United States
Environmental Protection
Agency
Office of Wastewater
Enforcement and Compliance
Washington, D.C.
Working Draft
March 1993
&EPA GUIDANCE FOR WRITING
PERMITS FOR THE USE OR
DISPOSAL OF SEWAGE SLUDGE
DRAFT
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAR I 8 1993
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Guidance for Writing Permits for the Use or Disposal of
Sewage Sludfae - Woa?kinq Draft
FROM: CyfltMa C.' Dougherty, D
Division (EN-33
TO: Users of the draft guidance
I am attaching for your comments and use a draft manual that
provides information to permit writers on implementing the
Standards for the Use or Disposal of Sewage Sludge (40 CFR Part
503) through permits.
EPA is developing this manual to assist permit writers in
writing sewage sludge permits. We are issuing it as a working
draft to have it available for use as- soon— as possible and to
obtain broad input from permit writers and from the regulated
community. We invite comments on the structure, format, and
content of the guidance. When submitting comments, please be as
specific as possible.
EPA expects to revise this guidance and issue it in final
form by October, 1993. Please forward your comments and
suggestions by July 31, 1993 to:
Wendy Bell
Permits Division (EN-336)
U.S. EPA
401 M Street SW
Washington, DC 20460
phone: (202) 260-9534
fax: (202) 260-1460
Attachment
Printed on Recycled Paper
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TABLE OF CONTENTS
Page
PREFACE i
1. INTRODUCTION 1-1
1.1 BACKGROUND 1-1
1.2 SEWAGE SLUDGE USE OR DISPOSAL PRACTICES 1-2
1.3 DEVELOPMENT OF THE PART 503 TECHNICAL STANDARDS AND
REQUIREMENTS '. 1-5
1.4 IMPLEMENTATION OF THE PART 503 REGULATIONS 1-7
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS 2-1
2.1 SEWAGE SLUDGE REGULATED BY PART 503 2-1
2.2 USE OR DISPOSAL PRACTICES REGULATED BY PART 503 2-2
2.3 DECIDING WHOM TO PERMIT AND WHICH PART 503 REQUIREMENTS
TO APPLY 2-5
2.3.1 FACILITIES REQUIRED TO APPLY FOR A PERMIT 2-6
2.3.2 APPLYING THE PART 503 REQUIREMENTS IN PERMITS . 2-7
2.4 PERMITTING PROCEDURES 2-11
2.4.1 CORE PERMIT CONDITIONS 2-11
2.4.2 FACT SHEET 2-11
3. PERMIT APPLICATION 3-1
3.1 PERMIT APPLICATION INFORMATION REQUIRED FOR ALL SEWAGE
SLUDGE USE OR DISPOSAL PRACTICES 3-1
3.2 PERMIT APPLICATION INFORMATION FOR LAND APPLICATION
OF SEWAGE SLUDGE 3-3
3.3 PERMIT APPLICATION INFORMATION FOR SURFACE DISPOSAL
OF SEWAGE SLUDGE 3-10
3.4 APPLICATION INFORMATION FOR SEWAGE SLUDGE INCINERATORS .... 3-18
3.5 REVIEWING THE APPLICATION 3-22
3.5.1 REVIEWING FOR COMPLETENESS 3-22
3.5.2 REVIEWING FOR ACCURACY 3-22
3.6 COLLECTING ADDITIONAL INFORMATION 3-23
3.6.1 EXISTING FACILITY INFORMATION . . . . 3-23
3.6.2 SITE VISITS 3-24
3.6.3 AERIAL PHOTOGRAPHS 3-24
3.6.4 OTHER SOURCES OF INFORMATION 3-24
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TABLE OF CONTENTS (CONTINUED)
Page
4. LAND APPLICATION - PART 503 SUBPART B 4-1
4.1 OVERVIEW 4-1
4.1.1 IDENTIFYING LAND APPLICATION 4-1
4.1.2 DETERMINING PROVISIONS TO APPLY TO SPECIFIC LAND
APPLICATION PRACTICES 4-2
4.1.3 SUBPART B REQUIREMENTS TO APPLY TO THE GENERATOR,
PREPARER, AND APPLIER 4-3
4.2 SPECIAL DEFINITIONS 4-3
4.3 GENERAL REQUIREMENTS 4-12
4.3.1 REQUIREMENT FOR PERSONS APPLYING SEWAGE SLUDGE TO
LAND TO OBTAIN INFORMATION AND TO COMPLY WITH
SUBPART B 4-12
4.3.2 RESTRICTIONS IN APPLYING SEWAGE SLUDGE TO LAND THAT
HAS REACHED CUMULATIVE POLLUTANT LOADING RATES 4-14
4.3.3 NOTICE TO PREPARER, APPLIER, OR OWNER 4-17
4.3.4 NOTICE TO PERMITTING AUTHORITY 4-19
4.4 POLLUTANT LIMITS 4-21
4.4.1 POLLUTANT CONCENTRATION LIMITS 4-24
4.4.2 ANNUAL POLLUTANT LOADING RATES 4-26
4.4.3 CUMULATIVE POLLUTANT LOADING LIMITS 4-30
4.5 OPERATIONAL STANDARDS-PATHOGENS AND VECTOR REDUCTION . . . 4-32
4.6 MANAGEMENT PRACTICES 4-40
4.6.1 ENDANGERED SPECIES OR CRITICAL HABITAT PROTECTION 4-40
4.6.2 APPLICATION OF SEWAGE SLUDGE TO FLOODED LAND 4-43
4.6.3 APPLICATION OF SEWAGE SLUDGE TO FROZEN OR SNOW-
COVERED LAND 4-46
4.6.4 DISTANCE TO SURFACE WATERS . . . . 4-50
4.6.5 AGRONOMIC APPLICATION RATE 4-53
4.6.6 LABEL OR INFORMATION SHEET REQUIREMENTS 4-69
4.7 MONITORING REQUIREMENTS 4-71
4.7.1 PARAMETERS TO BE MONITORED 4-71
4.7.2 MONITORING FREQUENCY 4-72
4.7.3 MONITORING POINTS 4-75
4.7.4 SAMPLE TYPES AND PRESERVATION PROTOCOL 4-75
4.7.5 ANALYTICAL METHODS 4-76
4.7.6 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) 4-83
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TABLE OF CONTENTS (CONTINUED)
Page
4.8 RECORD KEEPING REQUIREMENTS 4-83
4.8.1 DOCUMENTATION FOR POLLUTANT CONCENTRATIONS 4-90
4.8.2 DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION
REDUCTION 4-90
4.8.3 DOCUMENTATION TO SHOW COMPLIANCE WITH MANAGEMENT
PRACTICES 4-90
4.9 REPORTING REQUIREMENTS 4-93
5. SURFACE DISPOSAL - PART 503 SUBPART C 5-1
5.1 OVERVIEW : 5-1
5.1.1 IDENTIFYING SURFACE DISPOSAL 5-2
5.1.2 DETERMINING PROVISIONS TO APPLY TO SPECIFIC SURFACE
DISPOSAL SITES 5-3
5.1.3 SUBPART C REQUIREMENTS TO APPLY TO THE PREPARER AND
SITE OWNER/OPERATOR 5-4
5.2 SPECIAL DEFINITIONS 5-4
5.3 GENERAL REQUIREMENTS 5-8
5.3.1 LOCATION WITHIN 60 METERS OF A FAULT, IN AN UNSTABLE
AREA, OR IN A WETLAND PROHIBITED 5-10
5.3.2 WRITTEN CLOSURE AND POST-CLOSURE PLAN 5-11
5.3.3 NOTIFICATION TO SUBSEQUENT OWNERS 5-18
5.4 POLLUTANT LIMITS 5-20
5.4.1 POLLUTANT LIMITS FOR AN ACTIVE SEWAGE SLUDGE UNIT
WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM
THAT IS LOCATED 150 METERS OR GREATER FROM THE SITE
PROPERTY LINE 5-23
5.4.2 POLLUTANT LIMITS FOR AN ACTIVE SEWAGE SLUDGE UNIT
WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM THAT
IS LOCATED LESS THAN 150 METERS FROM THE SITE
PROPERTY LINE 5-24
5.4.3 SITE-SPECIFIC POLLUTANT CONCENTRATIONS 5-25
5.5 OPERATIONAL STANDARDS-PATHOGENS AND VECTOR ATTRACTION
REDUCTION 5-27
5.6 MANAGEMENT PRACTICES 5-29
5.6.1 ENDANGERED SPECIES OR CRITICAL HABITAT PROTECTION 5-29
5.6.2 FLOOD FLOW RESTRICTIONS 5-31
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TABLE OF CONTENTS (CONTINUED)
Page
5.6.3 REQUIREMENTS IN A SEISMIC IMPACT ZONE . 5-33
5.6.4 REQUIREMENT OF 60 METERS OR MORE FROM .A FAULT 5-37
5.6.5 UNSTABLE AREAS 5-39
5.6.6 WETLAND PROTECTION 5-44
5.6.7 STORM WATER RUN-OFF MANAGEMENT 5-47
5.6.8 LEACHATE COLLECTION AND DISPOSAL 5-55
5.6.9 METHANE GAS CONTROL 5-64
5.6.10 FOOD, FEED, AND FIBER CROPS AND GRAZING RESTRICTIONS . . . 5-74
5.6.11 PUBLIC ACCESS CONTROL ; . . .' 5-77
5.6.12 GROUND-WATER PROTECTION . 5-80
5.7 MONITORING REQUIREMENTS 5-94
5.7.1 PARAMETERS TO BE MONITORED 5-95
5.7.2 MONITORING FREQUENCY 5-95
5.7.3 MONITORING POINTS , i 5-98
5.7.4 SAMPLE AND PRESERVATION PROTOCOL 5-99
5.7.5 ANALYTICAL METHODS . 5-100
5.7.6 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC) 5-100
5.8 RECORD KEEPING REQUIREMENTS 5-103
5.8.1 DOCUMENTATION FOR POLLUTANT CONCENTRATIONS 5-103
5.8.2 DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION
REDUCTION :' 5-104
5.8.3 DOCUMENTATION TO SHOW COMPLIANCE WITH MANAGEMENT
PRACTICES 5-105
5.9 REPORTING REQUIREMENTS 5-111
6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503
SUBPART D 6-1
6.1 OVERVIEW 6-1
6.1.1 GENERAL CHARACTERISTICS OF PATHOGENS AND DISEASE
VECTORS 6-2
6.1.2 ROLE OF THE PERMIT WRITER IN APPLYING PATHOGEN
REDUCTION AND VECTOR ATTRACTION REDUCTION
REQUIREMENTS 6-5
6.2 SPECIAL DEFINITIONS 6-7
6.3 CLASS A PATHOGEN REDUCTION . 6-9
6.3.1 ALTERNATIVE 1 '. . . 6-10
6.3.2 ALTERATIVE 2 ; 6-12
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TABLE OF CONTENTS (CONTINUED)
Page
6.3.3 ALTERNATIVE 3 ......: , . 6-13
6.3.4 ALTERNATIVE 4 . 6-15
6.3.5 ALTERNATIVE 5 6-16
6.3.6 ALTERNATIVE 6 i 6-19
6.4 CLASS B PATHOGEN REDUCTION 6-20
6.4.1 ALTERNATIVE 1 . ; 6-21
6.4.2 ALTERNATIVE 2 6-22
6.4.3 ALTERNATIVE 3 • 6-24
6.5 CLASS B PATHOGEN REDUCTION SITE RESTRICTIONS 6-24
6.6 VECTOR ATTRACTION REQUIREMENTS 6-26
6.6.1 ALTERNATIVE 1 . . 6-27
6.6.2 ALTERNATIVE 2 6-28
6.6.3 ALTERNATIVE 3 6-29
6.6.4 ALTERNATIVE 4 : 6-30
6.6.5 ALTERNATIVE 5 : 6-30
6.6.6 ALTERNATIVE 6 6-31
6.6.7 ALTERNATIVE 7 6-32
6.6.8 ALTERNATIVE 8 6-32
6.6.9 ALTERNATIVE 9 6-33
6.6.10 ALTERNATIVE 10 6-33
6.6.11 ALTERNATIVE 11 6-34
' ' {
7. INCINERATION - PART 503 SUBPART E 7-1
7.1 OVERVIEW 7-1
7.1.1 IDENTIFYING INCINERATION 7-1
7.1.2 DETERMINING PROVISIONS TO APPLY 7-3
7.1.3 SUBPART E REQUIREMENTS TO APPLY TO THE OWNER/OPERATOR
OF THE INCINERATOR AND TO GENERATORS OF SEWAGE SLUDGE
FIRED IN A SEWAGE SLUDGE INCINERATOR 7-4
7.2 DEFINITIONS 7-4
7.3 GENERAL REQUIREMENTS . . . : 7-12
7.4 POLLUTANT LIMITS 7-13
7.4.1 SITE-SPECIFIC FACTORS 7-13
7.4.2 LEAD 7-19
7.4.3 ARSENIC, CADMIUM, CHROMIUM, AND NICKEL 7-21
7.4.4 BERYLLIUM 7-25
7.4.5 MERCURY 7-27
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TABLE OF CONTENTS (CONTINUED)
Page
7.5 OPERATIONAL STANDARDS 7-28
7.5.1 TOTAL HYDROCARBON CONCENTRATION (THC) 7-29
7.6 MANAGEMENT PRACTICES '....-.' 7-31
7.6.1 TOTAL HYDROCARBONS MONITOR 7-31
7.6.2 OXYGEN MONITOR 7-32
7.6.3 MOISTURE CONTENT 7-33
7.6.4 COMBUSTION TEMPERATURE 7-33
7.6.5 AIR POLLUTION CONTROL DEVICE OPERATING PARAMETERS .... 7-34
7.6.6 ENDANGERED SPECIES ACT 7-35
7.7 MONITORING REQUIREMENTS 7-37
7.7.1 SEWAGE SLUDGE MONITORING . . . 7-38
7.7.2 STACK GAS MONITORING '. 7^0
7.7.3 INCINERATOR AND AIR POLLUTION CONTROL DEVICE
MONITORING • • • 7-42
7.8 RECORD KEEPING REQUIREMENTS 7-44
7.8.1 INCINERATOR INFORMATION 7-44
7.8.2 DISPERSION MODELING : '. 7-45
7.8.3 STACK GAS DATA „!'...: 7-47
7.8.4 SEWAGE SLUDGE MONITORING INFORMATION 7-51
7.9 REPORTING INFORMATION 7-53
LIST OF APPENDICES (' ' .
APPENDIX A - CONVERSION FACTORS-ENGLISH SYSTEM UNITS TO METRIC SYSTEM
UNITS
APPENDIX B - SURFACE DISPOSAL SITE LINERS
APPENDIX C - INFORMATION SOURCES
APPENDIX D - DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E
APPENDIX E - DETERMINING SITE-SPECIFIC POLLUTANT LIMITS FOR PART 503,
SUBPARTC
Draft—March 1993 -vi-
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PREFACE
Section 405(d) of the Clean Water Act (CWA) directs the U.S. Environmental Protection Agency (EPA)
to develop regulations containing guidelines for the use and disposal of sewage sludge. This section also
requires EPA to establish standards that adequately protect public health and the environment from any
reasonably anticipated adverse effects from the use and disposal of sewage sludge. On February 19th,
1993 (58 Federal Register 9248), EPA published final regulations at 40 Code of Federal Regulations
(CFR) Part 503 as the culmination of a major effort to develop technical standards in response to Section
405(d). These regulations govern three sewage sludge use and disposal practices: land application,
surface disposal, and incineration.
PURPOSE OF THIS MANUAL
A key element in EPA's implementation of the Part 503 regulations is educating Agency and State
personnel about these new requirements. Although the regulations are generally directly enforceable
against all persons involved in the use and disposal of sewage sludge, they will also be implemented
through permits issued to "treatment works treating domestic sewage" as defined in 40 CFR 122.22.
Thus, the primary focus of this manual is to assist permit writers in incorporating the Part 503
requirements into permits; it serves as an update to the Guidance for Writing Case-by-Case Permit
Conditions for Municipal Sewage Sludge (EPA 1990).
HOW TO USE THIS MANUAL
This manual is -structured for use as a textbook or reference manual by the permit writer. It clearly
presents the provisions in 40 CFR Part 503 relating to land application, surface disposal, and incineration
as well as pathogen and vector attraction reduction. The manual also presents guidance on the factors
to consider in developing permit conditions that implement the Part 503 requirements. This manual can
aid the permit writer in setting appropriate permit limitations and requirements.
In addition, in developing a sewage sludge permit, the permit writer will need to use Best Professional
Judgment (BPJ) if drafting site-specific conditions. Because the permit writer may not be familiar with
all technical issues, the manual furnishes technical guidance on the issues encountered in drafting permit
conditions. For example, the permit writer may not be knowledgeable about the design, operation, and
maintenance of a leachate collection system required at a surface disposal site. Section 5.6 highlights
technical information about such a system so that the permit writer can draft appropriate permit
conditions. Similar technical material appears in other sections of this manual. However, the permit
writer should keep in mind that the technical material provided in this manual is intended as an overview
only; many chapters list references that the permit writer can consult to obtain more detailed information
on a particular technical issue.
The permit writer should also note that this manual does not cover septage or septage haulers. EPA will
draft separate guidance on this topic and the permit writer should contact his/her Regional EPA office
for the status of this guidance.
Finally, this manual is being released in draft form to enable permit writers to comment upon its
usefulness. If, after using the manual to draft a sewage sludge permit, you as a permit writer have any
relevant and constructive comments on it, please contact the nearest EPA Regional office. The Agency
plans to modify the manual to reflect comments and then publish it in final form.
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ORGANIZATION AND CONTENTS OF THIS MANUAL
This manual is organized into seven chapters with five appendices. To begin with, the permit writer
should read Chapters 1 and 2, which provide a broad overview of the Part 503 regulations and related
permitting issues. After reading these two chapters, the permit writer can select the chapters or sections
of chapters relevant to the particular sewage sludge use or disposal practice of interest, as shown in the
box below. An index, provided at the beginning of each chapter, is intended to aid the permit writer in
quickly locating a particular topic of interest. The index also lists figures and tables in that chapter.
However, the index may not list all of the subsections or all of the tables/figures in each chapter; the
Table of Contents at the beginning of this manual should be consulted for the,complete contents of each
chapter.
TABLE 1 - LOCATION OF SEWAGE SLUDGE USE AND DISPOSAL DISCUSSIONS
Land Application
Chapter 1
Chapter 2
Chapter 3
Section 3.1
Section 3.2
Section 3.5
Section 3.6
Chapter 4
Chapter 6
Surface Disposal \
Chapter 1
Chapter 2 ;
Chapters '
Section 3.1
Section 3.3
Section 3.5
Section 3.6
Chapters • .'-
Chapter 6
Incineration
Chapter 1
Chapter -2
Chapter 3
Section 3.1
Section 3.4
Section 3.5.
Section 3.6
Chapter 7
11
Chapter 3 discusses the application information that the permit writer will need.about the applicant or
facility to begin drafting a sewage sludge use or disposal permit. This chapter is divided into six
sections. Sections 3.1, 3.5 and 3.6 provide general information on receiving and reviewing permit
applications while Sections 3.2, 3.3, and 3.4 highlight information needs for each of the three sewage
sludge use or disposal practices. Specific information that is required or may be needed for each sewage
sludge use or disposal practice is listed in tables in Chapter 3 which, the .permit writer may use as
checklists. , , .
Chapters 4, 5, 6, and 7 each address one of the subparts (Subparts B, C, D, and E) of the Part 503
regulations as follows:
Chapter 4 - Subpart B, land application
Chapter 5 - Subpart C, surface disposal
Chapter 6 - Subpart D, pathogens and vector attraction reduction
Chapter 7 - Subpart E, incineration
In each of these chapters, the actual regulatory provision is reproduced, usually at the beginning of the
discussion on the specific requirement.
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Chapters 4, 5, and 7 are organized similarly, using the following structure:
Section 1 - Overview
Section 2 - Definitions
Section 3 - General requirements
Section 4 - Pollutant limits
Section 5 - Operational standards
Section 6 - Management practices
Section 7 - Monitoring requirements
Section 8 - Record keeping requirements
Section 9 - Reporting requirements
Section 1 of each chapter assists the permit writer in determining if that subpart of the Part 503
regulations applies to the sewage sludge use or disposal practice in question. A flow chart is included
to guide the permit writer in this determination. This section also gives a brief overview of the
appropriate Part 503 requirements that should be contained in the permit.
Section 2 goes on to discuss the special definitions used in various subparts of the Part 503 regulations
related to the specific sewage sludge use or disposal practice discussed in the chapter. The permit writer
can refer to this section, when needed, to further clarify these definitions as well as to review other
relevant definitions from the Part 503 regulations. Sections 3 through 9 of each chapter detail specific
Part 503 requirements. Each section provides guidance on how to implement the requirements, and,
where appropriate, furnishes instructions, provides examples of permit language, and shows calculations
for the permit writer's use.
Chapter 6, which is organized somewhat differently from Chapters 4, 5 and 7, discusses each of the Part
503 pathogen and vector attraction reduction alternatives that apply to land application and surface
disposal. As with these other chapters, Section 6.1 is an overview and Section 6.2 provides definitions.
The remaining sections of the chapter discuss each of the various pathogen and vector attraction reduction
alternatives and the associated monitoring and record keeping requirements for each alternative.
Five appendices also appear in the manual. Appendix A contains two tables of conversion factors — one
from the International System (SI) of units to the English system and the other from the English system
to SI units. Appendix B gives a brief overview of liners used at surface disposal sites. Appendix C gives
addresses and telephone numbers of additional information'sources. Appendix D contains information
on determining incinerator control efficiencies. Appendix E provides information for determining site-
specific pollutant limits at surface disposal sites.
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1. INTRODUCTION
QUICK REFERENCE INDEX
Section Page
BACKGROUND 1.1 1-1
SEWAGE SLUDGE USE OR DISPOSAL PRACTICES 1.2 1-2
DEVELOPMENT OF THE PART 503 TECHNICAL STANDARDS AND REQUIREMENTS 1.3 1-5
IMPLEMENTATION OF THE PART 503 REGULATIONS 1.4 1-7
1.1 BACKGROUND
The primary goals of the Clean Water Act (CWA) are to protect and improve the quality of the Nation's
water. To prevent contamination and deterioration of water quality, wastewater from households and
commercial and industrial activities is typically treated at wastewater treatment plants before it is
discharged to surface water or ground water. There are approximately 15,000 publicly owned treatment
works (POTWs) in the U.S. that process almost 34 billion gallons of domestic sewage and other
wastewater each day [EPA 1991]. Sewage sludge is the byproduct of POTWs and other treatment works
that treat domestic wastewater. The volume of sewage sludge generated is estimated at about 47 pounds
annually for every individual in the United S.tates (58 FR 9249, February 19, 1993).
The soil conditioning and nutrient values of sewage sludge have long been recognized. However,
historically this byproduct has been treated and disposed as a waste more often than it has been used
beneficially. EPA actively promotes the beneficial use of sewage sludge for a variety of reasons (49 FR
24358, June 12, 1984). However, because sewage sludge may also contain toxic chemicals and
pathogens, any use or disposal practice must be carefully managed to prevent adverse impacts on public
health and the environment.
Sewage sludge has been regulated under various environmental statutes. In the past, it was regulated
principally under the solid waste disposal regulations at 40 CFR Part 257, jointly promulgated under the
Resource Conservation and Recovery Act (RCRA) and the CWA. In addition, the Marine Protection,
Research, and Sanctuaries Act (MPRSA) regulated the dumping of sewage sludge to oceans and estuaries,
until the Ocean Dumping Ban Act of 1988 prohibited this disposal practice. Finally, the Clean Air Act
(CAA) regulates the air emissions (primarily particulates) from municipal sewage sludge incinerators.
The 1977 amendments to the CWA directed EPA to develop regulations containing guidelines for the use
and disposal of sewage sludge. In 1984, EPA's Office of Water convened a Sludge Task Force that made
recommendations for the development of a sewage sludge management program and published guidance
on the metals content of sewage sludge applied to land used for growing food crops. In 1987, Section
405(d) of the CWA was amended to require EPA to establish standards that adequately protect public
health and the environment from any reasonably anticipated adverse effects from the use or disposal of
sewage sludge. In response, EPA developed and published technical standards and requirements on
February 19, 1993 (58 FR 9248), codified in 40 CFR Part 503.
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1. INTRODUCTION
1.2 SEWAGE SLUDGE USE OR DISPOSAL PRACTICES
The National Sewage Sludge Survey (NSSS), which began in August 1988 and was completed in
September 1989, was conducted to support the development of the Part 503 regulations.1 It obtained
analytical data on sludge quality, and information on sewage sludge generation, treatment, and final use
and disposal practices. The survey focused on POTWs with either primary, secondary or advanced
treatment of wastewater. The survey results show that frequency of particular disposal options varies
widely by POTW size, except for land application, which is used frequently by all sizes of POTWs. For
example, most small POTWs use surface disposal, while this practice is uncommon among large POTWs.
Similarly, incineration and ocean disposal have been used by many large POTWs, but hardly at all by
small POTWs. The tables on the following pages provide more details on POTW sewage sludge use or
disposal options.
Table 1-1 shows national estimates of the number and percentage of POTWs managing sewage sludge
by major use or disposal practice and the quantity of sewage sludge managed under each practice. The
most prevalent practice is land application (34.6 percent), followed by placement in co-disposal landfills
(with municipal solid waste) (22.2 percent) and surface disposal (10 percent).
Table 1-2 reports national estimates of the total annual quantity and percentage of sewage sludge by use
or disposal practice and by POTW size category. As can be seen on the table, POTWs with a design
flow of over 100 million gallons per day (mgd) account for over 28 percent of sewage sludge used or
disposed. All POTWs over 10 mgd use or dispose of approximately 68 percent of the annual total
sewage sludge. In contrast, POTWs of less than one mgd account for only 7.6 percent of the sewage
sludge used or disposed annually.
The most frequently used disposal methods do not necessarily receive the largest quantity of sewage
sludge volume, because of the differences in use and generation rates among small and large POTWs.
Table 1-2 shows that land application (33.3 percent), co-disposal landfills (34 percent), and incineration
(16.1) account for the largest quantities of sewage sludge. Surface disposal represents only 10.3 percent
of sewage sludge disposed.
'NSSS data were initially reported in 55 FR 47210, November 9, 1990.
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1. INTRODUCTION
TABLE 1-1 NUMBER OF POTWS AND THE QUANTITY OF SEWAGE SLUDGE
USED/DISPOSED ANNUALLY BY USE OR DISPOSAL PRACTICE
Use/Disposal
Practice
Incineration
Land
Application
Co-Disposal:
Landfill
Surface
Disposal
Ocean Disposal
Unknown:
Other
Unknown:
Transfer
All POTWs
POTWs Using a Use/Disposal
Practice
Number
381
4,657
2,991
1,351
133
3,920
25
13,458C
Percent of
POTWs
2.8
34.6
22.2
10.0
i.o
29.1
0.2
100.0d
Quantity of Sewage Sludge
Used/Disposed
Quantity*
864.7
1,785.3
1,818.7
553.7
335.5
0
N/A
5,357.2
Percent of
Sludge
16.1
33.3
33.9
10.3
6.3
0.0
N/A
100.0d
aThousands of dry metric tons.
The National Sewage Sludge Survey was conducted before the Ocean Dumping Ban Act of 1988 generally
prohibited the dumping of sewage sludge into the ocean after December 31, 1991. Ocean dumping of sewage
sludge ended in June 1992.
°The total number of POTWs does not equal the number in the text because some POTWs utilize more than
one use or disposal practice and are counted twice in this table.
Numbers do not add up to 100 percent because of rounding.
Source: 1988 National Sewage Sludge Survey and 1988 Needs Survey. Extracted from 58 FR 9248, February
19, 1993.
Draft-March 1993
1-3
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1. INTRODUCTION
TABLE 1-2 ESTIMATED MASS OF SEWAGE SLUDGE DISPOSED ANNUALLY
BY SIZE OF POTW AND USE OR DISPOSAL PRACTICE
(THOUSANDS OF DRY METRIC TONS)
Use or Disposal
Practice •
Incineration
Land Application:
Agricultural
Land Application:
Compost
Land Application:
Forests
Land Application:
Public Contact
Land Application:
Reclamation
Land Application:
Sale
Land Application:
Undefined
Co-Disposal:
Landfill
Surface Disposal:
Dedicated Site
Surface Disposal:
Monofill
Surface Disposal:
Other
Ocean Disposal*
Unknown: Other
Unknown: Transfer
Total
(% of Total)
Mass of Sewage Sludge Used or Disposed by POTW Size
(in thousands of dry metric tons)
>100mgd
382.9
203.0
22.4
4.5
62.1
52.6
30.6
12.7
518.6
34.2
13.8
31.5
166.1
0
N/A
1,532.0
(28.6)
>10to 100 mgd
346.5
400.8
65.3
24.5
60.5
9.8
27.8
76.4
674.0
124.9
79.8
60.0
157.9
0
N/A
2,128.3
(39.7)
> 1 to 10 mgd
124.8
423.9
31.7
1.0
40.3
2.4
11.9
27.2
495.6
63.2
41.6
17.4
8.0
0
N/A
1,284.1
(24.1)
-------
1. INTRODUCTION
Part 503 addresses three of these practices—land application, surface disposal, and incineration—and is
expected to be applicable to about 48 percent of POTWs nationwide. The facilities that send their sewage
sludge to a municipal solid waste landfill (MSWLF) are also regulated by Part 503, but the MSWLFs are
regulated by 40 CFR Part 258.
1.3 DEVELOPMENT OF THE PART 503 TECHNICAL STANDARDS AND
REQUIREMENTS
To develop Part 503, EPA initially selected pollutants most likely to interfere with the safe use or disposal
of sewage sludge. Using the information available on the toxic effects of these pollutants, the Agency
then developed a list of pollutants for exposure assessment modelling. Because the use or disposal of
sewage sludge affects air, soil, and water, all media were considered in the risk assessment.
The Agency simulated the movement of pollutants into and through the environment with a series of
exposure assessment models to determine the concentrations of pollutants reaching an individual, plant,
or animal (see Figure 1-1). These models used human health and environmental criteria already
published by EPA to evaluate a pollutant's potential to cause harm.2 A risk-based approach was used
that analyzed the effect of a pollutant on a highly exposed individual (human, plant, or animal) and was
supported by an aggregate risk assessment on populations at higher risk. This approach took into account
potential data inadequacies, but did not protect against every conceivable combination of adverse
conditions (58 FR 9252). Where published criteria for specific pollutants did not exist, EPA used
reference doses listed in the Agency's computerized Integrated Risk Information System (IRIS) and risk
specific doses corresponding to an incremental carcinogenic risk level of 1 in 10,000 individuals for all
disposal practices.
The resulting requirements consist of specific numerical limits on the pollutant concentrations in sewage
sludge or equations for calculating pollutant limits. As illustrated in Table 1-3, 11 metals and total
hydrocarbons (THC) are regulated by the Part 503 rule in one or more use or disposal practice, although
not every pollutant is regulated under each practice. For sewage sludge incinerators and, in certain cases,
for surface disposal sites, the limits are based on the permitting authority's evaluation of site-specific
factors, which are provided by the owner/operator of the facility.
In addition to numeric pollutant limits, Part 503 contains:
• General requirements
• Management practices
• Operational standards for land application and surface disposal that include:
- Requirements for reduction of pathogenic organisms or indicator organisms (e.g., fecal
coliform)
'These criteria consisted of national ambient air quality standards (NAAQS), drinking water maximum
contaminant levels (MCLs), surface water quality criteria, and plant and animal toxicity values published in the
scientific literature.
Draft-March 1993 1-5
-------
1. INTRODUCTION
i Human
Animal
Human
Animal
Plant i
Sewage
Sludge
/
' Human/ ,
Home Gardener Jv
Human
Soil Biota
Contaminated
Water
Human
Soil Biota
Predator ol Soil Biota
Human
FIGURE 1-1 EXPOSURE PATHWAYS
Draft-March 1993
1-6
-------
1. INTRODUCTION
TABLE 1-3 POLLUTANTS REGULATED BY PART 503 REGULATIONS
Parameter
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Total Hydrocarbons
Land
Application
X
X
X
X
X
X
X
X
X
X
Surface
Disposal
X
X
X
Incineration
X
X
X
X
X
X
X
X
- Requirements for reducing properties of sewage sludge that attract nuisance vectors (e.g.j
insects)
• Operational standard for incinerators for THC in exit gas
• Monitoring frequencies and record keeping and reporting requirements
As required by Section 405(d) of the Act, the Part 503 regulations require compliance with the standards
(and monitoring, record keeping, and reporting for THC) as expeditiously as possible, but no later than
February 19, 1994, or no later than February 19, 1995, if construction of new pollution control facilities
is required to comply with the regulations. The monitoring, record keeping, and reporting requirements
(except those for THC) are effective on July 20, 1993.
1.4 IMPLEMENTATION OF THE PART 503 REGULATIONS
EPA designed Part 503 so that the standards and requirements would be directly enforceable against most
users or disposers of sewage sludge, whether or not they are required to obtain a permit. This means
that publication of Part 503 in the Federal Register serves as notice to the regulated community of its duty
to comply with the requirements of the rule. Thus, even without the terms and conditions of a sewage
sludge permit, regulated users and disposers of sewage sludge are required to meet the requirements
promulgated in the rule.
Draft-March 1993
1-7
-------
1. INTRODUCTION
In May 1989, EPA revised 40 CFR Part 122 to expand its authority to issue NPDES permits with sewage
sludge standards and requirements to all "treatment works treating domestic sewage" (as defined in
Section 122.2). Treatment works treating domestic sewage include all domestic wastewater treatment
facilities, regardless of ownership. This includes plants that discharge to ground water or treat the
wastewater for reuse, and other facilities that treat or dispose of sewage sludge, such as incinerators,
sewage sludge monofills, and sewage sludge composting facilities. Part 503 will eventually be
implemented through permits issued to all POTWs and other treatment works treating domestic sewage.
The following permits issued under Section 402 of the CWA will be the principal vehicles for
implementing Part 503:
• NPDES permits issued by EPA under Part 122
• State permits issued under an approved sewage sludge program which can be part of the State
NPDES (40 CFR Part 123) program or a non-NDPES (40 CFR Part 501) sewage sludge permit
program.
The Part 503 technical standards and requirements may also be included in permits issued under the
appropriate provisions of:
• Subtitle C of the Solid Waste Disposal Act
• Part C of the Safe Drinking Water Act
• The Marine Protection, Research, and Sanctuaries Act of 1972
• The Clean Air Act [see CWA Section 405(f)(2)].
This guidance document is also intended for use by permit writers in these permitting programs.
Initially, EPA Regions will be responsible for including conditions to implement Part 503 in NPDES
permits issued to treatment works in all States since, currently, no State has received EPA approval of
its State sludge management program.3 Where a State has an approved NPDES program, EPA will issue
a separate NPDES permit to implement the sewage sludge standards and requirements or negotiate with
the State on joint issuance of those NPDES permits containing the Part 503 technical standards and
requirements. Rather than issue individual permits, the EPA Regions may choose to develop and issue
general permits for different categories of facilities or sewage sludge use or disposal practices.
3EPA's sewage sludge permitting program will not displace existing State sewage sludge management
programs. States are encouraged to seek program approval as soon as possible, however, and the Agency
has published the State Sludge Management Program Guidance Manual (EPA 1990) to assist their efforts.
Draft-March 1993 1-8
-------
1. INTRODUCTION
REFERENCES
U.S. Environmental Protection Agency (EPA). 1984. Policy on Municipal Sludge Management.
U.S. EPA. 1990. National Sewage Sludge Survey; Availability of Information and Data, and Anticipated
Impacts on Proposed Regulations. Proposed Rule. 40 CFR Part 503. 55 FR 47210, November 9, 1990.
U.SVEPA. 1991. National Pretreatment Program Report to Congress. 21W-4004 Washington, DC:
Office of Water.
U.S. EPA. 1993. Standards for the Use or Disposal of Sewage Sludge. Final Rule, 40 CFR Part 503.
58 FR 9248, February 19, 1993.
Draft-March 1993 1-9
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2. OVERVIEW OF PART 503 SCOPE AND
CORE PERMIT REQUIREMENTS
QUICK REFERENCE INDEX
Section Page
SEWAGE SLUDGE REGULATED BY PART 503
USE OR DISPOSAL PRACTICES REGULATED BY PART 503
DECIDING WHOM TO PERMIT AND WHICH PART 503 REQUIREMENTS TO APPLY
FACILITIES REQUIRED TO APPLY FOR A PERMIT
APPLYING THE PART 503 REQUIREMENTS IN PERMITS
PERMITTING PROCEDURES
CORE PERMIT CONDITIONS
FACT SHEET
2.1
2.2
2.3
2.4
2-1
2-2
2-5
2-6
2-7
2-11
2-11
2-11
EPA will implement Part 503 directly and through permits issued to POTWs and other treatment works
treating domestic sewage, as defined in 40 CFR 122.2. Regulated facilities that are not required to obtain
a permit are still subject to Part 503, which is directly enforceables against them. This direct
enforceability of Part 503 contrasts with the implementation of CWA effluent limitations, State water
quality criteria, and other requirements for discharges into surface waters, which are generally not
enforceable against the regulated community unless included in a discharger's NPDES permit.
This chapter addresses the following key issues related to implementation of the technical standards:
(1) who and what is subject to Part 503; (2) who should be permitted and what should be the priorities
for permitting; and (3) what requirements apply to the different entities involved, from sewage sludge
generation to final use or disposal. These permitting issues are also discussed in detail in Part XII of the
preamble to the Part 503 regulations (58 FR 9357) and in the national sewage sludge management
program regulations published on May 2, 1989 (54 FR 18716) and amended on February 19, 1993 (58
FR 9404).
2.1 SEWAGE SLUDGE REGULATED BY PART 503
Sewage sludge, generated from the treatment of domestic wastewater, is usually more than 90 percent
water before it is treated further or dewatered. It contains organic solids and dissolved nutrients (e.g.,
nitrogen and phosphorus), making it useful as a supplement to chemical fertilizers and soil conditioners.
Other typical constituents are inorganic ions, such as iron and zinc. While trace amounts of these
inorganic ions are used by plants and organisms, some heavy metals that may be present in sewage sludge
from household or commercial and industrial sources can be toxic to plants, animals, and humans.
Untreated sewage sludge also contains disease-causing pathogenic organisms (e.g., bacteria, viruses,
protozoa, and eggs of parasitic worms). In addition, sewage sludge may contain toxic organic chemicals
from household, commercial, and manufacturing activities that use the sewer system to dispose of these
liquid wastes.
The general definition of sewage sludge includes most residue generated from the treatment of domestic
wastewater, although the first phase of Part 503 regulates only certain types of sewage sludge. Part 503
does not apply to sludges that do not meet the definition of sewage sludge. Moreover, Part 503 also
excludes specific sewage sludges that are regulated by other acts and regulations. If excluded sewage
sludges comply with the requirements of specified acts and regulations, they are considered to be in
Draft—March 1993 2-1
-------
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
compliance with 405 of the CWA. Table 2-1 lists
the sewage sludge material regulated by Part 503
and material that is regulated by other regulations.
In addition, the first phase of the Part 503
regulations does not cover sludge generated at an
industrial facility during the treatment of
industrial wastewater, including sewage sludge
generated during the treatment of industrial
wastewater combined with domestic sewage. The
use and disposal of sludges from these industrial
facilities are regulated under 40 CFR Part 257.
However, the Agency may regulate sewage sludge
generated at these industrial facilities in future
Part 503 rulemakings.
2.2 USE OR DISPOSAL
PRACTICES REGULATED BY
PART 503
The Part 503 regulations cover three sewage
sludge use or disposal practices:
• Land Application — The spraying or
spreading of sewage sludge onto the land
surface; the injection of sewage sludge
below the land surface; or the
incorporation of sewage sludge into the
soil so that the sewage sludge can either
condition the soil or fertilize crops or
vegetation grown in the soil.
Surface Disposal —
sewage sludge on a
The placement of
controlled area of
purpose of final
disposal site can
Definition of Sewage Sludge
Sewage sludge is solid, semi-solid, or liquid
residue generated during the treatment of
domestic sewage in a treatment works. Sewage
sludge includes, but is not limited to, domestic
septage; scum or solids removed in primary,
secondary, or advanced wastewater treatment
processes; and a material derived from sewage
sludge. Sewage sludge does not include ash
generated during the firing of sewage sludge in
a sewage sludge incinerator or grit and
screenings generated during preliminary
treatment of domestic sewage in a treatment
works. [40 CFR 503.9(w)]
Domestic septage is either liquid or solid
material removed from a septic tank, cesspool,
portable toilet, Type III marine sanitation
device, or similar treatment works that receives
only domestic sewage. Domestic septage does
not include liquid or solid material removed
from a septic tank, cesspool, or similar
treatment works that receives either commercial
wastewater or industrial wastewater and does
not include grease removed from a grease trap
at a restaurant. [40 CFR 503.9(f)]
Domestic sewage is waste and wastewater from
humans or household operations that is
discharged to or otherwise enters a treatment
works. [40 CFR 503.9(g)l
land for the sole
disposal. A surface disposal site can be a natural topographical depression, man-made
excavation, or diked area formed primarily of earthen material designed for final disposal (not
storage or treatment of) sewage sludge. Surface disposal sites also include sewage sludge
monofills and sewage sludge piles when used as a means of final disposal.
Incineration — The combustion of organic matter and inorganic matter in sewage sludge by high
temperature in an enclosed device.
Draft—March 1993
2-2
-------
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
TABLE 2-1 TYPES OF SEWAGE SLUDGE COVERED UNDER PART 503 AND
MATERIALS COVERED UNDER OTHER REGULATIONS
Regulated by 40 CFR Part 503
Regulated by Other Regulations
Sewage sludge generated from the treatment
of municipal wastewater and/or domestic
sewage in a publicly, privately, or Federally
owned treatment works that is land applied,
disposed of in a surface disposal site or
MSWLF, or incinerated in a sewage sludge
incinerator
Sewage sludge generated at an industrial
facility during the treatment of domestic
wastewater only
Material derived from sewage sludge, such as
commercially distributed soil conditioners, •
fertilizers, and soil supplements, as well as
sewage sludge mixed with bulking agents
(e.g., wood chips, rice hulls, manure)"
Domestic septage
• Incinerator ash (40 CFR Part 257)
• Grit and screenings removed during the
preliminary treatment of domestic sewage in
a treatment works (e.g., small pebbles, sand,
or other material with a high specific gravity,
and large materials, such as rags) (40 CFR
Part 257)
• Drinking water treatment sludges' (40 CFR
Part 257)
• Commercial and industrial septage, or any
mixture of commercial and/or industrial
septage with domestic septage (40 CFR Part
257) :
• Industrial sludges generated at an industrial
facility during the treatment of industrial
wastewater only (40 CFR Part 257)
• Sewage sludge generated at an industrial
facility during the treatment of a combination
of industrial and domestic wastewater (40
CFR Part 257)
• Hazardous sewage sludge (40 CFR Parts
261-268)
• Sewage sludge containing 50 mg/kg or more
of polychlorinated biphenyls (PCBs) (40 CFR
Part 761)
• Sewage sludge,co-fired in an incinerator with
other wastes (40 CFR Parts 60 and 61)
In addition, a facility that sends its sewage sludge to a municipal solid waste landfill (MSWLF) must meet
certain requirements in Part 503, even though the MSWLF is regulated under Part 258. Part 503 requires
that a treatment works sending sewage sludge to a MSWLF ensure that the sewage sludge is non-
hazardous and non-liquid (i.e., it passes the paint filter test). Part 503 also contains standards applicable
to pathogen and vector attraction reduction processes used to treat sewage sludge. Except for these
pathogen and vector processes, the operations and processes employed in treating sewage sludge are not
regulated by Part 503.
Draft-March 1993
2-3
-------
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
Innovative sewage sludge use and disposal techniques are emerging as communities find new ways to use
or recycle sewage sludge. The Part 503 regulations may be expanded to cover such techniques in the
future. Table 2-2 lists use and disposal practices regulated by Part 503 and other practices.
TABLE 2-2 USE OR DISPOSAL PRACTICES REGULATED BY PART 503 AND
BY OTHER REGULATIONS
Use or Disposal Practices Regulated by
Part 503
Use or Disposal Practices Not Regulated by
Part 503
• Land application of sewage sludge so that it .
can either condition the soil or fertilize crops
or vegetation grown in the soil
- Spraying or spreading sewage sludge on
forest land, pasture, or range land
- Injection below the land surface on
agricultural land ,
- Incorporation into the soil at reclamation
sites or public contact sites
- Application of a sewage sludge product,
such as material composed of sewage
sludge and other solid waste materials
(e.g., leaves or newspaper) as a soil
conditioner or fertilizer supplement on
lawns or gardens.
• Surface disposal
- Placement in a sewage sludge-only landfill
(monofill)
- Spraying, spreading, or piling onto the
land
• Incineration of sewage sludge only or sewage
sludge with auxiliary fuel
• Co-incineration of sewage sludge with more
than 30 percent municipal solid waste (40
CFRPart60)
• Disposal of sewage sludge with municipal
solid waste in a municipal solid waste landfill
(MSWLF) or used as a cover material at a
MSWLF (40 CFR Part 258),. ... .....
• Thermal conversion of sewage sludge to fuel
used to generate steam and electricity
• Use as road soil additive
• Use of sewage sludge slag as concrete
aggregate and for road subbase or granulated
and used in making pavement block
• Use of sewage sludge as raw material to
produce building materials, such as bricks
and concrete
• Use of sewage sludge in concrete and
bituminous mixes
• Use of sewage sludge/kiln dust products if
not used or disposed by land application or
surface disposal
Draft-March 1993
2-4
-------
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
2.3 DECIDING WHOM TO PERMIT AND WHICH PART 503
REQUIREMENTS TO APPLY
The Part 503 regulations apply not only to sewage
sludge itself but also to generators of the sewage.
sludge; to persons involved in treating,
distributing, or disposing of the sewage sludge;
and to users of sewage sludge or a sewage sludge
product. Part 503 also applies to the final use or
disposal site.
Many entities may be involved in sewage sludge
use or disposal, from its generation at the
treatment works to final use or disposal. As
discussed above, almost all of these parties are
regulated by Part 503. However, not all of the
involved entities may need to receive a permit.
For instance, homeowners and farmers who
beneficially use sewage sludge generally are not
subject to any permitting requirements, although
they are still subject to some of the Part 503
requirements. For example, depending upon the
sewage sludge quality, one owner of a land
application site may be required to comply with
specific site restrictions or management practices,
while another owner may be subject to no
restrictions or management practices.
One way in which EPA will implement Part 503
is through permits to facilities that "generate ^—^—m*mm^mm*m^ma^—^^mmmm^—*^
sewage sludge or otherwise effectively control the
quality of sewage sludge or the manner in which it is disposed (and hence its effect on the environment)"
(54 FR 18725-6, May 2, 1989). These targeted facilities are called "treatment works treating domestic
sewage." EPA's regulations give the permit writer broad authority in designating a facility as a treatment
works treating domestic sewage.
Under the NPDES regulations on sludge management, the permit writer has the discretion to permit any
entity that has the "potential for adverse effects on public health and the environment." For example,
the permit writer may issue a permit to a privately owned commercial sewage sludge operation that
changes the quality of the sewage sludge or controls the management of its final disposal. Sewage sludge
quality has been changed if its pollutant concentrations, pathogen levels, or vector attraction properties
have been modified. Processes that do and do not change the quality of the sewage sludge are identified
in Table 2-3.
Definition of Treatment Works Treating
Domestic Sewage
Section 405(f): defines the permitting universe
to include POTWs and other treatment works
treating domestic sewage, including facilities
that are not required to obtain NPDES permits
pursuant to Section 402 of the CWA [Section
405(f)(2)]. "Treatment works treating domestic
sewage" is defined at 40 CFR 122.2 as:
A POTW or any other sewage sludge or
wastewater treatment devices or systems,
regardless of ownership (including Federal
facilities) used in the storage, treatment,
recycling and reclamation of municipal or
domestic sewage, including land dedicated for
the disposal of sewage sludge. This definition
does not include septic tanks or similar
devices. For purposes of this definition,
"domestic sewage" includes waste and waste
water from humans or household operations
that are discharged to or otherwise enter a
treatment works.
Draft—March 1993
2-5
-------
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
TABLE 2-3 PROCESSES THAT AFFECT SEWAGE SLUDGE QUALITY
Processes That Change Sewage Sludge
Quality
Processes That Do Not Change Sewage
Sludge Quality
• Stabilization
• Composting
• Digestion
• Heat treatment
• Blending with bulking agents (such as
sawdust or wood chips)
• Blending with sewage sludge from another
treatment works
Dewatering
Placement of sewage sludge in a bag or other
container
2.3.1 FACILITIES REQUIRED TO APPLY FOR A PERMIT
An estimated 16,000 POTWs and an additional 3,000 to 5,000 other treatment works treating domestic
sewage will be subject to the requirements of Part 503. Table 2-4 identifies the types of facilities
required to apply for sewage sludge permits. Because of the large number of facilities anticipated to be
permitted, EPA has developed a phased approach to incorporate the Part 503 requirements into permits.
This approach is outlined in EPA's February 19,1993, amendments to the sewage sludge permit program
regulations (58 FR 9404).
The first phase of permitting will focus on facilities required to have or requesting site-specific pollutant
limits (i.e., incinerators and some surface disposal sites). These facilities must submit sewage sludge
application information within 180 days of publication of Part 503. For all other treatment works treating
domestic sewage that already have NPDES permits, the Part 503 requirements will be incorporated into
their permits as they are reissued in the normal 5-year cycle. Those facilities that were not required to
obtain or have not requested site-specific limits and that do not have NPDES permits must submit limited
baseline data within one year after Part 503 is published, and then a complete permit application when
requested by the permitting authority. EPA may develop other permitting priorities and maintains the
ability to require permit applications from any facility sooner than under the phased approach.
In general, Part 503 has been developed to be self-implementing; that is, persons can determine through
reading the regulations what requirements apply to specific use or disposal practices. Persons not
complying with the requirements are in violation of the Part 503 regulations and can be subject to
enforcement action. EPA will rely on this direct enforceability of Part 503 in the absence of a permit.
Draft-March 1993
2-6
-------
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
TABLE 2-4 FACILITIES REQUIRED TO APPLY FOR A PERMIT
Facilities .Required To Apply For a Permit
Facilities Not Required To Automatically Apply
For A Permit
• All generators of a sewage sludge that is
ultimately regulated by Part 503
• Industrial facilities that separately treat domestic
wastewater and generate a sewage sludge that is
ultimately regulated by Part 503
• All surface disposal site owners/operators
• All sewage sludge incinerator owners/operators
• Any person who changes the quality of a sewage
sludge that is ultimately regulated under Part 503
(e.g., sewage sludge blenders or composters)
• Industrial facilities that treat a combination of
industrial and domestic wastewater and generate
sewage sludge*
• Sewage sludge land appliers/haulers/transporters
(who do not change the quality of the sewage
sludge)*
• Sewage sludge packagers/baggers (who do not
change the quality of sewage sludge)*
• Land owners of property on which sewage sludge
is land applied*
• Septage haulers/land appliers*
*EPA maintains the ability to request permit applications from these facilities where necessary to protect public
health and the environment.
2.3.2 APPLYING THE PART 503 REQUIREMENTS IN PERMITS
Before drafting the permit, the permit writer needs, to determine:
• If the material being used or disposed by the permit applicant is sewage sludge subject to Part
503
• If the use or disposal practice is covered under Part 503, and if so, which practice the permit
applicant is employing
• All parties handling the sewage sludge from point of generation to final use or disposal and which
one(s) should receive the permit(s).'
The decision tree in Figure 2-1 depicts the process the permit writer will use to answer the above
questions. To answer these questions completely, the permit writer first needs to understand the terms
that Part 503 uses to describe the involved entities.
Table 2-5 defines some of the terms used in Part 503 to identify the regulated community.
Some of the Part 503 requirements apply to the preparer of the sewage sludge, some apply to the applier
of the sewage sludge, and some apply to the owner/operator of the surface disposal site or incinerator.
Therefore, a permit issued to one of these entities may not need to contain all of the Part 503
requirements; the permit should include only those requirements applicable to the particular entity. The
permit writer must use BPJ to determine what conditions should appear in which entity's permit. The
end of Chapters 4, 5 and 7 contains scenarios that demonstrate various possibilities.
Draft-March 1993
2-7
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2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
Step 1. Is the material considered sewage sludge?
the material generated
at a Federal, private, or
publicly owned treatment
works treating domestic
wastewater?
the material
from a septic tank, cesspool.
portable toilet, or Type III
sanitation device that
ives only domesti
sewage?
Is the material
generated at an
industrial facility during
treatment of industrial
wastewater only ?
Material is sewage sludge
Go to Step 2
Material is sewage sludge
Go to Step 2
Material is domestic
septage and is included in
the definition of sewage
sludge.
Go to Step 2
STOP
Material is not sewage
sludge subject to Pan 503
Step 2. Is the sewage sludge regulated by 40 CFR Part 5037
Is the sewage sludge
generated at an industrial
facility during treatment of a
of industrial
domestic wastewater?
Has the sewage sludge been
determined to be hazardous
in accordance with
40 CFR Part 261?
Does the sewage sludge
contain £ 50 mg/kg PCBs
on a dry weight basis?
STOP
Requirements of 40 CFR
Part 503 not applicable
Refer to 40 CFR Part 257
STOP
Requirements of
• 40 CFR Part 503
not applicable
Refer to 40 CFR Pan 261
STOP
Requirements of
40 CFR 503 not applicable
Refer to PCB regulations
at 40 CFR Part 761
FIGURE 2-1. DECISION TREE FOR DETERMINING APPLICABILITY OF PART 503
REQUIREMENTS
Draft—March 1993
2-8
-------
2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
Step 3. Is the activity considered final nie or disposal?
u die sewage sludge placed on
the land for storage?
b the stonge period greater
than two yean?
Activity ii.coosidered final
use or disposal
Goto Step 4
STOP
Requirement! of Put 503
not applicable until final use
or diipocal
Require demonstration that
the land utilized for storage
is not an active sewage sludge unit
is per 5303.20(b). If demonstration
ix not made successfully, continue
to Step 4.
Step 4. Is the sewage sludge use or disposal practice regulated
byPart503?
b the sewage sludge
disposed in a municipal solid
waste landfill?
Is the sewage sludge to be
land applied as defined in
S 503.11(10?
Is the sewage sludge to be\ Yes
disposed on a surface disposal
site as defined in
}503.21(p)7
Is the sewage sludge to be\ Yes
fired in a sewage sludge
incinerator as defined in
}503.41(k)7
Sewage sludge must meet
requirements of
Pan 258 u per }503.4
Requirements of
Part 503
Subparts A, B and D an
applicable
Requirements of
Part 503 Subparts A, C and
D are applicable
Requirements of
Part 503 Subparts A and E
are applicable
STOP
Current or proposed method of
sewage sludge use or disposal
is not subject to Part 503
FIGURE 2-1. DECISION TREE FOR DETERMINING APPLICABILITY OF PART 503
REQUIREMENTS (Continued)
Draft-March 1993
2-9
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2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
TABLE 2-5 TERMS AND DEFINITIONS ESTABLISHING THE SCOPE OF
PART 503 REQUIREMENTS
Applier refers to the person who applies the sewage sludge to the land. The applier may be the same as the
preparer or may be a separate entity. If the preparer applies the sewage sludge to the land, the preparer is the
applier. If the preparer (treatment works) provides the sewage sludge to a farmer who spreads the sewage
sludge onto a field, the farmer is the applier.
Class I sludge management facility is any publicly owned treatment works (POTW), as defined in 40 CFR
501.2, required to have an approved pretreatment program under 40 CFR 403.8(a) [including any POTW
located in a State that has elected to assume local program responsibilities pursuant to 40 CFR 403.10(e)] and
any treatment works treating domestic sewage, as defined in 40 CFR 122.2, classified as a Class I sludge
management facility by the EPA 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 sewage sludge
use or disposal practice to affect public health and the environment adversely. [40 CFR 503.9(c)]
Class I facilities are a subset of the universe of POTWs and other treatment works treating domestic sewage.
They are subject to the Part 503 reporting requirements, along with POTWs with a design flow equal to or
greater than one million gallons per day and POTWs that serve 10,000 people or more.
Person is an individual, association, partnership, corporation, municipality, State or Federal agency, or an
agent or employee thereof. [40 CFR 503.9(q)]
Place sewage sludge or sewage sludge placed means disposal of sewage sludge on a surface disposal site.
[40 CFR 503.9(s)]
Preparer is either the person who generates sewage sludge during the treatment of domestic sewage in a
treatment works or the person who derives a material from sewage sludge [see also definition of "person who
prepares sewage sludge" in 40 CFR 503.9(r)]. The preparer will usually be the generator of the sewage
sludge (i.e., the treatment works). The generator may be a Federally owned, publicly owned, or privately
owned treatment works. However, in some cases, the treatment works may give the sewage sludge to another
person who further treats the sewage sludge or in some manner changes the quality of the sewage sludge
before it is applied to the land. In this case, both the treatment works and the other person involved in
changing the sewage sludge quality are preparers. An example of a preparer would be a commercial
operation composting sewage sludge from one or more POTWs.
Store or storage of sewage sludge is the placement of sewage sludge on land on which the sewage sludge
remains for two years or less. This does not include the placement of sewage sludge on land for treatment.
[40 CFR 503.9(y)]
Treat or treatment of sewage sludge is the preparation of sewage sludge for final use or disposal. This
includes, but is not limited to, thickening, stabilization, and dewatering of sewage sludge. This does not
include storage of sewage sludge. [40 CFR 503.9(z)]
Treatment works is either a Federally owned, publicly owned, or privately owned device or system used to
treat (including recycle and reclaim) either domestic sewage or a combination of domestic sewage and
industrial waste of a liquid nature. [40 CFR 503.9(aa)]
Draft-March 1993 2-10
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2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
2.4 PERMITTING PROCEDURES
A NPDES permit or other sewage sludge permit containing the Part 503 requirements, as well as the
permit issuance process (including development of a fact sheet and public notice requirements), must
follow the NPDES permitting regulations in 40 CFR Parts 122 and 124. This section reviews appropriate
conditions for a sewage sludge permit and highlights fact sheet requirements.
2.4.1 CORE PERMIT CONDITIONS
Generally, each permit issued to a treatment works treating domestic sewage should contain:
• Specific numerical limits applicable to sewage sludge quality
• General requirements, operational standards, and management practices
• Compliance monitoring requirements
• Reporting and record keeping requirements
• Standard permit conditions required by Part 122
• Any other conditions related to any aspect of sewage sludge management developed on a case-by-
case basis where such conditions are necessary to protect public health and the environment.
As indicated above, each permit must contain the standard conditions required in every NPDES permit.
Previously, EPA modified some of these standard conditions to specifically include sewage sludge
activities; these modified conditions are shown in Table 2-6. For a sewage sludge-only permit, some of
the NPDES standard conditions from Section 122.41, which focus on discharges to waters of the United
States, do not apply (e.g., upset and bypass).
2.4.2 FACT SHEET
The permit writer must develop a fact sheet for each Class I facility and for each permit that includes a
land application plan, in accordance with the NPDES requirements in §124.56. When a fact sheet is not
required, a statement of basis must be prepared. A fact sheet must include:
• Any calculations or other necessary explanation of the derivation of specific standards for sewage
sludge use or disposal, including a citation to the standard for sewage sludge use or disposal as
required by §122.44 and reasons why they are applicable [40 CFR 124.56(a)].
• A brief description of the facility and when appropriate, a sketch or detailed description of the
location of the regulated activity described in the application.
• For permits that include a sewage sludge land application plan under §501.15(a)(2)(ix), a brief
description of how each of the required elements of the land application plan are addressed in the
permit [40 CFR 124.56(c)].
• The name and telephone number of a contact person.
• A description of the procedures for reaching a final decision on the draft permit.
Draft—March 1993 2-11
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2. OVERVIEW OF PART 503 SCOPE AND CORE PERMIT REQUIREMENTS
TABLE 2-6 NPDES STANDARD CONDITIONS THAT WERE
MODIFIED TO INCLUDE SEWAGE SLUDGE
122.41(a)(l), Duty to comply - The permittee shall comply with effluent standards or prohibitions
established under section 307(a) of the Clean Water Act for toxic pollutants and with standards for sewage
sludge use or disposal established under section 405(d) of the CWA within the time provided in the
regulations that establish these standards or prohibitions or standards for sewage sludge use or disposal,
even if the permit has not yet been modified to incorporate the requirement.
122.41(d), Duty to mitigate - The permittee shall take all reasonable steps to minimize or prevent-any
discharge or sludge use or disposal in violation of this permit which has a reasonable likelihood of
adversely affecting human health or the environment.
122.41(j)(2), Records retention - Except for records of monitoring information required by this permit
related to the permittee's sewage sludge use and disposal activities, which shall be retained for a period of
at least five years (or longer as required by 40 CFR Part 503).
122.41(j)(4), Monitoring per EPA approved test procedures - Monitoring results must be conducted
according to test procedures approved under 40 CFR Part 136 or, in the case of sludge use or disposal,
approved under 40 CFR Part 136 unless otherwise specified in 40 CFR Part 503, unless other test
procedures have been specified in the permit.
122.41(l)(l)(iii), Notification of significant change - The alteration or addition results in a significant
change in the permittee's sludge use or disposal practices, and such alteration, addition, or change may
justify the application of permit conditions that are different from or absent in the existing permit, including
notification of additional use or disposal sites not reported during the permit application process or not
reported pursuant to an approved land application plan.
122.41(l)(4)(i), Monitoring to be reported on form provided or specified by Director - Monitoring results
must be reported on a Discharge Monitoring Report (DMR) or forms provided or specified by the Director
for reporting results of monitoring of sludge use or disposal practices.
122.41(l)(4)(ii), Submission of all data collected using EPA approved test procedures - If the permittee
monitors any pollutant more frequently than required by the permit using test procedures approved under
40 CFR Part 136 unless otherwise specified in 40 CFR Part 503, or as specified in the permit, the results
of this monitoring shall be included in the calculation and reporting of the data submitted in the DMR or
sludge reporting form specified by the Director.
(From 40 CFR 122.41 as revised on May 2, 1989, 54 FR 18783)
Draft-March 1993 2-12
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3. PERMIT APPLICATION
QUICK REFERENCE INDEX
Section Page
PERMIT APPLICATION INFORMATION REQUIRED FOR ALL
SEWAGE SLUDGE USE OR DISPOSAL PRACTICES 3.1 3-1
PERMIT APPLICATION INFORMATION FOR LAND APPLICATION OF
SEWAGE SLUDGE 3.2 3-3
PERMIT APPLICATION INFORMATION FOR SURFACE DISPOSAL OF
SEWAGE SLUDGE
PERMIT APPLICATION INFORMATION FOR SEWAGE SLUDGE INCINERATORS
REVIEWING THE APPLICATION
COLLECTING ADDmONAL INFORMATION
3.3
3.4
3.5
3.6
3-10
3-18
3-22
3-23
To develop a permit that applies the appropriate Part 503 sludge use or disposal requirements, the permit
writer must obtain information about the facility that will receive the permit. The National Pollutant
Discharge Elimination System (NPDES) regulations in Section 122.21 require the submission of a
complete permit application to the permitting authority. Application requirements for treatment works
treating domestic sewage are specified in Sections 122.21 (c) and (d). This chapter is designed to help
the permit writer understand the permit application information required by the regulations and the
appropriate facility-specific information that may need to be submitted.
EPA is the permitting authority in any State that has not developed a sludge management program and
received approval to issue permits under 40 CFR Part 123 or Part 501. Therefore, a treatment works
treating domestic sewage submits its application for a sewage sludge use or disposal permit to the EPA
unless the applicant's State has an approved State program.
3.1 PERMIT APPLICATION INFORMATION REQUIRED FOR ALL
SEWAGE SLUDGE USE OR DISPOSAL PRACTICES
Section 122.21 (c) and (d) require that the following information be obtained in the application: general
facility information, annual sludge volume, other permits held or requested, a topographical map
extending 1 mile beyond the facility boundary, a narrative description of use and/or disposal practices,
any sludge monitoring data the applicant may have, and any other information requested by the permit
writer. The permit applicant must identify its chosen use or disposal practices and submit information
to enable the permitting authority to determine compliance with the standards or to verify site-specific
pollutant limits where the applicant requests or is required to have them.
Table 3-1 lists the general information required from all applicants for sewage sludge use or disposal
permits. Sections 3.2, 3.3, and 3.4 provide specific information related to each of the three use or
disposal practices regulated by Part 503.
Draft—March 1993 3-1
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3. PERMIT APPLICATION
TABLE 3-1 GENERAL PERMIT APPLICATION INFORMATION FOR ALL SEWAGE
SLUDGE USE OR DISPOSAL PRACTICES
General Information
1. Name, mailing address, and location of treatment works
2. Indication of whether the treatment works is located on Indian lands
3. Operator's name, address, telephone number, and ownership status (e.g., Federal, State, private, public,
or other entity)
4. Detailed description of sewage sludge use or disposal practices conducted by the applicant which require
it to obtain a permit under Part 503, including:
• Land application
• Surface disposal
• Incineration
• Co-disposal in municipal solid waste landfill
5. Location of any sites where sewage sludge is transferred for treatment, use, and/or disposal if outside
the applicant's property boundaries
6. List of all permits or construction approvals under any of the following programs, including compliance
history:
• RCRA Hazardous Waste Management program
• UIC program under SDWA
• NPDES under CWA
• Dredge or fill permits under Section 404 of CWA
• PSD program under CAA
• Nonattainment program under CAA
• NESHAPs under CAA
• Ocean dumping permit under MPRSA
• Any State or local environmental permit
Draft—March 1993 3-2
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3. PERMIT APPLICATION
TABLE 3-1 GENERAL PERMIT APPLICATION INFORMATION FOR ALL SEWAGE
SLUDGE USE OR DISPOSAL PRACTICES (Continued)
General Information
7.
8.
9.
10.
11.
Topographic map (7'/i standard USGS preferred) that extends 1 mile beyond property boundaries
indicates the following:
• Location of sewage sludge management facilities (identify all on-site disposal sites)
• Location of all water bodies
• Location of wells used for drinking water listed in the public record or otherwise known to the
applicant on-site and within U mile of property boundaries
and
Amount of sewage sludge (total dry metric tons per 365-day period) generated, and/or received from
offsite, and/or sent offsite.
Name of any preparer, applier, or other contractor who applies or disposes of sewage sludge if different
from the applicant
Existing data on sewage sludge characteristics, including:
• Percent solids
• Pollutant concentrations
• Determination of whether sewage sludge is hazardous (results of TCLP tests or a certification)
contains PCBs
Signatures and certifications as described in 40 CFR 122.22 for permit applications and reports
or
3.2 PERMIT APPLICATIONINFORMATIONFORLANDAPPLICATIONOF
SEWAGE SLUDGE
In addition to the information listed in Table 3-1, the permit writer will need additional specific
information when the facility indicates that its chosen final use or disposal option is land application.
Tables 3-2 and 3-3 identify specific information the permit writer may need:
• Table 3-2 lists the minimum information needed by the permit writer to apply the Part 503
requirements for land application of sewage sludge.
• Table 3-3 lists additional information that the permit writer may want to request from the
applicant if there is a need to provide special or more site-specific conditions. Although this
table is not all-inclusive, it should help the permit writer identify additional information needed
for developing special conditions.
Draft—March 1993 3-3
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3. PERMIT APPLICATION
TABLE 3-2 MINIMUM PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION
Sewage Sludge Data
1. Description of proposed final use for bulk sewage sludge or sewage sludge sold or given away in bags or
other containers (e.g., turf farms, agricultural land, forest, reclamation, golf courses, or home
gardeners)
2. If bulk sewage sludge, the following site information required when proposed site(s) are submitted with
application:
• Location of each site (street address or latitude and longitude) where bulk sewage sludge is applied
• Types of land use
- Agricultural
- Forest
- Public contact
- Reclamation
- Lawn or home garden
- Other (specify)
3. Nitrogen content
Information on Pathogen Reduction Processes
Identification of the pathogen reduction process(es) employed
Information on Vector Attraction Reduction Processes
Identification of the vector attraction reduction process(es) employed
TABLE 3-3 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION
Information for Pathogen Reduction
1. Detailed process description of the pathogen reduction process(es) used on-site showing compliance with
the alternative selected by the applicant. Specific information on the operating parameters and
performance indicators is needed for each alternative.
• Class A - Alternative 1
- Density of fecal coliform or Salmonella bacteria
- Temperature of sewage sludge and how long maintained
- Percent solids
• Class A - Alternative 2
- Density of fecal coliform or Salmonella bacteria
- pH of sewage sludge and how long maintained
- Temperature of sewage sludge and how long maintained
- Percent solids achieved by air drying
Draft—March 1993 3-4
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3. PERMIT APPLICATION
TABLE 3-3 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION (Continued)
Information for Pathogen Reduction
• Class A - Alternative 3
- Density of fecal coliform or Salmonella bacteria
- Density of viruses prior to pathogen reduction (number of plaque forming units/4 grams total solids)
- Documentation of values or ranges of values for operating parameters for pathogen reduction
processes used
- Density of viable helminth ova
• Class A - Alternative 4
- Density of fecal coliform or Salmonella bacteria
- Density of viruses
- Density of viable helminth ova
• Class A - Alternative 5
- Density of fecal coliform or Salmonella bacteria
- Composting
- Type of composting process
— Temperature(s) of sewage sludge and how long maintained
- Heat drying
— Moisture content of sewage sludge
— Temperature of sewage sludge
~ Temperature of gas leaving dryer
- Heat treatment
— Temperature of sewage sludge and how long maintained
- Thermophilic aerobic digestion
— Mean cell residence time
— Temperature of sewage sludge
- Beta ray irradiation
— Beta ray dosage
— Room temperature
- Gamma ray irradiation
— Type of isotope used
— Room temperature
- Pasteurization
— Temperature of sewage sludge and how long maintained
• Class A - Alternative 6
- Density of fecal coliform or Salmonella bacteria
- Information necessary to demonstrate PFRP equivalency
Draft-March 1993 3-5
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3. PERMIT APPLICATION
TABLE 3-3 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION (Continued)
Information for Pathogen Reduction
• Class B - Alternative 1
- Number of samples collected during each monitoring episode
- Calculations for the geometric mean of the density of fecal coliform measured
• Class B - Alternative 2
- Aerobic digestion
— Mean cell residence time
— Temperature
- Air drying
- Drying time
- Ambient temperature
- Anaerobic digestion
— Mean cell residence time
— Temperature
- Composting
- Type of composting process
— Temperarure(s) of sewage sludge and how long maintained
- Line stabilization
— pH of sludge/lime mixture
~ Time pH maintained
• Class B - Alternative 3
- Information necessary to demonstrate PSRP equivalency
2. Description of how the site restriction for Class B pathogen reduction processes will be implemented on-
site (if applicable) for the following:
• Public access restrictions
• Feed crop restrictions
• Food crop restrictions
• Animal grazing restrictions
• Turf harvest restrictions
Information for Vector Attraction Reduction
Detailed description of vector attraction reduction process(es). Specific operational parameters and
performance information for each alternative should be included.
• Volatile solids reduction in sewage sludge of minimum 38 percent
- Monitoring data before and after sludge treatment
- Sampling points
- Date of analysis
- Number of analyses
Draft-March 1993 3-6
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3. PERMIT APPLICATION
TABLE 3-3 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION (Continued)
Information for Vector Attraction Reduction
• Laboratory demonstration for anaerobically digested sludges not meeting 38 percent volatile solids
reduction
- Description of bench scale test
- Temperature maintained during test
- Volatile solids reduction after 40 days
• Laboratory demonstration for aerobically digested sludges not meeting 38 percent volatile solids
reduction
- Description of bench scale test
- Temperature maintained during test
- Volatile solids reduction after 30 days
• Aerobic digestion with a specific oxygen uptake rate (SOUR) of less than or equal to 1.5 mg oxygen
per hour per gram total solids
- Monitoring data for SOUR
- Temperature of sludge during analysis
- Date of analyses
- Number of analyses
• Aerobic digestion for 14 days at > 40°C
- Treatment time
- Sludge temperature (minimum and average)
• Alkali addition
- PH
- Time maintained at pH
• 75 percent solids content prior to mixing with other materials for sewage sludge without unstabilized
solids from primary treatment
- Moisture content of sewage sludge
- Origin of sewage sludge
• 90 percent solids content prior to mixing with other materials for sewage sludge with unstabilized
solids from primary treatment
- Moisture content of sewage sludge
- Origin of sewage sludge
• Injection below the surface
- Time between pathogen reduction and injection
• Incorporation into soil
- Time between pathogen reduction and incorporation
- Time between placement and incorporation
Draft-March 1993 3-7
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3. PERMIT APPLICATION
TABLE 3-3 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION (Continued)
Site Information
1. • Proximity of site to flood plains
• Slope of site
• Run-on/run-off controls (if any)
• Ground water monitoring (if any)
• Access controls
• Buffer strips around surface water
• Proximity of drinking water wells and dwellings to site
• Minimum depth to ground water
2. Description of how the proposed site(s) (submitted with application) will be managed including:
• Detailed description of land application methods (i.e., sprayed or spread on land surface, injected
below the land surface, or incorporated into the soil)
• Sewage sludge application rates
• Pollutant loading rates
• Agronomic rates
• Seasonal application restrictions due to:
- Frozen or snow covered land
- Flooding or rise in water table
- Rainfall
• Description of how compliance with site management controls will be documented
Land Application Plan
Land application plan (if land application sites are not identified at the time of permit application), including:
• A description of the geographical area covered by the plan (total hectares and location)
• Site selection criteria, including: slope of appropriate sites, run-off/run-off control measures, buffer
strips around surface water, drinking water wells and dwellings, minimum depth to usable ground
water, and an evaluation of how site soil texture, parent geologic material, permeability, infiltration,
and drainage will be factored into the site selection
• A description of how sites will be managed including: sludge application rates, pollutant loading
rates, seasonal limitations and how compliance with the management practices (e.g., buffer strips,
slope limitations) will be documented
Draft—March 1993 3-8
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3. PERMIT APPLICATION
TABLE 3-3 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION (Continued)
Land Application Plan
• Procedures for advance notification to permitting authority of specific land application sites and
reasonable time for permitting authority to object prior to sewage sludge application
• Procedures for advance public notice according to State and local law with notice to landowners and
occupants adjacent to or abutting the proposed land application site.
Ground Water Data
Existing ground water monitoring data or drilling log data for the land application sites, including:
• Pollutant concentrations
• Location of wells sampled
• Sample dates
• Dates of analyses
Information on Management Practices
1. Crop information, including:
• Type of crop
• Expected crop yield
• Previous crop(s)
• Nitrogen requirement of crop (kilograms per hectare)
• Estimated residual nitrogen (from previous crops, residues, or prior sewage sludge applications)
• Estimated nitrogen from commercial fertilizers to be used prior to sewage sludge applications
• Estimated nitrogen from commercial fertilizers to be used prior to planting and during growing season
• Estimated nitrogen from sewage sludge
• Estimated planting date(s)
• Estimated harvest date(s)
• Estimated sewage sludge application date (before planting, after harvest, or during crop growing
period)
• Crop residue management method
• Phosphorous requirement of crop (kilograms per hectare)
• Estimated phosphorus from commercial fertilizers to be used prior to planting and during growing
season
• Estimated phosphorus from sewage sludge
• Crop irrigation method (e.g., flood, furrow, sprinkler, or big gun) and schedule
Draft—March 1993 3-9
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3. PERMIT APPLICATION
TABLE 3-3 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR LAND APPLICATION (Continued)
2.
3.
4.
Information on Management Practices
Description of the criteria used to determine that the bulk sewage sludge will not adversely
threatened or endangered species of plant, fish, or wildlife or its designated critical habitat,
Identification of whether any threatened or endangered species exist on site
Identification of whether there any exist within 1 mile of the site
If present, list of species, where they are located, and type of habitat
Identification of any potential adverse impacts on the species or habitat
Description of any management practices used to mitigate impact
Copy of proposed label/information sheet
Information on Management Practices
Proximity to wetlands
affect a
including:
3.3 PERMIT APPLICATION INFORMATION FOR SURFACE DISPOSAL OF
SEWAGE SLUDGE
Tables 3-4 and 3-5 provide specific permit application information for surface disposal facilities.
• Table 3-4 provides the minimum information needed to apply the Part 503 regulations for surface
disposal of sewage sludge.
• Table 3-5 lists additional information that the permit writer may want to request from the
applicant if there is need to provide special conditions in a surface disposal permit based on-site-
specific conditions. Although this table is not all-inclusive, it should help the permit writer
identify additional information needed for developing special conditions.
It is especially critical that the permit writer have the following information in order to determine the
appropriate pollutant concentrations to apply to the sewage sludge placed in a surface disposal site.
• Whether the active sludge unit has a liner and leachate collection system (the unit must have both;
if the unit has only a liner or only a leachate collection system, it is designated as a unit without
a liner and leachate collection system).
• If the unit does not have a liner and leachate collection system, the permit writer will need to
know whether the unit boundary is equal to or greater than 150 meters from the property line of
the site. If less than 150 meters, the actual distance between the unit boundary and the property
line must be known.
Draft-March 1993 3-10
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3. PERMIT APPLICATION
TABLE 3-4 MINIMUM PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL
Minimum Information
1. Site information, including:
• Size of entire surface disposal site (hectares)
• Number of separate active or closed sewage sludge units
• Volume capacity (for monofills or lagoons)(cubic meters).
2. Information on whether site has liner and leachate collection system, including information on whether
liner has a hydraulic conductivity of 1 x IQr7
3. Distance from active sewage sludge unit boundary to site property line
Information on Pathogen Reduction Processes
Identification of the pathogen reduction process(es) employed
Information on Vector Attraction Reduction Processes
Identification of the vector attraction reduction process(es) employed
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL
Additional Information For Surface Disposal
1. Description of sludge storage practices, including:
• Duration of storage
• Management practices; if sludge remains on the land for more than 2 years, include
- Name and address of person who places sewage sludge on the land
- Name and address of land owner or lease holder
- Location (street or latitude and longitude) where stored
- Discussion of why the sludge must remain on the land prior to final use or disposal
(Information required if sludge remains on the land for more than 2 years; permit writer may
consider requiring this information if there are concerns that storage period may extend beyond 2
years)
Draft-March 1993 3-11
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3. PERMIT APPLICATION
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL (Continued)
Additional Information For Surface Disposal
2. Description of site location factors for each active sewage sludge unit, considering:
• Location in a wetland without a Section 404 permit
• Location within 60 meters of a fault that has displacement in Holocene time
• Location in an unstable area
3. Design specifications and/or calculations to show that:
• Sewage sludge unit can withstand maximum recorded horizontal ground level acceleration (if
located in a seismic impact-zone) including slope design, strength of components, etc.
• Sewage sludge units will not restrict the flow of a base flood
• Sewage sludge unit is located in an area where adequate support for structural components exists
(e.g., soil tests, etc.)
4. Description of liner and leachate collection system and operation and maintenance program,
including:
• Type of system and liner
• Operations (collection and removal of leachate)
• Maintenance and inspection schedules
(Information required only if sludge unit includes a liner or leachate system)
5. Description of the treatment and/or disposal of leachate under an existing NPDES permit, including:
• Description of any cm-site treatment systems
• Name of POTW, local limits or pretreatment standards that must be met
• Name and location of leachate disposal site and description of how disposed
(Information required only if sludge unit includes a liner or leachate system)
Draft-March 1993 3-12
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3. PERMIT APPLICATION
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL (Continued)
Additional Information For Surface Disposal
6. Description of the criteria used to determine that the active sewage sludge unit will not cause or
contribute to the harm of a threatened or endangered species of plant, fish or wildlife or result in the
destruction or adverse modification of the critical habitat of a threatened or endangered species,
including:
• Identification of whether there are any threatened or endangered species on site
• Identification of whether there are any threatened or endangered species within 1 mile of the site
• If present, a list of species where they are located, and type of habitat
• Description of practices or operations used to minimize impact
7. Description of controls to collect and dispose of run-off from the sewage sludge unit for a 25-year,
24-hour storm event, including:
• Existing NPDES permit requirements
• Operation and maintenance of run-off controls
• Structural controls (e.g., basins)
• Controls for base flood, if appropriate
• Management practices
• Site drainage patterns
8. Description of the methane gas monitoring system, including:
• Monitoring equipment
• Sampling points within site structures
• Sampling points at the property line
(Information required only if disposal site is covered or owner/operator is planning a final cover
when closed)
Draft-March 1993 3-13
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3. PERMIT APPLICATION
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL (Continued)
Additional Information For Surface Disposal
9. Description of management practices to be used to control methane gas at the site and emergency
procedures to protect public safety if methane gas limits are exceeded, including:
• Venting operations
• Treatment of sewage sludge
• Evacuation plans
• Monitoring programs
(Information required only if disposal site is covered or owner/operator is planning a final cover
when closed)
10. Description of how the following site restrictions will be implemented on site:
• Public access restrictions
• Feed crop restrictions
• Food crop restriction
• Animal grazing restrictions
11. For active sewage sludge units, a description of management practices to avoid aquifer contamination
• Certification or ground-water monitoring program
12. Existing ground-water monitoring data for surface disposal sites, including:
• Pollutant concentrations
• Location of wells sampled
• Sampling and analyses dates
13. Site characteristics (for monofill or lagoon)
• Hydraulic conductivity
• Depth to water table (inches below surface)
• Amount of rainfall (inches)
• Soil types
Draft—March 1993 3-14
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3. PERMIT APPLICATION
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL (Continued)
Additional Information For Surface Disposal
14. Sewage sludge unit closure and post closure plan describing how the site will be closed and the
measures taken to protect human health and environment (if any sewage sludge units are to be closed
during the permit term), including:
• A description of the final cover
• A discussion of how the final cover accommodates settling at the site and controls erosion
• A discussion of how final cover will be maintained for a period of 3 years after closure
• A description of methane gas monitoring systems in structures and at the property boundary for a
period of 3 years after closure if the site does not have another active unit
• A discussion of public access restriction for a period of 3 years after closure if the site does not
have another active unit
• Procedures for notification of subsequent owners of the site that sewage sludge was placed on the
land.
(Information is required 180 days prior to closure and does not necessarily have to be submitted at
the time of permit application. Permit writers may consider asking the permittee if it plans to close a
site within the first year of the permit.)
15. Detailed process description of the pathogen reduction process(es) used on-site showing compliance
with the alternative selected by the applicant. Specific information on the operating parameters and
performance indicators is needed for each alternative.
• Class A - Alternative 1
- Density of fecal coliform or Salmonella bacteria
- Temperature of sewage sludge and how long maintained
- Percent solids
• Class A - Alternative 2
- Density of fecal coliform or Salmonella bacteria
- pH of sewage sludge and how long maintained
- Temperature of sewage sludge and how long maintained
- Percent solids achieved by air drying
• Class A - Alternative 3
- Density of fecal coliform or Salmonella bacteria
- Density of viruses prior to pathogen reduction (number of plaque forming units/4 grams total
solids)
- Documentation of values or ranges of values for operating parameters for pathogen reduction *
processes used
- Density of viable helminth ova
Draft-March 1993 3-15
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3. PERMIT APPLICATION
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL (Continued)
Additional Information For Surface Disposal
• Class A - Alternative 4
- Density of fecal coliform or Salmonella bacteria
- Density of viruses
- Density of viable helminth ova
• Class A - Alternative 5
- Density of fecal coliform or Salmonella bacteria
- Composting
- Type of composting process
— Temperatures) of sewage sludge and how long maintained
- Heat drying
— Moisture content of sewage sludge
- Temperature of sewage sludge
— Temperature of gas leaving dryer
- Heat treatment
— Temperature of sewage sludge and how long maintained
- Thermophilic aerobic digestion
- Mean cell residence time
~ Temperature of sewage sludge
- Beta ray irradiation
— Beta ray dosage
— Room temperature
- Gamma ray irradiation
- Type of isotope used
— Room temperature
- Pasteurization
— Temperature of sewage sludge and how long maintained
• Class A - Alternative 6
- Density of fecal coliform or Salmonella bacteria
- Information necessary to demonstrate PFRP equivalency
• Class B - Alternative 1
- Number of samples collected during each monitoring episode
- Calculations for the geometric mean of the density of fecal coliform measured
• Class B - Alternative 2
- Aerobic digestion
— Mean cell residence time
— Temperature
- Air drying
— Drying time
— Ambient temperature
- Anaerobic digestion
- Mean cell residence time
— Temperature
Draft-March 1993 3-16
-------
3. PERMIT APPLICATION
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL (Continued)
Additional Information For Surface Disposal
• Class B - Alternative 2 (continued)
- Composting
- Type of composting process
- Temperatures) of sewage sludge and how long maintained
- Line stabilization
— pH of sludge/lime mixture
— Time pH maintained
• Class B - Alternative 3
- Information necessary to demonstrate PSRP equivalency
Information For Vector Attraction Reduction
1. Detailed description of vector attraction reduction process(es). Specific information for each
alternative includes:
• Volatile solids reduction in sewage sludge of minimum 38 percent
- Monitoring data before and after sludge treatment
- Sampling points
- Date of analysis
- Number of analyses
• Laboratory demonstration for anaerobically digested sludges not meeting 38 percent volatile solids
reduction
- Description of bench scale test
- Temperature maintained during test
- Volatile solids reduction after 40 days
• Laboratory demonstration for aerobically digested sludges not meeting 38 percent volatile solids
reduction
- Description of bench scale test ' '
- Temperature maintained during test
- Volatile solids reduction after 30 days,
• Aerobic digestion with a specific oxygen uptake rate (SOUR) of less than or equal to 1.5 mg
oxygen per hour per gram total solids
- Monitoring data for SOUR *
- Temperature of sludge during analysis
- Date of analyses
- Number of analyses
• Aerobic digestion for 14 days at > 40°C
- Treatment time
- Sludge temperature (minimum and average)
• Alkali addition
- pH
- Time maintained at pH
Draft—March 1993 3-17
-------
3. PERMIT APPLICATION
TABLE 3-5 ADDITIONAL PERMIT APPLICATION INFORMATION
FOR SURFACE DISPOSAL (Continued)
Information For Vector Attraction Reduction
• 75 percent solids content prior to mixing with other materials for sewage sludge without
unstabilized solids from primary treatment
- Moisture content of sewage sludge
- Origin of sewage sludge
• 90 percent solids content prior to mixing with other materials for sewage sludge with unstabilized
solids from primary treatment
- Moisture content of sewage sludge
- Origin of sewage sludges
• Injection below the surface
- Time between pathogen reduction and injection
• Incorporation into soil
- Time between pathogen reduction and incorporation
- Time between placement and incorporation
• Daily cover (for active sewage sludge units only)
- Description of daily operations
3.4 PERMIT APPLICATION INFORMATION FOR SEWAGE SLUDGE
INCINERATORS
This section present specific information that may be needed from the owner/operator of a sewage sludge
incinerator. The information has been divided into the following two tables.
• Table 3-6 provides the minimum information needed by the permit writer to apply the Part 503
requirements and to develop the site-specific requirements for a sewage sludge incinerator.
• Table 3-7 lists additional information that the permit writer may want to request from the
applicant if there is a need to verity the accuracy of data supplied by the owner/operator or to
develop special conditions. Although the table is not all-inclusive, it should help the permit
writer identify additional information needed for developing special conditions.
In order for the permit writer to develop the appropriate sewage sludge pollutant limits, he/she must
obtain the following application information:
• Control efficiencies for arsenic, cadmium, chromium, lead, and nickel, which are derived from
the permittee's performance test
• Dispersion factor, which is derived from the permittee's air dispersion model results
• Sewage sludge feed rate.
Draft—March 1993 3-18
-------
3. PERMIT APPLICATION
TABLE 3-6 MINIMUM PERMIT APPLICATION INFORMATION FOR
SEWAGE SLUDGE INCINERATORS
Minimum Information
1. Number of incinerator units on site and identification of incinerator type (from among the following):
• Multiple hearth
• Fluidizedbed
• Electric arc
• Rotary kiln
• Other
2. Description of the types of air pollution control devices used, including:
• Wet scrubbers
• Wet electrostatic precipitators
• Filters
• Dry scrubbers
• Others
3. Total sewage sludge feed rates (metric tons per day, dry weight basis) and average daily design rates
for all incinerators
4. Dispersion factors for lead, arsenic, cadmium, chromium, and nickel and how the values were derived
5. Control efficiencies and how the values were derived for lead, arsenic, cadmium, chromium, and nickel
Draft-March 1993 3-19
-------
3. PERMIT APPLICATION
TABLE 3-7 ADDITIONAL PERMIT APPLICATION INFORMATION FOR SEWAGE
SLUDGE INCINERATORS
Additional Information
1. Description of other materials and percentage of total volume incinerated with sewage sludge,
including:
• Natural gas
• Fuel oil
• Coal
• Anaerobic digestion gases
• Municipal solid waste
• Other (specify)
2. Air dispersion model used
• Name of model
• Parameter values used in model (besides stack height)
• Results of model
3. Stack height determined by good engineering practice, either true height if equal to or less than 65
meters or creditable height in accordance with 40 CFR 51.100
4. Number of days incinerators) is operated (in calendar year)
5. Compliance history and concentrations obtained in compliance with:
• NESHAPs (40 CFR Part 61) for beryllium and mercury
6. Incinerator performance test burn results for lead, arsenic, cadmium, chromium, and nickel, including:
• Mass of pollutant in the feed sludge (kg/day)
• Mass of pollutant in the exit gas (kg/day)
• Maximum combustion temperature
• Values for operating parameters
Draft-March 1993 3-20
-------
3. PERMIT APPLICATION
TABLE 3.7 ADDITIONAL PERMIT APPLICATION INFORMATION FOR SEWAGE
SLUDGE INCINERATORS (Continued)
Additional Information For Incineration Practices
7.
8.
9.
10.
11.
Additional information that should be requested with results of incinerator performance
including the following, if necessary:
• Location of sampling ports
• Sampling rate, volume, and time
• Verification of absence of cyclonic flow
• Equipment calibration
• Isokinetic calculations
• Proper temperatures maintained
• Leak checks performed with acceptable results
• Filter weight and moisture determination
• Field data sheets >
• Sample storage, preservation, shipping, and holding times . ,
• Sample chain-of-custody
• Sample preparation and analysis methods
• Calculations
• QA/QC program
Percent hexavalent chromium in total chromium concentration in exit gas from stack (at
option if it feels its percent of hexavalent chromium to total chromium is different than
EPA in its risk-specific concentrations)
Date(s) incinerators) was built
Total hydrocarbons concentration in exit gas (monthly average)
Percent oxygen concentration in exit gas
test bum,
the permittee's
assumed by
Draft-March 1993 3-21
-------
3. PEEMT AFPUCATDON
TAEBLE 3.7 ADDITIONAL PERMIT APPLICATION INFORMATION FOE SEWAGE
SLUDGE INCINERATORS
12. Description and specifications of instrumentation for continuous process monitoring (including a
discussion of appropriate calibration, operation, and maintenance program) for the following:
o Information used to determine moisture content in exit gas
° Oxygen content in exit gas
° Total hydrocarbons in exit gas with flams ioaization detector instrument, heated sampling line with
temperature of 150°C and calibration once during each 24-hour operating period using propane
13. Description or diagram showing sample locations for sewage sludge fed to incinerators)
3cS REVIEWING THE APPLICATION .
The better the information received at the time of application, the easier it is to assemble an appropriate
and accurate permit for a particular use or disposal site. Therefore, the most important step of the
permitting process is the review of the application information by the permit writer for completeness and
accuracy. Experience in NPDES permit writing has shown that considerable correspondence is often
required before an application is considered to be "complete" and "accurate" by the permit writer. Some
offices employ checklists for the review of application forms to facilitate this process. As the permit
writer gains experience in writing permits, he/she will be able to better detect omissions and errors in
the application information.
S.S.I REVIEWING FOR COMPLETENESS
At a minimum, the application information should address each of the requirements specified at Sections
122.21(c) and (d). When an information item is not applicable, "NA" should be used to show that the
item has been considered. However, if information is missing for an item, the permit writer must contact
the applicant to obtain a written response. Because an administrative record must be maintained in
processing a permit application and hearings are possible, only minor items should be handled by
telephone, and even these must be documented in writing. The preferred method is to return the
application to the applicant for completion, or to request a new application after the applicant has been
advised of the problem items. If changes or corrections to any application are extensive, the applicant
may be required to submit a new application. An application is considered complete when the permitting
authority is satisfied that all required materials have been submitted.
3.5.2 REVIEWING FOR ACCURACY
The permit writer should also review the application to ensure, to the best of his/her ability, that it is
accurate. While it can be difficult to detect many inaccuracies from the application alone, a number of
common mistakes can be readily detected. The permit writer should follow the same procedures for
correcting inaccurate information as are used for obtaining missing information. The following are
examples of accuracy reviews the permit writer may conduct for pollutant characterization data.
DrafU—March 19$3 3-22
-------
3. PERMIT APPLICATION
• Do the concentration and mass values correspond?
• Do the reported values correctly correspond to any existing permit, previous application, and
monitoring data?
• Do concentration values correspond with analytical detection levels? Were the correct analytical
methods used?
The permit writer should examine a number of data elements to verify that the data submitted are accurate
and representative of the quality of the sewage sludge. These include evaluations to ensure that:
• Samples of sewage sludge were collected so as to ensure a representative sample
• Samples were collected and transported using appropriate procedures
• All regulated parameters were analyzed
• EPA-approved analytical methods were used
• Appropriate detection levels were documented
• Results were reported on a dry weight basis
• Chain of custody was documented from sample collection through analysis
• Appropriate QA/QC procedures were followed.
3.6 COLLECTING ADDITIONAL INFORMATION
The permit writer may use additional sources of information to develop the draft permit. For example,
a review of any records existing on the facility can provide information that may be used by the permit
writer. Performing a site visit and reviewing supplemental information sources can also provide
additional information and insight into operations at a facility.
3.6.1 EXISTING FACILITY INFORMATION
Background'information on the facility may be available in the existing NPDES permit file or in other
permit program office files, such as Resource Conservation and Recovery Act (RCRA) and Clean Air
Act files. Information that may be available includes any current permits at the Federal, State, and local
levels; the fact sheets for the current permits; any existing pollutant monitoring or discharge monitoring
reports (DMRs); compliance inspection reports; correspondence concerning compliance problems;
information on changes in plant conditions; and communications with other agencies. Some of this
information may be stored in various automated data tracking systems, such as the NPDES Permit
Compliance System. The permit writer should use this information where available. The information
found may be used to verify information provided in the application, to gain a more detailed
understanding of the facility's operations, or to determine the compliance status of the facility for other
programs, which may indicate whether enforceable special conditions in the sewage sludge permit are
appropriate.
Draft-March 1993 3-23
-------
3. PERMIT APPLICATION
3.6.2 SITE VISITS
For a permit writer to gain a thorough understanding of complex facilities, a visit to the facility to inspect
the site personally can be invaluable. A site visit is important in cases where significant pollution control
or treatment improvements are required or where frequent compliance problems have occurred. The site
visit should include a review of sludge treatment facilities, including performance of the sewage sludge
treatment units, and operation and maintenance practices. A site visit supports an evaluation of the
adequacy of existing treatment practices and performance data and an assessment of the feasibility of
improvements. Monitoring points, sampling methods, and analytical techniques should be evaluated to
determine changes to monitoring requirements and to evaluate the quality of the data. In addition, raw
material and product storage and loading areas, sludge storage and disposal areas, land application sites,
storm water management controls, and all process areas should be observed to determine the need for
controls and for specific best management practices.
3.6.3 AERIAL PHOTOGRAPHS
Aerial photographs are an excellent aid for conducting a plant site visit and may provide much of the
needed information on the potential for contamination of surface runoff. Aerial photographs of a facility
are useful in determining a facility's effects on the surrounding environment. For example, changes in
vegetation in areas that should be uniform may indicate a pollution problem and a change in the
coloration of bodies of water may indicate the facility's effects on the surface waters. Aerial photographs
may be obtained from a variety of sources as identified in Table 3-8.
3.6.4 OTHER SOURCES OF INFORMATION
A great deal of information may be required to be submitted by the permit applicant. In an effort to
ensure the completeness and accuracy of the data received, the permit writer may use a variety of other
sources. Table 3-8 lists government agencies and organizations that may be contacted to obtain
information including topographic maps, flood rate and boundary maps, storm water management facility
design requirements, and air quality models which may support permit development efforts and can be
used to verify or supplement the permit applicant's responses.
As mentioned above, additional sources of information that may be useful to the permit writer include
other environmental permits, such as air or solid waste permits, and other sewage sludge management
.permits written for similar facilities. Supplemental data may be requested, as needed, from various State
agencies or from the applicant. References used in developing this guidance document, as listed at the
end of each chapter, are also good sources of information.
Finally, the permit writer may use secondary sources of information to obtain background data on sewage
sludge practices and their potential effects on public health and the environment. Use of these other
sources may supplement information received from the applicant. The following is a list of infonnation
sources on sewage sludge.
Draft-March 1993 3-24
-------
3. PERMIT APPLICATION
TABLE 3-8 LIST OF GOVERNMENT AGENCIES AND ORGANIZATIONS THAT MAY BE
CONTACTED FOR CERTAIN ADDITIONAL INFORMATION
Type of Information
1 . Topographical maps of the area being reviewed
2.
3.
4.
5.
6.
7.
8.
9.
10.
11
Information on types of habitat, endangered species of
plant, fish, and wildlife in the area being reviewed
Flood insurance rate maps (FIRMS) and flood boundary
and floodway maps in the area being reviewed
Information on 100-year flood and information to
determine the potential of flooding in the area being
reviewed
Information on the numerical models to aid in the
prediction of flood hydrographs, flow parameters, the
effect of obstructions on. flow levels, the simulation of
flood control structures, and sediment transport'
• Site-specific storm water management facility design
requirements in the area being reviewed
• Storm water permits.
Location of wetlands in the area being reviewed
Seismic impact zones, fault zones, and seismic hazards in
the area being reviewed
Copies of the computer software package, Geotechnical
Analysis for Review of Dikes Stability, which details the
basic technical concepts and operational procedures for
the analysis of site hydraulic conditions, dike slope,
foundation stability, dike settlement, and liquefaction
potential of dike and foundation soils
EPA's approved air quality models
Aerial photographs of a facility site to aid in identifying
the potential for surface runoff
Source
U.S. Geological Survey (USGS).
Regional U.S. Fish and Wildlife Service (FWS).
Federal Emergency Management Agency (FEMA)
Distribution Center, the Army Corps of Engineers, USGS,
the U.S. Soil Conservation Service, the Bureau of Land
Management, the Tennessee Valley Authority, or State and
local agencies.
U.S. Water Resources Council, Army Corps of Engineers.
Local Army Corps of Engineers District Office.
• Local planning agencies, civil works departments, or local
zoning boards (name and address of such local agencies
can be found in the local directories)
• NPDES permitting authority.
Local Army Corps of Engineers District Office and local
planning and zoning commissions or agencies.
USGS, the Building Seismic Safety Council, the Colorado
School of Mines, State Geological Surveys, Earthquake
Information Center, the National Information Service for
Earthquake Engineering, the National Institute of Science and
Technology, the American Institute of Architects.
EPA's Risk Reduction Engineering Laboratory.
EPA's Office of Air Quality and Standards in Research
Triangle Park, NC.
Environmental Services Division (in some EPA Regions), the
National Enforcement Investigation Center, EPA's
Environmental Monitoring and Support Laboratory in Las
Vegas, NV, the Environmental Photo Interpretation
Laboratory in Vint Hill, VA, and private contractors.
• EPA's National Sewage Sludge Survey — More than 400 POTWs were surveyed for information
on sewage sludge use or disposal practices and 200 were sampled for actual sludge quality data.
Copies of the analytical database and questionnaire database of this survey are available through
the National Technical Information Service (NTIS) in Springfield, Virginia. Information on
ordering these and other technical support documents is in Part XIV of the preamble to Part 503
(58 FR 9377).
Draft-March 1993
3-25
-------
3. PERMIT APPLICATION
• State solid waste management plans, individual facility solid waste/sludge management plans, and
State application forms — This information can be obtained through the State NPDES permit
office, solid waste program office, or health department.
• EPA Construction Grant Program information — This includes the NEEDS data base that
describes all treatment processes used at POTWs and other basic information about the facility's
design and operation. The NEEDS data base is administered by the Municipal Support Division
of the Office of Wastewater Enforcement and Compliance at EPA Headquarters.
• Pretreatment program information — This includes information on types and amount of
industrial loadings to the POTW and past or present sludge quality problems and can be found
in the POTW's pretreatment program application, annual reports, and environmental audit
reports. This information can be found in the State or EPA Regional NPDES permitting office.
• Basin plans and water quality management plans — These sources may be useful in identifying
sensitive areas such as wetlands or drinking water aquifers.
• Local and State health extension agencies and university agricultural research departments —
These sources may be useful for consultation on specific characteristics or problems having to
do with sludge management and potential impacts.
Draft-March 1993 3-26
-------
4. LAND APPLICATION - PART 503 SUBPART B
QUICK REFERENCE INDEX
Section Page
OVERVIEW 4.1 4-1
IDENTIFYING LAND APPLICATION 4-1
DETERMINING PROVISIONS TO APPLY TO SPECIFIC
LAND APPLICATION PRACTICES 4-2
SUBPART B REQUIREMENTS TO APPLY TO THE GENERATOR,
PREPARER, AND APPLIER 4-3
SPECIAL DEFINITIONS 4.2 4-3
GENERAL REQUIREMENTS 4.3 4-12
REQUIREMENT FOR PERSONS APPLYING SEWAGE SLUDGE TO LAND TO OBTAIN
INFORMATION AND TO COMPLY WITH SUBPART B 4-12
RESTRICTIONS IN APPLYING SEWAGE SLUDGE TO LAND THAT HAS REACHED
CUMULATIVE OR ANNUAL POLLUTANT LOADING RATES 4-14
NOTICE TO PREPARER, APPLIER, OR OWNER 4-17
POLLUTANT LIMITS 4.4 4-21
POLLUTANT CONCENTRATION LIMITS 4-24
ANNUAL POLLUTANT LOADING RATES 4-26
CUMULATIVE POLLUTANT LOADING RATES 4-30
OPERATIONAL STANDARDS-PATHOGENS AND VECTOR ATTRACTION REDUCTION 4.5 4-32
MANAGEMENT PRACTICES 4.6 4-40
ENDANGERED SPECIES OR CRITICAL HABITAT PROTECTION 4-40
APPLICATION OF SEWAGE SLUDGE TO FLOODED LAND 4-43
APPLICATION OF SEWAGE SLUDGE TO FROZEN OR SNOW-COVERED LAND 4-46
DISTANCE TO SURF ACE WATERS 4-50
AGRONOMIC APPLICATION RATE 4-53
LABEL OR INFORMATION SHEET REQUIREMENTS 4-69
MONITORING REQUIREMENTS 4.7 4-71
RECORD KEEPING REQUIREMENTS 4.8 4-83
REPORTING REQUIREMENTS 4.9 4-93
4.1 OVERVIEW
This chapter provides guidance to the permit writer on implementation of the requirements for Part 503,
Subpart B, which applies to the land application of sewage sludge, including material derived from
sewage sludge. The permit writer must initially verify that the material in question is indeed sewage
sludge or material derived from sewage sludge. Chapter 2 defines sewage sludge and provides a detailed
description of materials that are not regulated under Part 503.
4.1.1 IDENTIFYING LAND APPLICATION
The first step is to determine whether the practice qualifies as land application. For purposes of Part 503,
"land application" is the spreading, spraying, or injection of sewage sludge onto or just beneath the
surface of the land with the distinct objective of using the beneficial properties of the sewage sludge to
enhance the structure of the soil or to supply nutrients to the vegetation. The beneficial use objective is
the main distinction between land application and surface disposal. A key indicator of this distinction is
Draft—March 1993 4-1
-------
4. LANP APIPLICATHON - PART SUB SUBIPAOT 1
the rate at which sewage sludge is applied to the land area. If the sewage sludge is being applied at or
below the agronomic rate (the rate at which vegetation uses the nitrogen in the sewage sludge), then the
intent of the activity clearly is to use the nutrients available in the sewage sludge; thus, the activity is
considered land application and is regulated under Subpart B. This determination is relatively
straightforward where sewage sludge is applied to agricultural fields and pasture land, forests, and public
contact sites, such as parks and golf courses. In these situations, the sewage sludge is applied at a
relatively low rate determined by the nitrogen requirements of the vegetation.
Sewage sludge may also be applied to disturbed land in an effort to reclaim and revegetate the land. A
reclamation site is an area that has been disturbed by activities such as strip mining, clear-cutting, severe
erosion, or construction. The land is so disturbed that it no longer supports vegetation. Sewage sludge
is applied to provide a substrate in which vegetation may take root and flourish and to restore organic
material and nutrients to the otherwise impoverished land. When sewage sludge is applied at a
reclamation site, the applier may be authorized to apply the sewage sludge at a rate greater than the
agronomic rate. This is allowed because, in addition to providing nutrients for vegetation, the sewage
sludge is being applied to provide a soil substrate where there is none. Determining the difference
between a reclamation site and a surface disposal site can be difficult because the disturbed area may
share some of the characteristics of a surface disposal site (e.g., an excavated fill area). To distinguish
land application of sewage sludge to reclaim disturbed land from surface disposal, the permit writer
should look for a demonstration that: (1) the land was previously disturbed; and (2) the sewage sludge
is applied to use its beneficial properties.
For most situations, the permit writer will be able to easily distinguish between land application and
surface disposal. However, there may be a few cases where the distinction becomes difficult to
determine. If the applicant indicates or the permit writer determines that the primary use of the land is
for agricultural or other activities and not for the disposal of the sewage sludge, then the practice should
be designated as land application.
4.1.2 DETERMINING PROVISIONS TO APPLY TO SPECIFIC LAND APPLICATION
PRACTICES
Once the permit writer has determined that the applicant is subject to Subpart B, he/she must determine
the specific Subpart B requirements to be applied to the applicant. Subpart B was developed to address
a range of land application circumstances. The
specific requirements to apply will depend on the ' • • '
quality of the sewage sludge, the amount of Exceptional Quality Criteria
control the generator has over the final use of the
sewage sludge, and the intended final use (e.g., Sewage sludge or material derived from sewage
use on lawns and gardens by general public or sludge that acnieves the pollutant
application to agricultural land). Figure 4-1 concentrations established, in 40 CFR
provides a decision tree that identifies the 503.13(b)(3), one of the Class A pathogen
applicability of each provision of Subpart B. reduction alternatives listed in §503.32(a), and
one of the vector attraction reduction
As Figure 4-1 indicates, if the generator/preparer alternatives listed in §503.33(b)(l) through (8)
is able to demonstrate that a sewage sludge or a js referred to ^ exceptional quality sewage
material derived from sewage sludge meets the sludge.
criteria for "exceptional quality" sewage sludges
(see definition at right), the general requirements i1 ' ' ' ' >
Draft—March 1993 4-2
-------
4. LAND APPLICATION - PART 503 SUBPART B
and management practices need not be applied. In addition, whenever an exceptional quality sewage
sludge is used to produce another material derived from the exceptional quality sewage sludge, the
resulting material is automatically considered exceptional quality. The preparer of this resulting material
does not have to independently demonstrate that it meets the exceptional quality criteria as long as all of
the sewage sludge from which the material was derived met the exceptional quality criteria. Exceptional
quality sewage sludge is not subject to the Subpart B general requirements and management practices
unless the permit writer decides that these requirements are necessary. When the sewage sludge does not
meet the exceptional quality criteria, the sewage sludge is subject to the general requirements and
management practices.
4.1.3 SUBPART B REQUIREMENTS TO APPLY TO THE GENERATOR, PREPARER, AND
APPLIER
The treatment works generating the sewage sludge may not always be the entity ultimately responsible
for the land application of the sewage sludge. The sewage sludge may be transferred to another entity
that changes the quality or land applies the sewage sludge. When the generator provides the sewage
sludge to another preparer, the permit writer must decide whether the generator or preparer should be
responsible for the different requirements. This decision should be based on a thorough understanding
of the type of sewage sludge treatment that occurs at each facility. The permit writer may choose to put
some requirements such as pollutant limits in both permits. Another option is to issue one permit to both
entities as co-permittees.
Appliers who do not change sludge quality will usually not be required to obtain a permit. When the
applier is not the preparer, the permit writer may want to put the applier's requirements in the preparer's
permit, in order to ensure compliance by the applier. Table 4-1 lists the specific Subpart B requirements
that apply to a generator, another preparer, and an applier.
4.2 SPECIAL DEFINITIONS
Section 503.9 contains general definitions applicable to Part 503. In addition, §503.11 provides several
definitions specifically applicable to land application. This section briefly explains some of the terms in
§503.11 and lists the remainder for reference purposes. When these terms are used in permits, the permit
writer should include the regulatory definitions where appropriate to clarify permit conditions.
Draft—March 1993 4-3
-------
4. LAND APPLICATION - PART 503 SUBPART B
Does the sewage sludge or material derived from sewage sludge meet:
1) Ceiling Concentrations (Table 1):
2) Pollutant Concentrations (Table 3):
3) Annual Pollutant Loading Rates (Table 4):
4) Cumulative Pollutant Loading Rates (Table 2):
5) Class A Pathogen Reduction Requirements:
6) Class B Pathogen Reduction Requirements:
7) Vector Attraction Reduction Requirements (1-8):
8) Vector Attraction Reduction Requirements (9-10)
Eligible Land
Application Practice:
Pollutant Limits to Apply:
Pathogen Reduction
Requirements to Apply:
Vector Attraction Reduction
Requirements to Apply:
General Requirements to Apply:
Management Practices to Apply:
Monitoring Requirements to Apply:
Recordkeeping to Apply:
Reporting Requirements to Apply:
YES
YES
N/A
N/A
YES
N/A
YES
N/A
Sewage sludge is
"exceptional quality ."May
be applied: To any land in
bulk or bag form
i
Pollutant Concentration
Limits §503.13(aX2Xii).
(aX3),(a)(4)(i)Table3
1
Class A
{503.32(a)
I
{503.33(bXl-8)
1 (any one
Y method)
DO NOT APPLY
1 ,
T
DO NOT APPLY
{503. 16 (a)
1
{503.17(a)(l),(2)
1
{503.18
YES
YES
N/A
N/A
YES
N/A
NO
YES
May be applied: Bulk
to agricultural land, forest,
public contact sites,
reclamation sites
I
Pollutant Concentration
Limits {503.13(aX2)(ii).
Table 3
I
Class A
{503.32(a)
I
{503.33(b)(9)or(10)
1
{503.12(a),(d),(0.(g).
(h) (i)
i
{503.14(a),(b),(c).(d)
{503J6(a)
*
{503.17(a)(3)
1
{503.18
YES
YES
N/A
N/A
NO
YES
YES
N/A/YES
May be applied: Bulk
to agricultural land, forest.
public contact sites.
reclamation sites
1
Pollutant Concentration
Limits {503.1 3(aX2)(ii).
Table 3
1
Class B
{503.32(b)
I
J503.33(bXl-10)
J. (anyone
f method)
{503.12(a),(d),(f).(g),(h),
(0
1
{503.14(a),(b),(c),(d)
{503.16 (a)
1
{503.17(aX4)
1
{503.18
FIGURE 4-1 PROCEDURES FOR DETERMINING APPLICABILITY OF
PART 503 PROVISIONS
Draft-March 1993
4-4
-------
4. LAND APPLICATION - PART 503 SUBPART B
1) Ceiling Concentrations:
2) Pollutant Concentrations:
3) APLRs:
4) CPLRs:
5) Class A:
6) Class B:
7) Vector (1-8):
8) Vector (9- 10):
Eligible Land
Application Practice:
Pollutant Limits to Apply:
Pathogen Reduction
Requirements to Apply:
Vector Attraction Reduction
Requirements to Apply:
General Requirements to Apply:
Management Practices to Apply:
Monitoring Requirements to Apply:
Recordkecping to Apply:
Reporting Requirement! to Apply:
YES
NO
YES
N/A
YES
N/A
YES
N/A
1
Miy be applied:
Bagged/con taincred
for sale or giveaway
Jy
T
Ceiling Concentration
{503.13(a)(l), Table 1
1
1
Annual Pollutant
Loading Rates
{503.13(a)(4)(ii).
Table 4
I
Class A }503.32(a)
I,
1-
{503.33(b)(l-8)
1 (anyone
^method)
J503.12(a),(g)
I
t
{503. 14 (e)
1
{503.16 (a)
*
{503.17(a)(6)
1
{503.18
YES
NO
N/A
YES
YES/N/A
N/A/YES
YES
N/A/YES
*
May be applied: Bulk
to agricultural land,
forest, public contact
sites, reclamation site:
1
Ceiling
Concentrations
{503. 13(a)(l), Table 1
1
Cumulative Pollutant
Loading Rales
{503.13(a)(2)(i),
Table 2
ClassA{503.32(a)or
Class B {503.32(b)
1
{503.33(b)(l-10)
1 (anyone
W method)
{503.12(a),(b),(d).
(«). (0.
-------
4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-1 SUBPART B REQUIREMENTS APPLICABLE TO GENERATORS,
PREPARERS, OR APPLIERS
Generator or Preparer
General requirements
503.12(d)
503.12(f)
503.12(g)
503.12(i)
Pollutant limits
503.13
Management practice
503.14(e)
Operational standards
503.15(a) pathogens
503 . 3 3 (b)( 1 -8) vector attraction reduction
Monitoring
503.16(a)
Record Keeping
503.17(a)(l) exceptional quality sewage sludge
503.17(a)(2) exceptional quality sewage sludge
derived material
503. 17(a)(3)(i) sewage sludge subject to pollutant
concentration limits, Class A, and
vector attraction reduction in
503.33(b)(9) or 503.33(b)(10)
503.17(a)(4)(i) sewage sludge subject to pollutant
concentration limits and Class B
503. 17(a)(5)(i) sewage sludge subject to
cumulative pollutant loading rates
503. 17(a)(6) sewage sludge subject to annual
pollutant loading rates
Reporting
503.18
Applier
General requirements
503.12(a)
503.12(b)
503.12(e)
503.12(h)
503.12(j)
Pollutant limits
503.13
Management practices
503.14(a)
503.14(b)
503.14(c)
503.14(d)
Operational standards
503.32(b)(5) site restrictions for Class B sewage
sludge
503 . 33(b)(9) . vector attraction reduction
503.33(b)(10) vector attraction reduction
Record Keeping
503.17(a)(3)(ii) sewage sludge subject to pollutant
concentration limits, Class A, and
vector attraction reduction in
503.33(b)(9) or 503.33(b)(10)
503.17(a)(4)(ii) sewage sludge subject to pollutant
concentration limits and Class B
503.17(a)(5)(ii) sewage sludge subject to
cumulative loading rates
Reporting
503.18
Draft—March 1993
4-6
-------
4. LAND APPLICATION - PART 503 SUBPART B
Agronomic Rate
Statement of Regulations
§503.H(b) Agronomic rate is the whole sewage sludge application rate (dry weight basis) designed: (1) to
provide the amount of nitrogen needed by the food crop, feed crop, fiber crop, cover crop, or
vegetation grown on the land and (2) to minimize the amount of nitrogen in the sewage sludge
that passes below the root zone of the crop or vegetation grown on the bind to the ground water;:
The agronomic rate is the maximum quantity of sewage sludge (on a dry weight basis) that may be
applied to a parcel of land. It represents the ratio of sludge nitrogen needed for a particular crop or
vegetation type to the amount of available nitrogen in the sludge. The agronomic rate is designed to
provide, but not exceed, the annual nitrogen requirements of the crop or vegetation, while minimizing
the amount of nitrogen that leaches through the root zone of the crops or vegetation and into the
groundwater.
The agronomic rate is calculated from many pieces of information, including data on sludge composition
(especially nutrient analyses), soil test results, realistic yield and fertilizer requirements for the crop or
vegetation, and an estimate of available nitrogen from all possible sources (e.g., available nitrogen
remaining in the soil from previous sludge applications, residual nitrogen from previous crops or
vegetation, nitrogen from irrigation water, and nitrogen from supplemental fertilizers). Section 4.6.5 of
this manual provides a detailed discussion and guidance on calculating the agronomic rate. Bulk sewage
sludge may not be applied to land at greater than the agronomic rate, except at reclamation sites when
allowed by the permitting authority.
Annual Pollutant Loading Rate
Statement of Regulations
§503.11(c) Annual pollutant loading rate is U>e maximum amount of a pollutant that can be applied to a
unit area of land during a 365 day period.
The annual pollutant loading rates (APLRs) for ten inorganic pollutants are listed in Table 4 of §503.13.
They apply only to sewage sludge that is sold or given away in a bag or other container. The APLR does
not control the concentration of the pollutant in the sewage sludge. Instead, it limits the amount of a
pollutant that can be applied to a hectare each year. For example, according to Table 4 of §503.13, no
more than 21 kilograms of nickel may be applied to a single hectare of land over a 365 day period. The
21 kilograms may be applied all at once in one application or in several applications throughout the 365
day period. Once the 21 kilograms have been applied, no further sewage sludge may be applied to the
hectare during the remainder of the 365 day period. Therefore, if the 21 kilograms have been applied
by the 280th day, the next application of sewage sludge cannot occur until the first day of the next 365
day period.
Draft—March 1993 4-7
-------
4. LAND APPLICATION - PART 503 SUBPART B
Annual Whole Sludge Application Rate
Statement of Regulations
§503.11(d) Annual whole sludge application rate is the maximum amount of sewage sludge (dry weight
basis) that un be applied to a unit area of land during a 365 day period.
The annual whole sludge application rate (AWSAR) is used to express the quantity of sewage sludge that
can be applied to the land without causing the annual pollutant loading rate for any regulated pollutant
to be exceeded. For example, the annual pollutant loading rate for selenium [according to §503.13(b)(4)]
is 5 kilograms per hectare per 365 day period. Thus, if the sewage sludge has a selenium concentration
of 100 milligrams per kilogram, the AWSAR with respect to selenium is 50 metric tons.
Bulk Sewage Sludge
Statement of Regulations
§503.11(e) Bulk sewage sludge is sewage sludge that is not sold or given away in a bag or other container
for application to the land.
Bulk sewage sludge refers to sewage sludge that is transported and applied to the land in large quantities
(over 1 metric ton). Any sewage sludge that is piped to the application site is considered bulk sewage
_t j
sludge.
Cumulative Pollutant Loading Rate
Statement of Regulations
§503.11(0 Cumulative pollutant loading rate is the maximum amount of an inorganic pollutant that can
be applied to an area ofland.
The cumulative pollutant loading rates (CPLRs) for ten inorganic pollutants are listed in Table 2 of
§503.13. They apply only to bulk sewage sludge. This type of pollutant limit regulates the loading rate
of the pollutant, rather than the maximum concentration of the pollutant in the sludge. That is, the CPLR
is the total mass of the pollutant (on a dry weight basis) that may be applied to a unit area of land during
the entire life of the application site. For example, sludge may continue to be applied to a hectare until
the CPLR of 2,800 kilograms of zinc has been reached. Once the CPLR is reached, no further sewage
sludge subject to the CPLR may be applied to that hectare.
As illustrated in the chart below, the actual zinc loading to a hectare of land can be calculated by
multiplying the zinc concentration (mg/kg) in the sewage sludge by the application rate (kg/he). The
cumulative pollutant loading at the end of each year is calculated by adding the actual pollutant loading
for that year and the previous cumulative pollutant loading. Thus, by the end of 1998, the actual
cumulative loading for zinc is 713.5 kg/he or 25.5 percent of the CPLR (713.5 divided by 2,800).
Draft-March 1993 4-8
-------
4. LAND APPLICATION - PART 503 SUBPART B
TRACKING CUMULATIVE POLLUTANT LOADING FOR ZINC (EXAMPLE)
Year
1993
1994
1995
1996
1997
1998
Actual Pollutant
Concentration
(mg/kg)
7,500
5,000
6,500
7,200
7,500
8,000
Application Rate
(kg/hectare)
15
18
16
20
18
16
Actual Pollutant
Loading
(kg/hectare)
112.5
90.
104
144
135
128
Cumulative
Pollutant Loading
at End of Year
(kg/hectare)
112.5
202.5
306.5
450.5
585.5
713.5
Land Application
Statement of Regulations
§503.11(h) Land application is the spraying or spreading of sewage sludge onto the land surface; the
injection of sewage sludge below the land surface; or the incorporation of sewage sludge into the
soil so that the sewage sludge can either condition1 the soil or fertilize crops or vegetation grown
in the soil.
Land application refers to the application of sewage sludge to an area of land to take advantage of its
fertilizing value and soil conditioning properties. The application of sewage sludge for any purpose other
than the beneficial uses stated above is not considered land application. Various methods can be used
to apply sewage sludge to an area of the land. The following land application techniques are included
in the definition of land application:
Spraying or spreading onto the soil
surface—the sewage sludge is applied
on top of the soil with little to no soil
surface disturbance or mixing of
sewage sludge and soil.
Draft-March 1993
4-9
-------
4. LAND APPLICATION - PART 503 SUBPART B
Injecting below the soil surface—special equipment is
used to penetrate the soil and pump liquid sludge into the
soil.
• Incorporating into the soil—the soil surface
is turned over or disturbed by plowing or
discing so that sewage sludge is mixed
with the soil.
Other Container
Statement pf Regulations
§503.110) Other container is either an open or closed receptacle. This includes, but is not limited: to, a
bucket, a box, a carton, and a vehicle or trailer with a toad capacity of one metric ton or less.
The definition of other container distinguishes the distribution of sewage sludge in small quantities from
the transport of bulk sewage sludge to a land application site. For example, using trucks with load
capacities of 2 tons is considered transporting bulk sewage sludge. A pickup truck with a load capacity
of less than 1 metric ton is considered an other container.
Public Contact Site
Statement of Regulations
§503.11(1) Public contact site is land with a high potential for contact by the public. This includes, but is
not limited to, public parks, ball fields, cemeteries, plant nurseries, turf farms, and golf courses.
In most cases, a public contact site is easily identified; however, the permit writer should always evaluate
the site's use carefully. Examples of a public contact site, other than those listed in the definition, include
picnic areas and State or national historical sites.
Draft—March 1993
4-10
-------
4. LAND APPLICATION - PART 503 SUBPART B
The remaining definitions from §503.11 and selected definitions from §503.9 are shown below for
reference purposes.
Statement of Regulations
§503.11(a) Agricultural land is land on which a food crop, a feed crop, or a fiber crop is grown. This
includes range land and land used as pasture. >
§503.9(a> Apply sewaee sludge or sewage sludge applied to land means land application of sewage sludge.
§503.9(b) Base flood is a flood that has a one percent chance of occurring in any given year (i.e., a flood
with a magnitude equalled once in 100 years). .
§503.9(d) Cover crop is a small grain crop, such as oats, wheat, or barley, not grown for harvest.
§503.9(f) Domestic septaee is either liquid or solid material removed from a septic tank, cesspool, portable
toilet, Type III marine sanitation device, or similar treatment works that receives only domestic
sewage. Domestic septage does not include liquid or solid material removed from a septic tank,
cesspool, or similar treatment works that receives either commercial wastewater or industrial
wastewater and does not include grease removed from a grease trap at a restaurant.
§S03.9(g) Domestic sewage is waste and wastewater from humans or household operations that is
discharged to or otherwise enters a treatment works.
§S03.9(h) Dry weight basis means calculated on the basis of having been dried at 105 degrees Celsius until
reaching a constant mass (i.e., essentially 100 percent solids content).
§503.9(j) Feed crops are crops produces primarily for consumption by animals.
§503.9(k) Fiber crops are crops such as flax and cotton. .
§503.90) Food crops are crops consumed bv humans. This includes, but is not limited to, fruits,
vegetables, and tobacco.
§503.11(g) Forest is a track of land thick with trees and underbrush.
§503.9(m) Ground water is water below the land surface in the saturated zone.
I503.11Q) Monthly average is the arithmetic mean of all measurements taken during the month.
§503.Il(k) Pasture is land on which animals feed directly on feed crops such as legumes, grasses, grain
stubble, or stover.
§503.9(r) Person who prepares sewage sludge is either the person who generates sewage sludge during the
treatment of domestic sewage in a treatment works or the person who derives a material from
sewage sludge.
Draft-March 1993 4-11
-------
4. LAND APPLICATION - PART 503 SUBPART B
Statement of Regulations (Continued)
§503.11(m) Ranee land is open land with indigenous vegetation. V
§503.11(0) Reclamation site is drastically disturbed land that is reclaimed using sewage sludge. This
includes, but is not limited to, strip mines and construction sites. ; :
8503.9
-------
4. LAND APPLICATION - PART 503 SUBPART B
Technical Guidance
In general, the permit writer does not need to issue permits to persons involved in applying sewage sludge
if these persons are not generating or preparing the sludge. However, the permitting authority may
designate the applier as a treatment works treating domestic sewage (TWTDS) if he/she feels a permit
is necessary to ensure compliance with Part 503. He/she may want to require the applier to obtain
information on the quality of the sewage sludge received. The applier can then determine if such sewage
sludge can be applied and what requirements must be met to apply the sewage sludge to the land. For
example, the permit writer could require the applier to obtain (from the preparer) all sampling data on
pollutant concentrations in the sewage sludge and all data on pathogen and vector attraction reduction
requirements. Alternatively, the permit writer could require the applier to sample the sewage sludge
received from the preparer to obtain the sewage sludge quality data.
Each person involved in applying (or using) sewage sludge must obtain information on the pollutant
standards and requirements that apply to the sewage sludge. If, through labeling or information sheets,
the person is informed that the sewage sludge meets the exceptional quality criteria, no additional
information other than what is conveyed through the label is necessary. However, if the person knows
or is informed that the sewage sludge is not exceptional quality sewage sludge, the person needs to obtain
information on the other requirements that apply. The following example contains conditions for appliers
that may be included in a permit.
Permit Conditions
A person only applying sewage sludge to land will not
normally be permitted.
1.
The permittee shall receive from the preparer on a yearly basis a summary of
pollutant concentrations and pathogen and vector attraction reduction data. The
permittee shall maintain these data for [insert time period].
:
This condition is appropriate if the permittee is not the
preparer.
Draft-March 1993
4-13
-------
4. LAND APPLICATION - PART 503 SUBPART B
' 1
—
2. The permittee shall sample and analyze all sewage sludge applied to
each preparer for pollutant concentrations.
: f
This condition is appropriate if the permittee does not
receive analytical data from the preparer.
the site from
4.3.2 RESTRICTIONS IN APPLYING SEWAGE SLUDGE TO LAND THAT HAS REACHED
CUMULATIVE POLLUTANT LOADING RATES
Statement of Regulations
§503.12(b) No person shall apply sewage sludge subject to the cumulative pollutant loading rates in
§503.13(b)(2) to agricultural land, forest, a publk contact site, or a reclamation site if any of
the cumulative pollutant loading rates in §503.13(b)(2) has been reached.
§503.12(e)(2) (i) Before bulk sewage sludge subject to the cumulative pollutant loading rates in §S03.13(b)(2)
is applied to the land, the person who proposes to apply the bulk sewage sludge shall
contact the permitting authority for the State in which the bulk sewage sludge will be
applied to determine whether bulk sewage sludgesubject to the cumulative pollutant loading
rates in §S03.13(b)(2) has been applied to the site since July 20, 1993.
(ii) If bulk sewage sludge subject to the cumulative pollutant loading rates in §503.13(b)(2) has:
not been applied to the site since July 20,1993, the cumulative amount for each pollutant
listed b Table 2 may be applied to the site in accordance with §503.13(a)(2)(i).
(iii) If bulk sewage sludge subject to the cumulative pollutant: loading rates in §503.13(b)(2) has
: been applied to the site since July 20,1993, and the cumulative amount of each pollutant
applied to the site in the bulk sewage sludge since that date is known, the cumulative'
amount of each pollutant applied to the site shall be used to determine the additional:
amount of each pollutant that can be applied to the site in accordance with §503.13(a)(2)(i).
(iv) If bulk sewage sludge subject to the cumulative pollutant loading rates in §503.13(b)(2) has
been applied to the site since July 20, 1993 and the cumulative amount of each pollutant
applied to the site in the bulk sewage sludge since that date is not known, an additional
amount of each pollutant shall not be applied to the site in accordance with §503.13(a)(2)(i).
Purpose: To prevent a site that has reached its cumulative pollutant loadings from receiving any more sewage
sludge subject to cumulative pollutant loading rates.
Applies to: Appliers of bulk sewage sludge subject to cumulative pollutant loading rates.
Draft—March 1993
4-14
-------
4. LAND APPLICATION - PART 503 SUBPART B
Technical Guidance
The cumulative pollutant loading rates do not regulate the amount of pollutants in the sewage sludge.
Rather, they regulate the amount of pollutants that can be applied to a unit area of land. Thus, the
volume of sewage sludge and the pollutant concentration in the sewage sludge together determine the
pollutant loading. Each successive loading is added to determine the cumulative pollutant loading. When
a site has reached its cumulative pollutant loading rate, no further application of sewage sludge subject
to the cumulative pollutant loading rates can be allowed.
The tracking of successive loadings starts July 20, 1993. Any pollutant loadings prior to that date do not
have to be considered in determining the cumulative loading. Each pollutant loading after that date must
be considered. The applier must track the quantity and quality of the bulk sewage sludge applied to each
site to determine the cumulative loading and must notify the permitting authority of the sites it uses. The
applier must contact the permitting authority to determine if sewage sludge was applied to any sites that
the applier is proposing to use. The permitting authority does not track the cumulative loading but will
have records on whether CPLR sewage sludge has been applied to the site. If other appliers have used
the same site since July 20, 1993, the applier must contact these other appliers and obtain the necessary
information that will enable him/her to determine the cumulative loading.
The permit writer should perform the following steps when dealing with sewage sludge subject to the
cumulative pollutant loading rates.
Step 1: Determine if the land application site has received previous applications of sewage sludge
subject to the cumulative pollutant loading rates. If not, go to Step 2; if so, go to Step 3.
Step 2: The applier is allowed the entire cumulative pollutant loading rate established in
§503.13(a)(2).
Step 3: Require the applier to determine the cumulative loading that has been applied to the site
since July 20, 1993. If the applier can determine this loading, subtract this loading from the
cumulative pollutant loading rate established in §503.13(a)(2). Apply the remaining pollutant
loading rate as the allowable cumulative pollutant loading rate in the permit. If this previous
cumulative loading is not known, go to Step 4.
Step 4: If the cumulative pollutant loading since July 20, 1993 is not known, do not allow sewage
sludge subject to cumulative pollutant loading rates to be applied.
Provided below are examples of conditions that may be included in a preparer/applier's permit to restrict
the application of sewage to land that has reached its cumulative pollutant loading rate.
Draft-March 1993 4-15
-------
4. LAND APPLICATION - PART 503 SUBPART B
Permit Conditions
>, ,:
SAMPLE FEEMFF CONDITIONS FOE RESTRICTING
AFFLICATION OF SEWAGE SLUDGE TO LANB THAT HAS
CUMULATIVE POLLUTANT LOADING RATES
The permittee shall monitor and record the quantity of sewage sludge applied to the
site.
The permittee shall monitor the site's cumulative pollutant loading rate and shall
maintain records of the data for [insert time period].
The permittee shall not apply sewage sludge to the site in excess of the cumulative
pollutant rates for the following parameters: arsenic 41 kg/hectare; cadmium 39
kg/hectare; chromium 3000 kg/hectare; copper 1500 kg/hectare; lead 300
kg/hectare; mercury 17 kg/hectare; molybdenum 18 kg/hectare; nickel 420
kg/hectare; selenium 100 kg/hectare; and zinc 2800 kg/hectare.
The permit writer may apply more stringent limits
and/or require the monitoring of additional parameters
as necessary to protect the site.
4. The permittee shall provide the permitting authority each year with the name and
address of all persons applying sewage sludge to the site.
5. The permittee shall each year receive and record the total cumulative pollutant
loading from all sewage sludge appliers to the site.
6. The permittee shall not apply sewage sludge to the site if the combined cumulative
pollutant loading from all appliers exceeds the site rate.
Draft—March 1993
4-16
-------
4. LAND APPLICATION - PART 503 SUBPART B
4.3.3 NOTICE TO PREPARER, APPLIER, OR OWNER
Statement of Regulations
§503.12(d) The person who prepares bulk sewage sludge that is applied to agricultural land, forest, a public
contact site, or a reclamation site shall provide the person who applies the bulk sewage sludge
written notification of the concentration of total nitrogen (as N on a dry weight basis) in the bulk
sewage sludge. '
§503.I2(f) When a person who prepares bulk sewage sludge provides the bulk sewage sludge to a person
who applies the bulk sewage sludge to the land, the person who prepares the bulk sewage sludge
shall provide the person who applies the sewage sludge notice and necessary information to
comply with the requirements in this subpart.
§503.12(g) When a person who prepares sewage sludge provides the sewage sludge to another person who
prepares the sewage sludge, the person who provides the sewage sludge shall provide the person
who receives the sewage sludge notice and necessary information to comply with the
requirements in this subpart.
§503.12(h) The person who applies bulk sewage sludge to the land shall provide the owner or lease holder
of the land on which the bulk sewage sludge is applied notice and necessary information to
comply with the requirements in this subpart . •
Purpose:
§503.12(d) - to enable the applier of bulk sewage sludge to calculate the agronomic rate.
§503.12(f) - to ensure that the applier is aware of any specific conditions or regulations governing the application
of bulk sewage sludge that the applier receives from the preparer.
§503.12(g) - to ensure that the second preparer is aware of any specific conditions or regulations governing the bulk
sewage sludge that the preparer receives.
§503.12(h) - to ensure that the land owner or lease holder of a site receiving bulk sewage sludge is aware of any
specific conditions or regulations governing the application of bulk sewage sludge to the land.
Applies to:
§503.12(d) - preparers of bulk sewage sludge applied to agricultural land, forest, a public contact site, or a reclamation
site.
§503.12(0 - preparers of bulk sewage sludge.
§503.12(g) - preparers of sewage sludge who provide it to other preparers.
§503.12(h) - appliers of bulk sewage sludge.
Technical Guidance
The application of sewage sludge to the land may involve several persons. Not all of these persons need
to receive a permit, but all of them must comply with the appropriate Subpart B requirements. The first
person involved in application of sewage sludge to the site is the generator of the sewage sludge. Even
though the generator may contract further sludge treatment to another person or contract the hauling and
application of the sewage sludge to the land to another person, the generator is not relieved from the
responsibility of ensuring that the sewage sludge complies with Part 503. The permit writer needs to
construct a permit condition that requires the generator to inform any persons subsequently involved in
further preparing or applying the sewage sludge of the applicable requirements governing the use of the
Draft-March 1993 4-17
-------
4. LAND APPLICATION - PART 503 SUBPART B
sewage sludge. The permit writer should also develop a permit condition that specifically lists the type
of information that the generator must provide to the other preparer or applier. For example, the
generator should provide the following sewage sludge quality information to the other preparer or applier:
the total nitrogen concentration of the sewage sludge, the pollutant concentrations in the sewage sludge,
and any pathogen and vector attraction reduction information. This information would enable the other
preparer or applier to determine what further treatment may be necessary or to calculate loading rates.
If the permit writer is not issuing a permit to the applier, then the permit writer may want to include a
condition in the generator's permit regarding notification to the land owner or lease holder. A
notification permit condition could be constructed in several ways as illustrated in the examples below.
Permit Conditions
-
NOTICE TO FEEPAEERS, APPLIEEtS, OR OWNEMS
1 . The permittee must develop information sheets or labels and a procedure to transmit
the following information to subsequent handlers and users of the sewage sludge:
a. The total nitrogen concentration of the sewage sludge (dry weight basis)
b. The pollutant concentrations in the sewage sludge (in mg/kg dry weight basis)
and the percent solids
c. A statement indicating whether a specific Class A or Class B pathogen reduction
requirement is met
d. A statement indicating whether a specific vector attraction reduction requirement
is met
e. Any use restrictions on the sewage sludge
f. The Part 503 regulations that apply to the sewage sludge, including pollutant
limits, general requirements, and management practices.
2. The permittee shall provide any other preparer or applier of the sewage sludge it
generates with the following information regarding that sludge: total nitrogen (as N
on a dry weight basis); pollutant concentrations; pathogen levels; and vector
attraction reduction methods employed.
The permit writer may require additional parameters
and conditions.
S ts •. ' % ' ,
Draft-March 1993
4-18
-------
4. LAND APPLICATION - PART 503 SUBPART B
-
3. The permittee shall supply the land owner, land applier, and any subsequent
preparer with the applicable Part 503 requirements.
4. The permittee shall retain records documenting that the required notification has
been implemented.
•,
11
4.3.4 NOTICE TO PERMITTING AUTHORITY
Statement of Regulations
§S03.12(i) Any person who prepares bulk sewage sludge that is applied to land in a State other than the
State in whkh the bulk sewage sludge is prepared shall provide written notice, prior to the initial
applkation of bulk sewage sludge to the land application site by the applier, to the permitting
authority for the State in which the bulk sewage sludge is proposed to be applied. The notke
shall include:
(1) The location, by either street address or latitude and longitude, of each land applkation site.
(2) The approximate time period bulk sewage sludge will be applied to the site.
(3) The name, address, telephone number, and National Pollutant Discharge Elimination System
permit number (if appropriate) for the person who prepares the bulk sewage sludge.
(4) The name, address, telephone number, and National Pollutant Discharge Elimination System
permit number (if appropriate) for the person who will apply the bulk sewage sludge.
§503.12(j) Any person who applies bulk sewage sludge subject to the cumulative pollutant loading rates in
§503.13(b)(2) to the land shall provide written notke, prior to the initial applkation of bulk
sewage sludge to a land application site by the applier, to the permitting authority for the State
in whkh the bulk sewage sludge will be applied and the permitting authority shall retain and
provide access to the notke. The notke shall include:
(1) The location, by either street address or latitude and longitude, of the land application site.
(2) The name, address, telephone number, and National Pollutant Discharge Elimination System
permit number (if appropriate) of the person who will apply the bulk sewage sludge.
Purpose:
§503.12(i) - To enable the permitting authority (EPA Region or authorized State) to impose permitting or other controls;
in certain cases, to enable the State receiving out-of-State sewage sludge to inform the preparer of State requirements
governing the land application of sewage sludge.
§503.120 - to enable the permitting authority to track cumulative pollutant loads on a site-by-site basis.
Applies to:
§503.12(1) - preparers of sewage sludge that send the sludge to another State.
§503.12(j) - appliers of sewage sludge subject to cumulative pollutant loading rates.
Draft—March 1993 4-19
-------
4. LAND APPLICATION - PART 503 SUBPART B
Technical Guidance
A permit to a preparer of bulk sewage sludge that is being applied to land located in another State should
contain a permit condition that requires the preparer to notify the permitting authority of the State
receiving the bulk sewage sludge that bulk sewage sludge is or will be applied to land in that State.
Unless the receiving State has been authorized to administer the sewage sludge program pursuant to
EPA's sewage sludge permit program regulations (40 CFR Parts 123 and 501), the permitting authority
will be the EPA Region. The permit condition should list the information that the preparer must provide
to the permitting authority in the receiving state, for example, the location of the sites and the time period
sewage sludge will be applied as well as the name(s), address(es) and NPDES permit number(s) of the
preparer and applier(s).
The application of bulk CPLR sewage sludge requires the tracking of actual cumulative pollutant loadings
to a land application site to ensure that the cumulative pollutant loading rates are not exceeded. If an
applier were unaware that the land application site was being used by another applier or that the site had,
in the past, received bulk CPLR sewage sludge, then the applier would be unable to account for these
other loadings and the cumulative pollutant loading rates could be exceeded. Therefore, all appliers are
required to notify the permitting authority of the sites receiving bulk CPLR sewage sludge. The
permitting authority can then inform the appliers of any other appliers using the site or who have used
that site in the past. Since the permit writer will normally issue a permit to the preparer but not to the
applier, this notification requirement may be more appropriately addressed in the preparer's permit.
Permit Conditions
l.
The permittee shall notify the permitting authority in the State of [insert State name]
prior to the application of sewage sludge in that State. This notification shall
include: the site location (address); the date(s) the sludge is/will be land applied;
and its name, address, telephone number, and, if applicable, NPDES permit
number.
If the preparer land applies
State, the permit writer
condition similar to this one.
sewage
should
sludge in
include a
another
permit
Draft—March 1993
4-20
-------
4. LAND APPLICATION - PART 503 SUBPART B
2. The permittee shall provide the permitting authority with written notice prior to
land application of a sewage sludge that is subject to cumulative pollutant loading
rates. The notice shall include the location of the site, and the name, address,
telephone number, and, if applicable, its NPDES permit number of the land applier
of the sludge.
4.4 POLLUTANT LIMITS
Subpart B contains pollutant limits for sewage sludge that is land applied. First, sewage sludge cannot
be land applied if it exceeds the ceiling concentrations in §503.13(b)(l). If it can be land applied, then
there are three ways of regulating the pollutant levels in the sewage sludge. The three alternative sets
of pollutant limitations are: pollutant concentrations, annual pollutant loading rates, and cumulative
pollutant loading rates. These alternatives were developed to encourage the beneficial use of sewage
sludge under a variety of circumstances. A pollutant concentration can be imposed which regulates the
amount of pollutant allowed per unit amount of sewage sludge [measured as milligrams of pollutant per
kilogram of sewage sludge (mg/kg)]. For bagged sludge, an annual pollutant loading rate (APLR) can
be imposed which regulates the maximum amount of pollutant that can be applied to a unit of land during
a 365-day period. Instead of limiting the amount of pollutant in the sewage sludge, the APLR controls
the amount of pollutant applied to the land each year. For bulk sludge, a cumulative pollutant loading
rate (CPLR) can be imposed which regulates the maximum amount of pollutant that (CPLR) can be
applied to a unit area of land. Like the APLR, the CPLR does not restrict the pollutant concentration
in the sewage sludge but instead establishes the maximum amount of pollutant that can be applied to a
site.
The determination of which pollutant limit is the most appropriate to apply will depend upon the pollutant
concentrations in the sewage sludge, the pathogen reduction and vector attraction reduction levels to be
achieved, and the intended land application practice as illustrated in Table 4-2. The permit writer can
use the flow chart in Figure 4-2 to identify the appropriate set of pollutant limits to apply in the permit.
The first step for the permit writer is to evaluate whether or not the sewage sludge meets the ceiling
concentration limits in §503.13(b)(l). The permit writer should review all available pollutant data and
determine that all data points are below the ceilings in Table 1 of §503.13. Section 4.5 and Chapter 6
provide further discussion of the pathogen and vector attraction requirements of the Part 503 regulation.
Sewage sludge or material derived from bulk sewage sludge that achieves the pollutant concentrations
established in §503.13(b)(3), one of the Class A pathogen reduction alternatives listed in §503.32(a), and
one of the vector attraction reduction alternatives listed in §503.83(b)(l) through (8) is referred to as
exceptional quality sewage sludge. Persons may use or distribute the exceptional quality sewage sludge
in bulk or bag form with no additional regulatory requirements, other than monitoring, record keeping,
and reporting, except when the permitting authority determines additional requirements are necessary on
a case-by-case basis to protect public health and the environment. Exceptional quality sewage sludge also
refers to material derived from sewage sludge that met the exceptional quality criteria before it was mixed
Draft—March 1993 4-21
-------
4. LAND APPLICATION - PART 503 SUBPART B
Ceiling Coocenntian
PoUuunt
Ancaic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
•dry weight basis
75
85
3000
4300
MO
57
. 75
420
100
7500
Polluunl
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Cumulative Pollutant
Loading Rate (kg/ha)
41
39
3000
1500
300
17
18
420
100
2800
T»Me 3 «f 1503,13
Pollutant
Anenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
*drv weight basis
Pollutant
Concentration
(ing/kg)'
41
39
1200
1500
300
17
18
420
3«
2800
Pollutant
Anenk
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Annual Pollutant Loading Rale
(kg/ha/365 day period)
Znc
2.0
1.9
150
75
15
0.85
0.90
21
5.0
140
YES
u the wwage ttudge
exceptional quality?
U the wwage iludge told or
given away in a bag or other
container?
Don tewage iludge meet
pollutant concentration limits?
Apply Table 3
Apply Tabta 4 and 1
Apply Table 3
Apply Tablet 2 and 1
FIGURE 4-2 FLOW CHART TO DETERMINE APPLICABLE POLLUTANT LIMITS
Draft-March 1993
4-22
-------
4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-2 ELIGIBLE SEWAGE SLUDGE LAND APPLICATION
PRACTICES BASED ON SLUDGE QUALITY
Sludge Quality
Eligible Land Application Practices
• Pollutant concentration limits;
• Class A pathogen reduction alternative; and
• One of vector attraction reduction alternatives 1-8
This is referred to as exceptional quality sewage sludge
Sale or give away in bag or other container
Bulk application to:
• Agricultural land
Lawn or home garden
Forest land
Public contact site
Reclamation site
• Pollutant concentration limits;
• Class A pathogen reduction alternative; and
• One of vector attraction reduction alternatives 9 or
10
Bulk application to:
Agricultural land
Forest land
Public contact site
Reclamation site
Pollutant concentration limits;
Class B pathogen reduction alternative; and
One of vector attraction reduction alternatives 1-10
Bulk application to:
Agricultural land
Forest land
Public contact site
Reclamation site
Annual pollutant loading rate;
Class A pathogen reduction alternative; and
One of vector attraction reduction alternatives 1-8
Sale or give away in bag or other container
• Cumulative pollutant loading rate;
• Class A or Class B pathogen reduction alternatives;
and
• One of vector attraction reduction alternatives 1-10
Bulk application to:
Agricultural land
Forest land
Public contact site
Reclamation site
(which exempts it from all Part 503 requirements), and to sewage sludge-derived material meeting the
exceptional quality criteria after being mixed (even though the bulk sewage sludge may not have met
exceptional quality criteria prior to mixing). Further guidance on how to apply the exceptional quality
sewage sludge pollutant concentrations is provided in Section 4.4.1.
If the sewage sludge does not qualify for exceptional quality status because it does not meet Class A
pathogen reduction requirements, the pollutant concentration limits and Class B pathogen reduction
requirements can be applied. If the sewage sludge meets Class A pathogen reduction levels but it does
not meet one of the vector attraction reduction alternatives in §503.33(b)(l) through (8), then the pollutant
concentration limits, Class A pathogen reduction requirements and the vector attraction reduction
alternative 9 or 10 can be applicable. Further instructions on how to apply the pollutant concentration
limits are provided in Section 4.4.1.
If the sewage sludge does not meet the exceptional quality criteria because the concentration of any
regulated pollutant exceeds the pollutant concentrations established in §503.13(b)(3), the next step is to
determine whether >, not the annual or cumulative pollutant loading limits are applicable.
Draft—March 1993
4-23
-------
4. LAND APPLICATION - PART 503 SUBPART B
Annual pollutant loading rates (APLRs) apply to sewage sludge that is distributed in a bag or other
container with pollutant concentrations exceeding those established for exceptional quality sewage sludge.
In this case, the sewage sludge must meet the APLRs set forth in §503.13(b)(4). Because this sewage
sludge is distributed to the general public, it must still meet the Class A pathogen reduction levels and
the vector attraction reduction alternatives that must be met by exceptional quality sewage sludge.
Further guidance on the APLRs is provided in Section 4.4.2.
Cumulative pollutant loading rates (CPLRs) apply to bulk sewage sludge that does not meet the pollutant
concentration limits of §503.13(b)(3). The cumulative pollutant loading rates must be applied, as well
as either Class A or B pathogen requirements and one of the ten vector attraction reduction alternatives.
The permit writer should refer to Section 4.4.3 for further instructions on how to apply CPLRs.
4.4.1 POLLUTANT CONCENTRATION LIMITS
Statement of Regulations
§503.13 Pollutant limits
§503.13(a) Sewage sludge
§503.13(a)(2) If bulk sewage sludge is applied to agricultural land, forest, and public contact site, or a
reclamation site, either:
(i) the cumulative loading rate for each pollutant shall not exceed the cumulative loading rate
for the pollutant in Table 2 of §503.13; or
(ii) the concentration of each pollutant in the sewage sludge shall not exceed the concentration
for the pollutant in Table 3 of §503.13.
§503.13(a)(3) If bulk sewage sludge is applied to a lawn or a home garden, the concentration of each pollutant
in the sewage sludge shall not exceed the concentration for the pollutant in Table 3 of §503.13.
§503.13(a)(4) If sewage sludge is sold or given away in a bag or other container for application to the land,
either: . , . '•'• V'""'. ••" ;;' "• ' v "
(i) the concentration of each pollutant in the sewage sludge shall not exceed the concentration
for the pollutant in Table 3 of §503.13; or
(U) the product of the concentration of each pollutant in the sewage sludge and the annual
whole sludge application rate for the sewage sludge shall not cause the annual pollutant
loading rate for the pollutant in Table 4 of §503.13 to be exceeded. The procedure used to
determine the annual whole sludge application rate is presented in Appendix A of this part,
§503.13(b) Pollutant concentrations and loading rates - sewage sludge. r
Draft-March 1993 4-24
-------
4. LAND APPLICATION - PART 503 SUBPART B
§503.13(b)(3) Pollutant concentrations
TABLE 3 OF §503.13 - POLLUTANT CONCENTRATIONS
Monthly Average Concentration
Pollutant (milligrams per kilogram)*
Arsenic 41
Cadmium 39
Chromium 1200
Copper 1500
Lead 300
Mercury 17 : :: •
Molybdenum 18
Nickel 420
Selenium ' 3gi ::::;: ..:
Zinc 2800
* Dry weight basis
To qualify as exceptional quality, sewage sludge must meet Class A pathogen reduction requirements and
any of the first eight vector attraction reduction alternatives listed in the Part 503 regulations, in addition
to the pollutant concentrations in §503.13(b)(3). Once the permit writer makes a determination that the
sewage sludge can be appropriately regulated as exceptional quality sewage sludge, then the permit writer
will apply the pollutant concentrations contained in §503.13(b)(3) as well as the appropriate pathogen and
vector attraction reduction requirements in the permit. Persons generating exceptional quality sewage
sludge are relieved from certain requirements of Subpart B. For example, achieving exceptional quality
sewage sludge generally eliminates the need to notify subsequent users of sewage sludge quality or to
comply with management practices.
If the sewage sludge does not meet the exceptional quality criteria because it fails to achieve Class A
pathogen reduction requirements, the concentration limits may still be applied. The permit writer should
note that since the sewage sludge is not exceptional quality, there are general requirements, management
practices, and site restrictions to which the permittee is subject. Moreover, sewage sludge that does not
meet Class A pathogen levels may not be applied to lawns or home gardens, nor may it be sold or given
away in a bag or other container.
If the sewage sludge does not meet the exceptional quality criteria because vector reduction alternative
9 or 10 is used, the concentration limits may still be applied. In this situation, the permittee is subject
to general requirements and management practices. This sewage sludge also may not be applied to lawns
or home gardens, nor may it be sold or given away in a bag or other container.
Draft-March 1993 4-25
-------
4. LAND APPLICATION - PART 503 SUBPART B
When sewage sludge data indicate that the pollutant concentrations in §503.13(b)(3) are met, but
exceedences of the limitations may occur due to either significant variations in sewage sludge quality or
a trend showing worsening quality, the permit writer should consider imposing additional conditions,
including:
• Requirements to monitor and report more frequently than the minimum monitoring and reporting
frequencies set forth in the regulations
• Requirements to reduce the pollutant concentrations in the sewage sludge (for example, if the
generator is a POTW with a pretreatment program, the permit writer could require the POTW
to reevaluate its local limits or impose additional controls on the discharge to the sewage system).
The permit should include the pollutants and pollutant concentration limits that appear in §503.13(b)(3).
These limits should be expressed as monthly average concentrations. These limits should also be
expressed on a dry weight basis. The metric units (mg/kg) should be included in the permit.
4.4.2 ANNUAL POLLUTANT LOADING RATES
Statement of Regulations
§503.13 Pollutant limits
§503.13(a) Sewage sludge
§503.13(a)(l) Bulk sewage sludge or sewage sludge sold or given away in a bag or other container shall: not be!
applied to the land if the concentration of any pollutant in the sewage sludge exceeds the ceiling
concentration for the pollutant in Table 1 of §503.13.
§503.13(a)(4) If sewage sludge is sold or given away in a bag or other container for application to the land,
either:
(i) the concentration of each pollutant in the sewage sludge shall not exceed the concentration
for the pollutant in Table 3 of §503.13. y • j
(ii) the product of the concentration of each pollutant in the sewage sludge and die annual
whole sludge application rate for the sewage sludge shall not cause the annual pollutant
loading rate for the pollutant in table 4 of §503.13 to be exceeded. The procedure used to
determine the annual whole sludge application rate is presented in Appendix Aof this part.
Draft—March 1993 4-26
-------
4. LAND APPLICATION - PART 503 SUBPART B
§503.13(b) Pollutant concentrations and loading rates • sewage sludge.
§503.13(b)(l) CeUing concentrations
TABLE 1 OF §503.13 - CEILING
CONCENTRATIONS
Pollutant
Arsenk
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
*Dry weight basis
Ceiling Concentration
(milligrams per
kilogram)*
75
85
3000
4300
840
57
75
420
100
7500
§503. 13(b)(4) Annual pollutant loading rates
TABLE 4 OF §503.13 - ANNUAL POLLUTANT
LOADING RATES
Pollutant
Arsenk
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Annual Pollutant Loading Rate
(kilograms per hectare per 365 day
period)
,-.:. ..... . 2.0 • "•;.. ••:,..: :
••'• ' • -;-'" 1.9. < : • •:.,•.
::- •. •.. • ;' ..: . 150 .;,, : :/".. ...-.;
• • . •' ' :, 75 • •-. •:•;.:; '..,
'. • : .. •' : .....15 • •-" •..:.;::/•;•;<.-.
•' ' ••'•"••-'• 0;85 •'•:Y-"S-':.:'"<-::
0;90
• ' 21 "
5.0 ' v • , ,
: • .140. , •'::,' I. •:
The annual pollutant loading rates are generally applied to sewage sludge that is sold or given away in
a bag or other container when the sewage sludge or material does not meet the pollutant concentration
limits in §503.13(b)(3). If the following conditions apply to the sewage sludge, then it can be regulated
by annual pollutant loading rates:
• Sewage sludge does not exceed pollutant ceiling concentrations in §503.13(b)(l)
• Sewage sludge meets Class A pathogen reduction
• Sewage sludge meets one of the eight vector attraction reduction alternatives in §503.33(b)(l-8)
• Sewage sludge will be sold or given away in a bag or other container.
To implement the annual pollutant loading rates in a permit, the permit writer will need to develop and
impose permit conditions that address the following:
• Ceiling concentrations
• Annual pollutant loading rates
• Annual whole sludge application rate (AWSAR)
• Labelling requirements (management practice discussed in Section 4.6.6 of this chapter).
Draft—March 1993
4-27
-------
4. LAND APPLICATION - PART 503 SUBPART B
The sewage sludge cannot be applied to the land if the pollutant concentrations in the sewage sludge
exceed the ceiling concentrations established in §503.13(b)(l). The permit should include these ceiling
concentrations and a condition that prohibits the land application of the sewage sludge if it exceeds these
concentrations.
Annual Pollutant Loading Rates
The permit should include the pollutants and annual pollutant loading rates that appear in §503.13(b)(4).
These annual pollutant loading rates are not concentration limits, but instead are maximum amounts of
the pollutants that can be applied to a unit area of land during a 365 day period. This means, for
example, that 140 kilograms of zinc can be applied to a hectare of land annually. The same hectare of
land can receive 140 kilograms of zinc each subsequent annual period. These annual pollutant loading
rates should be expressed on a dry weight basis using kilograms/hectare (kg/ha), but English units can
also be used. Conversion factors are provided in Appendix A.
Annual Whole Sludge Application Rate
The annual whole sludge application rate (AWSAR) for each regulated pollutant is calculated using the
following equation.
AWSAR APLR
C x .001
Where:
AWSAR = annual whole sludge application rate in metric tons per hectare per 365 day period
(dry weight basis)
APLR = annual pollutant loading rate from §503.13(b)(4) in kilograms per hectare per 365
days
C = concentration of pollutant in sewage sludge in milligrams per kilogram (dry weight
basis)
.001 = conversion factor
After calculating an AWSAR value for each pollutant, the lowest AWSAR value is chosen to ensure that
none of the APLRs will be exceeded. Figure 4-3 provides an example calculation.
There are at least two ways to implement the AWSAR through the permit.
, • The permit writer can determine the AWSAR and require the permittee to comply with the
AWSAR. The permit writer will need to document the actual pollutant concentrations used in
the AWSAR equation in the permit fact sheet.
• The permit writer can require that the permittee calculate an AWSAR. If the pollutant
concentration increased tor any particular pollutant, the permittee must recalculate and comply
with a new AWSAR. The permittee should then be required to notify the permitting authority
any time a change in pollutant concentrations causes a change in the AWSAR.
Draft—March 1993 4-28
-------
4. LAND APPLICATION - PART 503 SUBPART B
Given: Step 1 shows the Information to be gathered from the applicant and the annual pollutant loading rates
Step 1: Measure the concentration of arsenic, cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium, and zinc
in the sewage sludge.
Annual pollutant loading rates from Table 4 in Section S03.13(b)(4) for land application and measured pollutant concentrations
in the sewage sludge are provided:
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Aniiual Pollutant Loading Rate* (kg/ha)
2.0
1.9
150
75
• 15
0.85
0.90
21
5
140
. Concentration** (nig/kg)
10
7
850
741
134
5
9
42
5
1,201
•From Table 4 of Section 503.13.
••Measured in the sewage sludge.
Calculations: Steps 2 and 3 show the procedures, using the Information gathered In Step I, to calculate the annual whole sludge
application rate (AWSAR) that ensures annual pollutant loading rates are not exceeded.
Step 2: Using the pollutant concentrations from Step 1 and the APLRs from Table 4 of the land application regulations, calculate the
AWSAR using the equation below.
AWSAR
APLR
C x 0.001
Where,
AWSAR
APLR
C
0.001
Annual whole sludge application rate in metric tons (mt) per hectare per 365 day period (dry weight basis).
Annual pollutant loading rate in kilograms per hectare per 365 day period.
Measured pollutant concentration in the sewage sludge in milligrams per kilograms of total solids (dry weight basis).
Conversion factor.
j : ANNUAL WHOLE SLUDGE APPLICATION RATE (AWSAR)
:?->':'.v y':<.V''"; Pollutant . ,. : :;
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
(mt/ka/365 day period*)
200
271
176
101
112
170
100
500
1,000
117
•Dry weight basis.
Step 3: Determine the AWSAR for the sewage sludge by selecting the lowest AWSAR from those calculated in Step 2.
The lowest Annual Whole Sludge Application Rate for the sewage sludge in this example is 100. If the sewage sludge is
applied to land at a rate greater than 100 metric tons per hectare per 365 day period, the APLR for molybdenum will be
exceeded.
FIGURE 4-3 EXAMPLE CALCULATIONS FOR DETERMINING THE AWSAR
Draft—March 1993
4-29
-------
4. LAND APPLICATION - PART 503 SUBPART B
Labelling Requirement
The permit should specify that a label or information sheet must be distributed with the sewage sludge.
This label or information sheet must contain the AWSAR. See Section 4.6.6 for further discussion. The
permittee should also be required to submit a copy of the revised label with the revised AWSAR.
4.4.3 CUMULATIVE POLLUTANT LOADING RATES
Statement of Regulations
|503.12(b) No person shall apply bulk sewage sludge subject to the cumulative pollutant loading rates in
§503.13(b)(2) to agricultural land, forest, a public contact site, or a reclamation site if any of the
cumulative pollutant loading rates in §503.13(b)(2) has been reached.
{503.13 Pollutant limits
§503.13(a) Sewage sludge
§503.13(a)(l) Bulk sewage sludge or sewage sludge sold or given away in a bag or other container shall not be '
applied to the land if the concentration of any pollutant in the sewage sludge exceeds the ceiling p r
concentration for the pollutant in Table 1 of §503.13. ;
§503.13(a)(2) If bulk sewage sludge is applied to agricultural land, forest, a public contact site, or a
reclamation site, either:
(i) the cumulative loading rate for each pollutant shall not exceed the cumulative pollutant:
loading rate for the pollutant in Table 2 of §503.13; or
(ii) the concentration of each pollutant in the sewage sludge shall not exceed the concentration
for the pollutant in Table 3 of §503.13.
§503.13(b) Pollutant concentrations and loading rates - sewage sludge. •
§503.13(b)(l) Ceiling concentrations
TABLE 1 OF §503.13 - CEILING
CONCENTRATIONS
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
•Dry weight basis
Ceiling Concentration
(milligrams per
kilogram)*
75
85
3000
4300
840
57
75
420
100
7500
§503.13(b)(2) Cumulative pollutant loading rates
TABLE 2 OF §503.13 -CUMULATIVE
POLLUTANT LOADING RATES :
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Cumulative Pollutant
Loading Rate
(kilograms per hectare)
'•:• • 41
39
••• •'••'- :•• • 3000 ••' •-:• '.•-
1500
•. =• . ,' 300 ',.-•-, :. :;
• -17. .'•-.••• •." -• -'
18
420
100
2800
Draft-March 1993
4-30
-------
4. LAND APPLICATION - PART 503 SUBPART B
The cumulative pollutant loading rates (CPLRs) are usually applied to bulk sewage sludge that cannot
meet the pollutant concentration limits in §503.13(b)(3). The CPLRs cannot be applied to bulk sewage
sludge applied to lawns or home gardens or to sewage sludge sold or given away in a bag or other
container. A CPLR represents the maximum amount of a pollutant that can be applied to a particular
piece of land. Therefore, the land applier must keep records on every application of sewage sludge to
each site in order to track the total amount of each pollutant applied to the site.
The CPLRs in §503.13(b)(2) are not concentration limits, but instead are maximum amounts of the
pollutants than can be applied to a unit area of land. The CPLR for a pollutant may be applied all in one
year or over a period of years. Once the cumulative loading rate is reached for any pollutant, no
additional sewage sludge subject to the CPLRs can be applied to the site.
The permit should include the pollutants and CPLRs that appear in §503.13(b)(2). CPLRs should be
expressed on a dry weight basis as kg/ha, but English units can also be used. Conversion factors are
provided in Appendix A. The permit should also include the ceiling concentration in §503.13(b)(l) and
a condition that prohibits the land application of the sewage sludge if it exceeds these concentrations.
The permit writer should also develop permit conditions that require the permittee to track the following
information:
• Concentration of pollutants in sewage sludge
• Amount of sewage sludge in kilograms per hectare applied to each site
• Size of each site in hectares
• Cumulative loading of each pollutant on each site.
In addition to tracking the pollutant loadings for each land application site, a permittee whose land
application practice is subject to CPLRs is also subject to additional management practices and reporting
requirements that are described in detail later in this chapter.
The permit writer may want to verify that the permittee has sufficient land application sites to handle the
quantity of sewage sludge to be applied. This will require the following information:
• Annual quantity of sewage sludge to be applied
• Land application sites' acreage.
Draft-March 1993 4-31
-------
4. LAND APPLICATION - PART 503 SUBPART B
Using this information, the permit writer can evaluate how long the sites identified in the application can
receive sewage sludge without exceeding the CPLRs. Figure 4-4 shows the procedures the permit writer
should follow when calculating or verifying the number of years sewage sludge may be applied to an area
of land. Figure 4-5 provides an example calculation using the procedures set forth in Figure 4-4. It
should be noted that these procedures are used only to estimate the number of years a sewage sludge can
be applied to a site. This estimate changes if the pollutant concentrations in the sewage sludge change
or if the sewage sludge application rate changes.
Where the permit writer's calculations indicate that exceedances of the CPLRs may or will occur, the
permit writer must require the permittee to make provisions to prevent such exceedances. Some
additional conditions which the permit writer may consider imposing include:
• Requirements to obtain additional acreage for land application purposes
.• Requirements to calculate site lives and to submit periodic reports verifying that CPLRs have not
been exceeded
• Requirements to reduce the pollutant concentrations in the sewage sludge by imposing additional
controls on industrial users as part of the pretreatment program (if applicable).
4.5 OPERATIONAL STANDARDS-PATHOGENS AND VECTOR
ATTRACTION REDUCTION
Bulk sewage sludge going to homes or gardens or any sewage sludge or material derived from sewage
sludge that is sold or given away must be carefully treated to reduce the risk of disease transmission to
the public using the substance. For this reason, the sewage sludge used in a manner that has high
potential for public contact is required to achieve the highest pathogen and vector attraction reductions.
Because of the lower potential for public exposure and the ability to control public access once the sewage
sludge is applied, bulk sewage sludge that is applied to agricultural land, forest, selected public contact
sites, and reclamation sites does not have to be treated to achieve the highest reductions. The different
alternatives to demonstrating or achieving pathogen and vector attraction reduction are discussed in
Chapter 6. Table 4-3 indicates which of the pathogen and vector attraction reduction requirements in
Subpart D apply to bulk sewage sludge and sewage sludge sold or given away in a bag or other container.
Because Part 503 provides for several alternatives for pathogen and vector attraction reduction, it is
necessary for the permit writer to specify the alternative (s) that the permittee must meet. Preferably only
one alternative should be specified in the permit. The permit writer should also include a statement that
no other alternatives are allowed unless authorized by the permitting authority.
Draft—March 1993 4-32
-------
4. LAND APPLICATION - PART 503 SUBPART B
Given: Steps 1 and 2 show the information to be obtained from the applicant for use in
calculating the site life
Step 1: The concentration of arsenic, cadmium, chromium, copper, lead, mercury, molybdenum,
nickel, selenium, and zinc in the sewage sludge.
Step 2: The whole sludge application rate (SR).
Calculations: Steps 3 through 5 show the procedures, using the information gathered in Steps
1 and 2, to calculate the number of years sludge could be applied
Step 3: Calculate a yearly pollutant loading rate (PL) for each inorganic pollutant using the
equation below.
PL = C x 0.001 x SR
Where:
i
PL = Yearly pollutant loading rate for an inorganic pollutant in kilograms per hectare
per 365 day period.
C = Measured pollutant concentration in the sewage sludge in milligrams per kilograms
of total solids (dry weight basis).
SR = Whole sludge application rate in metric tons per hectare per 365 day period (dry
weight basis).
0.001 = Conversion factor.
Step 4: Calculate the years an inorganic pollutant can be applied to the land by dividing the
cumulative pollutant loading rate in Table 2 of §503.13 by the PL calculated in Step 3
of this procedure.
Step 5: Determine the lowest number of years calculated in Step 4 of this procedure. This is the
period that sewage sludge can be applied to the land without causing any of the
cumulative pollutant loading rates in Table 2 of §503.13 to be exceeded.
FIGURE 4-4 PROCEDURES TO CALCULATE SITE LIFE
Draft-March 1993 4-33
-------
4. LAND APPLICATION - PART 503 SUBPART B
Given:
Step 1:
Step 2:
Calcula
Step 3:
f
Fl
Steps 1 and 2 show the information obtained from the facility for use in calculating site
W
The pollutant concentrations in sewage sludge (dry weight basis) follow:
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Measured Concentration (mg/kg)
10
7
850
741
134
5
9
42
5
1,201
Whole sludge application rate is 10 metric tons per hectare per 365 day period.
tions: Steps 3 through 5 show the calculations, using the information gathered in Steps
land 2. .
Determine the yearly pollutant loading rates (PL) for the pollutants using the equation
provided in Step 3 of Figure 4-5. ,
Pollutant Measu
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
red Concentration (mg/kg)
10
7 ' '
850
741
134
5
9
42
5
1,201
PL(kg/ha/yr)
0.10
0.07
8.50
7.41
1.34
0.05
0.09
0.42
0.05
12.01
[CURE 4-5 EXAMPLE CALCULATIONS FOR DETERMINING SITE LIFE
Draft-March 1993
4-34
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4. LAND APPLICATION - PART 503 SUBPART B
Step 4: Calculate the years an inorganic pollutant can be applied to the land by dividing the
CPLR by PL.
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
CPLR*
(kg/ha)
41
39
3,000
1,500
300
17
18
420
100
2,800
PL**
(kg/ha/yr)
0.10
0.07
8.50
7.41
1.34
0.05
0.09
0.42
0.05
12.01
Years
(CPLR/PL)
410
557'
353
202
224
340
200
1,000
2,000
233
*From Table 2 of Section 503.13
**From Step 3
Step 5: Determine the lowest number of years calculated in Step 4.
For this example, the lowest number of years is 200 for molybdenum. Sewage sludge
with the inorganic pollutant concentrations given in Step 1 of this procedure can be
applied to the land each year at a whole sludge application rate of 10 metric tons per
hectare for a period of 200 years.
FIGURE 4-5 EXAMPLE CALCULATIONS FOR DETERMINING SITE LIFE
(Continued)
Draft—March 1993
4-35
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4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-3 PATHOGEN AND VECTOR ATTRACTION REDUCTION REQUIREMENTS
FOR VARIOUS LAND APPLICATION PRACTICES
Sewage Sludge Uses
Regulatory Requirements
• Exceptional quality sewage sludge
• Material derived from exceptional quality sewage
sludge
• Material meeting exceptional quality criteria
• Bulk sewage sludge or material derived from bulk
sewage sludge applied to a lawn or a home garden
• Sewage sludge sold or given away in a bag or a
, other container . '
Pathogens—Class A: one in §503.32(a)
Vectors—one in §503.33(b)(l) through
§503.33(b)(8)
• Bulk sewage sludge applied to:
- Agricultural land
- Forest
- Public contact site
- Reclamation site
Pathogens—Class A or Class B: one in §503.32(a)
or §503.32(b),
Vectors—one in §503.33(b)(l) through
§503.33(b)(10)
To select the specific pathogen and vector attraction reduction alternatives with which the permittee must
comply, the permit writer should consider the following: ,;,
• Final Use of Sewage Sludge — The permit writer must be certain what land application practice
is to be used by the permittee.
• Sewage Sludge Treatment Processes — The permit writer should identify which treatment
processes the permittee employs. The permit writer should review any submitted sewage sludge
quality data and evaluate any information regarding existing or proposed sewage sludge treatment
processes to verify that the permittee is capable of meeting the pathogen and vector attraction
reduction requirements for the land application practice proposed. The permit writer should then
identify which specific pathogen and vector attraction reduction alternatives are:
- Required by Part 503 for the land application practice to be used
Possible given the permittee's sewage sludge treatment processes
Table 4-4 lists the alternatives that the preparer must meet and those that the applier must meet. In
specifying monitoring requirements, the permit writer should make clear the following requirements:
' • Sampling Location — The sample..point(s) should be specified in the greatest detail possible.
• Sample Type — The permit writer should specify whether composite or grab sampling is required
for each sample point and parameter. For each type specified, a definition should also be
, provided.
Draft—March 1993
4-36
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4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-4 PATHOGEN AND VECTOR ATTRACTION REDUCTION REQUIREMENTS
FOR LAND APPLICATION
PATHOGEN AND VECTOR ATTRACTION REDUCTION
REQUIREMENTS FOR PREPARERS OF SEWAGE SLUDGE
Class A Pathogen Reduction
Alternative 1 Time and temperature
Alternative 2 pH, temperature and time
Alternative 3 One-time demonstration correlating pathogen
levels and operating parameters
Alternative 4 Concentrations of enteric viruses and helminth
ova
Alternative 5 Processes to Further Reduce Pathogens (PFRP)
1 . Composting
2. Heat drying
3. Heat treatment
4. Thermophilic aerobic digestion
5. Beta ray irradiation . .
6. Gamma ray irradiation
7. Pasteurization
Alternative 6 Equivalent to PFRP ,
In addition all six alternatives include pathogen levels for fecal
coliform or Salmonella
Class B Pathogen Reduction
Alternative 1 Density of fecal coliform
Alternative 2 Processes to Significantly Reduce Pathogens
(PSRP)
1 . Aerobic digestion
2. Air drying
3. Anaerobic digestion
4. Composting
S. Lime stabilization
Alternative 3 Equivalent to PSRP
Vector Attraction Reduction
Alternative 1 ; 38 percent volatile solids reduction
Alternative 2 Lab demonstration of volatile solids reduction
anaerobically
Alternative 3 Lab demonstration of volatile solids reduction
aerobically
Alternative 4 SOUR & 1 .5 mg 0,/hour/g total solids
Alternative 5 Aerobic digestion for 14 days at > 40°C
Alternative 6 pH to & 12
Alternative 7 75 percent solids
Alternative 8 90 percent solids
•
PATHOGEN AND VECTOR ATTRACTION REDUCTION REQUIREMENTS FOR APPLEERS OF
SEWAGE SLUDGE
Class B Pathogen Reduction
Class B Sludge Site Restrictions
Vector Attraction Reduction
Alternative 9 Injection below land surface
Alternative 10 Incorporation into soil
503.32(b)(5) Site Restrictions
(i) Food crops with harvested parts above ground but touching the sewage sludge/soil mixture shall not be harvested for 14 months
after application.
(ii) Food crops with harvested parts below the surface shall not be harvested for 20 months after application when the sewage sludge
remains on the surface for 4 months or longer prior to incorporation into the soil.
(iii) Food crops with harvested parts below the surface shall not be harvested for 38 months after application when the sewage sludge
remains on the surface for less than 4 months prior to incorporation into the'soil.
Civ) Food/feed/fiber crops shall not be harvested for 30 days after application.
(v) Animals shall not be grazed on land for 30 days after application.
(vi) Turf grown where sewage sludge is applied shall not be harvested for 1 year after application when the harvested turf is placed
on land with a high potential for public exposure or on a lawn, unless otherwise specified by the permitting authority.
(vii) Public access to land with a high potential for public exposure shall be restricted for 1 year after application.
(viii) Public access to land with a low potential for public exposure shall be restricted for 30 days after application.
Draft-March 1993
4-37
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4. LAND APPLICATION - PART 503 SUBPART.B
• Sampling and Analytical Protocol — Methodology references should be specified and compliance
with those methodologies should be required.
• Monitoring Frequency — Pathogen density requirements and vector attraction reduction
requirements must be monitored at a frequency of once per year to 12 times per year depending
on the quantity of sewage sludge. The permit writer will need to use BPJ in determining the
appropriate frequency for monitoring the operating parameters of the pathogen and vector
attraction reduction processes.
The development of specific monitoring and record keeping conditions in the permit is vital if the
permittee is to be held accountable for compliance with the requirements. Table 4-5 summarizes the
specific monitoring/data or documentation information for which records should be required. The permit
must include the typical permit conditions regarding adequacy and completeness of records, and should
require retention for at least 5 years.
TABLE 4-5 SUGGESTED MONITORING AND RECORD KEEPING REQUIREMENTS
Alternatives
Pathogen or Vector Attraction Levels
Operating Parameters
Pathogen Reduction Alternatives
Class A
Alternative 1
Class A
Alternative 2
Class A
Alternative 3
Class A
Alternative 4
Class A
Alternative 5
Class A
Alternative 6
Class B
Alternative 1
Class B
Alternative 2
Class B
Alternative 3
• Fecal coliform or Salmonella
• Fecal coliform or Salmonella
Fecal coliform or Salmonella
Viruses
Helminth ova
Fecal coliform or Salmonella
Viruses
Helminth ova
• Fecal coliform or Salmonella
• Fecal coliform or Salmonella
• Fecal coliform
None
None
Percent solids
Sewage sludge temperature
Time temperature maintained
pH . .
. Time pH maintained
Sewage sludge temperatures
Percent solids
• Specific to the process
• Specific to the process
• Specific to PFRP* process
• Specific to the process
None
• Specific to PSRP+ process
• Specific to the process
"PFRP = Processes to further reduce pathogens
+PSRP = Processes to significantly reduce pathogens
Draft—March 1993
4-38
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4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-5 SUGGESTED MONITORING AND RECORD KEEPING REQUIREMENTS (Continued)
Site Restrictions for Class B (see description in Table 4-4) :
' (0
, (ii)
(iii)
,(iv)
' (v) '
(vi)
(vii)
(viii)
• Application dates, harvest dates
• Application dates, harvest dates
• Application dates, harvest dates
• Application dates, harvest dates
• Application date, date grazing was
initiated
• Application dates, harvest dates
• Application date, public access date
• Application date, public access date
Vector Attraction Reduction Alternatives (see description in Table 4-4)
1
2
3
4
5
6
7
8
9
10
• Volatile solids reduction
• Volatile solids reduction
• Volatile solids reduction
• Specific Oxygen Uptake Rate
• Sludge retention time
• Sewage sludge temperature
• PH
• Time
• Percent solids
• Percent solids
• Time between end of pathogen treatment
process and injection
• Time between application and
incorporation into soil
• Time between end of pathogen treatment
process and application
Draft—March 1993
4-39
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4. LAND APPLICATION - PART 503 SUBPART B
4.6 MANAGEMENT PRACTICES
Section 503.14 specifies five management practices for sewage sludge that is applied to the land. EPA's
intent in developing these management practices was to supplement the pollutant limits in §503.13 and
provide an additional measure of protection, not considered in the risk assessment models used to develop
the pollutant limits, to endangered species or critical habitat, surface water, wetlands, and ground water.
Section 503.14 also identifies an additional management practice, labelling sewage sludge sold or given
away in a bag or other container.
4.6.1 ENDANGERED SPECIES OR CRITICAL HABITAT PROTECTION
Statement of Regulations
§503.14(a) Bulk sewage sludge shall not be applied to the land if it is likely to adversely affect a threatened
or endangered species listed under Section 4 of the Endangered Species Act or its designated
critical habitat.
Purpose: To protect a threatened or endangered species or its designated critical habitat.
Applies to: Persons who apply bulk sewage sludge and materials derived from bulk sewage sludge to land where
there is potential for harming a threatened or endangered species of plant, fish, or wildlife or their habitat.
Permitting Factors
Land application sites are often located in rural areas that either contain or are surrounded by a wide
variety of plant, fish, and wildlife species, some of which may be endangered or threatened. Section 4
of the Endangered Species Act lists all threatened or endangered species of plants, fish, and wildlife. The
designated critical habitat is any place where a threatened or endangered species lives and grows during
any stage in its life cycle.
The permit writer will need to determine if any endangered or threatened species of plant, fish, or
wildlife exist on or near the application site. In addition, an application site may be located in the
migratory route of an endangered or threatened species offish or wildlife and may become a temporary
but critical habitat for such species. The permit application may provide information regarding the
existence of endangered species or critical habitats. The permit writer can also obtain such information
or verify the information provided in the permit application by contacting the field office of the U.S.
Department of Interior, Fish and Wildlife Service (FWS). To provide the permit writer with the
requested information, the FWS biologist may need specific data, such as the exact location (preferably
in terms of latitude and longitude), the size of the site, location and size of any nearby body of water,
and type and extent of vegetative cover.
If threatened or endangered species or their designated critical habitats are present in the areas proposed
to receive the sewage sludge, the permit writer will need to determine whether the application of the
sewage sludge to the land will likely cause an adverse effect upon the species or their habitats. An
adverse effect would be the destruction or adverse modification of the critical habitat to the extent that
Draft—March 1993 4-40
-------
4. LAND APPLICATION - PART 503 SUBPART B
the likelihood of survival and recovery of the species is diminished. Unfortunately, it may not be
possible to predict the effects of the land application of sewage sludge on the species or habitat without
site specific field studies. In some cases, it may be necessary to prohibit the application of sewage sludge
on sites where threatened or endangered species or their critical habitats are present. However, it may
be possible to allow the application of sewage sludge concurrent with field studies designed to measure
the effects of this application on the species and their habitats. EPA policy or best professional judgement
should be used to construct specific management practices to protect the species and their habitat.
Permit Conditions
Section 503.14(a) is not of concern if no endangered species of plant, fish, or wildlife are identified
within or near an application site and if it is determined that the application site is not located in the
migratory path of any endangered or threatened species of wildlife. However, as a precautionary
measure, the permit writer may include this management practice in the permit as it appears in Part 503.
If it is determined that the application site supports or is part of a critical habitat for a threatened or
endangered species of plant, fish, or wildlife, the permit writer should consult with FWS personnel or
other informed State or local agency personnel to determine and develop necessary permit conditions.1
For example, if the application site is located within the migratory path of an endangered species, the
permit writer could develop a permit condition prohibiting the application of bulk sewage sludge during
the migration period.
Other conditions that the permit writer may include are the following:
• Buffer zones that provide an adequate distance from the critical habitat of the endangered species
• Requirements for increased monitoring and reporting in certain areas
• Requirements to conduct special studies to determine the impact on the endangered species or its
critical habitat.
Examples of specific permit conditions are provided below.
'FWS and EPA are in the process of developing consultation guidance for such permitting activities.
Draft—March 1993 4-41
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4. LAND APPLICATION - PART 503 SUBPART B
If an endangered species or the critical habitat of an endangered species is present,
the permittee shall evaluate the likely adverse impact of the application of sewage
sludge, and shall develop and implement management practices that will assure no
adverse impact.
The permittee shall monitor the long-term effect of sewage sludge on the
endangered species or the critical habitat. The monitoring shall be conducted at a
frequency of (times per month, other) for a period of
(months, years) and shall include the following parameters:
The permit.writer should select a frequency which will
supply sufficient data to assess the long-term critical
impact without unnecessarily burdening the permittee.
The permit writer must also determine what parameters
are necessary to assure protection of the specific site
and what period of time will be required to conduct the
assessment.
If a likely adverse impact is determined, the permittee shall not apply sewage
sludge to the area occupied by the endangered species or the critical habitat of the
endangered species.
The permit writer should identify or include a list of the
endangered species or critical habitats.
Sewage sludge may be applied only if a protective buffer zone of
(feet, yards, other) from the critical habitat is maintained.
The permit writer should determine the appropriate size
of a buffer zone.
Draft—March 1993
4-42
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4. LAND APPLICATION - PART 503 SUBPART B
- ;
,"- s " " ^
5. Sewage sludgi
or greater in t
6. Sewage sludg
This <
migrat
the sit
3 shall not be applied to site areas with a slope of
he direction of the critical habitat.
3 shall not be applied to the site during the critical
, ,
condition is relevant if the endangered species
es through, but does not reside permanently at
e.
oercent
months of
; -
5 - -
4.6.2 APPLICATION OF SEWAGE SLUDGE TO FLOODED LAND2
Statement of Regulations
§503.14(b) Bulk sewage sludge shall not be applied to agricultural land, forest, a public contact site, or a
reclamation site that is flooded, frozen or snow-covered so that the bulk sewage sludge enters
a wetland or other waters of the United States, as defined in 40 CFR 122.2, except as provided
in a permit issued pursuant to section 402 or 404 of the CWA.
Purpose: To prohibit the application of sewage sludge to agricultural land, forest, a public site, or a reclamation
site that is flooded because application in this situation increases the chance for the sewage sludge to be washed into'
any nearby surface waters or wetlands.
Applies to: Any person who applies bulk sewage sludge to the land and land application sites that are flooded.
Permitting Factors
Generally, land is considered flooded when the soil at the surface of the land is saturated with water,
regardless of whether water is visible on the ground. Such flooding conditions may be produced by
heavy precipitation that occurs locally or at some distance from the site, the rise of any nearby surface
water levels, the rise of the ground-water table to the surface of the land, the melting of snow and ice
on the ground, or irrigation. Soil that is not well drained or not covered with grass or dense vegetation
can easily become saturated during heavy rainfalls and can remain saturated for an extended period during
rainy seasons. On the other hand, soil that is well drained and covered with thick vegetation can become
saturated but generally does not remain saturated for more than a few days after a major rain shower.
2Although §503.14(b) addresses application of sewage sludge to both flooded land and frozen or snow-covered
land together, this manual discusses sewage sludge application under these two situations separately for ease of
understanding.
Draft-March 1993
4-43
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4. LAND APPLICATION - PART 503 SUBPART B
The permit application (particularly the required topographic map) may provide information enabling the
permit writer to determine if a designated site has potential to flood. In addition, the permit writer may
wish to identify flood plains by contacting the local offices of the Army Corp of Engineers and the United
States Geological Survey. Typically, these offices maintain data concerning lands that may be flooded
in the event of precipitation. Particular attention should be paid to sites located adjacent to large water
bodies since these have the greatest potential to flood.
Lands located in flood plains are obviously more likely to become completely or partially flooded and
to remain flooded for an extended period. River floodplains are readily identifiable as the flat areas
adjacent to the river's normal channel. Floodplains are also identified in the flood insurance rate maps
(FIRMS); flood boundary and floodway maps are published by the Federal Emergency Management
Agency (FEMA). Guidance in using FIRMS is provided in How to Read a Flood Insurance Rate Map,
published by FEMA. FEMA also publishes The National Flood Insurance Program Community Status
Book, which lists communities that are in the Emergency or Regular Flood Insurance Programs, including
communities that may not be involved in the National Flood Insurance Program but that have FIRMS or
floodway maps published. Maps and other FEMA publications may be obtained from the FEMA
distribution center.
Areas not covered by FIRMS or floodway maps may be included in floodplain maps available through
the Army Corps of Engineers, the U.S. Geological Survey, the U.S. Soil Conservation Service, the
Bureau of Land Management, the Tennessee Valley Authority, and State and local agencies. Many of the
river channels covered by these maps may have undergone modification for hydropower or flood control
projects, and the floodplain boundaries represented may not be accurate or representative. To identify
current river channel modifications and land use watersheds that could affect floodplain designation, it
may be necessary to compare the floodplain map series to recent aerial photographs.
The rise of the ground-water table to the surface of the ground due to hydrogeological activities can also
cause flooding of the land. Such flooding conditions are most likely to occur in the lands where the ground-
water table is the ground surface. Information on the seasonal changes of the water table in an area can
be obtained from the U.S. Geological Survey. If the land regularly experiences upsurges of groundwater
and remains saturated for an extended period of time, it may be necessary to identify the approximate
period(s) of the year that such upsurges occur.
Irrigation is a controlled way of saturating the soil. The application of sewage sludge to an irrigated land
may not be a concern when irrigation is occurring during dry weather. In some cases, however, land
is flooded for an extended period to facilitate the crop or vegetation growth (e.g., rice fields, artificial
reedbeds, or artificial wetlands).
The permit writer should evaluate a land application site for all of the above factors that could cause the
land to become flooded and determine the conditions necessary to address in the permit. To handle this
issue properly in the permit, he/she should first define the conditions at which the land is considered
flooded and should then evaluate the geographic location of the land to determine the required conditions.
Different permit conditions may be needed depending on the location of the land and the extent of time
during which the land generally remains flooded. For example, land located in a flood plain that is often
flooded requires more specific permit conditions than land that is well drained and becomes saturated for
only a short period during local or seasonal precipitations.
Draft-March 1993 4-44
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4. LAND APPLICATION - PART 503 SUBPART B
Permit Conditions
Where no potential for floods is noted, the permit writer may incorporate the management practice as it
appears in Part 503. However, if the permit writer finds that potential for flooding exists, the permit
writer may address those land application sites with specific management practices. Some possible
conditions include:
• Prohibiting the application of sewage sludge to any site located in a floodplain.
• Restricting the application of sewage sludge to floodplains during periods that such land has the
potential to flood.
• Prohibiting the application of sewage sludge to land subject to ground-water upsurges or
restricting application during period(s) when the land is saturated.
• Prohibiting the application of sewage sludge when the land is flooded for irrigation.
• Requiring diking around application areas within the floodplain or nearby potentially flooded
area(s). These specifications should ensure that any diking is conducted under the supervision
and/or pursuant to the approval of the Corps of Engineers to prevent exacerbated floods
downstream.
Examples of specific permit conditions are provided below.
SAMPLE PEMMIT COMMONS FOR THE FLOODED LAM))
1. The permittee shall not apply sewage sludge to the site
or at anv time the site is in a
2. Sewage sludge shall be incorporated into the soil within
of application.
3. Sewage sludge shall not be surface applied during a pre
(hours, days) following a precipitation event.
4. Sewage sludge shall not be applied to the site when the
finches, feet) of the surface.
during the critical months of
flooded condition.
(hours, davs)
cipitation event or within
groundwater table is within
Draft—March 1993 4-45
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" 4. LAND APPLICATION - PART 503 SUBPART B
5. The permittee shall develop a map of the sewage sludge land application site that
identifies all springs and/or wetlands.
If springs or wetlands are present, the permit writer shall
establish protective buffer zones to reduce potential
adverse impacts.
6.
7.
8.
9.
Sewage sludge shall not be applied within
spring and/or wetland.
(feet, yards, other) of a
The permittee shall ensure that the site is not irrigated to a point of soil saturation or
run-off within a period of (weeks, months, other) following
the application of sewage sludge to the site.
The site floodplain area adjacent to the river shall have a maintained vegetative
buffer zone of (feet, yards, other).
The permittee shall maintain a record of precipitation events and flooding of the site.
The permit writer should only use conditions which apply
to the particular situation.
4.6.3 APPLICATION OF SEWAGE SLUDGE TO FROZEN OR SNOW-COVERED LAND
Statement of Regulations
§503.14(b) Bulk sewage sludge shall not be applied to agricultural land, forest, a public contact site, or a
reclamation site that is flooded, frozen or snow-covered so that the bulk sewage sludge enters
a wetland or other waters of the United States, as defined in 40 CFR 122.2, except as provided
in a permit issued pursuant to Section 402 or 404 of the CWA.
Purpose: To restrict application of sewage sludge to frozen or snow-covered land in those situations where the
bulk sewage sludge could enter surface waters or wetlands.
Applies to: To areas of the United States subject to freezing temperature.
Permitting Factors
Many factors must be considered to determine if bulk sewage sludge applied to frozen or snow-covered
land could enter surface waters or wetlands. When sewage sludge is properly applied to land that is not
Draft—March 1993
4-46
-------
. LAND APPLICATION - PART 503 SUBPART B
frozen, it gradually loses its water content by seepage into the ground and evaporation. However, it
retains most of its nutrients and inorganic pollutants. During precipitation, moist or dewatered sewage
sludge incorporated into the soil increases the soil's ability to absorb moisture and, therefore, reduces
runoff (Huddleston and Ronayne 1990). On the other hand, when sewage sludge is applied to frozen
land, it lies frozen on the surface of the ground with little or no chance for its moisture content to seep
into the ground. When sewage sludge freezes and thaws repeatedly, it loses most of its water content
in a short period of time during thawing (EPA 1987, Martel 1991). For this reason and because sewage
sludge will thaw before the frozen ground beneath it, there is a greater chance that the sewage sludge will
be washed off by any significant rainfall into a nearby stream, river, lake, or wetland.
The application of bulk sewage sludge on snow-covered land has certain consequences. Generally, in flat
areas with little rainfall during the thawing season, the snow melt occurs from bottom to top, leaving any
sewage sludge applied to the surface of the snow intact (assuming that the sewage sludge was applied on
the top of the last snow cover of the season). However, if the melting season is intermixed with
precipitation, sewage sludge exposed on the surface of the snow can wash away and enter any nearby
surface water or wetland.
This management practice is not a blanket prohibition of the application of bulk sewage sludge to frozen
or snow-covered land. Rather, it is intended to restrict such application only if the bulk sewage sludge
could enter surface waters or wetlands. For obvious reasons, the permit writer should not be concerned
with this management practice in areas where the ambient air temperature is rarely below freezing or
which seldom receive any significant snow precipitation. The permit writer should first determine
whether the conditions for frozen or snow-covered land exist in the area where sewage sludge is applied
(such information is available from the National Oceanic and Atmospheric Administration). If such
conditions do exist, the permit writer should then determine whether thawing snow or water runoff might
carry sewage sludge into nearby surface waters and should develop permit conditions to address this
eventuality.
The permit writer should consider the following four factors when developing permit conditions for a land
application practice that could involve frozen and snow-covered land: (1) the distance to surface waters
or wetlands, (2) the topography of the land, (3) the average precipitation in the area of the land
application site, and (4) the average length of time that land remains frozen. First, since runoff is
sometimes unavoidable, even over well-drained soils, it is reasonable to assume that the closer a land
application site is to surface waters or wetlands, the greater the chance is for sewage sludge to enter those
water bodies. As a general rule, more care must be taken to develop or determine the necessary permit
conditions where the site is close to water bodies than where a site is miles away from any surface body
of water. The permit writer will need data on the location of any surface waters or wetlands on or near
the application site. The permit application and topographic map submitted as part of the permit
application may provide this information. The U.S. Geological Survey quadrangle maps can also be used
to determine the distance from the application site to water bodies.
The second factor that plays an important role in determining the potential for runoff to surface waters
is topography. The slope of the land affects the amount and velocity of runoff. Hilly and steep terrains
(slope of 6 percent or above) produce more runoff having the capability to transport larger particles
(including sewage sludge) farther and faster (EPA 1983). Flat terrains (slope of less than 6 percent)
generate less runoff and at lower velocity, with little or no capacity to carry larger particles a long
distance (EPA 1983). Snow and ice deposited or accumulated on very hilly or steep terrain are not stable
and often move and break apart during rainfall or thawing. Of special concern is frozen or snow-covered
Draft—March 1993 4-47
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4. LAND APPLICATION - PART 503 SUBPART B
land that has a fairly steep uninterrupted slope (greater than 6 percent) leading to the edge of a body of
water and that lacks adequate controls to protect the surface water from the avalanching effect of the snow
and ice.
Third, information on average precipitation and general weather patterns is necessary to determine if the
application of sewage sludge to land should be restricted under certain conditions. Generally, heavy
snowfalls and freezing conditions followed by torrential rains of short duration produce large amounts
of runoff that will increase the potential for the sewage sludge to be washed off the land and into nearby
surface waters or wetlands. The information on average precipitation rates and weather patterns needed
to determine the occurrence and duration (months of the year) of such conditions is available for most
major cities from the following three publications of the National Oceanic and Atmospheric
Administration:
• Climatic Summary of United States
• Monthly Summary of Climatic Data, which provides basic information on total precipitation,
maximum and minimum temperatures, and relative humidity for each day of the month and for
every weather station located in a given area
• Local Qimatological Data, which provides an annual summary data for a relatively small number
of major weather stations.
Analyzing meteorological data is important to determine if there may be conditions that could produce
excessive surface runoff.
Fourth, the average length of time that land remains frozen in a 365-day period depends on the climatic
conditions and weather patterns of the area. If the land remains frozen for most of a given year and only
briefly thaws, the application of sewage sludge and its beneficial uses to land becomes highly
questionable. On the other hand, if the land stays frozen for only few days during a year or briefly
freezes at night and thaws during the day in cold seasons, there may be little or no additional risk of
sewage sludge entering nearby surface waters or wetlands.
Permit Conditions
Considering the above factors, the permit writer should use best professional judgment in determining
the potential for sewage sludge to enter surface waters or wetlands when applied to frozen or snow-
covered land. Where the risk is high, the permit writer should develop permit conditions or require the
permittee to develop and implement specific management practices to minimize this possibility. If the
permit writer determines that bulk sewage sludge has no potential to enter surface waters or wetlands
from snow-covered or frozen land application areas, additional management requirements should not be
necessary. As a general rule, there is little or no chance for sewage sludge to enter surface waters or
wetlands when the land is flat and located in a temperate zone with moderate snow and freezing
conditions and when the application site is very far from any surface waters or wetlands. As a
precautionary measure, the permit writer may want to incorporate the related management practice
verbatim from the Part 503 rule into the permit.
In locations where the land is not very flat (rolling hills with slopes of 6 to 12 percent), receives moderate
amounts of snow and ice, and is fairly distant from any surface waters or wetlands, the permit writer may
Draft-March 1993 4-48
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4. LAND APPLICATION - PART 503 SUBPART B
consider allowing the application of sewage sludge under certain conditions while the land is covered with
snow (EPA 1983). As part of such permit conditions, the permit writer may require that the sewage
sludge be applied only once to an area and at no time during or immediately before or after any rain
event or that runoff controls, such as buffer zones, berms, dikes, or any other measure necessary, be
required to prevent sewage sludge from entering into surface waters.
In the areas where land is fairly steep (slope of greater than 12 but less than 15 percent) or where there
is high probability that the sewage sludge applied on top of the frozen or snow-covered land will be
washed off by rain and into the nearby surface waters or wetlands, the application of sewage sludge
should generally be allowed only during the time when the ground is not snow-covered, frozen, or
thawing (saturated) (EPA 1983). Alternatively, the permit writer may allow limited application of sewage
sludge to such snow-covered ground as long as adequate runoff controls are employed to ensure no
sewage sludge can enter surface waters.
Lands with uninterrupted steep slopes are normally close to either permanent or intermittent bodies of
water. The application of sewage sludge to any land with a slope greater than 15 percent should be
prohibited when covered with snow (EPA 1983). In addition, the application of sewage sludge to land
that remains frozen for most of the year and only briefly thaws should be prohibited. Finally, if the
permit writer determines that additional management practices may be appropriate for sites on or near
wetlands, he or she may include conditions that limit sewage sludge application to times when lands are
not frozen or snow-covered, prohibit sewage sludge application to sites with significant wetlands, create
buffer zones around wetlands, and require diking around wetlands areas.
Examples of specific permit conditions are provided below.
1.
Sewage sludge shall not be applied to site areas with a slope of
greater.
percent or
The permittee can determine the allowable percent
slope by evaluating the surrounding land features, such
as surface waters and wetlands, in relationship to the
site. A greater slope may be allowed if the area at the
foot of the slope is also a land application site.
Draft—March 1993
4-49
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4. LAND APPLICATION - PART 503 SUBPART B
2. The permittee shall maintain protective buffer zones for a distance of
(feet, yards, other) from any surface water or wetland.
i
3. Sewage sludge shall not be applied to the site within (hours, days)
preceding a forecasted precipitation event or within (hours, days)
following a precipitation event.
4. Sewage sludge shall not be applied during the months of
\
The permit writer may wish to use the above condition
in regions with extreme frozen or snow-covered
conditions.
5. Sewage sludge shall not be applied during the months of when the
normal spring melt and runoff occurs.
6. When the site snow cover exceeds inches, the permittee shall not
apply sludge at a rate to exceed 1 which is a percent
reduction of the normal allowable rate.
4.6.4 DISTANCE TO SURFACE WATERS
Statement of Regulations
§503.14(c) Bulk sewage sludge shall not be applied to agricultural land, forest, or a reclamation site that
is 10 meters or less from waters of the United States, as defined in 40 GFR 122.2, unless
otherwise specified by the permitting authority.
Purpose: To reduce the potential for sewage sludge applied to the land to contaminate waters of the U .S. in case
of precipitation or sloppy land application practices.
Applies to: Sites that are located adjacent to water bodies. Ephemeral or intermittent flowing streams, as well
as rivers or lakes, should be considered when identifying nearby water bodies.
Permitting Factors
While a properly constructed and maintained 10-meter setback provides adequate protection to water
bodies in most cases, under certain conditions a wider buffer zone may be necessary. The major factors
in determining the appropriate size of the buffer zone or setback are: (1) slope of the land, (2) type of
surface water being protected, (3) condition of the ground surface of the buffer, (4) rate of sewage sludge
application, (5) water content of the sewage sludge, and (6) soil permeability.
Draft-March 1993 4-50
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4. LAND APPLICATION - PART 503 SUBPART B
Generally, steeper slopes produce more runoff with faster velocities thereby increasing the potential for
surface water contamination. As a general rule, the 10-meter setback should be adequate if the slope is
6 percent or less. Land with slopes greater than 6 percent but less than 12 percent may require wider
buffer zones, other soil conservation methods, and/or extensive runoff controls. The application of
sewage sludge to lands with slopes greater than 12 percent but less than 15 percent requires much wider
buffer zones, in addition to extensive runoff controls. The application of sewage sludge to lands located
near surface waters with slopes greater than IS percent should be prohibited except where the soil has
very good permeability and the slope length is short'and is only a small part of the entire application site
(EPA 1983, Huddleston and Ronayne 1990).
The type of surface water to be protected from sewage sludge contamination is the second major factor
in determining if a wider buffer zone is necessary. For example, a setback wider than 10 meters may
be necessary to protect a body of water used as a source of drinking water or a trout stream extremely
sensitive to paniculate matter and pollutants.
The condition of the ground surface of the buffer is the third important factor in determining the size of
the buffer zone. A buffer zone that is bare and has very low permeability provides almost no filtering,
while a surface with thick vegetation provides filtration and slows down the runoff.
Liquid sewage sludge is more likely to be washed into the nearby waters than is dried or dewatered
sewage sludge. In addition, if large quantities of sewage sludge are applied on slope greater than 6
percent, it may be necessary for the permit writer to require injection of liquid sewage sludge into the
soil or incorporation of dried or dewatered sewage sludge into the soil as soon as practicable after
application, in addition to requiring other runoff controls and a setback wider than 10 meters. However,
if the land is fairly steep (12 to 15 percent slope), the 10-meter setback is generally adequate for small
quantities of liquid sewage sludge or dried or dewatered sewage sludge applied to the land as long as the
sludge is immediately incorporated into the soil (EPA 1983, Huddleston and Ronayne 1990).
Permit Conditions
If the permit writer finds that adequate management practices are not in' place to prevent sewage sludge
from entering U.S. waters, additional management practices may be appropriate. Such practices may
include developing bufferzones greater than 10 meters and marking the boundaries of these zones using
flags, fences, or lines. Where the permit writer determines that bulk sewage sludge has no potential to
enter waters of the United States, he/she should incorporate the 10-meter setback with no additional
special conditions stipulated.
The permit writer may need to identify and specify, in the permit, the line from which the buffer zone
distance must be measured. Generally, the setback should be measured from the 5-year high water mark
of streams, rivers, creeks, and natural ponds and lakes. The setback from man-made lakes and ponds
must be measured from the highest designed water levels, which are normally shown on the maps of such
water bodies (maps and water level information can be obtained by contacting local authorities. The
location of the 5-year high water mark of water bodies is often identified on topographical maps of the
area prepared by the U.S. Geological Survey, which can be obtained by contacting that agency or the
Army Corps of Engineers. To eliminate any confusion over the location of the 5-year high water mark
as the reference point for measuring the setback, the permit writer may consider calculating a distance
to the center of the stream, river, or creek that includes the distance of the high water mark to the center
of the water body plus the required setback. In the areas where streams, rivers, or creeks have a history
Draft-March 1993 4-51
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4. LAND APPLICATION - PART 503 SUBPART B
of changing their course and where the center of the stream may accordingly shift, the permit writer may
consider incorporating both the distance to the center of the water body and the distance to the 5-year
high water mark.
£ ••
;• . . . . , . . <. i . , . .,, s
SPECIFIC FEKMIT CONDITIONS FUM THE UiSTANUS TO
SURFACE WA'JTEKS MANAGEMENT ftJCACTTCE
1. A 10-meter buffer zone shall be maintained between the surface waters and the land
application site. The permittee shall establish a vegetative cover on the buffer zone
prior to the land application of sewage sludge to the site and shall maintain that
cover during the lifetime of the site.
The permit writer may wish to specify an acceptable
cover.
2. Land application sites with slopes which exceed percent must have
an increased buffer zone width of (feet, yards, other).
3. On sites which are adjacent to surface waters which are designated as
the buffer zone shall be increased to a width of (feet, yards, other).
'. J i>
The permit writer should either list the name of the
surface waters or specify beneficial use designations
(e.g., drinking water source, scenic river, or cold
water fishery). Also, he/she should determine an
appropriate buffer zone width.
4. Sewage sludge shall be injected or incorporated into the soil within
(hours, days) of application.
5. Sewage sludge shall not be applied at,a total percent solids which is less than
(on sites with slopes that exceed percent).
The permit writer should evaluate the slope,
precipitation, runoff rates, vegetative cover, and
buffers to identify an acceptable percent solids.
Draft-March 1993
4-52
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4. LAND APPLICATION - PART 503 SUBPART B
6.
The permittee shall conduct water quality sampling of the adjacent surface waters
for the parameters of and at a frequency of
at designated locations both upstream and downstream from the site.
The permit writer should select parameters known to
be in the specific sewage sludge. The frequency of
sampling should be sufficient to identify contamination
of the surface waters. The sampling frequency may
be at scheduled times or related to precipitation events.
The permit writer may establish sample point
locations.
7. The permitting authority shall be notified within
(hours, days) of
any known contamination of surface waters from sewage sludge applied to the site.
The permittee shall cease the application of sewage sludge to the site from the time
the contamination is known until notified by the permitting authority that the
application may continue.
4.6.5 AGRONOMIC APPLICATION RATE
Statement of Regulations
§503.14(d), Bulk sewage sludge shall be applied to agricultural land, forest, or a public contact site, or a
reclamation site at a whole sludge application rate that is equal to or less than the agronomic
rate for the bulk sewage sludge unless, in the case of. a reclamation site, otherwise specified by
the permitting authority.
Purpose: To avoid nitrate contamination of ground water.
Applies to: Bulk sewage sludge applied to agricultural land, forest, a public contact site, or a reclamation site.
In the case where sewage sludge is disposed on a reclamation site, the permit writer may allow a larger amount
of sewage sludge (greater than the agronomic rate) to be applied as long as adequate conditions are included in the
permit to protect the ground water from nitrogen contamination.
Sewage sludges typically contain appreciable amounts of important plant nutrients (nitrogen, phosphorus,
and potassium), although the quantities of nutrients available from sewage sludge are normally lower than
amounts from most commercial fertilizers (Huddleston and Ronayne 1990, EPA 1976, EPA 1978).
Nitrogen and phosphorus are the most prevalent nutrients found in sewage sludge, and are the nutrients
most needed by plants.
Draft—March 1993
4-53
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4. LAND APPLICATION - PART 503 SUBPART B
Permitting Factors
Nitrate Contamination
Nitrogen occurs in soil in organic and inorganic forms. The inorganic forms of nitrogen primarily
include nitrate-nitrogen and ammonium-nitrogen. Because of their solubility, nitrate and ammonium
represent a short-term, quick-release fertilizer. Nitrate, in particular, is frequently found in solution and
is highly mobile in soil until it is immobilized by microorganisms or assimilated by plants. If applied
in amounts exceeding plant uptake capacity, nitrate has the greatest potential to leach below the root zone
and pose serious threats to ground-water quality. For example, in the 1988 National Water Quality
Inventory Report to Congress, nitrates were identified as the most common contaminant found in ground
water (EPA 1990). .
9 '
Organic nitrogen is a long-term, slow-release fertilizer source, as it must be transformed through a series
of steps before it can be used by plants. In the first step, organic nitrogen undergoes mineralization (or
ammonification), a process whereby microorganisms convert organic nitrogen to inorganic ammonium-
nitrogen. The other key transformation is nitrification, or the microbial transformation of the relatively
immobile ammonium-nitrogen form into nitrate, which is readily leached, taken up by plants or
denitrified. Only after these conversions is the nitrogen in sewage sludge readily available to plants.
Recognizing that sewage sludge, if applied at excessive rates could deteriorate ground water through
nitrate leaching, Part 503 requires that the land application of bulk sewage sludge be limited to the
agronomic rate. The agronomic rate is the whole sludge application rate (dry weight basis) designed: (1)
to provide the amount of nitrogen needed by the crop or vegetation grown on the land and (2) to
minimize the amount of nitrogen in the sewage sludge that passes below the root zone of the crop or
vegetation grown on the land to the ground water. EPA requires that the agronomic rate be used when
bulk sewage sludge is applied to agricultural or forest land, or a public contact site. If bulk sewage
sludge is applied to a reclamation site, the permit writer may allow exceedances of the agronomic rate
as long as adequate conditions are included in the permit to protect the ground water from nitrogen
contamination.
The agronomic rate is the ratio of the sewage sludge nitrogen used for the crop (dry weight per unit area)
divided by the available nitrogen in the sludge (dry weight of nitrogen per dry weight of sludge):
Sludge N needed for crop
Available N in sludge
Many steps go into determining the sludge nitrogen needed for the crop. These steps are fully described
in the worksheets presented in Figure 4-6. In summary, the sludge nitrogen required represents the
remaining fraction of nitrogen needed after all other possible sources of nitrogen are accounted for and
subtracted from the total fertilizer-nitrogen recommended for the crop (i.e., residual nitrogen in soil,
available organic nitrogen from previous sludge applications, available residual nitrogen from previous
crops and/or vegetation, nitrogen from irrigation water, and nitrogen from supplemental fertilizers).
Draft-March 1993 4-54
-------
4. LAND APPLICATION - PART 503 SUBPART B
Worksheet 1. Procedures to Calculate the Agronomic Loading Rate
Key to Symbols and Abbreviations
NH4* - N = Ammonium nitrogen content of the sewage sludge obtained from analytical testing
of the sewage sludge, kg/ml (dry weight basis).
Kv = Volatilization factor estimating ammonium nitrogen remaining after atmospheric
losses.
Org-N = Organic nitrogen content of the sewage sludge obtained from analytical testing,
kg/ml (dry weight basis).
FO-I = Mineralization rate for the sewage sludge during the first year of application, in
percent of organic nitrogen expressed as a fraction (i.e., 20% = 0.2).
1. Total available nitrogen from sewage sludge.
a. Ammonium nitrogen. kg/mt
Calculated with the following formula: AW<* - N (kg/ml) x Kv (Kv obtained from Table
W-l)
b. Mineralized organic nitrogen for first year of application;,. i ' • kg/mt
Calculated with the following formula: Org-N x Fa, (Fa, obtained from'table W-2)
c. Nitrate nitrogen. kg/mt
d. Total kg/mt
2. Available nitrogen from previous sewage sludge applications. kg/ha
(From Worksheet 2) . .
3. Nitrogen supplied from other sources:
a. Nitrogen from supplemental fertilizers kg/ha
b. Nitrogen from irrigation water . kg/ha
c. Nitrogen from previous crops and/or vegetation (e.g., legumes) kg/ha
Obtain information from agricultural extension agents or other agromony professionals
d. Other (specify): kg/ha
e. Total. kg/ha
4. Total nitrogen available from existing sources. kg/ha
Add 2 and 3e
5. Total nitrogen requirement of crop. . , kg/ha
6. Supplemental nitrogen needed from sewage sludge. kg/ha
Subtract 4 from 5
7. Agronomic loading rate. mt/ha
Divide 6 by I
FIGURE 4-6 WORKSHEETS FOR DETERMINING AGRONOMIC RATE
Draft-March 1993 4-55
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4. LAND APPLICATION - PART 503 SUBPART B
Worksheet 2. Calculating Mineralized Organic Nitrogen
The organic nitrogen in sewage sludge continues to decompose and release mineral nitrogen through the mineralization process
for several years following its initial application. This residual nitrogen from the previously applied sludge must be accounted
for as part of the overall nutrient budget when determining the agronomic rate for sewage sludge. The following procedures
calculate mineralized organic nitrogen. These calculations must be done for each yearly sewage sludge application (see example
calculations).
a.
b.
Number of previous years sewage sludge was applied
Total mineralized organic nitrogen from the sewage surface sludge
Use value for organic nitrogen remaining (column e) that represents the greatest number of
years since the first application (i.e., the smallest number in column d).
year(s)
kg/ha
a.
Year1
0-1 (first application)
1-2
2-3
3-4
4-5
b.
Starting1 (kg/ha);
c.5
Mineralization Rate
(TableW-2)
d.4
Mineralized Org-N
(kg/ha)
e.
Org-N Remaining1
(kg/ha)
'Number of years after initial application.
2In the first year, this equals the amount of N initially applied. In subsequent years, it represents the amount of
org-N remaining from the previous year (i.e., column e).
*The org-N content of the initially applied sewage sludge continues to be mineralized, at decreasing rates, for
years after initial application. See Table W-l for mineralization values.
'Multiply column b and column c.
'Subtract column d from column b.
Example
Assume sewage sludge was applied to the site at a rate of 5 mt/ha with a 3 % org-N content (dry weight basis) in
1986. The following year, 1987, 3 mt/ha of sewage sludge (same org-N contents a 1986) was applied to the
same site. No sewage sludge was applied to the site after 1987. It is now 1990 and you want to calculate the
available nitrogen from previous sludge applications.
In 1986, the org-N in the sludge applied = (0.03) (5 mt/ha) (1,000 kg/mt) = 150 kg/ha.
In 1987, the org-N in the sludge applied = (0.03) (3 mt/ha) (1,000 kg/mt) = 90 kg/ha.
Calculate the residual nitrogen from 1986 and 1987 in the following manner (assume anaerobically digested
sludge):
Year*
Starting N
(kg/ha)
Mineralization Rale
(TH.loW.2y
: Mineralized Org-N
: (kg/ha)
Org-N Remaining
(kg/ha)
1986 Sewage Sludge
0-1 (first application- 1986)
1-2 (1987)
2-3 (1988)
3-4 (1989)
4-5 (1990)
ISO
120
108
102.60
9952
0.2
0.1
0.05
0.03
0.03
30
12
5.40
3.08
2.99
120
108
102.60
99.52
96.53
1987 Sewage Sludge
0-1 (first application- 1987)
1-2 (1988)
2-3 (1989)
3-4 (1990)
90
72
64.8
61.56
0.2
0.1
0.05
0.03
18
7.2
3.24
1.85
72
64.80
61.56
59.71
To determine the total organic nitrogen remaining from the sewage sludge applied in 1986 and 1987, add the last
value in the last column of the table for the 1986 sewage sludge to the last value in the last column of the table
for the 1987 sewage sludge (i.e., 96.53 + 59.71 = 156.24 kg/ha).
FIGURE 4-6 WORKSHEETS FOR DETERMINING AGRONOMIC RATE (Continued)
Draft-March 1993
4-56
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4. LAND APPLICATION - PART 503 SUBPART B
FIGU
Table W-l - Volatilization Factors (Kv)
If Sewage Sludge Is: Factor Kv Is:
Liquid and surface applied .50
Liquid and injected into the soil* 1 .0
Dewatered and applied in any manner ' 1.0
Table W-2 - Mineralization Rate*
Time after
sludge
application
(Year)
0-1
1-2
2-3
3-4
4-5
5-6
6-7
7-8
8-9
9-10
% of Org-N
Mineralized
from Stabilized
Primary and
Waste Activated
Sewage :S|udges
40
20
10
5
3
3
3
3
3
3
% of Org-N
Mineralized
from Aerobically
Digested Sewage
Sludge
30
15
8
4 -
3
3
3
3
3
3
% of Org-N
Mineralized
from
Anaerobically
Digested Sewage
Sludge
20
10
5
3
3
3
3
3
3
3
% of Org-N
Mineralized
from
Composted
Sewage Sludge
10
5
3
3
3
3
3
3
3
3
* Percentage of Org-N present mineralized during the time interval shown.
TIE 4-6 WORKSHEETS FOR DETERMINING AGRONOMIC RATE (Continued)
Draft-March 1993
4-57
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4. LAND APPLICATION - PART 503 SUBPART B
The quantity of nitrogen available in the sewage
sludge (dry weight basis) should be determined
from the analytical results of sewage sludge
samples collected prior to land application. The
calculations to determine the quantity of nitrogen
available must include an assessment of the
available ammonium-nitrogen, nitrate-nitrogen,
and mineralized organic nitrogen for the first year
of application (see attached worksheets). Such
information must be carefully examined to ensure
that the data represent the final sewage sludge that
is applied to the land and not some intermediate
sewage sludge product. For example, data based
on samples collected before dewatering are not
representative of the nitrogen content of the
sewage sludge that is finally applied to the land.
The dewatering of sewage sludge removes a large
portion of the liquid sewage sludge, which holds
the majority of the inorganic nitrate- and
ammonium-nitrogen.
All nitrogen concentrations must be reported
based on dry weights. The reported data must
also be based on a sound sampling strategy and
EPA-approved analytical techniques.
Many factors can affect the likelihood of nitrate
leaching from land-applied sewage sludge to
ground water. These range from physical factors,
such as soil type and climatic conditions, to management techniques used during the application of sewage
sludge. Table 4-6 describes the major physical factors influencing the transport of land-applied nitrogen
to ground water. The table does not summarize the management considerations, because these are
described below under nutrient management planning. The permit writer will want to fully consider all
of these factors when evaluating the suitability of a location for the land application of sewage sludge.
Depending on the site characteristics of a proposed location, the permit writer may want to include permit
conditions beyond the use of agronomic rate.
Although EPA chose to focus on nitrate contamination of ground-water when selecting the agronomic rate
as a requirement in Subpart B, the nutrients from sewage sludge can also degrade surface water quality.
Nutrient overenrichment of surface water bodies is a common problem. EPA's National Water Quality
Inventory showed that nutrients were the leading cause of water quality declines in lakes, reservoirs, and
estuaries and the second leading pollutant in rivers and streams (EPA 1990). Nitrogen and phosphorus
pose serious threats to surface water quality. This is especially true of phosphorus, because phosphate
ions have low solubility in most soils, so leaching losses are rare. Instead, phosphate availability for
leaching decreases exponentially over time through precipitation reactions, adsorption on mineral surfaces,
and retention by soil constituents. As a result, most of the off-site transport of phosphorus is associated
with sediment erosion and becomes a surface water quality problem. Many of the factors that affect the
off-site transport of nutrients to surface water are described in Table 4-7. This table focuses on physical
The nitrogen content of sewage sludge is
usually reported as inorganic ammonium-
nitrogen, inorganic nitrate-nitrogen, and either
the total Kjeldahl nitrogen (TKN) or the total
nitrogen. TKN represents the organic nitrogen
and inorganic ammonium-nitrogen only. Total
nitrogen, on the other hand, represents organic
nitrogen and inorganic ammonium-nitrogen as
well as nitrate-nitrogen. Since it is not possible
to analytically test for total organic nitrogen, an
estimate of the total amount of organic nitrogen
in the sludge can be made based on the
analytical results for TKN or total nitrogen.
To determine the organic nitrogen, subtract the
ammonium-nitrogen from the TKN, or subtract
the sum of ammonium plus nitrate-nitrogen
from the total nitrogen. The nutrient contents
of sewage sludge are normally expressed either
as percent of dry weight or as mg/kg dry
weight. Specifically, the estimates may be
made as follows:
Organic N = TKN - ammonium, or
Organic N = Total N - (ammonium +
nitrate)
Draft—March 1993
4-58
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4. LAND APPLICATION - PART 503 SUBPART B
factors, although management techniques used in the application of sewage sludge can also affect off-site
transport. These considerations are described more fully in the next sections, as potential permit
conditions.
Nutrient Management Planning
Nutrient management represents the most effective way to reduce offsite nitrogen transport, as it
incorporates principles that lower nitrogen losses to all environmental media - surface water, ground
water, air, and soil. Simply put, the most effective way to reduce the loss of fertilizer-derived nitrate
to ground water is to reduce the quantity of nitrogen applied. Comprehensive nutrient management
planning incorporates a variety of measures that minimize the edge-of-field delivery of nutrients and
minimize the leaching of nutrients from the root zone by eliminating the application of excess nutrients,
improving the timing of nutrient application, and using agronomic crop production technology to increase
nutrient use efficiency. Many localities and States require nutrient management planning for an array of
land use types, especially agricultural lands. The principal components of nutrient management planning
are summarized in Table 4-8. Additional sources of information on nutrient management planning
include county extension agents, soil conservation service district conservationists, and agricultural
consultants. Some of the recommendations included in Table 4-8, especially these associated with the
consideration of environmentally high risk areas, need an assessment of site-specific conditions (e.g.,
depth to ground water and soil type). It is essential to contact local agricultural officials to determine
how to incorporate site-specific conditions into the overall nutrient management plan.
Although nutrient management planning is not required by Part 503, the permit writer may want to
include nutrient management planning as a permit condition for certain locations because it represents the
best way to protect water resources. Nutrient management planning is particularly important when
sewage sludge is land applied to high risk areas, such as:
• Lands near surface water or wetlands
• Soils with high leaching indices
.• Irrigated land in humid regions
• Highly erodible soils
• Shallow aquifers
• Karst topography containing sink holes and shallow soils over fractured bedrock.
In some instances, it is better to avoid the application of sewage sludge altogether. Such locations
include:
• Areas having a shallow depth to ground water, or seasonal high water table, especially if soils
are coarse-textured.
Draft—March 1993 4-59
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4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-6 MAJOR FACTORS INFLUENCING TRANSPORT OF LAND-APPLIED
NITROGEN TO GROUND WATER
Factor
Climate
Precipitation
Evapotranspiration
Temperature
Soil Properties
Water Content
Bulk Density
Hydraulic Conductivity
Texture
Soil Structure
Depth to Ground Water
Impact on Ground Water
Precipitation and/or irrigation has a dominant effect on the leaching of nitrate
to ground water. The extent of nitrate leaching is directly related to the
amount of water infiltrating the soil. Nitrate is most likely to leach below the
root zone when soil is at or near saturation (enables maximum hydraulic
conductivity). Heavy precipitation immediately after application also
increases nitrate losses to ground water, especially if soil is permeable.
Evapotranspiration rates in excess of precipitation and/or irrigation will
reduce the potential for nitrate leaching as there is usually insufficient water
to transport nitrate past the root zone. Conversely, if evapotranspiration rates
are low, water and dissolved materials (e.g., nitrates) can move downward
below the root zone.
Temperature affects all nitrogen transformation processes (e.g,
immobilization, mineralization, nitrification, and denitrification). However,
temperature impacts on the movement of water and solutes in soils are poorly
understood and are likely to be only a small factor in nitrate leaching.
Soluble nitrate is transported by soil water. Increased soil water levels
increase the movement of water and nitrate within and below the root zone.
Decreasing porosity or increasing bulk density (the two are inversely related)
decreases the leaching potential of nitrogen by decreasing the cross-sectional
area available for mass flow and increasing path lengths of water flow.
Soils with high hydraulic conductivity in relation to the initial infiltration of
water (e.g., sands) have a greater potential for the mass transport of water
and dissolved solutes below the root zone.
Particle size distribution affects water retention, porosity, hydraulic
conductivity, and adsorption capability. In general, coarser soils (e.g., sands)
have greater capacity for mass transport and fewer opportunities for
adsorption of nitrogen. Finer soils (e.g., silts and clays) have a greater
capacity for adsorption, which reduces the leaching potential of nitrate. Soils
with extremely high or extremely low permeability should be avoided.
Highly permeable soils are too susceptible to leaching, while soils with low
permeability may have internal drainage problems that restrict sludge
decomposition.
Highly structured soils have preferential pathways allowing the mass transport
of water and solutes below the root zone.
Shallow ground water has a greater potential for contamination with nitrates
because the distance and resulting travel time for materials leached below the
root zone is lessened.
Source: Adapted from Spectrum Research, Inc.
Draft-March 1993
4-60
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4. LAND APPLICATION - PART 503 SUBPART B
TABLE 4-7 MAJOR FACTORS INFLUENCING TRANSPORT OF LAND-APPLIED
NUTRIENTS TO SURFACE WATER
Factor
Impact on Surface Water
Nitrogen
Phosphorus
Climate
Rainfall/run-off
Highest concentration of N in run-off
occurs with first significant
rainfall/run-off event after
application. Because of high
solubility/mobility of N, the
concentration and availability of N at
the soil surface dissipates with time.
Highest concentration and loss of P in
run-off occurs with first significant
rainfall/run-off event after application.
The availability of soluble P in run-off
dissipates rapidly with time, because P
has a propensity to adsorb to soil
particles. Since mass loss of P is
related to sediment transport, peak run-
off loading of P corresponds to peak
sediment loads.
Rainfall Intensity
Run-off occurs when precipitation
exceeds infiltration. As rainfall
intensity increases, infiltration
decreases and run-off rate increases.
Increased amount and velocity of
run-off increases the energy available
for nitrogen extraction and transport.
Run-off occurs when precipitation
exceeds infiltration. As rainfall
intensity increases, infiltration decreases
and run-off rate increases. Increased
amount and velocity of run-off increases
the energy available for sediment
transport, and therefore, phosphorous
loss.
Rainfall
Duration/Amount
As rainfall duration/amount increase,
conditions for subsurface leaching of
nitrogen also increase. Nitrogen may
leach below the zone of surface run-
off leach extraction and transport,
thus decreasing nitrogen
concentration in run-off.
Increased rainfall duration/amount may
affect depth of surface interaction with
soil-adsorbed phosphorus. Since
phosphorus is much less soluble and
mobile than nitrogen, the concentration
of phosphorus in run-off is altered less
than that of nitrogen.
Time to Run-off After
Application
Nitrogen concentration in run-off and
time to run-off are inversely related;
run-off concentrations of nitrogen
increase as time to run-off decreases.
As the time from application to run-
off event increases, a greater
proportion of the nitrogen is
immobilized or leached below the
zone of surface run-off extraction.
Phosphorus concentration in run-off and
time to run-off are inversely related;
run-off concentrations of phosphorus
increase as time to run-off decreases.
As the time from application to run-off
event increases, a greater proportion of
the phosphorus is immobilized or
adsorbed/precipitated on soil surfaces
and not available in soluble form for
run-off.
Draft—March 1993
4-61
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-7 MAJOR FACTORS INFLUENCING TRANSPORT OF LAND-APPLIED
NUTRIENTS TO SURFACE WATER (Continued)
Factor
Impact on Surface Water
Nitrogen
Phosphorus
Soil
Soil Texture
Soil texture affects infiltration rates,
soil credibility, particle transport
potential. Run-off typically increases
on fine-grained soils, while
infiltration increases on coarse-
grained soils (e.g., sand). Time to
run-off is longer on coarse-grained
soils, possibly reducing initial run-off
losses of soluble nitrogen.
Conversely, time to run-off typically
decreases with fine-grained soils.
Run-off velocity also increases with
fine-grained soils.
Soil texture affects infiltration rates, soil
erodibility, particle transport potential.
Soil texture also affects phosphorus
adsorption sites. Run-off typically
increases on fine-grained soils, while
infiltration increases on coarse-grained
soils (e.g., sand). Time to run-off is
longer on coarse-grained soils, possibly
reducing initial run-off losses of soluble
phosphorus.
Surface
Crusting/Compaction
Decreases infiltration rates, reduces
time to run-off, and increases initial
concentrations of soluble-nitrogen.
Decreases infiltration rates, reduces
time to run-off, and increases initial
concentrations of soluble-phosphorus.
Water Content
As the water content of soil
increases, especially if soils are wet
at the time of application, the run-off
potential may be increased, time to
run-off may be reduced, and the
amount of subsurface leaching
reduced.
As the water content of soil increases,
especially if soils are wet at the time of
application, the run-off potential may be
increased, time to run-off may be
reduced.
Slope
Increasing slope may increase run-off
rate and soil detachment/transport.
In general, slopes of less than 6
percent are considered suitable for
land application; less than 4 percent
is ideal. Steeper slopes can be used
if careful crop and soil management
is employed.
Increasing slope may increase run-off .
rate and soil detachment/transport. In
general, slopes of less than 6 percent
are considered suitable for land
application; less than 4 percent is ideal.
Steeper slopes can be used if careful
crop and soil management is employed.
Degree of Aggregation
and Stability
Affects infiltration rates, crusting
potential, effective depth for
entrainment, sediment transport
potential, and adsorbed nitrogen
enrichment in sediments.
Affects infiltration rates, crusting
potential, effective depth for
entrainment, sediment transport
potential, and adsorbed phosphorus
enrichment in sediments.
Source: Adapted from Spectrum Research, Inc.
Draft—March 1993
4-62
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-8 PRINCIPAL COMPONENTS OF NUTRIENT MANAGEMENT PLANNING
Application Rate: Avoid applying excess fertilizer by using rates recommended as a result of soil testing,
consideration of all possible available sources of nitrogen (e.g., nitrogen available in the soil, nitrogen
contributions to the soil from legumes grown in rotation or other residual crops, carryover nitrogen from
previous years of fertilization, other significant sources of nutrients (e.g., irrigation water, commercial
fertilizers)), and an understanding of the growth requirements of the crop. Use the minimum amount of
fertilizer necessary to meet the plant needs. Ensure that crop yield estimates are realistic, based on producer-
documented yield history and other relevant information. Appropriate methods include averaging the three
highest yields in five consecutive crop years for the planning site, or other methods based upon criteria used
in developing a State Land Grant University's nutrient recommendations. In lieu of producer yield histories,
university recommendations based on interpretation of soils data may be used.
Tuning of Application: Apply sludge and fertilizer as close as possible to the time required for maximum
plant uptake. Avoid fall and winter applications for spring-planted crops. Time application to minimize
leaching losses from rainfall or irrigation (i.e., apply after these events). Also time application to avoid
periods of heavy rainfall and critical erosion periods. Use seasonally split nitrogen applications on most soils
to improve efficiency of nitrogen use and reduce total site loading. Avoid application to frozen soils.
Appropriate Method of Nutrient Application. Use application methods that promote efficient nutrient use.
Incorporate or inject sludge beneath the soil surface when possible. Avoid application methods that contribute
to soil erosion.
Ensure Application Equipment (e.g., sprayer, spreader) Works Properly: Calibrate equipment frequently.
Calibrate on similar terrain and at speeds similar to actual spraying condition. Check distribution pattern of
sprayer/spreader. Ensure uniform distribution.
Practice Water Conservation: Avoid excess irrigation. Use sensors to determine the need and timing of
irrigation.
Keep Detailed Records: Record information on nutrient management procedures. Include such information
as brand used, formulation, date and time of application, amount of application, climatic conditions during
application, irrigation schedule, and annual quantities of fertilizers used.
Leave Vegetated Buffers Around Water Bodies: Maintain and repair unfertilized vegetative buffer strips
around water bodies.
Use Cover Crops: Use small grain cover crops to scavenge nutrients remaining in the soil after harvest of
the principal crop, particularly on highly leachable soils.
Control Phosphorus Losses: Minimize loss of phosphorous from fields through a combination of erosion and
sediment controls.
Draft-March 1993 4-63
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a
4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
° Soils with very high (sands) or very low (clay) permeability, and poorly drained soils.
0 Steep slopes. If impossible to avoid application, use erosion and sediment controls.
° Areas where the soil cover is limited (e.g., less than approximately 4 feet thick in the humid east
coast) over bedrock, sink holes, and water table.
and Sediment Control
Nutrient management planning, as described in the previous section, is the most effective way of reducing
the quantity of land-applied nutrients available to contaminate surface and ground water. In addition to
nutrient management planning to reduce the quantity of nutrients applied and increase nutrient uptake
efficiency, sediment-bound nutrients (e.g, orthophosphate) should be managed using erosion and sediment
controls. Although use of these controls is not specifically required by Part 503, the permit writer may
want to add some or all of them as conditions in the permit. It is especially important to require sediment
and erosion control on locations close to environmentally- sensitive resources and areas with steep slopes
or highly erodible soils.
Nutrient runoff from the land is a function of the nutrient quantity and concentration in its carrier (water
or sediment), the mass of the carrier, and the ease at which delivery to receiving waters can occur.
Nutrient management planning serves to reduce nutrient quantities and concentrations. A variety of best
management practices (BMPs) to control erosion and sediment can be used to reduce the carrier mass and
reduce pollutant delivery. Table 4-9 briefly defines these BMPs. The choice of BMPs and their
effectiveness depends on complex site-specific factors such as soil type, slope, local climatic conditions,
crop type and farming technique, and farmer diligence. It is impossible to describe in this document all
of the considerations that must be taken into account when identifying BMPs to be used on a particular
site. The permit writer should contact local agricultural professionals, especially the Soil Conservation
Service, to determine which BMPs are best suited for that location. Most State and local agricultural
agencies have done extensive research on the effectiveness and suitability of BMPs for their jurisdictions.
For example, the USDA - Soil Conservation Service sponsors a series of Field Office Technical Guides
(FOTGs) that contain a variety of information on soil conservation practices and resource management,
including standards and specifications for BMPs. These guides are prepared for specific geographic
areas.
When evaluating BMPs to reduce erosion and sediment run-off, it is critical to recognize that some
techniques, depending on site-specific conditions, can actually have the potential to increase nitrogen
leaching by reducing and/or storing the carrier mass. Techniques that reduce the carrier mass (e.g.,
conservation tillage, terracing) may increase the concentration of nutrients, while techniques to contain
sediments (e.g., sediment detention basins) may increase the amount of time available for leaching. The
potential for enhanced ground-water contamination from these practices is extremely site-specific. Again,
permit writers should contact local agricultural agencies for help in assessing BMP applications. Table
4-10 provides general information on the effectiveness of certain BMPs on protecting ground and surface
water bodies. It is interesting to note that only nutrient management planning and the use of cover crops
definitively protect both surface and ground water resources.
Draft—March 1993 4-64
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-9 BMPs SUITABLE FOR EROSION AND SEDIMENT CONTROL
BMP Type
Reduces Carrier Mass
Conservation Tillage
Contouring
Terraces
Cover Crops
Vegetative Filter Strips
Reduces Pollutant Delivery
Terraces
Vegetative Filter Strips
Sediment Detention
Basins and Ponds
Infiltration Trenches
::''.,...; Description
Any tillage or planting system that leaves at least 30 percent of the soil
surface covered with crop residue after planting. Primary techniques include
no-till, ridge-till, and other minimum till practices. Conservation tillage
decreases soil erosion and surface runoff and increases infiltration.
A system where agricultural field preparation and tilling is conducted in the
. direction of the land's contour instead of cutting across contour lines.
Contouring is effective at reducing soil loss associated with agricultural
activities. Contouring is most effective on permeable soils with mild slopes
If heavy, intense rainfalls occur, contouring loses effectiveness because the
furrows may overtop and fail.
Terraces are constructed, flattened areas suitable for planting, that cut across
the natural slope of a site. By reducing slope length, terraces reduce runoff
velocity and can reduce soil loss upwards of 90 percent. Terraces serve to
store water temporarily, allowing sediment to deposit and water to infiltrate.
If terraces are overtopped by intense precipitation, severe erosion can occur.
The planting of crops (e.g., grains or grasses) to reduce the amount of time
an area is left fallow. Cover crops decrease nutrient losses to ground water
through plant uptake of nutrients. Legume cover crops will tie up soil
nitrogen during the winter and will provide nitrogen for subsequent crops.
The residual nitrogen from legumes must be considered when determining
nutrient requirements for future crops.
. Bands of natural or planted vegetation situated between pollutant source
areas and receiving waters. Filter strips remove soil particles and soil-bound
nutrients from runoff as it passes through. Filter strips work best in flatter
areas, as they can lose their sediment-trapping efficiencies if inundated with
high volumes of fast moving runoff. The needed widths for vegetative filter
strips will vary depending on site specific conditions.
See above description.
See above description.
Large structures designed to reduce peak run-off rates and to remove a
certain percentage of sediment and sediment-bound nutrients in run-off.
There are three basic types of detention ponds: dry ponds, wet ponds, and
extended wet ponds. Each type operates slightly differently and the
appropriate one should be selected based on site-specific conditions and local
requirements.
Subsurface trenches typically filled with coarse material that serves to slow
and store run-off so that it can infiltrate into the soil.
Source: Adapted from Dillaha 1990.
Draft-March 1993
4-65
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-10 EFFECTS OF CERTAIN BMPs ON SURFACE AND GROUND WATER
BMP-Type
Conservation Tillage
Contouring
Terraces
Cover Crops
Vegetative Filter Strips
Sediment Detention Basins and Ponds
Infiltration Trenches
Nutrient Management
Effect on
Surface Water
Positive (P)
P
P
P
P
P
P
P
Ground Water
No Effect (NE) or Adverse (A)
NE/A
NE/A
P
NE/A
A
NE/A
P
Source: Adapted from Dillaha 1990; Logan 1990; and Camacho 1990.
Permit Conditions
The permit writer can include the agronomic rate management practice in a permit in one of two ways.
In the first, the permit writer could calculate the whole sludge application rate for a specific land
application site that is equal to or less than the agronomic rate and could include this value in the permit..
This approach would require the permit writer to have information on crop nitrogen requirements,
residual nitrogen, and sludge nitrogen data. An easier approach may be to require the permittee to
determine the agronomic rate for his/her site and to calculate the appropriate whole sludge application
rate. With this approach, permit writer would need to specify how frequently these calculations should
be done (e.g., annually or for each sewage sludge application).
Although Part 503 only dictates application of sewage sludge at or below the agronomic rate, permit
writers may want to incorporate other nutrient management principles as permit conditions. Nutrient
management planning is the best way to protect water resources, regardless of land use; it is especially
necessary in areas with a high potential for transport (see Tables 4-6 and 4-7), and in environmentally-
sensitive areas. Comprehensive nutrient management planning is the best overall technique to protect
water resources, and should be supplemented with the use of best management practices (BMPs) to
control erosion and runoff from land application sites. Examples of specific permit conditions,
incorporating nutrient management principles and sediment and erosion control, are provided below.
Draft—March 1993
4-66
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
-
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SAMFLE PERMIT CONDITIONS FOR THE AGRONOMIC
Option 1. Permit Writer Calculates Whole Sludge Application Rate
1. The sewage sludge shall be analyzed for nitrogen content on a dry weight basis
prior to land application.
2. The permittee shall report the following information to the permit writer:
• Description of how the application site will be used, specifying vegetation types
and expected yields
• Results of soil analyses, providing pH, .phosphorus, potassium, and nitrogen
levels
• Historical information on land use (e.g., previously planted crops)
• Plans for use of supplemental fertilizer or irrigation, if any.
3. The permittee shall provide information on crop yield and nitrogen requirement for
each type of vegetation to be treated with the sludge.
4. The permittee shall provide soils information for each field on which the sludge will
be applied, unless the fields are substantially identical.
5. The permittee shall alert the permit writer if any of the factors on which the original
sludge application rates are based change substantially.
Option 2. Permittee Calculates Whole Sludge Application Rate
1. The sewage sludge shall be analyzed on a dry weight basis prior to land application
and applied at less than or equal to agronomic rates.
2. The permittee shall conduct, on an annual basis, soil testing representative of all
fields on which sewage sludge is to be land applied.
3. The permittee shall incorporate information on crop yield, residual nitrogen, and
supplemental nitrogen, with soil analysis results to determine sludge application
rates.
-
ft
Draft—March 1993 4-67
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
10. On sites which are adjacent to surface waters which are designated as
the buffer zone sha|l be increased to a width of (feet, yards, other).
The permit writer should either list the name of the
surface waters or use beneficial use designations,
(e.g., drinking water source, scenic river, cold water
fishery).
11. The permittee shall not apply sewage sludge to the site during heavy rainfall months
of or at anytime when the site is in a flooded condition.
12. The permittee shall only irrigate lands containing sewage sludge at rates needed by
the crop as indicated with moisture sensors.
13. The permittee shall only apply sewage sludge to the land at times of maximum plant
uptake. Sewage sludge should never be applied to fallow fields.
4.6.6 LABEL OR INFORMATION SHEET REQUIREMENTS
Statement of Regulations
§503.14(e) Either a label shall be affixed to the bag or other container in which sewage sludge is sold or
given away for application to-the land, or an information sheet shall be provided to the person
who receives sewage sludge sold or given away in an other container for application to the land:
The label or information sheet shall contain the following information:
(1) The name and address of the person who prepared the sewage sludge that is sold or given away
in a bag or other container for application to the land.
(2) A statement that application of the sewage sludge to the land is prohibited except in accordance
with the instructions on the label or information sheet.
0) The annual whole sludge application rate for the sewage sludge that does not cause any of the
annual pollutant loading rates in Table 4 of §503.13 to be exceeded.
Purpose: To ensure that persons using sewage sludge are aware of the restrictions and limitations involved in the
land application of sewage sludge.
Applies to: Preparers that sell or give away sewage sludge in a bag or other container.
Draft-March 1993
4-69
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
Permitting Factors
The permit writer should examine the information provided by the permittee in the application to
determine if a label or an information sheet has been developed. If such a label or information sheet is
already developed, the permit writer should first ensure that the minimum required information is
provided, as listed in §503.14(e), then examine the content for accuracy and consistency with Part 503.
The label or information sheet may contain other information, such as directions for use, nutrient and
mineral content, or any other marketing language that the permittee may wish to add. If such label or
information sheet is not provided, the permit writer should require the permittee to develop the label and
procedures for distributing the label or the information sheet.
The label or the information sheet must contain the annual whole sludge application rate that does not
cause the annual pollutant loading rates presented in §503.13(b)(4) to be exceeded. The label must
present this information as a warning or as part of the application instructions using clear, simple, and
easy to understand terms. The application rate should be expressed in units that are easy to understand
(e.g., pounds per acre or pounds per square foot). Section 4.3 of this manual provides detailed
instructions on calculating the annual whole sludge application rate.
'
-
SAMPLE PERMIT CONDITIONS FOE LABEL OR
1. The preparer shall develop the following information for the product user: name
and address of the preparer, directions for the use of the product, and the annual
whole sludge application rate. The preparer shall provide this information on a
label or information sheet.
2. The permittee shall submit (on an annual basis) a copy of. the label or information
sheet which will accompany the bag or container.
3. The label or information sheet must accompany each bag or container of sewage
sludge product.
4. The label or information sheet shall include the sludge quality data for arsenic,
cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium, zinc,
nitrate, and phosphate. Instructions for calculating the annual whole sewage sludge
application rate shall be provided on the label or information sheet along with the
annual pollutant loading rates.
5. The user information shall include recommended rates of application for various
uses to include home garden, lawn, potting soil, and other.
-
Draft-March 1993 4-70
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
4.7 MONITORING REQUIREMENTS
The permit writer will often impose the sewage sludge monitoring requirements upon the generator and
should require the generator to share the analytical results with appliers or other preparers who may need
sludge quality information to comply with Part 503 when land applying the sludge, when preparing the
sludge for final land application, or when preparing the sewage sludge for sale or give away in a bag or
other container. Invariably, the permit writer will encounter circumstances where it would also be
appropriate to require the other preparers or appliers to monitor sewage sludge quality. Any time a
preparer of sewage sludge receives sewage sludge from a generator and then changes the quality of the
sewage sludge, the preparer is required to monitor the final quality of the sewage sludge. Sewage sludge
monitoring requirements should be imposed on a preparer that accepts sewage sludge from multiple
generators and mixes or otherwise handles the sewage sludge such that the pollutant concentrations in the
sewage sludge applied to the land cannot be determined using the generator's data. Sewage sludge that
has been treated to reduce pathogens and vector attraction and then stored for several months or longer
needs to be resampled and reanalyzed for pathogens prior to being applied to the land.
In developing permit conditions for monitoring sewage sludge applied to the land, the permit writer
should consider including the following:
• Parameters to be monitored
• Monitoring frequencies
• Monitoring locations
• Sampling types and preservation protocol
• Analytical methods.
In addition, the permit writer may find that including a provision which specifies that QA/QC procedures
must be followed will ensure that the results of the monitoring program are reliable and precise. The
following subsections briefly highlight each of the above-listed monitoring issues that should be addressed
in the permit.
4.7.1 PARAMETERS TO BE MONITORED
Section 503.16 requires monitoring of sewage sludge for pollutant concentrations, pathogen reduction,
and vector attraction reduction. Parameters that must be monitored are listed in Table 4-11. Because
the pollutant concentrations in sewage sludge must be recorded on a dry weight basis, the total solids
content of the sewage sludge must be determined each time monitoring is performed.
Part 503 also requires monitoring for pathogen density and vector attraction reduction. However, the
specific monitoring requirements vary with each pathogen or vector attraction reduction alternative.
These requirements are discussed in more detail in,Chapter 6 of this manual. The permit writer will need
to select the appropriate monitoring requirements and establish permit conditions specific to the pathogen
and vector attraction reduction practices used by the individual permittee.
Draft-March 1993 4-71
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-11 PARAMETERS TO MONITOR IN LAND APPLIED SEWAGE SLUDGE
Parameters To Be Monitored
Pollutants*
Pathogens
Vector Attraction Reduction
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Fecal coliform or Salmonella
Enteric viruses'*
Helminth ova"
Volatile solids reduction***
Specific oxygen uptake rate*
pH+ +
Percent sol ids*+ +
"Percent solids of sewage sludge must be monitored to report pollutant concentrations on a dry
weight basis
"Class A alternatives 3 and 4
**"Vector attraction reduction alternatives 1, 2, and 3
+Vector attraction reduction alternative 4
+ +Vector attraction reduction alternative 6
+ ++Vector attraction reduction alternatives 7 and 8.
4.7.2 MONITORING FREQUENCY
The frequency of monitoring is typically established through individual permits on a case-by-case basis.
However, to enhance the self-implementation of the regulations, monitoring frequencies have been
established in Part 503. The monitoring frequencies established by §503.16 for land application are
shown in Table 4-12. However, the permit writer has the discretion to require more frequent monitoring
than established by the Part 503 regulations. Additionally, §503.16(a)(2) gives the permit writer
discretion to reduce the monitoring frequency to no less than once per year if, after 2 years, the
variability of pollutant concentrations and the detection frequency of pathogens are low and compliance
is demonstrated so that a reduction in frequency appears appropriate.
Draft-March 1993
4-72
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-12 FREQUENCY OF MONITORING-LAND APPLICATION
Amount of Sewage Sludge*
(metric tons per 365 day period)
Greater than zero but less than 290
Equal to or greater than 290 but less than 1,500
Equal to or greater than 1,500 but less than 15,000
Equal to or greater than 15,000
Frequency**
Once per year
Once per quarter
(four times per year)
Once per 60 days
(six times per year)
Once per month
(12 times per year)
•Either the amount of bulk sewage sludge applied to the land or the amount of sewage sludge received by a
person who prepares the sewage sludge that is sold or given away in a bag or other container for application
to the land (on a dry weight basis).
**After the sewage sludge is monitored for two years at the above frequency, the permitting authority may
reduce the frequency of monitoring for pollutant concentrations and for the pathogen density requirements in
§503.32(a)(5)(ii) and §503.32(a)(5)(iii), but in no case shall the frequency of monitoring be less than once per
year when sewage sludge is applied to the land [§503.16(a)(2)].
Source: 40 CFR 503. 16
For a generator or preparer who land applies sewage sludge, the monitoring frequency is determined
based on the total quantity of sludge he/she land applies in a given 365-day period. If the sewage sludge
is sold or given away in a bag or other container for land application, the monitoring frequency is based
on the amount of sewage sludge received in a given 365^lay period by the person who prepares the
sewage sludge for sale or give away, not on the amount of sewage sludge actually sold. Whenever
possible, the permit writer should specify the 365-day period and the corresponding monitoring
frequency. The permit writer should also specify that if the quantity of sludge to be land applied during
the 365-day period is going to exceed the quantity on which the monitoring frequency was based, then
the permittee must increase the monitoring frequency to that required for the quantity of sewage sludge
to be land applied. For example, if the permittee is expected to apply between 200 and 750 metric tons
per year during the 5-year permit period, the permit writer could specify two monitoring frequencies as
illustrated below. Alternately, the permit writer could simply apply the more frequent of the two
monitoring frequencies for the entire 5-year permit period.
Draft—March 1993 4-73
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
- -i
•:
SAMPLE PERMIT CONDITIONS FOR MONITO1ING
1 . On [date] of each year, the permittee shall notify the permitting authority of the
quantity of sewage sludge expected to be applied within that 365-day period.
a. The frequency of monitoring shall be once per year when the amount of sewage
sludge applied is less than 290 dry metric tons per 365-day period.
b. The frequency of monitoring shall be once per quarter when the amount of
sewage sludge applied is greater than 290 dry metric tons per 365-day period.
_
The permit writer should consider increasing the monitoring frequency beyond the frequency required
by §503.16 in cases where the permit writer has noted the following:
• Pollutant concentrations vary significantly between measurements
• Pollutant concentrations are close to the pollutant concentration limits
• A trend indicating worsening sewage sludge quality
• A lack of historical data on sewage sludge quality
• Other criteria that the permit writer believes substantiate an increased monitoring frequency.
The permit writer also has the discretion to reduce the monitoring frequency after 2 years of monitoring
at the frequency specified in Table 4-12. In deciding whether to reduce the frequency of monitoring, the
permit writer should consider the following:
• Variability of the pollutant concentrations — The frequency of monitoring should not be reduced
where sewage sludge quality varies significantly (e.g., more than 20 percent) between samples.
• Trends in pollutant concentrations — Facilities with data indicating an increase in pollutant
concentrations over the 2-year time period should not be granted a reduction in monitoring.
• The magnitude of the pollutant concentrations — If all sampling data reveal that the
concentrations of pollutants are significantly below pollutant limitations, a reduction in monitoring
may be appropriate.
• The frequency of detection of viruses and viable helminth ova in the sewage sludge — If all
sampling data on pathogen densities are significantly below the regulatory level, a reduction in
monitoring may be appropriate.
Draft—March 1993 4-74
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
4.7.3 MONITORING POINTS
Representative sampling is one of the most important aspects of monitoring. To obtain a representative
sample of sewage sludge, the sample must be taken from the correct location and represent the entire
volume of sewage sludge. For some facilities, the location of the monitoring point may have a dramatic
effect upon the monitoring results. It is important that samples be collected from a location representative
of the final sewage sludge that is land applied. Because the pollutant limits pertain to the quality of the
final sewage sludge applied to the land, samples must be collected after the last treatment process.
Samples should be taken at the same point and in the same manner each time monitoring is performed.
The sampling location should be safe and accessible.
The permit writer should determine how specific the description of the sampling location should be,
depending upon the following considerations:
• The potential for any changes in sewage sludge quality if samples are taken at different points
• The variability of the sewage sludge
• The ability to obtain a well-mixed sample.
For example, if a commercial preparer or applier receives sewage sludge from several different generators
on a batch basis, the ability to mix the sewage sludge to get a sample representative of all the sludges
may be difficult. The permit writer may then want to specify the exact location where the sample is to
be taken to obtain the most representative sample. If the sewage sludge separates easily between its liquid
and solids fraction, then the permit writer may want to specify where the sample should be taken to
ensure a well-mixed homogeneous sample.
EPA has developed two guidance manuals and a video that provide more detail on proper sample
collection for sewage sludge:
• POTW Sludge Sampling and Analysis Guidance Document (EPA 1989a)3
• Sampling Procedures and Protocols for the National Sewage Sludge Survey (EPA 1989b)
• Sludge Sampling Video (EPA 1992d).
4.7.4 SAMPLE TYPES AND PRESERVATION PROTOCOL
Also important in ensuring representative samples of sewage sludge are the methods for sample collection
and preservation. The sampling technique varies depending on whether the sludge is flowing through
pipes, moving on a conveyor, or stored in a pile or bin. Sewage sludge that flows through pipes or
moves on a conveyor should be sampled at equal intervals during the time the unit operates in a day.
When sampling from piles or bins, full-core samples should be taken from at least four points in the pile
or bin.
'The revised version of this document will to be available in 1993.
Draft-March 1993 4-75
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
The permit writer should consider whether it is more appropriate to specify that the permittee collect a
single grab sample or composite samples. With sewage sludge, as with wastewater, grab samples are
instantaneous samples where a volume of sewage sludge is collected all at one time. Composite samples
are a series of grab samples combined to make a single sample to be analyzed. Composite samples can
be made from a series of grab samples collected from several points in the cross-section of the entire
sewage sludge volume, or they can be a series of grab samples collected at regular time intervals.
In determining whether to specify that a sample be collected using a single grab sample or composite
sampling method, the permit writer may evaluate factors such as:
• How well the sewage sludge is mixed
• Whether the sample is collected from a single batch of sewage sludge or from a stock pile made
up of several batches
• Whether the composition of the sewage sludge varies over time.
In general, however, compositing several samples may provide a more representative sample than
collecting one grab sample. Sewage sludge is most often used, or disposed of, in a solid form and may
be treated in batch processes. Sewage sludge characteristics may also vary over time. For these reasons,
the quality may vary from day to day or even within the sewage sludge volume itself due to the inability
to completely mix sewage sludges that have high solids contents.
Appropriate preservation techniques will ensure that a sample remains representative for the period of
time it is held prior to being analyzed. For field and laboratory preservation of sewage sludge samples,
cooling to 4 degrees Celsius is, in most cases, the most appropriate method due to the inability to mix
high solid sewage sludges with other preservatives. The permit writer should consider specifying this
preservation method in the permit since it differs from the more common wastewater practices.
4.7.5 ANALYTICAL METHODS
All analyses performed to show compliance with the monitoring requirements of Part 503 must be
conducted using EPA-approved methods. Methods to analyze specific parameters in sewage sludge are
specified in §503.8 and shown in Table 4-13. The permit writer should identify the method needed for
each analysis in the permit or incorporate the method by referencing the regulatory citation. In addition
to listing the analytical methods specified by Part 503 for the regulated pollutants and pathogens, Table
4-13 lists suggested analytical methods for the various nitrogen forms and other soil characteristics.
Draft-March 1993 4-76
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TABLE 4-13 ANALYTICAL METHODS
s
I
Pollutant
Arsenic
Cadmium
s
•-J
Chromium
(total)
Copper
Lead
APPROVED METHODS FOR THE ANALYSIS OF SEWAGE SLUDGE
40 CFR PART 503
Analytical Method
A A Furnace
SW-846 Method 7060
AA Gaseous Hydride
SW-846 Method 7061
AA Direct Aspiration
SW-846 Method 7130
AA Furnace
SW-846 Method 7131
Inductively Coupled Plasma
SW-846 Method 6010
AA Direct Aspiration
SW-846 Method 7190
AA Furnace
SW-846 Method 7191
Inductively Coupled Plasma
SW-846 Method 6010
AA Direct Aspiration
SW-846 Method 7210
Inductively Coupled Plasma
SW-846 Method 6010
AA Direct Aspiration
SW-846 Method 7420
AA Furnace
SW-846 7421
Inductively Coupled Plasma
SW-846 Method 6010
Maximum Holding Time, Sample
Preservation, Sample Container,
Sample Preparation
6 months
Plastic or.glass container
Samples need to be digested prior
to analysis.
Comments
All samples must be digested using SW-846 Method 30SO prior
to analysis by any of the procedures indicated. The AA Direct
Aspiration analyses are applicable at moderate concentration
levels in clean complex matrix systems. AA Furnace methods
can increase sensitivity if matrix effects are not severe.
Inductively Coupled Plasma (ICP) methods are applicable over
a broad linear range and are especially sensitive for refractory
elements. Detection limits for ICP methods are generally
higher than for AA Furnace methods.
I
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i
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70
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TABLE 4-13 ANALYTICAL METHODS (Continued)
I
•—
8
APPROVED METHODS FOR THE ANALYSIS OF SEWAGE SLUDGE
40 CFR PART 503
Pollutant
Mercury
Molybdenum
t-
-------
I
f
TABLE 4-13 ANALYTICAL METHODS (Continued)
APPROVED METHODS FOR THE ANALYSIS OF SEWAGE SLUDGE
40 CFR PART 503
Pollutant
Total Solids,
Volatile
Solids, Fixed
Solids
Fecal
Coliform
Salmonella
Enteric
Viruses
Helminth
Ova
Specific
Oxygen
Uptake Rate
Percent
Volatile
Solids
Reduction
, Analytical Method
Gravimetric
SM-2540 G
SM-9221 E (MPN)
SM-9222 D (membrane filter)
SM-9260D.1
Kenner, B.A. and H.A. Clark
ASTM-Method D 4994-89
Yanko, W.A.
SM-2710 B
ERT
Maximum Holding Time, Sample
Preservation, Sample Container,
Sample Preparation
7 days
Cool to 4°C
Plastic or glass container
6 hours
Cool to 4CC
Plastic or glass container
6 hours
Plastic or glass container
2 hours at up to 25°C or 48 hours
at 2 to 10°C
Plastic or glass container
Perform as soon as possible
Plastic or glass container
Comments
Recommended procedure for solid and semisolid samples.
Both procedures are very temperature sensitive. Samples must
be analyzed within holding times.
Large sample volumes are needed due to the low concentration
of Salmonella in wastewater. Also, due to the large number of
Salmonella species, more than one procedure may be necessary
to adequately determine the Salmonella's presence.
Concentration of the sample is necessary due to the presumably
low numbers of viruses in the sample.
See reference list.
Quite sensitive to sample temperature variation and lag time
between sample collection and test initiation. Replicate samples
are suggested.
See reference list.
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-------
57
»
2
63
TABLE 4-13 ANALYTICAL METHODS (Continued)
t
SUGGESTED METHODS FOR THE ANALYSIS OF NITROGEN IN SEWAGE SLUDGE
Pollutant
Total
Kjeldahl
Nitrogen
(TKN)
Ammonia
Nitrogen
(NH3-N)
Nitrite
Nitrogen
(N02-N)
Nitrate
Nitrogen
(NOj-N)
Analytical Method
SM^SOO-N,^
SM-4500-NHj
SM-4500-N02-
SM-4500-NO3-
SW-846 Method 9200
Maximum Holding Time, Simple
Preservation, Sample Container,
Sample Preparation
28 days
Cool to 4°C
Plastic or glass container
28 days
Cool to 4°C
Plastic or glass container
28 days
Cool to 4°C
Plastic or glass container
48 hours
Cool to 4°C
Plastic or glass container
Comments
Total kjeldahl nitrogen is the sum of organic and ammonia
nitrogen in a sample. Sample digestion and distillation are
required and are included or referenced in the method.
All samples must be digested using procedure SM-4SOO-NH3 B
prior to analysis by one of the specific analysis procedures
listed.
Nitrite nitrogen is an intermediate oxidation state of nitrogen
and can be converted by bacteria to NO3" or NH3. Analyze
within holding time to prevent this conversion.
Nitrite nitrogen is the fully oxidized state of nitrogen.
Organics may interfere with the method.
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2
2
TABLE 4-13 ANALYTICAL METHODS (Continued)
SUGGESTED SOIL ANALYTICAL METHODS
SoU Chemical
Property
PH
Cation Exchange
Capacity (CEC)
Plant Avaikble
Nitrogen
Plant Available
Phosphorous
Background Metal
Analysis
Analytical Method
EPA-9045
SM-4500-H +
Sodium Acetate
EPA-9081
Ammonium Acetate
EPA-9080
N-Ammonia
Distillation, Nesslerization
SM-4500-NHj A,B,C
N*Nitrite
Colorimetric
SM-4500-NCV A,B
N-Nitrate
Electrode Method
SM-4500-NOj- A,D
SM^500-P A,B,C,D,E
Metals should be analyzed as per
appropriate methods prescribed
in Standard Methods for the
Examination of Water and
Wastewater 17th Edition and
SW-846.
Extraction and/or Digestion
Procedure
1:1 soil/water
Extract with 1 N NaO Ac (sodium
acetate)
Ammonium, Nitrite and Nitrate -
Extract with 2N KC1
a) Extract with 0.03N NH4 + H^O,,
b) Extract with dilute HC1 + HjSC^
c) Extract with 0.5M NaHCO3
d) Extract with water
Metal samples must be digested prior
to analysis.
Comments
A soil pH at or above 6.5 minimizes metal uptake by
crops.
Needed to determine the soil's ability to attenuate heavy
metal cations.
Inorganic nitrogen (NH4+,NO3~) is readily available for
plant uptake
4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
-------
TABLE 4-13 ANALYTICAL METHODS (Continued)
2
References
EPA - Methods for Chemical Analysis of Water and Wastes. U.S. Environmental Protection Agency, Environmental Monitoring Systems Laboratory-Cincinnati
(EMSL-CI), EPA-600/4-79-020, March 1983.
SM - Standard Methods For The Examination of Water and Wastewater. IS"1 Edition. American Public Health Association, Washington, D.C., 1992.
SW-846 - test Methods for Evaluating Solid Waste: Physical/Chemical Methods. U.S. Environmental Protection Agency, November 1986.
ASTM - Annual Book of Standards - Water. American Society for Testing and Materials, Phila., PA, 1991.
ASTM1 - "Standard Practice for Recovery of Viruses from Wastewater Sludge," Annual Book of ASTM Standards. Section 11, Water and Environmental jS
Technology, 1992. ~
USGS - Fishman, M. J., et al, "Methods for Analysis of Inorganic Substances in Water and Fluvial Sediments," U.S. Dept. of the Interior, Techniques of Water
Resource Investigations of the U.S. Geological Survey, Denver, CO, 1989.
£
KC - .Kenner, B.A. and H.A. Clark, "Determination and Enumeration of Salmonella and Pseudomonas aeruginosa." J. Water'Pollution Control Federation,
46(9):2163-2171, 1974.
Yanko - Yanko. W.A.. Occurrence of Pathogens in Distribution and Marketing Municipal Sludges. EPA 600/1-87-014. 1987. NTIS PB 88-154273/AS, National
Technical Information Service, Springfield, Virginia.
t/1
s
ERT - Environmental Regulations and Technology - Control of Pathogens and Vectors in Sewage Sludge. U.S. Environmental Protection Agency. Cincinnati.
OH, EPA-625/R-92/013, 1992. ' g
I
00
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
4.7.6 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
A QA program is used to achieve a desired quality for activities, such as sample collection, laboratory
analysis, data validation and reporting, documentation, and record keeping. A QA program will typically
address the following major areas:
• Proper collection procedures, equipment, preservation methods, and chain-of-custody procedures
to ensure representative samples
• Proper sample preparation procedures, instruments, equipment, and methodologies used for the
analysis of samples
• Proper procedures and schedules for calibration and maintenance of equipment and instruments
associated with the collection and analysis of samples
• Proper record keeping to produce accurate and complete records and reports, when required.
QC, which is part of the QA program, relates to the routine use of established procedures and policies
during sample collection and analysis. The objective of QC procedures is to ultimately control both the
accuracy and the precision of all analytical measurements made. QC for sample collection includes the
use of duplicate and spiked samples and sample blanks. QC of analytical procedures includes the use of
spiked and split samples, proper calibration protocols, and appropriate analytical methods and procedures.
While QA/QC is standard practice for most laboratories, the permit writer may determine that specificity
in the permit will ensure more reliable data. This may be appropriate in cases where the sewage sludge
is variable or where past permit history suggests that the permittee's self-monitoring program is
questionable.
4.8 RECORD KEEPING REQUIREMENTS
Records must be kept to demonstrate that the permit conditions that implement all applicable Part 503
requirements are being met. Part 503 requires specific information be kept to show compliance with
pollutant concentrations and loadings, pathogen reduction requirements, vector attraction reduction
requirements, and management practices. These records must be retained for 5 years, except for specific
cumulative pollutant loading information which must be kept indefinitely. The record keeping
requirements for land application of sewage sludge are shown in Table 4-14. This table identifies the
minimum requirements for which records must be kept, who must keep the records, and how long they
must be retained. The requirements differ depending on the pollutant limitations applied (see Figure 4-7).
The generator, preparer, and land applier may each be required to maintain records.
The permit writer is obligated to include the minimum appropriate record keeping conditions in each
permit. Additionally, the permit writer may specify that other records be obtained or developed and
maintained by the permittee to determine compliance with permit conditions. For example, if the permit
writer specifies that the permittee conduct a habitat study of an endangered species threatened by land
application practices, requirements to maintain such data should be included in the permit. The following
technical guidance provides examples of specific records the permit writer may want to specify that the
permittee retain.
Draft-March 1993 4-83
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-14 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION
(A) Exceptional Quality Sewage Sludge and Exceptional Quality Material Derived from
Sewage Sludge that Did Not Meet Exceptional Quality Criteria [§503.17(a)(l) and
$503.17(a)(2)]
If sewage sludge or a material derived from sewage sludge applied to the land meets the pollutant
concentrations in §503.13(b)(3), the Class A pathogen requirements in §503.32(a), and one of the
vector attraction requirements in §503.33(b)(l) through §503.33(b)(8), the person who prepares the
sewage sludge or the person who derives the material that meets those requirements shall develop
the following information and shall retain the information for a period of five years:
(i) The concentration of each pollutant listed in Table 3 of §503.13 in the sewage sludge or
material.
(ii) A certification that the Class A pathogen requirements in §503.32(a) and one of the vector
attraction requirements in §503.33(b)(l) through §503.33(b)(8)are met.
(iii) A description of how the Class A pathogen requirements in §503.32(a) are met (refer to
Chapter 6).
(iv) A description of how one of the vector attraction requirements in §503.33(b)(l) through
§503.33(b)(8) is met (refer to Chapter 6).
(B) Material Derived from Sewage Sludge That Did Meet Exceptional Quality Criteria
[§503.10(d) and (g)]
The requirements of Subpart B do not apply when a material derived from sewage sludge is applied
to the land or sold or given away in a bag or other container for application to the land if the
sewage sludge used to derive the material meets the pollutant concentrations in §503.13(b)(3), the
Class A pathogen requirements in §503.32(a), and one of the vector attraction requirements in
§503.33(b)(l) through §503.33(b)(8).
Draft—March 1993 4-84
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-14 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
(C) Bulk Sewage Sludge Meeting Pollutant Concentrations, Class A Pathogen Reduction
Requirements, and Vector Attraction Reduction Alternative 9 or 10 [§503.17(a)(3>]
If the pollutant concentrations in §503.13(b)(3), the Class A pathogen requirements in §503.32(a),
and the vector attraction reduction requirements in either §503.33(b)(9) or §503.33(b)(10) are met
when bulk sewage sludge is applied to agricultural land, forest, a public contact site, or a
reclamation site:
(i) The person who prepares the bulk sewage sludge shall develop the following information and
shall retain the information for five years.
(A) The concentration of each pollutant listed in Table 3 of §503.13 in the bulk sewage sludge.
(B) A certification that the Class A pathogen requirements in §503.32(a) are met.
(C) A description of how the pathogen requirements in §503.32(a) are met.
(ii) The person who applies the bulk sewage sludge shall develop the following information and
shall retain the information for five years. s '
(A) A certification that the management practices in §503.14 and the vector attraction reduction
requirement in either §503.33(b)(9) or §503.33(b)(10) have been met.
(B) A description of how the management practices in §503.14 are met for each site on which
bulk sewage sludge is applied.
(C) A description of how the vector attraction reduction requirements in either §503.33(b)(9)
or §503.33(b)(10) are met for each site on which bulk sewage sludge is applied.
Draft-March 1993 4-85
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-14 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
(D) Bulk Sewage Sludge Meeting Pollutant Concentrations and Class B Pathogen Reduction
Requirements [§503.17(a)(4)]
If the requirements in §503.13(b)(3) and §503.32(b) are met when bulk sewage sludge is applied to
agricultural land, forest, a public contact site, or a reclamation site:
(i) The person who prepares the bulk sewage sludge for application to the land shall develop the
following information and shall retain the information for five years.
(A) The concentration of each pollutant listed of Table 3 of §503.13 in the bulk sewage sludge.
(B) A certification that the pathogen requirements in §503.32(b) and one of the vector
attraction requirements in §503.33(b)(l) through §503.33(b)(8), if applicable, are met.
(C) A description of how the pathogen requirements in §503.32(b) are met.
(D) When one of the vector attraction reduction requirements in §503.33(b)(l) through
§503.33(b)(8) is met, a description of how the vector attraction requirement is met.
(ii) The person who applies the bulk sewage sludge to the land shall develop the following
information and shall retain the information for a period of five years.
(A) A certification that the management practices in §503.14, the site restrictions in
§503.32(b)(5) and the vector attraction reduction requirements in §503.33(b)(9) or (b)(10),
if applicaSle, are met for each site on which the bulk sewage sludge is applied.
(B) A description of how the management practices in §503.14 are met for each site on which
bulk sewage sludge is applied.
(C) A description of how the site restrictions in §503.32(b)(5) are met.
(D) A description of how the vector attraction reduction requirements in either §503.33(b)(9)
or (b)(10) are met, if one of these alternatives is used.
Draft-March 1993 4-86
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-14 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
(E) Bulk Sewage Sludge Subject to Cumulative Pollutant Loading Rates [§503.17(a)(5)]
If the requirements in §503.13(a)(2)(i) are met when bulk sewage sludge is applied to agricultural
land, forest, a public contact site, or a reclamation site:
(i) The person who prepares the bulk sewage sludge shall develop the following information and
shall retain the information for five years.
(A) The concentration of each pollutant listed in Table 1 of §503.13 in the bulk sewage sludge.
(B) A certification that the pathogen requirements in either §503.32(a) or §503.32(b) and one
of the vector attraction reduction requirements in §503.33(b)(l). through §503.33(b)(8), if
applicable, have been met.
(C) A description of how the pathogen requirements in either §503.32(a) or §503.32(b) are
met.
(D) When one of the vector attraction requirements in §503.33(b)(l) through §503.33(b)(8) is
met, a description of how the vector attraction requirement is met.
(ii) The person who applies the bulk sewage sludge shall develop the following information, retain
the information in §503.17(a)(5)(ii)(A) through §503.17(a)(5)(ii)(G) indefinitely, and retain the
information in §503.17(a)(5)(ii)(H) through §5Q3.17(a)(5)(ii)(M) for five years.
(A) The location, by either street address or latitude and longitude, of each site on which bulk
sewage sludge is applied.
(B) The number of hectares in each site on which bulk sewage sludge is applied.
(C) The date and time bulk sewage sludge is applied to each site.
(D) The cumulative amount of each pollutant (i.e., kilograms) listed in Table 2 of §503.13 in
the bulk sewage sludge applied to each site, including the amount in §503.12(e)(2)(iii).
(E) The amount of sewage sludge (i.e., metric tons) applied to each site.
(F) A certification that the requirements to obtain information in §503.12(e)(2) have been met
for each site on which bulk sewage sludge is applied.
Draft-March 1993 4-87
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-14 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
(E) Bulk Sewage Sludge Subject to Cumulative Pollutant Loading Rates (Continued)
(G) A description of how the requirements to obtain information in §503.12(e)(2) are met.
(H) A certification that the management practices in §503.14 have been met for each site on
which bulk sewage sludge is applied.
(I) A description of how the management practices in §503.14 are met for each site on which
bulk sewage sludge is applied.
(J) If the bulk sewage sludge meets the Class B pathogen requirements in §503.32(b), a
certification statement that indicates that the site restrictions in §503.32(b)(5) have been
met.
(K) A description of how the site restrictions in §503.32(b)(5) are met for each site on which
Class B bulk sewage sludge is applied.
(L) If the vector attraction reduction requirements in either §503.33(b)(9) or §503.33(b)(10)
are met, a certification statement that the vector attraction reduction requirements in either
§503.33(b)(9) or §503.33(b)(10) have been met.
(M) If the vector attraction reduction requirements in either §503.33(b)(9) or §503.33(b)(10)
are met, a description of how the requirements are met.
(F) Sewage Sludge Sold or Given Away in a Bag or Other Container Subject to Annual
Pollutant Loading Rates [§503.17(a)(6)]
If the requirements in §503.13(a)(4)(ii) are met when sewage sludge is sold or given away in a bag
or other container for application to the land, the person who prepares the sewage sludge for sale or
give away in a bag or other container shall develop the following information and shall retain the
information for five years:
(i) The annual whole sewage sludge application rate for the sewage sludge that does not cause the
annual pollutant loading rates in Table 4 of §503.13 to be exceeded.
(ii) The concentration of each pollutant listed in Table 4 of §503.13 in the sewage sludge.
(iii) A certification that the Class A pathogen requirements in §503.32(a) and one of the vector
attraction requirements in §503.33(b)(l) through §503.33(b)(8) are met.
(iv) A description of how the Class A pathogen requirements in §503.32(a) are met.
(v) A description of how one of the vector attraction requirements in §503.33(b)(l) through
§503.33(b)(8) is met.
Draft-March 1993 4-88
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
TABLE 4-14 MINIMUM REQUIRED RECORDS FOR LAND APPLICATION (Continued)
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FIGURE 4-7 DECISION TREE FOR DETERMINING
APPLICABLE RECORD KEEPING REQUIREMENTS
Draft-March 1993
4-89
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
4.8.1 DOCUMENTATION FOR POLLUTANT CONCENTRATIONS
At a minimum, each of the land application practices requires that the individual who prepares the sewage
sludge or sewage sludge product for application to the land keep sampling and analysis results. The
permit writer should require that this documentation include:
• Sampling records, including the date and time of sample collection, sample location, sample type,
sample volume, name of person collecting the sample, type of sample container, method of field
preservation, and sampling QC.
• Analytical records, including date and time of analysis, name of analyst, analytical methods,
laboratory bench sheets with raw data and calculations used to determine results, analytical QC,
and analytical results.
4.8.2 DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION REDUCTION
All of the land application practices require certification and documentation on how the pathogen and
vector attraction reduction levels were met. The certifications can be incorporated directly into the permit
from the regulatory language at §503.17 as illustrated in the example provided below. The permit writer
should note that the following is only an example and that separate certification statements are provided
in §503.17 corresponding to the different sewage sludge qualities and uses. For the appropriate
certification statement, the permit writer should refer directly to §503.17(a)(l)-(a)(6).
"I certify, under penalty of law, that the [insert applicable requirement(s) with appropriate
Part 503 citation] has/have been met. This determination has been made under my direction
and supervision in accordance with the system designed to ensure that qualified personnel
properly gather and evaluate the information used to determine that the [insert applicable
requirements] have been met. I am aware that there are significant penalties for false
certification including the possibility of fine and imprisonment."
These certifications must be signed by an authorized representative as defined by §122.22 (see Section
4.9).
The description of how the pathogen and vector attraction reductions were met should be supported by
analytical results documenting pathogen density, logs documenting operational parameters for sludge
treatment units, and records describing site restrictions to properly demonstrate compliance with the
provisions. Specific recommendations on this documentation are provided in Chapter 6.
4.8.3 DOCUMENTATION TO SHOW COMPLIANCE WITH MANAGEMENT PRACTICES
Facilities who land apply bulk sewage sludge are required to certify that they are meeting the management
practices in §503.14 and to describe how the management practices are met unless they are land applying
a sewage sludge that meets the exceptional quality criteria. If sludge is being prepared for sale or give
away in a bag or other container, the preparer must meet the management practice requiring a label. The
permit writer, at a minimum, can specify that the certification and description be maintained. After
review of the permittee's application package and/or a field visit to application sites or in response to
public concern, the permit writer may determine that more specific requirements are necessary to ensure
compliance with the management practices. If the permit writer decides that more specific information
Draft-March 1993 4-90
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
is needed to determine compliance with the management practices, the permit writer must establish permit
conditions that identity specific information, additional reports, or records that must be kept by the
permittee. The following discussions for each management practice provide examples of specific
information that may be requested to demonstrate compliance with the management practices.
Endangered Species or Critical Habitat Protection
Some of the following documentation may be necessary to demonstrate that the application site has been
evaluated for potential effects on endangered species of plant, fish, or wildlife or their designated critical
habitat and that necessary protective measures have been identified and implemented:
• The general proximity of the nearest critical habitat, including migration routes for endangered
species to the application site
• A list of endangered or threatened species in the area or documentation that none exist
• If there are endangered or threatened species, a determination from the FWS or appropriate State
or local agency that the land application activity will not adversely affect the survival of the
species or its critical habitat
• If the above determination indicates that adverse impacts can be avoided if specific measures are
taken, records containing documentation of the measures and how they have been met.
Application of Sewage Sludge to Flooded, Frozen, or Snow-Covered Land
Some of the following information may be needed to prove that: (1) the sewage sludge was not applied
to the land when land was flooded, frozen, or covered with snow, (2) it was highly unlikely for the
sewage sludge applied to the flooded, frozen, or snow-covered land to have entered any surface waters
or wetlands, or (3) the protection of nearby wetlands is already covered by another permit:
• A copy of any permit issued pursuant to either Section 402 or 404 of the CWA for protecting
the nearby wetlands from application of sewage sludge to the land
• A description of the general climatic conditions and the records of the average daily temperature
and amount of snowfall in the area of the application site
• The average uninterrupted slope of the land application site and the distance of nearby surface
waters or wetlands from the boundary of the application site
• A description of the run-off controls used at the site to prevent any sewage sludge from entering
nearby surface waters or wetlands
• Records of the average daily amounts of precipitation in the area and a description of how land
application of sewage sludge is avoided during periods of high rainfall
• The records of the periods and extent of flooding events in the area and a description of how land
application of sludge is avoided during these periods
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
• The average depth to the ground water and records of the periods and extent of any flooding
caused by ground water upsurges
• The types of crops grown and a brief description of the irrigation method used in addition to the
date and time of each irrigation event.
Distance to Surface Waters
Some of the following records may be appropriate to document that an adequate buffer zone is maintained
to prevent sewage sludge from entering adjacent surface water bodies:
• A log book entry for each application site describing the slope of the land application site, the
distance between the boundary of the land application site and nearest surface water body, or
documentation that surface water (which includes wetlands and intermittent stream beds) does not
exist near the land application site
• If there is surface water near the land application site: the approximate length of each water
body frontage; width, length, and slope of the protective buffer zone provided for that water
body; and description of the vegetative cover of the buffer zone
• A log entry documenting the condition of any buffer zone, including its width and vegetative
cover
• A description of any other run-off controls used at the site to minimize or prevent the sewage
sludge from being washed off into the adjacent surface water.
Agronomic Application Rate
The following documentation should be kept on file to demonstrate compliance with the agronomic rate
requirement:
• The original calculations used to determine the annual whole sludge application rate, including
all assumptions-and sources of background information, and data for the variables used in the
calculation, such as:
- Annual nitrogen required by the crop or vegetation (available from the local extension agent
of the Soil Conservation Service)
- Values for the nitrogen content (organic nitrogen, ammonia nitrogen, and nitrate-nitrogen) of
the sewage sludge
- Values for nitrogen content of supplemental fertilizers, if applicable
- Values for nitrogen available from sewage sludge applied in previous years, if applicable
- Nitrogen available from crop residue, if applicable
• The actual quantity of sewage sludge (dry weight basis) applied to the land application site
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
• The nitrogen content (organic nitrogen, ammonia nitrogen, and nitrate-nitrogen) of sewage sludge
that was applied to the land
• The type of vegetation actually grown on the land and the annual nitrogen requirement for the
vegetation or the annual whole sludge application rate authorized by the permitting authority
• The amount of supplemental fertilizer actually applied to the land and the nitrogen content of the
fertilizer.
Label or Information Sheet
Preparers of sewage sludge subject to annual pollutant loading rates are required to keep a copy of a label
or information sheet for at least 5 years. Part 503 requires that each label or information sheet contain
at least the following:
• The name and address of the person who prepared the sewage sludge for sale or give away in
a bag or other container for application to the land
• A statement that prohibits the application of the sewage sludge to the land except in accordance
with the instruction on the label or information sheet
• The annual whole sludge application rate (AWSAR) for the sewage sludge that does not cause
the annual pollutant loading rates to be exceeded.
The permit writer should specify that each time the quality of the sewage sludge changes, the new label
or information sheet be kept in the records.
4.9 REPORTING REQUIREMENTS
Statement of Regulations
§503.I8(a) Class I sludge management facilities, POTWs (as defined in 40 CFR 501.2) with a design flow
rate equal to or greater than one million gallons per day, and POTWs that serve 10,000 people
or more shall submit the following information to the permitting authority:
(1) The information in 503.17(a), except the information in 503.17(a)(3)(ii), 503.17(a)(4)(ii) and in
503.17(a)(5)(ii), for the appropriate requirements on February 19 of each year.
(2) The information in 503.17(a)(5)(ii)(A) through 503.17(a)(5)(ii)(G) on February 19 of each year
when 90 percent or more of any of the cumulative pollutant loading rates in Table 2 of §503.13
is reached at a site.
As was described in the previous section, virtually all persons involved in the preparation of sewage
sludge for land application or in the land application itself are required to keep records. However, only
a subset of facilities that are required to keep records are then required to report under §503.18.
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
A Class I sludge management facility is any
publicly owned treatment works (POTW), as
defined in 40 CFR 501.2, required to have an
approved pretreatment program under
§403.8(a) [including any POTW located in a
State that has elected to assume local program
responsibilities pursuant to §403.10(e)] and any
other treatment works treating domestic
sewage, as defined in §122.2, classified as a
Class I sludge management facility by the EPA
Regional Administrator, or, in the case of
approved State programs, the EPA Regional
Administrator in conjunction with the State
Director, because of the potential for its
sewage sludge use or disposal practice to
adversely affect public health and the
environment adversely. [§503.9(c)]
The reporting requirements in §503.18 apply to
the following facilities:
• Class I sludge management facilities
• POTWs with a flow rate equal to or
greater than 1 mgd
• POTWs serving a population of 10,000
or greater.
Most of the facilities covered by §503.18
reporting requirements are the treatment works
that generate or prepare the sewage sludge or
sludge product. However, there may be
circumstances where the Regional Administrator
or, in the case of approved State programs, the
Regional Administrator in conjunction with the
State Director, designate additional facilities as
Class I facilities. These facilities, which could •^"B™••••"•••••«•••••••f^gg^gUggg^n^
include land appliers, compost facilities, and
pelletization facilities, would then be subject to the reporting requirements.
At a minimum, §503.18 specifies that facilities report annually on the information that they are required
to develop and retain under the record keeping requirements. The permit writer should develop permit
conditions that specifically identify the information that must be reported, the dates by which the
information must.be received, and the address to which the report must be submitted. The following
technical guidance addresses these issues.
The permit writer is expected to set forth conditions requiring facilities to meet the minimum reporting
requirements. At a minimum, this includes the results of sludge analyses for pollutant concentrations and
a certification and description of how the pathogen reduction requirement was met. If the facility used
one of the pre-land application vector attraction reduction alternatives [§503.33(b)(l) through (8)], then
the report must include a certification and description of how the vector attraction reduction requirement
was met. In addition, if the sewage sludge prepared by the reporting facility is land applied under the
cumulative pollutant loading rates, the preparer is required to report site-specific information when the
cumulative loading of any pollutant reaches 90 percent of the cumulative pollutant loading rate for that
pollutant at that site.
When the permittee is instructed to report the results of sludge analyses for pollutant concentrations or
for pathogen density, he/she should be required to include the following information to improve the
reliability of the report:
• Units for reported concentrations
• Dry weight concentrations
• Number of samples collected during the monitoring period
Draft—March 1993
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
• Number of excursions during the monitoring period
• Sample collection techniques
• Analytical techniques.
In addition, the permittee should report separately all data collected using EPA approved methods during
the reporting period.
Whenever possible, the permittee should identify the specific elements to be contained in the description
of how the pathogen and vector attraction reduction requirements were met. Refer to Chapter 6 for a
detailed discussion of appropriate elements for each pathogen reduction and vector attraction reduction
alternative. The permit writer may require that additional information be reported over the minimum
requirements to determine the compliance status of the facility. In the case where additional information
is to be reported, the permit writer must specifically require that information in the permit. Additional
information that may need to be reported includes:
• The amount of sewage sludge being handled or treated
• The amount of the sewage sludge being used or disposed, by use or disposal option
• The operational and management practices at the site
• Special studies required to ensure management conditions are met (i.e., examination of
endangered species habitat)
• Notification of changes in sludge quality that affect the particular pollutant limits to apply, the
AWSAR, and the projected site life.
The permit writer will need to consider whether yearly reporting requirements are sufficient depending
upon site-specific conditions. He/she may want to require some reports to be submitted at a more
frequent interval than the yearly reporting requirement. For example, if the permit writer has imposed
quarterly monitoring requirements for pollutants in the permit, it may be appropriate to require quarterly
reporting of the concentrations or pollutant loadings to determine compliance with the permit limits and
to respond to noncompliance in a timely manner. In addition, several situations may warrant the
inclusion of more frequent reporting, such as:
• Where sewage sludge data show significant variations in quality or where sewage sludge data
indicate a trend toward poorer quality sludge. In these cases, more frequent reporting may assist
regulatory officials in addressing problems before violations of land application regulations occur.
Additionally, the permit writer may have more advanced warning of the need to reopen a permit
to address these situations.
• Where a compliance schedule was specified.
The permit writer may also want to specify the reporting format through the permit. Separate guidance
documents containing recommended reporting formats have been provided to the regulated community
as listed below:
Draft-March 1993 4-95
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
• Monitoring, Record Keeping and Reporting Requirements for Generators and Preparers of
Sewage Sludge (EPA 1992, draft).
• Monitoring, Record Keeping and Reporting Requirements for Land Appliers of Sewage Sludge
(EPA 1992, draft).
The permit writer should instruct the permittee to submit reports to the Water Compliance Chief at the
appropriate EPA Regional office or to the appropriate State counterpart in an approved State. The permit
should require that the reports be signed by an authorized representative. If the permit is an NPDES
permit, the standard conditions may already contain language defining the authorized representative. If
not, then the regulatory language found in §122.22 may be included to clearly identify the authorized
representative.
Signatory Requirement
(I) AH certifications, reports, or information submitted shall be signed as follows:
: (a) For a corporation: by a responsible corporate officer. For the purpose of this section, a responsible
corporate officer means: (1) a president, secretary, treasurer, or vice-president of the corporation in charge of
a principal business function, or any other person who performs similar policy or decision-making functions
for the corporation; or (2) the manager of one or more manufacturing, production or operating facilities
employing more than 250 persona or having gross annual sales or expenditures exceeding $25,000,000 (in
second-quarter 1980 dollars) if authority to sign documents has been assigned or delegated to the manager in
accordance with corporate procedures;
(b) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(c) For a municipality, State, Federal, or other public agency: by either a principal executive officer or tanking
elected official. For purposes of this part, a principal executive officer of a Federal agency includes (1) the
chief executive officer of the agency, or (2) a senior executive officer having responsibility for the overall
operations of a principal geographic unit of the agency (e.g., Regional Administrators of EPA).
(2) All reports required by the permit and other information requested by the Department shall be signed by a person
described above or by a duly authorized representative of that person.
A person is a duly authorized representative only if:
(a) The authorization is made in writing by a person described above and submitted to the Department with the
reports.
(b) The authorization specifies either an individual or a position having responsibility for the overall operation of
the regulated facility or activity, such as the position of manager, operator, superintendent, or position of
equivalent responsibility or an individual or position having overall responsibility for environmental matters
for the company. (A duly authorized representative may thus be either a named individual or any individual
occupying a named position.)
(3) Changes in Authorization. If an authorization is no longer accurate because a different individual or position has
responsibility for the overall operation of the facility, a new authorization satisfying the above requirements must be
submitted to the Department prior to or together with any reports, information, or applications to be signed by an
authorized representative.
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS
Scenario 1: Land Application of Bulk Sewage Sludge Subject to Cumulative Pollutant Loading Rates
Parties involved: One generator/preparer/applier
Numerous private landowners .
Description: The City of Sweetwater operates a 3.0 million gallons per day (mgd) POTW that
generates approximately 1050 tons of sewage sludge per year. The anaerobically digested
sewage sludge is dewatered with a belt press and land applied by the City to seven
different farms owned by private landowners. No other parties are involved in the
preparation and/or application of the sewage sludge. The sewage sludge generated at the
POTW is determined to not be of exceptional quality due to the concentration of copper
and lead.
Issue permit to: The City of Sweetwater POTW
Permit Conditions for the Generator
Standard conditions
General requirements that apply
Pollutant ceiling concentrations
Cumulative pollutant loading rates
Pathogen and vector attraction reduction requirements
Management practices
Monitoring requirements '
Record keeping requirements
Reporting requirements
Draft-March 1993 4-97
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4. LAND APPLICATION - 40 GFR PART 503 SUBPART B
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Scenario 2: Land Application of Bulk Sewage Sludge Subject to Pollutant Concentration Limits
Parties involved:
Description:
One generator
One commercial applier
Numerous private landowners
The Township of Muddy Flats operates a 2.5 mgd POTW which generates approximately
875 tons of sewage sludge per year. The sludge is stored in a-sewage sludge lagoon.
The POTW does not have any additional process units for sewage sludge treatment. The
sewage sludge lagoon dries the sludge to about 4 'percent total solids. Liquid Sludge
Company is contracted by the POTW to pump the lagoon and to haul and land apply the
liquid sludge by sub-surface injection to four closely located farm fields owned by
. different private landowners. Liquid Sludge Company was determined not to be a Class
I sludge management facility'by the EPA Regional Administrator. Only the sewage
sludge generated at the Township of Muddy Flats POTW is applied to the farm fields
with no addition of sewage sludge from other generators. The sewage sludge could meet
the pollutant concentration limits but it did not meet Class A pathogen reduction nor one
of the eight vector attraction reduction requirements.
Issue permit to: The Township of Muddy Flats POTW
Permit Conditions for the Generator
Standard conditions
General requirements that apply
Pollutant concentration limits
Pathogen and vector attraction reduction requirements
Management practices
Monitoring requirements ,
Record keeping requirements
Reporting requirements
i Requirements Applicable to the Commercial Applier
General requirements for appliers
Management practices
Draft—March 1993
4-98
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4. LAND APPLICATION - 40 CFR PART 503, SUBPART B
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Scenario 3: Land Application by One Preparer/Applier of Bulk Sewage Sludge from Several
Generators
Parties involved: Several generators
One large commercial preparer/applier
Numerous private landowners
Description: Five communities in the immediate vicinity of Big City U.S.A. contract with Sludge
Recovery Inc. to accept, mix, and apply their domestic sewage sludge on numerous large
farm fields surrounding Big City. In total, the five communities generate approximately
50,000 tons of sewage sludge per year. The farms are owned by different private
• landowners who each have a contract with Sludge Recovery Inc. to receive treated
sewage sludge from the five communities. Sewage sludge generated at three of the five
POTWs is determined to be of exceptional quality while the remaining two POTWs
generate sewage sludge that is not of exceptional quality. Sludge Recovery Inc. accepts
the. sewage sludge from all five POTWs and mixes the sewage sludge together. Sludge
Recovery Inc. was determined to be a Class I sludge management facility by the EPA
Regional Administrator. , .
Since sewage sludge from two or more POTWs is mixed, thus altering the characteristic
of sludge, since Sludge Recovery Inc. should be permitted, as well as the POTWs. Both
the POTWs and Sludge Recovery Inc. have reporting requirements because Sludge
Recovery Inc. is a Class I sludge management facility. The permits to the three POTWs
with exceptional quality sludge need not contain the general requirements and
management practices.
Issue permits to: The five POTWs and the commercial preparer/applier, Sludge Recovery Inc.
Permit Conditions for the Generators
Standard conditions
General requirement that apply (not needed for POTWs with exceptional quality sewage sludge)
Pollutant concentration limits (for POTWs with exceptional quality sewage sludge and possibly for other
POTWs)
Pathogen and vector attraction reduction requirements
Management requirements (not needed for POTWs with exceptional quality sludge)
Monitoring requirements
Record keeping requirements
Reporting requirements
Draft-March 1993
4-99
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Permit Conditions For the Commercial Preparer/Applier
Standard conditions
General requirements that apply
Pollutant ceiling concentrations
Cumulative pollutant loading rates
Pathogen and vector attraction reduction requirements
Management practices
Monitoring requirements
Record keeping requirements
Reporting requirements
Draft-March 1993 4-100
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Scenario 4: Land Application of Sewage Sludge Subject to Annual Pollutant Loading Rates
Parties involved:
Description:
One generator/preparer (packages the sewage sludge into bags)
Public/consumers
The City of Prague operates a 20 mgd POTW. The POTW generates approximately
7,000 tons (dry weight) of aerobically digested sewage sludge per year. The POTW
dewaters the sewage sludge with a three-meter belt filter press and the dewatered sewage
sludge is then composted in windrow piles. After composting, the sewage sludge does
not meet the pollutant concentrations limits but meets the Class A pathogen requirements
and one of the first eight vector attraction requirements. The composted sewage sludge is
packaged by the POTW and sold to the public at local stores for a modest profit. The
bags of composted sewage sludge are applied by the public to their gardens and/or lawns.
Issue permit to: The City of Prague POTW
Permit Conditions for the Generator
Standard conditions
Pollutant ceiling concentrations
Annual pollutant loading rates
Pathogen and vector attraction requirements
Label or information sheet requirement
Monitoring requirements
Record keeping requirements
Reporting requirements
Draft—March 1993
4-101
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Scenario 5: Land Application of Exceptional Quality Sewage Sludge
Parties involved:
Description:
Several generators
One large commercial packager ' '
Public/consumers
Three communities operate separate POTWs that generate sewage sludge determined to
be of exceptional quality. All three communities contract with Big Bags of Growth, Inc.
to accept and package their sewage sludge for ultimate sale to the public. It should be
noted that the sewage sludge meets exceptional quality before being sent to Big Bags of
Growth, Inc. Big Bags of Growth, Inc. does not perform any type of treatment and
merely distributes the exceptional quality sewage sludge to the public for a profit. Big
Bags of Growth, Inc. was determined not to be a 'Class I sludge management facility by
the EPA Regional Administrator. The public applies the bags of sewage sludge to their
gardens or lawns.
Issue permits to: The three POTWs
Permit Conditions for the Generators
Standard conditions
Pollutant concentration limits
Pathogen and vector attraction reduction requirements
Monitoring requirements
Record keeping requirements
Reporting requirements
Draft-March 1993
4-102
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Scenario 6: Land Application of Exceptional Quality Material Derived from Sewage Sludge
Parties involved: Several generators
One large commercial preparer (treats and packages the sewage sludge into bags)
Public/consumers
Description: Ten rural communities operate individual POTWs with design capacities of less than 1
mgd. Several of the POTWs have anaerobic digesters but none of the POTWs generates
sewage sludge which is determined to be of exceptional quality. All ten POTWs contract
with Nutrient Cycles Company to prepare and package their sewage sludge for sale to the
public. Because none of the sewage sludge individually meets the exceptional quality
criteria, Nutrient Cycles Company combines it and treats the combined sludge with a
compost operation. After the composting is complete, the sewage sludge is mixed with
peat moss and the material meets the exceptional quality criteria. This material is
packaged for sale to the public. Nutrient Cycles Company was determined to be a Class
I sludge management facility by the EPA Regional Administrator.
Issue permit to: The'ten POTWs and the commercial preparer, Nutrient Cycles Company
Permit Conditions to the Generators
Standard conditions
General requirements that apply
Monitoring requirements
Record keeping requirements
Permit Conditions for the Large Commercial Preparer
Standard conditions
Pollutant concentration limits
Pathogen and vector attraction reduction requirements
Monitoring requirements
Record keeping requirements
Reporting requirements
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
REFERENCES
Ahmed, A.U. and Sorensen, D.L. 1990. "Management of Dewatered Sewage Sludge: Long Term
Storage with Minimal Mixing to Destroy Pathogens Followed by Land Use." Environ. Eng. Proc. 1990
Specialty Conf. Am. Soc. Civ. Eng. Arlington, VA. 560.
Anthony, R.G. and G.W. Wood. 1979. "Effects of Municipal Wastewater Irrigation on Wildlife and
Wildlife Habitat." Pp. 213-223. In: Sopper, William E. and Sonja N. Kerr. 1979. Utilization of
Municipal Sewage Effluents and Sludge on Forest and Disturbed Land. Pennsylvania State University
Press. University Park, PA.
Bain, R.E. 1990. "Pollutant Export from Soil Amended with Sewage Sludge Compost." Environ. Eng.
Proc. 1990 Specialty Conf. Am. Soc. Civ. Eng. Arlington, VA. 807.
Barbier, D. et al. 1990. "Parasitic Hazard with Sewage Sludge Applied to Land." Appl. Environ.
Microbiol. 56, 1420. *
Berow, M.L. and Burridge, J.C. 1990. "Persistence of Metal Residues in Sewage Sludge Treated
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Brown, R.E. 1975. "Significance of Trace Metals and Nitrates in Sludge Soils." J. Water Pollut.
Control Fed. 47:2863-2875.
Chaney, R.L. 1973. "Crop and Food Chain Effects of Toxic Elements in Sludges and Effluents." Pp.
129-141. IQ: Proc. of the Joint Conf. on Recycling Municipal Sludges and Effluents on Land.
Champaign, IL. (July 9-13, 1973). National Assoc. State Univ. and Land Grant Colleges. Washington,
DC.
Cole, D.W. 1980. "Response of Forest Ecosystems to Sludge and Wastewater Applications - A Case
Study in Western Washington." in: U.S. EPA. 1980. Utilization of Municipal Wastewater and Sludge
for Land Reclamation and Biomass Production. Washington, DC. EPA 430/9-81-012.
Corps Of Engineers. 1970. Laboratory Soils Testing. United States Army Corps of Engineers.
EMI 110-2-1906.
Cramer, C. 1985. The Farmer's Fertilizer Handbook; How to Make Your Own NPK Recommendations
... And Make Them Pay. Regenerative Agriculture Association.
Dillaha, T.A. Undated. "Role of Best Management Practices in Restoring the Health of the Chesapeake
Bay: Assessments of Effectiveness." Virginia Polytechnic Institute and Scientific University.
Blacksburg, VA.
Driscoll, F.G. 1986. Groundwater and Wells. Johnson and Johnson. St. Paul, MN.
Dowdy, R.H. and W.E. Larson. 1975. "The Availability of Sludge-Borne Metals to Various Vegetable
Crops." J. Environ. Qual. 4:278-282.
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
Dunne, Thomas and Luna B. Leopold. 1978. Water in Environmental Planning. W. H. Freem and
Company. San Francisco, CA.
Environmental Canada. 1974. Land Disposal of Sewage Sludge, Volumes I and II. Pollution Control
Branch. Toronto, Ontario M4V IPS.
Federal Emergency Management Agency. How to Read a Flood Insurance Rate Map.
Folliett, R.F. 1989. Nitrogen Management and Ground Water Protection. Elsevier. New York, NY.
Folliett, R.F., D.R. Keeney, and R.M. Cruse. 1991. Managing Nitrogen for Groundwater Quality and
Farm Profitability. Soil Science Society of America, Inc. Madison, WI
Fresques, P.R. et al. 1990. "Sewage Sludge Effects on Soil and Plant Quality in a Degraded, Semiarid
Grassland." J. Environ. Qual. 19, 324.
Haire, M. and E.G. Krome. 1990. "Perspectives on the Chesapeake Bay, 1990; Advances in Estuarine
Sciences." U.S. EPA for the Chesapeake Bay Program.
Huddleston, J.H. and M.P. Ronayne. 1990. Guide to Soil Suitability and Site Selection for Beneficial
Use of Sewage Sludge, Manual 8. Oregon State University. Oregon.
Martel, C. 1991. "Freezing Out Sludge." Civil Engineering. 64.
Martensson, A.M. and Witter, E. 1990. "Influence of Various Soil Amendments on Nitrogen-Fixing
Soil Microorganism in a Long Term Field Experiment with Special Reference to Sewage Sludge." Soil
Biol. Biochem. (G.B.) 22, 977.
National Weather Service. Technical Paper 40. Rainfall Frequency Atlas of the United States for
Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100 years.
National Oceanic and Atmospheric Administration (NOAA). Climatic Summary of United States.
NOAA. Local Climatological Data.
NOAA. Monthly Summary of Climatic Data.
National Well Water Association. 1985. DRASTIC: A Standardized System for Evaluating Ground
Water Pollution Potential Using Hydrogeologic Settings. Ada, OK.
North Carolina Agricultural Extension Service. 1982. Best Management Practices for Agricultural
Nonpoint Source Control II: Commercial Fertilizer. In Cooperation with U.S. EPA and U.S.
Department of Agriculture. Raleigh, NC.
North Carolina Agricultural Extension Service. 1982. Best Management Practices for Agricultural
Nonpoint Source Control III: Sediment. In Cooperation with U.S. EPA and U.S. Department of
Agriculture. Raleigh, NC.
Draft-March 1993 4-105
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
Page, A.L., T.G. Logan, and J.A. Ryan. 1987. Land Application of Sludge. Lewis Publishers, Inc.
Chelsea, MI.
Schaller,F.W. and G.W. Bailey. 7953. Agricultural Management and Water Quality. low State
University Press.
Spectrum Research, Inc. 1990. Environmental Issues Related to Golf Course Construction and
Management: A Literature Search and Review. Completed for the U.S. Golf Association.
Thorn, W.O. Undated. Land Application of Sewage Sludge. University of Kentucky.
U.S. Department of Agriculture (USDA). 1988. "1-4 Effects of Conservation Practices on Water
Quantity and Quality." In: Water Quality Workshop, Integrating Water Quality and Quantity into
Conservation Planning. Soil Conservation Service. Washington, DC.
USDA. 1991. Water Quality Field Guide. Soil Conservation Service. Washington, DC. SCS-TP-160.
USDA. Field Office Technical Guides. Soil Conservation Service.
U.S. Department of the Interior. 1985. Ground Water Manual. Bureau of Reclamation. Washington,
DC.
U.S. Environmental Protection Agency (EPA). 1976. Application of Sewage Sludge to Cropland. Office
of Water Program Operations. Washington, DC. EPA 430/9-76-013.
U.S. EPA. 1978. Sewage Disposal on Agricultural Soils. Office of Research and Development. Ada,
OK. EPA 600/2-78-1316.
U.S. EPA. 1978. Sludge Treatment and Disposal, Volume 2. Washington, DC. April 1978. 625/4-78-
012.
U.S. EPA. 1980. Procedures Manual for Ground Water Monitoring at Solid Waste Disposal Facilities.
U.S. Environmental Protection Agency, Office of Water and Waste Management, Washington, D.C., SW-
611. December 1980.
U.S. EPA. 1981. Draft Guidance Closure and Postclosure of Hazardous Waste Treatment, Storage and
Disposal Facilities Under Interim Status Standards (Subpart G). U.S. Environmental Protection Agency,
Office of Solid Waste, Washington, D.C., SW-912. 1981.
U.S. EPA. 1983. Process Design Manual for the Land Application of Municipal Sludge. Municipal
Environmental Research Laboratory. Cincinnati, OH. EPA 625/1-83-016.
U.S. EPA. 1984. Ground Water Protection Strategy. Office of Ground Water Protection. August
1984. EPA 440/6-84-002.
U.S. EPA. 1984. Soil Properties Classification and Hydraulic Conductivity Testing—Technical Resource
Document for Public Comment. Office of Sol id Waste and Emergency Response. March 1984. SW-925.
Draft—March 1993 4-106
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4. LAND APPLICATION - 40 CFR PART 503 SUBPART B
U.S. EPA. 1986. RCRA Ground Water Monitoring Technical Enforcement Guidance Document. U.S.
Environmental Protection Agency, Office of Solid Waste and Emergency Response, Washington, D.C.
September 1986.
U.S. EPA. 1986a. RCRA Groundwater Monitoring Technical Enforcement Guidance Document. Office
of Solid Waste and Emergency Response. 9950.1.
U.S. EPA. 1987. Guidance For Applicants for State Wellhead Protection Program Assistance Funds
Under the Safe Drinking Water Act. Officeof Ground Water Protection. Washington, D.C. EPA 440/6-87-
011.
U.S. EPA. 1988. Guidance for Writing Case-by-Case Permit Requirements for Municipal Sewage
Sludge. Draft. Office of Water Experiment. Permits Division.
U.S. EPA. 1989a. POTW Sludge Sampling and Analysis Guidance Document. Permits Division.
U.S. EPA. 1989b. Sampling Procedures and Protocols for the National Sewage Sludge Survey. Office
of Water Regulations and Standards.
U.S. EPA. 1991. Summary of Phase II Regulations. U.S. Environmental Protection Agency, Office of
Ground Water Protection, Washington, D.C., EPA 570/9-91-022. October 1991.
U.S. EPA. 1992. Comprehensive State Ground Water Protection Program Guidance. Draft. Officeof
Ground Water Protection. Washington, D.C.
U.S. EPA 1992. Final Technical Manual for Solid Waste Disposal Facility Criteria-40 CFR Part 258.
Office of Solid Waste. Washington, D.C.
U.S. EPA. 1992. Guidance Specifying Management Measures for Sources of Nonpoint Pollution in
Coastal Waters.
U.S. EPA. 1992a. Monitoring, Record Keeping and Reporting Requirements for Generators and
Preparers of Sewage Sludge. Draft. Office of Wastewater Enforcement and Compliance.
U.S. EPA. 1992b. Monitoring, Record Keeping and Reporting Requirements for Land Appliers of
Sewage Sludge. Draft. Office of Wastewater Enforcement and Compliance.
U.S. EPA. 1992c. The Preamble to 40 CFR Part 503 Standard for the Use and Disposal of Sewage
Sludge. February 1993, FR 9248.
U.S. EPA. 1992d. Sludge Sampling Video. Office of Wastewater Enforcement and Compliance.
Draft-March 1993 4-107
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5. SURFACE DISPOSAL - PART 503 SUBPART C
QUICK REFERENCE INDEX
SECTION Page
OVERVIEW 5.1 5-1
IDENTIFYING SURFACE DISPOSAL 5-2
DETERMINING PROVISIONS TO APPLY TO SPECIFIC SURFACE
DISPOSAL SITES 5-3
SUBPART C REQUIREMENTS TO APPLY TO THE PREPARER AND SITE
OWNER/OPERATOR 5-4
SPECIAL DEFINITIONS 5.2 5-4
GENERAL REQUIREMENTS 5.3 5-8
LOCATION WITHIN 60 METERS OF A FAULT, IN A UNSTABLE AREA,
OR IN A WETLAND PROHIBITED 5-10
WRITTEN CLOSURE AND POST-CLOSURE PLAN 5-11
NOTIFICATION TO SUBSEQUENT OWNERS 5-18
POLLUTANT LIMITS 5.4 5-20
WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM
THAT IS LOCATED 150 METERS OR GREATER FROM THE SITE
PROPERTY LINE 5-23
WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM THAT IS
LOCATED LESS THAN 150 METERS FROM THE SITE
PROPERTY LINE 5-24
SITE-SPECIFIC POLLUTION CONCENTRATIONS 5-25
OPERATIONAL STANDARDS-PATHOGENS AND VECTOR ATTRACTION REDUCTION 5.5 5-27
MANAGEMENT PRACTICES 5.6 5-29
ENDANGERED SPECIES OR CRITICAL HABITAT PROTECTION 5-29
FLOOD FLOW RESTRICTIONS 5-31
REQUIREMENTS IN A SEISMIC IMPACT ZONE 5-33
REQUIREMENT OF 60 METERS OR MORE FROM A FAULT 5-37
UNSTABLE AREAS 5-39
WETLAND PROTECTION 5-44
STORM WATER RUN-OFF MANAGEMENT 5-47
LEACHATE COLLECTION AND DISPOSAL 5-55
METHANE GAS CONTROL 5-64
FOOD, FEED, AND FIBER CROPS AND GRAZING RESTRICTIONS 5-74
PUBLIC ACCESS CONTROL 5-77
GROUND-WATER PROTECTION 5-80
MONITORING REQUIREMENTS 5.7 5-94
RECORD KEEPING REQUIREMENTS 5.8 5-103
REPORTING REQUIREMENTS 5.9 5-111
5.1 OVERVIEW
This chapter provides guidance to the permit writer on how to implement the standards and requirements
for surface disposal contained in Part 503, Subpart C. It is presumed that the permit writer has
established that the sewage sludge being disposed is regulated by Part 503. Chapter 2 provides a detailed
discussion of sewage sludge that is and is not regulated by Part 503.
Draft—March 1993 5-1
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5. SURFACE DISPOSAL - PART 503 SUBPART C
5.1.1 IDENTIFYING SURFACE DISPOSAL
Major challenges for the permit writer in determining whether this subpart is applicable to a particular
facility include:
• Distinguishing surface disposal from land application
• Distinguishing surface disposal from treatment
• Distinguishing surface disposal from storage.
A surface disposal site is defined as an area of land that contains one or more active sewage sludge units.
A sewage sludge unit is an area of land on which only sewage sludge is placed for disposal. Land does
not include waters of the United States, as defined in §122.2. Examples of sewage sludge surface
disposal practices include sewage sludge-only landfills (monofills), sludge piles, and lagoons designed for
the final disposal of sewage sludge.
Surface disposal differs from land application in that it principally uses the land as final disposal, instead
of using the beneficial qualities of the sewage sludge to enhance the productivity of the land. Surface
disposal occurs when:
• The site has no land use activity other than sewage sludge disposal
• The sewage sludge is being applied at rates in excess of the agronomic rate needed by any
vegetation grown on the site (and the site is not a reclamation site).
However, some surface disposal practices, where the sewage sludge is applied on the surface of the land,
may be very similar to land application practices. For example, a surface disposal site where sewage
sludge is applied and a food, feed, or fiber crop is grown or animals are grazed may appear to be a land
application site. However, the site is a surface disposal site if it is dedicated exclusively to sewage sludge
disposal. Site-specific conditions must be developed to control land use activities such as growing of
crops or animal grazing.
The storage or treatment of sewage sludge (other than treatment to reduce pathogen levels and vector
attraction characteristics) is not regulated by Part 503. If sewage sludge is placed on an area of land for
either treatment or storage, Section 503.20(c) makes clear that neither the land nor the sewage sludge
placed on that land for treatment or storage is subject to the requirements in Subpart C. Lagoons, in
particular, are frequently used to dewater or stabilize the sewage sludge, as well as for storage. Storage
of sewage sludge is generally accepted as the temporary placement of sewage sludge on an area of land
prior to final use or disposal. The most obvious indicator that the land-based activity is treatment or
storage is whether or not the facility has designated a subsequent sewage sludge disposal option. Unless
the facility identifies a final use or disposal option for the sewage sludge, the permit writer should permit
the land-based activity as final disposal or require that the permittee develop a final use or disposal plan
for its sewage sludge.
Draft-March 1993 5-2
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Statement of Regulations
§503.20(b) This subpart does not apply to sewage sludge stored on the land or to the land on which sewage
Sludge is stored. It also does not apply to sewage sludge that remains on the land for longer
than two years when the person who prepares the sewage sludge demonstrates that the land on
which the sewage sludge remains is not an active sewage sludge unit. The demonstration shall
include the following information, which shall be retained by the person who prepares the
sewage sludge for the period that the sewage sludge remains on the land:
(1) The name and address of the person who prepares the sewage sludge.
(2) The name and address of the person who either owns the land or leases the land.
(3) The location, by either street address or latitude and longitude, of the land.
(4) An explanation of why sewage sludge needs to remain on the land for longer than two years
prior to final use or disposal.
(5) The approximate time period when the sewage sludge will be used or disposed.
§503.20(e) This subpart does not apply to sewage sludge stored or treated on the land or to land on which
sewage sludge is treated;
Another factor used to distinguish between storage and final disposal is the length of time that the sewage
sludge has been stored. Placement of sewage sludge for periods greater than two years is final use or
disposal unless the facility establishes through written justification a basis for leaving the sewage sludge
on the land for longer than two years according to §503.20(b). The permit writer should evaluate each
situation with regard to the safety of public health and the environment and the reasonableness of a
particular activity in determining whether or not it should be regarded as final disposal. Small facilities
that generate small quantities of sewage sludge may reasonably stockpile sewage sludge for a long period
of time before enough has been generated to warrant transfer to the use or disposal facility. Even some
large facilities may stockpile sewage sludge for long periods when they unexpectedly lose access to their
use or disposal option. In contrast, there are a number of facilities that indefinitely stockpile sewage
sludge under conditions that should be considered disposal. It is common in some areas to construct
sewage sludge "storage" lagoons with a 15 year capacity to postpone final disposal. This type of facility
is constructed similarly to a surface disposal facility and poses the same threat to human health and the
environment, particularly ground water, as a surface disposal unit and, therefore, should be regulated as
such.
5.1.2 DETERMINING PROVISIONS TO APPLY TO SPECIFIC SURFACE DISPOSAL SITES
Some provisions of Subpart C apply to the sewage sludge, some to the location or siting of the surface
disposal site and others to the operation of the surface disposal site. Not all of the management practices,
monitoring, and record keeping requirements apply to every surface disposal site. For example, some
apply only to sites with a liner and leachate collection system; others apply only to sites on which a cover
is placed over sewage sludge.
Draft-March 1993 5-3
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5. SURFACE DISPOSAL - PART 503 SUBPART C
5.1.3 SUBPART C REQUIREMENTS TO APPLY TO THE PREPARER AND SITE OWNER/
OPERATOR
When the preparer is not the owner/operator of the surface disposal site, the permit writer must decide
how to allocate the permit requirements. The general requirements and management practices would
apply to the site owner/operator. Requirements for pathogen and vector attraction reduction would be
allocated according to whether they are met by the preparer, the owner/operator, or both. The pollutant
limits should usually be placed in both permits; when they are based on site conditions the preparer's
permit might contain a condition to meet the pollutant limits that are imposed on the owner/operator.
5.2 SPECIAL DEFINITIONS
Section 503.21 contains definitions specifically related to surface disposal of sewage sludge. This section
of the guidance manual briefly explains some of the terms in §503.21 applicable to surface disposal of
sewage sludge and lists the remaining definitions in §503.21. This section also provides selected
definitions from §503.9 (general definitions for the Part 503 rule) for reference purposes.
For each of the terms discussed below, the definition from the regulation is presented .first, followed by
a brief explanation.
Aquifer
Statement of Regulations
5503.21(b) Aquifer is a geologic formation, group of geologic formations, or a portion of a geologic
formation capable of yielding ground water to wells or springs.
An aquifer is a saturated permeable geologic unit that can transmit significant quantities of water under
normal hydraulic gradients. An aquifer is typically described as being either confined, unconfmed, or
perched. In a confined aquifer, the permeable water-bearing and transporting material lies between two
layers of less-permeable confining material referred to as aquitards. An unconfmed aquifer will have an
aquitard as its lower boundary and the water table as its upper limit. A perched aquifer is a phenomenon
where a less permeable formation existing in the unsaturated zone above the water table acts as a lower
aquitard. Water percolating down toward the water table is intercepted and collected, forming an isolated
saturated zone and perched water table.
SoU
Surface
Unaaturatad sandstone
layer
Saturated
sandstone layer
Shale layer
AQUIFER
Draft—March 1993
5-4
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Cover
Statement of Regulations
§503.21 (d) fover is soil or other material used to cover sewage sludge placed on an active sewage sludge
unit.
Cover is the placement of earthen material over the sewage sludge once it has been deposited in the
sewage sludge unit. Cover is placed over the sewage sludge to reduce vector attraction characteristics,
to contain pathogens, and/or to mitigate odor problems. Virtually any soil is considered suitable cover
material if it accomplishes the desired objectives; very coarse soils; however, may be inappropriate if the
moisture content of the sewage sludge is so high that the soil sinks into the sewage sludge rather than
mounding over the surface.
On a case-by-case basis, other materials may be used as alternatives to soil cover material. The permit
writer may require a demonstration (similar to that required for municipal solid waste landfills by the Part
258 regulations) that the alternate material is suitable. Suggested methods for the applicant to
demonstrate alternative cover suitability are: (1) side-by-side comparison test of soil cover and alternative
material; (2) full-scale demonstration; or (3) short-term full scale tests. Alternatives to soil cover include
foams, polymer-bonded paper applied in a slurry/spray form, removable and reusable geotextiles, tarps,
wood chips, and amended soils. Alternatives may be used provided they control disease vectors and
odors without presenting a threat to human health and the environment (EPA 1992a).
A daily cover, applied at the end of the operating day, is one of the vector attraction reduction options
allowed under §503.25(b). A final cover is required for closure of each sewage sludge unit, as discussed
in Section 5.3.3.
Liner
Statement of Regulations
§503.21Q) Liner is soil or synthetic material that has a hydraulic conductivity of 1 x 10*7 centimeters per
second or less.
A liner is an impediment used during the construction of the sewage sludge unit to retard the downward
movement of liquid beyond the unit's boundary. It is considered part of the leachate collection system.
The liner must have a hydraulic conductivity (the rate at which liquid moves through the liner) of 1 x 10"7
(one ten-millionth) centimeters per second. There are three general types of liners: soil, flexible
membrane and composite. A soil liner is usually composed of compacted clay. Flexible membrane liners
(or geomembranes) are generally polymeric materials, such as plastics and synthetic rubbers. Composite
liners are flexible membrane liners overlying a compacted low-permeability soil layer.
Appendix B describes the types of liners that are commonly used and how the permit writer may
determine if a site has a liner that meets the above hydraulic conductivity requirement and would
appropriately be classified as a liner under Part 503.
Draft-March 1993 5-5
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Qualified Ground-Water Scientist
Statement of Regulations
§503.210) ' Qualified ground-water scientist is an individual with a baccalaureate or post-graduate degree
in the natural sciences or engineering who has sufficient training and experience in ground-water
hydrology and related fields, as may be demonstrated by State registration, professional
certification, or completion of accredited: university programs, to make sound professional
judgments regarding ground-water monitoring, pollutant fate and transport, and corrective
action.
The qualifications of a ground-water scientist are defined in Part 503 to ensure that professionals with
appropriate qualifications and judgment capabilities are used. The ground-water scientist must have an
education and background which allows him or her to evaluate ground-water flow, ground-water
monitoring systems, and ground-water monitoring technologies and methods. The ground-water scientist
must be able to solve solute transport problems and evaluate ground water remediation techniques. The
most appropriate education includes undergraduate or graduate studies in hydrogeology, ground-water
hydrology, engineering hydrology, water resource engineering, geotechnical engineering, geology, or
ground-water modeling. Although a ground-water scientist's education may vary from this list, the
individual's education should be through an accredited institution. Some States have certification
programs for ground-water scientists (EPA 1992a).
Sewage Sludge Unit
Statement of Regulations
§503.21(n) Sewage sludge unit is land on which only sewage sludge is placed for final disposal. This does
not include land on which sewage sludge is either stored or treated. Land does not include
waters of the United States as defined in 40 GFR 122.2.
A sewage sludge unit is usually a confined area of land within the surface disposal site used for the
disposal of sewage sludge only. Some units will be lined and employ leachate collection systems. A
sewage sludge unit is generally covered with soil or some other cover material after the sewage sludge
is placed in that unit. Numerous types of structures fall within the definition of sewage sludge unit,
including excavated trenches or fill areas of varying dimensions and area fill mounds which may actually
be located in depressions on the surface of the land.
Draft-March 1993
5-6
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Sewage Sludge Unit Boundary
Statement of Regulations
§503.21(o) Sewage sludge unit boundary is the outermost perimeter of an active sewage sludge unit.
The sewage sludge unit boundary is the perimeter that contacts the sewage sludge, in all dimensions, of
each individual sewage sludge unit. The bottom boundary is the liner for a sewage sludge unit if the unit
is lined; otherwise, it is the dirt or rock substrate over which sewage sludge has been placed. The side
walls of the sewage sludge unit define the unit's side boundaries. The sewage sludge unit boundary is
the point from which ground-water contamination is measured.
The remaining definitions from §503.21 and selected definitions from §503.9 are shown below for
reference purposes.
Statement of Regulations
§503 Jl(a) Active sewage sludge unit is a sewage sludge unit that has not closed.
§503.9(b) Base flood is a flood that has a one percent chance of occurring in any given year (i.e., a flood
with a magnitude equalled once in 100 years).
§503.21(c) Contaminate an aquifer means to introduce a substance that causes the maximum contaminant
level for nitrate in 40 CFR 141.11 to be exceeded in ground water or that causes the existing
concentration of nitrate in ground water to increase when the existing concentration of nitrate
in the ground water exceeds the maximum contaminant level for nitrate in 40 CFR 141.11.
§503.9(d) Cover crop is a small grain crop, such as oats, wheat, or barley, not grown for harvest
§S03.21(e) Displacement is the relative movement of any two sides of a fault 'measured in any direction.
§503.21(0 Fault is a fracture or zone of fractures in any materials along which strata on one side are
displaced with respect to strata on the other side.
§503.9(j) Feed crops are crops produced primarily for consumption by animals.
§503.9(k) Fiber crops are crops such as flax and cotton.
§503.21(g) Final cover is the last layer of soil or other material placed on a sewage sludge unit at closure.
§503.9(0 Food crops 'are crops consumed by humans. This includes, but is not limited to, fruits,
vegetables, and tobacco.
§503.9(m) Ground water is water below the land surface in the saturated zone.
§503.21 (h) Hotocene time is the most recent epoch of the Quaternary period, extending from the end of the
Pleistocene epoch to the present.
§503.210) Leachate collection system is a system or devke installed immediately above a liner that is
designed, constructed, maintained, and operated to collect and remove leachate from a sewage
sludge unit
Draft—March 1993
5-7
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Statement of Regulations
§S03.21(k) Lower explosive limit for methane gas is the lowest percentage of methane gas in air, by volume,
, that propagates a flame at 25 degrees Celsius and atmospheric pressure. ,
§503.9(s) Place sewage sludge or sewage sludge placed means disposal of sewage sludge on a surface
disposal site.
§503.9(T) Runoff is rainwater, leachate, or other liquid that drains overland on any part of a land surface
and runs off of the land surface.
§503 Jl(m) Seismic impact zone is an area that has a 10 percent or greater probability that the horizontal
ground level acceleration of the rock in the area exceeds 0.10 gravity once in 250 years.
§503.9(y) Store or storage of sewage sludge is the placement of sewage sludgeon land on which the sewage
sludge remains for two years or less. This does not include the placement of sewage sludge on
land for treatment.
§503JZl(p) Surface disposal site is an area of land that contains one or more active sewage sludge units.
$503.21 (q) Unstable area b land subject to natural or human-induced forces that may damage the structural
components of an active sewage sludge unit. This includes, but is not limited to, kind on which
the soils are subject to mass movement.
§503.9(bb) • Wetlands means those areas that are inundated or saturated by surface water or ground water
at a frequency and duration to support, and that under normal circumstances do support, a
prevalence of vegetation typically adapted for life in saturated; soil; conditions; Wetlands
generally include swamps, marshes, bogs, and similar areas.
5.3 GENERAL REQUIREMENTS
Section 503.22 outlines three general requirements for placing sewage sludge on an active sewage sludge
unit. Figure 5-1 provides a decision tree to help the permit writer apply the general requirements. First,
the active sewage sludge unit cannot be located within 60 meters of a fault, in an unstable area, or in a
wetland. Second, the owner/operator of an active sewage sludge unit must submit a written closure and
post-closure plan to the permitting authority 180 days before the unit is due to close. Finally, the owner
of a surface disposal site must provide written notification to the subsequent owner of the site that sewage
sludge was placed on the land. The following sections discuss each of these regulatory requirements and
provide example permit conditions which the permit writer may use as written or tailor to a particular
situation.
Draft—March 1993
5-8
-------
5. SURFACE DISPOSAL - PART 503 SUBPART C
Is the active sewage
sludge unit(s)
located within 60 meters of a
ault that has displacement i
holocene time?
Can the active sewage sludge
unites) be designed to
withstand seismic impacts?
Is the active sewage
sludge unit(s)
located in an unstable area as
defined in J503.21(q)?
Is the active sewage sludge
unit(s) permitted pursuant to
Section 402 or 404 of the
CWA?
Is the active sewage sludge
urut(s) located in a wetland ?
Active sewage sludge
unit is not located in
prohibited areas
Apply all surface
disposal requirements
Require active sewage sludge
unu(s) to be designed to
withstand maximum recorded
horizontal ground level
acceleration
Apply all surface
disposal requirements
Require active sewage
sludge unit(s) to comply
with Section 402
or 404 permit
Apply all surface
disposal requirements
Figure for Section 5.1 Decision Tree for Applying Surface Disposal General Requirements
FIGURE 5-1 DECISION TREE FOR APPLYING SURFACE DISPOSAL GENERAL
REQUIREMENTS
Draft-March 1993
5-9
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5. SURFACE DISPOSAL - PART 503 SUBPART C
5.3.1 LOCATION WITHIN 60 METERS OF A FAULT, IN AN UNSTABLE AREA, OR IN A
WETLAND PROHIBITED
Statement of Regulations
§503.22(b) An active sewage sludge unit located within 60 meters of a fault that has displacement in
Holocene time; located in an unstable area; or located in a wetland, except as provided in a
permit issued pursuant to section 402 of the CWA, shall close by March 19,1994, unless, in the
case of an active sewage sludge unit located within 60 meters of a fault that has displacement
in Holocene time, otherwise specified by the permitting authority.
Purpose: To eliminate continued placement of sewage sludges in geographical areas that pose high potential for
release of sludge to the environment and for adverse effects on human health and the environment.
Applies to: All active sewage sludge units.
Technical Guidance
The permit writer needs to refer to Section 5.6 to determine whether the sewage sludge disposal site is
located in any of the three prohibited or restricted areas identified above. The specific sections that
address these requirements are:
• Fault areas — Section 5.6.4
• Unstable areas — Section 5.6.5
• Wetlands — Section 5.6.6.
The permit writer should develop specific permit conditions to require an active sewage sludge unit to
close if he/she has determined that one of the following situations exists:
• The site is located within 60 meters of a fault and has not been adequately designed to withstand
seismic impacts
• The site is located in an unstable area
• The site is located in a wetland without a Section 402 permit.
Permit Conditions
If the permit writer includes a condition requiring closure of an active sewage sludge unit, this condition
must require the unit to close by March 19, 1994. The permit writer may need to coordinate
development of a compliance schedule that addresses closure activities and time frames. For example,
the compliance schedule may need to specify the dates for submission of a closure and post-closure plan,
and for initiation and completion of closure.
Draft-March 1993 5-10
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5. SURFACE DISPOSAL - PART 503 SUBPART C
"-
-
•^
-
-
-
- , ,
SAMPLE
PERMIT CONDITIONS FOR LOCATIONS ^
pyrraiN^
METERS OF A FAULT, UNSTABLE AREAS, OR WETLANB&
1. If the existing surface disposal site is located within a 60-meter (200-foot) distance
of a fault with movement in the Holocene epoch, or is located
within an area
subject to unstable conditions, the surface disposal site shall close, on or before
March 19, 1994.
3. If the surface disposal site is located in a wetland area, the permittee shall currently
hold a Section 402 permit (NPDES). If the permittee does not have a Section 402
permit and is unable to obtain this permit, the surface disposal site shall close on or
before March 19, 1994, and no additional amount of sewage sludge shall be placed
on the surface disposal site.
4. The permittee shall submit a written closure and post-closure plan to the permitting
authority on or before (insert date 180 days prior to date that the
active sewage sludge unit must close).
i
The permit writer shall establish permit conditions
which will assure site closure occurs within one year
of the effective date of the Part 503 rule - i.e., by
March 19, 1994.
5.3.2 WRITTEN CLOSURE AND POST-CLOSURE PLAN
Statement of Regulations
§503.22(c) The owner/operator of an active sewage sludge unit shall submit a written closure and post
closure plan to the permitting authority 180 days prior to the date that the active sewage sludge
unit closes. The plan shall describe how the sewage sludge unit will be closed and, at a
minimum, shaU include:
(1) A discussion of how the leachate collection system1 will be operated and maintained for three
years after the sewage sludge unit closes if the sewage sludge unit has a liner and leachate
collection system. ••'.'' ;
(2) A description of the system used to monitor for methane gas in the air in any- structures within
the surface disposal site and in the air at the property line of the surface disposal site, as
required in 503.24(j)(2). '' •.:..•''; VV'": '•' ^. i '- ' ••' "..vX:>:- i-X-' •;" :•''. " - ''.'•'-.
(?) A discussion of how public access to the surface disposal site will be restricted for three years
alter the last sewage sludge unit in the surface disposal site closes.
Draft—March 1993
5-11
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Purpose: To ensure that the owner/operator closes all units in a manner that protects human health and the
environment.
Applies to: The owner/operator of a sewage sludge surface disposal facility at the point when the owner/operator
is within 180 days of closing any one of the individual sewage sludge units at the facility.
Technical Guidance
The rule requires that a closure and post-closure plan be submitted to the permitting authority 180 days
prior to closure of a unit. The plan, at a minimum, must address the three items specified in §503.22(c):
• Operation and maintenance of the leachate collection system if the unit has a liner and leachate
collection system
• Methane gas monitoring if a cover is placed on the unit
• Public access restriction to the site.
The permit writer has the authority and discretion during the development of permit conditions to
elaborate on the Federal requirements and to include additional requirements as needed. For example,
the regulations use general language in specifying what the closure and post-closure plan must cover -
i.e., how the leachate collection system will be operated and maintained, the system used to monitor for
methane gas, and how public access will be restricted. The permit writer may need to develop more
specific permit conditions that detail what the discussion or description must contain. Table 5-1 is an
example outline of a closure and post-closure plan.
The closure and post-closure plan should also discuss post-closure activities - i.e., operating and
maintaining the systems that prevent or monitor releases from the unit and monitoring activities that will
be conducted throughout the 3-year period following the unit's closure. The plan should provide the
following specific information:
• Name, address, and telephone number of a person to contact about the site
• Description of land use after closure, including any use restrictions
• Schedule or frequency at which post-closure activities are conducted
• Procedure for verifying that post-closure was provided in accordance with the plan
• Inspection and routine maintenance schedules (e.g., site visits, vegetation control)
• Personnel responsible for post-closure activities (e.g., company, title, responsibilities)
• Procedures for non-scheduled repairs
• Contingency plans (EPA 1992a).
Draft-March 1993 5-12
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-1 SAMPLE CLOSURE AND POST-CLOSURE PLAN OUTLINE
Owner/Operator Name;
Mailing Address:
Telephone Number:
Site Location Address:
I. SURFACE DISPOSAL SITE CONDITIONS
A. General information
1. Size of surface disposal site (hectares or acres)
2. Description of liner, if applicable
3. Description of leachate collection system, if applicable
4. Copy of NPDES permit if there are discharges to U.S. waters
B. Schedule of partial closures, if applicable (milestone chart)
1. Size of each area partially closed
2. Type of cover
3. Source of cover materials
4. Vegetation
C. Inventory of auxiliary equipment (e.g., excavation machinery, spreaders, bulldozers, etc.)
D. Schedule of final closure (milestone chart)
1. Final date of sludge accepted
2. Date all on-site disposal completed
3. Date final cover completed
4. Final date vegetation planted or other material placed
5. Final date closure completed
6. Total time required to close the site
n. TREATING OR DISPOSING OF SEWAGE SLUDGE
A. Maximum volume of sewage sludge on site
B. Total volume of sewage sludge to be disposed on site (m3 or yd3)
C. Describe procedures for disposing of sewage sludge
1. Size of area, number of active sewage sludge units and size of units necessary for disposing of
sewage sludge (include site map of disposal area)
2. Design and construction of units, excavation, lining, etc.
HI. COVER AND VEGETATION
A. Final cover
1. Total area to be covered (m2 or yd2)
2. Characteristics of final cover
a. Type(s) of material(s)
b. Depth of material(s)
c. Total amount of material(s) required
3. Final cover design
a. Slope of cover
b. Length of run of slope
c. Type of drainage and diversion structures
Draft-March 1993 5-13
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-1 SAMPLE CLOSURE AND POST-CLOSURE PLAN OUTLINE
(Continued)
B. Vegetation (if vegetation is to be planted)
1. Total area requiring vegetation (hectares or acres)
a. Area receiving final cover which will have vegetation (hectares or acres)
b. Area partially closed but never vegetated (hectares or acres)
c. Area previously vegetated but requiring some replanting (hectares or acres)
d. Percentage of total area assumed to require replanting during closure (%)
2. Characteristics of vegetation
a. Name or type of vegetation (e.g., rye grass)
b. Climatic, soil and maintenance requirements (e.g., temperature, moisture and nutrient
requirements, replanting frequency)
c. Root structure (expected penetration depth of roots)
3. Soil preparation procedures
a. Type and quantity of fertilizer required per hectare; total required for unit(s) or site being
closed
b. Quantity of seed required per hectare; total required for unit(s) or site being closed
c. Type and quantity of mulch required per hectare; total required for unit(s) or site being
closed
d. Indication of who will perform procedures (contractor or owner/operator)
C. Erosion Control (if vegetation is not to be planted)
1. Procedures and materials for controlling cover erosion
2. Justification for procedures and materials used
IV. GROUND-WATER MONITORING
A. Analyses required
1. Number of ground-water samples to be collected
2. Ground-water monitoring schedule (e.g., quarterly, semi-annually, etc.)
3. Details of ground-water monitoring program
B. Maintenance of ground-water monitoring equipment
V. COLLECTING, REMOVING AND TREATING LEACHATE
A. Description of leachate collection system (i.e., pumping and collecting procedures)
1. Description of the leachate sampling and analysis plan
2. Estimated volume of leachate collected per month
B. Description of leachate treatment process
1. Is treatment on site or off site? If on-site treatment, describe process
a. Design objectives
b. Materials and. equipment required
C. Disposal of leachate
1. If discharged to surface waters, include copy of NPDES permit
2. If hauled off site, provide final destination
D. Maintaining equipment
1. Repairs and replacements required
2. Regular maintenance required over the duration of closure and post-closure periods
VI. METHANE MONITORING
A. Monitoring requirements
1. Monitoring locations
2. Types of samples
3. Number of samples
4. Analytical methods used
S. Frequency of analyses
Draft-March 1993 5-14
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-1 SAMPLE CLOSURE AND POST-CLOSURE PLAN OUTLINE
(Continued)
B. Maintenance of monitoring equipment
VD. MAINTENANCE ACTIVITIES
A. Surface disposal site inspections
1. List all structures, areas, and monitoring systems to be inspected
2. Frequency of inspections for each
B. Planned responses to probable occurrences (including those listed below)
1. Loss of containment integrity
2. Severe storm erosion
3. Drainage failure
C. Maintaining cover and/or vegetation
1. Cover maintenance activities and schedule
2. Mowing schedule
3. Reseeding and mulching schedule
4. Soil replacement
a. Labor requirements
b. Soil requirements
5. Fertilizing schedule
6. Sprinkling schedule
7. Rodent and insect control program
D. Controlling erosion
1. Maintenance program for drainage and diversion system
2. Activities required to repair expected erosive damage
3. Replacement cover soil
a. Amount to be stored on site during the post-closure period
b. Specification of alternative sources of cover soil, if applicable (i.e., off-site purchase
agreement or on-site excavation)
Vm. INSTALLING OR MAINTAINING THE FENCE
A. If a fence already exists, describe required maintenance at closure to ensure it is in good condition
B. If fence is to be installed, specify:
1. Area to be enclosed
2. Type of materials used
3. Dimensions of fence
C. Security and public access practices planned for the post-closure period
1. Description of security system
2. Maintenance schedule
IX. CLOSURE CERTIFICATION
A. Certification that closure has occurred
B. Schedule of periodic inspections
Draft-March 1993 5-15
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Operation and Maintenance of the Leachate Collection System
Leachate can contaminate ground water, surface water, and soil if it is not controlled. If the sewage
sludge disposal unit has a liner and leachate collection system, the closure/post-closure plan must describe
how the owner/operator will collect and manage the leachate for three years after closure. The
owner/operator must comply with all NPDES and other applicable requirements for leachate collection
and disposal. The closure and post-closure plan should furnish specific information on the operating
schedule, leachate management plan, and the leachate removal schedule. Section 5.6.8 provides
additional details on the operation and maintenance of the leachate collection system.
Methane Gas Monitoring System
Methane gas is a byproduct of the anaerobic decomposition of organic matter and is explosive within a
certain concentration range in air. Consequently, Part 503 requires continuous monitoring of methane
at sites where the sewage sludge is covered. Additionally, methane monitoring must be conducted for
a period of three years after closure of a covered sewage sludge disposal unit. At sites where methane
monitoring is required, methane must be monitored inside structures at the site and at the site boundary
to prevent the accumulation of methane to levels that could cause hazards such as explosions, fires, and
asphyxiation.
To provide for adequate monitoring of methane for three years after the unit closes, the closure and post-
closure plan should specifically describe the monitoring schedule, and data acquisition and database
management procedures. Data must be collected continuously and must be retained for five years.
Section 5.6.9 furnishes additional information on methane monitoring and collection systems.
Public Access Restriction
Part 503 restricts public access to a closed unit to prevent:
• Possible exposure to methane
• Direct contact with, or ingestion of, the sludge or sludge-soil mixture
• Traffic that could damage the final cover.
Section 5.6.11 provides examples of proper public access control that should be described in the closure
plan.
Final Cover
If a final cover is required for each active sewage sludge disposal unit that is to be closed, the cover
should be designed to:
• Control volatilization of pollutants
• Account for settling or subsidence in the unit
Draft—March 1993 5-16
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
• Resist erosion
• Control runoff and prevent other damage to the cover.
The closure plan should describe how the final cover accommodates settlement and subsidence, caused
by decomposition and consolidation of the sewage sludge, which can impair the integrity of the final
cover system (EPA 1992a). The plan should include erosion control to prevent surface water and
precipitation from damaging the cover if soil is removed from the cover or the cover system is somehow
degraded. Erosion control should be designed to minimize the amount of water that flows across the
cover and, thus, minimize damage to the unit's physical structure, prevent discharges of pollutants in
solution or suspension in the runoff, and limit downward percolation of water through the sewage sludge
that creates leachate. The permit writer may want to consider developing a permit condition that requires
the submission of final cover design and installation plans that address the above factors.
When the final cover is installed, repairs and maintenance may be necessary for the cover to continue
functioning properly. The permit writer should seek information on landfill closure technology, design,
and maintenance procedures relevant to sewage sludge unit closure. He/she may use this information to
develop permit conditions that meet the requirements for closing an active sewage sludge unit.
Permit Conditions
Example permit conditions to implement this requirement appear below.
1. The permittee shall develop and submit to the permitting authority a written closure
and post-closure plan. This plan shall be submitted at least 180 days prior to
closure of the sewage sludge unit. The written closure and post-closure plan shall
consider each of the elements contained in the outline in Attachment to this
permit. If an element is not applicable to the active sewage sludge unit, then the
permittee shall so state in the plan and provide the reasons why it is not applicable
to the site.
The permit writer may develop an outline of elements
similar to the one contained in Table 5-1 or may
simplify it, according to applicable elements.
Draft-March 1993
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
\
2. The permittee shall continuously monitor methane gas levels inside all structures
located on the surface disposal site and at the property line of the surface disposal
site. This monitoring shall be conducted for a period of not less than 3 years
following closure of the sewage sludge unit.
The permit writer may specify a longer period for
methane monitoring if methane has been a problem at
the surface disposal site.
3. The permittee shall maintain all gas monitoring records for a minimum of 5 years.
4. In the written closure and post-closure plan, the permittee shall describe the
procedures to be implemented to restrict public access to the site.
5. The permittee shall operate, patrol, and maintain the site such that public access is
restricted.
6. The permittee shall erect a chain link fence which is a minimum of feet
in height and is continuous along the disposal site property line.
7. The permittee shall post warning signs on the perimeter fencing. The signs shall be
separated by no more than feet.
5.3.3 NOTIFICATION TO SUBSEQUENT OWNERS
Statement of Regulations
§503.22(d) The owner of a surface disposal site shall provide written notification to the subsequent
owner of the site that sewage sludge was placed on the land. .-,..'
Purpose: To ensure that future owners are informed about the former use of the property so that they do not
engage in activities that are potentially incompatible with the property's former use as a sewage sludge surface
disposal site. Possible incompatible activities include the raising of food crops or the grazing of animals on the land
or excavation of the land.
Applies to: The owner of the surface disposal facility.
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Technical Guidance
This section addresses the two issues that the permit writer will encounter in implementing this
requirement: (1) identifying the type(s) of information that need to be provided to subsequent owners of
sewage sludge surface disposal sites; and (2) determining an appropriate mechanism for ensuring that this
information is passed on to subsequent owners. According to Part 503, a subsequent owner must be
provided with a written notification stating that the land has been used for surface disposal of sewage
sludge. The notice should describe the sewage sludge disposal activities as well as provide specific details
about the design and operations of the site.
The permit writer should consider requiring the following information in the notification statement:
• Name(s) and address(es) of the former owner(s) and operator(s) of the surface disposal site
• Map of the surface disposal site clearly showing the geographical location of sewage sludge
disposal units as well as a depth profile of the former sewage sludge disposal units at the surface
disposal site
• Estimate of the total amount of sewage sludge that has been disposed in each sewage sludge unit
at the surface disposal site
• Average chemical, physical and pathogenic composition of the sewage sludge disposed in the
sewage sludge units
• Results of methane gas monitoring (if conducted)
• Type of liner and leachate collection system installed, if appropriate, and leachate volume and
characteristics
• Copy of any written closure and post-closure plan.
To ensure that subsequent owners are notified that the land was used for sewage sludge surface disposal,
the permit writer should require that the notification statement and any accompanying documentation be
included in the deed for the property. This can be accomplished by recording the notification statement
and accompanying documentation in the local courthouse in the appropriate record book. State and/or
local law will dictate whether this option is available as well as which recording procedures must be
followed. Placing this information in the deed will, in most cases, ensure that subsequent purchasers
become aware of the past use of the property.
If the option of recording the required information in the deed for the property is unavailable, the permit
writer could require the permittee to provide the subsequent owner with a written notification statement
and submit a copy of this notification to the permitting authority and appropriate State or local agencies
such as local zoning commissions or land use agencies. The permit writer should contact State or local
officials to determine the appropriate agency with which this notice should be filed in the event the
notification cannot be included in the property deed.
Draft-March 1993 5-19
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Permit Conditions
If ownership of the surface disposal site changes at any time during the permit's
term, the permittee must notify the subsequent owner that the land has been used for
surface disposal of sewage sludge. This notification must include: the name and
address of the surface disposal permittee; the address of the site; a map identifying
the location of the site disposal unit(s); an estimate of the amount of sludge disposed
at the site; the chemical, physical, and pathogenic composition of the sewage sludge;
the results of the methane gas monitoring; the type of liner and leachate collection
system; a copy of the closure plan; and warnings against excavation, development,
grazing, and the growing of crops on the site.
The permittee must record, in accordance with State law, a notation on the deed to
the property, or on some other instrument which is normally examined during title
search, that the site was used for sewage sludge surface disposal. This notation shall
include:
1
The permit writer should determine the contents of this
notation and specify these contents in the permit.
3. The permittee shall file the notification with the local zoning or land use authority.
The permittee writer should
specific agencies that should be
identify
notified,
by name the
if possible.
4. The permittee shall submit a copy of the notification to the permitting authority.
5. The permittee shall retain a copy of the notification for a period of years.
5.4 POLLUTANT LIMITS
Sewage sludge placed in an active sewage sludge unit that is not equipped with a liner and a leachate
collection system must meet pollutant limits for three metals: arsenic, chromium, and nickel. The
specific pollutant limits to apply will depend on the distance between the unit boundary and the property
line.
Draft—March 1993
5-20
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
No pollutant limits pertain to sewage sludge placed in a unit that is equipped with a liner and leachate
collection system because this unit provides adequate protection to ground water. Sites that have liners
and leachate collection systems must demonstrate that those liners meet the specifications in §503.21(j).
If the liners are substandard, then the sewage sludge placed in these units must meet the pollutant
concentrations for unlined units. Appendix B contains information to assist in evaluating whether a liner
was designed, installed, and continues to maintain a hydraulic conductivity of 10"7 centimeters per second.
The permit writer may also determine that the conditions of the sewage sludge unit warrant the
development of site-specific limits. In this case, the permit writer may use the permittee's site-specific
data and the Tables in Appendix E to calculate site-specific sewage sludge quality limits. These limits
must be implemented through a permit.
The flow chart in Figure 5-2 and the instructions describe how to determine the applicable pollutant
concentration limits (other than site-specific limits) for an active sewage sludge disposal unit.
The permit writer will need the following information in order to determine the appropriate pollutant
concentrations applicable to the sludge disposed in a surface disposal site:
• Information on the liner and leachate collection system - in developing the specific pollutant
limits for sewage sludge disposed in these units, it was assumed that the liner would achieve a
minimum level of protection by slowing the passage of leachate through the liner to a rate of less
than 10"7 centimeters per second. If a liner does not meet this specification, then the unit is
considered unlined for purposes of assigning pollutant limits to the sewage sludge disposed in the
unit.
• Distance between unit boundary and the site property line - the distance of 150 meters was one
of the assumptions used when developing the Part 503 pollutant limits. If the unit is closer to
the property line, the potential for ground water contamination may be increased due to proximity
to a well; therefore, the pollutant limits may need to be reduced.
Step 1: Initially, the permit writer should review the permit application and determine whether the
permittee has requested site-specific pollutant concentration limits. Refer to Section 5.4.3 for
further instructions for the use of site-specific limits. If site specific limits are not requested or
appropriate, continue to the next step.
Step 2: Determine whether the active disposal unit has a liner and leachate collection system. If it does,
no pollutant concentration limits apply. If the unit does not have both a liner and a leachate
collection system, or if the liner does not meet the hydraulic conductivity specification, continue
to the next step.
Step 3: For an active unit without a liner and leachate collection system, identify the distance from the
unit boundary to the site property line. If the unit is located 150 meters or further from the site
property line, apply the pollutant concentration limits listed in Table 1 of §503.23. Refer to
Section 5.4.1 for further instructions on how to apply these limits.
Step 4: If this distance is less than 150 meters, apply the pollutant concentration limits listed in Table 2
of §503.23 for the appropriate actual distance. Refer to Section 5.4.2 for further instruction on
how to apply these limits.
Draft-March 1993 5-21
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
ave site-specific pollutant
, concentration limits been
requested by the permittee
and determined appropriate
by the permitting authority?
Does unit have a liner and
leachate collection system?
Is the distance of the unit
boundary to property line less
than or equal to 150 meters?
Using the tables in Appendix E
determine site-specific pollutant limits
for each pollutant listed in
Table 1 of §503.23.
No pollutant limits apply.
Use the procedure outlined in
§503.23(a)(2)(i) and (ii) to determine
the applicable limits listed in Table 2
of §503.23 for the actual distance.
Apply the limits established in
Table 1 of §503.23.
FIGURE 5-2 PROCEDURE FOR DETERMINING LIMITS FOR AN ACTIVE
SEWAGE SLUDGE UNIT
Draft-March 1993
5-22
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
In addition, the permit writer must recognize that a surface disposal site may have several different types
of sewage sludge units and that the sewage sludge disposed on site may be subject to different pollutant
limits depending upon the sewage sludge unit in which it is placed. In such situations, the permit writer
will have to designate different pollutant limits and monitoring and record keeping requirements for each
particular sewage sludge unit.
The pollutant limits apply to the sewage sludge placed on a surface disposal site. The owner or operator
of the surface disposal site is required to place only sewage sludge that meets these limits on the site.
Treatment works generating sewage sludge that is sent to a surface disposal site must also meet these
pollutant concentration limits.
5.4.1 POLLUTANT LIMITS FOR AN ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER
AND LEACHATE COLLECTION SYSTEM THAT IS LOCATED 150 METERS OR
GREATER FROM THE SITE PROPERTY LINE
Statement of Regulations
§503.23 Pollutant limits (other than domestic septage)
§S03.23(a) Active sewage sludge unit without a liner and leachate collection system
§503 J3(a)(l) Except as provided in §503.23(a)(2) and (b), the concentration of each pollutant listed in Table
6 of §503.23 in sewage sludge placed on an active sewage sludge unit shall not exceed the
concentration for the pollutant in Table 1 of §503.23. :
TABLE 1 OF §503.23 - POLLUTANT CONCENTRATIONS - ACTIVE
SEWAGE SLUDGE UNIT WITHOUT
A LINER AND LEACHATE COLLECTION
Concentration
Pollutant (milligrams per kilogram*)
Arsenic 73
Chromium 600
Nickel 420
•Dry weight basis
The permit writer applies the pollutant concentrations in Table 1 of §503.23 when the following
conditions exist:
• The active sewage sludge unit does not have a liner and leachate collection system or has a liner
that fails to meet specified hydraulic conductivity criteria
• The unit boundary is equal to or greater than 150 meters from the property line of the site.
The permit should contain the pollutants and pollutant concentration limits that appear in §503.23(a)(l).
These limits should be expressed as the maximum pollutant concentrations not to be exceeded. These
Draft-March 1993 5-23
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
limits should also be expressed on a dry weight basis. The metric units (mg/kg) should be included in
the permit, but English units can also be used. Conversion factors are provided in Appendix A.
5.4.2 POLLUTANT LIMITS FOR AN ACTIVE SEWAGE SLUDGE UNIT WITHOUT A LINER
AND LEACHATE COLLECTION SYSTEM THAT IS LOCATED LESS THAN 150
METERS FROM THE SITE PROPERTY LINE
Statement of Regulations
§503.23
PoDutant limits (other than domestk septage)
§503.23(a) Active sewage sludge unit without a liner and leachate collection system
§503 J3(a)(2) Except as provided in §503.23(b), the concentration of each pollutant listed in Table 1 of §503.23
i in sewage sludge placed on an active sewage sludge unit whose boundary is less than 150 meters
from the property line of the surface disposal site shall not exceed the concentration determined
using the following procedure.
(i) The actual distance from the active sewage sludge unit boundary to the property line of the
surface disposal site shall be determined.
(ii) The concentration of each pollutant listed in table 2 of §503.23 in the sewage sludge shall
not exceed the concentration in Table 2 of §503.23 that corresponds to the actual distance
in §503 J3(a)(2)(i).
TABLE 2 OF §503.23 - POLLUTANT CONCENTRATIONS - ACTIVE SEWAGE SLUDGE
UNIT WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM
THAT HAS A UNIT BOUNDARY TO(PROPERTY
LINE DISTANCE LESS THAN 150'MEtERS
Unit boundary to
property line
distance (meters)
0 to less than 25
25 to less than 50
50 to less than 75
75 to less than 100
100 to less than 125
125 to less than 150
Pollutant concentration*
Arsenic
(mg/kg)
30
34
39
46
53
62
Chromium:
(nig/kg)
200
220
260
300
360
450
Nickel
(me/kg)
210
240
270
320
390
420
*Dry weight basis
The risk assessment methodology used in developing pollutant concentrations for sewage sludge placed
in an unlined sewage sludge unit assumed that each unit would be at least 150 meters from the property
line of the surface disposal site. Sewage sludge placed in an active sewage sludge unit located closer than
150 meters from the property line must meet more stringent pollutant concentration limits to ensure
protection of ground water.
To determine the appropriate pollutant concentration limits for an active unit without a liner and leachate
collection system that is located less than 150 meters from the disposal site property line, the permit
Draft-March 1993
5-24
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
writer must know the actual distance from the sewage sludge unit boundary to the property line of the
surface disposal site. This distance should be the shortest distance measured between any point on the
unit boundary to any point located on the property line of the disposal site.
The permit writer should use the actual distance from the sewage sludge unit boundary to the property
line of the site and read the corresponding pollutant concentrations for arsenic, chromium, and nickel
from Table 2 of §503.23. This procedure is illustrated in the worksheet in Figure 5-3. The permit writer
can determine the applicable limits by using this worksheet and by following the example provided in the
figure.
The permit should include the pollutants and pollutant concentration limits that appear in §503.23(a)(2)
for the actual distance from the unit boundary to the site property line. These limits should be expressed
as the maximum pollutant concentrations not to be exceeded. These limits should be expressed on a dry
weight basis using the metric units (mg/kg), but English units can also be used. Conversion factors are
provided in Appendix A.
5.4.3 SITE-SPECIFIC POLLUTANT CONCENTRATIONS
Statement of Regulations
§503.23 Pollutant limits (other than domestic septage)
§503-23(b) Active sewage sludge unit without a liner and leachate collection system - site-specific limits
§503.23(b)(l) At the time of permit application, the owner/operator of a surface disposal site may request site-
specific pollutant limits in accordance with §503.23(b)(2) for an active sewage sludge unit without
a liner and leachate collection system when the existingivalues for site parameters specified by
the permitting authority are different from the values for those parameters used to develop the
pollutant limits in Table 1 of §503.23 and when the permitting authority determines that site-
specific pollutant limits are appropriate for the active sewage sludge unit.
§503.23(b)(2) The concentration of each pollutant listed in Table 1 of §503.23 in sewage sludge placed on an
active sewage sludge unit without a liner and leachate collection system shall not exceed either
the concentration for the pollutant determined during a site-specific assessment, as specified by
the permitting authority, or the existing concentration of the pollutant in the sewage sludge,
whichever is lower. : : : V
Site-specific pollutant concentrations can be developed for active sewage sludge units without liners and
leachate collection systems. If the owner/operator of a surface disposal site requests site-specific pollutant
limits, the permit writer will need to determine if such a request is valid and if site-specific pollutant
limits are appropriate. Thereafter, he/she will need to use the information in Appendix E to determine
the site-specific pollutant concentration limits. To determine whether a request for site-specific pollutant
concentrations is valid, the permit writer will need to request current information on specific site
parameters and compare this information to the values used in developing the pollutant concentrations in
§503.23(a).
The permit writer should consult Appendix E to determine if the site-specific parameter values are
substantially different from those used in developing the §503.23(a) pollutant concentration limits. Before
proceeding with the site-specific assessment, the permit writer should review all available sewage sludge
Draft-March 1993 5-25
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
The permit writer should follow these steps to determine the appropriate pollutant concentration
limits to apply to an active sewage sludge unit that does not have a liner and leachate collection
system or to a unit whose liner fails to meet the hydraulic conductivity requirements:
Step 1: Obtain the actual distance from the sewage sludge unit boundary to the site property line.
Step 2: Review the columns in the table below to locate the range containing the distance obtained
in Step 1.
Step 3: Incorporate the pollutant limits provided in the appropriate column into the permit for the
surface disposal site.
POLLUTANT CONCENTRATIONS FOR AN ACTIVE SEWAGE SLUDGE UNIT
WITHOUT A LINER AND LEACHATE COLLECTION SYSTEM
(milligrams per kilogram*)
Pollutants
Arsenic
Chromium
Nickel
^150
73
600
420
< ISO- 2s 125
62
450
420
<125-2UOO
53
360
390
i <1
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
pollutant concentration data. The site-specific limits issued in the permit must be the lower of either the
values derived from the site-specific tables or the existing concentration of the pollutant in the sewage
sludge.
5.5 OPERATIONAL STANDARDS-PATHOGENS AND VECTOR
ATTRACTION REDUCTION
Sewage sludge to be disposed in an active sewage sludge unit must meet one of the Class A or Class B
pathogen reduction alternatives in §503.32 and one of the vector attraction reduction alternatives listed
in §503.33, unless the sewage sludge placed on an active sewage sludge unit is covered with soil or other
material at the end of each operating day. Each of the pathogen and vector attraction reduction
requirements listed in Table 5-2 and Table 5-3 and their associated monitoring and record keeping
requirements are further discussed in Chapter 6.
Table 5-2 lists the pathogen and vector attraction reduction requirements that apply to the preparer of the
sewage sludge. Table 5-3 summarizes those that apply to the owner/operator of an active sewage sludge
unit. If the owner/operator covers the sewage sludge at the end of each operating day [vector attraction
reduction requirement of §503.33(b)(ll)], then no pathogen or vector attraction reduction requirements
need to be placed on the preparer of the sewage sludge.
In developing permit conditions, the permit writer will need to rely on the information provided by the
applicant on the pathogen and vector attraction reduction treatment processes employed by the preparer
and by the owner/operator. The pathogen and vector attraction reduction requirements that the
owner/operator would be required to meet would depend on whether the sewage sludge provided to the
owner/operator by the preparer already meets one of the Class A or Class B pathogen reduction
alternatives and one of the vector attraction reduction requirements in §503.33(b)(l) through (8). If so,
then the owner/operator would not be subject to any pathogen or vector attraction reduction requirements.
However, if the preparer does not meet one of these vector attraction reduction requirements, then the
owner/operator would be required to comply with the vector attraction reduction alternatives in
§503.33(b)(9) through (11). If the preparer does not meet one of the Class A or Class B pathogen
reduction alternatives, the owner/operator must either meet one of them or cover the sewage sludge daily.
The site restrictions in §503.32(b)(5) associated with the Class B pathogen reduction alternatives do not
apply to sewage sludge placed in a surface disposal site. The permit writer should require the
owner/operator to submit periodic certifications that the sewage sludge meets pathogen and vector
attraction reduction requirements prior to being received. The owner/operator would also need to
describe how these requirements were met by indicating that the preparer provided a certification or
records demonstrating compliance to the owner/operator.
Draft-March 1993 5-27
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-2 PATHOGEN AND VECTOR ATTRACTION REDUCTION
REQUIREMENTS FOR PREPARERS OF SEWAGE SLUDGE
Pathogen Reduction
Vector Attraction Reduction
Class A
Alternative 1 time and temperature
Alternative 2 pH, temperature and time
Alternative 3 one-time demonstration correlating
pathogen levels and operating
parameters
Alternative 4 pathogen levels for fecal coliform,
enteric viruses, and helminth ova
Alternative 5 Processes to Further Reduce
Pathogens (PFRP)
1. Composting
2. Heat drying
3. Heat treatment
4. Thermophilic aerobic digestion
5. Beta ray irradiation
6. Gamma ray irradiation
7. Pasteurization
Alternative 6 equivalent to PFRP
In addition all six alternatives include pathogen
levels for fecal coliform or Salmonella
Alternative 1 38 percent volatile solids reduction
Alternative 2 lab demonstration of volatile solids
reduction anaerobically
Alternative 3 lab demonstration of volatile solids
reduction aerobically
Alternative 4 SOUR £ 1.5 mg 02/hour/g total
solids
Alternative 5 Aerobic digestion for 14 days at
> 40°C
Alternative 6 pH to ^ 12
Alternative 7 75 percent solids
Alternative 8 90 percent solids
Class B
Alternative 1
Alternative 2
Alternative 3
pathogen levels for fecal coliform
Processes to Significantly Reduce
Pathogens (PSRP)
1. Aerobic digestion
2. Air drying
3. Anaerobic digestion
4. Composting
5. Lime stabilization
equivalent to PSRP
TABLE 5-3 PATHOGEN AND VECTOR ATTRACTION REDUCTION
REQUIREMENTS FOR OWNERS/OPERATORS OF SURFACE DISPOSAL SITES
Pathogen Reduction
None
Vector Attraction Reduction
Alternative 9 injection below land surface
Alternative 10 incorporation into soil
Alternative 1 1 daily cover
Draft—March 1993
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
5.6 MANAGEMENT PRACTICES
5.6.1 ENDANGERED SPECIES OR CRITICAL HABITAT PROTECTION
Statement of Regulations
§503 .24(a) Sewage sludge shall not be placed on an active sewage sludge unit if it is likely to adversely affect
a threatened or endangered species listed under section 4 of the Endangered Species Act or its
designated critical habitat.
Purpose: To ensure that the operation of an active sewage sludge unit will not cause harm to threatened or
endangered species or their habitat.
Applies to: All active sewage sludge units, located were there is a potential for harming a threatened or
endangered species of plant, fish, or wildlife, or their habitat; as well as to the owner/operator of the surface
disposal site.
Permitting Factors
The permit writer will need to determine whether any threatened or endangered species or its designated
critical habitat are present on or around the surface disposal site, evaluate whether the surface disposal
activities being permitted might have adverse effects upon the species or habitat, and develop the
appropriate management practices. The first step is to determine whether these species or their designated
critical habitats are, or may be, found at the surface disposal site or in areas which might be affected by
the permitted activities. It is important to understand that affected species might be transient and only
present at limited times of the year (e.g., migrating birds). It is also important to understand that
permitted activities at the site might affect species or habitat adjacent to the site.
As part of obtaining permit application information, the permit writer may want to request that the owner/
operator of the surface disposal site certify to the presence or absence of threatened or endangered species
or critical habitats. U.S. Fish and Wildlife Service (FWS) biologists can help the permit writer determine
if any threatened or endangered species or critical habitats are present on or surrounding the surface
disposal site or active sewage sludge unit. The permit writer should contact the FWS field office nearest
to the site; otherwise, regional offices should be contacted. During consultations with FWS personnel,
the permit writer may also request contacts at relevant State agencies who might provide additional
information regarding species or habitat of importance within the State. If endangered or threatened
species are identified, the permit writer will need to determine whether the surface disposal activities are
likely to adversely affect the threatened or endangered species or its critical habitat. FWS and State
agency personnel should be consulted regarding these determinations.
After reviewing the information available from the applicant, relevant agencies, and any other sources
the permit writer has consulted, the permit writer should determine the potential for surface disposal
activities causing an adverse impact to endangered or threatened species or their habitat. The permit
should include either a general prohibition against adverse impacts to threatened or endangered species,
or a set of specific requirements for avoiding or mitigating impacts to these species or to their habitat,
where the permit writer has identified potential harm.
Draft—March 1993 5-29
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Permit Conditions
Where there is no likely adverse effect on
endangered or threatened species, the permit
writer may simply include in the permit a
restatement of the requirements of §503.24(a).
However, in cases where permitted activities
might have impacts on identified species or their
habitat, the permit writer should develop permit
conditions for specific management practices that
are tailored to species, conditions, and potential
impacts at the site. For example, if the surface
disposal activities will likely adversely affect the ^aaiaimMHH••MmiBM^HMM•tmmMMmmmmm•
nesting activities of an endangered bird species,
then conditions may be put into the permit to prohibit the placement of sewage sludge on the active
sewage sludge units during the nesting season.
In cases where the surface disposal activities will definitely result in adverse impact(s) to threatened or
endangered species that special conditions would not sufficiently mitigate, the permit writer should
prohibit the siting of active sewage sludge units in the affected area. If active units exist, the permit
writer may want to require the units to close.
Threatened or endangered species include those
species listed pursuant to Section 4 of the
Endangered Species Act. A critical habitat is
any place where a threatened or endangered
species lives and grows during any stage in its
life cycle. Adverse impacts are destruction or
modification of a critical habitat that diminishes
the likelihood of survival and recovery of the
species, .^v .. ' • .
'
1 . The permittee shall monitor the long-term effect of sewage sludge on the
endangered species or the critical habitat. The monitoring shall be conducted at a
frequency of Cx/month. other) for a period of
(months, years) and shall include the following parameters
2. If a likely adverse impact is determined, the permittee shall discontinue the
placement of sewage sludge on the surface disposal site.
3. The permittee shall not establish a surface disposal site within (feet.
meters, miles) of an endangered species or critical habitat.
4. Access roadways to the site shall not adversely impact on endangered species or
critical habitat.
5. Surface disposal equipment and machinery shall not disturb an endangered species
or its designated critical habitat.
Draft-March 1993
5-30
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
5.6.2 FLOOD FLOW RESTRICTIONS
Statement of Regulations
§503.24(b) An active sewage sludge unit shall not restrict the flow of a base flood.
Purpose: To ensure that any active sewage sludge unit located in a flood plain does not increase the threat posed
by a base flood to human health, the environment, and property downstream of the site.
Applies to: Any active sewage sludge unit located within the 100-year flood plain.
Permitting Factors
The siting of sewage sludge surface disposal sites ^^^•^•^•^^^^••^^••^^^•••^^•'^^
on areas subject to flooding requires special Base flood is a flood that has a one percent
considerations to ensure that the flow of chanceof occurring in any given year:(i.e., a
floodwaters is not restricted. Restricting the flow flood with a magnitude equalled once in 100
of a base flood can increase the velocity of the years). [40 CFR 503.9(b)T
flow downstream of the site, reduce the
temporary Storage capacity Of the flood plain, or ^mtmm^mmm^^mm^mmm^^mmH^mmi^m^mm
increase the level of the flood waters.
A sewage sludge unit located in the base flood area that affects the flow of the base flood and flood water
storage capacity of the flood plain is acceptable, unless the effect is large enough to cause higher flood
levels and greater flood damage. If the owner/operator of the sewage sludge unit can demonstrate that
the sewage sludge unit will not pose unacceptable threats of higher flood levels and flood velocity, the
requirements of this provision are met. This demonstration must be submitted to the permitting authority.
If this demonstration can not be made, the owner/operator must close the active sewage sludge units
located in the 100-year flood plain. Closure must be performed in accordance with the closure and post-
closure plan required by §503.22(c).
The permit writer should first determine whether "^^"^"v^^^T^^"^^^"""^^^"""™
the surface disposal site is located within an area .Restriction of the flow of a base flobd is
that is likely to be inundated during the 100-year defined asthe raising of flood levels by one
base flood (i.e. within the 100-year flood plain). foot or mpre due to ^ presence of an
River flood plains are readily identifiable as the obstruction.
flat areas adjacent to the river's normal channel.
The 100-year flood plains are identified in the ••^•••••••••••••••••••••••••••••^^••i
flood insurance rate maps (FIRMS) and flood
boundary and flood way maps published by the Federal Emergency Management Agency (FEMA).
Guidance in using FIRMS is provided in "How to Read a Flood Insurance Rate Map" published by
FEMA. FEMA also publishes "The National Flood Insurance Program Community Status Book" which
lists communities that are in Emergency or Regular Flood Insurance programs, including communities
that may not be involved in the National Flood Insurance Program but which have FIRMS or floodway
maps published. Maps and other FEMA publications may be obtained from the FEMA Distribution
Center. Areas not covered by the FIRMS or floodway maps may be included in flood plain maps
available through the Army Corps of Engineers, the U.S. Geological Survey (USGS), the U.S. Soil
Conservation Service, the Bureau of Land Management, the Tennessee Valley Authority, and State and
Draft-March 1993 5-31
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
local agencies. Many of the river channels covered by these maps may have undergone modification for
hydropower or flood control projects and the flood plain boundaries represented may not be accurate or
representative. The permit writer may want to compare the flood plain map series to recent aerial
photographs to identify current river channel modifications and land use watersheds that could affect flood
plain designation (EPA 1992a).
If flood plain maps are not available and the surface disposal site is located within a flood plain, then a
field study to delineate the 100-year flood plain may be required. A flood plain delineation program
would be based primarily on meteorological records and physiogeographic information, such as existing
and planned watershed land use, topography, soils and geologic mapping, and aerial photo interpretation
of geomorphic (land form) features. The U.S. Water Resource Council provides information to
determine the potential for floods in a given location by stream gauge records. Estimation of the peak
discharge by these methods also allows an estimation of the probability of exceeding the 100-year flood
(EPA 1992a).
If the active sewage sludge units are not located on the 100-year flood plain, the permit writer need not
include any condition in the permit. However, if the surface disposal site is located near a flood plain
and there is a potential that future sewage sludge units may be placed in the flood plain, the permit writer
should include a permit condition that any active units constructed or placed in service during the term
of the permit must not restrict the flow of the base flood.
If the active sewage sludge unit is located in a 100-year flood plain, the permit writer must evaluate
whether the sewage sludge unit will restrict the flow of a base flood. The demonstration that the sewage
sludge unit does not restrict the flow of a base flood relies on estimates of the flow velocity and volume
of flood plain storage in the vicinity of the sewage sludge unit during a base flood. The assessment
should consider the flood plain storage capacity and floodwater velocities that would exist in the absence
of the sewage sludge unit. Raising the base flood level by more than one foot can indicate that the
sewage sludge unit may reduce and restrict storage capacity and flow. In some smaller areas, a greater
than one foot increase in the flood level may be acceptable (EPA 1992a).
The assessment of flood water velocity will require that the channel cross section be known above, at,
and below the sewage sludge unit. Friction factors on the overbank are determined from the surface
conditions and vegetation present. River hydrologic models may be used to simulate flow levels and
estimate flood velocities through these river cross sections. The Army Corps of Engineers has developed
several numerical models to aid in the prediction of flood hydrographs, flow parameters, the effect of
obstructions on flow levels, the simulation of flood control structures, and sediment transport (COE
1982).
If the permit writer determines that the sewage sludge unit will restrict base flood flow, he/she may need
to write site-specific conditions into the permit that will prevent restriction of the flow of a base flood
or require closure of the active sewage sludge units. To determine whether to draft such site-specific
conditions, the permit writer will require additional information about the site, the design parameters of
the sewage sludge units, and management practices that will be used to prevent restriction of the base
flood. The permit writer may also need to develop permit conditions that require the sewage sludge unit
to be adequately protected from flood damage, such as embankment designs with rip-rap and geotextiles
to prevent scour. Guidelines for design with these materials may be found in Maynard (1978) and the
Department of Agriculture (1983). Embankment designs will require an estimate of river flow velocities,
Draft—March 1993 5-32
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
flow profiles (depth), and wave activity. The use of alternate erosion controls such as gabions (cubic-
shaped wire structures filled with stone), paving bricks, and mats may be considered (EPA 1992a).
Permit Conditions
x-l """..
! ?-
:• s
V X -.
•,* vv,
•.' ¥•*•
f.\*^
;
o- X^'"
SAMPLE FERMFF CONPFHONS FOE FLOOD FLOW
1. The surface disposal unit shall not cause the base flood level to be raised by one
foot or more.
2. The permittee shall monitor all flood events and record the level of the flood waters
at designated floodplain sites both above and below the sewage sludge unit.
3. The surface disposal site shall be designed and constructed such that the sewage
sludge unit(s) shall not be inundated by or suffer damage from flood waters.
4. The permittee shall not place sewage sludge on the surface disposal site at any time
the site is experiencing a base flood event.
-
5.6.3 REQUIREMENTS IN A SEISMIC IMPACT ZONE
Statement of Regulations
§503.24(c) When a surface disposal site is located in a seismic impact zone, an active sewage sludge unit
shall be designed to withstand the maximum recorded horizontal ground level acceleration.
Purpose: To ensure that the active sewage
sludge unit will not collapse during seismic
activity and release pollutants into the ground
water.
Applies to: Any surface disposal site that is
located in a seismic impact zone.
Seismic impact zone is an area that has a10
: percent or greater probability that the
horizontal ground level; acceleration of the rock
in the area exceeds 0; 10 gravity once in 250
years. [40 CFR 503.2 l(m)]
Draft-March 1993
5-33
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Permitting Factors
Ground motion from earthquakes can cause structural failure of the active sewage sludge unit(s). Studies
indicate that, during earthquakes, superficial (shallow) slides and differential displacement are produced,
rather than massive slope failures (Dept. of Navy 1983). Stresses created by superficial failures can
affect liner and final cover systems, and leachate and gas collection and removal system performance.
For example, tensional stresses within the liner system can fracture the soil liner and/or tear the flexible
membrane liner. The effects of seismic activity on earth material are discussed in Section 5.6.5.
First, the permit writer should determine whether the surface disposal site is located in a seismic impact
zone. If it is, the permit writer must require that the owner/operator ensure that the sewage sludge units
are, or will be, designed to withstand the maximum recorded horizontal ground level acceleration. Table
5-4 lists documents and Table 5-5 identifies governmental and non-governmental organizations that can
provide information on seismic impact zones and seismic hazards. These lists are not a complete
compilation of sources for seismic information but should provide the permit writer with enough
information to make an informed decision.
If active sewage sludge units are located in seismic impact zones, the permit writer will need to determine
the amount of risk posed by geological and hydrogeological conditions. The permit writer should
investigate the following potential site hazards:
• Liquefaction (the partial or total loss of shear strength of loose, saturated fine sands as a result
of an increase in pore water pressure; the soil acts like a liquid)
• Soils with low foundation strength
• Slope instability
• Ground deformation
• Fault rupture.
For units located in an area with an estimated ^*^^^™^—p™^^^"1^
maximum horizontal acceleration greater than 0.1 fhe horizontal acceleration is expressed as a
gravity (g), the permit writer's evaluation of percentage of the: acceleration due to gravity
seismic effects should consider both foundation ^ -fhe accdeVatibn due to grayity is 9:8
soil stability and sewage sludge stability under meters/sec2;
seismic loading. Conditions that may be
considered for the evaluation include the •••••^^^••^•^^••••••••••••^^^^
construction phase (maximum open excavation
depth of new sewage sludge unit) and closure activities.
Draft-March 1993 5-34
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-4 SOURCES OF INFORMATION ON SEISMIC IMPACT ZONES
AND FAULT AREAS
"Preliminary Map of Horizontal Acceleration in Rock With 90 % Probability of Not Being Exceeded in 250
Years" - Algermissen and Perkins, Probabilistic Estimates of Maximum Acceleration and Velocity in Rock in
the Contiguous United States, U.S. Geological Survey Open-File Report 82-1033, 1982 (Updated 1991)
Available from USGS Map Center.
Preliminary Young Fault Maps, MF916, U. S. Geological Survey, 1978 -identifies the location of Holocene
faults in the United States. Available from USGS Map Center.
National Aerial Photographic Program/National High Altitude Program (NAPP/NHAP) high altitude, high
resolution aerial photographs. Available from U.S. Geological Survey, EROS Data Center.
USGS State seismic maps - USGS Map Distribution
Building Seismic Safety Council, "NEHRP Recommended Provisions for the Development of Seismic
Regulations for New Buildings" (Fed. Emergency Mgmt. Agency 1991). Available from FEMA.
TABLE 5-5 GOVERNMENTAL AND NON-GOVERNMENTAL ORGANIZATIONS THAT
MAY PROVIDE SEISMICITY INFORMATION
USGS
Earthquake Information Center, Colorado School of Mines, Golden, Colorado (seismicity maps of all 50 states
and a database of known earthquakes and fault zones)
State Geologic Surveys
The National Information Service for Earthquake Engineering
The Building Seismic Safety Council
The American Institute of Architects
Draft-March 1993 5-35
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
There are no standard procedures for designing sewage sludge units for seismic events. Winterkorn and
Fang (1975) and Department of the Navy (1983) do, however, review engineering evaluations which
consider the influence of local soil conditions on ground response and shaking intensity, soil settlement,
soil liquefaction, and slope instability during earthquakes. Design modifications to accommodate an
earthquake may include shallower sewage sludge unit side slopes and more conservative design of dikes
and runoff controls. Well compacted cohesion-less embankments or reasonably flat slopes in insensitive
clay are less likely to fail under moderate seismic shocks (up to O.lSg and 0.20g acceleration).
Additional contingencies should be installed for leachate collection in the event primary systems are
disrupted. The materials that make up the individual components must be able to withstand seismic forces
while contributing to the unit's strength. New sewage sludge units can be designed to these standards
or to the requirements of this part (EPA 1992a).
Permit Conditions
Provided below are examples of conditions that may be included in the permit of a surface disposal site
that has units located within a seismic impact zone.
The sewage sludge unit shall be designed, constructed, operated and maintained to
withstand the site area maximum recorded ground motion during earthquakes, as
specified in the attached plans and specifications labelled Exhibit A in this permit.
\ .:•.:•:. •
The permit writer needs to determine how to
document the structural adequacy of the unit.
-
The sewage sludge unit shall have side slopes of less than
percent.
The sewage sludge unit shall have a backup leachate collection system.
The permittee shall develop and implement a corrective action and emergency
response plan to protect human health and the environment in the case of seismic
damage to the unit. The plan shall be implemented should damage occur during the
period the sewage sludge unit is active and for a period of years
following the closure of the site.
The permit writer should specify the amount of time
the permittee is responsible for corrective action
should an earthquake occur.
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
5.6.4 REQUIREMENT OF 60 METERS OR MORE FROM A FAULT
Statement of Regulations
§503.24(d) An active sewage sludge unit shall be located 60 meters or more from a fault 'that
displacement in Holocene time unless otherwise specified by the permitting authority;:;
Purpose: To prohibit locating a sewage sludge disposal unit within 60 meters of a fault that has had movement
during the Holocene epoch in order to prevent a release that could endanger human health or the environment.
Applies to: All active sewage sludge units.
Permitting Factors
Seismologists generally believe that the structural integrity of an engineered unit cannot be unconditionally
guaranteed when it is built within 60 meters (200 feet) of a fault along which movement is highly likely
to occur (EPA 1991b). A 60 meter (200 feet) buffer zone is, in most cases, sufficient to protect
engineered structures from seismic damages. The permit writer must first determine whether a site is
within 60 meters (200 feet) of a fault which has had movement during the Holocene epoch. To make
this determination, the permit writer should obtain information on any lineaments that suggest the
presence of any faults within a 915 meter (3,000 foot) radius of the site. Sources of the information are:
• A review of available maps, logs, reports, scientific literature, or insurance claim reports
• An aerial reconnaissance of an area ^•"•^^•"•^••••^^™""^"^™^^™
within a five mile radius of the site, A faujt is a fracture or a zone of fractures in
including an aerial photo analysis ^y. materials along which strata on one side
are displaced with respect to strata on the other
• A reconnaissance based on walking side [40 CFR 503.21 (f)] A fault may have
portions of the area within 915 meters sudden raovement or it may have very slow
(3,000 feet) of the unit (EPA 1992a). movement. A fault includes main, branch, or
secondary faults.
In 1978, the USGS published a map series
identifying the location of Holocene faults in the Displacement is the relative movement of any
United States (Preliminary Young Fault Maps, two sides of a fault measured in any direction.
MF916). For an area where movement along a MQ QPR 503.21(e)l
Holocene fault has occurred since 1978, when the
maps were made, the owner/operator will need to Holocene time is the most recent epoch of the
conduct a geologic reconnaissance of the site and Quaternary period, extending from the end of
surrounding areas. The National Aerial the Pleistocene Epoch to the present. This is
Photographic Program/National High Altitude approximately the last 11,000 years. [40 CFR
Program (NAPP/NHAP) aerial photographs with 503.21(h)l
stereo coverage are a useful remote sensing aid
for delineating fault traces and Structural ^••••••••••••••••••••••••••••••••••B
lineaments. This series of aerial photography
provides coverage over most of the United States and is available through the USGS, EROS Data Center
(EPA 1992a). Tables 5-4 and 5-5 list sources of more information about fault areas.
Draft—March 1993 5-37
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
If the permit writer's information indicates a fault (or faults) is located within 915 meters (3,000 feet) of
the unit, he/she should specify that the owner/operator investigate further and determine the presence or
absence of any faults within 60 meters (200 feet) of the site. A fault may be located by performing one
or more of the following activities:
• Conducting a site walkover to detect any fault related phenomena, such as offset curbs or walls,
offset drainage channels, or fault scarps
• Conducting subsurface exploration, including drilling and trenching to locate fault zones and
evidence of faulting
• Trenching perpendicular to any fault or lineaments within 60 meters (200 feet) of the unit
• Determining the age of any displacements
• Constructing supporting maps and other analyses (EPA 1992a).
Displacement of surficial deposits across a fault may indicate that such displacement has occurred in
recent times. In addition, seismic epicenters recorded in recent times may indicate recent movement or
activity along structures in a given area. The results of the investigation should be prepared by a
qualified professional. Data that should be contained in the report are:
• A plan view of any faults within 915 meters (3,000 feet) of the site
• A map showing all faults within 60 meters of the site boundary and identification of faults that
have had movement during the Holocene epoch
• A site topographic map of sufficient detail to show any offset streams, linear ridges, fault scarps,
and other horizontal features
• A description of geology with respect to stratigraphy (e.g., comparison of soils across a fault)
which can determine the fault's age.
Permit Conditions
If an active sewage sludge unit is not located within 60 meters (200 feet) of a fault that has displacement
in Holocene time, the permit writer does not need to place any conditions addressing this Part 503
requirement in the permit.
If an active sewage sludge unit is located within 60 meters of a fault that has displacement in Holocene
time, the permit writer must require the unit to be closed, if he or she cannot conclude that continued
operation of the sewage sludge unit is protective to human health and the environment. If an active
sewage sludge unit is not located within 60 meters of a fault that has displacement in Holocene time, but
is located within 915 meters (3,000 feet) of a fault that has displacement in Holocene time, the permit
writer should require that the owner/operator hire a qualified professional trained in seismic area/fault
location to investigate. Additional requirements that the permit writer could include are: (1) a
requirement to map all fault traces within 915 meters; (2) a requirement that all engineered structures
must be at least 60 meters from any fault; or (3) a requirement to submit a site engineering plan that
contains the investigative report and mapping of all faults.
Draft—March 1993 5-38
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
The permit writer should be aware that some States may have more stringent siting standards. The permit
writer may need to consult with state agencies in developing any specific conditions.
s
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-
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-
-
'•-••'•''','•*•.*
SAMPLE PERMIT CONDITIONS FOE LOCATING UNITS m
METE1S OR MO1E FROM A FAULT
1. Active sewage sludge unit(s) shall not be located within a 60-meter (200-foot)
distance of a fault with movement in the Holocene epoch.
2. If an active sewage sludge unit is located within 60 meters (200 feet) of a fault, that
unit shall begin closure within month(s) of the effective date of the permit.
The unit shall complete closure within (months) of the effective date of the
permit.
r-
The permit writer may want to attach a diagram ^ui r
locating the units that must be closed.
3. All site structures and active sewage sludge units located within 60 meters of a fault
shall be designed to meet or exceed all local and State earthquake design guidelines,
codes, or regulations.
4. The permittee shall conduct an investigation of the integrity of the unit within
(days, month(s)) of any known seismic activity occurring within a (distance)
radius of the sewage sludge unit.
, "
-
-'
5.6.5 UNSTABLE AREAS
Statement of Regulations
§503 J4(e) An active sewage sludge unit shall not be located in an unstable area.
Purpose: To prohibit locating an active sewage sludge unit in an unstable location prone to destabilizing events
that would damage the structural components of the unit, particularly the foundation.
Applies to: All active sewage sludge units.
Draft-March 1993 5-39
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Unstable area is land subject to natural or
human-induced forces that may damage the
structural components of an active sewage
sludge disposal unit. This includes, but is not
limited to, land on which the soils are subject
to mass movement. [40 CFR 503.2 l(q)J
Unstable areas have features that indicate
protective measures cannot be designed to
withstand a natural event. Examples of
unstable areas are: areas within 60 meters of
a fault, karst terrains, fissures, surface areas
weakened by underground mining or other
excavations or oil, gas, or water withdrawals,
and areas near volcanoes.
Permitting Factors
The permit writer should be able to recognize
unstable areas such as landslide-prone areas, karst
terrain, volcanic regions, areas that overlay
extensive underground mining operations, and
areas that overlay oil, gas, or water withdrawal
operations. As part of the permit application or
as a permit condition, the owner/operator should
certify that an active sewage sludge disposal unit
is not located in an unstable area. The permit
writer may want to require the owner/operator to
conduct an engineering assessment if the unit is
located in a potentially unstable area. This
assessment should be performed by a qualified
engineering professional and should contain the
following information:
• A detailed geotechnical and geological HMIMHBHHIBHBBIHBIIiHHHaHiBIHIHMHBHaMBM>BHi
evaluation to assess the stability of the
foundation soils, adjacent man-made and natural embankments, and slopes
• A geotechnical evaluation of the ability of the subsurface to support the active sewage sludge unit
adequately, without damage to the foundation or other structural components.
Landslide-Prone Areas
Landslides are a problem that can be remedied with varying degrees of success. Recognizing areas
susceptible to downslope movements is important to design considerations. Many features are unstable
when combined with seismic impact zones, such as liquefaction potential and slope failure. The type of
slope material determines the earthquake resistance of the slope. The permit writer should require the
owner/operator to assess the slope materials in areas subject to seismic activities. Slope stability maps
should be available from State geological surveys: Slope materials vulnerable to earthquake shocks
include:
• Very steep slopes of weak, fractured and brittle rocks or unsaturated loess which are vulnerable
to transient shocks caused by tensional faulting
• Loess and saturated sand which may be liquefied by seismic shocks causing the sudden collapse
of structures and flow slides
• Sensitive cohesive soils when natural moisture exceeds the soil's liquid limit
• Dry cohesion-less material on a slope at the angle of repose which will respond to seismic shock
by shallow sloughing and slight flattening of the slope (Winterkorn and Fang 1975).
Draft—March 1993
5-40
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Where the active sewage sludge units are comprised of the above types of slope materials, the permit
writer should require closure of the units in areas where seismic activities occur.
Slope failures occur when the driving forces imposed on the soils or engineered structure exceed the
resisting forces of the material. Such a slope failure often occurs in the absence of seismic activity. Non-
seismic slope failure can be caused by:
• Excessive rainfall on steep slopes
• Removing the toe (downslope edge) of a slope
• Overloading a slope
• Removing vegetation from a slope.
The site can be evaluated by a site walkover during which the permit writer looks for evidence that may
indicate a potential landslide problem. Specific features to look for include:
• Retaining walls, fences, and posts that are aligned in a uneven pattern
• Utility poles with taut or sagging wires
• Hummocky or step-like ground features
• Seeping water from the base or toe of a slope.
A computer software package and technical manual, Geotechnical Analysis for Review of Dike Stability
(GARDS), developed by EPA's Risk Reduction Engineering Laboratory (RREL), can assist permit writers
and designers in evaluating earth dike stability. GARDS details the basic technical concepts and
operational procedures for the analysis of site hydraulic conditions, dike slope and foundation stability,
dike settlement, and liquefaction potential of dike and foundation soils. The program was designed as
a geotechnical support tool to facilitate evaluation of existing and proposed earthen dike structures at
hazardous waste sites (EPA 1988b). The GARDS concepts also apply to sewage sludge disposal units.
If an area is considered unstable because of landslide,potential, engineering designs are available to
stabilize slopes. While these methods cannot be unconditionally guaranteed, they have been successful
in different regions. Methods for slope stabilization include:
• Regrading the slope profile
• Seepage and ground-water control
• Use of retaining structures.
Draft-March 1993 5-41
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Flattening and/or benching of the slope or adding material at the slope's toe may sufficiently enhance
stability. Surface control of drainage to decrease infiltration may reduce the potential for mud and debris
slides in some areas. Lowering the ground water table may also have stabilizing effects. Walls or large
diameter piling can be used to stabilize a slide of relatively small dimension or to retain steep toe slopes
so that failure will not extend into a larger mass. The design plans for the site should include this type
of information.
Other potential procedures for stabilizing natural and man-made slopes are:
• Geotextiles and geogrids to provide additional strength
• Wick and toe drains to relieve excess pore pressures
• Grouting, and vacuum and wellpoint pumping to lower ground water (EPA 1992a).
During construction and operation, monitoring of slope stability may be appropriate as additional stresses
on natural and engineered soil systems (e.g., slopes, foundations, and dikes) are exposed by excavating
and filling activities.
The permit writer should include monitoring activities that may indicate potential problems. Monitoring
parameters may include settlement, lateral movement and pore water pressure. Monitoring for pore water
pressure usually is accomplished with piezometers screened in the particularly sensitive strata. Lateral
movements may be detected on the surface by surveying (horizontal and vertical) movements while
subsurface movements may be detected by slope inclinometers. Settlement may be monitored by
surveying benchmarks.
Karst Terrain '
Karst terrains are subject to progressive and/or catastrophic failure of subsurface conditions from sink
holes, solution cavities, and subterranean caverns. When an active sewage sludge unit is located in a
karst area, the permit writer may require that the owner/operator document engineering measures that
ensure that the unit will have sufficient ground support. The permit writer should require that this
information be retained at the facility.
The subsurface should be characterized before starting construction in a karst terrain. Subsurface karst
structures may have surface topographic expressions, such as circular depressions over subsiding solution
caverns. Geophysical techniques, such as electromagnetic conductivity, seismic refraction, ground
penetrating radar, gravity, and electrical resistivity, may be used to characterize the subsurface.
Interpretation and applicability of different geophysical techniques should be reviewed by a qualified
geophysicist. Often more than one technique should be employed to confirm and correlate findings and
anomalies. Subsurface borings may also provide the only reliable method to identify the occurrence,
depth and size of solution cavities that pose a potential for catastrophic collapse (EPA 1992a).
Additional information on karst conditions can come from remote sensing techniques, such as aerial
photograph interpretation. Surface mapping of karst features can help to provide an understanding of
structural patterns and relationships in karst terrains. An understanding of local carbonate geology and
stratigraphy can aid in the interpretation of both remote sensing and geophysical techniques.
Draft-March 1993 5-42
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
The following engineering controls may mitigate a.karst terrain problem:
• Surface water control and conveyance to mitigate the solution rate of near-surface carbonate
structures (limestone)
*
• Structural replacement or filling of karst voids
• Excavating loose soils overlying limestone
• Grouting cavities with cement or other material
• Filling sinkholes and monitoring sinkhole collapse rates
• Deep dynamic or vibro-compaction of loose granular overburden soils (EPA 1992a).
In addition, the facility may use reinforce concrete mats or other construction techniques to strengthen
the unit's components. However, since catastrophic failures such as sink hole collapse are difficult to
predict, it is preferable to avoid construction of active sewage sludge units over karst conditions with the
potential for uncontrollable or catastrophic failure (EPA 1992a).
Underground Mining Operations
Areas with extensive underground mining operations are subject to catastrophic failures and subsidence
in a manner similar to karst terrains. Some mining operations'may weaken the structural support for the
overlying strata. In extreme cases, roof collapse of the mine could cause a catastrophic failure of any
overlying engineered structures. Mine grouting or filling actions may not be feasible due to the
uncertainty in the volume that is required to successfully fill the void and the interconnections between
mines and breached barrier pillars. State mining departments can be contacted to obtain mine maps.
Streets or roads located over land subject to underground mining operations that have a wavy, uneven
pitch are good indicators of subsidence.
Oil, Gas, and Water Withdrawal Operations
Oil and gas operations and/or water pumping operations can lead to locally developed subsidence
condition that can damage structural components. Oil and gas extraction subsidence tends to be more
localized than subsidence due to water pumping operations. Subsidence due to oil and gas and/or water
pumping operations occasionally can be reversed. To do this, water is injected into a formation which ,
raises the fluid pressure in the formation.
Permit Conditions
Where a surface disposal site is located in an unstable area, the permit writer should develop a permit
condition that prohibits the siting of any new active sewage sludge units in unstable areas. Where an
existing unit is located over potentially unstable areas (such as karst topography or landslide-prone areas),
the permit writer should require the owner/operator to submit a detailed geotechnical and geological
evaluation of the area and an engineering analysis of the design measures to ensure that the unit has
Draft-March 1993 5-43
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
sufficient ground support to withstand any ground movement that could rupture the unit's integrity and
cause an environmental release of the sewage sludge pollutants. These investigations should be performed
by qualified ground-water and engineering professionals. Existing active sewage sludge units located in
unstable areas that are not (or cannot be) designed with sufficient protection against ground movement
must be closed by March 19, 1994.
SAMPLE PEMMFF CONDITIONS FOR UNSTABLE AREAS
1. The surface disposal site or active sewage sludge unit(s) shall not be located in
unstable areas.
The permit writer will need to define unstable areas
using the criteria presented in this section.
2. The permittee shall notify the permitting authority of any natural or man-made
activity that may create an unstable area which has or could adversely affect the
structural integrity of the sewage sludge unit.
-
5.6.6 WETLAND PROTECTION
Statement of Regulation
§503.24(0 An active sewage sludge unit shall not be located in a wetland, except as provided in a permit
issued pursuant to section 402 or 404 of the CWA.
Purpose: To discourage future siting of sewage sludge surface disposal sites in wetlands and to close sites that are
located in wetlands that may cause adverse effects to human health and the environment and damage these
ecologically sensitive areas so that they no longer can function as wetlands. Siting of an active sewage sludge unit
in a wetland can be allowed only if the surface disposal site has obtained and is in compliance with a dredge and
fill permit under Section 404 of the CWA or an NPDES permit under Section 402 of the CWA.
Applies to: All active sewage sludge units that are currently located in a wetland or that are proposed to be located
in a wetland. This requirement applies to both the sewage sludge unit and the owner/operator of the surface
disposal site.
Draft-March 1993
5-44
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Permitting Factors
EPA, the Army Corps of Engineers (COE), and ™
FWS have identified wetlands protection as a top
priority. Constructing and operating surface
disposal sites in wetland areas is essentially a fill
activity; therefore, this activity has the potential to
significantly alter the structure and function of a
wetland. Once damaged by fill activities, wetland
ecosystems are difficult or impossible to restore
because of their complexity and fragility.
Proposals to locate surface disposal sites in
wetlands should undergo rigorous demonstration
requirements to establish that there are no suitable
alternative locations. COE is the Federal agency
with jurisdiction for issuing permits to entities •
proposing fill activities in wetlands. Fill activities
in wetland areas are regulated by the COE and EPA
States also regulate activities in wetlands.
If wetlands are within the surface disposal site
boundary and the owner/operator plans to
locate an active sewage sludge unit within a
wetland, the owner/operator must apply for and
receive a Section\404 permit from the Army
Corps of Engineers. If an active sewage
sludge unit is currently located in a wetland,
the owner/ operator should produce a valid
Section 404 permit or a NPDES permit to
demonstrate compliance with this regulatory
provision.
under Sections 404 and 402 of the CWA. Many
Any active sewage sludge unit located in a wetland and not covered by a valid Section 402 permit must
be closed in accordance with §503.22(b) by March 19, 1994. An owner/operator of a surface disposal
facility that is planning construction or opening of a new active sewage sludge unit must determine
whether or not the proposed location or construction activity is subject to Section 404 and obtain a
Section 402 or Section 404 permit, if applicable, prior to project initiation.
To implement §503.24(f), the permit writer first needs to know if the surface disposal site or any active
sewage sludge units are or will be located within a wetland. As part of the permit application, the permit
writer should receive information as to whether the surface disposal site is located in a wetland. If this
information is not provided, the permit writer should require the owner/operator of the surface disposal
site to indicate whether it holds or is applying for a valid Section 404 or 402 permit.
If the permittee does not have a Section 404 or
402 permit, the permit writer needs to determine
(or require the owner/operator to certify) whether
there is a wetland onsite. Wetlands are identified
on the basis of soil conditions, vegetation type,
and site hydrology. They are typically found
along the fringe of waterbodies. Some types of
wetlands such as prairie potholes, vernal pools,
and cypress domes are not directly associated with
surface water, but are found in surface
depressions in the land. These depressional
wetlands can be particularly difficult to identify
because they are usually dry for a portion of the
year. If the permit writer or the owner/operator
suspects that there are wetlands on the site where
Definition of Wetlands
Wetlands are areas that are inundated or
saturated by surface water or ground water at
a frequency and duration sufficient to support;
and that under; normal! circumstances; :ilQ:
support, a prevalence of vegetation adapted fpir
growth in water or wet soil. Wetlands include,;
but are not limited to, swamps, marshes, bogs,
prairie pot holes, playa basins, and similar
areas. [40 CFR 503.9(bb)]
Draft-March 1993
5-45
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
active sewage sludge units are or may be located, he/she should contact the local COE District Office and
request a wetland delineation.1 A list of the District Offices and their address is published annually in
33 CFR Part 330. Additionally, any State agency that regulates activities in wetlands should be contacted
and invited to inspect the location of a surface disposal site.
A wetlands assessment should be conducted by a qualified and experienced multidisciplinary team with
a soil scientist and a botanist or biologist. The assessment identifies: (1) the limits of the wetland
boundary based on soil and plant types, (2) the type and relative abundance of vegetation including trees,
and (3) rare, endangered, or otherwise protected species of flora and fauna and their habitat (EPA 1992a).
Criteria used in wetlands identification have been developed by a task force consisting of representatives
from the EPA, FWS, Soil Conservation Service, and COE and are presented in the Federal Manual For
Identifying and Delineating Jurisdictional Wetlands (COE 1989). This publication also contains an
extensive list of literature available on identification and prevalence of plant species characteristic of
wetlands throughout the United States, hydraulic soil classifications, and related wetland topics (EPA
1992a). Additional published information useful to the permit writer in identifying areas that are wetlands
is listed in Table 5-6. If it is determined that wetlands are at the surface disposal site and the site does
not have a Section 404 or 402 permit, the permit writer should require the site or active sewage sludge
unit to close.
TABLE 5-6 SOURCES OF INFORMATION TO IDENTIFY WETLANDS
Federal Manual For Identifying and Delineating Jurisdictional Wetlands (COE 1989)
USGS topographic maps
National Wetland Inventory (NWI) Maps
Soil Conservation Service (SCS) soil maps
Local wetland inventory maps
If the owner/operator has a Section 402 or 404 permit, the permit writer should require the owner/
operator to demonstrate that the site is in compliance with the permit. The permit writer can contact the
Section 404 permitting authority and inquire about the permittee's compliance status. If the site is not
in compliance with its Section 404 or 402 permit, the permit writer, working with the Corps of
Engineers, should determine whether the site or active sewage sludge unit(s) should be closed.
Permit Conditions
If there are wetlands at the surface disposal site, it may be appropriate to include a permit condition
requiring compliance with the Section 404 permit or to incorporate the Section 404 permit into the
'The definition and regulatory strategy for wetlands is currently being reevaluated at the Federal level and may
be revised.
Draft-March 1993 5-46
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
NPDES permit by reference, if the site has a NPDES permit. If the wetland assessment indicates that
there are no wetlands on the property, then the permit writer may either disregard this provision or
include, as a general prohibition, that no future expansions of the surface disposal site may be located
in wetlands, unless authorized in a permit issued pursuant to Section 402 or 404 of the CWA.
,••
SAMFLE PERMIT CONDITIONS FOR
WOTLANDS FKUTECTIUN
1. The permittee shall comply with the conditions in a Section 404 permit from the
Army Corps of Engineers.
The permit writer may require the permittee to provide
a copy of the Section 404 permit.
2. The permittee shall monitor the water quality of the wetland at a frequency of
per (day, week, month) for the following parameters
.
3. If the wetland is found to have sustained degradation, the permittee shall contact the
permitting authority within days of knowledge of the adverse impact.
4. Upon knowledge of any adverse impact to the wetland, the permittee shall cease
sewage sludge placement activities at the disposal site. The permittee shall initiate
whatever actions are necessary to mitigate or correct adverse impact within
[time frame].
..
5.6.7 STORM WATER RUN-OFF MANAGEMENT
Statement of Regulations
§503-24(g)(l) Run-off from an active sewage sludge unit shall be collected and shall be disposed in accordance
with National Pollutant Discharge Elimination System permit requirements and any other
applicable requirements
§503 J4{g)(2) The run-off collection system for an active sewage sludge unit shall have the capacity to handle
run-off from a 24-hour, 25-year storm event.
Purpose: To prevent contamination of surface water caused by run-off from active sewage sludge units. The
requirement that the run-off collection system have the capacity to handle the run-off from a 24-hour,.25-year storm
event is provided to be consistent with other regulatory requirements for both municipal solid waste landfills (40
CFR Part 258) and hazardous waste landfills (40 CFR Part 264).
Applies to: All active sewage sludge units.
Draft-March 1993
5-47
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
Permitting Factors
Storm water run-off is a point source discharge ^"••"^^••'^•^••••^•^^""•••••••^™
regulated by the NPDES program. The run-off Run-off is rainwater, leachate, or other liquid
collection system from an active sewage sludge ^^ drains overland on any part of a land
unit must have the capacity to handle the water surface and runs off of the land surface. [40
volume generated from a 24-hour, 25-year storm. CFR 503.9(v)l
A 25-year storm is a storm event with a
frequency of occurrence of 25 years. •••^•••••^•••••••••••••••••MBiMi
Control of surface run-off can be accomplished in the following ways: (1) by minimizing water that
enters the active sewage sludge units (i.e., run-on controls); (2) by minimizing the size and number of
active sewage sludge units in a surface disposal site; (3) by preventing the disposal of sewage sludge with
low solids content; and (4) collecting and managing the run-off.
The permit writer should determine whether appropriate controls and capacity for collecting and
controlling a 24-hour, 25-year storm have been incorporated into the design of the surface disposal site.
Therefore, brief descriptions of how to calculate the water volume generated by storm events and the
different types of controls that may be used are provided below to aid the permit writer in making this
determination.
Design for 24-Hour, 25-Year Storm
The typical approach to designing run-on/run-off controls includes the following:
• Identifying the intensity of the design storm
• Determining peak discharge rates
• Calculating the run-off volume during peak discharges
• Designing the controls.
Site-specific design storm information is generally obtained from local planning agencies, civil works
departments, or local zoning boards. The most accurate determination of the design storm uses
precipitation from at least the past 25 years. The permit writer may wish to verify the information used
by the owner/operator by referring to a publication entitled "Technical Paper 40, Rainfall Frequency
Atlas of the United States for Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100
Years" prepared by the National Weather Service of the Department of Commerce (1963) for the eastern
and central United States. In western states, the permit writer should refer to the "NOAA Atlas 2,
Precipitation Frequency Atlas of the United States" prepared by the National Oceanic and Atmospheric
Administration of the Department of Commerce (1973).
To determine peak run-on/run-off flows, a designer most commonly uses one of two methods (although
others are available). One method is the Soil Conservation Service (SCS) Method (USDA 1986). This
model assumes that the rate and amount of rainfall is uniform throughout the watershed over a certain
Draft-March 1993 5-48
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
amount of time. The rainfall run-off volume is estimated from cumulative rainfall data by using a
typified unit hydrograph. This allows the estimation of both peak discharges and total run-off
hydrograph. Run-off curves used in this methodology have been developed to account for the effects of
soils, plant cover, amount of impervious areas, interception, and surface storage. Another method, the
Rational Method, assumes that maximum run-off, resulting from uniformly intense precipitation, will
occur when the entire watershed upstream of the site location contributes to the discharge (Dunne et. al.
1978). Details of these methods can be found in many common references and textbooks.
The permit writer may request calculations for the determination of peak flow and run-off volume
associated with the 25-year, 24-hour storm from the owner/operator in order to ensure that the
appropriate storm volume has been considered in sizing the run-off controls and collection systems. The
owner/operator must design the controls and collection systems for at least the volume of storm water
produced by the 25-year, 24-hour storm. If the area is located within an area subject to flooding, the
owner/operator of the site may need to design controls that address flooding and a higher volume of
storm water than the 25-year, 24-hour storm would produce (see Section 5.6.2).
The permit writer will need to review the storm water run-off management information provided by the
owner/operator to determine that:
• All the storm water controls and collection systems for the active sewage sludge units or the
entire surface disposal site are sized appropriately for the storm water magnitude of a 24-hour,
25-year storm event
• The calculation of run-off volume used to size the controls is correct
• The run-off is collected and disposed of properly in accordance with an NPDES or other permit.
Run-on/Run-off Storm Water Controls
Often, the most economical designs for collecting and controlling storm water discharges include run-on
controls as well as run-off controls to prevent additional storm water from becoming contaminated and
to minimize the amount of water that must be collected and treated. Both run-on and run-off controls
are generally used in partnership and they will both be discussed. The permit writer should remember,
however, that run-on controls are not required specifically by Part 503.
Run-on and run-off control structures, whether temporary or permanent, can be incorporated into the
surface disposal site design. Because of the variety of types of controls, specific design considerations
are beyond the scope of this document, and only a brief description of the more commonly used control
structures is presented in Table 5-7. The permit writer can use the information in the table to review a
choice of controls for a site and to determine which aspects of the design may need additional conditions
in the permit to ensure proper collection and disposal of the storm water.
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-7 TYPICAL RUN-ON/RUN-OFF CONTROL BEST MANAGEMENT PRACTICES
Control
Dikes and Berms
Drainage Swales,
Channels and
Waterways
Description
Dikes and berms are
compacted ridges or
ledges, generally
earthen, constructed
immediately upslope
or around the
perimeter of an active
sewage sludge unit.
Drainage swales,
channels and
waterways are
drainage ways
installed to collect
and convey the flow
of storm water run-off
in a manner that does
not contribute to
erosion.
These controls can be
temporary or
permanent and can be
lined with vegetation,
rip rap, asphalt,
concrete, or other
materials.
Purpose/
Function
Diverts
uncontaminated storm
water around the site
to natural or
manmade drainage
channels, manmade
outlets, or
sedimentation basins.
Dikes can be used as
interceptors to reduce
slope lengths,
minimize erosive
forces, and divert the
run-off away from a
source of
contamination.
Cross-sections vary
and can be
trapezoidal, triangular
or parabolic.
Generally swales
have a less steep
cross section and
when vegetated may
promote infiltration
of some of the storm
water discharge;
however, they are
appropriate only for
uncontaminated
discharges.
Maintenance
Relatively
impermanent. Must
be inspected
regularly, especially
after heavy storms to
maintain their
integrity. Typically,
dikes and berms are
reconstructed yearly.
Should be inspected
to remove debris
within 24 hours of
rainfall, or daily
during periods of
prolonged rainfall.
Drainages to
conveyances should
be repaired as soon as
possible.
Special (Design)
Considerations
Construction is
simple and typically
designed from
standard
specifications.
Design of drainage
swales, channels and
waterways must
consider the local
drainage patterns,
soil permeability,
annual precipitation,
area land use, and
other characteristics
of the watershed
contributing to the
run-off.
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-7 TYPICAL RUN-ON/RUN-OFF CONTROL BEST MANAGEMENT PRACTICES
(Continued)
Control
Terraces and
Benches
Chutes and Down
Pipes
Seepage Drains
and Ditches
Description
Terraces and benches
are earth
embankments or ridge
and channels
constructed along the
contour of a steep
slope, generally one
with no vegetation
and with a water
erosion problem.
Specifically, chutes
are excavated earthen
channels that have
been lined with non-
erodible materials.
such as bituminous
concrete or grouted
riprap. Down pipes
are rigid or flexible
piping that has been
installed.
A seepage basin
typically consists of
the actual basin, a
sediment trap, and a
bypass for extra flow
and emergency
overflow.
Purpose/
Function
Diverts storm water
run-off away from
steep slopes where
erosion may occur.
Also minimizes
erosion by reducing
both the length of a
slope and the velocity
of the run-off. The
permit writer will
want to ensure that
any contaminated
discharges are
diverted to an
appropriate outlet
which leads to a
discharge that is in
compliance with an
NPDES permit.
Chutes and down
pipes carry run-off to
the bottom of a slope
so that erosion is
prevented while the
disposal unit is
inactive and covers
have been
constructed, yet
stabilization of the
surface has not been
completed.
Seepage drains and
ditches provide in-situ
treatment and
recharge to ground
water. Not
appropriate for
contaminated run-off
and should not be
used for discharges
from active surface
disposal units. Most
effective in highly
permeable soils and
typically are used in
areas where the water .
table is close to the
surface.
Maintenance
Should be inspected
at least once a year
and after major
storms.
Must be inspected on
a regular schedule
and after major
storms to promptly
clear clogged pipes.
Drains and ditches
must be inspected
regularly for pipe
breaks or clogging
debris in ditches.
Special (Design)
Considerations
Must be designed
with adequate outlets,
such as a grassed
waterway, vegetated
areas, or tile outlet.
Should not be
constructed on slopes
with sandy or rocky
soils.
The maximum
recommended
drainage area for a
chute and down pipe
is approximately 10
acres.
If contaminated
discharges could be
directed to a seepage
drain or ditch, the
permit writer should
consider adding a
permit condition to
ensure compliance
with the requirements
that the discharge
from a 24-hour, 25-
year storm be
disposed in
accordance with an
NPDES permit.
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5-51
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5. SURFACE DISPOSAL - 40 CFR PART 503 SUBPART C
TABLE 5-7 TYPICAL RUN-ON/RUN-OFF CONTROL BEST MANAGEMENT PRACTICES
(Continued)
Control
Sedimentation
Basins
Surface
Roughening
Description
Major components
include a principal
and emergency spill
way, an anti-vortex
device, and the basin.
Sedimentation basins
often serve as the last
step in the collection
of storm water run-off
from a site.
Soil is roughened by
the creation of
horizontal grooves,
depressions, or steps
that run parallel to the
contour of the land.
Purpose/
Function
Sedimentation basins
detain run-off so that
settling of suspended
solids can occur.
They also store storm
water run-off so that
the discharge can be
released at a slower
rate. Sedimentation
basins can be
constructed by
excavation or by
placing an earthen
embankment across a
low area or drainage
swale.
This practice reduces
erosion on steep
slopes. It slows run-
off, increases
infiltration, traps
sediment, and helps
establish vegetative
cover.
Maintenance
Maintenance is
imperative to provide
the designed capacity
for storage. If the
basin becomes filled
with sediments, the
capacity will be
lessened. Inspections
are also important to
make sure the
embankments are
stable and that the
outlet is not clogged
with trash or other
debris.
Should be seeded as
soon as possible.
Regular inspections
should be made,
especially after
storms. Rills should
be filled, graded, and
reseeded.
: Special (Design):
Considerations
The permit writer
should assess the
need for specific
permit conditions
addressing sediment
basins.
The surface grade
should be greater
than 2 percent to
promote collection of
the run-off and
inhibit ponding but
less than 5 percent to
reduce flow velocities
and to minimize soil
erosion.
Source: Extracted from Dunne & Leopold (1978), EPA (1992a).
Maintenance and Inspections
One aspect of the controls and best management practices (BMPs) that the permit writer may want to
evaluate is operation and maintenance. Often controls and BMPs require specific maintenance activities.
Some are considered temporary and will need to be maintained and rebuilt on a regular basis if disturbed
due to storm water or other activities. The permit writer will want to ensure that the appropriate
maintenance activities are being performed at the facility so that the controls and BMPs maintain their
ability to collect the volume of run-off from the 24-hour 25-year storm. The permit writer may request
inspection and maintenance schedules from the owner/operator and incorporate these schedules in the
permit. Inspections should be made monthly and after every storm event that is of a measurable size.
A measurable storm event is often defined as having 0.1 inch of rainfall.
Erosion and Sedimentation Best Management Practices
Although not specifically required, the permit writer may wish to address other BMPs or run-off control
measures in the permit. Conditions for minimizing erosion and sedimentation at surface disposal sites
where large areas of land are disturbed may be appropriate. For more information on the erosion and
Draft-March 1993
5-52
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5. SURFACE DISPOSAL - PART 503 SUBPART C
sedimentation BMPs, see EPA's "Storm Water Pollution Prevention for Industrial Activities" (EPA
1992b).
Permit Conditions
If the site is located within an area subject to flooding, the permit writer may want to put special
conditions in the permit for the facility to be able to retain a higher volume of storm water. The permit
writer may also establish permit conditions for inspection and maintenance of the storm water run-on
controls. Provided below are examples of conditions dial may be included in a permit to control storm
water run-off and run-on.
-
1. The permittee shall design, construct and operate appropriate run-off controls to
convey and collect the volume of storm water resulting from the 24-hour, 25-year
storm.
The permit writer may specify the exact controls to be
used on site, or if the permittee has submitted
appropriate plans and specifications for run-off
controls, the permit may refer to them instead.
2. The permittee shall inspect and maintain run-off controls to ensure that the design
capacity of the collection system and holding facilities is sustained. The inspection
and maintenance activities must be performed at an interval as specified in an
approved inspection and maintenance schedule.
The
maintt
(e.g.,
holdin
3. Any deteriorati
(hour
malfunction to t
permit writer may specify exactly what
;nance would be required on a regular basis
sediment removal from sediment basins or
g ponds).
Dn or malfunction of the run-off controls shall be repaired within
s, days, weeks) of the inspection which brought the deterioration or
he attention of the inspector.
-
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5. SURFACE DISPOSAL - PART 503 SUBPART C
4. The permittee shall discharge the storm water run-off in accordance with the terms
and conditions of an NPDES storm water discharge permit.
5.
7.
The facility may already have an NPDES storm water
discharge permit or must obtain one to discharge
storm water that flows across the surface disposal site.
This permit may be in the form of an individual
permit or a general permit.
The flow of any discharges from the storm water run-off collection system shall be
measured. The permittee shall sample the discharge from the storm water run-off
collection system at a frequency of for the following parameters:
. The discharge shall not exceed the following limits.
The permit writer should develop the above conditions if
they are not maintained in an NPDES storm water
discharge permit.
6. The permittee shall identify areas which, due to topography, activities, or other
factors, have a high potential for significant soil erosion and implement structural,
vegetative, and/or other stabilization measures to limit the erosion.
The permit writer should develop permit conditions for
sites that have the potential for erosion (i.e., sites with
steep slopes, high run-off velocities). The conditions can
be general as above or can specify the type of
stabilization needed. , . ..
All run-on/run-off flow shall be retained in a collection system. The collection
system shall be designed to retain a volume of . Sediment shall be
removed from the system as necessary to maintain the design retention time.
The permit writer may want to specify the type of
collection system .that the permittee willbe using; for
example, a seepage basin for ground-water discharge or
a sedimentation basin.
Draft-March 1993
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5. SURFACE DISPOSAL - PART 503 SUBPART C
5.6.8 LEACHATE COLLECTION AND DISPOSAL
Statement of Regulations
§503J4(h) The leachate collection system for an active sewage sludge unit that has a liner and leachate
collection system shall be operated and maintained during the period the sewage sludge unit is
active and for three years after the sewage sludge unit closes.
§503.24{i) Leachate from an active sewage sludge unit that has a liner and leachate collection system shall
be collected and shall be disposed in accordance with the applicable requirements during the
period the sewage sludge unit is active and for three years after the sewage sludge unit closes.
Purpose: To protect the ground water by ensuring proper operation and maintenance of the liners and leachate
collection systems of active sewage sludge units.
Applies to: All active sewage sludge units that have liner and leachate collection systems. These requirements
apply during the period the sewage sludge unit is active and over a period of three years after the sewage sludge
unit closes.
Permitting Factors
In order to implement these requirements, the permit writer must draft permit conditions that require the
owner/operator of a surface disposal site to:
• Operate and maintain the leachate collection system during the active life of the sewage sludge
unit and for three years after the unit closes
• Collect and dispose of the leachate properly.
The permit writer should request that the owner/operator describe the leachate collection system and the
provisions made for operating and maintaining the system while the sewage sludge units are active and
for at least three years after closure. This information may be supplied by the owner/operator in the
permit application.
In order to evaluate the data furnished by the owner/operator and develop adequate permit conditions,
permit writer will need to be familiar with the design and operation of leachate collection systems. The
following technical guidance introduces the permit writer to leachate collection systems and to the options
available for treatment and/or disposal of leachate.
Leachate Collection System
When a liner is included in the design of a surface "^"^^•^^^^^^^^^^™
disposal site to protect ground water, a leachate 'Leachate collection system is a system or
collection system should also be installed. A device installed immediately above a liner
leachate collection and removal system is installed mat is designed, constructed, maintained, and
under the sewage sludge unit to relieve hydraulic operated to collect and rerrioye leachate from
pressures within a lined sewage sludge unit. a sewage sludge unit. [4ad;R 503.210)]
Without a collection and removal system, the
leachate may accumulate and increase the mm^fmmmmmmmmmmmmimmmmmmmmmimiiiimmim
Draft-March 1993 5-55
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5. SURFACE DISPOSAL - PART 503 SUBPART C
possibility of its migration through the liner. Also, the leachate may back up in the unit and eventually
result in seepage at the surface.
Part 503 requires that the leachate collection system for an active sewage sludge unit that has a liner be
operated and maintained during the period the sewage sludge unit is active and for a period of three years
after the sewage sludge unit closes. The permit writer may want to evaluate the following three aspects
of the surface disposal site to determine if the permit for the surface disposal site needs to contain special
conditions for the operation and maintenance of the leachate collection system:
• Design of the system
• Operations
• Maintenance.
Each aspect is briefly discussed below.
Design
The design considerations for a leachate collection system for a surface disposal site are similar to those
for solid waste landfills. Each leachate collection system consists of the following components:
• A low permeability base (i.e., liner)
• A high permeability drainage layer of either natural granular material, such as sand and gravel,
or synthetic materials, such as a geonet. The drainage layer is placed either directly over the
liner or over a protective layer (e.g., filter fabric) of the liner
• Perforated leachate collection pipes within the high permeability layer to collect and convey the
leachate to the sumps where it can be removed
• A protective filter material that surrounds the pipe to prevent clogging of the pipes or
perforations
• A protective filter layer over the high permeability drainage material to prevent clogging of the
permeable layer by finer materials
• Leachate collection sumps or header pipe system where leachate can be removed
• Storage tanks or ponds for storage, treatment or disposal (EPA 1978, EPA 1988b)
At a minimum, the permit writer will want a description of the design of the leachate collection system
and the procedures for inspection, cleaning, maintenance, and operation of the system. Proper design
is crucial to the long-term reliability of the system, and the permit writer may consider evaluating certain
aspects of the design to ensure that proper operation and eas.y maintenance have been provided for. In
particular:
Draft—March 1993 5-56
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Sedimentation by granular drainage materials may clog pipes, and can be avoided by surrounding
pipes with filter fabric (EPA 1992a).
• Precipitation of dissolved ionic species may settle in, and. foul pipes; the system design should
prevent this by allowing for flow velocities that are high enough to provide a self-cleansing
action. These velocities depend upon the diameters and specific gravities of the particles, but
generally flows ranging from one to two feet per second are sufficient (EPA 1988b). the permit
writer may request documentation and calculations for the designed flow rates and flow volumes.
• Biological fouling can also occur, and for this reason the system should be designed to
accommodate pipe system cleanings as follows:
- A minimum of six-inch diameter pipe to facilitate cleaning
- Access points located at major pipe intersections or bends to facilitate inspections and cleaning
- Valves, ports, or other appurtenances to introduce biocides or cleaning solutions (EPA 1988b).
The strength of the structural materials and chemical compatibility between the materials and leachate can
affect the continued operation of the leachate collection system. The pipe materials should have the
strength required to withstand the loads of the wastes arid cover system of the surface disposal unit as
well as the loads required by the equipment during the unit's construction. The permit writer may want
to look at loading calculations to see that these loads were considered in the design.
Another design aspect is the size and construction of the pumps used, in particular:
• Sufficient capacity to ensure leachate removal at the expected rate of generation
i
• Sufficient operating head to lift the leachate to the required height from the sump to the access
point
• Resistance to corrosion
• Ability to perform during the three-year closure period.
Calculations and specifications should be available from the owner/operator that can verify these
considerations.
Draft-March 1993 5-57
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Operations
The leachate must be removed from the surface
disposal site, at a frequency dependent upon the
amount of liquid being generated at the site, and
then must be treated or disposed of. Usually,
leachate collection systems are designed to
maintain a certain level of leachate over the liner
and, correspondingly, removal of leachate at a
regular rate. The permit writer should develop
permit conditions requiring adherence to operation
schedules which ensure that the leachate is
removed at the designed rate. The permit writer
should also require the owner/operator to maintain
documentation that demonstrates leachate
collection, treatment and disposal. For example,
if the leachate is hauled off-site for treatment or
disposal, the volume of leachate hauled and the
dates that the leachate was hauled off-site should
be maintained by the owner/operator.
Clogging is the primary cause of concern in me
long-term performance of leachate collection
and removal systems. Clogging can occur by
the following means: (1) the sand filter can
clog the drainage gravel; (2) solid material in
the leachate can clog the drainage material or
geonet; and (3) solid suspended material in the
leachate can clog the sand filter or geotextile
fabric. Biological clogging arises from slime,
sheath formation, and biomass accumulation.
Inorganic clogging can be caused by cohering,
sulfide deposition and carbonate deposition.
For determining the potential for biological
clogging, a high biochemical oxygen demand
(BOD) in the leachate is a good indicator.
Operations at the site should allow for easy access to the removal points, whether they are sumps, or
tanks. Often access to the sumps is provided by either a solid pipe laid in a shallow trench along the
sidewalls or a vertical manhole that is constructed as the unit is filled (EPA 1988b).
Maintenance ,
Maintenance of the leachate collection system entails regular inspection and cleaning, including the
following:
• Maintenance of pumps
• Periodic flushing (or by cleaning by mechanical means) with biocides to remove deposited solids
and to prevent biological fouling
• Inspection of equipment and piping to detect clogging problems and or material failure.
Inspection and cleaning should be conducted periodically after the sewage sludge is placed in the unit.
To flush particulates and biological clogging, a low-pressure cleaning jet system is introduced into the
drains of the leachate collection system which dislodges the particles from the filter and drainage materials
(EPA 1983a). For biological growth, biocides can be introduced with the flushing water or added to the
system during manufacture.
Inspections are important aspects of any good operation and maintenance program. The intent of an
inspection is to determine if the system is in the process of becoming clogged or has clogged so that
maintenance procedures can be performed immediately or so that contingency plans can be set into action.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
A weekly inspection routine is recommended as well as inspections after large storm events. The
following components should be present in a good inspection program:
• Confirmation that leachate levels above the liner in the sewage sludge unit are equal to, or less
than, the design depth at all points
• Confirmation of the'depth of leachate in the collection sumps
• Confirmation that pumps and piping are in good operating order
• Recording of leachate depths and flow rates in all parts of the system.
Detailed inspection guidance is not feasible in this
document since there are many different types of
systems. The permit writer, when evaluating the
inspection, program provided by an owner/
operator, should ensure that the program has
provisions for what, where, why 'and how checks
will be made. Specific criteria that will trigger
corrective action should also be stated.
Disposal or Treatment of Leachate
Part 503 requires that the leachate from an active
sewage sludge unit that has a liner and leachate
collection system be collected and disposed in
accordance with the conditions of a National
Pollutant Discharge Elimination System permit
and/or other applicable requirements. This
requirement extends for the time that the sewage
sludge unit is active and for three years after the
unit is closed. Collected leachate may be treated ;; :; •
and/or disposed through one or more of the .••••^^••••^••••^^•••^^•••••^^™
following methods:
• Discharge or haul to a publicly owned treatment works
• On-site treatment and release to surface waters
• Off-site disposal.
The treatment or disposal option used by the owner/operator should be evaluated by the permit writer to
determine if appropriate requirements are being met or if special conditions for the disposal of the
leachate should be incorporated into the permit.
Leachate is the liquid that is generated in a
surface disposal unit due to: (1) percolation of
surface waters into the soil; (2) water content
of the sludge when disposed; (3) water
produced during decomposition of the sludge;
and (4) water migration from surrounding soils
and sludges. The leachate's quality varies;
depending upon the quality of the sludge.
Generally, leachate is high in biochemical
oxygen demand, organics and, sometimes, in
metals. Because of these characteristics,
leachate has the potential for causing adverse
conditions when discharged to surface or
ground water. Therefore, it is important to
treat and/or dispose of it properly so that it
does hot cause harm! to human health and the;
.:•: environment;
Draft—March 1993
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Discharge or Haul to a Publicly Owned Treatment Works (POTW)
If leachate is discharged directly to a POTW collection system or hauled to a POTW for treatment, the
owner/operator may be required to pretreat the leachate prior to discharging it into the treatment works.
In some cases, the leachate may need pretreatment for high organic and metals loadings. The permit
writer may request information from the owner/operator showing compliance with local requirements,
such as permits or other control mechanisms issued by the POTW as well as local ordinances. The
permit writer may contact the POTW directly for the compliance status on the surface disposal leachate
discharge.
On-site Treatment
Most commonly, on-site treatment of leachate consists of the following processes:
• Recycle through the sewage sludge unit
• Biological processes, both anaerobic and aerobic
• Physical-chemical treatment
• Evaporation in ponds.
A leachate recycling system can provide excellent treatment of the leachate because it promotes rapid
development of anaerobic decomposition. Unfortunately, this process is not feasible at most sites because
of high rainfall or high application rates. Leachate recycling is best when sewage sludge is co-disposed
with other wastes or in climates where the evaporation rate exceeds the rainfall rate (EPA 1978). Some
problems that have been associated with leachate recycling are: (1) an increase in leachate production,
(2) clogging of the leachate collection system, (3) buildup of the hydraulic head within the unit, (4) an
increase in odor problems, and (5) an increase in the potential of leachate pollutant releases due to runoff
(EPA 1988d). Some States are considering the ban of this process; the permit writer may wish to contact
the State or local control authorities to find out whether the method is acceptable for a site (EPA 1990).
Biological treatment processes include anaerobic filters, anaerobic sewage sludge bed reactors, aerated
lagoons, rotating biological contactors, and trickling filters. Physical-chemical systems include chemical
precipitation using lime and oxidation with calcium hypochlorite or ozone. Some systems may also
employ carbon adsorption. Evaporation ponds are shallow lagoons used in areas where the evaporation
rate is high. Ponds should be designed to provide ample capacity for storm water from a 25-year, 24-
hour storm event so that the pond does not get washed out during large storms and threaten surface
waters.
A surface disposal site is required to have an NPDES permit for any discharge of treated leachate to
surface water. If the site has an existing NPDES permit, the permit writer should evaluate provisions
in the permit to ensure that the site is in compliance. If the site is new, or does hot currently have a
NPDES permit, the permit writer should require the submittal of an NPDES permit application for a point
source discharge. The permit writer will need to develop appropriate permit conditions, effluent limits,
and monitoring and reporting requirements for the outfall.
Draft-March 1993 5-60
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Off-site Disposal
Where off-site disposal is practiced, the permit writer should request a detailed description of how the
leachate is collected and how it is transferred to the off-site disposal site. Also, the permit writer may
want to contact the off-site disposal facility to identify leachate disposal requirements and whether those
requirements are being met.
Permit Conditions
The permit writer will need to assess the operation and maintenance of the leachate collection system and
the current treatment or disposal system for the collected leachate. He/she should draft specific permit
conditions for such a system. When the permit writer determines that design, operation or maintenance
of the leachate collection system is inadequate, he/she should include a compliance schedule in the permit
to require the owner/operator to correct the inadequacies. The permit writer should develop permit
conditions focusing on these issues. For example, the permit writer could develop specific conditions
that require the owner/operator to conduct inspections of the leachate collection system and to maintain
documentation of these inspections.
If leachate goes to a POTW or is hauled off site for disposal, the permit writer may want to establish
permit conditions that require the owner/operator of the surface disposal site to comply with any
requirements imposed by the POTW or other off-site disposal facility.
Provided below are examples of conditions that may be included in a permit to regulate leachate
collection and disposal from a sewage sludge unit.
SAMPLE PERMIT COMMONS FOE LEACHATE
COLLECTION AN® BSSFOSAL
1. The permittee shall design, construct, maintain and operate a leachate collection
and removal system above the liner to collect and remove leachate from the sewage
sludge unit as prescribed in the attached plans and specifications labelled Exhibit A
in this permit.
1
The permit writer may want to specify more specific
design criteria in the conditions of the permit. The
following are examples.
i
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5. SURFACE DISPOSAL - PART 503 SUBPART C
2.
3.
4.
5.
6.
7.
8.
The permittee shall design, construct, maintain, and operate the leachate collection
and removal to maintain a leachate depth of feet over the liner.
The permittee shall design the leachate collection system with filter fabric
surrounding the collection pipes and appropriate velocities to prevent precipitation
from settling in the pipes. The system shall be designed to allow periodic pipe
system cleanings or flushings.
The permittee shall develop and implement an inspection and maintenance program
for the leachate collection and removal system. The program should include a
schedule of inspection and maintenance activities for pumps, piping and other
equipment and periodic flushing of the collection system, as appropriate. The
program will be subject to the approval of the permitting agency.
The permit writer may specify the frequency and
specific activities that must be performed if proper
operations depend upon specific maintenance activities
or the permit writer may simply reference to the plan
submitted by the permittee. Examples of more specific
conditions follow.
The permittee shall inspect the leachate collection and removal system on a
(daily, weekly) basis.
Inspections shall include confirmation of the following: leachate levels above liner
are equal to or less than the designed depth; depth of leachate in collection sumps
does not warrant more frequent removal rates; and mechanical equipment is in
good operating order.
The permittee shall maintain records of operation, inspection, and maintenance
activities for the leachate collection and removal system. Records of the operation,
inspection, and maintenance activities should be maintained onsite.
1
The permit writer may include the specific
requirements for what records are to be kept. The
following conditions are examples.
The permittee shall maintain records of all inspection activities including
documentation of the date and time of the inspection, depth of leachate in the
active sewage sludge unit, depth of leachate in sumps, and equipment checked.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
9.
Preventative maintenance activities shall be performed in accordance with
manufacturer's specifications and/or standard operating procedures. Other non-
scheduled maintenance activities shall be performed immediately upon identification
of a problem or as soon as possible thereafter.
i
Some sites may require
example is as follows:
even more specificity. An
10. Periodic flushing of the leachate collection and removal system shall be performed
on a basis.
11. The permittee shall store (on site) back-up leachate collection and removal
equipment for use in circumstances where the principal system is inoperable.
1, .
The permit
required (e.
writer may want
g, leachate pumps
to specify
, etc.)
the equipment
12. The permittee shall remove leachate at appropriate intervals to ensure the proper
operation of the liner and leachate collection and removal system.
13. The permittee shall remove leachate from the active sewage sludge unit on a
(daily, weekly, monthly) basis.
14. The permittee shall remove leachate from the active sewage sludge unit, as needed,
to maintain a leachate depth of feet over the liner.
15. Leachate shall be disposed in accordance with the terms and conditions of NPDES
permit number .
:
The permit writer may want to specify exactly how the
leachate is to be treated once it is removed from the
surface disposal unit.
16. Leachate may be discharged to the sanitary sewer provided the concentration of
pollutants discharged is in compliance with any Federal, State and local
pretreatment standards and/or limitations or other applicable requirements.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
5.6.9 METHANE GAS CONTROL
Statement of Regulation
§503.24(j)(l) When a cover Is placed on an active sewage sludge unit, the concentration of methane gas in air
in any structure within a surface disposal site shall not exceed 25 percent of the lower explosive:
limit for methane gas during the period that the sewage sludge unit is active and the
concentration of methane gas:'in: air at the property line of the surface disposal site shall not
exceed the lower explosive limit for methane gas during the period that the sewage sludge unit
is active. • ;• ; ' . -.'"": •' ; ..:' ' .'.'••- '"'
(2) When a final coyer is placed on a sewage sludge unit at closure, the concentration of methane
gas in air in any structure within the surface disposal site shall not exceed 25 percent of the
lower explosive limit for methane gas for three years after the sewage sludge unit closes and the
concentration of methane gas in air at the property line of the surface disposal site shall not
exceed the lower explosive limit for methane gas for three years after the sewage sludge unit
closes, unless otherwise specified by the permitting authority.
Purpose: To prevent explosions and fires that can endanger employees and users of the disposal site, and occupants
of structures near the site boundary.
Applies to: Any active or closed sewage sludge unit and to the owners/operators of these active units where a
cover or final cover has been placed over the disposed sewage sludge. The requirements apply during the period
the sewage sludge unit is active and for three years after a sewage sludge unit has been closed.
Permitting Factors
If sewage sludge is covered with soil or other ^^^••^^^"•^^•«^^™«^^™"^^«""^^"«
material, the owner/operator of an active sewage Cover is soil or other material used to cover
sludge unit is required to install equipment to sewage sludge placed on an active sewage
monitor methane continuously in structures and at sludge unit Final cover :is ^Q last layer of soil
the site boundary. Methane gas levels cannot or other materjai placed on a sewage sludge
exceed 25 percent of the lower explosive limit unit at closure
(LEL) in on-site structures such as buildings.
Methane levels cannot exceed the LEL at the site ^^^^^^^^^^^^^^^^^^^^^^^^^—
property boundary. The LEL for methane is 5
percent by volume in air.
Methane Generation and Migration
Methane is generated as a result of anaerobic microbial decomposition of sewage sludge, and is a concern
at active sewage sludge disposal sites because it is odorless and highly combustible. In addition to
methane, carbon dioxide and lesser amounts of other gases (hydrogen and hydrogen sulfide) are
produced. While hydrogen (HJ is explosive and is occasionally detected in landfill gas, it readily reacts
to form methane or hydrogen sulfide. Hydrogen sulfide (H2S) is an asphyxiant and is readily identified
by its "rotten egg" smell at a threshold concentration near 5 ppb (EPA 1992a).
Gas composition may vary spatially within a sewage sludge disposal unit as a result of pockets of
microbial activity. Partial pressure, density of the materials, and temperature gradients affect the
migration of gases. Gas in an active sewage sludge unit tends to migrate laterally if the active sewage
sludge unit has been covered with geomembranes or clay materials and if interior side slopes of the unit
Draft-March 1993 5-64
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Part 503 requires continuous methane gas
monitoring. In addition to quantitative
measurement, other signs of gas migration may
be observed. Non-quantitative indications of
gas migration are:
« Odor [generally described as a "sweet" or
rotten egg (H2S) odor]
•Vegetation damage
• Audible or visual venting of gases,
especially in standing water.
do not contain an effective gas barrier such as
may exist with a composite infiltration layer.
Lateral gas migration is common in facilities that
lack clay or geomembrane systems. The degree
of lateral migration in these facilities depends on
the type of natural soils surrounding the facility.
Coarse, porous soils, such as sand and gravel,
allow greater lateral migration or transport of
gases than finer-grained soils. Generally,
resistance to landfill gas flow increases slightly as
moisture content increases, and an effective
barrier to gas flow is created under saturated
conditions. Thus, readily drained soil conditions,
such as sands and gravels above the water table,
may provide a preferred flowpath, but unless
finer-grained soils are saturated, landfill gases will
not exclusively flow in the sand and gravel ••••••••••••••^•••••^••••••••••i
deposits (EPA 1992a).
Gas Monitoring
The permit writer may need to verify that the methane gas monitoring system has been installed
appropriately. The monitoring system should detect gas migration based on subsurface conditions and
changing disposal unit conditions, gas migration control system operation or failure, and changes in
landscaping or land use practices. The number and location of gas probes are site-specific and highly
dependent on subsurface conditions, land use, and location and design of facility structures. Monitoring
for gas migration should be in permeable strata. Multiple or nested probes are useful in defining the
vertical configuration of the migration pathway. Structures with basements or crawl spaces are more
susceptible to landfill gas infiltration, where elevated structures typically are not at risk.
In addition to placement at the site boundary and in on-site structures, sample probes can be placed:
• Within the active or closed sewage sludge unit
• Within the leachate collection system
• In soil between the sewage sludge unit and the property boundary or structures where gas
migration may pose a danger (EPA 1992a).
Monitoring the effectiveness of gas control requires gas sampling from probes installed in the areas to
be protected. To install a gas probe, a hole must be drilled to the desired monitoring depth. The
monitoring depth usually is the entire vertical zone through which the gas can be expected to migrate.
A perforated pipe is positioned in the hole with the perforations at the monitoring interval. The probe
is installed into the pipe and the annulus is backfilled with sand or another porous material to a point
above the perforations. Soil is placed in the annulus on top of the permeable material to the surface.
Draft—March 1993
5-65
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Detectors that monitor gas constantly must be installed in the monitoring locations. Automatic detectors
that sense the presence of combustible and/or toxic gases should be installed in ventilation areas, work
areas, utility vaults, and subsurface soils. The detectors should sound alarms or other types of warnings
when gas levels exceed 25 percent of the LEL in onsite structures or the LEL at the property line.
Detectors are sensitive to temperature and humidity changes and require regular calibration and periodic
replacement.
Section 503.24(j)(2) requires that the methane gas be monitored for a period of three years after a sewage
sludge unit is closed. This is the minimum amount of time that the permit writer must specify in the
permit. The permit writer, however, may specify longer monitoring periods based on the potential for
methane gas generation at the surface disposal site. The regulatory requirement is based on studies
performed with sewage sludge that had been treated in anaerobic or aerobic processes. Because these
processes provide a more stabilized sewage sludge, the permit writer may want to require a longer
monitoring period for sewage sludges disposed in surface disposal sites that are not treated by such
processes (e.g., lime stabilized sludges).
Explosive Conditions
If the methane concentration exceeds 25 percent of the LEL in a structure or exceeds the LEL at the
property boundary, the danger of explosion is imminent. All personnel should be evacuated from the
area immediately. Venting the building upon exit (e.g., leaving the door open) is desirable but should
not replace evacuation procedures (EPA 1992a). Emergency procedures should be defined clearly in a
site health and safety plan.
If any of the explosive criteria are exceeded at the site, an investigation of subsurface conditions may be
necessary in the vicinity of the monitoring probe where the criterion was exceeded. The objectives of
this investigation should be to describe the frequency and lateral and vertical extent of excessive methane
migration and the possible causes of the increase in gas concentrations. A detailed discussion of methane
gas monitoring systems for remedial or corrective purposes is found in the Handbook—Remedial Action
at Waste Disposal Sites (EPA 1985). If methane levels are not attenuated, some form of remedial action
is required to control methane generation and migration.
Because the presence of explosive conditions at a surface disposal site may endanger human health and
the environment, the permit writer may require special conditions in the permit to develop emergency
procedures and/or remedial action plans for potentially explosive conditions. These procedures or plans
should be required if there is a history of methane gas problems at the site. The permit writer should
require that these procedures and/or plans be maintained on site at all times. The permit writer may also
include a condition in the permit that requires the owner/operator to investigate subsurface conditions
should the LEL criterion for methane gas be exceeded.
Gas Control Systems
Most surface disposal sites that cover the sewage sludge are designed with gas control systems to prevent
the build-up of explosive gas at the site. The permit writer should be aware of the type of system
employed at the site, and may wish to request additional information on the system during the application
process if gas problems have occurred at the site. The following information introduces the permit writer
to gas control systems and some of the design considerations for both passive and active systems.
Draft-March 1993 5-66
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Systems used to control or prevent gas migration are categorized as either passive or active systems.
Passive systems provide preferential flowpaths by means of natural pressure, concentration, and density
gradients. Passive systems are primarily effective in controlling convective flow; they have limited
success controlling diffusive flow. Active systems use mechanical equipment to direct or control landfill
gas by providing negative or positive pressure gradients. They are effective in controlling both types of
flow. Suitability of the systems is based on the design and age of the sewage sludge disposal unit, the
soil, and the hydrogeologic and hydraulic conditions of the facility.
Passive System
A passive gas control system relies on natural pressure and convection mechanisms to vent landfill gas
to the atmosphere. A passive system typically uses "high-permeability" or "low-permeability" techniques,
either singularly or in combination at a site. A high-permeability system uses conduits such as ditches,
trenches, vent wells, or perforated vent pipes surrounded by coarse soil to vent landfill gas to the surface.
A low-permeability system blocks lateral migration using barriers such as synthetic membranes and high
moisture-containing fine-grained soils (EPA 1992a).
A passive system may be incorporated into the unit design or may be used for remedial or corrective
purposes. It may be installed within a landfill unit, along the perimeter, or between the landfill and the
disposal facility property boundary. A detailed discussion of passive systems for remedial or corrective
purposes is found in the Handbook—Remedial Action at Waste Disposal Sites (EPA 1985).
A passive system may also be incorporated into the final cover. It may consist of perforated gas
collection pipes, high permeability soils, or high transmissivity geosynthetics located just below the low-
permeability gas and hydraulic barrier or infiltration layer in the cover system. These pipes may be
connected to other pipes that vent gas through the cover system or are connected to header pipes located
along the site's perimeter. The gas collection system also may be connected with the leachate collection
system to vent gases in the headspace of leachate collection pipes (EPA 1992a).
A high-permeability passive control system should be installed in a gravel-lined trench between the
sewage sludge unit and the area to be protected. The depth of the trench depends on the unit depth and
the geology of the area in the unit's vicinity. The piping component of this passive control system has
horizontal perforated pipes and vertical solid-wall pipes used to vent gas to the atmosphere if the top of
the trench is blocked by debris. Polyvinylchloride (PVC) perforated pipe is the most common type of
pipe installed. Joints can be cemented, heat welded, or screwed together. After the pipes are laid, the
trench is filled with crushed gravel. The top should be sloped to provide runoff control and the ground
should be graded to draw away from the trench to prevent the washing of soil into the voids of the stone
(EPA 1985). However, this method may not be suitable if air emission requirements cannot be met.
Figure 5-4 shows a passive gas control system using a permeable trench.
Draft-March 1993 5-67
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5. SURFACE DISPOSAL - PART 503 SUBPART C
PLAN VIEW
PERMEABLE
VENT TRENCH
AREA TO BE
PROTECTED
DRAINAGE SWALE
AROUND LANDFILL
PAVED DRAINAGE MONITORING PROBE
CROSSING IF REQUIRED (SPACE @ 100' ± O.C.)
\
SECTION A-A
4" PVC, VENT PIPE*
(SPACE @ 50'±O.C.
4" PVC PERFORATED COLLECTOR •
(CONTINUOUS)
NATURAL
GROUND
««.,•., »OP MONITORING
DRAINAGE PBnBF
SWALE PROBE
GROUNDWATER TABLE. BEDROCK
NATURAL GROUND
AREA TO
BE
PROTECTED
GRAVEL
OR STONE
" MIN. SIZE)
Source: SCS, I960
Extracted: EPA 1985
• FOR APPLICATIONS WHERE
VENTING OF GASES TO
ATMOSPHERE IS ACCEPTABLE.
'• COLLECTOR CAN BE USED TO
CONVEY GASES TO A TREAT-
MENT SYSTEM.
FIGURE 5-4 PASSIVE GAS CONTROL SYSTEM USING A PERMEABLE TRENCH
Draft-March 1993
5-68
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5. SURFACE DISPOSAL - PART 503 SUBPART C
A low-permeability design is identical to the high permeability system except that a synthetic barrier lines
the trench and a low permeability material is used as a backfill. A geomembrane draped over the far wall
of the trench is the barrier and the excavated earth is used for the backfill. Figure 5-5 shows a design
for a low permeability passive gas control system.
The two types of passive systems can be combined. In a combined low/high permeability passive system,
the membrane is installed, and then the piping and high permeability material are installed in front. The
high permeability material should be rounded gravel to avoid puncturing the geomembrane. This
combination encourages gas to flow through the system.
Passive systems are prone to clogging through accumulation of snow and dirt, vandalism, and biological
clogging. To work properly, passive systems should be designed to keep components clear of
obstructions.
Active System
An active gas control system removes methane gas through either positive pressure (air injection) or
negative pressure (gas extraction). A positive pressure system induces a pressure greater than the
pressure of the migrating gas and drives the gas out of the soil and/or the unit in a controlled manner.
A negative pressure system extracts gas from a unit by using a blower to pull gas out of the unit. The
negative pressure system has wider use because it is more effective and offers more flexibility in
controlling gas migration. The gas may be discharged directly to the atmosphere, recovered for energy
conversion, treated, or burned in a flare system. A negative pressure system may be used as either a
perimeter gas control system or an interior gas collection/recovery system (EPA 1992a).
An active system uses a series of wells, collection headers, and blowers to extract gas. The wells are
installed to the depth of the seasonably low water table or to depth of the base of the sewage sludge unit,
whichever is less. The well bore diameter should be between 12 and 36 inches in diameter. A 2 to 6
inch pipe, perforated in the monitoring zone and solid above, is installed in the wellbore. The wellbore
is filled with crushed stone and a clay or cement seal is placed around the solid portion of the pipe at the
top of the well to minimize infiltration of atmospheric air into the system. A valve is placed on top of
the well to regulate the gas flow and to balance multi-well systems. Figure 5-6 is a diagram of an
idealized gas extraction well.
Well spacing is a critical consideration in the design of an active system, and depends on the size of the
sewage sludge unit, the magnitude of the vacuum, and the rate of gas withdrawal. The radius of
influence should allow for overlap between wells. The wells should be constructed first to allow system
components to be positioned according to well location. The header system and piping can be buried or
placed aboveground. Blowers or vacuums must also be installed and the header system connected to the
gas treatment facility. In addition, construction materials should be resistant to corrosion because of the
high moisture content of the gas. Monitoring effectiveness of the system is identical to those for passive
systems. Figure 5-7 depicts an active gas control system (EPA 1985).
An active system is not as sensitive to freezing or saturation of cover soils as a passive system. Although
an active gas system is more effective in withdrawing gas from the sewage sludge unit, the capital,
operation, and maintenance costs of such systems are higher and these costs continue throughout the post-
closure period. As the disposal unit ages, the owner/operator may wish to convert active gas controls
Draft-March 1993 5-69
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5. SURFACE DISPOSAL - PART 503 SUBPART C
PLAN VIEW
SYNTHETIC
'MEMBRANE
AREA TO BE
PROTECTED
MONITORING PROBE
(SPACE® 100'± O.C.)
SECTION A-A
MONITORING
PROBE
DEPTH
VARIES
GROUNDWATER
TABLE, BEDROCK, ETC.
SYNTHETIC
r'MEMBRANE
AREA TO BE
NATURAL
GROUND
PROTECTED
TRENCH
BACKFILL
kANY CONVENIENT WIDTH
5oum: SCS, 1960
Extracted: EPA 1985
FIGURE 5-5 LOW PERMEABILITY PASSIVE GAS CONTROL SYSTEM
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5-70
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5. SURFACE DISPOSAL - PART 503 SUBPART C
VALVE BOX AND COVER
GAS
COLLECTION
HEADER
1" PVC MONITORING
PORT W/CAP
COMPACTED
SOIL OR
XREFUSE ,y
Source: SCS, 1980
Extracted: EPA 1985
FIGURE 5-6 IDEALIZED GAS EXTRACTION WELL
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5-71
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5. SURFACE DISPOSAL - PART 503 SUBPART C
PLAN VIEW
BLOWER/BURNER
FACILITY
AREA TO BE
PROTECTED
GAS
EXTRACTION
WELL
GAS COLLECTION
HEADER
"MONITORING PROBE
(SPACE @ 100'±)
SECTION A-A
GAS EXTRACTION WELL
CONTROL VALVE
GAS COLLECTION
HEADER
\NATURAL
GROUNDS
DEPTH
VARIES
GROUNDWATER OR
BASE OF LANDFILL
Source: SCS, 1960
Extracted: EPA 1985
MONITORING
PROBE
FIGURE 5-7 ACTIVE GAS CONTROL SYSTEM
Draft—March 1993
5-72
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5. SURFACE DISPOSAL - PART 503 SUBPART C
into a passive system when gas production diminishes. The conversion option and its environmental
effects (i.e., gas releases causing odors and health-and safety concerns) should be addressed in the
original design (EPA 1992a).
Permit Conditions
In addition to writing permit language implementing §503.24(j), the permit writer may want to require
the owner/operator to:
• Install equipment to monitor methane continuously in structures and at the facility boundary.
• Develop inspection, calibration, and replacement schedules for the methane gas detection devices.
The schedules can be included in the closure plan for methane monitoring requirements.
• Develop a remedial action plan for use if methane gas levels exceed the allowable levels. This
plan should include procedures to reduce the methane gas levels, emergency procedures to
prevent potentially explosive conditions, and an evacuation plan.
The permit writer may also want to require a longer period of time for methane gas monitoring.
The permit writer can develop site-specific conditions that address the design, operation, and maintenance
of the methane gas control system or can incorporate the surface disposal site's design and operation
manual for methane gas control and monitoring. The permit writer should structure the language so that
the permittee is not exempt from enforcement actions or liability should the design or procedures prove
inadequate in maintaining compliance with the Part 503 requirements.
Examples of language that can be used to establish permit conditions for regulating methane gas levels
are provided below.
1. The permittee shall construct and operate a gas control system, of an approved
design, to reduce the level of methane gas at the site. At the time of site closure, a
gas control system shall also be installed in the final cover.
The permit writer may want to require the venting of
methane gas from the sewage sludge unit if problems
have occurred onsite in the past.
Draft—March 1993
5-73
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5: SURFACE DISPOSAL - PART 503 SUBPART C
-
' ;
2. The permittee shall install a methane gas monitoring system to continuously monitor
the level of methane gas inside structures at the disposal site and at the disposal site
property boundary.
3. The concentration of methane gas in the air in any structure within the surface
disposal site shall not exceed 25% of the lower explosive limit for methane gas. The
concentration of methane gas in the air at the property line of the surface disposal
site shall not exceed the lower explosive limit for methane gas.
4. The methane gas monitoring system shall be inspected by the permittee at a
frequency of per year and calibrated at a frequency of
per year.
5. The permittee shall develop a remedial action plan which shall be implemented if the
methane gas exceeds the specified limit.
6. The permittee shall develop an emergency operating procedure and evacuation plan.
All staff shall, be trained in proper safety procedures regarding methane gas. A copy
of the procedures must be posted onsite.
7. All gas monitors shall have visual and audio alarm and signals which must activate
when the methane gas level exceeds 25% of the lower explosive limit.
8. The continuous methane gas monitoring system shall be operated and maintained for
a minimum period of 3 years after closure of the active sewage sludge unit.
.
The permit writer may select a longer period of time
for required monitoring after site closure if the levels of
methane gas are of concern and have not shown a
declining trend.
&
-
s
5.6.10 FOOD, FEED, AND FIBER CROPS AND GRAZING RESTRICTIONS
Statement of Regulations
§503.24(k) A food crop, a feed crop, or a fiber crop shall not be grown on an active sewage sludge unit,
unless the owner/operator of the surface disposal site demonstrates to the permitting authority
that through management practices public health and the environment are protected from the
reasonably anticipated adverse effects of pollutants in sewage sludge when crops are grown.
$503.24(1) Animals shad not be grazed on an active sewage sludge unit, unless the owner/operator of the
surface disposal site demonstrates to the permitting authority that through management practices
public health and the environment are protected from the reasonably anticipated adverse effects
of pollutants in sewage sludge when animals are grazed.
Draft-March 1993
5-74
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Purpose: To ensure that the operation of surface disposal sites will not introduce pathogens or dangerous levels
of toxic pollutants into the human food chain.
Applies to: All active sewage sludge units and to the owners/operators of these active units.
Permitting Factors
Food crops are crops grown for human •""•^^^••^^^^•••l™l^^—™"™11^^^^
consumption (e.g., fruits and vegetables) or for Food crops ^ crops consumed by humans.
use in making products for human consumption ; these include, but are !nbt limited to, fruits;
(e.g., soybeans for soybean oil). Feed crops are vegetabiesP;and tobacw: [40 dFR 503.9(1)]
crops grown for use in feeding animals raised for ;
human consumption (e.g., pigs) or for use in fcifr-ctf^are crops produced primarily for
making products for human consumption (e.g., consumption by animals. (40 CFR 503.90)]
cows for milk). Fiber crops are crops used for
making textiles (e.g., flax and cotton). _.. . ., ,. . ..
6 v 6 ' ' Fiber crops are crops such as flax and cotton.
• .u •. •. u ^A u-w [40 CFR 503,9(k)]
In general, the permit writer should prohibit,
through a permit condition, the growing of food, ^••^^•^^••^^•^^^^•^•^^^^•••^^^
feed, or fiber crops or the grazing of animals on
active sewage sludge units. However, if the owner/operator requests permission to grow food, feed, or
fiber crops or graze animals on the active sewage sludge unit, the permit writer may allow such activity
if the owner/operator demonstrates to the permitting authority that management practices will be
implemented that will adequately protect public Health and the environment from reasonably anticipated
adverse effects of pollutants in the sewage sludge if crops are grown or if animals are grazed on the
active sewage sludge unit. The permit writer will need to assess whether the proposed management
practices are sufficient to protect human health and the environment if these activities are allowed. For
example, the permit writer may need to evaluate the pollutant loadings to the surface disposal site and
assess the potential for accumulation of these pollutants in the food, feed, or fiber crop or animals grazing
on the land. The permit writer may want to establish management requirements, such as monitoring the
crops and animal products, to ensure that human health is protected.
Permit Conditions
Permit conditions prohibiting the growing of food, feed, or fiber crops or the grazing of animals can be
supplemented with site-specific permit conditions that require management practices to prevent access to
the surface disposal site by animals. If the permit writer allows the growing of food, feed, or fiber crops
or the grazing of animals, specific management practices should be applied as well as all the associated
monitoring, record keeping and reporting requirements. The permit writer should also consider imposing
requirements in the permit to monitor the food, feed, or fiber crop grown or the animals grazed or
products (such as milk) from animals grazed on the site.
Draft-March 1993 5-75
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5. SURFACE DISPOSAL - PART 503 SUBPART C
J>
%
;'
SAMPLE PfcXMlT CONDITIONS FOM FUUD, FEED, ANB 1OTEM
CROPS ANB GRAZING MESTMCT1ONS
1 . No food crop, feed crop, or fiber crop shall be grown on any active sewage sludge
unit.
2. No animals shall be grazed or pastured on any active sewage sludge unit covered by
this permit.
3. The permittee is prohibited from the following activities on the surface disposal site:
growing and harvesting food crops for human consumption; growing and harvesting
feed crops for livestock utilized for human consumption; growing and harvesting
fiber crops; or the grazing of livestock whose dairy or meat products will be
consumed by humans.
The permit writer may prohibit the activities altogether
or may require additional information to determine the
potential for adverse impacts to human health and the
environment as follows.
4. The permittee must implement management practices that will prevent animals from
grazing on the surface disposal site.
5. The permittee shall implement management practices that ensure the safety and
protection of public health and the environment.
6. The permittee shall conduct soil analyses at the frequency of per
year to monitor the cumulative effect of pollutant loadings for the following
pollutants. The results of the analyses shall be submitted to the permitting authority
within days of sample collection. Records of the results shall be
maintained on site.
1
The permit writer will supply the numerical information
for the blanks according to site-specific needs.
-
Draft-March 1993
5-76
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5. SURFACE DISPOSAL - PART 503 SUBPART C
, \
•:•
ac
^ ':
V. ••••
¥•
:••.•.•.••
V
;fv
- >."^*,,v..^: . .>
7. The pen
tissue an
shall be
collectio
8. If the pc
fiber cro
shall occ
9. The pen
crop gro
on the si
10. The pen
on the su
nittee shall assess the accumulation of pollutants in the crop through plant
alysis at a frequency of per year. The results of the analyses
submitted to the permitting authority within days of sample
n. Records of the results shall be maintained on site.
illutant concentration exceeds mg/kg in the soil, no food, feed, or
p shall be grown on [or harvested from] the site and no livestock grazing
ur on the site.
The permit writer may want to specify the pollutant
concentrations of the crop or animal tissue, rather than ""' —
the soil.
nittee shall track and record the final usage of each food, feed, and fiber
wn and/or livestock grazed or livestock product used from livestock grazed,
irface disposal site. The record shall be maintained on site.
nittee shall (grow, harvest, or graze) only the following (crops or animals)
rface disposal site:
i
The permit writer may want to specify those crops or
animals that will be allowed on the surface disposal site ~* —
based on results of an assessment.
\ - ' '
*
5.6.11 PUBLIC ACCESS CONTROL
Statement of Regulations
§503.24(m) Publk access to a surface disposal site shall be restricted for the period that the surface disposal;
site contains an active sewage sludge unit and for three years after the last active sewage sludge
unit in the surface disposal site closes. • ; : j 2
Purpose: To protect public health by restricting contact with sewage sludge placed on the site and restricting access
to an area where the potential for methane explosions exists.
Applies to: All surface disposal sites with active sewage sludge units. It also applies to surface disposal sites
containing closed sewage sludge units for a period of three years after the date of closure of the last active sewage
sludge unit.
Draft—March 1993
5-77
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Permitting Factors
The permit writer must require, through conditions in the permit, that the owner/operator of a surface
disposal site ensure that exposure of the public to the sewage sludge placed on the site does not occur.
The permit writer will need to determine the existence and adequacy of current management practices that
restrict public access. This information may be in the permit application; if not, the permit writer may
need to request this information from the owner/operator. The permit writer will have to consider
whether the existing access restriction practices are adequate.
As part of his/her evaluation, the permit writer should consider the population density of the surrounding
area and the land use practices of the surrounding areas. In general, the higher the population density
or sensitivity of current land use practices in the surrounding area, the greater the degree of protection
required. A land use practice that is sensitive to the presence of a surface disposal site is one which will
increase the probability of exposure of the public to sewage sludge during a normal course of activity.
For example, if the surface disposal site is in an urbanized area surrounded by residential housing
developments, the likelihood of the public entering the surface disposal unit is high. Therefore, very
stringent management practices must be used to prevent access.
Numerous management practices are appropriate for controlling access to a surface disposal site, such
as:
• Installation of perimeter fencing around the surface disposal site with gates and locks. The
fencing can be chain link, barbed wire added to chain link, or open farm fence
• Restriction of vehicular traffic across access roads by installing locked gates in conjunction with
perimeter fencing
• Incorporation of the sewage sludge into the soil or placement of a daily cover of soil or other
material over the sewage sludge
• Installation of warning signs such as "Do not enter," "Sewage sludge disposal site, no
trespassing," and "Access restricted to authorized personnel only."
The use of natural barriers, such as trees, hedges, embankments, berms and ditches, is not considered
adequate access restriction since they can be crossed by pedestrians and off-road vehicles fairly easily.
However, natural barriers coupled with warning signs in a remote rural area may be adequate.
At surface disposal sites containing active and/or closed sewage sludge units located in areas with high
population densities or sensitive land use practices, several of the above management practices may be
necessary. In areas that are less susceptible to public trespass, such as rural areas, warning signs alone
may suffice. In areas with a high probability of vehicular traffic across the surface disposal site,
measures restricting vehicular traffic must be taken. If a surface disposal site contains only closed sewage
sludge units, provision must be made to maintain the access control practices for three years from the date
that the last active sewage sludge unit on that surface disposal site closes.
Draft-March 1993 5-78
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Permit Conditions
The regulatory requirement of §503.24(m) can be embodied in the permit in three ways:
• By using the exact language from Part 503
• By prescribing specific public access controls as permit conditions
• By incorporating a permit condition that requires submission of a plan and schedule for
implementation of best management practices to restrict public access.
If the permit writer determines that current access management practices are adequate, he/she may want
to include these management practices in the permit or reference the surface disposal site's design plan
or other document where these management practices are described. The permit writer should also
include a permit condition requiring the maintenance and upkeep of access restriction measures.
Examples of the types of conditions that may be included in the permit are given below.
Measures used to restrict public access shall include installation of perimeter fencing
with gates and locks, installation of gates and locks across access roads, and the
placement of warning signs prohibiting access to the property. These measures shall
be maintained for a period of three years after the closure of the last active sewage
sludge unit on the site.
I .-
Above condition is for sites with
for public exposure.
high potential
2. The permittee shall post warning signs along the perimeter of the site at a maximum
distance of feet between the signs. The signs shall be posted at a height of
not less than feet or more than feet from the ground. The warning
signs shall be visible for a distance of
feet.
j., .••,,.„,•
Above condition
public exposure.
.. .. ••
is for sites with low potential for
'
Draft-March 1993
5-79
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5. SURFACE DISPOSAL - PART 503 SUBPART C
f - %
•f
•4 ••*..
-»*&?>*>'
3. The pen
restrict p
managen
4. The pen
fencing .
deteriora
nittee shall develop and implement best management practices to adequately
ublic access to the site and submit a schedule for implementation of the best
lent practices.
If the p
existing
modifica
nittee sha
and signs
tion that v
ermit writer does not feel comfortable with
public access control, he/she may require
dons to be made.
11 inspect the fencing and signs on a frequency. AH
shall be repaired or replaced as necessary to prevent a breach or
nil render the restriction device inoperable.
-- - - ,
-
5.6.12 GROUND-WATER PROTECTION
Statement of Regulations
§S03.24(n)(l) Sewage sludge placed on an active sewage sludge unit shall not contaminate an aquifer.
§503.24(n)(2) Results of a ground-water monitoring program developed by a qualified ground-water scientist
or a certification by a qualified ground-water scientist shall be used to demonstrate that sewage
sludge placed on an active sewage sludge unit does not contaminate an aquifer.
Purpose: To prevent siting, construction, and operation of any active sewage sludge units in a manner that would
contaminate an aquifer with nitrate-nitrogen.
Applies to: All active sewage sludge units.
Permitting Factors
Part 503 prohibits contamination of an aquifer.
The regulations provide for two alternatives for
the owner/operator to demonstrate that the aquifer
is not contaminated: providing a certification that
the sewage sludge being placed on the active
sewage sludge unit will not contaminate the
aquifer or performing ground-water monitoring.
The certification is not a simple signed statement;
rather, it is a hydrogeologic assessment by a
qualified ground-water scientist. Based on the
hydrogeology of the site and the design of the ,
surface disposal site, the scientist determines the
likelihood of ground-water contamination occurring
Contaminate an aquifer means to introduce a
substance that causes the maximum
contaminant level for nitrate in 40 CFR 141.11
to be exceeded in ground water or that causes
the existing concentration of nitrate in ground
water to increase when the existing
concentration of nitrate in the ground water
exceeds the maximum contaminant level for
nitrate in 40 CFR 141.11. [40 CFR 503.21(c)J
at the site and then certifies that, based on his/her
Draft-March 1993
5-80
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5. SURFACE DISPOSAL - PART 503 SUBPART C
knowledge of the site, contamination is not likely to occur. The ground-water monitoring alternative,
on the other hand, is an actual demonstration that aquifer contamination is not occurring through actual
measurement of nitrate in the ground water below the surface disposal site.
The permit writer must verify the information •"^"•••••••^^•••••^"^••"•^^^••••i
submitted to support either option. While Aquifer is a geologic formationr group of
verifying information, the permit writer should logic formations> or a portion of a geologic
consider the potential of the site to cause formation b,e of ie,di d ^ to
contamination, and the risks to human health and we,,s of - [4Q CFR 503210,)]
the environment should contamination of the
ground water occur. •^^•••^^•••••^^^••••^^••••^^•i
To perform these assessments, the permit writer should obtain appropriate documentation from the owner/
operator, and the State and local ground-water protection agencies, to determine if the surface disposal
site is located over an aquifer designated for ground-water protection or whether the aquifer is already
contaminated. In addition, preliminary design information and site-specific geological information may
indicate if the site needs special consideration.
The first assessment should determine the potential of the surface disposal site to cause or contribute to
nitrate contamination. This potential will depend upon many considerations, such as:
• Age of the surface disposal site or sewage sludge unit
• Site design features (e.g., lined versus unlined)
• Site-specific hydrogeological and meteorological features.
Second, the permit writer should determine the risk to human health and the environment associated with
the contamination of an aquifer below the surface disposal site. This assessment should consider the
degree of contamination that could occur (i.e., whether the increase in nitrate levels in the aquifer will
lead to levels above the MCLs). This assessment should also consider the size of the affected community
if contamination occurs (i.e., whether the site is located over a sole source aquifer serving a small
community or serving several large communities). The permit writer should also determine if any
applicable State or locality-specific ground-water protection requirements apply. To do so, the permit
writer should consult the following documents, if available:
• State Wellhead Protection Plan
• Comprehensive State Ground-Water Protection Program Plan.
A State Wellhead Protection Plan is a plan that is established under the Wellhead Protection (WHP)
Program to protect ground waters that supply wells and well fields contributing drinking water to public
water supply systems (SDWA 1986). The Comprehensive State Ground Water Protection Program Plan
is developed by States to implement the 1991 EPA Ground-Water Protection Strategy (EPA 199Ic).
These plans may include information useful to the permit writer, such as:
• Ground-water protection goals
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Identification of ground-water classification systems, special aquifers requiring protection, or
priorities for ground-water protection
• Designated wellhead protection areas (WHPA) for each wellhead based on hydrogeologic data,
ground-water flow, and aquifer recharge and discharge.
Performing these assessments allows the permit writer to assign the surface disposal site a relative risk
factor. However, the permit writer should be aware that the determination of whether a site has a low,
medium or high risk factor is a subjective determination. Some States and/or localities may have
prioritized areas within their jurisdiction and have actually identified specific criteria on which to base
the judgment (e.g., Wellhead Protection Programs or State Ground-Water Protection Programs) while
others may not have.
Where the permit writer does not find institutionalized policies on assigning priorities and risks, he/she
may develop a system for assigning the relative risk factors. The system may be based on one of several
criteria:
• Quality of ground water beneath the active sewage sludge unit
• Designated uses or potential uses of ground water below the active sewage sludge unit
• Design of the active sewage sludge unit (i.e., lined versus unJined, and stable versus unstable
land).
The permit writer may wish to develop the relative risk factor system based on one of these criteria or
a combination of all three. For example, using the first criterion, low-risk sites may be identified as sites
located over contaminated aquifers. A high-risk site would be located over ground water of exemplary
quality. An example using all three criteria would yield low-risk sites where ground waters are
contaminated and will never be useable as a drinking water source because of the cost of remediation,
and where the sewage sludge unit has a liner and leachate collection system. A high potential risk site
would be an unlined site located in an area with known seismic activity and over a high-quality drinking
water source that is irreplaceable and ecologically vital.
Based on the relative risk factors assigned to the site, the permit writer can decide if the appropriate
measures have been taken. In general, a certification is appropriate for a surface disposal site with low
to medium relative risk factors. Ground-water monitoring may be necessary for high-risk surface disposal
sites. Both the certification and the ground-water monitoring program must be developed by a qualified
ground water scientist. The permit writer should request that information on the qualified ground-water
scientist's educational and work experience be submitted along with the certification or ground-water
monitoring plan to allow the permit writer to evaluate the scientist's credentials and expertise.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Certification
As mentioned above, the certification ""^^^^^""™^^^™ll™lll^^^"™l^^^^^"^^l^i"
alternative is most appropriate for low to A qualified grbund^ater scientist is an individual
medium risk sites because it is far less . witha baccalaureate or postgraduate degree ui the
expensive than a full-scale ground-water natural sciences or engineermg who has siiffident
monitoring program. This certification is a gaining and experience in ground water hydrology
hydrogeologic assessment that the aqu.fer ,s ^ relatfid fie]d M m be deraonstrated by State
not and will not be contaminated by sewage registratiohj professional certification, or
sludge placed in the active sewage sludge compleiion of accredited university programs, to
umtsX This hydrogeological assessment ^ .^ professional:judgmyen;s: regarding
must be based on site-specific data. The . -.,•, . . J • „ .. ' r j
assessment report should: ground water monitormgv; pollutant ftte^d
* transport, and corrective action. [40 CFR
• Identify regional geologic and ' ^
hydrogeologic characteristics, such as I^^^^M^^^M^MMI^M^^MBBBI^H^^^^^MBBH
geologic formations and origins,
geomorphology, seismic activity, drainage, surface waters and their quality, soils, aquifer
recharge and discharge areas, regional topography, and meteorological and climatological
information
• Analyze the effect of site topographic and geomorphic features on the site ground-water
hydrology
• Classify and describe site hydrogeological properties, such as aquifer thickness, porosity, texture,
hydraulic conductivity, infiltration rates, transmissivity, and structure
• Include structural contour maps and geological sections showing hydrogeology of uppermost
aquifer, perched zones, interconnections, and water table elevations
• Characterize ground water, including water levels, flow patterns, flow rates, and water quality.
The complexity of the certification depends on the relative risk factor and on specific site characteristics.
For low relative risk sites, the permit writer may require that the certification be based on a
hydrogeological assessment prepared from already existing documentation on the hydrogeology of the site
and surrounding areas. Such documentation includes historical records (e.g., precipitation or land
development), USGS information or State geologic survey maps, Soil Conservation Service reports and
maps indicating soil types, studies performed on nearby sites, and geologic logs of existing wells or test
borings that have been taken near the site. Ascertaining that the aquifer is not and will not be
contaminated would be deduced from this information.
For medium relative risk sites, the permit writer may require that the above existing information on the
hydrogeology of the site be verified or supplemented with site-specific, field-collected measurements, such
as soil borings, rock corings, material tests, surface geophysical surveys, and hydraulic conductivity
measurements. For medium relative risk sites that have existing problems with nitrates, the permit writer
may consider requiring in the permit that the certification be based on fate and transport demonstrations,
such as:
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Site-specific, field collected measurements, sampling, and analysis of physical, chemical and
biological processes affecting nitrate fate and transport
• Nitrate fate and transport predictions that maximize nitrate migration and consider impacts on
human health and the environment.
The permit writer could require a one-time monitoring of the aquifer to verify that the active sewage
sludge units are not contaminating the aquifer. The permit writer may decide that there are sufficient
wells in close proximity to the surface disposal site to provide the needed monitoring information or
he/she may require the construction of wells specifically for this purpose. The monitoring information
should be submitted with the certification. The results can be used by the permit writer to determine the
need for additional periodic monitoring at that surface disposal site. If wells were constructed for this
initial assessment, they can then be used for the required periodic monitoring.
At sites that have a high relative risk, certification should not be allowed. Instead, the owner/operator
should be required to develop and implement a ground-water monitoring program.
Ground-Water Monitoring
As stated above, sites that a permit writer determines have a high relative risk factor may be required to
monitor the ground water to demonstrate that the sewage sludge placed on any active sewage sludge units
at the surface disposal site does not contaminate an aquifer. Such a demonstration is made by analyzing
ground-water samples collected from monitoring wells placed downgradient and comparing the analytical
results of the nitrate concentrations to samples taken from wells placed upgradient of the active sewage
sludge unit.
Before the permit writer can determine which ground-water monitoring permit conditions to incorporate
into the permit, he/she must have a clear understanding of the hydrogeological conditions at the surface
disposal site. This is accomplished by requiring the owner/operator to submit a hydrogeologic report of
the disposal site and to develop a ground-water monitoring plan, either as part of the permit application
information or as the initial milestone in a compliance schedule in the permit. The permit writer should
review and evaluate the hydrogeological report and ground-water monitoring plan. If the owner/operator
does not have adequate information or resources to develop such a hydrogeologic report and monitoring
plan for the permit application, the permit writer may choose to require the owner/operator to submit all
available hydrogeologic information and issue the permit incorporating a compliance schedule for
development and implementation of a ground-water monitoring program. The milestones in the
compliance schedule could address the development of an adequate hydrogeologic report, completion of
a monitoring plan, commencement of monitoring well development, and commencement of monitoring
well sampling.
Hydrogeologic Assessment and Ground-Water Monitoring Plan
The permit writer must require that the ground-water monitoring plan be prepared by a qualified ground-
water scientist. This plan can then be used by the permit writer to develop permit conditions for periodic
ground-water monitoring. At a minimum, the permit writer should require the owner/operator to submit
the following information as part of a hydrogeologic study that assesses aquifer contamination:
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• A characterization of the site geology and hydrology (hydrogeologic assessment) including
seasonal variability in ground-water flow directions and an interpretation of the information and
data submitted
• A description of the ground-water monitoring system design and installation for the active sewage
sludge unit(s) (including a well location map)
• A discussion of sampling and analytical procedures including statistical methods used
• Results of nitrate-nitrogen analyses of ground-water samples with associated quality
assurance/quality control (QA/QC) data.
The permit writer will need to determine whether the ground-water hydrogeologic assessment and
monitoring plan is complete and whether the information provided by the owner/operator verifies the
absence of aquifer contamination. This type of evaluation requires: (1) a review of the data quality; (2)
an understanding of the interpretation of the hydrogeologic and water quality data; and (3) an analysis
of whether the data and information submitted fully characterize the potential ground-water impact of
placing the sewage sludge on the sewage sludge unit. Finally, the evaluation should also include a
comparison of the nitrate-nitrogen levels reported for each ground-water sample to the MCL for nitrate-
nitrogen (10 mg/1) to verify the absence of aquifer contamination.
Several other guidance documents published by EPA may be useful to the permit writer in reviewing the
ground-water assessment and monitoring plan. These documents are listed in Table 5-8. Much of the
information provided in these documents is not duplicated in this document. Instead, only the most
important technical considerations that the permit writer must address in a review of a hydrogeologic
assessment.and ground-water monitoring program are discussed. The following discussion details the
type of information that should be included in the hydrogeologic assessment and monitoring plan
submitted by the owner/operator.
Characterization of Site Geology and Hydrology
The permit writer should require that the owner/operator provide data on the site geology and hydrology
in order to identify all potential migration pathways and the target monitoring zones. The collection of
subsurface samples, ground water-level measurements, water quality data, aquifer data, meteorological
and climatological data, and descriptions of other site-specific conditions are used to formulate
interpretative tools, such as geologic cross sections, isoconcentration maps, water-level contour maps,
flow nets, and aquifer characteristics. The final hydrogeologic assessment should identify the spacial
variability of geologic units and the seasonal/temporal variability expected to occur in the ground- water
flow systems.
The geologic units that compose the targeted monitoring zone must be identified and characterized. It
is important to determine how these units may vary spatially and how they are connected hydraulically
with surrounding units. The quantity of data required to characterize the target monitoring zone(s)
depends upon the site's geological complexity. For example, a subsurface environment composed of
geologic units that are highly variable and appear to be discontinuous may require considerably more data
than a system that is relatively homogeneous and predictable.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
TABLE 5-8 SUPPORTING DOCUMENTS FOR REVIEW OF GROUND-WATER
ASSESSMENT AND MONITORING PLANS
Document Title
The Ground Water Monitoring Technical
Enforcement Guidance Document (TEGD)
(OSWER 9950.1)
RCRA Comprehensive Ground-Water
Monitoring Evaluation (CME Guidance
Document)
Statistical Analysis of Ground-Water
Monitoring Data at RCRA Facilities
(EPA/530-SW-89-026)
Procedures Manual for Ground Water
Monitoring at Solid Waste Disposal
Facilities
Guidance Provided to the Permit Writer
Provjdes. technical guidance on the development of ground-
water monitoring programs, including site characterization, well
design and placement, and well construction
Provides guidance to evaluate the compliance of a ground- water
monitoring system
Provides information to review and evaluate ground-water
quality data using statistical methods
Provides guidance for hydrogeologic investigation including
characterization of site hydrogeology, design of detection
monitoring systems, design and construction of monitoring
wells, and sampling and analysis of ground water
Important geologic features that indicate a high degree of variability and irregularity within the subsurface
are: fracture zones, solution cavities, pinchout zones (i.e., discontinuous strata across the site), tilted or
folded beds, or high hydraulic conductivity zones. These types of geologic features often control the
direction and velocity of ground-water flow. For example, since fractures are often preferred pathways
for ground water, the orientation of fractures can control the direction of ground-water flow.
Seasonal and temporal variability of ground-water flow directions and. ambient ground-water quality must
be characterized. The influence of surface water bodies on the ground-water system (e.g., tidal variations
and river stage variations) is often an important control on the direction and quality of ground-water flow.
Other local influences on ground-water flow that can change seasonally or temporally include on or off-
site pumping wells, injection wells, irrigation or agricultural activities, and other land-use activities.
Site conditions may help identify the amount and extent of potential contaminant migration. For example,
orientation and dimensions of a sewage sludge unit will affect the placement of ground-water monitoring
wells, and should be evaluated to ensure that all migration pathways are monitored.
The site characterization is adequate when the following conditions are satisfied: (1) the target monitoring
zone is identified (usually the uppermost aquifer); (2) the degree of hydrogeologic variability within the
targeted monitoring zone is defined; and (3) all potential contaminant migration pathways from the sewage
sludge unit are identified. This information fosters accurate placement of monitoring wells to detect
potential contamination.
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S. SURFACE DISPOSAL - PART 503 SUBPART C
Description of the Ground-Water Monitoring System
The permit writer should require that the owner/operator provide a well location map as well as
information on well installation and construction. Monitoring wells should be placed downgradient of
the sewage sludge unit to intercept ground water that flows beneath the unit. This requires identification
of the area of ground-water flow that could interact with potential contaminant migration from the unit.
The number of downgradient wells should be' sufficient to determine water quality at the point of
compliance (i.e., as close to the unit boundary as possible). Typically, at least three downgradient wells
are required to monitor the lateral extent of contaminant migration. An upgradient well, which is not
influenced by the sewage sludge unit but is within the vicinity to represent background ground water
quality, should be part of the ground-water monitoring system. In order to avoid potential pathways of
contamination, an upgradient/background well should be located where it won't be influenced by ground-
water mounding beneath the unit.
Monitoring wells should be screened laterally and vertically within the target monitoring zone(s) and be
constructed of materials that will not affect the quality of ground-water samples. The owner/operator of
the surface disposal site should explain the number and placement of the monitoring wells. After
consideration of all migration pathways and the effects of temporal variations on the ground water flow
system, additional monitoring wells or alternative monitoring techniques such as vadose zone monitoring
or tracer tests may be required. For example, fracture and solution channels in an aquifer (e.g., karst
hydrology) may require non-conventional monitoring techniques. In addition, certain subsurface
conditions such as multiple aquifers may require additional monitoring for hydrologic interconnectiveness.
Sampling and Analytical Procedures
The permit writer should require that the owner/operator submit a description of all sampling and
analytical procedures that were followed to collect the data and that will be followed in the future if
periodic ground-water monitoring is determined to be needed. The following components of the sampling
and analysis program should be addressed in the plan:
• Sample collection, preservation, and handling
• Analytical'procedures
• Statistical methods used to assess ground-water monitoring data
• Chain-of-custody procedures
• Field and laboratory quality assurance/quality control procedures.
A representative ground-water sample is collected when the following are ensured: (1) the use of proper
well evacuation techniques; (2) sampling equipment and techniques that minimize alteration of the
chemical constituents in the ground water; (3) adequate documentation of field activities; and (4)
identification and reporting of errors or anomalies. Sample integrity must be maintained through proper
sample preservation, handling, and chain-of-custody procedures.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
All activities related to characterizing the site hydrogeology, design and installation of ground-water
monitoring wells, and sampling and analysis should include a quality assurance/quality control (QA/QC)
program. All samples must be evaluated with respect to standard QA/QC procedures and to the specified
data quality objectives (i.e., the amount of imprecision and bias that will be tolerated). QA/QC
procedures should include the use of standards, laboratory blanks, field and trip blanks, and duplicates.
Field QA/QC procedures should include equipment decontamination and chain-of-custody.
The frequency of any initial compliance sampling and number of samples collected should represent any
expected seasonal variation in ground-water quality. Typically, at least four rounds of ground-water
samples are collected over a course of one year to ensure seasonal variability. Statistical procedures are
often used to determine the appropriate sampling interval that will reflect site-specific hydrogeologic
conditions.
Developing Permit Conditions for Ground-Water Monitoring
Permit conditions for ground-water monitoring are developed according to the complexity of the site, site
hydrogeblogy, and potential and real risks. The variability of sites is so great that it becomes difficult
to provide guidance to the permit writer in developing the ground-water monitoring permit conditions.
Appropriate permit conditions could range from simply incorporating the owner/operator's ground-water
monitoring plan by reference to developing detailed conditions specifying construction details and
statistical procedures. The following discussion provides the minimum information that the permit writer
should address in the permit and furnishes guidance on the consideration of more detailed provisions.
If the permit writer determines that the proposed ground-water monitoring plan provides a sound technical
basis for detection monitoring, the permit writer may incorporate the plan by reference in the ground-
water monitoring section of the permit. If, however, the permit writer determines that the ground-water
assessment and monitoring plan is deficient, he/she may decide to specify the terms and conditions of the
monitoring to be performed in the permit. At a minimum, the conditions associated with ground-water
monitoring that the permit writer should address in the permit include:
• Frequency of monitoring
• Well location, construction, and maintenance
• Monitoring program and data evaluation
y
• Reporting and record keeping.
Frequency of Periodic Ground-Water Sampling and Analysis
The permit writer should specify an appropriate frequency for sampling and analysis of nitrate in ground
water for any active sewage sludge units at the surface disposal site. Monitoring frequency can be
influenced by the following factors:
• Rate and direction of the ground-water flow
• Location of the monitoring well
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Trends in the water quality data
• Climatological and meteorological characteristics
• Others (such as the resource value of the aquifer and the fate and transport of the nitrate in
ground water).
The permit writer must, therefore, develop a flexible monitoring schedule, allowing for modification
based on these factors. Initially, the permit writer may want to base the frequency of monitoring on the
ground-water flow rate, location, and climate. However, he/she may want to modify this provision later,
based on the trends in the site's water quality data. Special considerations are warranted for sites where
contamination is suspected and the frequencies must be altered for aquifer contamination assessment
reasons.
Flow rates are primarily dependent upon the aquifer porosity and permeability as well as the hydraulic
gradient at the site. The higher the flow rate, the greater the monitoring frequency needed. For sites
that are underlain by impervious clay soils, semi-annual or annual monitoring may be sufficient. For
sites that have fracture or solution porosity aquifers, it is possible that contaminants could migrate from
the active sewage sludge unit within weeks or even days. Thus, quarterly or monthly monitoring may
be more appropriate.
By considering regional climatological characteristics, the permit.writer may obtain information on the
fluctuations of leachate development that may occur over the year. This type of information may indicate
that, instead of arbitrarily assigning a sampling date every third month (for quarterly monitoring), it
would be more appropriate to correlate the sampling period with ground-water recharge periods when
leachate generation is greatest.
Frequency of monitoring may also be based upon the level of concentration of nitrate found in the ground
water and whether the surface disposal site is located over an aquifer used for drinking water or with the
potential to be used for drinking water. If the surface disposal site is located over an aquifer used for
drinking water, the permit writer may elect to specify, in the permit, trigger-based monitoring such as
that used in EPA's Phase II Rule for National Primary Drinking Water Standards. These regulations
require that ground-water systems sample for nitrate annually as a baseline frequency. If any sample is
greater than or equal to 50 percent of the MCL, this triggers an increase in monitoring frequency to
quarterly sampling. If four quarterly samples are shown to be reliably and consistently below the MCL,
then the sampling can be again reduced to annually, in which case samples must be taken during the
quarter which previously yielded the highest analytical result.
Well Location, Construction and Maintenance
The permit writer should specify, in the permit, the design specifications for the ground-water monitoring
system. This monitoring system may be the same system as that provided in the ground-water monitoring
plan furnished by the owner/operator. If the permit writer determines that any aspect of the proposed
system is deficient, the appropriate design specifications should be included in the permit. At a
minimum, the permit writer should specify the design of the monitoring network, including the number,
location, and sampling depths of all background and downgradient monitoring wells. This information
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5. SURFACE DISPOSAL - PART 503 SUBPART C
can be specified through the use of maps and cross-sections. Construction materials and well design
should also be specified. This may include as much detail as possible on drilling methods, well casing
and materials, well diameter, well intake design, well development procedures, and methods for sealing
the annular space.
The spacing and required number of downgradient wells is based on the size of the sewage sludge unit.
However, the permit writer should, at a minimum, require three downgradient wells located as close as
possible to the edge of the unit penetrating the entire saturated thickness of the aquifer. The line of wells
should not have less than one downgradient well for every 76 meters of frontage (EPA 1980). The
permit writer may specify an additional well within the landfill to indicate whether leachate is reaching
ground water and to give early warning of potential aquifer contamination. In addition, the permit writer
may want to add a provision that any detection of nitrates in the indicator well will trigger the
owner/operator to monitor the downgradient wells more frequently.
The number and location of upgradient wells to determine background water quality should be specified
based on the variability of the water quality prior to flowing under the site. In many cases, the permit
writer may want to require multiple background wells to provide better measurements. However, at a
minimum, one must be required. Additionally, the statistical procedure used to determine the presence
or absence of contamination may dictate how many wells are needed. Background wells do not
necessarily have to be placed upgradient of the sewage sludge unit, but the permit writer should review
any placement criteria to ensure that the wells are not being influenced by any contamination at the site.
The permit should require that the owner/operator provide appropriate maintenance for the wells.
Ground-water monitoring plans should contain a schedule for maintaining the ground-water monitoring
system, including replacing or redrilling monitoring wells, replacing seals and caps, repairing or replacing
pumps, and any other kinds of general equipment maintenance.
Monitoring Program and Data Evaluations
The permit should specify sample collection, preservation, chain of custody controls, analytical
procedures and QA/QC procedures to be used for the ground-water monitoring. The permit writer may
also want to specify evacuation techniques to remove stagnant water from the wells prior to sampling.
Monitoring wells require sampling at different depths in order to ensure that the contamination potentially
migrating from the site will be intercepted by the wells. The permit writer should specify the amount
of sampling and the sampling required in the vertical dimension. The permit writer should be careful
when specifying sampling depths to avoid mixing of waters of different quality during sampling. In most
cases, sampling of sites on the downgradient boundary requires sampling at the water table and several
additional depths.
The sampling and analysis section of the permit should include provisions to measure static water
elevations in each well prior to each sampling event. This collection of the water elevation is important
in determining if horizontal and vertical flow gradients have changed since the initial hydrogeologicaJ
characterization (EPA 1992a). Any changes would then require that the owner/operator modify the
existing ground-water monitoring system.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
The permit writer must also specify, in the permit, that the owner/operator use a statistical procedure that
provides a reasonable confidence that the migration of nitrates in amounts that could cause contamination
from the active sewage sludge unit into an aquifer is detected. The statistical performance standards will
limit the possibility of making false conclusions from the monitoring data (EPA 1992a).
Record Keeping and Reporting
At a minimum, the permit writer should require that the owner/operator maintain the results of any
ground-water monitoring in the operating record during the period the sewage sludge unit is active and
for three years after the sewage sludge unit closes. At high-risk sites, however, the permit writer may
want to require that, in addition, the monitoring results be reported on a periodic basis. In this case, the
owner/operator should be required to submit the results to the permitting authority along with an
explanation of the sampling and analytical methods used and the statistical methods employed to determine
presence or absence of contamination.
At a minimum, reporting should be required for those sites that have trigger-based monitoring
requirements or when the owner/operator determines that there is a statistically significant increase above
the MCL concentration for nitrates or, if the aquifer is already contaminated, above the existing
concentration. In the case of contamination, the owner/operator may be required to submit an application
for a permit modification in order to establish corrective action requirements in the permit.
Permit Conditions
Provided below are examples of conditions that may be included in a permit to ensure protection against
ground-water contamination.
1.
The permittee shall provide a certification that the aquifer is not, and will not be,
contaminated by sewage sludge placed in the active sewage sludge units at the
surface disposal site. This certification shall be made by a qualified ground-water
scientist based on the results of a site-specific hydrogeological assessment.
This certification is appropriate for low to medium
risk surface disposal sites only. The permit writer will
want to specify what is required in the hydrogeological
assessment (e.g., existing documentation, site-specific
field-collected measurements, monitoring, etc).
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The permittee shall submit a site hydrogeologic assessment and a proposed ground-
water monitoring plan which has been developed by a qualified ground-water
scientist. The hydrogeologic assessment shall provide a characterization of the site
geology and hydrology, including seasonal variation in ground-water flow,
directions of flow, and an interpretation of the information and data submitted. The
proposed ground- water monitoring plan shall include a description of the ground-
water monitoring system design and installation (including a well map), an
explanation of the sampling and analytical procedures (including statistical methods
used), and the results of preliminary background nitrate-nitrogen analyses with
associated quality assurance/quality control (QA/QC) data.
The permit writer should require the documentation
for those sites that are considered high risk. This
information may be required with the permittee's
application or as a permit condition. If the proposed
monitoring plan is appropriate, the following
conditions may be used.
The permittee shall install and maintain ground-water monitoring wells at the
locations specified in the attached map labeled Attachment A to this permit.
The permittee shall construct and maintain the ground-water monitoring wells in
accordance with the attached plans and specifications labeled Attachment B to this
permit.
The above conditions would require that the permittee
provide a map with the location of all monitoring
wells and design drawings and specifications that
include depth of wells, screened intervals, construction
materials, etc. The permit writer may want to specify
the well location(s) and construction details directly in
the permit or refer to the proposed ground-water
monitoring plan. All information in the maps, design
plans, or ground-water monitoring plans should be
acceptable to the permit writer before incorporating
these into the permit. An example of a specific
construction condition is provided below.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
*•
-:
-
•;
'
5. Monitoring wells shall be cased in a manner that maintains the integrity of the
monitoring well borehole. The casing shall be screened or perforated and packed
with gravel and sand, where necessary, to enable the collection of ground-water
samples. The annular space above the sampling depth shall be sealed to prevent
contamination of samples and the ground water.
6. The permittee shall ensure that monitoring wells, piezometers, and other
measurement, sampling, and analytical devices used be operated and maintained so
that they perform to design specifications throughout the life of the ground-water
monitoring program.
7. The permittee shall construct ground-water monitoring wells upslope and
ground-water monitoring wells downslope of the surface disposal site.
The wells shall be continuously maintained. Any well which is located where it
may be damaged by either a vehicle or machinery shall have posts or barriers
erected as protection.
8. The permittee shall collect and analyze ground-water samples from wells numbered
on a basis for a period which is not less than
months prior to the addition of sewage sludge to the surface disposal unit to
establish background ground-water nitrate concentrations. The values established
will automatically become part of the permit.
9. The permittee shall notify the permitting authority of the exact start date prior to the
unit becoming an active sewage sludge unit. The notification shall be given no less
than days prior to the disposal of sewage sludge at the site.
10. The permittee shall sample each load of sewage sludge which exceeds dry
tons prior to its placement in the active sewage sludge unit. The sample shall be
analyzed for nitrate levels. The analysis results shall be retained onsite as long as
the site is active and for years following closure of the site.
11. The permittee shall conduct ground-water monitoring at a frequency of per
(month, year) for nitrates.
12. The permittee shall use the methods, techniques and procedures described in the
Ground-Water Monitoring Plan in Attachment for sample collection, sample
preservation, nitrate analysis, sample chain-of-custody, and QA/QC procedures.
I
The permit writer may want to specify the exact
procedures and analytical methods to be used in the
permit rather than reference the permittee's ground-
water monitoring plan.
-
Draft-March 1993 5-93
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5. SURFACE DISPOSAL - PART 503 SUBPART C
- -
-
.
13. The permittee shall determine the ground-water surface elevation each time ground
water is sampled in accordance with the conditions above.
14. The monitoring well sample analyses shall be reported within days of
sample collection.
15. When evaluating the monitoring results obtained, the permittee shall use the
following procedures:
a. When the background nitrate concentration level in the ground water has a
sample coefficient of variation less than 1.00, the permittee shall follow the
statistical procedures described in [insert
the title of an appropriate statistical procedure or guidance manual].
b. In all other situations, the permittee shall use the statistical procedures specified
in [insert the title of an appropriate statistical
procedure or guidance manual].
[
The permit writer should specify the statistical
procedures to be used in determining compliance
with the water protection standard. The method
may be specified or a group of separate methods
may be specified depending upon the variability of
the background nitrate concentration.
16. The permittee shall determine the ground-water flow rate and direction in the
uppermost aquifer at least (monthly, semi-annually, annually).
17. The permittee shall determine whether there is a statistically significant increase,
over the background values, each time ground-water quality is determined in
accordance with the conditions in . In determining whether such an
increase has occurred, the permittee shall compare the ground-water quality at each
monitoring well to the background levels specified in condition , in
accordance with the procedures specified in condition
. •
-
5.7 MONITORING REQUIREMENTS
In developing permit conditions for monitoring sewage sludge disposed in sewage sludge units, the permit
writer should consider including the following:
• Parameters to be monitored
Draft—March 1993
5-94
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Monitoring frequencies
• Monitoring locations
• Sampling types and preservation protocol
• Analytical methods.
In addition, the permit writer may find that including a provision which specifies that QA/QC procedures
must be followed will ensure that the results of the monitoring program are reliable and precise. The
following subsections briefly highlight each of the above-listed monitoring issues that should be addressed
in the permit.
If an active sewage sludge unit is not owned and/or operated by the generator of the sewage sludge to
be disposed at the surface disposal site, the permit writer will need to decide whether to impose the
sewage sludge monitoring requirements on the surface disposal facility, the generator, or both.
5.7.1 PARAMETERS TO BE MONITORED
Sewage sludge placed on unlined units must be monitored for the three regulated pollutants, pathogen
reduction, and vector attraction reduction. Sewage sludge disposed on units that are equipped with liners
and leachate collection systems are only subject to the pathogen reduction and vector attraction reduction
requirements. The permit writer should note that if the owner/operator applies a cover over the sludge
after placement on the sewage sludge unit, then the pathogen reduction and vector attraction reduction
monitoring does not need to be performed.
If a cover is placed over the sewage sludge, air monitoring for methane is required continuously at the
surface disposal site property boundary and within any structures at the site. This air monitoring is
required while the sewage sludge unit is active and for 3 years after it is closed. This monitoring was
discussed earlier as a management practice in Section 5.6.9.
The sewage sludge quality parameters established by §503.26 have been reproduced in Table 5-9.
5.7.2 MONITORING FREQUENCY
The frequency of monitoring is typically established through permits on a case-by-case basis. However,
to enhance the self-implementation of the regulations, minimum monitoring frequencies have been
established in Part 503. The monitoring frequencies established by §503.26 for surface disposal are
shown in Table 5-10, but the permit writer has the discretion to require more frequent monitoring than
established by Part 503. Additionally, the regulations give the permit writer discretion to reduce the
monitoring frequencies if, after 2 years, the variability of pollutant concentrations and the detection
frequency of pathogens are low and compliance is demonstrated so that a reduction in frequency appears
appropriate. This frequency, however, cannot be less than once per year.
Draft-March 1993 5-95
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5. SURFACE DISPOSAL - PART 503 SUBPART C
TABLE 5-9 PARAMETERS REQUIRED TO BE MONITORED AT
SURFACE DISPOSAL SITES
Parameters To Be Monitored
Pollutants*
Pathogens
Vector Attraction Reduction
Arsenic
Chromium
Nickel
Fecal coliform or Salmonella
Enteric viruses'1
Helminth ovak
Volatile solids reduction0
Specific oxygen uptake rated
pH«
Percent solidsf
'Percent solids of sewage sludge must be monitored to report pollutant concentrations on a dry
weight basis
bClass A alternatives 3 and 4
"Vector attraction reduction alternatives 1, 2, and 3
""Vector attraction reduction alternative 4
•Vector attraction reduction alternative 6
fVector attraction reduction alternatives 7 and 8.
TABLE 5-10 FREQUENCY OF MONITORING - SURFACE DISPOSAL
Amount of Sewage Sludge*
(metric tons per 365 day period)
Greater than zero but less than 290
Equal to or greater than 290 but less than 1,500
Equal to or greater than 1,500 but less than 15,000
Equal to or greater than 15,000
Frequency11
Once per year
Once per quarter
(four times per year)
Once per 60 days
(six times per year)
Once per month
(12 times per year)
'Amount of sewage sludge placed on active sewage sludge unit (on a dry weight basis).
bAfter the sewage sludge is monitored for two years at the above frequency, the permitting authority may
reduce the frequency of monitoring for pollutant concentrations and for the pathogen density requirements in
§503.32(a)(5)(ii) and (a)(5)(iii), but in no case shall the frequency of monitoring be less than once per year
when sewage sludge is placed on an active sewage sludge unit [§503.26(a)(2)J.
Source: 40 CFR 503.26
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5-96
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5. SURFACE DISPOSAL - PART 503 SUBPART C
The monitoring frequency is based on the total quantity of sludge placed in an active sewage sludge unit
in a given 365-day period. Whenever possible, the permit writer should specify the 365-day period and
the corresponding monitoring frequency. The permit writer should also specify that if the quantity of
sludge to be disposed during the 365-day period exceeds the quantity on which the monitoring frequency
was based, then the permittee must notify the permitting authority and increase the monitoring frequency
to that required for the quantity of sewage sludge to be disposed. For example, if the permittee is
expected to dispose between 200 and 750 metric tons per year during the 5-year permit period, the permit
writer could specify two monitoring frequencies as illustrated below.
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SAMPLE PEMMIT CONDITIONS FOE MONITORING
1. The frequency of monitoring shall be once per year when the amount of sewage
sludge placed on active unit(s) is less than 290 dry metric tons per 365-day period.
2. If the amount of sewage sludge placed on active unit(s) increases to greater than 290
dry metric tons but less than 1,500 dry metric tons per 365-day period, the
frequency of monitoring shall be increased to four times per year. At least one
monitoring event shall occur per each quarter that sewage sludge is placed in/on the
active sewage sludge unit(s).
3. The permittee shall notify the permitting authority of an increase in the quantity of
sewage sludge expected to be placed in active sewage sludge units, to the extent that
an increase in the monitoring frequency is triggered.
The permit writer should remember that, in some cases, it may be more appropriate to increase the
monitoring frequency beyond the frequency required by §503.26, particularly where the permit writer
has noted the following:
• Pollutant concentrations vary significantly between measurements
• Pollutant concentrations are close to the pollutant limits
• A trend indicating worsening sewage sludge quality
• A lack of historical data on sewage sludge quality.
Draft-March 1993 5-97
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Sewage sludge data collected over a 2-year period should be adequate to calculate the variability of
pollutant concentrations and to determine trends in pollutant concentrations. The permit writer also has
the discretion to reduce the monitoring frequency after 2 years of monitoring at the frequency specified
in Table 5-10. In deciding whether to reduce the frequency of monitoring, the permit writer should
consider the following:
• Variability of the pollutant concentrations — The frequency of monitoring should not be reduced
where sewage sludge quality varies significantly (i.e., more than 20 percent) between samples.
• Trends in pollutant concentrations — Facilities with data indicating an increase in pollutant
concentrations over the 2-year time period should not be granted a reduction in monitoring.
• The magnitude of the pollutant concentrations — If all sampling data reveal that the concentration
of pollutants are significantly below pollutant limitations, a reduction in monitoring may be
appropriate.
• The frequency of detection of viruses and viable helminth ova in the sewage sludge — If all
sampling data on pathogen densities are significantly below the regulatory level, a reduction in
monitoring may be appropriate.
5.7.3 MONITORING POINTS
Representative sampling is one of the most important aspects of monitoring. To obtain a representative
sample of sewage sludge, the sample must be taken from the correct location and represent the entire
volume of sewage sludge. For some facilities, the location of the monitoring point may have a dramatic
effect upon the sewage sludge's quality. It is important that samples be collected from a location
representative of the final sewage sludge that is placed on an active sewage sludge unit. Samples should
be taken in the same manner each time monitoring is performed. The sampling location should be safe
and accessible.
The permit writer will need to determine if there is an appropriate monitoring location to specify in the
permit. For example, there may be a receiving station or temporary storage pile that receives all sewage
sludge loads hauled to the site for final disposal in active sewage sludge unit. Instead of a specific
monitoring location, the permit writer could specify that each load or a random number of loads of
sewage sludge be sampled. For generators that send sewage sludge to a surface disposal site not owned
or operated by the generator, the permit writer should determine whether a general description of the
sampling location, such as "a location just prior to shipment to the surface disposal site" or a specific
description of the exact location for collecting samples is appropriate, depending upon the following
considerations:
• The variability of the sewage sludge at different sample points
• The ability to obtain a well-mixed sample.
Draft-March 1993 5-98
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5. SURFACE DISPOSAL - PART 503 SUBPART C
For example, where a surface disposal site receives sewage sludge form several different wastewater
treatment plants on a batch-basis, the ability to mix the sewage sludge to get a sample representative of
all the sewage sludge may be difficult. The permit writer may want to require sampling of each sewage
sludge load or a percentage of all the sewage sludge loads hauled to the site.
EPA has developed two guidance manuals and a video that provide more detail on proper sample
collection for sewage sludge:
• POTW Sludge Sampling and Analysis Guidance Document (EPA 1989a)2
• Sampling Procedures and Protocols for the National Sewage Sludge Survey (EPA 1989b)
• Sludge Sampling Video (EPA 1992).
5.7.4 SAMPLE AND PRESERVATION PROTOCOL
Also important in ensuring representative samples of sewage sludge are the methods for sample collection
and preservation prior to analysis. The technique for sampling sewage sludge varies depending on
whether the sludge is flowing through pipes, moving on a conveyor, or stored in a pile or bin. Sewage
sludge that flows through pipes or moves on a conveyor should be sampled at equal intervals during the
amount of time the unit operates in a day. When sampling from piles or bins, full-core samples should
be taken from at least four points in the pile or bin.
The permit writer should consider whether it is more appropriate to specify that the permittee collect a
single grab sample or composite samples. With sewage sludge, as with wastewater, grab samples are
instantaneous samples where a volume of sewage sludge is collected all at one time. Composite samples
for sewage sludge are a series of equal volume grab samples collected and then combined to make a
single sample. Composite samples can be made from a series of grab samples collected from several
points in the cross-section of the entire sewage sludge volume, or they can be a series of grab samples
collected at regular time intervals over the duration of a sewage sludge discharge.
In determining whether to specify that a sample be collected using a single grab sample or composite
sampling method, the permit writer may evaluate factors such as:
• How well the sewage sludge is mixed
• Whether the sample is collected from a single batch of sewage sludge or from a stock pile made
up of several batches
• Whether the composition of the sewage sludge varies over time.
In general, combining several samples of the sewage sludge may provide a more representative sample
than collecting one grab sample. Sewage sludge is most often used, or disposed of, in a solid form and/
or may be treated in batch processes. Sewage sludge characteristics may also vary over time. For these
Revised version of this document will be available in 1993.
Draft-March 1993 5-99
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5. SURFACE DISPOSAL - PART 503 SUBPART C
reasons, the quality may not be homogeneous from day to day or even within the sewage sludge volume
itself due to the inability to completely mix sewage sludges that have high solids contents.
Appropriate preservation techniques will ensure that a sample remains representative for the period of
time it is held prior to being analyzed. For field and laboratory preservation of sewage sludge samples,
cooling to 4°C is usually the most appropriate method due to the inability to mix high solid sewage
sludges with other preservatives. The permit writer should consider specifying this preservation method
in the permit since it differs from the more common wastewater practices.
5.7.5 ANALYTICAL METHODS
All analyses performed to show compliance with the monitoring requirements of Part 503 must be
conducted using EPA-approved methods. Methods to analyze specific parameters in sewage sludge are
specified in the Part 503 regulations and shown in Table 5-11. The permit writer should indicate the
methods needed for each analysis in the permit or incorporate the method by referencing the regulatory
citation.
The permit writer should specify the methods needed for each analysis in the permit. When specifying
methods, the permit writer should consider the following:
• The detection limit of the method should be below the pollutant limit in the permit
• Matrix interferences (many of the wastewater methods must be combined with digestion methods
because of the solids contents of sewage sludge).
5.7.6 QUALITY ASSURANCE/QUALITY CONTROL (QA/QC)
A QA program is used to achieve a desired quality for activities, such as sample collection, laboratory
analysis, data validation and reporting, documentation, and record keeping. A QA program should
address the following major areas:
• Proper collection procedures, equipment, preservation methods, and chain-of-custody procedures
to ensure representative samples
• Proper sample preparation procedures, instruments, equipment, and methodologies used for the
analysis of samples
• Proper procedures and schedules for calibration and maintenance of equipment and instruments
associated with the collection and analysis of samples
• Proper record keeping to produce accurate and complete records and reports, when required.
Draft—March 1993 5-100
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TABLE 5-11 ANALYTICAL METHODOLOGIES
M
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APPROVED METHODS FOR THE ANALYSIS OF SEWAGE SLUDGE
40 CFR PART 503
Pollutant
Arsenic
Chromium
(total)
Nickel
Total Solids,
Volatile
Solids, Fixed
Solids
Fecal
Coliform
Salmonella
Percent
Volatile
Solids
Reduction
Analytical Method
AA Furnace
SW-846 Method 7060
AA Gaseous Hydride
SW-846 Method 7061
AA Direct Aspiration
SW-846 Method 7190
AA Furnace
SW-846 Method 7191
Inductively Coupled Plasma
SW-846 Method 6010
AA Direct Aspiration
SW-846 Method 7520
Inductively Coupled Plasma
SW-846 Method 6010
Gravimetric
SM-2540 G
SM-9221 E (MPN)
SM-9222 D (membrane filter)
SM-9260D.1
Kenner, B.A. and H.A. Clark
ERT
Maximum Holding Time, Simple
Preservation, Sample Container,
Sample Preparation
6 months
Plastic or glass container
Samples need to be digested prior
to analysis.
7 days
Cool to 4°C
Plastic or glass container
6 hours
Cool to 4°C
Plastic or glass container
6 hours
Plastic or glass container
Comments
All samples must be digested using SW-846 Method 30SO prior
to analysis by any of the procedures indicated. The AA Direct
Aspiration analyses are applicable at moderate concentration
levels in clean complex matrix systems. AA Furnace methods
can increase sensitivity if matrix effects are not severe.
Inductively Coupled Plasma (ICP) methods are applicable over
a broad linear range and are especially sensitive for refractory
elements. Detection limits for ICP methods are generally
higher than for AA Furnace methods.
Method 2540 G is the recommended procedure for solid and
semisolid samples.
Both procedures are very temperature sensitive. Samples must
be analyzed within holding times.
Large sample volumes are needed due to the low concentration
of Salmonella in wastewater. Also, due to the large number of
Salmonella species, more than one procedure may be necessary
to adequately determine the Salmonella's presence.
See reference list.
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TABLE 5-11 ANALYTICAL METHODOLOGIES (Continued)
s
APPROVED METHODS FOR THE ANALYSIS OF SEWAGE SLUDGE
40 CFR PART 503
Pollutant
Enteric
Viruses
Helminth
Ova
Specific
Oxygen
Uptake Rate
Analytical Method
ASTM-Method D 4994-89
Yanko, W.A.
SM-2710 B
Maximum Holding Time, Sample
Preservation, Sample Container,
. . . Sample Preparation
2 hours at up to 2S°C or 48 hours
at 2 to 10°C
Plastic or glass container
Perform as soon as possible
Plastic or glass container
Comments
Concentration of the sample is necessary due to the presumably
low numbers of viruses in the sample.
See reference list.
Quite sensitive to sample temperature variation and lag time
between sample collection and test initiation. Replicate samples
are suggested.
References
EPA - Methods for Chemical Analysis of Water and Wastes. U.S. Environmental Protection Agency, Environmental Monitoring Systems Laboratory-
Cincinnati (EMSL-C1), EPA-600/4-79-020, March 1983.
SM - Standard Methods For The Examination of Water and Wastewater. 18th Edition. American Public Health Association, Washington, D.C., 1992.
SW-846 - Test Methods for Evaluating Solid Waste: Physical/Chemical Methods. U.S. Environmental Protection Agency, November 1986.
ASTM - Annual Book of Standards - Water. American Society for Testing and Materials, Phila., PA, 1991.
ASTM1 - "Standard Practice for Recovery of Viruses from Wastewater Sludge," Annual Book of ASTM Standards. Section 11, Water and Environmental
Technology, 1992.
KC - Kenner, B.A. and H.A. Clark, "Determination and Enumeration of Salmonella and Pseudomonas aeruginosa." J. Water Pollution Control
Federation, 46(9):2163-2171, 1974.
Yanko - Yanko, W.A., Occurrence of Pathogens in Distribution and Marketing Municipal Sludges. EPA 600/1-87-014, 1987. NTIS PB 88-154273/AS,
National Technical Information Service, Springfield, Virginia.
ERT - Environmental Regulations and Technology - Control of Pathogens and Vectors in Sewage Sludge. U.S. Environmental Protection Agency,
Cincinnati, OH, EPA-625/R-92/013, 1992.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
QC, which is a part of the QA program, relates to the routine use of established procedures and policies
during sample collection and analysis. The objective of QC procedures is to ultimately control both the
accuracy and the precision of all analytical measurements made. QC for sampling procedures would
include the use of duplicate, spiked, split samples and samples blanks. QC of analytical procedures
should include the use of spiked and split samples, proper calibration protocols, and appropriate analytical
methods and procedures. While QA/QC is standard practice for most laboratories, the permit writer may
determine that specificity in the permit will ensure more reliable data, particularly where the sewage
sludge is variable or where past NPDES permit history suggests that the self-monitoring program is
questionable.
5.8 RECORD KEEPING REQUIREMENTS
Records must be kept to demonstrate that the permit conditions that implement all applicable Part 503
regulatory requirements are being met. Part 503 requires specific information be kept to show
compliance with pollutant concentrations, pathogen reduction, vector attraction reduction, and
management practices. These records must be retained for 5 years. The record keeping requirements
for surface disposal of sewage sludge are shown in Table 5-12. This table identifies the minimum
requirements for which records must be kept, who must keep the records, and how long they must be
retained.
The permit writer is obligated to include at least the minimum appropriate record keeping conditions in
each permit. Additionally, the permit writer may specify that other records be obtained or developed and
maintained by the permittee to determine compliance with permit conditions. For example, if the permit
writer determines that the active sewage sludge unit is located in a seismic zone, requirements to maintain
geologic studies and design calculations should be placed in the permit. The following technical
guidance provides examples of specific records the permit writer may want to require that the permittee
retain.
5.8.1 DOCUMENTATION FOR POLLUTANT CONCENTRATIONS
Whoever is required to meet pollutant concentration limits should be required to keep sampling and
analysis results documenting the pollutant concentrations. The permit writer should require that this
documentation include:
• Sampling records, including the date and time of sample collection, sample location, sample type,
sample volume, name of person collecting sample, sample container, field preservation, and
sampling QC.
• Analytical records including date and time of analysis, name of analyst, analytical methods,
laboratory bench sheets with raw data and calculations used to determine results, analytical QC
and analytical results.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
TABLE 5-12 RECORD KEEPING REQUIREMENTS FOR SURFACE DISPOSAL SITES
Record Keeping (§503.27)
(a) When sewage sludge (other than domestic septage) is placed on an active sewage sludge unit:
(1) The person who prepares the sewage sludge shall develop the following information and shall retain
the information for five years.
(i) The concentration of each pollutant listed in Table 1 of §503.23 in the sewage sludge when the
pollutant concentrations in Table 1 of §503.23 are met.
(ii) A certification statement (see Table 5-13).
(iii) A description of how the pathogen requirements in §503.32(a), (b)(2), (b)(3), or (b)(4) are met
when one of those requirements is met.
(iv) A description of how one of the vector attraction reduction requirements in §503.33(b)(l)
through (b)(8) is met when one of those requirements is met.
(2) The owner/operator of the surface disposal site shall develop the following information and shall
retain that information for five years.
(1) The concentration of each pollutant listed in Table 2 of §503.23 in the sewage sludge when the
pollutant concentrations in Table 2 of §503.23 are met or when site-specific pollutant limits in
§503.23(b) are met.
(ii) A certification statement (see Table 5-13).
(iii) A description of how the management practices in §503.24 are met.
(iv) A description of how the vector attraction reduction requirements in §503.33(b)(9) through
(b)(l 1) are met if one of those requirements is met.
5.8.2 DOCUMENTATION FOR PATHOGEN AND VECTOR ATTRACTION REDUCTION
Records must be maintained of certifications made by the preparer and the owner/operator that the
management requirements, pathogen reduction requirements, and vector attraction reduction requirements
were met and a description of how the requirements were met. Permit conditions should specify the
required certification statement to be used by the permittee. The statements to be used by the preparer
and by the owner/operator are presented in Table 5-13. These certifications must be signed by a
responsible individual from the facility. If the permit is an NPDES permit, there may already be
language in the standard conditions defining the person who must sign all records and reports. If not,
then the NPDES language in §122.22 may be used.
Draft-March 1993 5-104
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5. SURFACE DISPOSAL - PART 503 SUBPART C
TABLE 5-13 CERTIFICATION STATEMENTS FOR PATHOGEN
AND VECTOR ATTRACTION REDUCTION REQUIREMENTS
Preparer's certification statement
"I certify, under penalty of law, that the pathogen requirements, in [insert §503.32(a), §503.32(b)(2),
§503.32(b)(3), or §503.32(b)(4) when one of those requirements is met] and the vector attraction
reduction requirements in [insert one of the vector attraction reduction requirements in §503.33(b)(l)
through §S03.33(b)(8) when one of these requirements is met] have been met. This determination
has been made under my direction and supervision in accordance with the system designed to ensure
that qualified personnel properly gather and evaluate the information used to determine the [pathogen
requirements and vector attraction reduction requirements if appropriate] have been met. I am aware
that there are significant penalties for false certification including the possibility of fine and
imprisonment." . •
Owner/operator's certification statement
"I certify, under penalty of law, that the management practices in §503.24 and the vector attraction
reduction requirement in [insert one of the requirements in §503.33(b)(9) through §503.33(b)(l 1) if
one of those requirements is met] have been met. This determination has been made under my
direction and supervision in accordance with the system designed to ensure that qualified personnel
properly gather and evaluate the information used to determine that the management practices [and
the vector attraction reduction requirements if appropriate] have been met. I am aware that there
are significant penalties for false certification including the possibility of fine and imprisonment."
The description of how the pathogen and vector attraction reductions were met should be supported by
analytical results documenting pathogen density, logs documenting operational parameters for sewage
sludge treatment units, and records describing site restrictions to properly demonstrate compliance with
the provisions. Further discussion of the suggested monitoring and record keeping requirements and
supporting documentation is provided in Chapter 6.
5.8.3 DOCUMENTATION TO SHOW COMPLIANCE WITH MANAGEMENT PRACTICES
Records are required to contain a certification that the facility is meeting the management practices in
503.24 and to describe how the management practices have been met. There are specific signatory
requirements for the certification as discussed in the previous section. Please note that the signatory
requirements for certifying compliance with the management practice for aquifer non-contamination
differ. The permit writer, at a minimum, can require that a description be maintained in the records or
may be more specific in the permit as to the documentation that is required. If the permit writer decides
that more specific information is needed to determine compliance with a management practice, the permit
writer must specify in the permit the type of information or additional reports that are to be kept in the
records. '
The following discussions provide recommendations on the type of documentation that could be required
to demonstrate compliance with the management practices. Some information can be used for several
management practices so they have been grouped together. .
Draft-March 1993 5-105
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Endangered Species
The following documentation may be necessary to demonstrate that the site was evaluated for potential
effects on endangered species of plant, fish, or wildlife or their habitat and that necessary protective
measures were identified and implemented:
• The general proximity of the nearest critical habitat, including migration routes for endangered
species to the application site
• A description of how the nearby endangered species of plant, fish, or wildlife and their critical
habitat were protected from the disposal of sewage sludge
• A list of endangered or threatened species in the area or documentation that none exist
• If there are endangered or threatened species, a determination from the FWS or appropriate State
or local agency that the surface disposal activity will not likely adversely affect the survival of
the species or its critical habitat
• If the above determination indicates that adverse impacts can be avoided if specific measures are
taken, records containing documentation of the measures and how they have been implemented.
Flood Flow Restrictions
The types of information required to demonstrate compliance with flood flow restrictions may include
the following:
• A flood plain insurance rate map (available from the Federal Emergency Management Agency)
with the site location marked. Other sources of this information include the U.S. Army Corps
of Engineers, the USGS, Bureau of Land Management, Tennessee Valley Authority, and local
and State agencies.
• If the unit is in the 100-year flood plain, a description of the design details and management
practices that will prevent restricted flow of the base flood, including a plan view, a cross section
of the unit, and calculations used to determine that the site will not restrict the base flood flow.
Seismic Zone
The following types of information may be required to demonstrate compliance with the seismic impact
zone management standards:
• A seismic map available from State or local agencies with the site location marked on the map
• Reports from State or local agencies on earthquake activity
• The maximum recorded horizontal ground level acceleration (as a percentage of the acceleration
due to gravity (g), g=9.8 m/s2) (this information is probably contained in any reports on
earthquake activity obtained from State or local agencies)
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• The maximum recorded horizontal ground level acceleration (as a percentage of the acceleration
due to gravity (g), g=9.8 m/s2) (this information is probably contained in any reports on
earthquake activity obtained from State or local agencies)
• A reconnaissance of the site that focuses on slopes that may have had the toe removed, water
seeps from the base of a slope, less resistant strata at the base of a slope, posts and fences that
are not aligned, utility poles with sagging or too tight wires, leaning trees, or cracks in walls and
streets
• If the surface disposal site is located in a seismic impact zone, documentation on design
modifications to accommodate the ground motion from earthquakes, such as shallower unit side
slopes, more conservative design of dikes and runoff controls, and contingency plans for leachate
collection systems
• Design plans for the unit indicating the maximum ground motion that unit components are
designed to withstand, including foundations, embankments, leachate collection systems, liners
(if installed), and any ancillary equipment that could be damaged from the seismic shocks
• Copy of local building codes applicable to the unit and building permits
• Certification by an engineer with seismic design and geotechnical experience that the unit is
designed to withstand the maximum recorded horizontal ground level acceleration.
Fault Zones
Documentation to support this management practice may include the following:
• A Holocene fault map [available from local, State agencies, or the U.S. Geological Survey
(USGS)] with the site location marked on the map. In 1978, the USGS published a map series
identifying the location of Holocene faults in the United States (Preliminary Young Fault Maps,
MF916). For areas along Holocene faults, a reconnaissance of the site and surrounding areas
should be performed to determine if movement has occurred since 1978.
• A report on the area reconnaissance findings of the site, emphasizing the location of faults,
lineaments, or other features associated with fault movement, such as offset streams, cracked
culverts and foundations, shifted curbs, scarps, or other linear features.
• A geotechnical report on the site indicating the presence or absence of any faults or lineations.
Unstable Areas
The following information may be required to demonstrate that the surface disposal site and individual
sewage sludge units are located in stable areas:
• A detailed geotechnical and geological evaluation of the stability of the foundation soils, adjacent
manmade and natural embankments and slopes
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• An evaluation of the ability of the subsurface to support the active sewage sludge unit adequately,
without damage to the structural components.
Wetlands
The types of information necessary to demonstrate compliance with wetlands restrictions may include the
following:
• The location of the site on a wetlands delineation map, such as a National Wetlands Inventory
map, Soil Conservation Service (SCS) soil map, or a local wetlands inventory map
• A permit or permit application for a Section 402 or Section 404 permit
• Description of wetlands assessment conducted by a qualified and experienced multidisciplinary
team, including a soil scientist and a botanist or biologist.
Storm Water Run-off Controls
The types of information required to support this management practice may include the following:
• Copies of the NPDES permit and any other permits
• Description of the design of the system used to collect and control run-off, including plan view,
drawing details, cross sections, and calculations showing that the system has the capacity to
collect total run-off volume
• Calculation of peak run-off flow, including data sources and methods used to calculate the peak
run-off flow
• Description of inspection and maintenance required for the system
• Description of the procedures for managing liquid discharges and complying with NPDES and
other requirements.
Leachate Collection and Control
If the unit has a liner and leachate collection and removal system (LCRS), the owner/operator must
present evidence that the LCRS is properly operated and maintained. In addition, documentation must
indicate that the leachate is properly disposed. The types of information required to demonstrate
compliance with the management standards for leachate collection and removal systems may include the
following:
• Detailed material specifications for the liner, including drainage layer, filter layer, piping, and
sumps
• Description of the LCRS design, leak detection, and removal of leachate and liquid from the
system
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Design details, including layout of system and components shown in plan view and cross section,
spacing and configuration of pipes, sumps, pumps, drainage plans
• Test results demonstrating the system's compatibility with sewage sludge and leachates for all
system components and materials
• Description of inspection and maintenance of systems and schedules
• Operational plan describing method of treatment and/or disposal of leachate and disposal
schedules.
Methane Monitoring and Control
Methane monitoring and controls are required at covered sewage sludge units while they are active and
for 3 years after closure. The system should be designed by an engineer with experience in methane
monitoring and extraction systems at landfills, surface impoundments, or sewage sludge units. The
methane monitoring system is required to detect the presence of methane in site structures and at the
property line. Alarms, lights, or other warning devices should be deployed to notify site personnel of
any methane levels exceeding 25 percent of the lower explosive limit (LEL) for methane in facility
structures and levels exceeding 100 percent of the LEL for methane at the property line. Contingency
plans should be developed as part of the methane monitoring plan. The types of information required
to demonstrate compliance with the management standards may include the following:
• Description of the system design, including plan view, drawing details, cross sections, and
calculations showing that the system can monitor and manage methane generated
• Design details of the site, including monitoring locations, spacing and layout of any piping,
vents, pumps, collection wells
• Descriptions of methane monitoring schedules, alarm systems, emergency procedures,
contingency plans, system maintenance schedules, and methane mitigation
• Cover design details, including plan view of the unit, details of penetrations for gas vents, and
cross sections at several points
• Results of methane monitoring, including the minimum, maximum, and average levels recorded.
Aquifer Contamination
The placement of sewage sludge on a sewage sludge unit shall not contaminate an aquifer. Part 503
allows two options for demonstrating compliance with this management practice; either a certification
based on the results of a ground-water monitoring program or a certification by a qualified ground-water
scientist that, due to site-specific factors, the aquifer is not contaminated.
The first certification described above should be signed by an authorized representative of the surface
disposal site. The permit writer should require that the ground-water monitoring records be retained with
the certification.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
The second type of certification, which is supplied by a qualified ground-water scientist, must be
supported by documentation that demonstrates a hydrogeologic assessment has been made which indicates
that the aquifer is not contaminated. This documentation may include:
• Description of the methods used to reduce the possibility of contaminating ground water, such
as liners and leachate. collection systems
• Demonstration that the liner construction and/or geology of the site are sufficient to retard liquid
flow during the active life and post closure period
• Data indicating that ground water is at a great depth, or hydrologic data demonstrating low
rainfall at the site such that there is a low probability that contaminants will leach to ground
water.
Food, Feed or Fiber Crops
Growing food, feed or fiber crops on any active sewage sludge unit is prohibited, unless explicitly
authorized by the permitting authority. A certification that no food, feed or fiber crop was grown may
be sufficient documentation. The owner/operator could also be required to list the type of vegetation
grown (if any). If crops are grown, then the permit writer will need to specify the records and
documentation that must be maintained to demonstrate compliance with the site-specific management
practices established to protect the public health and environment. For example, the permit writer might
require crop tissue sampling and analysis of pollutants.
Grazing
Animal grazing on active sewage sludge units is prohibited, unless specifically authorized by the
permitting authority. The type of information necessary to demonstrate compliance with the grazing
restriction on active sewage sludge units may include a certification that no animal grazing occurred or
a description (and map showing the placement) of animal restriction devices, such as grates at gate
entrances or electrified fencing.
If animal grazing is allowed, the permit writer will need to specify the records and documentation that
must be maintained to demonstrate that the site-specific management practices are being implemented.
For example, the permit writer may want to require periodic analysis of animal tissue.
Public Access
The following types of information may be required to demonstrate compliance with the public access
restriction standards:
• Site map, showing the access control locations
• Description of access restriction measures, such as placement of vehicle barriers, signs, and
construction plans with the placement and configuration of fences and gates
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Material specifications for fencing, barbed wire, gates, locks, vehicle barriers, and any other
access barrier
• Language on warning signs
• Inspection schedule for the access controls and repair procedures
• Schedules for security guard postings or security inspections.
Storage of Sewage Sludge
As discussed at the beginning of this chapter, sewage sludge which is stored on the land for less than 2
years is not covered by Part 503. Records are required to be kept on the rationale for placing sewage
sludge on land for a period of time greater than 2 years. At a minimum, this rationale must include the
following:
• The name and address of the person who prepares the sewage sludge
• The name and address of the person who either owns the land or leases the land
• The location, by either street address or latitude and longitude, of the land
• An explanation of why sewage sludge needs to remain on the land for longer than two years
prior to final use or disposal
• The approximate time period when the sewage sludge will be used or disposed.
The permit writer must determine if there are mitigating factors at the site justifying this longer storage
period. The permit writer may want to develop specific conditions pertaining to sewage sludge storage.
If necessary, the permit writer may want to stipulate that the facility develop plans to eliminate or reduce
long-term storage.
5.9 REPORTING REQUIREMENTS
Statement of Regulations
§503.28(a) Class I sludge management facilities, POTWs (as defined in 40 CFR 501.2) with a design flow
rate equal to or greater than one million gallons per day, and POTWs that serve 10,000 people
or more shall submit the information in 503.27(a) to the permitting authority on February 19
of each year. ,
Only a subset of facilities required to keep records are required to report under Section 503.28 of the
regulations. The reporting requirements in §503.28 apply to the following facilities:
• Class I sludge management facilities
• Publicly owned treatment works with a flow rate equal to or greater than one mgd
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5. SURFACE DISPOSAL - PART 503 SUBPART C
• Publicly owned treatment works serving
a population of 10,000 or greater.
However, the permit writer has the authority and
discretion to require reports from other facilities
not specified in Part 503. Under the NPDES
regulations, the permitting agency may designate
any treatment works treating domestic sewage as
a Class I facility because of the potential for its
sewage sludge use or disposal practices to
adversely affect public health and the
environment. The permit writer may want to
consider the following conditions to determine the
need for a facility to report:
• The amount of sewage sludge being
handled or treated
• The design of the surface disposal site
• The operational and management
practices at the site
A Class I sludge management facility is any
publicly owned treatment works (POTW), as
defined in 40 CFR 501.2, 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 treatment works
treating domestic sewage, as defined in 40
CFR 50|;2, classified as a Class I sludge
managemeifit facility by the EPA Regional
Administrator,: or, in the case of approved
State prbgrams; the EPA Regional
Administrator in conjunction with the State
Director, because of the potential for its
sewage sludge use or disposal practices to
affect public health and the environment
adversely; 40 CFR 503.7(b).
• Other conditions which show the potential for any adverse effect to public health and the
environment.
The reporting requirements specify that facilities report annually on the information they are required to
develop and retain under §503.27. The permit writer should develop permit conditions that specifically
identify the information that must be reported, the date(s) by which the information must be received,
and the address to which the report must be submitted.
When the permittee is instructed to report the results of sludge analyses for pollutant concentrations as
Sections 503.27(a)(l) and (2) require, he/she should be required to include the following information:
• Units for reported concentrations
• Dry weight concentrations
• Number of samples collected during the monitoring period
• Number of excursions during the monitoring period
• Sample collection techniques
• Analytical techniques.
The permittee should report separately all data collected (using EPA approved methods) during the
reporting period.
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5-112
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5. SURFACE DISPOSAL - PART 503 SUBPART C
The permittee should identify the specific elements to be contained in the description of how the pathogen
and vector attraction reduction requirements were met. Refer to Chapter 6 for a detailed discussion of
appropriate elements for each pathogen reduction and vector attraction reduction alternative.
The permit writer may also require that additional information be reported needed to determine the
compliance status of the facility. In the case where additional information is needed, the permit writer
must specifically require that information in the permit. Additional information that may be needed
includes:
• The amount of sewage sludge being handled or treated
• Special studies required to ensure management conditions are met (e.g., examination of
endangered species habitat)
• Notification of changes in sludge quality.
The permit writer will need to consider whether a yearly reporting requirement is sufficient. He/she may
want to require some reports to be submitted at a more frequent interval than the yearly reporting
requirement. Situations that may warrant the inclusion of more frequent reporting include:
• Where sewage sludge data show significant variations in quality or sewage sludge data indicate
a trend toward poorer quality sewage sludge. In these cases, more frequent reporting may assist
the permitting authority in addressing problems before violations.
• Where conditions at the site warrant more frequent reporting of the certification for management
practice to ensure compliance with the practices.
• Where a compliance schedule was specified.
The permit writer may also want to specify the reporting format through the permit. Separate guidance
documents containing recommended reporting formats have been provided to the regulated community
as listed below:
• Monitoring, Record Keeping and Reporting Requirements for Generators and Preparers of
Sewage Sludge (EPA 1992, draft).
• Monitoring, Record Keeping and Reporting Requirements for Land Appliers of Sewage Sludge
(EPA 1992, draft).
The permit writer should instruct the permittee to submit reports to the Water Compliance Chief at the
appropriate EPA Regional office or to the appropriate State counterpart in an approved State. The permit
should require that the reports be signed by an authorized representative. If the permit is an NPDES
permit, the standard conditions may already contain language defining the authorized representative. If
not, then the regulatory language found in §122.22 may be included to clearly identify the authorized
representative.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
Signatory Requirement
(1) All certifications, reports, or information submitted shall be signed as follows:
(a) For a corporation: by a responsible corporate officer. For the purpose of this section, a responsible
corporate officer means: (1) a president, secretary, treasurer, or vice-president of the corporation in charge of
a principal business function, or any other person who performs similar policy or decision-making functions
for the corporation; or (2) the manager of one or more manufacturing, production or operating facilities
•'•--•"' employing more than 250 persons or having gross annual sales or expenditures exceeding $25,000,000 (in
second-quarter 1980 dollars) if authority to sign documents has been assigned or delegated to the manager in
accordance with corporate procedures; :.:0 : . .••'.":;.:'.•
(b) For a partnership or sole proprietorship: by a general partner or the proprietor, respectively; or
(c) For a municipality, State, Federal, or other public agency: by either a principal executive officer or ranking
elected official. For purposes of this part, a principal executive officer of a Federal agency includes (!) the
chief executive officer of the agency, or (2) a senior executive officer having responsibility for the overall
operations of a principal geographic unit of the agency (e.g., Regional Administrators of EPA).
(2) AH reports required by the permit and other information requested by the Department shall be signed by a person
described above or by a duly authorized representative of that person.
A person is a duly authorized representative only if: : :
(a) The authorization is made in writing by a person described above and submitted to the Department with the
reports. .
(b) The authorization specifies either an individual or a position having responsibility for the overall operation of
the regulated facility or activity, such as the position of manager, operator, superintendent, or position of
equivalent responsibility or an individual or position having overall responsibility for environmental matters
for the company. (A duly authorized representative may thus be either a named individual or any individual
occupying a named position.)
. (3) Changes in Authorization. If an authorization is no-longer accurate because a different individual or position has
responsibility for the overall operation of the facility, a new authorization satisfying the above requirements must be
submitted to the Department prior to or together with any reports, information, or applications to be signed by an
authorized representative.
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5. SURFACE DISPOSAL - PART 503 SUBPART C
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS
Scenario 1: Surface Disposal
Parties involved:
Description:
Issue permit to:
One POTW that is an owner/operator of a surface disposal site
The City of Fragrance operates a 2 mgd design capacity POTW which accepts only
commercial and domestic wastewater. Approximately 700 tons of sewage sludge are
generated each year and are dewatered with a belt press prior to being disposed in a
surface disposal site (monofill) owned by the City. The surface disposal site is ten
years old and has no liner or leachate collection system. The surface disposal site
contains an active sewage sludge unit that has been used for only the past year. The
active sewage sludge unit is in the immediate vicinity of a housing complex and is
also bordered by a preschool. The sewage sludge is applied to the active sewage
sludge unit within 75 meters from the property line. It is not known whether the
entire surface disposal site is located within a flood plain. There are no groundwater
monitoring wells installed to date.
The City of Fragrance POTW
Permit Conditions for the Generator/Owner
Standard conditions
General requirements
Pollutant limits
Pathogen and vector attraction reduction requirements
Management practices that apply
Monitoring requirements
Record keeping requirements
Reporting requirements
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5-115
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5. SURFACE DISPOSAL - PART 503 SUBPART C
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Scenario 2: Surface Disposal
Parties involved:
Description:
Issue permit to:
Several generators
Owner/operator of surface disposal unit
Pleasant Township, the Greater Metropolitan Water and Sewer District No. 1, and
Turbid City operate separate POTWs which dispose of their sewage sludge at
Municipal Disposal, Inc.'s surface disposal site located in the middle of all three
communities. Each of the POTWs has a design capacity of approximately 3.5 mgd
and produces more than 1225 tons (dry weight) of sewage sludge per year each.
Industrial users discharge wastewater to each POTW and the Pleasant Township
POTW treats wastewater from numerous metal finishers. The surface disposal site
has three sewage sludge units which have been active for more than five years. All
of the active sewage sludge units are lined, have leachate collection systems, and are
circled by groundwater monitoring wells. A daily cover is placed over sewage
sludge. No sewage sludge is disposed within 150 meters of the property boundary.
The aquifer below the unit shows no sign of contamination and the unit is in a
geologically stable area. Municipal Disposal, Inc. was determined not to be a Class
I sludge management facility by the EPA Regional Administrator.
The three POTWs and the owner/operator of the surface disposal site, Municipal
Disposal, Inc.
Permit Conditions for the Generators
Standard conditions
Record keeping requirements
Permit Conditions for Owner/Operator of Surface Disposal Unit
Standard conditions
General requirements
Management practices that apply
Cover requirement
Monitoring requirement
Record keeping requirements
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5-116
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5. SURFACE DISPOSAL - PART 503 SUBPART C
REFERENCES
Aller, et al. 1985. DRASTIC: A Standardized System for Evaluating Ground Water Pollution Potential
Using Hydrogeologic Settings. U.S. EPA. Robert S. Kew Environmental Research Laboratory. Ada,
OK.
Barfield, B.J., R.C. Warner and C.T. Haan. 1981. Applied Hydrology and Sedimentology for Disturbed
Areas. Oklahoma Technical Press.
Dunne, Thomas and Lyna B. Leopold. 1978. Water in Environmental Planning. W.H. Freeman and
Co.
Federal Emergency Management Agency (FEMA). 1980. How to Read a Flood Insurance Rate Map.
Washington, DC. Available from FEMA Regional Office.
FEMA. 1992. The National Flood Insurance Program Community Status Book. GPO. Washington,
DC. (Each publication is for one State and is updated annually).
FEMA. 1991. NEHRP Recommended Provisions for the Development of Seismic Regulations for New
Buildings. Washington, DC: Building Seismic Safety Council.
Keller, E.A. 1978. Environmental Geology. Charles E. Merrill Publishing Co., Columbus, Ohio.
Maynard, S.T. 1978. "Practical Riprap Design." Hydraulics Laboratory Miscellaneous Paper H-78-7.
U.S. Army Engineers Waterways Experiment Station. Vicksburg, MS.
McCandless, R.M., A. Bodoczi and P.R. Cluxton. 1986. Geotechnical Analysis for Review Dike
Stability (GARDS). Technical Manual. Cincinnati,.OH: U.S. Environmental Protection Agency, Office
of Research and Development.
Merritt, Frederick S. 1983. Standard Handbook for Civil Engineers. McGraw-Hill Book Co. Third
Edition.
Public Law 99-399. 1986. Safe Drinking Water Act (SOWA).
U.S. Army Corps Of Engineers. 1970. Laboratory Soils Testing. EM 1110-2-1906.
U.S. Army Corp of Engineers. 1989. Federal Manual for Identifying and Delineating Jurisdictional
Wetlands. Washington, DC: U.S. Army Corps of Engineers, U.S. EPA, U.S. Fish and Wildlife
Service, and USDA Soil Conservation Service; Cooperative Technical Publication.
U.S. Department of Agriculture. 1983. Maryland Standards and Specifications for Soil Erosion and
Sediment Control. College Park, MD: Soil Conservation Service.
U.S. Department of Agriculture. 1986. Urban Hydrology for Small Watersheds. Soil Conservation
Service. PB87-101580.
Draft-March 1993 5-117
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5. SURFACE DISPOSAL - PART 503 SUBPART C
U.S. Department of Commerce. Technical Paper 40. Rainfall Frequency Atlas of the United States for
Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100 Years. National Weather
• Service.
U.S. Department of Navy. 1983. Soil Dynamics, Deep Stabilization, and Special Geotechnical
Construction. Design Manual. NAVFAC DM-7.3. Washington, DC.
U.S. Environmental Protection Agency (EPA). 1978. Process Design Manual-Municipal Sludge
Landfills. Washington, DC: Office of Solid Waste. EPA/625/1-78-010.
U.S. EPA. 1980. Procedures Manual for Ground Water Monitoring at Solid Waste Disposal Facilities.
Office of Water and Waste Management. SW-611.
U.S. EPA. 1983a. Draft Permit Writers' Guidance Manual for Hazardous Waste Land Treatment,
Storage, and Disposal Facilities. Volumes 1 and 2. Washington, DC: Office of Solid Waste and
Emergency Response. '
U.S. EPA. 1983b. Methods for the Chemical Analysis of Waters and Wastes. Environmental
Monitoring and Support Laboratory.
U.S. EPA. 1985. Remedial Action at Waste Disposal Sites. Handbook. Washington, DC: Office of
Emergency and Remedial Response. EPA/625/6-85/006 (9380.0-04).
U.S. EPA. 1987. Test Methods for Evaluating Solid Waste-Physical/Chemical Methods. Washington,
DC: Office of Solid Waste and Emergency Response. EPA SW-846. Third edition and Update to the
Third Edition.
U.S. EPA. 1988a. Geotechnical Analysis for Review of Dike Stability (CARDS). Cincinnati, OH: Office
of Research & Development.
U.S. EPA. 1988b. Guide to Technical Resources for the Design of Land Disposal Facilities. (Location):
Risk Reduction Engineering Laboratory. EPA/625/6-88/018.
U.S. EPA. 1988c. Guidelines for Ground Water Classification Under the Ground Water. Protection
Strategy. Washington, DC: Office of Ground-Water Protection.
U.S. EPA. 1988d. "Solid Waste Disposal Facility Criteria." Proposed Rule. 40 CFR Parts 257 and
258. Federal Register. 53 FR 33314, August 30, 1988.
U.S. EPA. 1988e. Design, Construction, and Evaluation of Clay Liners for Waste Management
Facilities. Washington, DC: Office of Solid Waste and Emergency Response. NTIS PB 86-134496.
U.S. EPA. 1989a. Final Covers on Hazardous Waste Landfills and Surface Impoundments. Technical
Guidance Document. Washington, DC: Office of Solid Waste and Emergency Response. EPA/530-SW-
89-047.
U.S. EPA. 1989b. POTW Sludge Sampling and Guidance Document. Permits Division.
Draft-March 1993 5-118
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5. SURFACE DISPOSAL - PART 503 SUBPART C
U.S. EPA. 1989c. Requirements for Hazardous Waste Landfill Design, Construction, and Closure.
Seminar Publication. Washington, DC: Office of Research and Development. EPA/625/4-89-022.
U.S. EPA. 1989d. Sampling Procedures and Protocols for the National Sewage Sludge Survey.
Washington, DC.
U.S. EPA. 1989e. "Standards for the Disposal of Sewage Sludge." Proposed Rule. 40 CFR Parts 257
and 503. Federal Register. 54 FR 5746, February 6, 1989.
U.S. EPA. 1990. Guidance for Writing Case-by-Case Permit Requirements for Municipal Sewage
Sludge. Washington, DC: Office of Water. EPA/505/5-90-001.'
U.S. EPA. 1991a. Design and Construction of RCRA/CERCLA Final Covers. Seminar Publication.
Washington, DC: Office of Research and Development. EPA/625/4-91/025.
U.S. EPA. 1991b. "Solid Waste Disposal Facility Criteria." Final Rule. 40 CFR Parts 257 and 258.
Federal Register. 56 FR 50978, October 9, 1991.
U.S. EPA. 1991c. "Protecting the Nations Ground-Water: EPA Strategy for the 1990s." Final Report.
Office of the Administrator, 21Z-1020.
U.S. EPA. 1992a. Draft Technical Manual for Solid Waste Disposal Facility Criteria. 40 CFR Part
258. Washington, DC: Office of Solid Waste.
i
U.S. EPA. 1992b. Draft Storm Water Pollution Prevention for Industrial Activates. Washington, DC:
Office of Water.
U.S. Geological Survey. 1978. Preliminary Young Fault Maps. (MF916).
Washington State Department of Ecology. 1992. Draft Stormwater Management Manual for the Puget
Sound Basin.
Winterkorn, H.F. and H.Y. Fang. 1975. Foundation and Engineering Handbook. Van Nostrand
Reinhold. New York.
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6. PATHOGENS AND VECTOR ATTRACTION
REDUCTION - PART 503 SUBPART D
QUICK REFERENCE INDEX
OVERVIEW
SPECIAL DEFINmONS
CLASS A SLUDGE PATHOGEN REDUCTION REQUIREMENTS
ALTERNATIVE 1
ALTERNATIVE 2
ALTERNATIVE 3
ALTERNATIVE 4
ALTERNATIVE 5
ALTERNATIVE 6
CLASS B SLUDGE PATHOGEN REDUCTION REQUIREMENTS
ALTERNATIVE 1
ALTERNATIVE 2
ALTERNATIVE 3
CLASS B SLUDGE SITE RESTRICTIONS
VECTOR ATTRACTION REDUCTION REQUIREMENTS
ALTERNATIVE I
ALTERNATIVE 2
ALTERNATIVE 3
ALTERNATIVE 4
ALTERNATIVE 5
ALTERNATIVE 6
ALTERNATIVE 7
ALTERNATIVE 8
ALTERNATIVE 9
ALTERNATIVE 10
ALTERNATIVE 1 1
Section Page
6.1 6-1
6.2 6-7
6.3 6-9
6-10
6-12
6-13
6-15
6-16
6-19
6.4 6-20
6-21
6-22
6-24
6.5 6-24
6.6 6-26
6-27
6-28
6-29
6-30
6-30
6-31
6-32
6-32
6-33
6-33
6-34
6.1 OVERVIEW
This chapter provides guidance on the implementation of the requirements for pathogen and vector
attraction reduction in Part 503, Subpart D. The requirements in this Subpart apply to sewage sludge
that is land applied or placed on a surface disposal site and to the sites on which such disposal practices
take place. This chapter assumes that the permit writer has determined that the sewage sludge is
regulated under Part 503 (see Chapter 2) and has identified the sewage sludge use or disposal practice
as either land application or surface disposal (see Chapters 4 and 5).
Draft-March 1993 6-1
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION r PART 503 SUBPART D
For the purpose of this regulation, "pathogens"
and "vector attraction" are defined as follows:
Pathogenic organisms are disease-causing
organisms. These include, but are not limited
to, certain bacteria, protozoa, viruses, and
viable helminth ova. 40 CFR 503.3 l(f).
Vector attraction is the characteristic of
sewage sludge that attracts rodents, flies,
mosquitos, or other organisms capable of
transporting infectious agents. 40 CFR
503.31(k).
6.1.1 GENERAL CHARACTERISTICS OF
PATHOGENS AND DISEASE
VECTORS
Pathogen content and vector attraction are
characteristics of sewage sludge that directly
affect the potential for sewage sludge use or
disposal practices to transmit communicable
human diseases. Therefore, the Part 503
regulations require sewage sludge to be treated to
reduce the pathogen levels and vector attraction
characteristics. This section will discuss the
general characteristics of pathogens and disease
vectors. In addition, several considerations in the
reduction and control of pathogens and vectors
will be mentioned. ^1—|li^-|^^—^^^^B—il|-B|B—lii|il||-—i-||11^—1,,,
General Characteristics of Pathogens
Pathogens are organisms capable of causing diseases. These include certain bacteria, fungi, viruses,
protozoa (and their cysts) and intestinal parasites (and their ova). These organisms produce disease by
entering the body, and then interfering with one or more metabolic functions. The diseases produced are
communicable because the organisms are transferred from infected hosts to potential hosts through either
direct or indirect physical contact.
Pathogens found in domestic wastewater are contributed by the following sources:
• Residential wastes, including those related to personal hygiene, toilet use, clothes washing and
food preparations
• Commercial food processing and preparation wastewaters
• Street run-off (in systems with combined sewers).
These organisms enter the wastewater treatment plant in both active and inactive states (see the discussion
below of individual organism types). Regardless of type, pathogenic organisms are removed relatively
efficiently by sedimentation and entrainment in biological floes in secondary treatment. In the absence
of disinfection, pathogenic organism removal rates can be well in excess of 90 percent. Nevertheless,
this still leaves sufficient levels of organisms in the wastewater treatment plant effluent to pose a health
threat - hence the inclusion of disinfection requirements in most permits to facilities processing domestic
wastewaters. The efficiency with which most pathogenic organisms are removed by wastewater treatment
plants results in them being concentrated in sewage sludge. The general pathogen types are as follows:
• Bacteria — Bacteria are single celled organisms. In general, bacteria are the only pathogens that
can carry out their entire life cycle outside of a "host," or infected organism. Pathogenic bacteria
are heterotrophic; that is, they use organic materials as both carbon and energy sources. Because
pathogenic bacteria can complete their life cycles outside man (or another host), sewage sludge
Draft—March 1993
6-2
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
that has been treated to reduce pathogens can be reinfected. or may exhibit an increase in
bacterial concentration under conditions favorable to the bacteria.
• Viruses — Viruses are wholly parasitic in nature. They are capable of reproducing only through
the invasion of the host organism's own cells. Viruses that cause disease in man are typically
present in the gut, and thus are routinely present in wastewater. Viruses have been found to be
removed effectively by sedimentation (presumably through entrainment in sewage sludge floe
particles) and are thereby concentrated in sewage sludges.
• Parasites — Parasites include protozoa, and a variety of multi-cellular animals, all of which
utilize the resources of their host's body to complete their life cycle. Protozoa are single-celled
organisms which form cysts. Cysts remain dormant until ingested by a host. In the host's gut
the cyst is changed into an active protozoan, which in turn releases cysts to be expelled with the
feces.
Most of the multicellular parasites are worms of various types. These infect their host through
the ingestion of their ova. The ova changes to an active worm in the gut. Some types then
remain in the gut, while others invade other body tissues. For example, helminth are flatworms
which are commonly associated with meat-animals (such as cattle and sheep) and with rodents.
Disease is caused by the development of one or more worms in the gut. In the case of some
helminths, the worm(s) will migrate to other tissues, such as the heart or nervous system. These
later conditions are potentially fatal to the infected host.
• Fungi — Fungi are non-photosynthetic plants which reproduce by generating spores. The
pathogenic nature of certain fungi is exhibited when the spores are inhaled by man. In general,
the pathogenic effect exhibited is the result of the growth of the fungi in the nasal passages,
throat, mouth or lungs of the individual.
General Characteristics of Disease Vectors
Vector attraction is any characteristic which attracts disease vectors. Disease vectors are animals which,
as a result of some aspect of their life cycle, are capable of transporting and transmitting infectious
agents. Their interaction with man provides a pathway for the transmission of disease. Vectors are
themselves not pathogenic. Vectors fall into two broad categories:
• Insects — These include fleas, flies and mosquitos. They typically transmit disease through their
feeding habits; in the case of mosquitos and fleas pathogens are picked up and spread by the
biting and feeding on infected animals or humans, and subsequently feeding on an uninfected
animal or human. Flies and certain other insects typically transmit disease through the
contamination of exposed food on which they are feeding.
• Mammals — Rodents are the most well known mammalian vectors but other mammals, including
feral domestic animals, can act as disease vectors. In general, mammals act as disease vectors
by acting as hosts for infected insects (such as fleas) and transporting the infected insects to
places where they may come into contact with man.
Draft-March 1993 6-3
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
In general, unprocessed sewage sludge contains an organic component which is an attractive food source
to certain vectors. Specific components of raw sewage sludge which act as attractants include feces and
food wastes.
General Technical Considerations in Controlling Pathogens and Reducing Vector
Attraction
The reduction of the pathogen content of any sewage sludge requires the following:
• That the sewage sludge be exposed to conditions which are sufficiently physiologically
disadvantageous for the pathogenic organisms, for a sufficient length of time, that destruction of
the pathogenic organisms takes place.
• To the extent possible, the characteristics of the raw sewage sludge should be permanently altered
such that if any exposure to pathogenic organisms occurs after sewage sludge processing, the
likelihood of re-infection is minimized.
• Following processing to reduce pathogens, sewage sludge should be handled in a manner so as
to minimize the chance for reintroduction of pathogenic organisms. Reintroduction most often
occurs through contact or mixing with raw sewage sludge prior to disposal.
While pathogenic organism reduction is not the primary goal of most of the sewage sludge stabilization
processes in use at wastewater treatment plants, these processes are generally effective at reducing
pathogens. Commonly used sewage sludge stabilization processes which reduce pathogens include:
• Anaerobic digestion
• Aerobic digestion
• Chemical stabilization
• Wet-air oxidation
• Heat treatment.
These processes exhibit pathogen reduction characteristics which range from significant to virtual
sterilization.
One of the primary goals of most sewage sludge stabilization processes is reducing putrescibility, which
directly affects the tendency for sewage sludge to attract disease vectors. In general, efforts to reduce
the attraction of disease vectors to sewage sludge require some or all of the following:
• Reduction in the sewage sludge's organic content
• Disposal of the sewage sludge such that the possibility of direct access to the sewage sludge by
vectors is minimized
• Modification of the sewage sludge's chemical characteristics to make it unattractive to vectors.
Draft—March 1993 6-4
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
The pathogen reduction and vector attraction reduction alternatives allowed under Part 503 acceptably
reduce pathogen levels and vector attraction qualities of sewage sludge.
6.1.2 ROLE OF THE PERMIT WRITER IN APPLYING PATHOGEN REDUCTION AND
VECTOR ATTRACTION REDUCTION REQUIREMENTS
The permit writer needs to review the permittee's application and to verify that the chosen pathogen
reduction and vector attraction reduction requirements are appropriate based on:
• Existing and proposed sewage sludge treatment process(es)
• Sewage sludge pathogen levels and vector attraction characteristics achieved by the sewage sludge
treatment process(es)
• The final use or disposal method employed or proposed.
Based on the evaluation of these factors, the permit writer will need to specify the following:
• The specific alternatives under which the permittee may demonstrate compliance with pathogen
reduction and vector attraction reduction requirements
• Monitoring and reporting requirements for the specified alternatives.
Pathogen and Vector Attraction Reduction Requirements
Prior to the Part 503 rule, sewage sludge pathogen control was demonstrated through the use of certain
treatment processes that provided the required level of pathogen control. Under Part 503, monitoring
of pathogen densities to directly demonstrate pathogen control will be required. The Part 503 pathogen
reduction alternatives do not specify the type of processes to be used to eliminate the pathogens. Any
process that meets the pathogen density and vector attraction reduction performance level and the
operating parameters specified by the alternative can be used.
The sewage sludge must meet the pathogen density levels:
• At the time it is applied to or placed on the land
• At the time it is placed in a bag or other container for sale or give away
• At the time that it meets all the requirements necessary to be considered "Exceptional Quality."
Twelve vector attraction reduction requirements are included in §503.33. One of these requirements only
applies to septage and therefore, will not be discussed in this chapter. These requirements, like the
pathogen reduction requirements, should be considered by the permit writer as alternatives. Further
discussion of these alternatives is provided in Section 6.4.
As land application practices generally provide greater opportunity for human contact with the sewage
sludge being used or with vectors attracted by those uses, somewhat more stringent requirements are
Draft—March 1993 6-5
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
*
applied by Part 503 to the land application of sewage sludge than to the surface disposal of sewage
sludge.
Land Application
A sewage sludge will be determined to be either Class A or Class B based on pathogen reduction
alternatives and measured pathogen densities. The Class A pathogen reduction requirements result in
sewage sludges having low pathogen densities; as a result, no site restrictions are applied to sites on
which Class A sewage sludges are applied.
Surface Disposal
Sewage sludge to be disposed in a surface
disposal unit must meet the pathogen reduction
requirements of either Class A or Class B sewage
sludge.
Monitoring Requirements
For those alternatives that establish pathogen
reduction performance levels and vector attraction
reduction performance levels, the monitoring ^^^^^^^^^^^^^^^^^^^^^^^^^™
frequency shall be specified in Table 6-1.
TABLE 6-1 MONITORING FREQUENCY FOR PATHOGEN DENSITY LEVELS AND
VOLATILE SOLIDS REDUCTION OR SOUR
Processes to Significantly Reduce Pathogens
(PSRP) and Processes to Further Reduce
Pathogens (PFRP) — specific sludge treatment
process(es) which were first defined in 40 CFR
Part 257, 44 FR 53460, September 13, 1979.,
These processes are defined on the basis of
operational criteria, rather than performance
criteria. They are discussed in detail in Section
6.3 below.
Amount of sewage sludge*
(metric tons per 365 day period)
Greater than zero but less than 290
Equal to or greater than 290 but less than 1,500
Equal to or greater than 1,500 but less than 15,000
Equal to or greater than 15,000
Frequency
once per year
once per quarter (four times per year)
once per 60 days (six times per year)
once per month (12 times per year)
* Either the amount of bulk sewage sludge applied to the land or the amount of sewage sludge
received by a person who prepares the sewage sludge for sale or give away in a bag or other
container for application to the land (on a dry weight basis).
The permit writer has the authority and discretion to specify greater frequencies of monitoring. Reasons
for doing so may include:
• Very high potential for contact by the public with the use or disposal site
• A history of poor sewage sludge management on the part of the permittee.
Draft—March 1993
6-6
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
In specifying monitoring frequency, the permit writer should:
• Make clear the minimum frequency required for each limited parameter
• Include language noting the need to submit all data if monitoring is carried out more frequently
than specified.
In requiring operational monitoring, the permit writer should also specify the required frequency of
monitoring. The frequency specified should reflect:
• Good practice in the operation of sewage sludge treatment processes
• The size and complexity of the facility and the treatment units involved.
For more insight into what constitutes appropriate operational monitoring, the permit writer is referred
to:
• Operation of Wastewater Treatment Plants, MOP 11, WEF
• Sludge Handling and Conditioning, EPA 430/9-78-002
The permit writer should specifically require that the analytical techniques specified in §503.8 be used.
6.2 SPECIAL DEFINITIONS
Statement of Regulations
§503,31(a) Aerobic digestion is the biochemical decomposition of organic matter in sewage sludge into
carbon dioxide and water by microorganisms in the presence of air.
§S03.31(b) Anaerobic digestion is the biochemical decomposition of organic matter in sewage sludge into
methane gas and carbon dioxide by microorganisms in the absence of air.
§503.31(c) Density of microorganisms b the number of microorganisms per unit mass of total solids (dry
weight) in the sewage sludge.
§503.31(4) Land with a high potential for public exposure is land that the public uses frequently. This
includes, but is not limited to, a public contact site and a reclamation site located in a populated
area (e.g., a construction site located in a city).
§50331 (e) Land with a tow potential for public exposure is land that the public uses infrequently. This
includes, but is not limited to, agricultural land, forest, and a reclamation site located in an
Unpopulated area (e.g., a strip mine located in a rural area).
§503.31(0 Pathogenic organisms are disease-causing organisms. These include, but are not limited to,
certain bacteria, protozoa, viruses, and viable helminth ova.
§503 Jl(g) pH means the logarithm of the reciprocal of the hydrogen ion concentration.
Draft—March 1993
6-7
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
§S03.31(to) Sp&eifEC oxygen uptake rate (SOUR) is the mass of oxygen consumed per unit time per unit mass
of total solids (dry weight basis) in the sewage sludge.
§503.31(8) Total solids are the materials in sewage sludge that remain as residue when the sewage sludge;
is dried at 103 to 105 degrees Celsius.
§503 Jl(j> Umstobilized solids are organic materials in sewage sludge that have not been treated in either
an aerobic or anaerobh treatment process. v ;
§503Jl(k) Vector attraction is the characteristic of sewage sludge that attracts rodents, flies, raosqustos,
oir oxter organisms capable of transporting infectious agents. .•'.. '';'.' .; • :•"
§503.310) Voiatife solids is the amount of the total solids in sewage sludge bst when the sewage sludge is
combusted at 550 degrees Celsius in the presence of excess air. .. ."•,'• ; -
Colony Forming Unit - The density of microorganisms expressed as a count of colonies on an agar plate or filter
disk. Since a cotony might have originated from a clump of bacteria (instead of an individual), the count is not a
count of separate individuals.
Indicator Organism - is an organism which is itself not pathogenic, but whose presence or absence is indicative of
the respective presence or absence of pathogenic organisms.
Most Probable Number (MPN) - is determined using a test based on the fermentation of a fixed number of
replicates of a number of dilutions of the test sample. The number of repltcable tubes in each dilution exhibiting
certain behavior (e.g., gas production for coliforms) is used to probablistccally estimate the organism density in
the original sample. (See Standard Methods, 17th Ed.)
Plaque-forming Units - Virus densities are determined by inoculation of several standard types of host cells. The
inoculated host cells are placed in a growth medium; after an incubation period zones of no growth, or plaques.
will form as a result of the viral action on the host cells. Counting of these zones provides the numerical value
expressed as Plaque-forming Units.
Mean Cell Residence Time (MCRT) - is defined as:
_ _ mass of cells in the digestion
c ~ mass of cells removed per day
The resulting number, in days, is related to the time an average cell spreads in the digester. Exact determination
of an actual average cell residence time is complicated by the fact that due to digestion, mass of cells into a
digester does not equal mass of cells out.
Wet Bulb Temperature - is measured using a thermometer which has its bulb encased in a water-saturated wick;
the thermometer and wick are allowed to reach evaporative equilibrium with the gas whose temperature is being
measured. In effect, the use of wet bulb temperature provides a better measure of the degree to which the sludge
has been dried.
The megarad - is a measure of the energy dose received per unit mass of the material being irradiated. One
megarad is equivalent to 10 joules of energy per grain (a joule is about 1/100 btu).
Draft—March 1993 6-8
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.3 CLASS A PATHOGEN REDUCTION
In order for sewage sludge to be classified as Class A with respect to pathogens, the sewage sludge must
meet the requirements of one of the following six treatment alternatives. Table 6-2 summarizes the Class
A alternatives allowed for each sewage sludge use or disposal practice. All the Class A pathogen
reduction alternatives require that the sewage sludge meet either a fecal coliform (an indicator organism)
density level or a Salmonella sp. bacteria density level:
• Fecal Coliform — Less than 1,000 Most Probable Number (MPN) per gram total dry solids, or;
• Salmonella sp. — Less than 3 MPN per 4 grams total dry solids.
The fecal coliform density level is used to demonstrate that the sewage sludge is free of pathogenic
bacteria. The use of this indicator organism is based on research. However, some reports indicate that
the composting process may not meet the specified fecal coliform level even though SaJmonellae are
below detection. Also, lime effectively destroys Salmonellae but leaves some surviving fecal coliforms,
that under favorable regrowth conditions will increase to levels higher than the specified fecal coliform
level. Thus, if the preparer believes that the process cannot consistently meet the fecal coliform standard,
the preparer can choose to verify that Salmonellae are absent. The Salmonellae must be demonstrated
to be present in the sewage sludge prior to the pathogen reduction process, since Salmonellae are not
being used as an indicator, but instead as demonstration of the destruction of bacterial pathogens.
The Class A pathogen reduction requirements must be met prior to or at the same time the vector
attraction reduction requirements are met, except for the vector attraction alternatives 6, 7, or 8.
TABLE 6-2 PATHOGEN REDUCTION CLASS A ALTERNATIVES
ALLOWABLE BY USE OR DISPOSAL PRACTICE
Final Use or Disposal Practice
Bulk sewage sludge to agricultural land/forest/public
contact sites/reclamation sites
Bulk sewage sludge to lawns and home gardens
Sewage sludge bagged for sale or give away
Surface disposal
Class A Alternatives
1
X
X
X
X*
2
X
X
X
X*
3
X
X
X
X*
4
X
X
X
X*
5
X
X
X
X*
6
X
X
X
X*
'''Class A (or Class B) pathogen requirements shall be met when sewage sludge is placed in an active sewage
unit unless the vector attraction requirement in §503.33(b)(ll) (i.e., the sewage sludge is covered with soil or
other material at the end of each operating day) is met.
The sections below provide detailed technical discussions of the reduction alternatives for Class A sewage
sludge.
Draft-March 1993
6-9
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.3.1 ALTERNATIVE 1
Statement of Regulations
§503.32
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<5. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Alternative 1 applies to processes that reduce pathogens by thermal means (elevated temperatures) such
as heat treatment, thermophilic digestion, pasteurization, heat drying, addition of lime or kiln dust with
the heat, and composting. This alternative requires both the demonstration of pathogen density levels and
adherence to specified operating parameters. The sewage sludge must be heated to a temperature of 50°C
or higher. There is a somewhat predictable inverse relationship between the temperature and the time
of contact needed to destroy pathogenic organisms to a desired level. The equations presented in the
regulations are mathematical expressions of this relationship between temperature and time. The time
that sewage sludge must be held at a given temperature is determined using the equations provided in the
Part 503 regulations.
Appropriate parameters to be monitored and a monitoring frequency to impose are suggested below. The
permit writer may also want to specify the records or documentation that should be kept. Suggested
documentation to demonstrate compliance with this alternative is also provided below.
MONITORING
Pathogen Parameters
Salmonella or fecal coliform
Frequency
Once per year, quarterly, bimonthly, or monthly (see Table 4-
12 or 5-10)
Operating Parameters
Sludge temperature/time maintained
Percent solids
Frequency
At least 2 readings per day
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Salmonella or Fecal Coliform and Percent Solids
Date and time of sample collection, sampling location, sample type, sample volume, name of sampler, type
of sample container, and methods of preservation, including cooling
Date and time of sample analyst, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless a contract
lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures
Analytical results expressed as dry weight.
Records of Operating Parameters
Date and time temperature checked
Record or documentation of detention time of the sewage sludge in the treatment unit
- Daily volumes of sludge to the treatment unit(s) and daily volume of supernatant and processed sludge
withdrawn
- Size (gallons) of the treatment unit(s).
Draft-March 1993
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.3.2 ALTERATIVE 2
Statement of Regulations
§503.32(a)(4) Class A - Alternative 2
(1) Either the density of fecal coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight basis), or the density of Salmonella
sp. bacteria in the sewage sludge shall be less than three Most Probable Number per four
grams of total solids (dry weight basis) at the time the sewage sludge is used or dbposed;
at the time the sewage sludge is prepared for sale or five away in a bag or other container
for application to the land; or at the time the sewage sludge or material derived from
sewage sludge is prepared to meet the requirements in 503.10(b), S0310(c), 503.10(e), or
503.10(0.
(ii) (A) The pH of the sewage sludge that is used or disposed shall be raised to above 12 and
shall remain above 12 for 72 hours.
(B) The temperature of the sewage sludge shall be above 52 degrees Celsius for 12 hours
or longer during the period that the pH of the sewage sludge is above 12.
(C) At the end of the 72 hour period during which the pH of the sewage sludge is above
12, the sewage sludge shall be air dried to achieve a percent solids in the sewage sludge
: greater than 50 percent.
Alternative 2 applies to processes that reduce pathogens by means of high pH, high temperature, and air
drying to achieve a high percent solids. An example of such a process is the addition of lime or kiln dust
in a manner that raises the temperature of the sewage sludge above 52 degrees Celsius followed by air
drying to greater than 50 percent solids.
Alternative 2 contains pathogen density performance levels for fecal coliform or Salmonella and also
requires adherence to the following process and operational criteria:
• The pH of the sewage sludge must be raised to over 12, and maintained above 12 for at least 72
continuous hours
• For at least one 12-hour period during the 72 hours, the temperature of the sewage sludge must
be raised (and maintained) to over 52 °C.
• Following the 72 hours, the sewage sludge must be air dried to over 50 percent solids.
Suggested parameters to be monitored, frequency of monitoring, and records to be kept are provided
below.
MONITORING
Pathogen parameters
Salmonella or fecal coliform
Operating parameters
pH of sewage sludge/tune maintained
Temperature of sewage sludge/time maintained
Percent solids
Frequency
Once per year, quarterly, bimonthly, or monthly (see
Table 4-12 or 5-10)
Frequency
Beginning, middle, and end of treatment
Beginning, middle, and end of treatment
Once at end of air drying (batch mode)
Draft—March 1993
6-12
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis of Pathogens
Date and time of sample collection, sampling location, sample type, sample volume, name of sampler, type
of sample container, and methods of preservation, including cooling
Date and time of sample analyst, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless a contract
lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures
Analytical results expressed as dry weight.
Records of Operating Parameters
• Time (hours) pH maintained above 12
• Time (hours) temperature maintained greater than 52°C
6.3.3 ALTERNATIVE 3
Statement of Regulations
§503 J2(a)(5) Class A - Alternative 3
0) Either the density of fecal conform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight basis), or the density of
Salmonella sp. bacteria in sewage sludge shall be less than three Most Probable
Number per four grams of total solids (dry weight basis) at the time the sewage sludge
is used or disposed; at the time the sewage sludge is prepared for sale or give away in
a bag or other container for application to the land; or at the time the sewage sludge
or material derived from sewage sludge is prepared to meet the requirements in
503.10(b), 503.10(c), S03.10(e), or 503.10(0.
(ii) (A) The sewage sludge shall be analyzed prior to pathogen treatment to determine whether
die sewage sludge contains enteric viruses.
(B) When the density of enteric viruses in the sewage sludge prior to pathogen treatment
is less than one Plaque-forming Unit per four grams of total solids (dry weight basis),
the sewage sludge is Class A with respect to enteric viruses until the next monitoring
episode for the sewage sludge.
(C) When the density of enteric viruses in the sewage sludge prior to pathogen treatment is
equal to or greater than one Plaque-forming Unit per four grams of total solids (dry
weight basis), the sewage sludge is Class A with respect to enteric viruses when the
density of enteric viruses in the sewage sludge after pathogen treatment is less than one
Plaque-forming Unit per four grams of total solids (dry weight basis) and when the
values or ranges of values for the operating parameters for the pathogen treatment
process that produces the sewage sludge that meets the enteric virus density
requirements are documented.
(D) After the enteric virus reduction in (ii)(C) of this subsection is demonstrated for the
, pathogen treatment process, the sewage sludge continues to be Class A with respect to
enteric viruses when the values for the pathogen treatment process operating
parameters are consistent with the values or ranges of values documented in (ii)(C) of
this subsection.
Draft-March 1993 6-13
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Statement of Regulations
§503.32(a)(5) (iii) (A) The se>rage sludge shall be analyzed prior to pathogen treatment to determine whether
the sewage sludge contains viable helminth ova.
(B) When the density of viable helminth ova in the sewage sludge prior to pathogen
treatment is less than one per four grams of total solids (dry weight basis), the sewage
sludge is Class A with respect to viable helminth ova until the next monitoring episode
for the sewage sludge.
(O When the density of viable helminth ova in the: sewage sludge prior to pathogen
treatment is equal to or greater than one per four grams of total solids (dry weigh
basis), the sewage sludge b Class A with respect to viable helminth ova when the
density of viable helminth ova in the sewage sludge after pathogen treatment is less than
one per four grams of total solids (dry weight basis) and when the values or ranges of
values for the operating parameters for the pathogen treatment process that produces
the sewage sludge that meets the vUblehdminth ova density requirement are
documented. . . .••'. ;;'; ..••'.. • :•. .. ' •' . '..••• . ;.••'••'•: ..'
(D) After the viable helminth ova reduction in (iii)(C) of this subsection is demonstrated
for the pathogen treatment process, the sewage sludge continues to be Class A with
respect to viable helminth ova when: the values for the pathogen treatment process
operating parameters are consistent with the values or ranges of values documented
in (Ui)(C) of this subsection.
Alternative 3 applies to processes that do not qualify for or meet the thermal requirements of Alternatives
1 and 2. Under Alternative 3, the preparer can test the sewage sludge for viruses and viable helminth
ova prior to the pathogen reduction processes. The sewage sludge must meet the following criteria:
• Viruses — Less than 1 Plaque-forming Unit per 4 grams total solids (dry weight basis)
• Helminth Ova — Less than 1 viable ovum per 4 grams total solids (dry weight basis).
If the raw sewage sludge meets these criteria, then no further monitoring of that parameter is required
until the next permit-specified monitoring episode. If the raw sewage sludge fails to meet either criterion,
then the sewage sludge must also be tested after pathogen reduction for that parameter. The sewage
sludge must meet the above criteria after pathogen reduction.
In addition, the ranges of pathogen reduction process operating parameters which result in meeting the
criteria must be documented. Thus, unless a sewage sludge meets both the virus and helminth criteria
prior to pathogen reduction, this alternative imposes operational record keeping requirements on the
permittee.
MONITORING
Parameters
Salmonella or fecal coliform
Enteric viruses
Helminth ova
Operating parameters
Frequency
Once per year, quarterly, bimonthly, or monthly (see Table
4-12 or 5-10)
Prior to and at end of treatment
Prior to and at end of treatment
Specific to process
Draft-March 1993
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Pathogens
Date and time of sample collection, sampling location, sample type, sample volume, name of sampler, type of
sample container, and methods of preservation, including cooling
Date and time of sample analysis, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in calculation of results (unless a contract lab
performed analysis for the permittee)
Sampling and analytical QA/QC procedures.
Records of Operating Parameters
Specific to the process. < •'
6.3.4 ALTERNATIVE 4
Statement of Regulations
§503.32(a)(6) Class A - Alternative 4
(i) Either the density of fecal coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram to total solids (dry weight basis), or the density of Salmonella
sp. bacteria in the sewage sludge shall be less than three Most Probable Number per four
grains of total solids (dry weight basis) at the time the sewage sludge is used or disposed;
at the time the sewage sludge is prepared for sale or give away in a bag or other container
for application to the land; or at the time the sewage sludge or material derived from sewage
sludge is prepared to meet the requirements in 503.10(5), 503.10(c), 503.10(e), or 503.10(0-
(u) The density of enteric viruses in the sewage sludge shall be less than one Plaque-forming
Unit per four grams of total solids (dry weight basis) at the time the sewage sludge is used
or disposed; at the time the sewage sludge is prepared for sale or give away in a bag or
other container for application to the land; or at the time the sewage sludge or material
derived from sewage sludge is prepared to meet the requirements in 503.10(b), 503.10(0),
503.10(e), or 503.10(f), unless otherwise specified by the permitting authority.
(iii) The density of viable helminth ova in the sewage sludge shall be less than one per four
grains of total solids (dry weight basis) at the time the sewage sludge is used or disposed;
at the time the sewage sludge is prepared for sale or give away in a bag or other container
for application to the land; or at the time the sewage sludge or material derived from sewage
sludge is prepared to meet the requirements in 503.10(b), 503.10(c), 503.10(e), or 503.10(0,
unless otherwise specified by the permitting authority.
Alternative 4 is ideally suited for the following situations:
• Sewage sludge has been treated using a newly developed or innovative treatment process(es) that
has operating parameters different from those specified by the other Class A alternatives
• Sewage sludge has been treated using a treatment process(es) that has not derived a correlation
between its operating parameters and pathogen reduction performance
• Processes with operating parameters similar to those specified in the other alternatives but cannot
meet the requirements of the other alternatives yet can demonstrate the required pathogen
reduction level
Draft-March 1993 , 6-15
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
• There is no history of any pathogen reduction process or its operating parameters to demonstrate
adequate pathogen reduction
• Sewage sludge stored for long periods of time.
This alternative requires demonstration that the sewage sludge meets the following pathogen density
levels:
• Fecal Coliform — Less than 1,000 MPN per gram total dry solids, or
• Salmonella sp. — Less than 3 MPN per 4 grams total dry solids
• Viruses — Less than 1 Plaque-forming Unit per 4 grams total solids (dry weight basis)
• Helminth Ova — Less than 1 viable ovum per 4 grams total solids (dry weight basis).
If the fecal coliform or Salmonella density levels are below the required levels, the permitting authority
may waive the monitoring for viruses and helminth ova if site-specific conditions indicate that it is
unlikely that viruses or helminth ova are present.
MONITORING
Parameters
Salmonella or fecal coliform
Enteric viruses
Helminth ova
Frequency
Once per 'year, quarterly, bimonthly, or monthly (see
Table 4-12 or 5-10)
Once per year, quarterly, bimonthly, or monthly
Once per year, quarterly, bimonthly, or monthly
RECORDS OR DOCUMENTATION
• Date and time of sample collection, sampling location, sample type, sample volume, name of sampler, type of
sample container, and methods of preservation, including cooling
• Date and time of sample analysis, name of analyst, and analytical methods used
• Laboratory bench sheets indicating all raw data used in calculation of results (unless a contract lab
performed analysis for the permittee)
• Sampling and analytical QA/QC procedures.
6.3.5 ALTERNATIVE 5
Statement of Regulations
§503.32(a)(7) Class A - Alternative 5
0) Either the density of fecal coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight basis), or the density of Salmonella.
sp. bacteria in the sewage sludge shall be less than three Most Probable number per four
grams of total solids (dry weight basis) at the time the sewage sludge is used or disposal;
at the time the sewage sludge is prepared for sale or give away in a bag or other container
for application to the land; or at the time the sewage sludge or material derived from
sewage sludge is prepared to meet the requirements in 503.10(b), 503.10(c), 503.10(e), or
503.10(0. .. ':.-••"-.'.'. '.V'. .<'"' ..... >;-'-;. ••?/...;- '^'-f'^
Draft—March 1993
6-16
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Statement of Regulations
§503.32(a)(7) 09 Sewage sludge that is used or disposed shall be treated in one of the Processes to Further
Reduce Pathogens described in Appendix B of this part.
APPENDIX B - PATHOGEN TREATMENT PROCESSES
B. Processes to Further Reduce Pathogens (PFRP)
1. Composting
Using either the within-vessel composting method or the static aerated pile composting
method, the temperature of the sewage sludge is maintained at 55 degrees Celsius or
higher for three days.
Using the windrow composting method, the temperature of the sewage sludge is
maintained at 55 degrees Celsius or higher for 15 days or longer. During the period
when the compost is maintained at 55 degrees Celsius or higher, there must be a
minimum of five turnings of the windrow.
2. Heat drying ,
Sewage sludge is dried by direct or indirect contact with hot gases to reduce
the moisture content of the sewage sludge to 10 percent or lower. Either the
temperature of the sewage sludge particles exceeds 80 degrees Celsius or the
wet bulb temperature of the gas in contact with the sewage sludge as the
sewage sludge leaves the dryer exceeds 80 degrees Celsius.
3. Heat treatment
Liquid sewage sludge is heated to a temperature of 180 degrees Celsius or greater for
30 minutes.
4. Tbermophiiic aerobic digestion
Liquid sewage sludge is agitated with air or oxygen to maintain aerobic conditions and
the mean cell residence time of the sewage sludge is 10 days at 55 to 60 degrees
Celsius.
5. Beta ray irradiation
Sewage sludge is irradiated with beta rays from an accelerator at dosages of at least,
1.0 megarad at room temperature (ca. 20 degrees Celsius).
6. Gamma ray irradiation
Sewage sludge is irradiated with gamma rays from certain isotopes, such as Cobalt 60
and Cesium 137, at room temperature (ca. 20 degrees Celsius).,
7. Pasteurization
The temperature of the sewage sludge is maintained at 70 degrees Celsius or higher for •
* 30 minutes or longer.
Draft—March 1993 6-17
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
This alternative requires the use of one of seven sewage sludge stabilization processes. These processes
are those originally defined in 40 CFR Part 257 as Processes to Further Reduce Pathogens (PFRPs).
Suggested monitoring and record-keeping requirements are provided below.
MONITORING
Pathogen Parameters
Salmonella or fecal' coliform
Operating Parameters
• Heat drying
- Moisture content of dried sludge
- Temperature of sludge particles or wet bulb
temperature of exit gas
• Thermophilk aerobic digestion
- Temperature of sewage sludge in digester
• Heat treatment
- Temperature of sewage sludge during treatment
• Composting
- Temperature of sewage sludge during
composting process
• Gamma ray irradiation
- Dosage
• Pasteurization
- Temperature of sewage sludge during treatment
• Beta ray irradiation
- Dosage
Frequency
Once per year, quarterly, bimonthly, or monthly (see
Table 4-12 or 5-10)
Frequency
Once at end of treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
Continuous or periodic during treatment
RECORDS OR DOCUMENTATION
Records of Samoline and Analysis for Salmonella or Fecal Coliform and Percent Solids
• Date and time of sample collection, sampling location, sample type, sample volume, name of sampler, type of
sample container, and methods of preservation, including cooling
• Date and time of sample analyst, name of analyst, and analytical methods used
• Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless a contract
lab performed the analyses for the preparer)
• Sampling and analytical QA/QC procedures
Draft-March 1993
6-18
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
RECORDS OR DOCUMENTATION (Continued)
Heat drying
Records of Operating Parameters
• Gamma ray irradiation
- Moisture content of dried sludge > 10%
- Logs documenting temperature of sludge
particles, or wet bulb temperature of exit gas
exceeds 80°C (either continuous chart or a
minimum of 2 readings per day 7 or more
hours apart)
Thermophilic aerobic digestion
- Logs documenting temperature maintained at
55-60°C for 10 days (at least 2 readings per day
7 or more hours apart)
Heat treatment
- Logs documenting sludge heated to
temperatures greater than 180°C for 30
minutes (either continuous chart or 3 readings
at 15 minute intervals)
Composting
- Description of composting method
- Logs documenting amount of time temperature
maintained above 55°C (at least 2 readings per
day 7 or more hours apart)
- Logs documenting compost pile turned at least
5 times per day, if windrow compost method
- Gamma ray isotope used
- Ambient room temperature log (either
continuous chart or a minimum of 2 readings
per day 7 or more hours apart)
Pasteurization
- Time temperature maintained above 70°C
(either continuous chart or a minimum of 2
readings per day 7 or more hours apart)
Beta ray irradiation
- Beta ray dosage
- Ambient room temperature log (either
continuous chart or a minimum of 2 readings
per day 7 or more hours apart)
6.3.6 ALTERNATIVE 6
State of Regulations
§S03.32(a)(8) Class A > Alternative 6
(i) Either the density of fecal coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight basis), or the density of Salmonella.
Sp. bacteria in the sewage sludge shall be less than three Most Probable Number per four
grams of total solids (dry weight basis) at the time the sewage sludge is used or disposed;
at the time the sewage sludge is prepared for sale or give away in a bag or other container
for application to the land; or at the time the sewage sludge or material derived from
sewage sludge is prepared to meet the requirements in 503.10(b), S03.10(c), 503.10(e), or
503.10(0.
(ii) Sewage sludge that is used or disposed shall be treated in a process that is equivalent to a
Process to Further Reduce Pathogens, as determined by the permitting authority.
This alternative requires the use of a process deemed equivalent to one of the Processes to Further Reduce
Pathogens (PFRPs) as determined by the permitting authority.
Draft—March 1993
6-19
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
MONITORING
Parameters
Salmonella or fecal coliform
Operating parameters
Frequency
Once per year, quarterly, bimonthly, or monthly (see
Table 4-12 or 5-10)
Specific to process
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Salmonella or Fecal Coliform
Date and time of sample collection, sampling location, sample type, sample volume, name of sampler, type of
sample container, and methods of preservation, including cooling
Date and time of sample analyst, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless a contract
lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures
6.4 CLASS B PATHOGEN REDUCTION
In order for sewage sludge to be classified as Class B with respect to pathogen content, the sewage sludge
must meet the requirements of one of the following three treatment alternatives. Table 6-3 summaries
the Class B alternatives allowed for each sewage sludge use or disposal practice.
TABLE 6-3 PATHOGEN REDUCTION CLASS B ALTERNATIVES
ALLOWABLE BY USE OR DISPOSAL PRACTICE
Final Use or Disposal Practice
Bulk sewage sludge to agricultural land/forest/
public contact sites/reclamation sites
Bulk sewage sludge to lawns and home gardens
Sewage sludge bagged for sale or give away
Surface disposal
Class B Alternatives
1
X
**
**
x***
2
X
**
**
X***
3
X
**
**
X***
Site Restrictions
X*
The site restrictions in §503.32(b)(5) shall be met when sewage sludge meeting Class B pathogen
requirements is applied to land.
**Not allowable for these practices; bulk sewage sludge to lawns or home gardens and sewage sludge bagged
for sale or give away must meet Class A pathogen requirements.
""•""Class A or Class B pathogen requirements shall be met when sewage sludge is placed in an active sewage
sludge unit unless the vector attraction requirement in §503.33(b)(ll) (i.e., the sewage sludge is covered with
soil or other material at the end of each operating day) is met.
Provided below is a summary of the pathogen reduction alternatives for Class B sewage sludge.
Draft-March 1993
6-20
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.4.1 ALTERNATIVE 1
Statement of Regulations
§503 J2(b)(2) Class B - Alternative 1
(i) Seven samples of the sewage sludge shall be collected at the time the sewage sludge is used
or disposed.
(ii) The geometric mean of the density of fecal coliform in the samples collected in paragraph;
(b)(2)(i) of this section shall be less than either 2,000,000 Most Probable Number per gram
of total solids (dry weight basis) or 2,000,000 Colony Forming Units per gram of total solids
(dry weight basis).
This alternative requires compliance with one ^•••••••••••••••^^^^^^^
performance criterion. The geometric mean of the
fecal coliform densities of seven (7) samples taken Geometric Mean -then root of the product
during each monitoring event must be less than: °/ " ^mbers- In thls case:
• 2,000,000 MPN per gram total solids (dry
weight basis), or
• 2,000,000 Colony Forming Units per gram
Geo. Mean
7
x S* x SJ x S4 x S5 x S6 x S7
Where S" = fecal density for sample n.
MONITORING
Pathogen Parameters
Fecal coliform
Frequency
Once per year, twice per year, quarterly, or monthly
(see Table 4-12 or 5-10)
RECORDS OR DOCUMENTATION
Records of Sampling and Analysis for Pathogen
Date and time of sample collection, sampling location, sample type, sample volume, name of sampler, type of
sample container, and methods of preservation, including cooling
Date and time of sample analyst, name of analyst, and analytical methods used
Laboratory bench sheets indicating all raw data used in analyses and calculation of results (unless a contract
lab performed the analyses for the preparer)
Sampling and analytical QA/QC procedures
Draft—March 1993
6-21
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.4.2 ALTERNATIVE 2
Statement of Regulations
§503J2(b)(3) Class B - Alternative 2
Sewage sludge that is used or disposed shall be treated in one of the Processes to Significantly
Reduce Pathogens described in Appendix B of this part.
APPENDIX B - PATHOGEN TREATMENT PROCESSES
A. Processes to Significantly Reduce Pathogens (PSRP)
I. Aerobic digestion
Sewage sludge is agitated with air or oxygen to maintain aerobic conditions for a
specific mean cell residence time at a specific temperature. Values for the mean cell
residence time and temperature shall be between 40 days at 20 degrees Celsius and 60
days at 15 degrees Celsius.
2. Air drying
Sewage sludge is dried on sand beds or on paved or unpaved basins. The sewage
sludge drys for a minimum of three months. During two of the three months, the
: ambient average daily temperature is above zero degrees Celsius.
3.. Anaerobic digestion
Sewage sludge is treated in the absence of air for a specific mean cell residence time
at a specific temperature. Values for the mean cell residence time and temperature
shall be between 15 days at 35 degrees Celsius and 55 degrees Celsius and 60 days at
20 degrees Celsius.
4. Composting
: Using either the within-vessel, static aerated pile, or windrow composting methods, the
temperature of the sewage sludge is raised to 40 degrees Celsius or higher and remains
at 40 degrees Celsius or higher for five days. For four hours during the five days, the
temperature in the compost pile exceeds 55 degrees Celsius.
5. Lime stabilization
Sufficient lime is added to the sewage sludge to raise the pH of the sewage sludge to
12 after two hours of contact.
The preparer can combine processes with each other, as long as they produce the desired result (fecal
coliform level). For example, short-term digestion followed by air drying is possible.
Draft-March 1993 6-22
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
MONITORING
Operating Parameters
Aerobic digestion
- Temperature of sewage sludge during
treatment
Air drying
- Daily average ambient temperature
Anaerobk digestion
- Temperature of sewage sludge during
treatment
Composting
- Temperature of sewage sludge during
treatment
Lime stabilization
- pH of sewage sludge
Frequency
Continuous or periodic during treatment
At least once per day during drying period
Continuous or periodic during treatment
Continuous or periodic during treatment
At least twice, once upon addition of lime and once 2
hours after addition
RECORDS OR DOCUMENTATION
Records of Operating Parameters
• Aerobic digestion
- Mean residence time of sludge in digester
- Logs showing temperature was maintained for
sufficient period of time (ranging from 60 days at
1S°C to 40 days at 20°C) (continuous charts or 2
readings per day at least 7 hours apart)
• Air drying
- Description of drying bed design
- Depth of sludge on drying bed
- Drying time in days
- Daily average ambient temperature
• Anaerobic digestion
- Mean residence time of sludge in digester
- Logs showing temperature was maintained for
sufficient period of time (ranging from 60 days at
20°C to 15 days at 35°C) (continuous charts or 2
readings per day at least 7 hours apart)
Composting
- Description of composting method
- Daily temperature logs documenting sludge
maintained at 40°C for 5 days (at least 2
readings per day 7 or more hours apart)
- Hourly readings showing temperature exceeded
55°C for 4 consecutive hours
Lime stabilization
- pH of sludge immediately and then 2 hours after
lime addition
Draft—March 1993
6-23
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.4.3 ALTERNATIVE 3
Statement pf Regulations
§503J2(b)(4>
Class B
Sewage
Process
- Alternative 3
sludge that is used or disposed shall be treated in a process that is equivalent to a
to Significantly Reduce Pathogens, as determined by the permitting authority.
MONITORING/RECORDS OR DOCUMENTATION
• Specific to
the process.
Records of Oueratine Parameters
6.5 CLASS B PATHOGEN REDUCTION SITE RESTRICTIONS
Statement of Regulations
§503J2(b)(5) Site Restrictions
(i) Food crops with harvested parts that touch the sewage sludge/soil mixture and are totally
above the land surface shall not be harvested for 14 months after application of sewage
s lodge.
(u) Food crops with harvested parts below the surface of the land shall not be harvested for 20
months after application of sewage sludge when the sewage sludge remains on the land
surface for four months or longer prior to incorporation into the soil.
(iii) Food crops with harvested parts below the surface of the land shall not be harvested for 38
months after application of sewage sludge when the sewage sludge remains on the land
surface for less than four months prior to incorporation into the soil.
0v) Food crops, feed crops, and fiber crops shall not be harvested for 30 days after application
of sewage sludge.
(v) Animals shall not be allowed to graze on the land for 30 days after application of sewage
sludge.
(vi) Turf grown on land where sewage sludge is applied shall not be harvested for one year after
application of the sewage sludge when the harvested turf is placed on either land with a
high potential for public exposure or a lawn, unless otherwise specified by the permitting
authority.
(vii) Public access to tend with a high potential for public exposure shall be restricted for one
year after application of sewage sludge.
(viii) Public access to land with a low potential for public exposure shall be restricted for 30 days
after application of sewage sludge.
Draft-March 1993 6-24
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
Due to the higher likelihood of having pathogenic organism densities which might pose a threat to human
health under certain circumstances, Mi Class B sewage sludges applied to land are required to meet the
following site restrictions:1
• Food crops with harvested parts which touch the ground may not be harvested from a site on which
Class B sewage sludge is land applied sooner than 14 months after the sewage sludge application
takes place.
• Food crops with harvested parts below the surface may not be harvested prior to:
- 20 months after sewage sludge application if the sewage sludge was allowed to remain on the
surface for at least 4 months prior to incorporation to the soil
- 38 months after sewage sludge application if the sewage sludge was allowed to remain on the
surface for less than 4 months prior to incorporation into the soil.
Table 6-4 lists examples of food crops with harvested parts that touch the ground or are below the
ground.
TABLE 6-4 EXAMPLES OF CROPS AFFECTED BY CLASS B SITE RESTRICTIONS
Crops with Harvested Parts Which May
Touch the Ground _
Crops with Harvested Parts Below the
Ground
Melons
Eggplant
Squash
Tomatoes
Cucumbers
Celery
Strawberries
Cabbage
Lettuce
Potatoes
Yams
Sweet Potatoes
Mushrooms
Peanuts
Onions
Leeks
Radishes
Turnips
Rutabaga
Beets
• All other food crops as well as feed and fiber crops shall not be harvested from the land for a
period of 30 days after application of the sewage sludge. Feed crops are any crops grown for
animal feed, such as hay, corn, and alfalfa.
• Animals shall not be allowed to graze on the land for a period of 30 days after application of the
sewage sludge. (This is interpreted as including wild animals, such as deer.) Measures which
may be employed to limit animal grazing include controlling the use of adjacent land parcels or
'Class B sewage sludges placed in an active sewage sludge unit (i.e., surface disposal) are not subject
to these site restrictions. The surface disposal site is subject to management practices restricting public
access, crop production and animal grazing.
Draft—March 1993
6-25
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
fencing. In areas with significant wild grazing animal populations, control of grazing by these
animals is likely to be difficult.
• Turf grown on land where sewage sludge l"^™^^^^^^™>111^^^^^^^^^^™^^^
is applied shall not be harvested for a Sites with high potential for public exposure:
period of one year after application of the
sewage sludge if the harvested turf is • Parks
placed on either land with a high potential . Commercial properties where the public has
for public exposure or a lawn. In access to turfed areas
practice, many turf producers may have • Cemeteries
difficulty controlling where turf is • Schools
applied. In addition, turf producers
having both turf which meets the above Sites with low potential for exposure:
restrictions and turf which does not, may
have difficulty reliably segregating the « Commercial properties such as office parks
two qualities of turfs. , Public buildings where turfed area access is
restricted
• Public access to land with a high potential
for public exposure shall be restricted for ^^^.,,^^^1^^^^^,^^,,^^^^^^^1BB—i
-------
6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
TABLE 6-5 VECTOR ATTRACTION REDUCTION ALTERNATIVES
ALLOWABLE BY USE OR DISPOSAL PRACTICE
Alternatives "• ^;;:f ^ ;/; • • .• ';.,,;' • :: ' ;•;-.:.':. '•-' ^^•'^±IM:/^
Final Use or Disposal Practice
Bulk sewage sludge to agricultural
land/forest/public contact sites/
reclamation sites
Bulk sewage sludge to lawns or
home gardens
Sewage sludge bagged for sale or
give away
Surface disposal
1
X
X
X
X
2
X
X
X
X
3
X
X
X
X
4
X
X
X
X
5
X
X
X
X
6
X
X
X
X
7
X
X
X
X
8
X
X
X
X
9
X
X
10
X
X
11
X
Each of these vector attraction reduction alternatives is discussed below.
6.6.1 ALTERNATIVE 1
Statement of Regulations
§503.33(b)(l) The mass of volatile solids in the sewage sludge shall be reduced by a minimum of 38 percent.
Alternative 1 applies to sewage sludges processed by anaerobic or aerobic biological treatment or
chemical oxidation. To measure the volatile solids reduction the sewage sludge should be sampled at the
beginning of the sewage sludge digester and at the end of the vector attraction reduction process. For
example, if, after digestion, the sewage sludge is placed on drying beds for further vector attraction
reduction, the sewage sludge should be sampled at the end of the drying time.
The mass of volatile solids in the sewage sludge
must be reduced by at least 38 percent. Volatile
solids reduction is measured as follows:
VS
V - V
Red
X 100%
Volatile Fraction - (the fraction of volatile
solids) is defined as the difference in mass of
solids filtered from a sample before and after
heating at 550°C for 1 hour. The material
"burned" off is representative of the organic
content of the sludge.
where:
= Percent reduction of volatile solids
= Volatile fraction in raw sewage sludge
= Volatile fraction in stabilized sewage sludge
Draft-March 1993
6-27
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
MONITORING REQUIREMENTS
Parameter
Volatile solids
Frequency
Once per year, quarterly, bimonthly, or monthly
Table 4-12 or 5-10)
(see
RECORD KEEPING REQUIREMENTS
• Volatile solids concentration of raw and final sludge streams (mg/L dry weight) evaluated weekly
6.6.2 ALTERNATIVE 2
Statement of Regulations
§503 J3(b)(2) When the 38 percent volatile solids reduction requirement in 503 J3(b)(l) cannot be met for an
anaerobkally digested sewage sludge, vector attraction reduction can be demonstrated by
digesting a portion of the previously digested sewage sludge anaerobkally in the laboratory in
a bench-scale unit for 40 additional days at a temperature between 30 and 37 degrees Celsius.
When at the end of the 40 days, the volatile solids in the sewage sludge at the beginning of that
period fa reduced by less than 17 percent, vector attraction reduction is achieved.
Alternative 2 applies to sewage sludges processed by anaerobic biological treatment processes that are
working properly but are unable to demonstrate 38% volatile solids reductions.
This alternative can only be used if the sewage sludge fails to meet the 38 percent volatile solids reduction
required by Alternative 1. If anaerobic digestion of a sewage sludge cannot achieve 38 percent mass
reduction of volatile solids, sewage sludge can be demonstrated to be adequately stabilized (from a vector
attraction reduction standpoint) by the following laboratory test:
1. Anaerobic digestion between 30°C and 37°C for 40 days (following full scale digestion)
2. After 40 days, reporting that the mass of volatile solids has been further reduced by less than 17
percent.
This bench scale digestion would be carried out as follows:.
• pH will be maintained at 7.0 to 7.4 and checked daily
• Under completely anaerobic conditions; gas produced should be vented from the batch digestion
through a one-way valve.
MONITORING REQUIREMENTS
Parameter
Volatile solids
Frequency
Once per year, quarterly, bimonthly, or monthly
Table 4-12 or 5-10)
(see
RECORD KEEPING REQUIREMENTS
• One-time description of bench-scale digestion
• Time (days) that sample was further digested in bench-scale digester
• Temperature (degrees Celsius) maintained while sludge was in digester (at least
2 readings per day)
Draft—March 1993
6-28
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.6.3 ALTERNATIVE 3
Statement of Regulations
§503.33(b)(3) When the 38 percent volatile solids reduction requirement in 503.33(b)(l) cannot be met for an
aerobically digested sewage sludge, vector attraction reduction can be demonstrated by digesting
a portion of the previously digested sewage sludge that has a percent solids of two percent or less
aerobkally in the laboratory in a bench-scale unit for 30 additional days at 20 degrees Celsius.
When at the end of the 30 days, the volatile solids in the sewage sludge at the beginning of that
period is reduced by less than 15 percent, vector attracting reduction is achieved.
Alternative 3 applies to sewage sludges processed by aerobic biological treatment that is working
properly but are unable to demonstrate 38 percent volatile solids reductions. This alternative can only
be used if the sewage sludge fails to meet the 38 percent volatile solids reduction required by Alternative
1. If aerobic digestion of a sewage sludge cannot achieve 38 percent mass reduction of volatile solids,
then the following demonstration may be carried out in order to show adequate stabilization.
1. A sample of digested sewage sludge having less than two percent solids is digested in the
laboratory for 30 days at a temperature maintained at 20°C
2. After 30 days, the sample should show that the mass of volatile solids has been further reduced
by less than 15 percent.
In carrying out this bench scale demonstration, the following guidelines should be followed:
• If the digested sewage sludge has a total solids of more than 2 percent, either digester decant or
pig-disinfection plant effluent may be used to dilute the sample to less than 2 percent solids
• In order to maintain the required temperature range, a constant temperature bath or incubator
should be used.
• Dissolved oxygen in the bench scale digestion should be maintained at between 1.0 and 2.0 mg/1
at all times during the 30 days.
MONITORING REQUIREMENTS
Parameter
Volatile solids
Frequency
Once per year, quarterly, bimonthly, or monthly
Table 4-12 or 5-10)
(see
RECORD KEEPING REQUIREMENTS
• One-time description of bench-scale digestion
• Time (days) that sample was further digested in bench-scale digester
• Temperature (degrees Celsius) maintained while sludge was in digester (at least 2 readings per day)
Draft—March 1993
6-29
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.6.4 ALTERNATIVE 4
Statement of Regulations
5503 J3(b)(4) The specific oxygen uptake rate (SOUR) for sewage sludge treated in an aerobic process shall be
equal to or less than 1.5 milligrams of oxygen per hour, per gram of total solids (dry weight basis)
at a temperature of 20 degrees Celsius.
Alternative 4 provides another method of demonstrating adequate vector attraction reduction by aerobic
processes. Sewage sludges generated from aerobic biological wastewater treatment processes may not
be able to demonstrate a 38 percent volatile solids reduction because the sewage sludge entering the
sewage sludge aerobic digester is already partially
aerobically digested. This is frequently the case
for sewage sludges held or circulated in
wastewater treatment operations for periods as
long as 30 days.
Aerobically digested sewage sludge will be
considered adequately stabilized from a vector
attraction reduction standpoint if its Specific
Oxygen Uptake Rate is no more than 1.5
mg/hr/gram at 20°C (total solids-dry weight).
Specific Oxygen Uptake Rate (SOUR) - SOUR
is a measure of the rate of oxygen utilization of
a wastewater mixed liquor or sludge. In
general, SOUR is the Oxygen Uptake Rate
(OUR), in milligrams of dissolved oxygen per
hour per gram of volatile solids. OUR is
measured using a device known as a
respirometer.
MONITORING REQUIREMENTS '
Parameter
SOUR
Frequency
Once per year, quarterly, bimonthly, or monthly (see
Table 4-12 or 5-10)
RECORD KEEPING REQUIREMENTS
• Dissolved oxygen readings for sludge sample over 15-minute period (mg/L) '
• Calibration records for the DO meter
• Temperature (degrees Celsius) at beginning and end of DO readings
• Total solids for sludge sample (g/L)
• SOUR calculations (mg/h/g)
6.6.5 ALTERNATIVE 5
Statement of Regulations
§503.33(b)(5) Sewage sludge shall be treated in an aerobic process for 14 days or longer. During that time,
the temperature of the sewage sludge shall be higher than 40 degrees Celsius and the average
temperature of the sewage sludge shall be higher than 45 degrees Celsius.
For some aerobic processes, such as composting, it is not possible to assess the percent of volatile solids
reduction. This alternative provides another way to demonstrate vector attraction reduction. Rather than
measure vector attraction reduction, specific operating parameters of the vector attraction reduction
Draft-March 1993
6-30
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
process must be met. Under this alternative, the operating parameters that the aerobic process must meet
are:
• Treatment of the sewage sludge for a minimum of 14 days
• The temperature of the sewage sludge remains above 40°C at all times during the 14 days
• The temperature averages over 45°C.
The determination of temperature should be based on readings throughout the digestion period.
Alternative 5 usually applies to the composting process but could also apply to other aerobic processes
such as aerobic digestion. However, for aerobic digestion, Alternatives 1, 3, or 4 may be more
appropriate and easier to meet.
MONITORING AND RECORD KEEPING REQUIREMENTS
* Sewage sludge treatment time
• Sewage sludge temperature
6.6.6 ALTERNATIVE 6
Statement of Regulations
5503 J3(b)(6) The pH of sewage sludge shall be raised to 12 or higher by alkali addition
addition of more alkali, shall remain at 12 or higher for two hours and then
for an additional 22 hours.
and, without the
at 11.5 or higher
Alternative 6 is generally selected by processes using lime addition but any alkali may be appropriate if
it achieves the required pH. Vector attraction reduction can be achieved by pH adjustment if:
1. pH is raised to 12 or higher
2. Following pH adjustment, the pH remains at 12 or higher for at least 2 hours with no further
chemical addition.
3. The pH remains at 11.5 or higher for at least 22 hours from the time pH dropped below 12.
MONITORING AND RECORD KEEPING REQUIREMENTS
• pH of sludge/alkali mixture
• Hours pH was maintained
• Amount of alkali added to sludge (Ibs or gal)
• Amount of sludge treated
Draft-March 1993 6-31
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.6.7 ALTERNATIVE 7
Statement of Regulations
J503 J3(bX7) The percent solids of sewage sludge that does not contain unstabilized solids generated in a
: primary wastewater treatment process shall be equal to or greater than 75 percent based on the
moisture content and total solids prior to mixing with other materials.
This alternative applies to sewage sludges containing no. unstabilized primary sewage sludge. This could
be raw or stabilized secondary or tertiary sewage sludges, or stabilized primary sewage sludges. The
sewage sludge cannot contain unstabilized primary sewage sludge because the organic material in this
sewage sludge can attract vectors even though the solids content is greater than 75 percent.
Under this alternative, sewage sludges must be dried to a moisture .content of no more than 25 percent
by weight. This requirement must be met by the sewage sludge prior to mixing with other materials.
This reduction must be achieved by removing water, not by adding inert materials. Materials, such as
lime, can be added that remove water by reaction, by adsorption, or as water of crystallization.
MONITORING AND RECORD KEEPING REQUIREMENTS
• Percent solids
• Absence of unstabilized solids generated during primary treatment
6.6.8 ALTERNATIVE 8
Statement of Regulations
§503J3(b)(8) The percent solids of sewage sludge that contains unstabilized solids generated in a primary
wastewater treatment process shall be equal to or greater than 90 percent based on the moisture
content and total solids prior to mixing with other materials.
This alternative applies to sewage sludges containing unstabilized primary sewage sludges. Even though
the sewage sludge contains primary unstabilized sewage sludge, a solids content of 90 percent or greater
is sufficient to adequately reduce the vector attraction characteristics of the sewage sludge. As with
Alternative 7, this reduction must be achieved by removing water, not by adding inert materials.
Materials, such as lime, can be added that remove water by reaction, by adsorption, or as water of
crystallization. , •
MONITORING AND RECORD KEEPING REQUIREMENTS
• Percent solids
• Presence of unstabilized solids generated during primary treatment
Draft—March 1993 6-32
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
6.6.9 ALTERNATIVE 9
Statement of Regulations
§503.33(b)(0) (1) Sewage sludge shall be injected below the surface of the land.
(U) No significant amount of the sewage sludge shall be present on the land surface within one
hour after the sewage sludge is injected.
(JH) When the sewage sludge that is injected below the surface of the land is Class A with
respect to pathogens, the sewage sludge shall be injected betow the land surface within eight
houri after being discharged from the pathogen treatment process.
This alternative applies only to the land application of bulk sewage sludge to agricultural land, forest,
public contact sites, or reclamation sites, or to the final disposal of sewage sludge to a surface disposal
site. Vector attraction reduction is considered to be effected by subsurface injection:
• If no significant amount of sewage sludge remains on the surface one hour after the injection
takes place.
• If a sewage sludge of Class A quality (with respect to pathogens) is injected within 8 hours of
its discharge from the pathogen reduction process.
MONITORING AND RECORD KEEPING REQUIREMENTS
Time between end of pathogen treatment process and injection
6.6.10 ALTERNATIVE 10
Statement of Regulations
§503.33(bX10) fi) Sewage sludge applied to the land surface or placed on a surface disposal site shall be
incorporated into the soil within six hours after application to or placement on the hind.
(ii) When sewage sludge that is incorporated into the soil is Class A with respect to pathogens,
tie sewage sludge shall be applied to or placed on the land within eight hours after being
discharged from the pathogen treatment process.
This alternative applies only to the land application of bulk sewage sludge to agricultural land, forest,
public contact sites, or reclamation sites, or the final disposal of sewage sludge to a surface disposal site.
Vector attraction reduction may be achieved by incorporating the sewage sludge into the soil within 6
hours of its application to land. Incorporation is effected by "turning over" or plowing the land to which
the sewage sludge is applied. This results in the mixing of the sewage sludge with the upper 6-12 inches
of the soil.
Draft-March 1993 6-33
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6. PATHOGENS AND VECTOR ATTRACTION REDUCTION - PART 503 SUBPART D
MONITORING AND RECORD KEEPING REQUIREMENTS
• Time between placement and incorporation into soil
• Time between end of pathogen treatment process and incorporation
6.6.11 ALTERNATIVE 11
Statement, of Regulations
5503 J»0>K11) Sewage sludge placed on an active sewage sludge unit shall be covered with soil or other material
at the end of each operating day.
Alternative 11 applies to sewage sludge placed on active sewage sludge units at a surface disposal site.
The permit writer should impose this alternative when the sewage sludge has not been reduced in vector
attraction by one of the other 10 vector attraction reduction alternatives.
This vector attraction reduction alternative for surface disposal requires that the sewage sludge placed in
the unit be covered with soil or other non-sewage sludge material at the end of each operating day. This
method ensures that the sewage sludge is not exposed during the periods, typically at night, when vectors
are most likely to gain access to sludge placed on the unit.
Draft-March 1993 6-34
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7. INCINERATION - PART 503 SUBPART E
QUICK REFERENCE INDEX
Section Page
OVERVIEW 7.1
IDENTIFYING INCINERATION
DETERMINING PROVISIONS TO APPLY
SUBPART E REQUIREMENTS TO APPLY TO THE GENERATOR AND INCINERATOR
DEFINITIONS 7.2
GENERAL REQUIREMENTS 7.3
POLLUTANT LIMITS 7.4
SITE-SPECIFIC FACTORS
LEAD
ARSENIC, CADMIUM, CHROMIUM, AND NICKEL
BERYLLIUM
MERCURY
OPERATIONAL STANDARDS 7.5
TOTAL HYDROCARBON CONCENTRATION (THC)
MANAGEMENT PRACTICES 7.6
TOTAL HYDROCARBONS MONITOR
OXYGEN MONITOR
MOISTURE CONTENT
COMBUSTION TEMPERATURE
AIR POLLUTION CONTROL DEVICE OPERATING PARAMETERS
ENDANGERED SPECIES ACT
MONITORING REQUIREMENTS 7.7
RECORD KEEPING REQUIREMENTS 7.8
REPORTING REQUIREMENTS 7.9
7-1
7-1
7-3
7-4
7-4
7-12
7-13
7-13
7-19
7-21
7-25
7-27
7-28
7-29
7-31
7-31
7-32
7-33
7-33
7-34
7-35
7-37
7-44
7-53
7.1 OVERVIEW
This chapter provides guidance to permit writers on the implementation of the Part 503, Subpart E
regulations for incineration of sewage sludge. Each section states and discusses the corresponding
Subpart E regulations.
7.1.1 IDENTIFYING INCINERATION
The permit writer should first determine whether the practice is regulated by Part 503, Subpart E. To
assist the permit writer, a simple decision tree is provided as Figure 7-1.
Draft-March 1993 7-1
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7. INCINERATION - PART 503 SUBPART E
Does sludge fed to the incinerator meet the definition of "sewage
sludge' as stated in §503.6 and §503.9?
• Is the sludge a sewage sludge?
• Is the concentration of PCBs in the sewage sludge less than 50
milligrams per kilogram of total solids on a dry weight basis?
• Is the sewage sludge non-hazardous?
NO
The incinerator is not
covered under Part
503 regulations.
YES
Is sewage sludge co-fired in the incinerator with other wastes?
Other wastes do not include auxiliary fuel used in a sewage sludge
incinerator. [40 CFR 503.6(c)]
YES
The incinerator is not
covered under Part
503 regulations.
NO
Is municipal solid waste used as auxiliary fuel to fire sewage
sludge in the incinerator? If yes, is municipal solid waste more
than 30 percent of the dry weight of sewage sludge and auxiliary
fuel together? {40 CFR 503.41(b)]
YES
The incinerator is not
covered under Part
503 regulations.
NO
The sewage sludge incinerator is subject to Part 503 requirements.
FIGURE 7-1 FLOW CHART TO DETERMINE IF AN
INCINERATOR IS SUBJECT TO PART 503
The permit writer must decide if the sludge to be fired in the incinerator meets the definition of sewage
sludge as provided in Part 503, Subpart A. The regulatory definition of sewage sludge (and a
clarification) is included in Chapter 2 of this manual. Both the source and the quality of the sludge must
be submitted as part of the permit application. If not, the permit writer should request this information
from the applicant.
Next, the permit writer should examine pollutant concentrations in the sewage sludge to verify that the
concentration of PCBs in the sewage sludge is less than 50 milligrams per kilogram of total solids (on
a dry weight basis), and that the sewage sludge does not meet any of the characteristics of a hazardous
waste as identified in 40 CFR Part 261, Subpart C (i.e., ignitable, corrosive, reactive, and toxic).
The permit writer must then determine whether the incinerator is regulated under Part 503. Co-
incineration of sewage sludge with other wastes in an incinerator is not covered under this rule (other
wastes do not include auxiliary fuels). The permit writer should examine the information provided by
the owner/operator concerning the types and quantities of auxiliary fuel or other wastes used in the
incinerator. Municipal solid wastes can be used as auxiliary fuel to fire sewage sludge in a sewage sludge
Draft-March 1993
7-2
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7. .INCINERATION - PART 503 SUBPART E
incinerator as long as the quantity of the solid waste is no more than 30 percent of the dry weight of the
total material fed to the incinerator. The permit writer should use his/her judgement as to an acceptable
period of time to determine an average percent of municipal solid wastes. For example, if 10 metric tons
(dry weight) of sewage sludge and auxiliary fuel are fed to the incinerator per day, the quantity of
municipal solid waste that can be used as auxiliary fuel must not exceed 3 metric tons (dry weight) per
day. The use of additional auxiliary fuels such as fuel oil may allow a total of more than 3 tons/day of
total auxiliary fuel. The permit writer should ensure that the incinerator does not co-incinerate the
sewage sludge with other waste nor uses municipal solid wastes at rates equal to or greater than 30
percent of the total material fed to the incinerator. The co-incineration of sewage sludge with more than
30 percent municipal solid waste may be subject to the requirements of 40 CFR Part 60, Subparts C, E,
and/or O.
7.1.2 DETERMINING PROVISIONS TO APPLY
Part 503, Subpart E contains standards and requirements that apply to the sewage sludge which is fed to
sewage sludge incinerators, operational standards that apply to the exit gas from incinerator stacks, and
management practices that apply to sewage sludge incinerators. The Subpart E requirements to be
developed by the permitting authority are listed in Table 7-1. For example, the permitting authority will
need to specify the air dispersion model to be used by the owner/operator and the performance test
protocols in order to establish the specific pollutant limits. The protocols for installing, calibrating,
operating, and maintaining the continuous monitoring instruments and the frequency of monitoring for
beryllium and mercury also need to be specified by the permitting authority.
TABLE 7-1 SUBPART E REQUIREMENTS TO BE SPECIFIED BY THE PERMITTING
AUTHORITY
Pollutant Limits
Air dispersion model to be used
Performance test to be conducted
RSC value for chromium
Management Practices
Continuous monitoring instruments for THC, oxygen, moisture content, and combustion
temperatures in stack exit gas. Values for the operating parameters for the air pollution control
device
Monitoring Requirements
Frequency of monitoring for beryllium and mercury
Frequency of monitoring for the incinerator air pollution control device operating parameters
Emissions of arsenic, cadmium, chromium, lead, and nickel into the atmosphere during the operation of
a sewage sludge incinerator are regulated by limiting the concentration of these pollutants in the sewage
sludge fired in the sewage sludge incinerator. The emissions of organic compounds from a sewage sludge
incinerator are regulated by limiting the concentration of total hydrocarbons (dry weight basis and
corrected for oxygen content) in the exhaust gas from the sewage sludge incinerator. In addition, Part
Draft-March 1993 7-3
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7. INCINERATION - PART 503 SUBPART E
503 requires that the firing of sewage sludge in a sewage sludge incinerator not violate the National
Emission Standards for Hazardous Air Pollutants (NESHAPs) for beryllium and mercury in Subparts C
and E, respectively, of 40 CFR Part 61.
Sewage sludge incinerators may also be subject to the Clean Air Act (CAA) requirements of the Standards
of Performance for Sewage Treatment Plants in Subpart 0 of 40 CFR Part 60. It is important to
remember that these CAA regulations have separate applicability requirements (and separate permitting
authority) from those of Part 503. Therefore, a sewage sludge incinerator that is subject to the Part 503,
Subpart E regulations may not necessarily be subject to the Part 60, Subpart O regulations.
7.1.3 SUBPART E REQUIREMENTS TO APPLY TO THE OWNER/OPERATOR OF THE
INCINERATOR AND TO GENERATORS OF SEWAGE SLUDGE FIRED IN A SEWAGE
SLUDGE INCINERATOR
The permit to the owner/operator of the sewage sludge incinerator should contain all of the Part 503,
Subpart E requirements. If the sewage sludge incinerator receives sewage sludge from various sources,
the owner/operator may have difficulty controlling the quality of the sewage sludge. Nevertheless, the
permit writer will require the operator to fire only sewage sludge meeting the specific numerical standards
developed in accordance with the §503.43 requirements.
While Subpart E mainly addresses requirements for the actual firing of sewage sludge, any person who
prepares sewage sludge is required to ensure that the applicable requirements of Subpart E are met when
the sewage sludge is fired (§503.7). Thus, a treatment works that sends its sewage sludge to an
incinerator that it does not own or operate should be issued a permit that includes requirements to
monitor, maintain records, and report on the quality of the sewage sludge. The permit should also
require the treatment works to ensure that the sewage sludge it generates is sent to an incinerator that is
in compliance with the Subpart E requirements.
7.2 DEFINITIONS
Section 503.9 contains general definitions applicable to Part 503. In addition, terms and definitions
specifically applicable to the incineration of sewage sludge are set out in §503.41. This portion of the
guidance manual elaborates on each of the §503.41 definitions and reproduces relevant general definitions
from §503.9 at the end for reference purposes.
Air Pollution Control Device
Statement of Regulations
§503.41(a) Air pollution control device is one or more processes used to treat the exit gas from a sewage
sludge incinerator stack.
Although the Part 503 regulations do not require either the use or specific types of air pollution control
devices, in most cases they are needed for a sewage sludge incinerator to comply with emission standards.
Typically, air pollution control devices used with sewage sludge incinerators control emissions of
particulate matter (including metals) and organic compounds. Cyclones, wet scrubbers, dry and wet
electrostatic precipitators, and fabric filters control particulates. Afterburners provide more complete
Draft-March 1993 7-4
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7. INCINERATION - PART 503 SUBPART E
combustion of organic compounds (EPA 1992a). Air pollution control devices are frequently arranged
in series to provide better removal efficiencies of different pollutants from incinerator exhaust gases.
Auxiliary Fuel
Statement of Regulations -
8503.41 (b) Auxiliary fuel is fuel used to augment the fuel value of sewage sludge. This includes, but is not
limited to, natural gas, fuel oil, coal, gas generated during anaerobic digestion of sewage sludge,
and municipal solid waste (not to exceed 30 percent of the dry weight of sewage sludge and
auxiliary fuel together). Hazardous wastes are not auxiliary fuel.
The heating value of sewage sludge is relatively high and the combustion of sewage sludge can be self
sustaining if sewage sludge is both high in volatile solids content and low in moisture content (i.e., less
than 70 percent). However, the high water content of most sewage sludges requires additional heat to
sustain combustion of sewage sludge in the furnace. This additional heat is generated by burning
auxiliary fuel in the combustion chamber. Auxiliary fuel is any fuel (or combination of different fuels)
that can be used to maintain combustion in the furnace. Some examples of auxiliary fuels are provided
in the regulatory definition of auxiliary fuel. Other materials such as wood or waste oils are also
auxiliary fuels. Hazardous wastes are specifically excluded from the regulatory definition of auxiliary
fuel. Municipal solid waste can be used as the auxiliary fuel if the municipal solid waste constitutes no
more than 30 percent of the dry weight of sewage sludge and auxiliary fuel together. If 30 percent or
more of the material fired in an incinerator is municipal solid waste, the incinerator is not covered under
this regulation.
Control Efficiency
Statement of Regulations
§503.41 (c) Control efficiency is the mass of a pollutant in the sewage sludge fed to an incinerator minus the
mass of that pollutant in the exit gas from the incinerator stack divided by the mass of the
pollutant in the sewage sludge fed to the incinerator.
Control efficiency must be determined from a performance test of the sewage sludge incinerator. The
performance test must be conducted in accordance with test methods and procedures specified by the
permitting authority. Generally, performance tests should be conducted under conditions that are
representative of the normal performance of the sewage sludge incinerator. For example, operations
during periods of startup, shutdown, and malfunction do not constitute representative conditions. To
simplify the establishment of permit conditions, performance tests should be conducted at "worst-case"
conditions (e.g., the highest possible sewage sludge feed rate) whenever possible.
During the performance test, the volume or weight of the sewage sludge charged to the incinerator must
be determined accurately. Samples of sewage sludge must be collected and analyzed to determine the
pollutant content of the sewage sludge. Samples must be collected from the sewage sludge charged to
the incinerator at the beginning of each test run and at a minimum of 30-minute intervals thereafter until
the test run ends. The sewage sludge samples collected during each test run should be combined into a
single composite sample. A minimum of three composite samples, representing three test runs, should
Draft-March 1993 7-5
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7. INCINERATION - PART 503 SUBPART E
be collected and analyzed to determine the pollutants and the mass of each pollutant that is fed to the
incinerator. A representative measurement of pollutant emissions and total volumetric flow rate of the
exit gas must also be obtained to determine the mass of each pollutant that exits from the incinerator
stack. Normally, an appropriate sampling location where the exit gas stream is flowing in a known
direction is selected, and the cross-section of the stack is divided into a number of equal areas. Exit gas
is then collected from points located within each of these equal areas and analyzed for pollutants of
interest. During a performance test, stack sampling is typically conducted at least 3 times, with a
sampling period of one to four hours each. If more than one sewage sludge incinerator is located at a
site, the control efficiency of each incinerator must be determined. Then, the pollutant limits for each
incinerator must be calculated using only the control efficiency determined for that incinerator (EPA
1989).
The permit writer should review performance test records to determine the conditions of the performance
test and the appropriateness of the methods used. Subpart 0 of 40 CFR Part 60 includes procedures to
determine the concentrations of metals in sewage sludge and in incinerator exhaust gases. The stack gas
procedures of Subpart O, however, only account for metals (solid particles) that are captured by the
sample train filter; they do not account for metals that are emitted in the vapor phase, therefore, they
should not be used when determining control efficiency. The protocol entitled "Methodology for the
Determination of Metal Emissions in Exhaust Gases from Hazardous Waste Incineration and Similar
Combustion Processes" in Appendix 9 of 40 CFR Part 266 does measure vapor phase metals and should
be used when control efficiency determinations are to be made.
Dispersion Factor
Statement of Regulations
§503.41 (d) Dispersion factor is the ratio of the increase in the ground level: ambient air concentration: for
a pollutant at or beyond the property line of the site where the sewage sludge incinerator is
located to the mass emission rate for the pollutant from the incinerator stack.
The dispersion factor is used in equations presented in Part 503 to calculate the sewage sludge pollutant
concentration limits for metals. The dispersion factor is determined by using an EPA approved air
dispersion model. A dispersion model is a detailed air dispersion analysis. The model predicts the
downwind ambient air concentration at a specified distance from the stack for a given set of site-specific
meteorological conditions, stack height, and stack gas emission rates. Once the relationship between stack
gas emission rates and the ambient ground-level concentration of a pollutant is established, through use
of a dispersion model, the dispersion factor can be calculated. For example, if the model predicts that
at a specified mass emission rate, the ground-level ambient air concentration will increase from X to Z,
the dispersion factor can be calculated using the equation:
Draft-March 1993 7-6
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7. INCINERATION - PART 503 SUBPART E
where: DF = dispersion factor
X = ground-level ambient air concentration without mass emission
rate
Y = mass emission rate from stack gas of sewage sludge incinerator
Z = ground-level ambient air concentration with mass emission rate
ofY
The units of measurement used for the dispersion factor in Part 503 are micrograms per cubic meter per
gram per second.
Fluidized Bed Incinerator
Statement of Regulations
§503.41 (e) Fluidized bed incinerator is an enclosed device in which organic matter and inorganic matter in
sewage sludge are combusted in a oed of particles suspended in the combustion chamber gas.
A fluidized bed incinerator is a unique combustion device in which air, sewage sludge, and inert solid
particles (sand) are mixed so that the mixture behaves as a fluid. Fluidizing sewage sludge during
combustion provides excellent mixing of combustion air with the sewage sludge and sand particles. The
turbulent mixing action provides intimate contact between the sewage sludge, combustion air, and the hot
sand particles, resulting in improved heat transfer capabilities, lower excess air and auxiliary fuel
requirements, and lower sewage sludge residence times compared to other types of sewage sludge
incinerators. The improved mixing capability of fluidized bed incinerators also provides some protection
against fluctuations in sewage sludge feed rate and moisture content.
Hourly Average
Statement of Regulations
§503.41(f) Hourly average is the arithmetic mean of all measurements taken during a hour. At least two
measurements must be taken during the hour.
The hourly average concentration of total hydrocarbons must be calculated in order to derive the monthly
average concentration for total hydrocarbons. For example, if the THC instrument is operated to collect
and analyze the exit gas every 15 seconds, then 240 measurements would be made in one hour. The
individual values would be summed and then divided by 240 to obtain the hourly average.
Draft-March 1993 7-7
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7. INCINERATION - PART 503 SUBPART E
Incineration
Statement of Regulations
§503.41 (g) Incineration is the combustion of organic matter and inorganic matter in sewage sludge by high
temperatures in an enclosed device.
Although sewage sludges contain large amounts of water, the dry solids in the sewage sludges are largely
organic and, on a dry basis, very combustible. For the purposes of this regulation, combustion is the
thermal oxidation of sewage sludge at relatively high temperatures resulting in ash, water, and carbon
dioxide as primary end products. The oxygen required for combustion is normally furnished from
ambient air (approximately 21 percent oxygen by volume). The exhaust gases from sewage sludge
incinerators are a mixture predominantly composed of nitrogen, carbon dioxide, water vapor, and oxygen.
Depending on the composition of the incinerated sewage sludge, the auxiliary fuel that is fired, and the
design and operation of the incinerator and any air pollution control device, small quantities of sulfur
dioxide, nitrogen oxides (mostly NO), carbon monoxide, organic compounds, and paniculate matter may
also be present. The paniculate matter will, in part, consist of various trace metals in the form of oxides,
carbonates, silicates, and/or as elemental metals. Some metals, particularly mercury, will volatilize
during incineration and will be emitted from the incinerator largely in gaseous form. A wide variety of
organic compounds may exist in incinerator exhaust gases. These organic compound emissions may
result from the incomplete combustion of sewage sludge and/or auxiliary fuel. In some cases, these
products of incomplete combustion can recombine to form larger organic compounds as they are emitted
from the incinerator. Other components of sewage sludge, mostly inorganic materials, will be discharged
from the incinerator as a bottom ash.
Monthly Average
Statement of Regulations
§503.41(h) Monthly average is the arithmetic mean of the hourly averages for the hours a sewage sludge
incinerator operates during the month.
The total hydrocarbons limit of 100 parts per million is expressed as a monthly average concentration.
The monthly average concentration is determined by dividing the sum of all hourly averages (see
definition of hourly average) obtained during a month by the hours the sewage sludge incinerator operated
during that month.
Risk Specific Concentration
Statement of Regulations
•
,§503.410) Risk specific concentration is the allowable increase in the average daily ground level ambient
air concentration for a pollutant from the incineration of sewage sludge at or beyond the
property line of the site where the sewage sludge incinerator is located.
Draft-March 1993 7-8
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7. INCINERATION - PART 503 SUBPART E
The Risk Specific Concentrations (RSCs) are used in the equation provided in §503.43(d)(l) to calculate
the pollutant limits for arsenic, cadmium, chromium, and nickel. The RSCs were derived by EPA based
on a predefined risk level of 1 chance in 10,000, a body weight of 70 kg, and an inhalation rate of 20
m'/day. RSC values are provided in §503.43 for arsenic, cadmium, nickel, and chromium. Part 503
allows the RSC value for chromium to be determined in one of two ways. The chromium RSC value
can be selected from four RSC values listed in the regulations depending on the type of sewage sludge
incinerator and air pollution control device, or the RSC value for chromium can be calculated using
Equation (6) of the regulations.
Sewage Sludge Feed Rate
Statement of Regulations
§503.41(j> Sewase sludge feed rate is either the average daily amount of sewage sludge fired in all sewage
sludge incinerators within the property line of the site where the sewage sludge incinerators are
located for the number of days in a 365 day period that each sewage sludge incinerator operates,
or the average daily design capacity for all sewage sludge: incinerators within the property line
of the site where the sewage sludge incinerators are located.
The sewage sludge feed rate can play a crucial role in optimizing the operation of the sewage sludge
incinerator. In general, the sewage sludge feed rate is kept constant as a rapid change in the amount of
sewage sludge fed to the incinerator can cause drastic changes in furnace operation. Sewage sludge feed
rate changes can affect the quantity and temperature of the incinerator off-gases and therefore may
decrease the efficiency of air pollution control devices (EPA 1992a).
The sewage sludge feed rate is used to establish the maximum acceptable concentration of the metal
pollutants in sewage sludge to be incinerated. The owner/operator can elect to use the average daily
amount of sewage sludge that is actually fired in the sewage sludge incinerator or the average daily design
capacity of the sludge incinerator. The actual average daily amount is determined by dividing the total
amount of sewage sludge fired in a 365-day period by the number of days the sewage sludge incinerator
operated in that same 365-day period. A sewage sludge incineration facility may contain more than one
sewage sludge incinerator within the property lines of the facility. The operating capacities and schedules
of the individual incinerators may vary considerably. Where there is more than one sewage sludge
incinerator located at a site, sewage sludge feed rates for each incinerator at the site may need to be
determined since individual incinerators may have different values for dispersion factor and control
efficiency. However, if the values of control efficiency and dispersion factor are the same for each
incinerator, the sewage sludge feed rate for the entire site can be used to calculate pollutant limits. The
following is an example of a multi-unit calculation for sewage sludge feed rate:
Draft-March 1993 7-9
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7. INCINERATION - PART 503 SUBPART E
Incinerator A
Incinerator B
Sewage fired per year
1500 metric tons
2500 metric tons
Operating days per year
280 days
260 days
1500
Incinerator A: = 5.36 metric tons per day
2500
Incinerator B: = 9.62 metric tons per day
Average daily feed rates 14.98 metric tons per day
Sewage Sludge Incinerator
Statement of Regulations
§503.41(k) Sewage sludge incinerator is an enclosed device in which only sewage sludge and auxiliary fuel
are fired.
The term "an enclosed device," used in the definition of sewage sludge incinerator, in general refers to
some type of furnace. The most common types of furnaces currently used for sewage sludge incineration
are multiple-hearth furnaces and fluidized-bed furnaces (EPA 1990c). Other less commonly used furnaces
include electric-infrared furnaces and rotary kilns. Sewage sludge drying and stabilization units are not
considered to be sewage sludge incinerators.
Some incinerators are operated under conditions of starved-air combustion in a primary chamber,
followed by excess air combustion in a secondary chamber (sometimes referred to as an afterburner).
No Federal regulations specify which type of incinerator must be used to incinerate sewage sludge.
However, the permit writer must be aware that some States (e.g., Kansas and Rhode Island) or regional
authorities may specify certain types of incinerators for firing sewage sludge (EPA 1990b). References
listed at the end of this chapter provide more detailed information on the types and operation of sewage
sludge incinerators.
Draft-March 1993 7-10
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7. INCINERATION - PART 503 SUBPART E
Stack Height
Statement of Regulations
§503.410) Stock height is the difference between the elevation of the top of a sewage sludge incinerator
stack and the elevation of the ground at the base of the stack when the difference is equal to or
less than 65 meters. When the difference is greater than 65 meters, stack height is the creditable
stack height determined in accordance with 40 CFR 51.100 (ii).
Either the actual incinerator stack height or a creditable stack height must be used in an air dispersion
model specified by the permitting authority, to determine the dispersion factor. Currently, most sewage
sludge incinerators have stacks less than 65 meters. If the difference in elevation is greater than 65
meters, the stack height to be used in the air dispersion model is the creditable stack height obtained in
accordance with instructions provided in 40 CFR §51.100(ii). More detailed guidance on determining
the stack height is provided in Section 7.4.1 of this manual.
Total Hydrocarbons
Statement of Regulations
§503.41(m) Total hydrocarbons means the organic compounds in the exit gas from a sewage sludge
incinerator stack measured using a flame ionization detection instrument referenced to
propane.
Numerous organic compounds have the potential to be emitted from sewage sludge incinerators.
However, identifying and quantifying potential organic compound emissions from incinerators is
complicated and expensive. Identification and quantification of organics can only be done by analyzing
samples of incinerator exhaust gas obtained over discrete time periods.
EPA has determined that there is a significant correlation between the concentration of several organic
compounds in sewage sludge incinerator exhaust gases and the total hydrocarbons (THC) concentration
(as measured by a flame ionization detector) in the same gases. Because of this correlation and since
THC data can provide incinerator operators with information necessary to make relatively quick
adjustments to incinerator operating parameters, EPA uses a THC standard to regulate organic compound
emissions from sewage sludge incinerators (EPA 1992a).
Wet Electrostatic Precipitator
Statement of Regulations
§S03.41(n) Wet electrostatic precipitator is an air pollution control device that uses both electrical forces
and water to remove pollutants in the exit gas from a sewage sludge incinerator stack.
A wet electrostatic precipitator is a variation of the more widely used dry electrostatic precipitator.
Primarily, wet electrostatic precipitators are designed to remove paniculate matter (including metals) from
exhaust gases. Since wet electrostatic precipitators use water in their operation, some absorption of
Draft-March 1993 7-11
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7. INCINERATION - PART 503 SUBPART E
gaseous pollutants can also occur. The use of water also makes the wet electrostatic precipitators more
compatible for use with wet scrubbers.
In wet electrostatic precipitator operation, water sprays are used to condition the incoming gas stream.
The water sprays cool the gas stream, help maintain more uniform particle size, and ease the application
of electrical charge to paniculate matter. After particles are charged, they migrate to the charged surfaces
of collection plates. Collected paniculate matter is removed from the plates by continuous flushing with
water.
Wet Scrubber
Statement of Regulations
§503.41(o) Wet, scrubber is an air pollution control device that uses water to remove pollutants in the
exit gas from a sewage sludge incinerator stack.
Wet scrubbers exist in numerous forms, ranging from relatively simple spray chambers and wet cyclones
to more Complex and more efficient plate and tray and venturi scrubbers. Regardless of whether the
scrubber is used to control gaseous pollutants or paniculate matter, the removal efficiency of the scrubber
depends largely on the scrubber's pressure drop during operation. Generally, the higher the operating
pressure drop of the scrubber, the higher the pollutant removal efficiency.
Statement of Regulations
§S03.9(h) Dry weight basis means calculated on the basis of having been dried at 105 degrees Celsius until
reaching a constant mass (i.e., essentially 100 percent solids content).
§503.9(u) Pollutant limit is a numerical value that describes the amount of a pollutant allowed per unit
amount of sewage sludge (e.g., milligrams per kilogram of total solids); the amount of a
pollutant that can be applied to a unit area of land (e.g., kilograms per hectare); or the volume
of a material that can be applied to a unit area of land (e.g., gallons per acre).
§503.9(w) Sewage sludge is solid, semi-solid, or liquid residuegenerated during the treatment of domestic
sewage in & treatment works. Sewage sludge includes, but is not limited to, domestic septage;
scum or solids removed in primary, secondary, or advanced wastewater treatment processes; and
a material derived from sewage sludge. Sewage sludge does not include ash generated during
the Tiring of sewage sludge in a sewage sludge incinerator or grit and screenings generated
during preliminary treatment of domestic sewage in a treatment works.
7.3 GENERAL REQUIREMENTS
Statement of Regulations
; §503.42 No person shall fire sewage sludge in a sewage sludge incinerator except in compliance with the
. requirements in this subpart.
Purpose: To make the Subpart E requirements directly enforceable.
Applies to: Owner/operator of sewage sludge incinerator.
Draft-March 1993 7-12
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7. INCINERATION - PART 503 SUBPART E
The general requirement of §503.42 enhances the direct enforceability of the requirements of Subpart E.
The compliance period, established in §503.2, requires compliance to be achieved as expeditiously as
practicable, but no later than February 19, 1994. If the owner or operator of the incinerator must
construct new pollution control facilities in order to comply with the rule, compliance shall be achieved
no later than February 19, 1995. The permit writer should ensure that construction of new pollution
control facilities is indeed necessary for compliance purposes (construction should not be used in lieu of
other management practices).
Frequency of monitoring, recordkeeping, and reporting requirements are effective on July 20, 1993.
However, these requirements for total hydrocarbons in the exit gas from a sewage sludge incinerator are
effective on February 19, 1994. If construction of new pollution control facilities is necessary in order
to comply with the operational standard for total hydrocarbons, these requirements are effective on
February 19, 1995.
To ensure that the owner/operator of the incinerator complies with the requirements of Subpart E by the
specified dates, the permit writer may have to develop compliance schedules as permit conditions. For
example, the permit writer may set milestone dates for installation of monitoring equipment or
construction of new pollution control facilities. Any compliance schedule contained in a permit may not
extend the compliance dates beyond these imposed by the Part 503 regulations.
7.4 POLLUTANT LIMITS
Subpart E of Part 503 regulates five pollutants in'sewage sludge fired in a sewage sludge incinerator:
lead, arsenic, cadmium, chromium, and nickel. Part 503 contains equations for calculating numerical
limits for these five metals based on site-specific conditions. This section provides procedures on how
to calculate the pollutant limits for the five metals using equations and site-specific factors. Emissions
of beryllium and mercury are regulated by the National Emission Standards for these pollutants in Subpart
C and Subpart E of 40 CFR Part 61, respectively. This manual provides instructions on how to
incorporate the Part 503 regulations governing beryllium and mercury. Total hydrocarbons emissions
are limited by an operational standard discussed in Section 7.5.
7.4.1 SIT&SPECIFIC FACTORS
The development of pollutant limits for a sewage sludge incinerator requires the use of site-specific
information supplied by the incinerator's owner/operator. Before calculating the five metal limits, the
permit writer will need to obtain the site-specific factors to be used in the equations of the Part 503
regulations. These site-specific factors should be reviewed and accepted by the permit writer. These
factors include the dispersion factor, control efficiency, stack height, and sewage sludge feed rate. Each
of these factors is discussed in more detail below.
The determination of the appropriate values for these factors requires knowledge of air dispersion
modeling, emissions testing, and the design and operation of the incinerator. The permit writer may want
to consider requiring the owner/operator to submit additional certification (other than what is required
by Part 122) by qualified professionals involved in developing or selecting the numerical values for these
factors. The permit writer may want the owner/operator to indicate the qualifications of the professionals
involved in conducting any air modeling or incinerator performance tests. The permit writer should work
with EPA's Air Program to evaluate the information supplied by the owner/operator.
Draft-March 1993 7-13
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7. INCINERATION - PART 503 SUBPART E
Dispersion Factor — correlates the emission
rate for a pollutant with the resulting increase
in ambient ground level pollutant
concentrations in the air around the
incinerator
Dispersion Factor = increase in ambient
ground-level pollutant concentration
divided by emission rate (g/sec)
Dispersion Factor
The dispersion factor is determined through the
use of air dispersion models. Air dispersion
models range from simple screening techniques to
more sophisticated models. Screening techniques
are relatively inexpensive and do not require a
great deal of modeling expertise, computer time,
or input data. However, screening techniques are
conservative in their design and tend to predict
higher ambient pollutant concentrations than more
complex models. The use of screening techniques
to determine a dispersion factor is acceptable;
however, both the permit writer and the permit mmm^^^^^^mmmmmmm^^f^mfmmmam
applicant should recognize and accept that the
calculated sewage sludge pollutant limits will be lower (more stringent) than those derived from more
refined dispersion models. For this reason, the owner/operator may choose to perform more detailed and
refined dispersion modeling.
A knowledgeable air quality modeler with adequate computer resources and meteorological and source
parameter data for model input is needed to perform a detailed air dispersion modeling analysis. For
refined modeling, three air dispersion models are most commonly used (see box below). Selection of
the appropriate model depends mainly on two factors:
• Terrain Type — A simple terrain model is used if all terrain in the surrounding area is below the
facility's lowest stack elevation; a complex terrain model is used if terrain elevations exist above
the lowest stack elevation
• Urban/Rural Classification — Urban plume dispersion coefficients are used if the incinerator is
located in an urban area; rural plume coefficients are used if the incinerator is located in a rural
area.
AIR DISPERSION MODEL
Industrial Source Complex Long-Term modela>b
(ISCLT)
LONGZ c
COMPLEX Ic
WHEN USED
Simple terrain; both rural and urban areas
Complex urban terrain
Complex rural terrain
Sources:
" Industrial Source Complex (ISC) Dispersion Model User's Guide - Second Edition
b Sludge Incineration Modeling (SIM) System User's .Guide
c Guidelines on Air Quality Models (GAQM)
Draft-March 1993
7-14
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7. INCINERATION - PART 503 SUBPART E
In addition to terrain and land use classification considerations, source parameters, meteorological data,
receptor grids, and model control options need to be provided in most dispersion models. Two
parameters that are necessary to perform refined modeling are incinerator design and operation
considerations. A list of typical source parameters needed for dispersion modeling appears below.
Source Parameters for Input to the Air Dispersion Models:
Stack height above ground level
Inside stack diameter
Gas velocity at stack exit
Gas flow rate
Gas temperature at stack exit
Stack-base elevation
Building dimensions
Stack coordinates (based on distance from grid origin)
Emission rate
The meteorological data used in the dispersion model should be representative of the incinerator location.
The Guidelines on Air Quality Models state that, if possible, one year or more of on-site meteorological
data are preferred for use in the dispersion model. If such data are unavailable, 5 years of meteorological
data from the nearest or most representative National Weather Service station should be used. The data
needed vary depending on the specific model to be run but, in general, consist of hourly observations of
wind speed and direction, mixing heights, stability class, and atmospheric temperatures. Sources of
meteorological data are listed below.
Sources of Meteorological Data:
• National Weather Service (NWS)
• Onsite meteorological measurement program
• Federal Aviation Administration (FAA)
• Local universities
• Military stations
• Pollution control agencies
• National Climatic Data Center, Asheville, NC (NWS and military station data)
• Support Center for Regulatory Air Model's (SCRAM) Electronic Bulletin Board System
(BBS) (NWS)
• Onsite Meteorological Program Guidance for Regulatory Modeling Applications, GAQM,
EPA 1987
• Ambient Monitoring Guidelines for Prevention of Significant Deterioration (PSD), GAQM,
EPA 1987
• Quality Assurance Handbook for Air Pollution Measurements Systems, Volume IV:
Meteorological Measurements, EPA 1983
Draft-March 1993 7-15
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7. INCINERATION - PART 503 SUBPART E
Control Efficiency
As discussed earlier, sewage sludge incinerator control efficiencies for the five regulated metals must be
determined from a performance test specified by the permitting authority. Control efficiency is crucial
in that it indicates the extent to which pollutants remain in the incinerator exhaust and, therefore, the
potential ambient air impacts of emissions from the incinerator.
Under Part 503, control efficiency determinations should include three elements:
• Sampling and analysis of sewage sludge for the regulated metals
• Sampling and analysis of incinerator air emissions for the regulated metals
• Monitoring and documentation of incinerator and control equipment operating parameters during
sampling. Parameters of interest include sewage sludge feed rate, incinerator exhaust flowrate,
incinerator combustion temperature, sewage sludge characteristics, auxiliary fuel type and feed
rate, and specific air pollution control device parameters.
The Part 503 regulation gives permit writers and permitting authorities the responsibility for specifying
and/or approving specific test methods. Permitting authorities may refer to the following recommended
procedures for guidance in developing control efficiency test procedures:
• For Sewage Sludge Sampling and Analysis — POTW Sludge Sampling and Analysis Guidance
Document.
• For Stack Sampling and Analysis for Metals — "Methodology for the Determination of Metal
Emissions in Exhaust Gases from Hazardous Waste Incineration and Similar Combustion
Processes," Appendix 9 of 40 CFR Part 266.
• For Stack Sampling and Analysis for Hexavalent Chromium — "Determination of Hexavalent
Chromium Emissions from Stationary Sources" (draft method), Appendix 9 of 40 CFR Part 266.
The recording of operating parameters during any performance test is important since this information
establishes "baseline" operating conditions of the incinerator and its control equipment when control
efficiencies were determined. If, at a later time, the monitored operating parameters were to change
significantly from the baseline levels established during the performance test, the control efficiencies for
regulated pollutants may also have changed. If this situation were to occur, .another performance test may
need to be conducted to confirm control efficiencies for each regulated pollutant.
Permit writers should carefully review any performance test results and reports that support control
efficiency determinations. Whenever possible, the owner/operator should submit a test protocol to the
permitting authority for review and approval before any testing is conducted. Please refer to Section 7.8,
Record Keeping Requirements, for a more detailed discussion of test protocols.
In some instances, the owner/operator may have data obtained from a performance test conducted to meet
the requirements of 40 CFR Part 60, Subpart 0. These data, although useful, may not accurately
represent the pollutant control efficiencies for the sewage sludge incinerator and may result in higher
sewage sludge pollutant limits than would be calculated using more accurate control efficiencies.
Draft-March 1993 7-16
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7. INCINERATION - PART 503 SUBPART E
Stack Height
Stack height plays an important role in Part 503, Subpart E for calculating pollutant limits in sewage
sludge. Stack height is used in the dispersion model to derive the site-specific dispersion factors.
Stack height can generally be obtained from engineering and/or construction drawings or plans specific
to each sewage sludge incinerator. If these drawings are unavailable or do not indicate stack height, the
permit writer should request that the owner/operator measure or approximate the stack height using
methods approved by the permitting authority. One recommended method is the use of transit in land
surveying techniques to determine inclination angle and, ultimately, stack height.
To determine stack height for use in the air dispersion model, do the following:
A. If the actual stack height, measured from the ground-level elevation at the base of the stack,
is less than or equal to 65 meters, the actual stack height is used in the air dispersion model
to determine the dispersion factor (DF).
B. If the actual stack height, measured from the ground-level elevation at the base of the stack,
exceeds 65 meters, determine a creditable stack height based on good engineering practice
(GEP). The creditable stack height is the largest stack height determined using the following
guidelines (in accordance with §51.100 (ii)):
(1) 65 meters, measured from the ground-level elevation at the base of the stack.
(2) For stacks in existence on January 12, 1979, which the owner/operator has obtained all
applicable permits or approval required under 40 CFR Parts 51 and 52, the creditable
stack height should be calculated using the following equation:
Creditable Stack Height = 2.5 x H
Where:
. H is the height of nearby structure(s) measured from the ground-level elevation at the
base of the stack.
V
For example, consider a sewage sludge incinerator that has been in existence since
January 1976 and has a stack which measures 66 meters from the ground-level
elevation at the base of the stack and where a structure measuring 30 meters high, 20
meters wide and 50 meters long exist within 60 meters of the stack. Using the above
equation the creditable stack height is calculated as:
Creditable Stack Height = 2.5 x 30 = 75 meters
Draft-March 1993 7-17
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7. INCINERATION - PART 503 SUBPART E
(3) For all other stacks, the stack height should be calculated based on good engineering
practice using the following equation:
Hg = H + 1.51
Where:
H, = good engineering practice stack height, measured from the ground-level
elevation at the base of the stack.
H = height of nearby structure^) measured from the ground-level.elevation at
the base of the stack.
L = lesser dimension, height or projected width, of nearby structure(s).
In this part, "nearby" is defined as that distance up to five times the lesser of the height
or the width dimension of a structure, but not greater than 0.8 kilometers (1/2 mile).
The regulations do allow for modeling or field studies to determine effective stack heights,
but these must first be approved by the EPA, State or local control agency. Specific
requirements are identified in §51.100(ii)(3).
For example, consider a sewage sludge incinerator having a stack which measures 66
meters from the ground-level elevation at the base of the stack and is located within 60
meters of a structure measuring 30 meters high, 20 meters wide, and 50 meters long. The
GEP stack height for this incinerator is calculated as:
Hg = 30 + 1.5 x 20 = 60 meters
The creditable stack height for this incinerator is therefore 65 meters since this number
is larger than the GEP stack height.
Sewage Sludge Feed Rate
The sewage sludge feed rate is used directly in the pollutant limit equations. Any changes in sewage
sludge feed rate will therefore cause a direct, proportional change in pollutant limits. In addition, as
mentioned earlier, sewage sludge incinerator operating parameters (including sewage sludge feed rate)
can influence pollutant control efficiencies. The specific control efficiency achieved by the sewage sludge
incinerator at one sewage sludge feed rate may not be achieved at a different sewage sludge feed rate.
In addition, changes in sewage sludge feed rate may not result in proportional changes in control
efficiency. Therefore, a significant change in sewage sludge feed rate necessitates a performance test to
determine the control efficiency to be used to calculate sewage sludge pollutant limits. To avoid these
additional performance tests and future permit changes, it is important to conduct performance tests and
calculate sewage sludge pollutant limits using worst-case or maximum capacity sewage sludge feed rates.
Draft-March 1993 7-18
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7. INCINERATION - PART 503 SUBPART E
A variety of methods can be used to measure sewage sludge feed rate to a sewage sludge incinerator.
The most commonly used methods are conveyor weighing systems and volumetric methods. Conveyor
weighing systems rely on weight sensors (load cells) mounted beneath conveyor belts or screw augers to
measure sewage sludge feed rates. Volumetric methods rely on the measurement of rotational speed on
the sewage sludge feeding equipment, generally using a tachometer calibrated to a known feed rate, to
measure sewage sludge feed rates. Volumetric methods include calibrated augers, pumps, rotary feeders,
and belt conveyors (EPA 1992a).
7.4.2 LEAD
The Part 503 regulations control the emission of lead into the atmosphere by limiting the allowable daily
concentration of lead in the sewage sludge fed to the incinerator. The Part 503 rule includes an equation
to calculate a site-specific limit for lead.
Statement of Regulations
§503.43(c) Pollutant limit - lead.
§503.43(c)(l) The daily concentration of lead in sewage sludge fed to a sewage sludge incinerator shall not
exceed the concentration calculated using Equation (4).
C = 0.1 x NAAQS x 86.400
DF x (1 - CE) x SF
Eq. (4)
Where:
C = Daily concentration of lead in sewage sludge in milligrams per kilogram of total
solids (dry weight basis).
NAAQS = National Ambient Air Quality Standard for lead in micrograms per cubic meter.
DF = Dispersion factor in micrograms per cubic meter per gram per second.
CE = Sewage sludge incinerator control efficiency for lead in hundredths.
SF = Sewage sludge feed rate in metric tons per day (dry weight basis).
(i) When the sewage sludge stack height is 65 meters or less, the actual sewage sludge
incinerator stack height shall be used in an air dispersion model specified by the permitting
authority to determine the dispersion factor (DF) in Equation (4).
(ii) When the sewage sludge incinerator stack height exceeds 65 meters, the creditable stack
height shall be determined in accordance with 40 CFR 51.100 (ii) and the creditable stack
height shall be used in an air dispersion model specified by the permitting authority to
determine the dispersion factor (DF) in Equation (4).
§503.43(c)(3) The control efficiency (CE) in Equation (4) shall be determined from a performance test of the
sewage sludge incinerator, as specified by the permitting authority.
The permit writer can use the following four-step procedure to determine the appropriate values for each
of the variables used in the equation provided in §503.43(c) and calculate the maximum allowable daily
concentration of lead in sewage sludge fed to a sewage sludge incinerator.
Draft-March 1993
7-19
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7. INCINERATION - PART 503 SUBPART E
Step 1: Determine whether the DF (dispersion factor) has been obtained using the appropriate stack
height in an acceptable air dispersion model. Review the dispersion model report to verify that
the modeling conducted was done correctly and used appropriate input parameters and
assumptions. If the value of DF is not available or was obtained incorrectly, request the
owner/operator to prepare a modeling protocol for approval. Review the protocol and require
that any necessary changes be made before modeling is conducted.
Step 2: Ensure that a numerical value for CE (control efficiency) has been provided by the
owner/operator in the permit application and that this value is based on a performance test
conducted by the owner/operator of the facility in accordance with instructions and
requirements of the permitting authority. If the value is not available or has been obtained
using inappropriate performance test methods, request the owner/operator to prepare a
performance test protocol for approval. Review the protocol and make any necessary changes
to it. After approval of the protocol, review the performance test report and obtain the value
for control efficiency.
Step 3: Verify that the NAAQS for lead provided in the permit application is the current correct
number. This information is listed in 40 CFR 50.12. The current NAAQS for lead is 1.5
Hg/m3.
Step 4: From the information provided by the owner/operator in the permit application, obtain the
value for sewage sludge feed rate (SF) in metric tons per day (dry weight basis). If this is not
provided in the permit application, request this value from the owner/operator. The permit
writer should also request and carefully review any documentation of how the SF value was
determined by the owner/operator. Calculations of average sewage sludge feed rates should
be verified and compared with historical data, air dispersion modeling parameters, performance
testing, and design capacity SF values before being used to set permit limits.
Step 5: Incorporate all necessary variables determined in the previous steps into equation (4) and
calculate the pollutant limit for lead. Compare this limit with the limit calculated and requested
in the permit application and incorporate the most stringent of the two in the permit. (The
example language presented below can be utilized to incorporate this limit into the permit.)
^
Sewage sludge fired in sewage sludge incinerator(s) located at this facility shall not
contain lead in excess of mg/kg of total sewage sludge solids (dry weight basis).
This limit is based on values for dispersion factor, control efficiency and sewage sludge
feed rate presented in the permit application dated and its supporting
documentation. Any changes in the design or operation of the incinerator(s) or air
pollution control equipment that may affect these values, other than those specified in this
permit, are prohibited unless approved by the permitting authority.
Draft-March 1993 7-20
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7. INCINERATION - PART 503 SUBPART E
7.4.3 ARSENIC, CADMIUM, CHROMIUM, AND NICKEL
Like lead emissions, Part 503 controls the emission of arsenic, cadmium, chromium, and nickel by
limiting the allowable daily concentration of these pollutants in the sewage sludge charged into the
incinerator. Part 503 contains an equation to calculate the pollutant limits for the above pollutants.
Whereas the NAAQS was used in equation (4) for lead, arsenic, cadmium, chromium, and nickel,
equation (5) employs a risk specific concentration (RSC) factor which reflects the risk associated with
incineration of sewage sludge and release of these pollutant into the atmosphere.
Statement of Regulations
§503.43(d) Pollutant limit - arsenic, cadmium, chromium, and nickel.
§503.43(4X1) The daily concentration for arsenic, cadmium, chromium, and nickel in sewage sludge fed to a
sewage sludge incinerator each shall not exceed the concentration calculated using Equation (6).
C = RSC x 86.400 Eq. (5)
DP x (1 - CE) x SF
Where:
C =" Daily concentration of arsenic, cadmium, chromium, or nickel in sewage sludge in
milligrams per kilogram of total solids (dry weight basis).
CE = Sewage sludge incinerator control efficiency for arsenic, cadmium, chromium, or
nickel in hundredths.
DF = Dispersion factor in micrograms per cubic meter per gram per second.
RSC = Risk specific concentration in micrograms per cubic meter.
SF - Sewage sludge feed rate in metric tons per day (dry weight basis).
(2) The risk specific concentrations for arsenic, cadmium, and nickel used in equation (5) shall be
obtained from Table 1 of §503.43.
TABLE I OF 503.43 - RISK SPECIFIC CONCENTRATION - ARSENIC, CADMIUM, AND NICKEL
Risk Specific Concentration
Pollutant (micrograms per cubic meter)
Arsenic 0.023
Cadmium 0.057
Nickel 2.0
Draft-March 1993 7-21
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7. INCINERATION - PART 503 SUBPART E
§S03.43(dK3) The risk specific concentration for chromium used in equation (5) shall be obtained from Table
2 of §503.43 or shall be calculated using equation (6), as specified by the permitting authority.
TABLE 2 OF 503.43 - RISK SPECIFIC CONCENTRATION - CHROMIUM
Risk Specific Concentration
Tvne of incinerator (micrograms per cubic meter)
Fluidized bed with wet scrubber 0.65
FUiidbed bed with wet scrubber 0.23
and wet electrostatic precipitator
Otter types with wet scrubber 0.064
Other types with wet scrubber 0.016
and wet electrostatic precipitator
RSC = Eq. (6)
Where:
RSC = risk specific concentration for chromium in micrograms per cubic meter used in
equation (5).
r & decimal fraction of the hexavalent chromium concentration in the total chromium
; concentration measured in the exit gas from the sewage sludge incinerator stack in
hundred ths.
(4) (D When the sewage sludge incinerator stack height is equal to or less than 65 meters, the
actual sewage sludge incinerator stack height shall be used in an air dispersion model, as
specified by the permitting authority, to determine the dispersion factor (DF) in Equation
(6).
(li) When the sewage sludge incinerator stack height is greater than 65 meters, the creditable
Stack height shall be determined in accordance with 40 CFR 51.100 (ii) and the creditable
stack height shall be used in an air dispersion model, as specified by the permitting
authority, to determine the dispersion factor (DF) in equation (5).
(5) The control efficiency (CE) in equation (5) shall be determined from a performance test of the
sewage sludge incinerator, as specified by the permitting authority.
The permit writer can use the following five step procedure to determine the appropriate values for the
variables in equation (5) and calculate the maximum allowable daily concentrations of arsenic, cadmium,
chromium, and nickel in sewage sludge charged into the sewage sludge incinerator.
Step 1: The DF used in this equation is the same numerical value used in equation (4) calculate the
pollutant limit for lead. Refer to Section 7.4.2 for instructions on how to obtain the value of
the dispersion factor.
Step 2: Ensure that numerical values for CE for arsenic, cadmium, chromium, and nickel have been
provided by the owner/operator in the permit application and that these values are based on a
performance test(s) conducted by the owner/operator of the sewage sludge incinerator in
Draft-March 1993 7-22
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7. INCINERATION - PART 503 SUBPART E
accordance with the requirements established in an approved test protocol. If the values are not
available or have been obtained using inappropriate performance test methods, request the
owner/operator to prepare a performance test protocol for approval. Review the protocol and
make any necessary changes to it. After approval of the protocol, review the performance test
report and obtain the values for control efficiency.
Step 3: The risk specific concentrations (RSC) for the pollutants arsenic, cadmium, and nickel are as
follows:
RSC(arsenic) = 0.023 /i/m3
RSC(cadmium) = 0.057 /i/m3
RSC(nickel) = 2.0 n/m3
The RSC for chromium should be obtained using either of the following two methods:
A. Determine the type of incinerator and the air pollution control devices installed. The
numerical value of RSC for chromium for each type of incinerator and air pollution
control devices is as follows:
If incinerator is fluidized bed with wet scrubber, RSC(chromium) = 0.65 /ig/m3
If incinerator is fluidized bed with wet scrubber and wet electrostatic precipitator,
RSC(chromium) = 0.23/xg/m3
If incinerator is another type with wet scrubber, RSC(chromium) = 0.064 jig/m3
If incinerator is another type with wet scrubber and wet electrostatic precipitator,
RSC(chromium) = 0.016 /ig/m3
B. The following equation can also be used to calculate the RSC for chromium:
RSC(chromium) =
Where:
RSC = risk specific concentration for chromium in micrograms per cubic meter (also
see the definition provided for RSC in Section 7.2).
r = decimal fraction of the hexavalent chromium concentration in the total chromium
concentration measured in the exit gas from the sewage sludge incinerator stack in
hundredths. Please note that a specific stack test method for the determination of
hexavalent chromium in stack gases should be used. The permit writer should use
best professional judgement to determine the acceptable number of samples for
identifying the hexavalent chromium concentration.
Draft-March 1993 7-23
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7. INCINERATION - PART 503 SUBPART E
The RSC for chromium can easily be determined by substituting the value of the variable
r hi this equation.
For example, if 15 percent of the total chromium concentration measured in the exit gas
of a sewage sludge incinerator is hexavalent chromium, the decimal fraction of the
hexavalent chromium would be 0.15 and the value for RSC is calculated as:
RSC(chromium) = °-Q°18| = 0.057 /ig/m3
If the permittee uses Method B, the permit writer should compare the RSC for chromium
with those in Table 2 of §503.43 to ensure that the calculated valve is appropriate.
Step 4: From the information provide by the owner/operator in the permit application, obtain the value
for sewage sludge feed rate (SF) in metric tons per day (dry weight basis). If this is not
provided in the permit application, request this value from the owner/operator. This is the
same value used to calculate the pollutant limit for lead.
Step 5: Substitute variables obtained in the previous steps into equation (5) to calculate the allowable
daily concentration of arsenic, cadmium, chromium, and nickel in sewage sludge in milligrams
per kilogram (dry weight basis). If the owner/operator calculated and reported these limits in
the permit application, the permit writer should evaluate the protocol used and, if sound,
incorporate these limits into the permit. Differences in calculated limits between the
owner/operator and the permit writer may be due to differing interpretations of the regulations
(e.g., the number of samples analyzed to determine the hexavalent chromium concentration)
and should be resolved. The example language provided below can be used to incorporate
these pollutant limits into the permit.
Draft-March 1993 7-24
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7. INCINERATION - PART 503 SUBPART E
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Sewage sludge 1
contain arsenic,
expressed as mg
based on values
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Any changes in
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prohibited unless
Pollutant
Arsenic
Cadmium
Chromium
Nickel
SAMPLE PEKMIT CONBFHON8 FOR
MC, CADMIUM, CHROMIUM, ANB NICKEL
fired to sewage sludge incinerator(s) located at this facility shall not
cadmium, chromium and nickel in excess of the quantities listed below
/kg of total sewage sludge solids (dry weight basis). These limits are
for dispersion factor, control efficiencies and sewage sludge feed rate
permit application dated and its supporting documentation.
the design or operation of these incinerators) or their air pollution
hat may affect these values, other than those specified in this permit, are
allowed by the permitting authority.
Daily Concentration Limits mg/kg (dry weight)
•>
7.4.4 BERYLLIUM
Statement of Regulations
§503.43(a) Firing of sewage sludge in a sewage sludge incinerator shall not violate the requirements in the
National Emission Standard for Beryllium in subpart C of 40 CFR Part 61.
§6U2(a) Emissions to the atmosphere from stationary sources subject to the provisions of this subpart
shall not exceed 10 grams of beryllium over a 24-hour period, except as provided in paragraph
(b) of this section.
§61.32(b) Rather than meet the requirement of paragraph (a) of this section, an owner or operator may
request approval from the Administrator to meet an ambient concentration limit on beryllium
in the vicinity of the stationary source of 0.01 itglm , averaged over a 30-day period.
Beryllium emissions from a sewage sludge incinerator are regulated by the National Emission Standards
for Hazardous Air Pollutants (NESHAPs) in Subpart C of 40 CFR Part 61. The Part 503 regulations
require that the NESHAP for beryllium be met when sewage sludge is fired in a sewage sludge
incinerator. The emission of beryllium can be regulated in one of two ways:
• In the exit gas from the sewage sludge incinerator stack
• In the ambient air around the incinerator.
Draft-March 1993 7-25
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7. INCINERATION - PART 503 SUBPART E
The conditions placed in the permit will depend
on the method chosen by the applicant to
demonstrate compliance with the beryllium
requirements.
The NESHAP for beryllium that applies to all
sewage sludge incinerators covered under Part
503 is 10 grams of beryllium over a 24-hour
period. This standard applies to each regulated
incinerator, except when the owner/operator of a
sewage sludge incinerator has been granted a
written approval from the Administrator to meet
an ambient concentration limit on beryllium in the
vicinity of the sewage sludge incinerator of 0.01
ftg/m3. averaged over a 30-day period. The first
limit stated above requires that, when sewage
sludge is fired in a sewage sludge incinerator, the
total quantity of beryllium emitted must not
exceed 10 grams during any 24-hour period. This
limit is for each incinerator (e.g., if three
incinerators are on site, each incinerator could
emit up to 10 grams per 24-hour period). The
alternative limit requires that the ambient
concentration of beryllium in the proximity of the
sewage sludge incinerator not exceed 0.01 /*g/m3 m^timmm^^imammmmi^mmim^mmimmi^^^tm
when averaged over any 30-day period. The
radius of the area that is considered within proximity or vicinity of the plant is generally described in the
written approval from the Administrator for this alternative limit.
The permit writer can utilize the following two step procedure to determine and incorporate the
appropriate emission standard for beryllium:
Step 1: From the information provided by the owner/operator of the sewage sludge incinerator,
determine whether or not a written approval has been granted to the owner/operator by
the Administrator to meet the alternative ambient concentration limit of 0.01 /xg/m3,
averaged over a 30-day period in the vicinity of the incinerator facility. If written
approval was granted, first obtain a copy of the original written approval, then include
this alternative limit in the permit (example language is provided below). If written
approval was not granted, go to Step 2.
Step 2: If the owner/operator of the incinerator does not hold a written approval from the
Administrator granting the alternative ambient concentration limit, incorporate the
NESHAP of 10 grams of beryllium over a 24-hour period into the permit (example
language is provided below).
The NESHAP for beryllium in Subpart C of 40
CFR Part 61 includes a provision that allows
an owner or operator to request approval from
the Administrator to meet an ambient
concentration limit on beryllium in the vicinity
of the stationary source of 0.01 jtg/m3
(averaged over a 30-day period) to replace the
limit of 10 grams of beryllium over a 24-hour
period. Because the deadline for seeking such
request was April 6, 1973, a sewage sludge
incinerator covered under the Part 503 rule can
only be subject to this alternative ambient
concentration limit if the owner/operator of the
incinerator has already been granted a written
approval to comply with this provision.
The term "in the vicinity of the stationary
source" refers to the distance from the sewage
sludge incinerator stack to the point of
maximum impact or concentration of the
beryllium emissions, as determined by use of a
proper air dispersion model.
Draft-March 1993
7-26
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7. INCINERATION - PART 503 SUBPART E
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SAMPLE PERMIT CONDITIONS FOR BERYLLIUM
1. The firing of sewage sludge in the sewage sludge incinerator(s) at this facility shall
not cause the maximum ambient air concentration of beryllium in the vicinity of the
facility to exceed 0.01 micrograms/cubic meter, averaged over a 30-day period. This
limit is based on the attached written approval from the Administrator dated
, any documents related to the issuance of this approval, and any
conditions included with this approval.
2. The firing of sewage sludge in the sewage sludge incinerator shall not cause
beryllium emissions from the incinerator to exceed 10 grams in a 24-hour period.
Compliance with this standard will be demonstrated by a performance test using
procedures approved by the permitting authority at frequencies specified by the
permitting authority.
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7.4.5 MERCURY
Statement of Regulations
§S03.43(b) Firing of sewage sludge in a sewage sludge incinerator shall not violate the requirements in the
National Emission Standard for Mercury in subpart E of 40 CFR Part 61.
§61.52(b) Emissions to the atmosphere from sludge incineration plants, sludge drying plants, or a
combination of these that process wastewater treatment plant sludge shall not exceed 3200 grams
of mercury per 24-hour period.
The air emissions of mercury from a sewage sludge incinerator are regulated by the National Emission
Standards for Hazardous Air Pollutants (NESHAPs) in Subpart E of 40 CFR Part 61. Part 503 requires
that the NESHAP for mercury be met when sewage sludge is fired in a sewage sludge incinerator. The
emission of mercury can be regulated in one of two ways:
• In the exit gas from the sewage sludge incinerator stack
• In the sewage sludge fed to the incinerator.
The conditions placed in the permit will depend on the method chosen by the applicant to demonstrate
compliance with the mercury requirements.
The NESHAP for mercury that applies to all sewage sludge incinerators covered under Part 503 is 3200
grams of mercury over a 24-hour period. This means the total quantity of mercury that is emitted into
the atmosphere from all incinerators at a given site must not exceed 3200 grams during any 24-hour
period (e.g., if three incinerators are on site, the three incinerators could emit a total of 3200 grams per
Draft-March 1993 7-27
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7. INCINERATION - PART 503 SUBPART E
24-hour period). The permit writer can incorporate this pollutant limit requirement verbatim from the
regulations or use the example language provided below.
The permit writer should construct the permit language carefully. The permit condition should not be
written to imply that the permit writer is establishing an air standard or emission rate that the permit
writer has no authority to establish. For example, the following language clearly indicates that the air
emission rate was established by an air permit, specific state implementation plan or air regulation
governing the incinerator.
The firing of sewage sludge in the incinerator shall not cause a violation of the specific
mercury emission rate that has been established for the incinerator by [specific cite to an
air permit or state implementation plan specific provision in a regulation establishing the
specific emission rate]. The specific emission rate, established by [cite again], is
provided below:
3200 g of mercury/24-hr period.
7.5 OPERATIONAL STANDARDS
Subpart E does not contain numerical standards for specific toxic organic compounds in sewage sludge
or in the exit gases from sewage sludge incinerators. However, in order to protect human health and the
environment from excessive emissions of organic pollutants when sewage sludge is incinerated, the
regulation provides an operational standard for total hydrocarbons (THC). This operational standard
applies to all sewage sludge incinerators that are covered under Part 503. The following guidance
provides the necessary information and direction to incorporate this operational standard into the permit.
Statement of Regulations
§503.44(a) The total hydrocarbons concentration in the exit gas from a sewage sludge incinerator shall be
corrected for zero percent moisture by multiplying the measured total hydrocarbons
concentration by the correction factor calculated using equation (7).
Correction factor (percent moisture) = TjTx) Eq. (7)
Where:
X = Decimal fraction of the percent moisture in the sewage sludge incinerator exit gas in
hundredths.
Draft-March 1993 7-28
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• 7. INCINERATION - PART 503 SUBPART E
gJ03i.4S^b) Tfes total hydrocarbons concentration ia the exit gas from a sewage sludge incinerator shall b*
iwwfiriBEted to seven percent oxygen by multiplying the measured total hydrocarbons concentration
fey t&e correction factor calculated using Equation (8). •
Correction factor (oxygen) = i\t f yv Eq. (8)
¥ * Percent oxygen concentration ia the sewage sludge incinerator stock exit gas (dry
^ votuwe/dliry volume). ' ^
1 ' ' <*'
(c) Tfee monthly overage concentration for total hydrocarbons in the exit gas from a sewage sludge
, corrected for zero percent mto&ture using the correction factor from equation
to Severn percent oxygen using the comn&tbn factor from equation (8), shall not exceed
parts per million on a volumetric basis when measured using the instrument required by
7.5.1 TOTAL HYDROCARBON CONCENTRATION (TEC)
THC is a measure of the carbon-carbon (C-C) or carbon-hydrogen (C-H) bonds of the organic material
present in the exhaust gas of an incinerator. THC provides an indirect measurement of the total organic
pollutants in the exit gases of an incinerator. Therefore, limiting the THC levels in the exhaust gas of
an incinerator provides an indirect control over the total quantities, of organic pollutants released from
that incinerator. Part 503 provides a numerical limitation for THC in the stack emissions to ensure that
excessive amounts of organic pollutants are not released into the atmosphere. This limitation is a
technology-based operational standard based on operating data from a study of four sewage sludge
incinerators (EPA 1992a).
The corrected THC level in the exhaust gases must not exceed a monthly average of 100 parts per million
on a volumetric basis. This operational standard requires that the THC concentration in the stack exit
gas be measured continuously and corrected to 7 percent oxygen (from 21 percent oxygen in air) and 0
percent moisture using an equation provided in the regulation. The THC concentration is corrected to 7
percent oxygen in order to account for the excess air used in the combustion of sewage sludge.
Excess air refers to the amount of air that is present in the combustion chamber of the incinerator in
excess of the minimum amount required for the combustion process to take place. The presence of excess
air in the combustion chamber enhances the combustion process and provides a safety measure against
variations in the system, such as changes in sewage sludge feed rate and sewage sludge moisture content,
that could lead to incomplete combustion of the organic matter. In addition, a sewage sludge incinerator
operated with very little excess air could easily exceed the operational standard of 100 ppm THC. On
the other hand, facilities could lower the THC concentration without reducing the actual emission rate
simply by adding higher rates of air to the incinerator. High excess air rates "dilute" the THC
concentration detected by the flame ionization detector (FID). This could allow an incinerator to appear
to be meeting the THC standard, when the actual THC emissions are in excess of those set by the
regulations taking dilution into account (EPA 1989, 1992b).
The presence of moisture in the exit gas can dilute the THC measurement and create artificially low
readings. Since most sewage sludges contain substantial amounts of water, the exit gas contains moisture
Draft—Mai-ell 1993 7-29
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7. INCINERATION - PART 503 SUBPART E
and the THC must be corrected for this moisture content. Conventionally, the THC is measured in terms
of dry-volumetric basis (0 percent moisture) and therefore correction for moisture is based on 0 percent
moisture content. The THC concentration in the exit gas must be corrected for 0 percent moisture by
multiplying the measured THC concentration by the following correction factor:
Correction factor (percent moisture) = TTT~XI
Where:
X = decimal fraction of the percent moisture in the exit gas in hundredths.
Further correction of the measured THC concentration to 7 percent oxygen must be performed by
multiplying the measured THC concentration by a dimensionless correction factor specified in the
regulation [§503.44(b)]. That correction factor is as follows:
14
Correction factor (oxygen) = .
Where:
Y = percent oxygen concentration in the exit gas (dry volume/dry volume).
For example, if the measured THC is 30 ppm, the measured oxygen content is 9 percent, and the
measured moisture content is 30 percent, the THC value corrected to 7 percent moisture and no oxygen
is calculated as the following:
THC (dry, 7 percent oxygen) = 30 ppm x 14
(100 - 30)/100 (21 -9)
42.9 ppm x 1.1667
= 50 ppm
The monthly average THC limit of 100 ppm is based on continuous measurements while sewage sludge
is being incinerated. Thus, the regulation requires installation of instruments for continuous monitoring
of THC, oxygen, and moisture in the exit gas of any sewage sludge incinerator (detailed discussion of
these continuous monitoring requirements are provided in Section 7.6 of this chapter).
The permit should clarify that the THC standard is based on continuous measurement with the specified
instrumentation, oxygen concentration, and moisture content in the sewage sludge incinerator stack exit
gas (see Section 7.6 for the monitoring instruments required). Furthermore, the permit writer should
include in the permit the specific equations that must be used to correct for excess air and moisture
content. The permit should also specify that the limit of 100 ppm must be on a volumetric basis and that
hourly averages of THC measurements after correction to 7 percent oxygen and 0 percent moisture should
be recorded continuously. The raw monitoring data used to derive the values of corrected, dry THC
should also be collected, maintained, and made available to the permitting authority upon request. The
incinerator operator should also be required to document incidents when THC (corrected) exceeds 100
ppm. To implement this requirement, the operator should document the following:
Draft-March 1993 7-30
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7. INCINERATION - PART 503 SUBPART E
° Each time (1-minute averages) the total corrected THC concentration exceeded 100 ppm
o The number of minutes each incident lasted
° A description of the circumstances surrounding each incident, identifying the cause of each
incident and, if unavoidable, explaining why the incident was unavoidable.
7.6 MANAGEMENT PRACTICES
Part 503 contains several management practices related to the firing of sewage sludge in a sewage sludge
incinerator. These management practices require that certain instruments be installed, calibrated,
operated, and maintained for each sewage sludge incinerator. They also require that standards be
established for incinerator combustion temperature and air pollution control device operating parameters,
based on those values obtained during performance testing. The following technical guidance provides
a more detailed discussion of the purpose and need of such instrumentation. These management practices
apply to all sewage sludge incinerators covered under Part 503.
7.6.1 TOTAL HYDROCARBONS MONITOR
Statement off Eegulatiomis
§503.4S5(a)(l) An instrument that measures and records the total hydrocarbons concentration in the sewage
sludge incinerator stack exit gas continuously shall be installed, calibrated, operated, and
maintained for each sewage sludge incinerator, as specified by the permitting authority.
(2) The total hydrocarbons instrument shall employ a flame bnizatton detector; shall have a heated
sampling line maintained at & temperature of 1150 degrees Celsius or higher at all times; and
shall b* calibrated at least once every 24-hour operating perbd using propane.
Part 503 requires installation of an instrument that continuously measures and records the total
hydrocarbons concentration in the sewage sludge incinerator stack exit gas. This instrument must have
a flame ionization detector and a heated sampling line which can maintain a temperature of 150°C or
higher at all times. The flame ionization detector (FID) measures hydrocarbon emissions in the stack of
an incinerator. The instrument reports the stack monitoring results as a concentration of hydrocarbons
(in parts per million of THC by volume). The FID is a hydrogen-oxygen flame into which a small
sample of incinerator exhaust gases is introduced. The flame burns any gases present in the sample. If
the detector has little or nothing to burn (the sampled gas contains.less than 10 ppm THC), the incinerator
has destroyed the organisms adequately. A high level (greater than 10 ppm) indicates that the incinerator
is operating inefficiently.
The Part 503 regulation also requires that this instrument be calibrated at least once every 24-hour period
using propane gas. When carbon-carbon (C-C) or carbon-hydrogen (C-H) bonds are broken and oxidized
in the flame, an ion is released and an electrical detector senses the release of the ion. Thus, the number
of C-C and C-H bonds being oxidized in the flame can be measured directly by the strength of the
electrical signal produced. The direct readout of this electrical signal can be calibrated to indicate the
concentration of hydrocarbons in the sample stream. Calibration is achieved by periodically introducing
a series of calibration gases of known hydrocarbon concentration into the sample flame and marking or
adjusting the readout to the actual concentration of calibration gases. EPA has selected propane as the
Draft-March 1993 7-31
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7. INCINERATION - PART 503 SUBPART E
reference gas for calibration of THC instruments. The Agency also believes that 24 hours is the
maximum amount of time that this type of instrument can maintain its accuracy without calibration.
In addition to daily calibration, other issues related to THC monitor installation and performance need
to be addressed by permit writers. In order to ensure that the THC .standard can be enforced
continuously, the permit writer needs to establish specific criteria for judging whether THC continuous
emission monitor (CEM) data are accurate. Section 7.7 of this document presents a more detailed
discussion of these criteria. A permit writer, however, will need to specify these criteria and acceptable
mechanisms that operators can use to achieve them as permit conditions. Because of the potential
complexity in outlining CEM performance criteria and test procedures, the permit writer may want to
refer to a separate document containing these items for all CEM systems. An example of suggested
permit condition language is presented below.
An instrument that continuously measures and records the total hydrocarbon concentration
in the exit gas of each sewage sludge incinerator shall be installed, calibrated, operated,
and maintained by the incinerator operator. This instrument shall use a heated sample
line maintained at 150°C or higher at all times of instrument operation. The instrument
shall be installed, certified, calibrated, and maintained in accordance with the attached
specifications and procedures.
7.6.2 OXYGEN MONITOR
Statement of Regulations
< §S03.45(b) An instrument that measures and records the oxygen concentration in the sewage sludge
incinerator stack exit gas continuously shall be installed, calibrated, operated, and maintained
for each sewage sludge incinerator, as specified by the permitting authority.
Part 503 requires installation of an instrument that continuously measures and records the oxygen
concentration in the sewage sludge incinerator stack exit gas. As discussed in Section 7.5, this
management practice is needed to obtain information to correct the THC concentration to 7 percent
oxygen.
Oxygen CEMs use one of several possible analytical techniques and sampling mechanisms to measure
oxygen concentrations. Oxygen CEMs can be either in situ or extractive. In situ monitors are in direct
contact with the gas stream and measure the oxygen concentration at that specific location. Extractive
monitors use a sampling system that continuously withdraws gas samples from the gas stream and directs
it to an analyzer that may be up to several hundred feet away. Extractive systems are almost always
Draft-March 1993 7-32
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7. INCINERATION - PART 503 SUBPART E
equipped with sample conditioning systems that remove dust and moisture from the gas stream. The most
important difference to note is that in situ monitors measure oxygen on a wet basis and extractive
monitors generally measure oxygen on a dry basis. This difference is important since an oxygen
concentration on a wet basis can differ significantly from one measured on a dry basis, depending on the
moisture content of the gas sample. Both, wet and dry oxygen CEM measurements can be used to
calculate stack gas moisture content continuously.
Three types of analytical techniques are generally used with oxygen CEMs. These techniques include
electrocatalytic, polarographic, and paramagnetic. Detailed descriptions of each type of analyzer can be
found in EPA's Handbook of Continuous Air Pollution Source Monitoring Systems (June 1979). As with
the THC CEM, permit writers need to specify performance criteria and test procedures to ensure accurate
data that can be used to enforce the THC standard. Language similar to the example presented for the
THC monitor can be us.ed to set permit conditions requiring continuous oxygen monitoring. The permit
writer can refer to the CEM specification established in Appendix B of 40 CFR Part 60, Subpart O for
continuous oxygen monitors for sewage sludge incinerators.
7.6.3 MOISTURE CONTENT
Statement of Regulations
§503.4S(e) An instrument that measures and records information used to determine the moisture content
in the sewage sludge incinerator stack exit gas continuously shall be installed, calibrated,
operated, and maintained for each sewage sludge incinerator, as specified by the permitting
, authority. I. ' . .
Part 503 requires installation of an instrument that continuously measures and records information that
can be used to determine the moisture content in the sewage sludge incinerator stack exit gas. As
discussed in Section 7.5, this information is necessary to correct the THC concentration to 0 percent
moisture. As mentioned earlier, one method used to measure the moisture content of a stack gas sample
is to measure wet and dry oxygen concentrations simultaneously and calculate moisture content from the
differences in these measurements. Other proprietary monitors that measure stack gas moisture content
directly are also available. Since moisture content is essential to the calculation of THC, the instruments
used to measure moisture content need to meet performance specifications as described for THC and
oxygen monitors.
7.6.4 COMBUSTION TEMPERATURE
Statement of Regulations
§503.45(d) An instrument that measures and records combustion temperatures continuously shall be
installed, calibrated, operated and maintained for each sewage sludge incinerator, as specified
by the permitting authority.
§S03.45(e) The maximum combustion temperature for a sewage sludge incinerator shall be specified by the
permitting authority and shall be based on information obtained during the performance test of
the sewage sludge incinerator to determine pollutant control efficiencies. '/>.
Draft-March 1993 7-33
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7. INCINERATION - PART 503 SUBPART E
Part 503 requires the installation, maintenance, operation and calibration of a device that continuously
measures and records incinerator combustion temperatures. The regulations also require that the
maximum combustion temperature be established for each incinerator based on information obtained
during the control efficiency performance test of the incinerator. Combustion temperature can affect both
organic and inorganic emissions. Low combustion temperatures can result in poor combustion of sewage
sludge and increased organic emission rates. High combustion temperatures can increase the volatilization
of metals in the sewage sludge being incinerated and the potential for higher metal emission rates. High
combustion temperatures can also result in high flue gas temperatures that could possibly damage air
pollution control devices.
Since EPA's THC standard regulates emissions of organic compounds, the establishment of a minimum
combustion temperature was not needed. By relating the combustion temperature limit to the temperature
observed during performance testing, the potential rate of metals volatilization is theoretically maintained
at the same level achieved during the performance test. This condition, therefore, limits the metals
loading applied to the incinerator's air pollution control device.
Combustion temperatures are typically measured using thermocouples. They offer a relatively
inexpensive, reliable and accurate means of measuring fairly high temperatures. Thermocouples are
almost always enclosed in a thermowell which protects the thermocouple from the hostile environment
of the incinerator combustion areas. Because of the potential for frequent damage, thermocouples are
located downstream of the combustion zone near the exit of the combustion chamber. Thermowells that
extend away from the incinerator wall improve the accuracy and response of the thermocouple, but are
subject to slag buildup or abrasion (EPA 1990a). Periodic inspection and replacement of thermocouples
is recommended; periodic calibration of thermocouples that are in place is impractical. If possible, the
use of two thermocouples in separate wells is recommended to provide a cross-check of the operation of
each thermocouple.
7.6.5 AIR POLLUTION CONTROL DEVICE OPERATING PARAMETERS
Statement of Regulations
§503.45(0 The values for the operating parameters for the sewage sludge incinerator air pollution control
device shall be specified by the permitting authority and shall be based on information obtained
during the performance test of the sewage sludge incinerator to determine pollutant control
efficiencies.
Part 503 requires the permitting authority to establish values for the operating parameters of an
incinerator's air pollution control device (APCD) based on information obtained during the incinerator's
performance test. By recording key APCD operating parameters during control efficiency performance
testing, one can establish baseline values for these parameters at known control efficiencies. By operating
the incinerator and its control equipment at these baseline values in the future, the control efficiencies can
be expected to remain relatively unchanged from performance test values. By continuously monitoring
these operating parameters, incinerator operators have, at least theoretically, an indirect means of
monitoring pollutant control efficiencies.
Because specific permit conditions will be established for operating parameter values based on
performance testing, care must be taken so that the test program is conducted at capacity conditions.
Draft-March 1993 7-34
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7. INCINERATION - PART 503 SUBPART E
Conducting performance testing in this manner can help to assure that future operations will not be
restricted by conditions based on testing conducted at lower than design capacities.
Since each incinerator and APCD combination is site-specific, APCD operating parameter values will also
be site-specific. Table 7-2 presents several APCD operating parameters that can be indicators of
performance. Section 7.7 of this chapter discusses the establishment of incinerator and APCD operating
parameters in permit conditions in greater detail.
7.6.6 ENDANGERED SPECIES ACT
Statement of Regulations
§S03.4S(g) Sewage sludge shall not be Tired in a sewage sludge incinerator if it is likely to adversely affect
a threatened or endangered species listed under Section 4 of the Endangered Species Act or its
designated critical habitat.
The sewage sludge pollutant limits established according to the procedures in Subpart E of the Part 503
regulations may not be protective of threatened or endangered species or their critical habitats. Additional
management practices that would prevent likely adverse effects on these species or habitats may need to
be developed on a site-specific basis. First, the permit writer will need to determine whether there are
any endangered species or their critical habitats present in the areas affected by the air emissions from
the sewage sludge incinerator. In general, this determination should be done by the owner /operator.
Results of the air dispersion modeling conducted by the owner/operator will help in delineating the area
of impact.
This management practice is not of concern if no endangered species or critical habitats are present.
However, the permit writer may want to include this management practice in the permit as it appears in
Part 503.
If threatened or endangered species or their designed critical habitats are present, the permit writer will
need to determine whether the firing of sewage sludge will be likely to cause an adverse effect upon the
species or their habitats. Again, this determination may need to be done by the owner/operator. An
assessment of potential adverse impacts may be expensive and the causal link between the air emissions
from the sewage sludge incinerator and the degree of impact to the species or habitat may be difficult to
substantiate. The field office of the U.S. Department of Interior, Fish and Wildlife Service (FWS) may
have information on any studies of the area's threatened and endangered species or critical habitats. If
there is any available information indicating potential adverse impacts due to the firing of sewage sludge,
then a site-specific assessment may be needed. The permit writer should document in the fact sheet the
presence of threatened or endangered species or their critical habitats and any information indicating
adverse impacts. The permit writer should include a permit condition that incorporates the management
practice that firing of sewage sludge shall not cause adverse effects upon the species or habitats present
in the area.
If adverse effects are likely, the permit writer will need to follow EPA policies or use best professional
judgement in constructing site-specific management practices to prevent these likely adverse impacts. It
will be necessary for the permit writer to work with the owner/operator in identifying these specific
management practices.
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7. INCINERATION - PART 503 SUBPART E
TABLE 7-2 PERFORMANCE INDICATOR PARAMETERS FOR AIR POLLUTION
CONTROL DEVICES
APCD
Parameters
Example Measuring Devices
Venturi scrubber
Pressure drop
Liquid flow rate
Differential pressure (AP)
gauge/transmitter
Orifice plate with AP
gauge/transmitter
Gas temperature (inlet and/or
outlet)
Gas flow rate
Thermocouple/transmitter
Annubar or induced (ID) fan
parameters
Impingement scrubber
Pressure drop
Liquid flow rate
Gas temperature (inlet and/or
outlet)
Gas flow rate
AP gauge/transmitter
Orifice plate with AP
gauge/transmitter
Thermocouple/transmitter
Annubar or ID fan parameters
Mist eliminator (types include a
wet cyclone, vane demister,
chevron demister, mesh pad, etc.)
Pressure drop
Liquid flow
Differential pressure
gauge/transmitter
Orifice plate with AP
gauge/transmitter
Dry scrubber (spray dryer
absorber)
Liquid/reagent flow rate to
atomizer
pH of liquid/reagent to atomizer
For rotary atomizer: Atomizer
motor power
For dual fluid flow: Compressed
air pressure
Compressed airflow rate
Gas temperature (inlet and/or
outlet)
Magnetic flowmeter
pH meter/transmitter
Wattmeter
Pressure gauge
Orifice plate with AP
gauge/transmitter
Thermocouple/transmitter
Fabric filter
Pressure drop (for each
compartment)
Broken bags
Opacity
Gas temperature (inlet and/or
outlet)
Gas flow rate
AP gauges/transmitters
Proprietary monitors
Transmissometer
Thermocouple(s)
Annubar or ID fan parameters
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7. INCINERATION - PART 503 SUBPART E
TABLE 7-2 PERFORMANCE INDICATOR PARAMETERS FOR AIR POLLUTION
CONTROL DEVICES (Continued)
APCD
Wet electrostatic precipitator
Parameters
Secondary voltage (for each
transformer/rectifier)
Secondary currents (for each
transformer/rectifier)
Liquid flow(s) (for separate
liquid feeds)
Gas temperature (inlet and/or
outlet)
Gas flow rate
Example Measuring Devices
Kilovolt meters/transmitter
Milliammeters/transmitter
Orifice plate(s) with AP
gauge/transmitter
Thermocouple(s)
Annubar or ID fan parameters
Source: EPA 1990a
7.7 MONITORING REQUIREMENTS
The monitoring requirements presented in §503.46 apply to any sewage sludge incinerator, to sewage
sludge fired in a sewage sludge incinerator, to any person who fires sewage sludge in a sewage sludge
incinerator, and to the exit gas from a sewage sludge incinerator while sewage sludge is being fired.
Although not specified in §503.46, monitoring requirements applicable to sewage sludge incinerators
through other regulations are important to note since they are likely to be implemented using a single
permit.
• The monitoring requirements of the National Emission Standard for Beryllium of 40 CFR
Part 61, Subpart C apply to any incinerator that processes beryllium containing waste.
• The monitoring requirements of the National Emission Standard for Mercury of 40 CFR Part 61,
Subpart E apply to any sewage sludge incinerators.
The monitoring requirements applicable to sewage sludge incinerators can be divided into the following
three categories, each to be discussed individually in greater detail:
• Sewage sludge information.
• Stack gas information.
• Incinerator and air pollution control device information.
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7. INCINERATION - PART 503 SUBPART E
7.7.1 SEWAGE SLUDGE MONITORING
Statement of Regulations
§503.46(a) Sewage sludge
§503.46(a)(l) The frequency of monitoring for beryllium and mercury shall be specified by the permitting
authority.
(2) The frequency of monitoring for arsenic, cadmium, chromium, lead, and nickel in sewage sludge
fed to a sewage sludge incinerator shall be the frequency in Table 1 of §503.46;
Section 503.46 requires that incinerated sewage sludge be monitored for arsenic, cadmium, chromium,
lead, and nickel at the frequencies presented in Table 1 of §503.46. The frequency of monitoring for
these pollutants depends on the amount of sewage sludge fired in an incinerator in a 365-day period.
TABLE 1 OF 503.46 - FREQUENCY OF MONITORING - INCINERATION
Amount of Sewage Sludge*
(metric tons per 365 dav period) Frequency
Greater than zero but .once per year
less than 290
Equal to or greater than once per quarter
290 but less than 1,500 (4 times per year)
Equal to or greater than once per 60 days
1,500 but less than 15,000 (6 times per year)
Equal to or greater than once per month ;,
15,000 (12 times per year)
* Amount of sewage sludge fired in a sewage sludge incinerator (dry weight basis). •
§503.46(a)(3) After the sewage sludge has been monitored for two years at the frequency in Table 1 of §503.46,
the permitting authority may reduce the frequency of monitoring for arsenic, cadmium,
, chromium, lead, and nickel, but in no case shall the frequency of monitoring be less than once per
year when sewage sludge is fired in a sewage sludge incinerator.
The regulations allow the permitting authority to modify the frequency of sewage sludge monitoring after
sewage sludge has been monitored at the frequencies in Table 1 of §503.46 for two years. Under no
circumstances can sewage sludge fired to a sewage sludge incinerator be monitored less than once per
year. Some important factors that a permit writer should consider in establishing permit conditions for
sewage sludge monitoring frequencies include:
• History of compliance with the pollutant limits
• Variability of pollutant concentrations in the sewage sludge
• Trends in pollutant concentrations in the sewage sludge
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7. INCINERATION - PART 503 SUBPART E
• Magnitude of typical pollutant concentrations
• Magnitude of the pollutant limits.
Permit writers may also wish to specify either by permit or by referencing appropriate guidance
documents how sewage sludge monitoring is to be conducted. Specifically:
• Sewage Sludge Sampling Methods — Discussions should include the entity responsible for
sampling; sample splitting; equipment to be used; sample techniques, locations, times, amounts,
and types (grab or composite); sample handling and preservation; sampling records to be kept;
and conditions when sampling should occur.
• Analytical Methods — Discussions should include the numbers of analyses, acceptable techniques,
quality assurance and quality control procedures, analytical records to be kept, and calculations
to be made.
Grab — A single grab sample can be a representative sample if every part of the sewage sludge has an
equal chance to be sampled and the sewage sludge is fairly homogenous in pollutants and solids content.
Since the sample collection point is fixed and cannot be randomly selected, the time at which a sample
is collected should be randomly chosen. For example, a number from 1 to 24 can be randomly selected
to determine the time at which a grab sample should be collected from an incinerator sewage sludge feed
line during a 24-hour continuous operation period.
Composite — Another method of obtaining a representative sample is to collect single grab samples at
predetermined intervals during a continuous operation period and combine them into a single composite
sample. A composite sample is more representative of the sewage sludge than a single grab sample.
Since the sewage sludge feed rate can effect incinerator emissions and the air pollution control device,
a permit writer should consider establishing an enforceable sewage sludge feed rate permit condition. The
establishment of a sewage sludge feed rate condition can be particularly important to confirming
compliance with the beryllium and mercury emission standards of Part 61, Subparts C and E. Since both
of these standards are expressed as grams per day, an increase in the sewage sludge feed rate could result
in higher beryllium and mercury emission rates, assuming constant pollutant control efficiencies. In fact,
both regulations require that "No changes in the operation shall be made, which would potentially
increase emissions above that determined by the most recent source test, until a new emission level has
been estimated by calculation and the results reported to the Administrator." Refer to Section 7.8.4 for
further discussion of sewage sludge feed rates.
When establishing a permit condition for sewage sludge feed rates to an incinerator, several factors that
can affect enforceability need to be addressed. These factors include:
• Sewage sludge feed rate averaging time(s) that correspond with the permit condition(s) need to
be established.
• Data reduction requirements should be specified. How are 1-hour, daily, and 365-day averages
calculated?
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7. INCINERATION - PART 503 SUBPART E
• The sewage sludge feed rate should be expressed on a dry basis. Sewage sludge moisture content
determination frequencies should be specified.
• The operating range and resolution of the sewage sludge feed rate monitor should be specified.
• Under §60.153, sewage sludge feed rate monitors are to be certified by the manufacturer to have
an accuracy of at least 5 percent over the monitor's operating range.
• Calibration and other QA/QC procedures should be specified. These procedures should also
outline criteria used to judge when the data from the sewage sludge feed rate monitor is not
acceptable. The procedures should indicate acceptable downtime of sewage sludge feed rate
monitors, if any.
7.7.2 STACK GAS MONITORING
Statement of Regulations
§503.46(b) Total hydrocarbons, oxygen concentration, information to determine moisture content, and.
combustion temperatures.
The total hydrocarbons concentration and oxygen concentration in the exit gas from a sewage
sludge incinerator stack, the information used to measure moisture content in the exit gas, and
the combustion temperatures for the sewage sludge incinerator shall be monitored continuously.
Section 503.46 requires that the exit stack gas from a sewage sludge incinerator be monitored
continuously for total hydrocarbons, oxygen, and moisture concentrations. Section 60.153 requires the
use of an oxygen continuous emissions monitor (CEM). The primary purpose of the CEM is to provide
data to verify an incinerator's compliance with the operational standard of §503.44. In order to ensure
that the data supplied by a sewage sludge incinerator operator can be used to enforce the operational
standard, the permit writer should address several important issues either in each permit or in a separate
document. These issues include the following:
• CEM quality assurance and quality control procedures should be required and the criteria used
to judge these procedures should be specified. Besides the daily calibration and maintenance
requirements of §503.45, quarterly calibration error checks and annual relative accuracy tests of
the CEMs are recommended. Written calibration, testing, and maintenance procedures for CEMs
should also be required from incinerator operators.
• CEMs should be required to meet certain performance specifications. These performance
specifications should establish the criteria used to judge the acceptability of the CEMs at the time
of installation. Important elements of performance specifications include performance test
procedures (calibration drift and relative accuracy), monitor range and resolution, calibration gas
requirements, response time, and conditioning and operational test period requirements.
• Data availability requirements should be required and defined. Is CEM data required 100 percent
of the time? Is monitor downtime allowed for monitor calibration, maintenance, and
malfunctions? If so, how much and how frequently?
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7. INCINERATION - PART 503 SUBPART E
• Data reduction and averaging procedures and calculations should be detailed. Specific procedures
for the calculation of THC exceedance incidents, for the percentage of THC exceedance time and
for correction of total hydrocarbons for oxygen and moisture should be defined. Permit writers
should also consider specifying CEM data acquisition system requirements (simple strip charts
or more sophisticated computer-based systems). Permit writers should also specify how CEM
data should be stored (1-minute or 1-hour averages, or both) and how the data is made available
to the Permitting Authority. Recent air quality permits and regulations require some air pollution
sources to provide or make available CEM data to regulatory agencies using computer data
telemetry systems.
• Acceptable locations of CEM sample points and calibration gas injection points should be
specified. The chief consideration in CEM sample point location is that the measurement obtained
is representative of incinerator exit gases. The CEM sampling point should be located such that
the potential for gas stratification and air in-leakage are minimized and that manual stack
sampling and maintenance accessibility is provided. The quality and concentrations of calibration
gases also need to be specified.
• The criteria should be defined for judging the validity of CEM data and determining when
corrective actions need to be taken.
Permit writers may wish to refer to the CEM performance specifications and test procedures located at
Part 60, Appendix B, the CEM quality assurance procedures located at Part 60, Appendix F, and the
CEM performance specifications outlined in Methods Manual for Compliance with the BIF Regulations
or in Appendix 9 of Part 266. Appendix B of Part 60 presents specifications and test procedures for
sulfur dioxide, nitrogen oxide(s), oxygen, carbon dioxide, carbon monoxide, total reduced sulfur,
hydrogen sulfide, and flow rate. Appendix F of Part 60 presents procedures used to evaluate the
effectiveness of QA/QC procedures and the quality of data produced by any CEM system that is used to
determine compliance with emission standards specified in applicable regulations. Methods Manual for
Compliance with the BIF Regulations and Appendix 9 of Part 266 present performance specifications, test
methods, and quality assurance procedures for oxygen, carbon monoxide, and hydrocarbon CEMs used
at incinerators, boilers, and industrial furnaces that burn hazardous waste. Although not specific to the
sewage sludge incinerator regulations, this material can provide information that may be applicable to
sewage sludge incinerator CEM requirements.
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7. INCINERATION - PART 503 SUBPART E
7.7.3 INCINERATOR AND AIR POLLUTION CONTROL DEVICE MONITORING
Statement of Regulations
§S03.46(b) Total hydrocarbons, oxygen concentration, information to determine moisture content,; and;
combustion temperatures.
The total hydrocarbons concentration and oxygen concentration in the exit gas from a sewage-
sludge incinerator stack, the information used to measure moisture content in the exit gas, and
the combustion temperatures for the sewage sludge incinerator shall be monitored continuously.
§503.46(e) Air pollution control device operating parameters. •
The frequency of monitoring for the sewage sludge incinerator air pollution control device
operating parameters shall be specified by the permitting authority.
The requirements at §503.46 require the incinerator combustion temperature to be monitored
continuously. Air pollution control device operating parameters are to be specified by the permitting
authority. The values of these parameters should be consistent with the values observed during the
performance test to determine pollutant control efficiencies.
The regulations at Part 61, Subparts C and E do not specify operating parameters to be monitored. They
do require that no change in the operation be made which would potentially increase beryllium or
mercury emission rates above those estimated by the most recent stack test, until new emission rates are
calculated and the results are reported to the Administrator. To satisfy this requirement, operating
parameters that impact beryllium and mercury emission rates should be established and monitored.
These regulations provide permit writers with flexibility in establishing permit conditions for incinerator
and APCD operating parameters. This flexibility is necessary so that appropriate conditions can be
applied, based on incinerator and APCD designs and operating procedures; it also burdens the permit
writer with the responsibility of identifying important operating parameters and establishing limits for
them. When writing permits, the permit writer should consider the following:
• Specific averaging times ensure enforceability
• Ranges allow for some operational flexibility. "Never to exceed" conditions should be carefully
considered and be clearly stated as such in the permit
• Limits must be tied to the values of the operating parameters observed during any performance
tests. It is important to understand that the conditions that exist during a performance test can
restrict the future operations of the incinerator and its APCD.
Some key parameters for which permit writers should consider establishing permit conditions include:
• Auxiliary fuel type and feed rates — in some cases, an increase in auxiliary fuel(s) feed rate may
increase pollutant emission rates. Permit writers should consider limiting the type(s) and feed
rates of auxiliary fuels.
Draft—March 1993 7-42
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7. INCINERATION - PART 503 SUBPART E
• Incinerator combustion temperature — low combustion temperatures for even short time periods
can result in poor combustion efficiencies, and short-term increases in organic and odor-causing
emissions. Higher combustion temperatures can result in increased metals volatilization and
metals loading on the APCD. Because it may be difficult to reliably measure the combustion
zone temperature in many incinerators, another sampling location within or near the combustion
chamber can be used as an indicator of combustion zone temperature. The location should be
away from any quench water or air injection points.
• Temperature of flue gas entering the APCD — increased temperature at the inlet to the APCD
increases the volatility of metals that may be present. Metals that remain in the vapor form in the
APCD will be less efficiently captured.
• Flue gas flow rate — higher flue gas flow rates can result in higher pollutant emission rates. A
gas flow rate condition should specify temperature, pressure, and moisture content.
• Scrubber liquid to gas ratio — particulate matter and metal removals decrease with reduced
scrubber liquid to gas ratio.
• Scrubber liquid solids content — higher solids or metals contents can result in increasing amounts
of particulate and metals re-entrainment in the scrubber exhaust.
• Scrubber liquid pH — metals removals may be affected by scrubber liquid pH.
• Venturi scrubber pressure drop — particulate and metals removals decrease with reduced pressure
drop.
• Fabric filter pressure drop — a low pressure drop can be indicative of torn or missing filters that
can lead to increased particulate and metals emissions. A high pressure drop can be indicative
of plugged or "blinded" filters that could potentially fail.
• Electrical power applied to an electrostatic precipitator or ionizing wet scrubber — reduced
electrical power or the number of fields in operation decreases the rate of particle charging thus
decreasing collection efficiencies. The unit of power applied and where the applied power is
measured should also be specified.
Permit writers should also remember that sewage sludge incinerators and their control equipment are
complex systems and that many of the parameters outlined earlier are related. Permit writers should be
aware of operating parameters and potential permit conditions that may conflict. Conflict may also occur
when parameters used to gauge compliance cannot be simultaneously operated at their worst-case
conditions. One example might be incinerator combustion temperature conditions established to maximize
organic destruction and to minimize metal volatilization. Permit writers should also be alert to parameter
limits that could violate permit conditions for reasons that may not be related to emissions. For example,
a low APCD pressure drop may result from reduced air flow rate or lower sewage sludge charging rates
and not from APCD problems.
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7. INCINERATION - PART 503 SUBPART E
7.8 RECORD KEEPING REQUIREMENTS
The permit should contain requirements for maintaining records that demonstrate compliance with the
operational standard, pollutant limits, and management practices. Specific records that must be
maintained by the person who fires sewage sludge in a sewage sludge incinerator are listed in §503.47.
In general, the record keeping requirements in §503.47 pertain to the monitoring requirements in
§503.46. Thirteen types of records are required to be developed and retained for at least five years by
any person who fires sewage sludge in a sewage sludge incinerator. These records, however, will be
largely based on other pieces of information and documents such as air disposion models, testing
procedures, calculations, and incinerator design and operating manuals. Without this documentation, the
incinerator operator will not be able to support reports made to the permitting authority. Similarly, the
permitting authority will not have enough information to make complete evaluations of compliance or to
judge the adequacy of the information used to show compliance.
Since the Part 503 rule does not detail documentation requirements, the permit writer needs to be specific
enough so that incinerator owner/operator knows what is expected. Depending on the specific
requirement, the permit writer may require documentation to be submitted in the permit application,
during the review of the application, and after the permit has been issued (as an ongoing permit
condition). Some of the record-keeping requirements in §503.47 are very specific and some must be
developed by the permit writer based on site-specific conditions. This document provides general
recommendations for record keeping and documentation. The permit writer will need to develop site
specific requirements. The record keeping requirements and recommended documentation to be discussed
in this section has been divided into the following four categories, each to be discussed individually in
greater detail:
t
• Incinerator information
• Dispersion modeling
• Stack gas data
• Sewage sludge monitoring information.
7.8.1 INCINERATOR INFORMATION
Statement of Regulations
§503.47(a) The person who fires sewage sludge in a sewage sludge incinerator shall develop the information
in §503.47(b) through §503.47(n) and shall retain that information for five years.
§503.47(g) Values for the air pollution control device operating parameters.
Detailed information about each sewage sludge incinerator and its air pollution control device is necessary
in order to establish proper sewage sludge pollutant limits and sewage sludge monitoring frequencies.
This information should include:
• The number of sewage sludge incinerators.
Draft-March 1993 7-44
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7. INCINERATION - PART 503 SUBPART E
• The type of each sewage sludge incinerator (e.g., multiple hearth or fluidized bed).
• The design and typical operating capacities of each incinerator in dry pounds of sewage sludge
fired per hour.
• The operating schedule for each incinerator.
• The type and firing rate of auxiliary fuel(s).
• The type of air pollution control device used for each sewage sludge incinerator. Permit writers
may also request specific design and operating parameters for the air pollution control system in
order to evaluate the adequacy of emissions control.
Certain incinerator exhaust stack parameters also need to be determined and documented so that a
dispersion factor can be obtained. Important stack parameters to document are:
• Stack height (the distance from ground level to the top of the stack discharge point).
• Stack diameter (if round) or stack opening length and width (if rectangular or square).
• Stack gas discharge velocity at or near the top of the stack.
• Stack gas discharge temperature at or near the top of the stack.
Since this information is unlikely to change very often, if at all, it would be appropriate for this general
information to be submitted as part of the permit application. The permit writer should include a permit
condition requiring the owner/operator to notify the permitting authority of any changes in the
information submitted in the application as soon as the owner/operator is aware of the change (preferably
before the change occurs).
7.8.2 DISPERSION MODELING
Statement of Regulations
§503.47(a) The person who Tires sewage sludge in a sewage sludge incinerator shall develop the information
in §503.47(b) through §503.47(n) and shall retain that information for five years.
§503.47(j) The stack height for the sewage sludge incinerator;
§503.47(k) The dispersion factor for the site where the sewage sludge incinerator is located.
Part 503 requires the use of a Dispersion Factor (DF) to calculate limits of lead, arsenic, cadmium,
chromium, and nickel in sewage sludge fed to a sewage sludge incinerator. Since the pollutants subject
to dispersion modeling requirements can be assumed to behave similarly (all act as particles and do not
undergo atmospheric reactions), one DF can be used to calculate sewage sludge limits for all five
regulated metals.
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7. INCINERATION - PART 503 SUBPART E
The increase in the ground level ambient air pollutant concentration at the property line can be determined
by using an air dispersion model. Models provide differing levels of sophistication and suitability
depending on the modeling application. Because .of the variety of models available and the potential
complexities in their use, a modeling protocol should be prepared and reviewed for approval by the
permitting authority prior to conducting any sophisticated dispersion modeling. A modeling protocol
establishes procedures, data requirements and acceptable assumptions. A protocol can help to avoid
misunderstandings and the need to conduct additional modeling runs.
The regulations do not specify acceptable methods of dispersion modeling to be applied to development
of a DF; methodologies acceptable to both the owner/operator and the permitting authority should be
developed on an individual basis. Many technical issues need to be considered when discussing the
application of air dispersion models, such as:
• The mathematical algorithm of the model.
• Meteorological data requirements.
• Averaging times for emission rates and predicted ambient air impacts.
• Topographic and land use considerations.
• Receptor site locations.
• Downwash considerations.
The permit writer and incinerator operator may wish to refer to Guidelines on Air Quality Models
(Revised) and Screening Procedures for Estimating the Air Quality Impact of Stationary Sources (both
published by EPA) for more detailed discussions on the application of dispersion models. The permit
writer and incinerator operator should also get help from personnel trained and experienced in dispersion
modeling whenever possible, to conduct and review dispersion modeling runs.
Regardless of the model chosen, the permit writer should require complete modeling documentation and
should thoroughly review this documentation after modeling is conducted. Sewage sludge incinerator
operators should be required to maintain the following documentation:
• Modeling protocols and approvals granted by the permitting authority.
• Complete modeling reports that follow the approved protocols and include the model used, who
performed the modeling, all model input data, and the output of the model.
• The pollutant emission rates used.
• A scale diagram of the incinerator facility that shows the location of the incinerator stack(s),
property lines, buildings and other significant structures. The diagram should indicate building
dimensions and distances between buildings, property lines and the incinerator stack(s).
• A map of the area of the incineration facility that shows its topography and land use.
Draft-March 1993 7-46
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7. INCINERATION - PART 503 SUBPART E
• The value of the dispersion factor used to calculated sewage sludge limits and how it was
calculated.
7.8.3 STACK GAS DATA
Statement of Regulations
§503.47(a) The person who fires sewage sludge in a sewage sludge incinerator shall develop the information
in §503.47(b) through §503.47(n) and shall retain that information for five years.
§503.47(d) Information that indicates the requirements in the National Emission Standard for beryllium in
Subpart C of 40 CFR Part 61 are met.
§503.47(e) Information that indicates the requirements in the National Emission Standard for mercury in
Subpart E of 40 CFR Part 61 are met.
§503.47(1) The control efficiency for lead, arsenic, cadmium, chromium, and nickel for each sewage sludge
incinerator. . , ,
, > , ' - *
§S03.47(m) The risk specific concentration for chromium calculated using equation (7), if applicable.
Stack gas data required to be obtained and retained by sewage sludge incinerator operators can be divided
into two categories: stack test data and continuous emissions monitoring (CEM) data.
Stack Test Data
The sewage sludge incinerator operator is required to conduct incinerator emissions stack testing by
regulations found at the following locations:
• Part 503, Subpart E — determine control efficiencies for lead, arsenic, cadmium, chromium, and
nickel.
• Part 61, Subpart C — determine beryllium emission rate.
• Part 61, Subpart E — determine mercury emission rate.
Before discussing the specific documentation requirements of the testing outlined above, it may be helpful
to discuss some general stack testing documentation needs. As with dispersion modeling, a protocol
should be prepared for review and approval by the permitting authority before any stack testing is
performed. A stack test protocol can prevent misunderstandings and the need for frustrating and costly
re-tests. A stack test protocol should establish approved sampling and analytical methods, sample point
location(s), and incinerator and air pollution control device operating conditions. The final stack test
report should follow the approved protocol and should explain deviations from agreed-upon procedures
and operating conditions. The test report should document the following:
• Sampling methods including the amount of sample, the duration of sampling, the number of
samples, time and date of samples, person who conducted sampling, and sample point locations.
• Analytical methods including the number, time, date, and analyst for each analysis.
Draft-March 1993 7-47
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7. INCINERATION - PART 503 SUBPART E
• Raw sampling and laboratory sheets.
• Calculation sheets. '
• Quality assurance and quality control procedures such as sample train leak tests and sampling
and laboratory equipment calibrations and checks.
• Chain-of-custody sheets.
• Incinerator operating parameters during testing such as sewage sludge feed rate, auxiliary fuel
feed rate, oxygen concentrations, and incinerator temperatures. The locations of oxygen and
temperature monitors should be specified.
• Applicable air pollution control device parameters during testing, such as stack gas opacity,
pressure drop across the pollution control device, scrubber liquid flow .rates and solids
concentrations, stack gas flow rates, temperatures and pressures, and electrostatic precipitator
field power, voltage, and amperage being applied during testing.
Part 503, Subpart E requires that both the mass of a pollutant in the sewage sludge fed to a incinerator
and the mass of that pollutant in the incinerator exhaust stack gas be determined in a performance test.
The mass of pollutants in the incinerator exhaust can be determined by stack testing and documented as
described in the earlier paragraph. The mass of pollutants in the sewage sludge fed to the incinerator can
be determined by sewage sludge sampling and analysis. Sewage sludge sampling should precede stack
sampling by the time it takes a metal molecule to move through the incinerator so that the same sludge
is compared at both ends. Sewage sludge sampling documentation that should be maintained from the
performance test includes:
• Sampling and analytical methods.
• Sample point(s).
• Sample times, amounts, and frequencies.
• Sample compositing techniques.
• Raw sampling and laboratory sheets.
• Calculation sheets used in sampling and analysis.
• Chain-of-custody sheets.
• Quality assurance and quality control data.
Sewage sludge incinerator operators should also document the actual control efficiencies used in each
reporting period and the calculations used to determine control efficiencies from sewage sludge and stack
test results. The sewage sludge incinerator regulations do not specify the frequency of control efficiency
determinations. However, the incinerator and air pollution control device must be operated with
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7. INCINERATION - PART 503 SUBPART E
parameters consistent with those observed during the performance test. If operating parameters were to
change significantly, an additional control efficiency determination would be required.
Part 61, Subpart C and Subpart E require initial performance testing to verify compliance with beryllium
and mercury emission standards. The documentation requirements for stack gas and sewage sludge
sampling described earlier would also apply to these emission standards. Since both the beryllium and
mercury emission standards are expressed as,grams emitted in a 24-hour period, sewage sludge
incinerator operators need to document, on a daily basis, that incinerator operating conditions do not
deviate from those conditions that were used to demonstrate worst-case beryllium and mercury emissions
in a 24-hour period. Subpart E also requires that incinerators with mercury emissions greater than 1,600
grams per 24-hour period must monitor and document mercury emissions by either stack testing or
sewage sludge sampling and analysis annually.
Recommendations for stack gas sampling methods to be used are as follows:
• Beryllium — EPA Method 104 found in Part 61, Appendix B.
• Mercury — EPA Method 101A found in Part 61, Appendix B.
• Other metals — EPA protocol entitled "Methodology for the Determination of Metal Emissions
in Exhaust Gases from Hazardous Waste Incineration and Similar Combustion Processes."
Permit writers should require incinerator operators to submit testing protocols to the permitting authority
for. approval, follow approved testing procedures, and develop and submit the documentation discussed
earlier regarding any stack gas testing.
Continuous Emissions Monitoring Data
Statement of Regulations
§503.47(a) The person who fires sewage sludge in a sewage sludge incinerator shall develop the information
in §503.47(b) through §503.47(n) and shall retain that information for five years.
§503.47(c) The total hydrocarbons concentration in the exit gas from the sewage sludge incinerator stack.
§503.47(0 The combustion temperatures, including the maximum combustion temperature, for the sewage
sludge incinerator.
§503.47(h) The oxygen concentration and information used to measure moisture content in the exit gas from
the sewage sludge incinerator stack.
§503.47(n) A calibration and maintenance log for the instruments used to measure the total hydrocarbons
concentration and oxygen concentration in the exit gas from the sewage sludge incinerator stack,
the information needed to determine moisture content in the exit gas, and the combustion
temperatures.
The use of continuous emissions monitors at sewage sludge incinerators is required by Part 503, Subpart
E. This subpart requires the use, calibration, and maintenance of CEMs to determine total hydrocarbon,
oxygen, and moisture concentrations in the incinerator stack gases.
Draft-March 1993 7-49
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7. INCINERATION - PART 503 SUBPART E
As indicated earlier in Section 7.7, the Part 503 regulations do not specify CEM performance and record
keeping requirements. The CEM data issues identified in this section also need to be considered and
resolved before establishing record keeping requirements. Generic recommendations for CEM
documentation that should be maintained by the sewage sludge incinerator operator include:
• Daily calibration records, including a description of calibration procedures, the time and date of
each calibration, the calibration gas values, the CEM calibration results, any automatic calibration
correction factors used, and any corrective actions taken.
• Daily maintenance records, including a description of any maintenance and corrective actions and
the amount of monitor downtime.
• Other records of quality assurance and quality control procedures, including quarterly calibration
error determinations and annual relative accuracy testing.
• A minimum of one-minute averages for all CEM data (raw and calculated) when the sewage
sludge incinerator is in operation and during calibrations and other QA/QC tests. The operator
should also be required to maintain one-hour averages for all CEM data during incinerator
operation and to document how the values for total hydrocarbons on a dry basis, corrected to 7
percent oxygen are calculated. THC exceedances and the percentage of exceedance time in each
30-day period should also be documented.
• The criteria used to specify invalid CEM data. The operator should be required to document
what CEM data are excluded and why they were excluded from the calculation of the monthly
average for total hydrocarbons. The operator should be required to calculate monitor downtime
on a daily and monthly basis.
• A description of data reduction and averaging procedures and calculations approved by the
permitting authority.
• The criteria used to specify when corrective actions must be taken and preventative maintenance
schedules and procedures.
• The locations of the CEM sample points, stack gas sample ports, and calibration gas injection
points.
• The initial certification plan and final test report for the CEM system.
As previously indicated, the permit writer may want to refer to the CEM requirements established under
the Clean Air Act regulations, specifically Part 60, Subpart O and 40 CFR Part 266.
The permit writer may also require that the sewage sludge incinerator operator maintain calibration and
maintenance records for sewage sludge feed monitors, auxiliary fuel feed monitors, monitors for pressure
drop across wet scrubbers, incinerator combustion temperature monitors, and any monitors for other
operating parameters specific to a particular incinerator. The operator should be required to maintain,
at a minimum, records of 1-hour averages for these data so that any significant deviations of the values
of key operating parameters from those observed during performance tests can be documented. The
Draft-March 1993 7-50
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7. INCINERATION - PART 503 SUBPART E
permit writer should also consider requiring the operator to maintain records of any such deviations of
operating parameter values and minimum data availability requirements for these monitors.
Under Part 60, Subpart 0, the sewage sludge incinerator operator is required to submit semi-annual
reports of exceedances of operating parameters to the Administrator under certain circumstances. To
fulfill these reporting requirements, the incinerator operator should maintain the following records in the
event that a semi-annual exceedance report is needed:
• Scrubber pressure drops averaged over 15-minute and 1-hour periods.
• Oxygen content averaged over 1-hour periods.
• Incinerator combustion temperatures averaged over 1-hour periods.
• Sewage sludge charging rate averaged over 1-hour periods.
• Fuel use'averaged over 8-hour periods.
• Daily sewage sludge analysis for moisture and volatile solids.
7.8.4 SEWAGE SLUDGE MONITORING INFORMATION
Statement of Regulations
§503.47(a) The person who fires sewage sludge in a sewage sludge incinerator shall develop the information
in §503.47(b) through §S03.47(n) and shall retain that information for fiye years.
§503.47(b) The concentration of lead, arsenic, cadmium, chromium, and nickel in the sewage sludge fed to
the sewage sludge incinerator.
§503.47(i> The sewage sludge feed rate.
Sewage sludge incinerator operators are required by Part 503, Subpart E and Part 60, Subpart 0 to record
the sewage sludge feed rate to a sewage sludge incinerator. Subpart E of Part 503, requires the operator
to monitor the concentrations of lead, arsenic, cadmium, chromium, and nickel in the sewage sludge to
be incinerated. The frequency of monitoring of metals concentrations in the sewage sludge to be burned
depends on the amount of sewage sludge fired in an incinerator. Table 1 of 40 CFR §503.46 outlines
the monitoring frequency requirements.
Sewage sludge incinerators are generally designed and built to operate continuously, but a sudden change
in the quantity of sewage sludge fed to the incinerator can develop dramatic changes in operation. As
a result, the combustion process can be upset and THC concentrations can increase. Feed rate changes
also affect air pollution control devices, which operate within specific design parameters. When the
sewage sludge feed rate varies, the incinerator off-gases will also vary in quantity and temperature. This
variability can decrease the efficiency of the air pollution control devices and result in excess emissions
for paniculate matter and metals.
Under steady-state conditions, the burning of sewage sludge provides enough heat both to evaporate the
large quantities of water that enter with the sewage sludge solids and to initiate combustion of the new
Draft-March 1993 7-51
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7. INCINERATION - PART 503 SUBPART E
sewage sludge. Keeping constant the volume of the sewage sludge burned optimizes the required rate
of excess air and therefore reduces heat lost in excess air. In the case of multiple-hearths, ash is not
removed from the incinerator until it has cooled and given up its heat to entering combustion air. It is
almost impossible to achieve these optimum conditions unless the sewage sludge feed is consistent
(Perking 1974; EPA 1981, 1979/1987; WPCF 1988).
The sewage sludge feed rate should be monitored to provide information to the operator on the quantities
of sewage sludge being fed to the incinerator(s). Monitoring the sewage sludge feed rate ensures that it
does not exceed the feed rate used to establish the concentration of the metal pollutants.
The most widely used instruments to measure the incinerator sewage sludge feed rate are load cell
conveyor belt scales. The weight of sewage sludge on the belt is measured by strain gauges. As the
weight on the belt increases, the stress on the load cell increases, which causes a corresponding change
in the electrical resistance of the strain gauge. The electrical resistance, combined with the speed of the
belt, is fed to a microprocessor that calculates the mass per unit time of sewage sludge on the belt. These
scales, like any other instrument, often need calibration, require maintenance, and must be replaced when
beyond repair (EPA 1992a). Based on the requirements of Part 60, Subpart O, the sewage sludge feed
rate monitor should be certified by the manufacturer to have an accuracy of plus or minus 5 percent over
its operating range. The monitor should be calibrated and adjusted at a frequency necessary to maintain
this accuracy. The recommended frequency of sewage sludge feed rate monitor calibration can be
initially set at once every seven operating days. The calibration frequency can be adjusted by the
permitting authority, if warranted by a review of calibration records obtained from the incinerator
operator.
Important sewage sludge monitoring documentation and records that should be maintained by sewage
sludge incinerator operators include:
• Sewage sludge feed rates (on a dry basis) expressed as hourly, daily, and annual averages.
• The operating range of the sewage sludge feed rate monitor and a certification of the monitor's
accuracy over that range.
• Calibration and maintenance records of the sewage sludge feed rate monitor.
• Records of sewage sludge feed rate monitor malfunctions, corrective actions, and downtime.
• Sewage sludge sampling records including the methods used, sample amounts, compositing
techniques, times and dates, sample point locations, person(s) who obtained samples, and chain
of custody sheets.
• Sewage sludge analytical results including the methods used, times and dates of analysis,
laboratory data and calculation sheets, person(s) performing the analysis, and laboratory quality
assurance and quality control procedures that were followed.
Draft-March 1993 7-52
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7. INCINERATION - PART 503 SUBPART E
Permit writers need to stipulate the acceptable sewage sludge sampling and analytical methods to be used.
Permit writers can refer to the following EPA documents for detailed guidance in sewage sludge sampling
and analysis:
• SW-846, Test Methods for Evaluating Solid Wastes
• POTW Sludge Sampling and Analysis Guidance Document
• Hazardous Waste Incineration Measurement Guidance Manual
• Handbook on Quality Assurance/Quality Control Procedures for Hazardous Waste Incineration.
7.9 REPORTING REQUIREMENTS
Statement of Regulations
§503.48(a) Class I sludge management facilities, POTWs (as defined in 40 CFR 501.2) with a design flow
rate equal to or greater than one million gallons per day, and POTWs that serve a population
of 10,000 people or greater shall submit the information in §503.47(b) through §503.47(h) to the
permitting authority on (insert the month and day from the date of pnblkatkm of Part 503) of
each year.
The reporting requirements of Part 503 provide a regulatory mechanism that allows permitting authorities
to gather information from sewage sludge incinerators and certain publicly owned treatment works to
assess compliance. Since all sewage sludge incinerators are classified as Class I sewage sludge
management facilities, all sewage sludge incinerators as defined in §503.41 are subject to the reporting
requirements of §503.48.
These reporting requirements establish a minimum for reporting sewage sludge incinerator emission and
operating records. Incinerator operators are required to submit the information specified in §503.48 to
the permitting authority each year, provided sewage sludge was fired to the incinerator in that particular
year.
The information specified in §503.47 is more complex than it may appear to be. As discussed in Sections
7.7 and 7.8, the information required in §503.47 is largely based on other pieces of information, such
as performance test reports, dispersion modeling reports, and CEM certification and exceedance reports.
Without this detailed information, the permitting authority is not able to verify the validity of the §503.47
information. Therefore, he/she cannot draw accurate and complete conclusions on the compliance status
of the sewage sludge incinerators. Therefore, the imposition of more detailed record keeping and
reporting permit conditions is recommended.
More detailed record keeping and reporting requirements serve two basic purposes:
• To provide documentation that supports the §503.47 information reported. This documentation
describes how the §503.47 information was obtained. Examples include performance test
protocols and reports, modeling protocols and reports, CEM installation plans and certification
reports, and sewage sludge monitoring methods.
Draft-March 1993 7-53
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7. INCINERATION - PART 503 SUBPART E
• To establish reporting formats so that the information is meaningful and useful to the permitting
authority for evaluating compliance and enforcing standards and limits. Examples include
specifying averaging times for CEM and APCD operating parameter data, combustion
temperature, and sewage sludge feed rate. The permit writer may also want to specify the more
frequent reporting of certain data. For example, by reviewing CEM data submitted by an
incinerator operator every quarter or month, the permitting authority can identify patterns of
noncompliance earlier than would be possible using the §503.48 requirements. Once these
emission exceedances are identified, actions can be taken to correct these violations and prevent
future ones.
Since these issues were discussed in earlier sections of this chapter, a similar detailed discussion will not
be repeated. When permit writers specify permit conditions that require the detailed record keeping and
monitoring described earlier, they may also want to include requirements to report or make available to
the permitting authority these records and data.
Draft-March 1993 7-54
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7. INCINERATION - PART 503 SUBPART E
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS
Scenario 1: Incineration
Parties involved:
Description:
Issue permit to:
One POTW that is owner/operator of a sewage sludge incinerator
The City of Cough operates a 40 mgd POTW which produces 14,000 tons (dry
weight) of sewage sludge per year. The dewatered sewage sludge is disposed in a
sewage sludge incinerator owned and operated by the City. The incinerator receives
only sewage sludge from the Cough POTW with no other contributors. The stack
height of the sewage sludge incinerator is 30 meters, and incineration is conducted
with a fluidized bed equipped with a wet scrubber. The City of Cough is a Class I
sludge management facility.
The City of Cough
Permit Conditions for the Generator/Owner
Standard conditions
Pollutant limits
Operational standard for total hydrocarbons
Management practices
Monitoring requirements
Record keeping requirements
Reporting requirements
Draft-March 1993
7-55
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7. INCINERATION - PART 503 SUBPART E
EXAMPLES ILLUSTRATING THE APPLICATION OF 40 CFR PART 503
REQUIREMENTS IN PERMITS (Continued)
Scenario 2: Incineration
Parties involved:
Description:
Issue permit to:
Several generators
Owner/operator of the sewage sludge incinerator
Several large urban municipalities operate independent POTWs and contract with BS,
Inc. to incinerate their sewage sludge by using a fluidized bed incinerator equipped
with a wet scrubber and wet electrostatic precipitator. BS, Inc. is the
owner/operator of the incinerator and accepts a total of 110,000 tons of sewage
sludge per year from the municipalities. The stack height was determined to be 72
meters. BS, Inc. was determined to be a Class I sludge management facility by the
EPA Regional Administrator.
All of the generators and owner/operator of sewage sludge incinerator, BS, Inc.
Permit Conditions for the Generators
Standard conditions
Reporting requirements (to any of the generators classified as a Class I facility)
Permit Conditions for the Owner/Operator of Incinerator
Standard conditions
Pollutant limits
Operational standard of total hydrocarbons
Management practices
Monitoring requirements
Record keeping requirements
Reporting requirements
Draft-March 1993
7-56
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7. INCINERATION - PART 503 SUBPART E
REFERENCES
Perking, H. C. 1974. Air Pollution. McGraw-Hill, Inc. New York, NY.
U.S. EPA. 1972. Sewage Sludge Incineration. August 1972. R2-72-040.
U.S. EPA. 1978a. Sludge Handling and Conditioning. Washington, DC. September 1978. 430/9-78-
002.
U.S. EPA. 1978b. Sewage Sludge Treatment and Disposal, Volume 2. Washington, DC. April 1978.
625/4-78-012.
U.S. EPA. 1981. Engineering Handbook for Hazardous Waste Incineration. Washington, DC.
September 1981. SW-889.
U.S. EPA. 1979. Process Design Manual for Sludge Treatment and Disposal. U.S. Environmental
Protection Agency 625/1-79-001, January 1987.
U.S. EPA. 1983. Guidance Manual for Hazardous Waste Incineration Permits. Washington, DC. July
1983. SW-966.
U.S. EPA. 1985. Guidelines for Determining Good Engineering Practice Stack Height.
U.S. EPA. 1989. Technical Support Document: Incineration of Sewage Sludge. Draft. Washington:
Office of Water.
U.S. EPA. 1990a. Guidance Document for Testing and Permitting Sewage Sludge Incinerators. Draft
Report. Midwest Research Institute. September 1990.
U.S. EPA. 1990b. Guidance for Writing Case-by-Case Permit Requirements for Municipal Sewage
Sludge. Office of Water. May 1990. 505/8-90-001,
U.S. EPA. 1990c. Locating and Estimating Air Toxics Emissions from Sewage Sludge Incinerators.
May 1990 EPA-450/2-90-009.
U.S. EPA. 1992. Technical Implementation Document for EPA's Boiler and Industrial Furnace
Regulations. March 1992. EPA-530-R-92-011.
U.S. EPA. 1992a. Sewage Sludge Incinerator Total Hydrocarbon Analyzer Evaluation. Cincinnati, OH:
Office of Research and Development, Wastewater Research Division.
Is
U.S. EPA. 1993. The Preamble to 40 CFR Part 503 Standard for the Use and Disposal of Sewage
Sludge. February 1993. FR 58, 9248.
Draft-March 1993 7-57
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7. INCINERATION - PART 503 SUBPART E
U.S. EPA. Technical Support Document for Proposed Publicly Owned Treatment Works Sludge
Incineration Regulation. Washington, DC. July 1992.
Water Pollution Control Federation. 1988. Incineration, Manual of Practice. No. OM-11. Alexandria,
VA.
Draft-March 1993 7-58
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APPENDIX A
CONVERSION FACTORS - ENGLISH SYSTEM UNITS TO
METRIC SYSTEM UNITS
-------
TABLE A-l. CONVERSION FACTORS - ENGLISH SYSTEM UNITS TO METRIC
SYSTEM UNITS
English System International System of Units (SI)
Name
Inch
Foot
Mile
Abbreviation
in
ft
mi
Multiplier
Length
2.54
0.3048
1.609
Symbol
cm
m
km
Name
Centimeter
Meter
Kilometer
Area
Square Inch
Square Foot
Square Mile
Square Mile
Acre
in2
ft2
mi2
mi2
acre
6.4516
9.29 x la2
2.59
259
0.4047
cm2
m2
km2
ha
ha
Square Centimeter
Square Meter
Square Kilometer
Hectare
Hectare
Volume
Cubic Foot
Cubic Foot
Gallon
Million Gallons
Acre Foot
ft3
ft3
gal
Mgal
acre-ft
28.32
2.832 x 1(T2
3.785
3.7854 x 103
1233
L
m3
L
m3
m3
Liter
Cubic Meter
Liter
Cubic Meter
Cubic Meter
Pressure
Pounds per Square
Inch
lbs/in2
7.031 x 10-2
kg/cm2
Kilograms per Square
Centimeter
Mass
Pound
Pound
Ton (short)
Ib
Ib
T
4.539 x 102
0.4536
0.9072
gm
kg
mt
Gram
Kilogram
Metric Tonne
Density
Pounds per Cubic
Foot
Tons per Acre
Tons per Acre
Ibs/ft3
T/acre
T/acre
16.02
2242.15
2.2421
kg/m3
kg/ha
mt/ha
Kilograms per Cubic
Meter
Kilograms per
Hectare
Metric Tonnes per
Hectare
A-l
-------
TABLE A-l. CONVERSION FACTORS - ENGLISH SYSTEM UNITS TO METRIC
SYSTEM UNITS (Continued)
English. System International System of Units (SI)
Name
Abbreviation
Multiplier
Symbol
Name
. : Discharge (flow rate, volume/time)
Cubic Feet per
Second
Gallons per Minute
Gallons per Day
Million Gallons per
Day
Million Gallons per
Day
rV/sec
gal/min
gal/day
Mgal/day
Mgal/day '
28.32
6.39 x 1(T2
4.3813 x 10"5
43.8126
3.7854 x 103
L/sec
L/sec
L/sec
L/sec
m3/day
Liters per Second
Liters per Second
Liters per Second
Liters per Second
Cubic Meters per Day
;-. Power
Horsepower
hp
0.7457
kW
Kilowatt
Temperature
Degrees Fahrenheit
oF
0.555(°F-32)
,°C
Degrees Celsius
Miscellaneous
Parts per Million
Parts per Billion
Million Gallons per
Acre
ppm
ppb
Mgal/acre
1.0
1.0
9354.537
mg/L
. ug/L
m3/ha
Milligrams per Liter
Micrograms per Liter
Cubic Meters per
Hectare
A-2
-------
TABLE A-2. CONVERSION FACTORS - METRIC SYSTEM UNITS TO ENGLISH SYSTEM
UNITS
International System of Units (SI) English System
Name
Centimeter
Meter
Kilometer
Abbreviation
cm
m
km
Multiplier
Length
0.3937
3.2808
0.6214
Symbol
in
ft
mi
Name
Inch
Foot
Mile
Area
Square Centimeter
Square Meter
Square Kilometer
Hectare
Hectare
cm2
m2
km2
ha
ha
0.155
10.763
.3861
3.861 x 10-3
2.471
in2
ft2
mi2
mi2
ac
Square Inch
Square Foot
Square Mile
Square Mile
Acre
Volume
Liter
Liter
Cubic Meter
Cubic Meter
Cubic Meter
L
L
m3
m3
m3
3.531 x 10-2
0.2642
35.3147
2.641 x 10-4
8.1071 x 10-4
ft3
gal
ft3
Mgal
acre-ft
Cubic Foot
Gallon
Cubic Foot
Million Gallons
Acre-foot
Pressure
Kilograms per Square
Centimeter
kg/cm2
14.22
lbs/in2
Pounds per Square
Inch
Mass
Gram
Kilogram
Metric Tonne
gm
kg
mt
2.20 x 10-3
2.205
1.103
Ib
Ib
T
Pound
Pound
Ton (short)
Density
Kilograms per Cubic
Meter
Kilograms per
Hectare
kg/m3
kg/ha
0.0624
4.46 x 10-4
.Ibs/ft3
T/acre
Pounds per Cubic
Foot
Tons per Acre
A-3
-------
TABLE A-2. CONVERSION FACTORS - METRIC SYSTEM UNITS TO ENGLISH SYSTEM
UNITS (Continued)
International System of Units (SI) English System
Name
Metric Tonnes per
Hectare
Abbreviation
kg/ha
Multiplier
0.446
Symbol
T/acre
Name
Tons per Acre
Discharge (flow rate, volume/time)
Liters per Second
Liters per Second
Liters per Second
Liters per Second
Cubic Meters per
Day
L/sec
L/sec
L/sec
L/sec
nrVday
3.531 x ia2
15.85
22,824.5
2.28 x lO"2
2.6417 x 10-4
ftVsec
gal/min
gal /day
Mgal/day
Mgal/day
Cubic Feet per
Second
Gallons per Minute
Gallons per Day
Million Gallons per
Day
Million Gallons per
Day
Power
Kilowatt
kW
1.341
hp
Horsepower
Temperature
Degrees Celsius
°C
1.8°C'+ 32
OF
Degrees Fahrenheit
Miscellaneous
Milligrams per Liter
Micrograms per Liter
Cubic Meters per
Hectare
mg/L
ug/L
m3/ha
1.0
1.0
1.069 x IV4
ppm
ppb
Mgal/acre
Parts per Million
Parts per Billion
Million Gallons per
Acre
A-4
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APPENDIX B
SURFACE DISPOSAL SITE LINERS
-------
SURFACE DISPOSAL SITE LINERS
A liner is defined in §503.21(j) as soil or synthetic material that has a hydraulic conductivity of 1 x 10"7
centimeters per second or less. Three types of liners and their properties are discussed in detail below.
Soil Liners (Compacted Clay)
The permeability and performance of soil liners are most affected by the following factors: soil
properties; liner thickness; lift thickness, placement, and bonding; and hydraulic conductivity. Although
the soil may contain all the correct properties for successful construction of the liner, the soil liner may
still not meet the hydraulic conductivity criterion if the construction practices are not properly controlled.
Thus, construction information is needed to verify the integrity of the liner.
Soil Properties
The permeability and performance of a soil liner
depends upon the properties of the soil. The
compacted clay component of a soil liner defines
the liner's hydraulic conductivity. There are two
systems of soil classification used in the United
States to determine whether a soil is considered a
clay or a silt. These two classification systems
are difficult to compare. Therefore, rather than
define the soils by one or the other of the
classifications, soils for clay liners can be defined
based upon their specific characteristics. To
determine whether a soil will meet the hydraulic
conductivity requirement, the following
characteristics of the soil should be present:
• At least 20 percent fines (fine, silt and
clay sized particles); however, some soils
The United States Department of Agriculture's
(USDA) soil classification system is based on
grain size and uses a three-part diagram to
classify all soils. The American Society of
Testing and Materials' (ASTM) soil
classification system does not use grain size as
a criteria but instead bases the classification of
clays on plasticity criteria. The ASTM system
uses a plasticity diagram and the slope of line
"A" to distinguish between clays and silts
(those soils that fall in the area above the "A"
line are considered to be clays, those below
silts) (EPA 1989c).
with less fines may meet the hydraulic conductivity of 10"7 cm/sec (EPA 1989c)
• A plasticity index (PI) of the soil between 10 and 30 percent (soils with a PI greater than 30
percent are sticky and difficult to work with) (EPA 1989c)
• No more than 10 percent gravel-sized particles (coarse fragments can cause zones with higher
conductivity) (EPA 1989c)
• No soil particles or chunks of rock greater than 1 to 2 inches in diameter (large particles can
form permeable "windows" through a layer) (EPA 1989c).
B-l
-------
SURFACE DISPOSAL SITE LINERS (Continued)
The most common additive used for soil
amendment is sodium bentonite. This clay
mineral, generally in the form of a dry
powder, when mixed with water expands by
absorbing the water into the mineral matrix.
The addition of a relatively small amount (5 to
10 percent) of this mineral to a; noncohesive
soil makes the soil more cohesive.
Generally, natural soil materials are recommended
for surface disposal sites; however, soils amended
or blended with different additives (e.g., lime,
cement, bentonite clays, and borrow clays) may
also meet the criteria for hydraulic conductivity.
Thickness of Liner
A thickness of two feet is generally considered the
minimum thickness needed to obtain adequate
compaction of the soil and meet the hydraulic •"i^••••••••••••••••••••••••••
conductivity requirement (EPA 1992a).
Lift Thickness, Placement, and Bonding
Soil liners are most often constructed in a series of lifts, each compacted separately. The lift thickness
(generally 5-9 inches) is dependent upon soil properties, compaction equipment, and the compaction
needed to meet the hydraulic conductivity requirement. At smaller sites, the soil liner may be constructed
over the entire site at one time. At larger sites with multi-unit designs the liners may be constructed in
segments over the life of the site. In the case of multi-unit designs, the design should address how the
old and new liner segments will be bonded together to maintain the hydraulic conductivity requirement
(EPA 1992a).
Hydraulic Conductivity
The hydraulic conductivity of a liner is the most important design parameter when evaluating a
constructed soil liner. The hydraulic conductivity determines the ease with which water passes through
the liner material. The hydraulic conductivity depends upon the degree of compaction, compaction
method, soil moisture content, and density of the soil during liner construction. Hydraulic conductivity
is also dependent upon the viscosity and density of the leachate and on the shape, size, and area of the
conduits though which the liquid flows. Leachates from surface disposal sites have physical properties
similar to those of water so water is appropriate for testing the compacted soil liner and source materials.
The hydraulic conductivity of a partially saturated soil is less than the hydraulic conductivity of the same
soil when saturated, due to a reduction of flow area from air entrapment. Hydraulic conductivity testing
should be conducted on samples that are fully saturated (EPA 1992a).
The lowest hydraulic conductivity of compacted clay soil usually occurs when the soil is compacted at
a moisture content slightly higher than the optimum moisture content, generally in the range of 1 to 7
percent (EPA 1989c). When compacting clay, water content and compactive effort are the two factors
that should be controlled to meet the maximum hydraulic conductivity criterion. Since it is impractical
to specify and construct a clay liner to a specific moisture content and to a specific compaction, and
because moisture content is difficult to control in the field during construction, the design plan usually
specifies a range of moisture contents and corresponding soil densities (percent compaction) to achieve
the required hydraulic conductivity. During construction of the liner, soil testing is conducted to ensure
that the design specifications are being met. The amount of soil testing to define these construction
parameters is dependent on the degree of natural variability of the source material (EPA 1992a).
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SURFACE DISPOSAL SITE LINERS (Continued)
Laboratory and field testing are performed to determine compaction requirements and moisture contents
of material delivered to the site. Laboratory testing is usually conducted on field samples for
determination of hydraulic conductivity of the in-place liner. In laboratory testing, soil samples can be
fully saturated and the effects of a large overburden stress on the soil, which is not easily performed in
the field, can be simulated (EPA 1989c).
Differences between laboratory and field conditions (e.g., uniformity of material, control of water
content, compactive effort, and compaction equipment) may make it unlikely that minimum hydraulic
conductivity values measured in the laboratory on remolded, pre-construction borrow source samples are
the same as the values achieved during actual liner construction. Laboratory testing also does not account
for operational problems that may occur in the field. Methods that can be used to measure hydraulic
conductivity in the lab are provided below.
Laboratory Methods To Measure Hydraulic Conductivity
i
EPA Method 9100 for measuring hydraulic conductivity of soil samples in publication SW-846, Test
Methods for Evaluating Solid Waste — Physical/Chemical Methods (EPA 1986).
U.S. Army Corps of Engineers Engineering Manual 1110-2-1906 (1970) (4) and the newly
published Measurement of Hydraulic Conductivity of Saturated Porous Materials
American Standards and Testing Methods (ASTM) D-5084 Measurement of Hydraulic Conductivity
of Saturated Porous Materials Using a Flexible Wall Permeameter [To verify full saturation of the
sample, this method may be performed with back pressure saturation and electronic pore pressure
measurement (EPA 1992a)].
Field tests provide an opportunity to check representative areas of the liner for conformance with
compaction specifications (including density and moisture content). Field tests are the most accurate
method of determining hydraulic conductivity because laboratory values generally are lower than those
measured in test fills or actual liners (EPA 1992a). Therefore, the results of both field tests and
laboratory tests should be evaluated when determining the compliance of soil liners with the hydraulic
conductivity requirement.
There are four kinds of field hydraulic conductivity tests, as described below:
• Borehole test — A hole is drilled into the soil and filled with water. The rate at which water
percolates into the borehole is measured.
• Porous probe test — A porous probe is driven into the soil and water is poured into the probe.
The amount of water that is released from the probe into the soil is measured.
• Infiltrometer test — An infiltrometer is embedded into the surface of the soil liner so that the rate
of flow of a liquid into the liner can be measured. There are two types of infiltrometers — open
and sealed. Open rings are less desirable than popular sealed rings because they make it difficult
to account for evaporative basis when measuring the drop in water levels. Also, double-ringed
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SURFACE DISPOSAL SITE LINERS (Continued)
infiltrometers are preferred to single rings because double-ringed infiltrometers are less
susceptible to the effects of temperature.
• Underdrain test •>- Underdrains, which are installed during construction of the liner, are the most
accurate in-situ permeability testing device because they measure the exact amount of leachate
that migrates from the bottom of the liner (EPA 1989c).
Flexible Membrane Liners (Geomembranes)
Flexible membrane liners (FMLs), also called geomembranes, are generally polymeric materials,
particularly plastics and synthetic rubbers, mixed with a variety of other ingredients, such as carbon
black, pigments, fillers, plasticizers, processing aids, crosslinking chemicals, anti-degradants, and
biocides. There are several types of polymeric materials that are used in the manufacture of the FML
sheeting, including (EPA 1992a):
• Thermoplastics, such as polyvinyl chloride (PVC)
• Crystalline thermoplastics, such as high density polyethylene (HOPE), very low density
polyethylene (VLDPE), and linear low density polyethylene (LLDPE)
• Thermoplastic elastomers, such as chlorinated polyethylene (CPE) and chlorosulfonated
polyethylene (CSPE).
In assessing whether a FML will meet the hydraulic conductivity requirement, the following important
information should be examined:
• Thickness — The thickness of an FML affects permeability and can range anywhere from 20 to
120 mils. However, the recommended minimum thickness for all FMLs is 30 mils [with the
exception of high density polyethylene (HDPE) which should be at least 60 mils for proper
seaming] (EPA 1992a).
• Chemical compatibility with the contained waste — Plastics and rubber exhibit various degrees
of compatibility with different leachates. Materials used in an FML should be selected based on
exposure to the leachate during its intended life. Compatibility testing is often performed prior
to installation. The most common test is the EPA Method 9090 Compatibility Test found in the
EPA document entitled, Test Methods for Evaluating Solid Waste, SW-846. This test simulates
the conditions to which the FML may be exposed during operation of the disposal site and what
effects, if any, the leachate and wastes will have on the liner.
Composite Liners
Composite liners are combinations of flexible membrane liners and compacted soil liners often used to
reduce the impact of penetrations of the FML. The use of a flexible membrane liner, in addition to the
soil, increases the leachate collection efficiency of the liner and provides a more effective hydraulic
barrier. The ability of a composite liner to meet the hydraulic conductivity requirement should be
assessed in a manner similar to that described above for each of the liner components: the soil liner and
the FML.
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APPENDIX C
INFORMATION SOURCES
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INFORMATION SOURCES
Many EPA, State, Federal, and other organizations distribute technical publications that can
provide valuable information to the permit writer to address various issues that may arise during the
permitting process. The following list of information sources, arranged alphabetically, provides a brief
description of the types of information these sources can provide.
Building Seismic Safety Council
1201 L St., NW
Suite 400
Washington, DC 2005
(202) 289-7800
The Building Seismic Safety Council (BSSC) is dedicated to wide distribution of technology for
designing seismic safety into buildings. FEMA stocks all BSSC publications and will send the requestor
copies at no charge by calling FEMA publications at (202) 646-3484.
Federal Emergency Management Agency (FEMA)
Flood Map Distribution Center
6930 (A-F) San Thomas Rd.
Baltimore, MD 21227-6227
Federal Emergency Management Agency (FEMA)
(800) 638-6620 Continental U.S. only, except Maryland
(800) 492-6605 Maryland only
(800) 638-6831 Continental U.S., Hawaii, Alaska, Puerto Rico, Guam, and the
Virgin Islands
The Federal Emergency Management Agency (FEMA) can provide assistance and information
on flooding and floodplains. The National Flood Insurance Program Community Status Book is published
bimonthly and can be obtained by calling the toll-free numbers listed above. Flood insurance rate maps
and other flood maps, including those delineating 100-year floodplains, may be obtained from the map
distribution center.
National Climatic Data Center
Federal Building
Asheville, NC 28801
(704) 259-0682
The National Climatic Data Center stocks various weather publications for the United States.
National Weather Service meteorological data older than one year is available from the center. A useful
guide for determining rainfall in the western U.S., on a state by state basis is Precipitation Frequency
Atlas of the Western United States - NOAA Atlas 2. A publication for the eastern and central U.S.
entitled 5 to 60 Minute Precipitation Frequency for Eastern and Central United States is available from
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INFORMATION SOURCES (Continued)
NTIS (see above). The order number is PB 272112/AS. The center is open Monday through Friday
from 8:00 a.m. to 4:00 p.m. EST.
National Earthquake Information Center
P.O. Box 25046
Denver Federal Center MS 967
Denver, CO 80225
(303) 273-8500
The National Earthquake Center (NEIC) is the national data center and archive for earthquake
information. NEIC maintains a data base that has cataloged earthquake data that covers a time period
from 2100 BC to approximately four weeks behind the current date. There is a charge for this data base
service. To obtain further information the permit writer should call (303) 273-8406.
National Information Service for Earthquake Engineering
University of California, Berkeley
404A Davis Hall
Berkeley, CA
(510) 231-9401
The National Information Service for Earthquake Engineering provides information for earthquake
engineering through a series of research reports, computer software programs, databases and library
services. The center is open from 8:00 a.m. to 12:00 p.m. and from 1:00 p.m. to 5:00 p.m. Monday
through Friday. There is a charge for publications and software. The permit writer should call the
service for the specific information required.
National Technical Information Service (NTIS)
5285 Port Royal Rd.
Springfield, VA 22151
(703) 487-4650
(800) 553-6847 [
The National Technical Information Service provides information about technical reports
published by various sources, including EPA. NTIS has a large inventory of technical publications which
are available for a charge. The hours of operation are from 8:30 a.m. to 5:00 p.m. Monday through
Friday. Information on NTIS services and ordering information can be accessed by calling one of the
numbers listed above.
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INFORMATION SOURCES (Continued)
RCRA/Superfund Industrial Assistance Hotline
(800) 424-9346
The RCRA/Superfund Hotline provides information to the public and the regulated community
in understanding EPA regulations and policy on Resource Conservation and Recovery Act (RCRA) which
includes regulation of municipal solid waste landfills. Although the hotline does not deal with the subject
of sewage sludge disposal, they can provide state and local contacts for a variety of agencies. The hotline
also can be a source of information for the latest publications from the U. S. EPA, in particular, solid
waste disposal, methane gas control, covers, liners, and leachate collection systems. The phone call is
toll free and the hours of operation are from 8:30 a.m. to 7:30 p.m. EST, Monday through Friday.
U.S. Army Corps of Engineers
Publication Depot
2803 52nd Ave.
Hyattsville, MD 20781-1102
(301) 436 2063
The Corps of Engineers Publication Depot has many documents pertaining to flooding and
floodplains. The Federal Manual for Identifying and Delineating Jurisdictional Wetlands is available
from the Depot. All publications are free, however, they must be ordered in writing, no phone orders
are accepted. The Depot is open from 7:30 a.m. to 4:00 p.m. EST Monday through Friday.
The Corps of Engineers Hydrologic Engineering Center can supply the HEC models. The Center
will distribute the models to Federal Agencies only from this location. The software is available to the
public from NTIS. The center can be contacted at:
Hydrologic Engineering Center
609 2nd St.
Davis, CA 95616
(916)756-1104
U. S. Department of Agriculture
Soil Conservation Service (SCS)
P.O. Box 2890
Washington, DC 20013
Publication Distribution Office
Room 0054E
South Building
Washington, DC 20250
(202) 720-5157
The Soil Conservation Service (SCS) of the United States Department of Agriculture can provide
technical assistance in determining the nitrogen requirements of crops or vegetation, and calculating the
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INFORMATION SOURCES (Continued)
agronomic rate. SCS has a nationwide network of nearly 3,000 offices and focuses its assistance on non-
Federal land. SCS district offices can provide on-site assistance in determining the acceptability of sites
to receive sewage sludge for land application. SCS can provide publications to assist the permit writer
on subjects including wetlands delineation, floodplains and erosion control.
For SCS programs and assistance, the permit writer should find the local office in the phone book
which is listed under the United States Government, Department of Agriculture. If the permit writer
needs specific documents that are not available at the local office, the Publication Distribution Office
should be contacted.
U.S. Department of Interior
1 Fish and Wildlife Service
Publications Unit
4401 N. Fairfax St.
130 Webb Building
Arlington, VA 22203
(703)358-1711
(703) 358-2283 (FAX)
The Publication Unit of the Fish and Wildlife Department distributes free publications that may
be helpful for determining the presence of endangered species and delineating wetlands. The Publication
Unit is open from 7:45 a.m. to 4:30 p.m. EST Monday through Friday. Publications are free to the
public and may be ordered by phone, fax, or written request.
U.S. Geological Survey (USGS)
Earth Science Information Center
12201 Sunrise Valley Drive
Reston, VA 22092
(800) USA-MAPS (872-6277)
The USGS Earth Science Information Center stocks an extensive supply of maps covering the
entire United States. The Center is open from 8:00 a.m. to 4:00 p.m. EST, Monday through Friday.
The toll-free telephone number allows the caller a variety of options for obtaining information.
The types of maps available from the Center that are mentioned in thisTnanual as very useful to
the permit writer are:
1) Algermissen S .T., et. al. 1990. Probabalistic Earthquake Acceleration and Velocity Maps for the
United States and Puerto Rico. Map MF 2120. (Maps of horizontal acceleration useful for determining
whether a sewage sludge disposal unit lies within a seismic impact zone.)
2) USGS. 1978. Preliminary Young Fault Maps. Map MF 916. (Delineates Holocene faults in the
United States.)
Other maps available include topographic maps, state geologic maps, and various specialized maps
that may be useful in determining the suitability of a location for a sewage sludge disposal unit.
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INFORMATION SOURCES (Continued)
State seismicity maps can be obtained from USGS Map Sales offices. Mail orders can be
addressed to:
U.S. Geological Survey
Map Distribution
Denver Federal Center, Box 25286
Denver, CO 80225
(303)236-7477
The EROS Data Center distributes aerial photographs that may be useful for delineating fault
traces and structural lineaments. The center carries the National Aerial Photographic Program/National
High Altitude Program (NAPP/NHAP) stereo photos, landsat photos, and other aerial photographs. The
center is open from 7:30 a.m. to 4:00 p.m. Monday through Friday. The center can be contacted at:
U.S. Geological Survey
EROS Data Center
Sioux Falls. SD 57198
(605) 594-6151
U.S. Environmental Protection Agency
Center for Environmental Research Information (CERI)
Cincinnati, OH 45268
(513) 569-7562
The Office of Research and Development (ORD) has centralized most of its information
distribution and technology transfer activities at CERI. CERI serves as the distribution center for ORD
reports and research results. The permit writer can contact CERI to request information for summary
reports and technical documents on a wide range of topics including landfill covers, liners, construction
techniques, etc. - ,
U.S. Environmental Protection Agency
Office of Air Quality and Standards
Research Triangle Park
(919)541-5381 (Joe Tuma)
Information on the availability and cost of the air dispersion models can be obtained by calling
Joe Tuma at the number given above.
U.S. Environmental Protection Agency
Reduction Risk Engineering Laboratory (RREL)
Cincinnati,'OH
(513) 569-7834
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INFORMATION SOURCES (Continued)
The Geotechnical Analysis for Review of Dike Stability (CARDS) software package was developed
to assist in evaluating earth dike stability. CARDS may be obtained from RREL. There is no charge
for the program, however, the program must be copied onto discs which the user must supply.
C-6
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APPENDIX D
DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E
The pollutant limits for metals presented in Section 503.43 are calculated, in part, from sewage sludge
incinerator control efficiencies (CE) for each of these metal pollutants. Section 503.43 states that CE
shall be determined from a performance test of a sewage sludge incinerator, as specified by the permitting
authority. The regulatory definition of control efficiency can be expressed by the following formula:
CE = [Pollutant^, - Pollutant^,,]/ Pollutant^
where:
Pollutantrm) = the mass of a pollutant in the sewage sludge fed to an incinerator,
Pollutant(out) = the mass of the same pollutant in the exit gas from the incinerator stack.
Without CE determinations sewage sludge limits cannot be established. The Part 503 regulations do not
establish the procedures to be followed to determine CE; instead, these CE performance test procedures
are specified by the permitting authority. The following discussion is intended to guide permit writers
and incinerator operators to appropriate test procedures that can be used to determine and document
values for CE.
Control efficiency performance testing involves three elements: determining the mass of a pollutant in
the exit gas from the sewage sludge incinerator stack; determining the mass of that pollutant in the sewage
sludge fed to a sewage sludge incinerator; and determining the operating parameters of the incinerator's
air pollution control device during the performance test of the incinerator. The first two elements are
components of the regulatory definition of CE. The third element is not part of the definition of CE,
however, it is important since it can be used for on-going documentation of CE values after performance
testing has been completed. Each of these elements will be discussed individually in greater detail.
Determining pollutant mass in the incinerator exit gas
In order to accurately determine the mass of a pollutant in an incinerator's exit gas, sampling and
subsequent analysis of the incinerator exit gas stream must be conducted in discrete time periods. It is
important to understand that these procedures, known as stack tests in air pollution control jargon, only
provide data about the incinerator exit gas when gas sampling took place. Stack tests, therefore, only
provide a "snap-shot" of an incinerator's exit gas.
Appendix A of 40 CFR Part 60 contains test methods that are used to determine emission rates for
various pollutants from stationary sources. Although these methods are used primarily to determine
compliance with EPA's New Source Performance Standards (NSPS) and in some cases, National
Emission Standards for Hazardous Air Pollutants (NESHAP), they have also been applied widely to other
situations. For example, these methods have been used extensively to determine emission rates from
sources subject to state air quality regulations.1 Some of the Part 60 Appendix A stack test methods can
also be applied to determine, in part, the mass of metal pollutants emitted from sewage sludge incinerator
stacks.
1 It should be noted that some State agencies have developed their own test methods that sources must
follow in order to demonstrate compliance with state specific requirements.
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E (Continued)
The mass emission rate of a particular metal pollutant from an incinerator stack can determined from the
concentration of the pollutant in the incinerator exit gas and the exit gas flow rate as expressed by the
following formula:
emission rate = (pollutant concentration) x (gas flow rate)
Although not included in Part 60 Appendix A, the test procedure entitled, Methodology for the
Determination of Metal Emissions in Exhaust Gases from Hazardous Waste Incineration and Similar
Combustion Processes, is recommended for determining metals concentrations in sewage sludge
incinerator exit gases. This test method, commonly called the multi-metals method, has been used
extensively to measure metals emissions from municipal solid waste, hazardous waste, and sewage sludge
incinerators. The multi-metals method has been incorporated into EPA's regulations governing the
burning of hazardous waste in boilers and industrial furnaces (the BIF Rule, 40 CFR Part 266, Subpart
H).
The multi-metals method collects both volatile and non-volatile fractions of metals in stack gases and can
be applied to the following metals: total chromium, cadmium, arsenic, nickel, manganese, beryllium,
copper, zinc, lead, selenium, phosphorus, thallium, silver, antimony, barium, and mercury. In this
method, the stack gas sample is withdrawn isokinetically from the emission source, with paniculate
emissions collected in the probe and on a heated filter, and gaseous emissions collected in a series of
chilled impingers containing solutions of nitric acid in hydrogen peroxide and of acidic potassium
permanganate. After sampling is completed, sample train components are recovered and digested in
separate front- and back-half fractions. Materials collected in the sampling train are acid-digested to
dissolve inorganics and to remove organics that may create analytical interferences. After digestion, both
fractions are brought up to their required volumes for metals analyses. Depending on the metals of
interest and necessary analytical sensitivities, the fractions are analyzed by atomic absorption spectroscopy
(AAS), graphite furnace AAS, inductively coupled argon plasma emission spectroscopy, and/or cold
vapor AAS. The analytical results from both fractions can be combined to yield metals values for the
entire train. The multi-metals method specifies a normal sampling run of one hour in duration, collecting
a stack gas sample volume of 1.25 m3. In many situations, greater sensitivity is needed to quantify metal
emission rates, therefore the method allows the sampling duration and sample volume to be increased to
4 hours and 5 m3, respectively to increase method detection limits. The multi-metals method expresses
resulting metals concentrations as milligrams per dry standard cubic meter.
The flow rate of an incinerator's exit gas can be determined by using EPA Methods 1,2, and 4 from 40
CFR 60, Appendix A. The following table briefly describes each of these methods.
TABLE D-l. EPA REFERENCE METHODS TO DETERMINE GAS FLOW RATES
Method
EPA Method 1
EPA Method 2
EPA Method 4
Method Description
Sample and velocity traverses for stationary sources
Determination of stack gas velocity and volumetric flow
pitot tube)
rate (type S
Determination of moisture content in stack gases
D-2
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E (Continued)
Determining pollutant mass in the feed to the incinerator
• Determined by multiplying the average metal concentrations in the sludge fed to the incinerator
while stack gas sampling took place by the amount of sludge fed to the incinerator while stack
gas sampling took place.
• Metal concentrations in sludge is determined by sampling and analysis of the sludge before it is
fed to the incinerator.
- Grab samples should be taken at various times during the test run and later combined to form
a composite sample for the run.
- The composite sample should be representative of the sludge that is actually fed to the
incinerator. One grab sample should be taken every IS minutes unless data is available to
indicate that less frequent sampling is adequate. The size of the composite sample must be
established so that "representativeness" is ensured.
^
- Sludge sampling should be conducted simultaneously with stack gas sampling. Since sludge
residence times and gas residence times of the incinerator can differ significantly, sludge
sampling should begin and end before stack gas sampling begins and ends; the "off-set" should
be equal to the difference between sludge and stack gas residence times.
- The resulting composite sample should be "flow-weighted" on a dry sludge basis. If the sludge
feed rate (dry basis) and the metal concentrations in the sludge both vary over the duration of
the performance test, the resulting composite sample will not be indicative of the metals
introduced to the incinerator if sampling is not flow-weighted.
- Flow-weighted samples require that the sludge feed rate to the incinerator be measured and
recorded and that the moisture content of the sludge be measured.
- Previous discussions of sludge sampling and compositing apply to all feed streams into the
incinerator (sludge and scum).
- Sampling, sample handling and preparation, and analyses procedures should primarily follow
EPA's "Test Methods for Evaluating Solid Waste - Physical/Chemical Methods, SW-846" and
the ASTM Annual Book of ASTM Standards. (OTHER METHODS MAY ALSO BE
APPLICABLE)
• The amount of sludge fed to the incinerator during a test can be determined by obtaining an
average of the sewage sludge feed rate during the performance test run and multiplying by the
duration of the test run.
- This method requires the use of a sludge feed rate monitor; precautions must be taken to
evaluate and ensure the accuracy of the monitor. The monitor must be certified for accuracy
and maintained and calibrated properly.
- In some cases, the amount of sludge fed to an incinerator could be determined by measuring
the difference in sludge feed tank levels before and after each test run. This method requires
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DETERMINING CONTROL EFFICIENCIES FOR PART 503, SUBPART E (Continued)
that the feed tank be sized such that accurate and precise level measurements could be taken
and that sludge was not added to the tank during the test run.
Documenting operating parameters of air pollution control devices (APCD) during CE performance
testing
• Not directly related to the determination of CE.
• Regulations require that permit conditions for APCD operating parameters be set by permitting
authority based on CE performance testing.
• The operating parameter values observed during the performance test establish "baseline"
conditions that can be used to compare with future operations. If these parameters deviate from
the values observed during the performance test, a difference in the measured CE value could
be indicated.
• Operating parameter values should be monitored and recorded as continuously as possible to
provide an indication of the actual parameter values, as well as the variability of these values
during sampling.
• The incinerator operator should clearly understand the importance of documenting APCD
parameter values during testing to future incinerator operations. The operator may want to
perform testing at unusual conditions to establish worst-case operating parameters that could
provide flexibility of future operations.
• Operating parameters depend on the type of APCD. See guidance in Chapter 7 of text.
D-4
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APPENDIX E
DETERMINING SITE-SPECIFIC POLLUTANT LIMITS FOR PART 503, SUBPART C
To be added later.
(This appendix will be sent to all recipients of this draft guidance manual.)
• U.S COVERNME.VTPRWTINCOFFICE:: 993 -720 -9".7/80210
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