Chemical and Microbiological Implications. Office of Research
and Development, EPA 600/2-78/13Ib, June 1978.
Loeht, R.C., Pollution Control for Agriculture. (Academic Press Inc., 1984).
A-2
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V. LANDFILLING
Municipal Sludge Landfills. Environmental Research Information Center, Office of Solid Waste, EPA
625/1-78/010, SW-705, October 1978.
VI. DISTRIBUTION AND MARKETING
Composting of Municipal Wastewater Sludges. EPA Center for Environmental Research Information,
EPA 625/4-85-014, August 1985.
Composting Processes to Stabilize and Disinfect Municipal Sewage Sludge. Office of Water Program
Operations, EPA 430/9-81-011, MCD-79, June 1981.
VH. INCINERATION
Municipal Wastewater Sludge Combustion Technology. EPA Center for Environmental Research
Information, EPA 625/4-85-015, September 1985.
. MISCELLANEOUS
Dewatering Municipal Wastewater Sludges. Office of Research and Development, EPA 625/1-87/014,
September 1987.
Odors Emitted from Raw and Digested Sewage Sludge. Office of Research and Development, EPA 670/2-
73/098, December 1973.
Process Design Manual for Dewatering Municipal Wastewater Sludges. Office of Research and
Development, EPA 625/1-82-014, October 1982.
Radioactivity of Municipal Sludge. Office of Water Regulations and Standards, EPA, April 1986.
A-3
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