U nrTed States Environmental Protection Agency Office of Water (WH-556 F) EPA 503/9-90/006 April 1990 Sludge Recycling Alternatives Report to Congress ------- REPORT TO CONGRESS ON SLUDGE RECYCLING ALTERNATIVES April 1990 U. S. Environmental Protection Agency Office of Marine and Estuarine Protection Washington, DC 20460 ------- INTRODUCTION In 1988, the United States Congress responded to the public’s increasing concern over ocean dumping by passrng the Ocean Dumping Ban Act (ODBA) The Act amended the Marine Protection, Research, and Sanctuaries Act (MPRSA) of 1972 which regulates ocean dumping, and requires that ocean dumping of industrial waste and municipal sewage sJudge be terminated by December 31, 1991 The U S Envirorrriental Protection Agency (EPA or the Agency) was assigned primary responsibilrty for implementing ODBA, arid since enactment several program actions have been initiated to ensure that the Iegis1ation’s statutory requirements are met Termination of ocean disposal of industrial waste has already been achieved, and thus EPA is now focusing its efforts on the nine sewerage authorities in New Jersey and New York which use ocean disposal to manage their sewage sludge ODBA required EPA. the states of New Jersey and New York, arid the sewerage authorities to enter into compliance agreements that would include a negotiated schedule to design, construct, arid implement an alternative system to ocean dumping by December 31, 1991 In case full implementation can not be achieved by this date, enforcement agreements will be required Given the stringent time frame, all nine sewerage authorities entered into enforcement agreements, the agreements were signed on or before August 4, 1989. The sewerage authorities agreed to implement interim disposal plans until long-term plans could be implemented Interim and final disposal plans, as well as compliance dates, are shown for each sewerage authority in Table 1. Currenity, most of the New Jersey sewerage authorities plan dewatering arid out-of-state disposal as the interim land-based alternative and incineration is expected to be the4r final land- based alternative. However, many of the New Jersey sewerage authorities are continuing to investigate other alternatives For example, the Passaic Valley Sewerage Commissioners are considering a proposal for gasification, and the Rahway Valley Sewerage Authority is considering a proposal for pe4letization In New York, the sewerage authorities will dewater and then utilize private vendors to manage ther sewage sludge in the interim. The malonty of responses received as a result of the request for proposal process indude chemical fixation, composting, pefletization, land application and in a few cases , Iandfllling and inoneration. Alternatives for long-term land- based disposal are still under study. ------- TABLE 1 CURRENT SLUDGE MANAGEMENT COMPUANCE SCHEDULES AND PLANS FOR INTERIM AND LONG-TERM IMPLEMENTATION INTERIM LONG-TERM SEWERAGE AUTHORifY DATE DATE Bergen County 3/17/91 Dewatering/ 1/1/96 Incineration Utilities Authority Out-of-state disposal Joint Meeting of 3/17/91 Dewatenng/ 2/10/98 Incineration Essex and Union Out-of-state Counties disposal Ljnden Roselle 3/17/91 Dewaterir ig/ 1/1/96 Incineration Sewerage Authority Out-of-state disposal Middlesex County 3/1 7/91 Chemical fixation/ 3/17/91 Chemical f xation/ Utilities Authority Landfill cover Landfill cover Passaic Valley 3/17/91 Dewatering/ 12/31/96 Incineration Sewerage Out-of-state Commissioners disposal Rahway Valley 3/17/91 Dewatenng/ 2110/98 Incineration (at Sewerage Authority Out-of-state Joint Meeting of disposal Essex and Union Counties) Nassau County 6/30/91 (50%) Dewatering/ 12/31/94 Under study Department of Public 12/31/91 (100%) Private venture Works New York City 12/31/91 ( 20 %)b Dawatenng/ 12/31/96 ( 50 %)C Under study Department of 6/30/92 (100%) Private venture 6/30/96 (100%) Environmental Protection Westchester County 12/31/91 Dewatering/ 9/15/96 Under study Department of Private venture Environmental Facilities $ Under its interim pLan, NCDPW plans to phase out 50% of its ocean dumping by 6/30/91 and 100% by 12/31/91 b Under its interim plan, NYCOEP plans to phase out 20% of its ocean dumping by 12/31/91 and 100% C LYndec rts long-term plan, NYCDEP plans to phase in 50% of its capacity by 12/31/96 and 100% by 6/30/98 2 ------- At a hearing on the FY90 Appropriations Bill, the Senate Appropriations Subcommrtt on VA. HUD, and Independent Agencies considered the Sewerage auttiormes’ Interim and final plans. Concern was expre that the sewerage authorities Selecting Incineration had done so wrthO t fully Considering other disposal alternatives. The Subcomnit ee stated that under ODBA and the Agency’s Pollution Prevention Policy, EPA has a responSlbilrfy to Centrfy environmentally sound sludge recycling alternatives and assist the sewerage authorities with their efforts to implement these atternatr es In Senate Conference Report ioi-i , the Subcommittee reques that EPA prepare a report on actions it has taken to work with the sewerage authorities to identify and implement sludge recycling alternatives Specii9celty, the Subcommittee requested the following • A description of the process that EPA is using to assist the sewerage authorrties, and • Economic and technologicel feasibility assessments of alternatives that have been proposed to reuse or recycle sewage sludge EPA ASSISTANCE IN SELECTING SLUDGE RECYCLING ALTERNATIVES During ODBA Oversight Hearings in May 1989, the House Merchant Marine Fisheries Committee, along with the Natural Resources Defense Council, asked EPA to provide the sewerage authorities with information and assistance on sludge management technology via a rouridtable meeting on land- based alternatives to ocean dumping. EPA Region II, with assistance from the EPA Office of Marine and Estuarine Protection (OMEP) and Office of Municipal Pollution Control (OMPC), responded by hosting a two-day meeting in November 1989, in East Rutherford, New Jecsey EPA invited the nine sewerage authorities, along with officials from other sewerage authorities already familiar with the operation of land-based sludge management systems. The meeting provided an open forum to identify and discusa the political, economic and technolOgK J difficulties associated with implementing land- based technolog e . A report summarizing the discussions at the rotindtable meeting was prepared and is induded as Attachment 1 EPA has also developed offlciai policies to provide guidance on sludge management issues. The Agenc s Pollution Prevention Policy promotes source reduction and recycling and states that AJtho .gh source reduction is preferred to other mane garment practices, b )e Agency recognizes The 3 ------- value of env,ronmentaity sound recycling. and is Committed to promoting recycling as a second prefer- ence, above beaUnenf control and disposal The Agency’s Beneficial Use of Sludge Policy is directed solely towards management of sewage sludge and states that • The U.S. Enwonmontal Protection Agency will active promote Those municipal sludge management practices That provide for The beneficial use of sludge while maintaining or improving eiw:ronmenta! quality and protecting public health .. EPA and other agencies (e.g, Department 01 Agriculture, Department of the Interior, National Science Foundation, Tennessee Valley Authority) have conducted and/or funded many research inrtiat;ves, workshops, conferences, and demonstration projects to si.ipport the Beneficial Use of Sludge Policy; results have been published in numerous EPA and external publications. These publications, which are available to the sewerage authorities, their consultants, and the general public through private publishers, National Technical Information System, General Pnnting Office, and other means, have focused on a variety of public policy and technical issues related to beneficial use of sewage sludge. Major topics addressed inckjde • Health effects associated with sludge and-application practices • Crop responses when grown on sludge amended soils • Use of sludge compost in turf production and maintenance • Use of sludge in and reclamation and biomass production • Application of sludge to forest lands • Technology assessment of n-vessel composting • Technology assessment of static pile and wrndow composting • Technology assessment of dual digestion • Technology assessment of chemical fixation and alkaline stabilization processes 4 ------- While EPA recogrnzes that it has a role in providing assistance to the sewerage authorities, it Should be noted that Section 405(e) of the Clean Water Act dearly states that - the determination o( the manner o( disposal or use of sewage sludge is a local determinabon - EPA cannot prohibit a local government from implementing a particular technology, and thus, the ultimate responsibility for evaluating and selecting a land-based sludge disposal technology lies with the local government. EPA FEASIBILITY ASSESSMENTS OF SLUDGE RECYCLING ALTERNATIVES Economic and technological fe oility assessments of various land-based sludge management technologies have been conducted for years as a result of EPA’s Construction Grants Program The program, which has provided over $52 billion in federal funding since 1972 for construction of publidy owned wastewater treatment facilities, requires a facility to conduct a full evaluation of potential alternatives before selection of a technology As a result, project- and area-specific economic and technical assessments have been conducted of various land-based sludge management alternatives. In addition, a number of area-wide Sludge management studies, including specific technology assessments and pilot tests, have been funded by EPk Examples include the Los Angeles/Orange County Metropolitan Area Regional Wastewater Solids Management Program, the San Francisco Bay Regional Wastewater Solids Study, and the New York/New Jersey Interstate Sanitation Commission Study. These project-specific assessments have not been collected or published by EPA in a central location; however, if a sewerage authority official requests information on the economic and technical feasibility of a technology, the Agency can help to direct the official to appropriate sources of information, and in many cases operating facilities. While the assessments are generally project-specific, the information can stifi provide a sewerage authority official with an appreciation for the positive and negative trsiie-offs associated with various technologies. In some circumstances. EPA has conducted rt8 own economic and technological assessments of proposed Construction Grants projects through the preparation of environmental impact statements. In eddition, EPA has supported state-of-the-art assessments and issued design guidance s l id cost estimating guidance applicable to most of the major sludge use and dispossi technologies. (Some of the major reference ciocuments that have been prepared are listed in Attachment 2) EPA is 5 ------- currently planning a technicai assessment of chemical fixation, a technology selected by Middlesex County Utilities Auttiorrty and under consideration by some of the other sewerage authorities The study, which is being sponsored by OMEP and OMPC, will be conducted in the summer of 1990 It will be useful to the sewerage authorities that are still evaluating their long-term disposal alternatives. 6 ------- ATTACHMENT 1 PROCEEDINGS OF THE SLUDGE MANAGEMENT ROUNDTABLE Held November 26-27, 1989 East Rutherford, New Jersey April 1990 U. S. Environmental Protection Agency Office of Marine and Estuarine Protection Washington, DC 20460 ------- EXECUTIVE SUMMARY In 1968, the United States Congress amended the Marine Protection, Research, and Sanctuaries Act (MPRSA) of 1972 by enacting the Ocean Dumping Ban Act (ODBA) to end the practice of ocean dumping of industrial waste and municipal sewage sludge. The U S Environmental Protection Agency (EPA) is delegated primary responsibility for the implementation of ODBA Currently, all Industrial-wa.ste generators subject to ODBA have stopped dumping, however, the following nine municipal sewerage authorrties en New Jersey and New York are still ocean dumping sewage sludge New Jersey • Bergen County Utilities Authority (BCUA) • Joint Meeting of Essex and Union Counties (JMEUC) • Linden Roselle Sewerage Authority (LPSA) • Middlesex County Utilities Authority (MCUA) • Passaic Valley Sewerage Commissioners (PVSC) • Rahway Valley Sewerage Authority (RVSA) New York • Nassau County Department of Public Works (NCDPW • New York City Department of Environmental Protection (NYCOEP) • WestchesterCounty Departmertof Environmental Facilities (WCDEF) ODBA established a framework for terminating ocean disposal of sewage sludge and prohibited ocean dumping of sludge after August 14, 1989, unless the municipal sewerage authorities had received a permit and entered into a compliance or enforcement agreement with EPA and the applicable state. EPA received complete permit applications for the transport and disposal of municipal sewage sludge from all nine municipal sewerage atjthorrties. Final permits were issued and enforcement agreements were signed by EPA, the states of New York and New Jersey, and the nine municipal sewerage authorities on or before August 4, 1989 The permits became effective on August 14, 1989; the enforcement agreements, in the forni of judicial consent decrees, were filed with the court by August 14, 1989 At an ODBA hearing on May 17, 1989, the U. S. House of Representatives Committee on Merchant Marine and Fisheries and the Natural Resources Defense Council (NRDC) asked EPA to convene a roundtable on land-based alternatives to ocean dumping of sewage sludge foi the nine sewerage authorities affected by ODBA.. Members of the committee reiterated the Attachment 1 1- e ------- recommen ion to the Honorable William Reilly, EPA Administrator, in a letter dated July 19, 1989, emphasi.zing the need 1o provide information and assistance to the authorities, ensuring that all potential avenues to safely manage se vage sludge on land are considered EPA. committed to the effective implementation of ODBA and sensitive to the concerns of Congress, the public, and the municipal sewerage authorities, agreed to host a sludge management roundtable. The roundtable convened on November 27-28, 1989, in East Rutherford, New Jersey This document summarizes the discussions that took place among participants at the rounCtable. Participants included the New York and New Jersey sewerage authority officials who are now faced with implementing land-based sludge management alternatives, guest speakers representing sewerage authorities already familiar with operation of land-based sludge management systems, state and federal regulatory officials acting as resources for the participants, a representative of the NRDC, and a roundtable facilitator. The public was invited to observe the proceedings The opinions expressed by the roundtable participants arid described herein do not necessarily reflect the opinions or policies of EPA. EPA, with the support of New York and New Jersey state officials, sponsored the roundtable and formed a planning group to develop the agenda. The planning group recognized the importance of acquiring input for the agenda. Thug, a questionnaire was produced and distributed to all nine municipal sewerage authorities and to NRDC. The respondents were encouraged to voice their concerns arid priorities through the completion of this questionnaire Using results from the questionnaire, the planning group identrfled three goals for the sludge management roundtable 1. To understand the factors contributing to the challenges being experienced by the municipal sewerage authorities in the development of Land- based sludge management. 2. To define various strategies for handling the challenges of land-based sludge management. 3. To define realistic actions to be pursued in the succesaful implementation of land-based sludge management alternatives. Based on those issues rated as most challenging and other issues identified by the respondents, the topic for discussion were 1-it Attachment 1 ------- focused on two rnaior areas (1) permitting and siting arid (2) technologies in relalion to public health and enwonmental concerns. The planning group formatted the roundtable in a manner that would stimulate productive discussion on strategies for implementing land-based management alternatives for municipal sewage sludges. The two-day roundtable consisted of three sessions. In addrtjon, a presentation on the status of proposed 503 sludge regulations followed the conclusion of Round 1 on the first day. Round 1 opened with introductions arid comments by Richard Caspe, EPA Region II Water Management Division Director He identified three overall objectives to be accornplisl-ied at the roundtable I To establish a network of people experiencing similar challenges. 2. To provide a forum for an open exchange of information and ideas 3 To provide an increased sensitivity to the issues being faced by the New York and New Jersey authorities among all involved with sludge management. Roger Dotan, general manager of the Central Contra Costa Sewerage District, California, served as the primary roundtable facilitator and began the dialogue with comments on the issues affecting land-based sludge management. During the discussion that followed, there was general consensus among the participants that the schedules to terminate ocean dumping are tight and, in most cases , more difficult than the schedules faced by the guest speakers. The sewerage authority representatives expressed confidence in their ability to meet the deadline for implementing long-terni alternatives. Their moat critical concern was meeting the agreed upon interim deadlines for ending ocean dumping. The New Jersey authorities were concerned about the even more stringent, state-mandated March 17, 1 1, deadline Producing dewatered sludge and hauling it to landfills was identified as the most realistic interim land-based alternative. The authorities noted that numerous difficulties are associated with implementing this disposal option, including siting dewstenng facilities and finding landfill sites, gaining public acceptance. obtaining necessary state and municipal permits, constructing the necessary facilities, and transporting the dawatered sludge to landfills. Members of EPA. the New Jersey Department of Environmental Protection, and the New Yoik State Department of Environmental Attachment I 1-ui ------- Conservation joined the guest speakers, sewerage authorities, and NRDC in the focus group diScussi n in Round 2 on the second day The purpose of the break-out groups was to discuss the issues introduced in Round i In greater detail The topica were divided into two sactions (1) Focus Group A — Technologies in Relation to Public Health and Environmental Concerns arid (2) Focus Group B — Permitting and Siting The two Focus Group A sessions addressed primarily public misconception arid acceptance; traditional technologies such as land application and incineration; less conventional technologies such as chemical fixation or gasification; techniques used in the successful implementation of a dewatering/laridfill disposal system, and concern for using the best technologies for long-term Land- based sludge management. The two Focus Group B sessions centered on the challenge of siting and implementing sludge management systems that adhere to both state agency permitting procedures and the consent decree schedules The sludge management roundtable addressed the concerns and challenges presented by all of the groups involved in the implementation of land-based sludge management alternatives (1) the city, state, and federal legislators who will make, or have made, decisions on sludge management, (2) the regulators who enforce the legislative decisions, (3) the sewerage authorities responsible for implementing sludge management alternatives, (4) the private contractors employed for sludge management. (5) the environmental and public health activists, and (6) the public, who, in many instances, believe that their health and personal property may be jeopardized by the recommended sludge management methods. Consequently, the rouridtable provided EPA, the state agencies, and NRDC with an increased sensit rty to the issues being faced by the New York and New Jersey sewerage authorities in pursuing and implementing interim arid long-term alternatives. The sewerage autnormes benefttteci from the in-depth information exchange that took place during the roundtable. Many strategies and possible endeavors were discussed. In addition to the strategies listed in Section 3, the following suggestions were made in the final round: 1 Establish an information eennghouse, possibly by or with support from EPA. 2. Continue the networking process that began at this roundtable. 3 Seek cooperation at all levels federal, state, local, and private sector. 1-iv Attachment I ------- 4 Consider the possibility of reglonalization in the development of IOng- .term sokrtions 5. Use multiple contractors and diversification in implementing siudge management options 6 Increase Sewerage authonty staffs for the negotiation and management of multiple contracts with the private sector. 7 Involve a City attorney knowledgeable in the local permitting regulations for negotiating contracts 8. Increase public awareness of the sewerage authorities’ decision-making Processes and sludge management activities, EPA Should be more involved in providing nlormation to the public on the public health and environmental effects of various sludge management technologies The New York and New Jersey sewerage authorities expressed their gratitude to EPA for holding the roundtable and reiterated a firm commitment to m <’ting their deadlines and si .iccessfufly terminating ocean durn g. The sewerage authorities strongly voiced their desire to implement the most environmentally Sound sJudge management alternatives and expressed a willingness to remain Open-minded and flexible in their Implementation plans They also expressed the hope that the regulators maintain the same open-mindedn and flexibility Attachment 1 ------- TABLE OF CONTENTS Page EXECUTiVE SUMMAPY . i-i 1 0 INTRODUCTiON 1-1 20 ROUNDTABLE ORGANIZATiON 1-5 2.1 Attendees . 1-5 22 Key Issues . 1-6 22.1 Results of the Questionnaire 1-6 222 Development of Key Issues Based on Questionnaire Results 1-9 23 Roundtable Structure and Process 1-9 30 ROUNDTABLE DISCUSSION SUMMARY 1-12 3 1 Round 1 The Challenge 1-12 311 Facility and Landfill Siting 1-13 3 1 2 Public Acceptance 1-13 3 1 3 Private Contractors 1-14 3 1 4 Conclusion 1-15 3.1 5 New Sludge Management Regulations 1-15 32 Round 2 Developing Alternative Strategies 1-16 32.1 Focus Group A Technologies in Relation to Public Health and Environmental Concerns 1-16 3 2 11 Public Health and Environmental Concerns 1-16 32.12 Technologies 1-17 3 2 1 3 Dewatering/Landfill Disposal System 1-17 32.1 4 Alternative Selection 1-18 322 Focus Group B Siting arid Permitting 1-19 322 1 State Requirements 1-19 3.2.22 Time Constraints 1-20 32.23 Public Acceptance and Siting Strategies 1-21 33 Round 3: Realistic Actions to Pursue 1-22 APPENDIX A Roundtable Planning Group Members 1-24 APPENDIX B Roundtable Attendees . 1-25 1 -vi Attach merit 1 ------- LIST OF TABLES Page TABLE 1 CURRENT SLUDGE MANAGEMENT COMPUANCE SCHEDULES AND PLANS FOR INTERIM AND LONG-TERM IMPLEMENTATiON 1.3 TABLE 2. RESULTS OF THE QUESTiONNAIRE 1-7 TABLE 3. ROUNDTABLE AGENDA AND FORMAT 1-10 AttacS ment 1 1 -vii ------- 1.0 INTRODUCTION In 1988, the United Stales Congress amended the Marine Protection, Research, and Sanctuaries Act (MPRSA) of 1972 by enacting the Ocean Dumping Ban Act (ODBA) to end the practice of ocean dumping of industrial waste and municipal sewage sludge The U S Environmental Protection Agency (EPA) is assigned primary responsibility for the implementation of ODBA The act assigns a number of tasl s to the agency, including establishing compliance and enforcement agreements, issuing and enforcing permrta: collecting ocean dumping fees, and conducting monitoring, research and surveillance actryrties, as weB as preparing Reporta to Congress. ODBA requires a compliance or enforcement agreement for all industries or sewerage authorities that use ocean disposal to manage their waste. The agreements must include a negotiated schedule to terminate ocean disposal by December 31, 1991 The schedule must include plans for the design, Construclion, and full implementation of a long-term, land-based, alternative system for the management of industrial waste or sewage sludge Currently, all industrial-waste generators subject to ODBA have stopped dumping, howeier, the following nine municipal sewerage authorities in New York and New Jersey are still ocean dumping sewage sludge New Jersey • Bergen County Utilities Authority (BCUA) • Joint Meeting of Essex and Union Counties (JMEUC) • Linden Ros Ie Sewerage Authority (LRSA) • MCClesax County Utilities Authority (MCUA) • Passaic Valley Sewerage Commissioners (PVSC) • Rahway Valley Sewerage Authority (RVSA) New York • Nassau County Department of Public Works (NCDPW) • New York City Department of Environmental Protection (NYC DEP) • Westchester County DepartmentofEnvironmentai Faol ties (WCDEF) OOBA established a framework for terrniriathg ocean disposal of sewage sludge and prohibited such dumprng after August 14, 1989, unless the muniopei sewerage authorttiee had received a permit and entered into an agreement with EPA and the applicable state EPA received complete permit applications for the transport and disposal of municipal sewage sludge from all nine municipal Attachment 1 1-1 ------- sewerage authorities. Enforcement agreements were signed by EPA Region II, the U S Department of Justice, the states of New York and New Jersey, and the nine municipal sewerage authorities on or before August 4, 1989 Permits were issijed to the nine authorities on or before August 4, 1969, arid became effective on August 14, 1969. EPA. along with the affected states, negotiated the enforcement agreements with the municipal sewerage authorities to ensure that the authorities will aggressively pursue the implementation of alternative land-based sludge management methods as required by O08& The enforcement agreements require that the municipal aijthornies specificeil’y define thor long-term plans by May 1,1991 The municipal sewerage authorities’ interim and long-term plans of action, as well as compliance dates, are detailed in Table 1 The New Jersey Oceen Sludge Dumping Elimination Act requires a complete cessation of ocean disposal by March 17, 1991 A companion piece of legislation, which amends the New Jersey Water Pollution Control Act, requires the submittal of a plan for land-based sludge management by Apnl 30, 1989 Currently, most of the New Jersey sewerage authorities plan dewatering and Out- of-state disposal as the interim land-based alternative, while incineration is expected to be ther final land-based alternative However, many of the New Jersey authorities are continuing to investigate other alternatives. For rnpIe, PVSC is considering a proposal for gasification, arid RVSA is considering a proposal for pelletization. The New York sewerage authorrties currently plan to dewater sludge and utilize private vendors to manage their sewage sludge in the iritenm. The majority of the responses received as a ree&itt of the request for proposals (RFP) process comprise chemical fixation, compostirig, pelletization, land application, and in a few cas landfilling and incineration. Alternatives fo long-term disposal are still under study Land-based sludge management alternatives are use and disposal technologies that do not involve dump4ng sludge ‘rita the ocean Disposal methods include incineration of sludge with ash thspOaaI in a landfill and direct landfilllng of sludge. Land application and land reclamation are other common diepoesi method& 8ecause of the benefits derived from land application and land reclamation, these disposal m ods are commonly referred to as ‘beneficial use.’ It shou be noted that benefits may be derived from other alternatives as wet For mple, energy can be recovered from some indnerators and landfills. 1-2 Attachment 1 ------- TABLE 1. CURRENT SWDGE MANAGEMENT COMPLIANCE SCHEDULES AND PLANS FOR INTERIM AND LONG-TERM IMPlEMENTATiON M SA A LONG ERM *TE Bergen County 3/17/91 Dewatering/ 1/1/96 Incineration ulilities Authority Out-of-state disposal Joint Meeting of 3/17/91 Dewatering/ 2/1 98 Incineration Essex and Union Counties disposal Linden RosalIe 3/17/91 DawaterinaJ 1/11% Incineration Sewerage Authority Out-of-state disposal Middlesex County 3/17/91 Chemical fixationl 3/17/91 Che mcal fixatiori/ Utilities Authorrty L.andflhl cover Landfill cover Passaic Valley 3/17/91 Dewatenno/ 12131/96 Incineration Sewerage Out-of-state Commissioners disposal Rahway Valley 3/17/91 Dewatenng/ 2 /1 W98 Incineration at Joint Sewerage Authority Out-of-state Meeting of Essex disposal and Union Counties Nassau County 6/30/91 (50%) Dewatemmn / 12/31/94 Under study Department of Public 12131/91 (100%) Private vent jre Works New York City 12/31/91 ( %)b Dg/ 12/31/96 ( 50 %)C Under study Department of 6/3 (100%) Private venture &3Cd98 (100%) Environmental Protection Westchester CourTty 12/31/91 DewatennaJ 15/96 Under study Department of Private venture EnvironmentaJ Facilities ‘ Under its interim plan, NCDPW plans to phase out 50% of its ocean dumping by 6/30/91 and 100% b nd rflenm plan, NYCDEP plans to phase out 20% of its ocean dumping by 12/31/91 and 100% C nder its ‘ong-term plan, NYCOEP plans to phase ri 50% of its r pecfty by 12 /31/96 and 100% by & 98. Attachment 1 1-3 ------- The technologies for processing sludge prior to land application or reclamation to control pathogen. very depending on site cond- tions. end use, and sludge quality. Those in common use include digestion or billzation, compostrng, heel or air drying, and pelletization. Sludge must be dewatered prior to the implemen- tioii 01 incin ratjon and the rnalorlty of land apphcation or reclamation alte es. Implen,en tjon of land-based sludge mar agemei-it alternatives, as well as the proc aee used to prepare sludge for these options, can be hindered by a variety of difficulties. For example, because New York and New Jersey are such densely populated areas, land- fill apace very lImited. Also, concerns regarding human health and environmen J impacts casi create significant public opposition to alternatives. EPA recognizes the difficulties associated with implementing land-based sludge management alternatives. At an ODBA hearing on May 17, 1969. the U S. House of Represenita- trves Committee on Merchant Manna and Fisheries and the Natural Resources Defense Council (NPDC) asked EPA to convene a rourid ble on land-based alternatives to ocean dumping of sewage sludge for the nine sewerage authorities affected by ODB& Members of the committee reiterated the recommendation to William Rally, EPA Administrator, in a letter dated July 19, 1969, emphasizing the need to provide information and assis nce to the authorities. ensuring that all potentiai avenues to safely manage sewage sludge on land are Coneidered. EPA. committed to the effective implemen tion of QOBA and sensitive to the concerns of Congress, the public, and the muniopai sewerage authorities, agreed to host a sludge management roundteble. The round ble convened on November 27-28, 1969, in East Rutherford, New Jersey. This document summarizes the discussion that took place at the rounC b1e. The roundteble participants included the New York and New Jersey sewerage authority officials who are now faced with implementing land-based sludge management alternatives, guest speakers representing sewerage authorities aIr y familiar with operation of land-based sludge management systems; te and federal regulatory officials acting as resources for the partidpants; a repreeentstive of NRDC; and a roundtable facililator. The pub c invited to observe the proceedings. The oprnions pre by the roundteble participants and described hereln do not necessarily reflect the opinions or policies of EPA. 1-4 Attschmerit 1 ------- 2.0 ROUNOTABLE ORGANIZATION EPA, with the support of New Yorl and New Jersey state officials, sponsored the roundtable and formed a planning group to d e4op the agenda. The planning group consisted of person from EPA. the New Jersey Department of Enwonmentaj Protection (NJDEP), the New York State Department of Environmeritsi Conser,a on (NYSDEC). and corisuttarn are shown in Appendix A. Planning the roundtable involved three tasks (1) entffy1ng the roundtable attendees, (2) Cemifying the key issues, and (3) determining the roundtaole structure and process. 2.1 AUENDEES Categonceily, there were three groups of attendees at the sludge management roundtable: 1. DISCUSSION PAR11CIPANTS The discusaion participants consisted of the rounctable facilitators, guest speakers, sewerage authority officials, and a rePresentative from NROC. The primary facilitator had the responsibility for keeping the roundtabie discussions directed to the appropriate issues throughout Round I and Round 3 and for facilrtating Focus Group A during Round 2. A second facilitator directed Focus Group B dunng Round 2. The gu speakers were officials from various arees of the United States who had either successfully implemented land-based sludge management systems o were in the process of implementing such programs. They were invited in order to share their penences with the New York and New Jersey sewerage authorities. The sewerage authority officials e from the nine New Jersey arid New York municipalities affected by the 006k A representative from NRDC was induded in the discuseion group beceuse of the organizations involvement in the initIation of the roundtable mestlng. 2. RESOURCE PEOPLE Resource people consisted of regulatory and enforcement officials arid technology ei perta involved with various aspects of sludge management or ocean dumping. This group Included repreeentatves from EPA H quarters, EPA Region Ii, and the tes of New York, and New Jersey. Attachment 1 1-5 ------- 3. OBSERVERS Obser,ers were representatjves from an array of public arid pirvate interest groups concerned with the issues of ocean dumping and sludge management EPA Region I I provided the planning group with a list of more than 800 indrvidual who had attended public meetings and/or permit hearings on sludge manage- ment Issues or who had otherwise pessed an inta in 008A Implementetion during the past year Invitations e sent to au names on the mailing list. Names and organizations of all roundtable attendees are provided in Appendix B. 22 KEY ISSUES The planning group recognized the importance of acquiring riput for the roundtable agenda from the nine New Jersey and New York sewerage authorities. Their input was requested to more dearly define the goals of the roundtable and increase their comm itment to participation The planning group pi oduced a questionnaire and distributed it to all nine municipal sewerage authorrties and NRDC. The respondents were encouraged to voice their concerns and priorities through the completion of this quest,rrriaire. 2 2. 1 Results of the Questionnaire The planning group de eIoped a list of 10 items that the New York and New Jersey authorities arid NRDC were asked to rate in terms of their importance as maior challenges to the implementation of land-based sludge management alternatives. The respondents were also asked for suggestions regarding how the roundtable cou assist in addressing these challenges and what other topics they felt should be indudad in the roundtable discussions. Au nine municipal sewerage authorities completed the questionnaire (see Table 2). Perceived environmental risks and public health concerns ranked highest in the questionnaire responses. The publics misconceg- tions and resulting opposition affects several areas of land-based sludge management: facilfty siting, the ability to obtain necessary permrts facility flnandng, and the need for immediate action. The .ãAR U County Department of Public Woiis (NCDPW) sicpresaed a specific concern regarding the siting of lftiea, daiming t there wes no time allowed ki the consent decree for educeting the public on erMronmentsl and health safety , and that the media misrepresents sludge managernent osusing unnecessary public apprehension. The Linden Roesile Sewerage A thortty (LRSA) ted that they aipect ‘strong. . . negative reaction from various groups arid the general public’ In itt1ee siting. 1-6 Attachment 1 ------- TA&E 2. RESULTS OF THE QUESTiONNAIRE QM _____ I MQ PV8C -- H WW NYU) il POTM. Ah 1 1 Fy i S 5’ 5 4 2 2 5 5 5 38 42 2 28 prod S 3 1 5 5 2 3 5 5 34 38 mliil uü 3Far co 2 3 3 3 I I 3 3 4 28 28 9 4 3 3 4 1 5 8 5 5 36 39 5 5 5 3 4 I 5 4 5 5 37 41 3 P4ssd v . 4 4 2 2 4 1 4 2 2 28 28 8 5*as - m p 4ds — b 7 5 3 6 4 3 2 5 5 5 37 41 3 __ - P 8Y ___ 4 3 2 4 3 6 5 4 3 33 37 7 Iu,4.d1b.d* G a- - — 9daA 3 3 2 2 3 1 1 3 3 21 23 10 1OPoi Sd V Vfl 3 8 6 4 2 6 5 5 5 39 43 1 b sd On a S S I 56 bSVIO * hhjt4 ------- AJong with the problem of public misConCept ns, there were sed’er other concerns expressed regarding site location planning The New York City Department of Er v,ronmen j Protection (NYCDEP) noted that other states are beginning the process of tightening their regulations for acceptance of out-of-state sludge The NCDPW defined interim facilrty siting as their most drfficuft challenge because landfill space may be Impossible to obtain Since landfllling is a common irrWim solution, the NCDPW suggested that EPA review and produce an up-to-date list of landfill locations and their specifications as a resource for the sewerage authorities. The Westchester County Department of Enwonmental Facilities (WCDEF) also commented on having drfficutty finding an acceptable interim landfill site. Both the L.RSA and the NYCOEP noted that the public review process nec c ry for obtaining permits hinders quick decisions on permit applications. Respondents commented that facility financing also depends on public support, negative reaction to rate increases can have major implications for projects Atthough present-day technologies proved to be the least challeng- ing issue in the questionnaire, tne NYCDEP expr sed a concern that the technologies available today could become unusable in the future owing to changing sludge regulations. Sewerage authorities commented that future federal and state regulations may prevent the exporting of sludge products Out of state The marketing of sludge products appeared to be another issue of concern The LRSA felt that sludge marketing was not a realistic possibility The WCDEF stated that sludge qualrty limrts marketing options. The PVSC expressed concerns regarding the length of time needed to develop markets for sludge products and how to subcontract to private vendors. The NYCDEP pressed an addrtionai concern regarding markets, stating that as more federal sludge products are produced existing markets will suffer. The NCDPW acknowledged that sludge product marketing would be a viable alternative unless changes in the federal sludge regulations affect current markets The authority requested that the roundtable clarify the proposed EPA sludge management regulations and provide information on how to effectively use private contractors! vendors fo tasks such as con ucting and operating facilities, transporting sludge, and marketing sludge products. The WCDEF suggested that it would be helpful if the regulators would declare a clear position on the acceptability of management options and the necessary sludge characteflstlca for sach. (The bJs of the federal sludge management regulations i discussed in Section 31.5.) The NCDPW strongly suggested induding Interim planning fix product management in the roundtable discussions. 1-8 Attachment 1 ------- The PVSC expreesed an Iritereet In C rYtracts that re4ate to large-. scale lanafIlling or other thaposal optiona Suggestec thacussion topics were single versus multiple contracts, the appropriate length of contracts, performance bonds, and single versus multiple Sludge rnanagemern options. It recommended that examples of various critracts and Specifications for managernent alternatives be brought to the roundtable for review by the participants 2 2.2 Development of Key Issues Based on Questionnaire Results Using the information from the questionnaire, the planning group identified three goals for the roundtable 1 To fully under nd the ctors contributing to the challenges being experienced by the municipal sewerage authorities in the development of land- based sludge management. 2. To define various strategies for handling the challenges of land-based sludge management 3. To define realistic actions to be pursued in the sUCCes8fuI — lementabon of land-based Sludge management aflernatives. Based on those iseues rated as most challenging, and other issues identified by the respondents, the topics for discussion were focused on two rnaior areas: (1) permitting and siting and (2) technologies in relation to public health and environmental concerns. 2.3 ROUNDTABLE STRUCTURE AND PROCESS The planning group formatted the roundlable in a manner that wou stimulate productive discussion on strategies for attaining land-based management solutions for wastewater treatment plant Sludges. The 2-day roundtable consisted of three sessions (see Table 3). A presentation on the tu8 of future 503 sludge regulations followed the condusion of Round 1 on the first day During the first and third rounds, the sewerage authorities, the olitator, and the guest speakers set at the table; the resource people and observers were seated around them. The dialogue induded the sewerage authorIties. guest speakers, and the facilrtator. The resource people participated in the discussion only at the request of those seated at the table. Attachment 1 1-9 ------- TABLE 3 ROUPIDTABLE AGEN . AND FO AAT DAY I ROUND 1 THE CHALLENGE OB,JECT1VE To fully understand the factors contributing to the challenges being cpenenced by muniopal sewerage authorities in developing land-based sludge management. • Welcome and opening remarks • Introduction of rouridtable participarita • Discussion of roundlable procedures and issues • Open discussion • Conclusion and consensus of Round 1 • Reception • Presentation regarding proposed 503 sludge regulations DAY 2 ROUND 2: DEVELOPING ALTE 4AT1VE STRATEGIES OBJECTiVE To define various strategies for handling the challenges of land-b ed sludge management • Rotation of sewerage authorities betwesn two focus groups Focus Group A Permitting and Siting Focus Group B Technologies in Relation to PublIc Health and Environmental Concerns ROUND 3: ALJST1C ACTiONS TO PUASLE OBIJECT1VE. To define realistic actions to be taken for the implementation of land-based sludge management. • Open d ecuse on • Conduelons 1-10 Attachment 1 ------- Round 2 consisted of two focus group8 Focus Group A discussed pemlitbng and sitng, and Focus Group B discussed technologies in relation to public health and en’ ,ronmen j risks EacI group had two sessions, one in the morning and one in the afternoon. The guest Speakers fld the resource people were assigned to a focus group based on their expertise and remained in that group for both sessions. The sewerage authorities ro ted between the two focus groups to discuss both groups topics. In the focus group sessions, the resource people sat at the table and entered into the discussion wrth the sewerage aUthorTbee, Quest Speakers, and the facilrtator in each group. Although observers were not allowed to participate directly in any of the Sessaon , they were invited to submit questions or issues for discussion. Attachment 1 1-11 ------- 3.0 ROUNDTABLE DISCUSSION SUMMARY The roundtable opened with iniroductioris and comm by RIChard Caspe, EPA Region II Water Management Division Director He identified three overall objectives to be accomplished by the roundtable 1 To establish a ngtwork of people experiencing similar challenges. 2. To provide a forum for an open exchange of lnfo(Tnatlon and ideas. 3 To provide an increased sensitivity to the issues being faced by the New York and New Jersey authorrties among all involved with sludge management 3.1 ROIJND1: THE CHALLENGE Roger Dolan, general manager of the Central Contra Costa Sewerage District. Cairfomia, served as the pnmary roundtable facilitator and began the dialogue with comments on the issues affecting land-based sludge management He then requested that the participants introduce themsetves to the other roundtable members. The representatives of the sewerage authorities and NRDC summanzed issues that they wished to see eddressed at the roundtable. Guest speakers from other sewerage authorities from around the country, invited beceuse of their experiences in implenieriting land-based sludge management technologies, provided brief descnptions of their backgrounds. During the discussion that followed, there was general consensus g the participants that the schedules to terminate ocean dumping are tight and, n most ceses . more drfficult than the schedules faced by the guest speakers. The sewerage authority representatives expressed confidence in their ability to meat the d line for implementing long-term alternatives. Their most criticel concern was meeting the agreed upon inteiim d linee for ending ocean dumping. The New Jersey authorities were concerned about the ewen more stnngant, state-mandated March 17, 1991, d line. Producing dewatered sludge and Pieuling it to landfills was idenVfied as the most resilatlc interim land-based alternative. The authorities noted that numerous difficulties are associated with implementing this dieposal option, induding siting dewatenng facilities and finding landfill sites, gaining public a ptence, obteining rieceeeary te arid mun permits. con&ru ng the neceasary faoll es, and transporting the dewatered sludge to landfifls. 1-12 Attachment I ------- 311 Facilityand Landfill Siting Landfill siting was Identrfied as a critical issue by all of the New York and New Jersey sewerage authorities Landfill sites are severely limited in both states In New Jersey, landfilling is prohibited except in the case of emergency or overriding circumstances. fl is becoming increasingly difficult to find out-of- state landfills, Pennsylvania has recently enacted an executive order temporarily banning other states from access to their landfills The authorities also stated that finding locations to build dewatering facilities presents a significant challenge While it may be possible for some of the needed facilities to be built at the wastewater treatment plants producing the sludge, New Jersey and New York authorities with facilities in residential areas may face intense public opposition to potential odors and the increased truck traffic necessary to haul the dewatered sludge to disposal sites The guest speakers discussed how facility siting can be undertaken by either private contractors or the sewerage authorities In some cases, a contractor may be more successful than the sewerage authority in locating a facility or landfill site In other situations. the authority’s ability to deal with municipal officials may be needed to acquire a site Cooperation between the sewerage authorities and political officials is clearly necessary Unfortunately, most politicians do not typically become involved unless a site is chosen in their locality NJDEP officials have stated that selection and implementation of a land-based management alternative is the responsibility of the sewerage authorities, pursuant to the New Jersey Ocean Sludge Dumping Elimination Act Consequently, the state has declined to intercede in out-of-state management options This position is of concern to the sewerage authorities, for they believe that a team effort is needed to successfully implement land-based disposal ahernatives. 3 1 2 Public Acceptance Clearly, gaining public acceptance of sludge management alternatives is not easy The public may equate sludge with sewage and oppose any land-based disposal or use in their own backyard - The participants agreed that it is essential to educate the public about land-based sludge management alternatives. However, credibility is a key issue; the public is reluctant to believe the municipal sewerage authorities. The guest speakers pointed out that it is far more effective to invotve independent sources that have positive public images to answer the public’s questions and provide information. The guest speaker from the State of Attachment 1 1-13 ------- Washington described a project whereby 118 sewerage authorities funded the University of Washington and Washington State Univer- sity to support research and public information/education pro- grams It was suggested during the roundtable discussion that EPA become more involved in educating the public and that per- haps the ocean dumping fees paid by the sewerage authorities could be used to implement a public, information/education program Public opposition can be a major impediment in using facility sites Considering the short time frames for implementing New York’s and New Jersey’s interim plans, gaining public acceptance may be especially difficult The NCDPW commented that it appears to the public that one is asking for the publics acceptance after the plans have already been put into place NRDC stated that it is critical to involve the public in the initial planning stages, and noted that the NYCDEP has effectively involved the public via the forma- tion of a citizens advisor-y committee Another sewerage authority agreed with the value of having such a committee but also pointed Out that once a site is chosen, the anticipated impact on the affected local community will still cause Opposition 3.1 3 Private Contractors Using private contractors to build facilities and/or provide for ultimate disposal appears to be a viable solution for the New York and New Jersey sewerage authorities in meeting their interim plan deadlines, however, the sewerage authorities noted several areas of concern regarding the use of private contractors the RFP process, legal restrictions, contract writing, using multiple contractors, contractor versus authority responsibilities, and staff availability to coordinate and manage contractors Some of the guest speakers provided examples of RFPs and contracts to the participating roundtable sewerage authorities In choosing a contractor through the RFP process, the issuing sewerage authority first determines which proposals appear to be reasonable and responsible and then interviews the candidates. The authorities were advised by the guest speakers to look at the contractor’s applicable experience, responsiveness to the proposal request (e g, Do they have a permitted site’ Do they have the necessary subcontractors who can pass regulatory requirements’ 7 ), and the price for the job. In New York, accepting a higher bid requires a legal opinion. In New Jersey, a higher bid can be accepted if lower bids are not submitted by responsible bidders. Several of the guest speakers emphasized the need for multiple contractors If a contractor defaults on his contract or it is determined that a contractor should be replaced because of poor performance, a back-up plan must be in place. Ultimate 1-14 Attachment I ------- management responsibility rests with the Sewerage authority, not with the contractor The guest speskers provided some veluable success stones concerning the use of private contractors, but in many cases those Sewerage authorities were not under the same time constraints that the New York arid New Jersey authorities face Requesting proposals from the private sector, Setting up contracts, and providing effective management Of contractors 8 time-consuming In ximo the New York and New Jersey authorities have low staff levels as compared to the staffing levels of the guest speskers and they may have to rely on consii nts to help manage con acto 3.1.4 Condusion In concluding Round 1, the sewerage authorrties identified the f lIowing issues for continued discussion during the second day sessions • Attaining public acceptance of sites in order to meet compliance schedules. • Managing contracts (setting up contracts, handling sludge production vanability, single versus multiple hauling Contracts, spill prevention/response plans) • Dealing with critical time constraints in the implementation process. • Exploring cooperative regional efforts. • Identifying pubhdy acceptable short-term strategies for the sludge management • Under nding the perceived and reel public concerns of marketing sludge producta • Establishing an information network for land-based sludge management 3.1 5 New Sludge M agement Reguldons Following the condusion of Round 1 of the roundtable, a repreaentetive of EPA’s Office of Water Regulations and Standards presented an update on the tus of the proposed federal sludge management regulations. Pursuant to a tutory directive in SectIon 406 of the Cleen Water Act. EPA proposed new risk-based technicel sludge regulations in February 1999. Comments on the proposed regulations are now being eddreesed, and EPA cpects to Issue the regulations in final form in October 1991 Once Attachment 1 1-15 ------- IssUed, these regulations will appesr at 40 CFR Part 503 and will esl an minimum federal standards for the use and disposel of Sewage sludge when applied to land, thstnbuted and marketed, placed in sludge-only landfills or on surface disposel sates, or ifl flerated. In addition to the 503 regulations. EPA also propos in August 1968 the Muniopal Solid Waste Landfill Rule. which regulates all sewage sludge to be tandfllled EPA expects to issue the final rule in May 1990. 32 ROUND 2: DEVELOPING ALTERNA11VE STRATEGIES Members of EPA, N JDEP, and NYSDEC joined the guest speakers, sewerage authorities. and NRDC in the focus group discussions on the second clay of the roundtable. The purpose of these break- out groups was to discuss the issues introduced in Round 1 in greater detail. The topice were divided into two Sections (1) technologies in relation to public health and environmen l concerns and (2) permitting and siting 32.1 FocusGroupA: Technologies ki Relation to PublIc Health and En*onmen The two Focus Group A sessions primarily addressed the issues of public misconception and acceptance; traditional technologies such as land application and inaneratlon; less conventional technologies such as chemical fixation or coal gasification, the techniques used in the successful implementation of a dewatering/ landfill dispossl system: and the sewerage authorities’ concern for using the best technologies for long-term land-based sludge management plans. 3.2. 11 Public HeaWi and Environmental Concerns Guest speakers cpenenced in the use of land application, con’tposting, and inonerabon discussed ther operations. These pract)ces frequently generate public opposition: consequently. the authonties often cannot enlist the support of the local pollbcians or officials. In many cases , opposition stems from the fact that many people equate sludge with hazardous waste. They assume that if sludge is unesfe for ocesn disposal, it is also unsafe tar nd-bssed management alternatives. The public fasrs Uiet composted sludge will poison the food chein and sludge incineration will release toians into the air. It is essential to educate the public on the regulations conti ’olling the quality of sludge and land-based management options No matter what regulations are in place, h er, It will usuAlly be difficult to gain public ptence, pertlcular$-y when matanal is 1-16 Attachment 1 ------- moved from one juriadiction to ariotj,e’ A poesible way to convince people in another juriSdiction to accept sludge is to ShOw them that the very Junathotion that produces the materiaj is aiso using a substasmaj amount M authority should be aware that this approach could backfire and leed to opposition to currer tJy accepted in-etate pra cet The sewerage authorities emphasized the need for credible inrmanon sour and suggested that EPA become more involved in educating the public, it is crucial to gaining public acceptance that people receive ptanaijong in simple terms. scientific jargon tends to ceuse confusion. Also, terminology modifications were suggeet . The word s/udge Should be replaced with a more positive word and the term solid waste should be avoided. Ae(ernng to sludge as waste creetee a problem in perception, it implies that sludge must be disposed of and cannot be used for beneficial purposes. [ EDITORLAL. NOTE. While adopting more positive terminology may be beneficial from a public acceptance standpoint, the use of s/udge or so/id waste can be impor nt in maintaining disposel options. In New York State, referring to sludge as solid wa_ste allows a municipality to enter unto long-term cornracta for privatization under the New York State Municipal Law 12 V. If the material was not c’ass’fled as a solid waste, the sewerage authorities would not have this option] 32.1.2 Technologies In the discussion of new technologies, it was evident that the sewerage authorities were keenfy interested in au possible alternatives, especiaRy beneficial use. Se.wal newer technologies were mentioned, induding gasification of sludge to produce energy and an inert, glaaallke material, and a Japanese process that turns incinerator ash into glassy. sendy material suitable for use in tile. Incineration is the long-term land-based alternative for many New Jersey authorities. The sewerage authorities and guest speakers discussed the venous types of furnaces and the quality of air emissions and ash that each produ , as w l as the problems associated with ash hauling and lanCflhIlng. 3.2.1 3 Dewe 1ng/Lanc1flhl In 1987, the City of Los Mgeies ed time constreinta similar to those of the New Jersey and New York authoit es’. To quickly terminate oc durnp.ng, Los Angeles de eloged a program for sludge dewataring and landfill dispoesi. The Los Angeles guest speaker deacilbed the clty s cpenence in detail, answering qu ons arid providing copies of RFPs. Attachment 1 1.17 ------- The Loe AJ geles guest speakers description of the RFP process for aecunng the services of multiple contractor S induded details such as average contract size, duration of contracts, division of work based on daily variabilmes of sludge volume, and meeting city procurement requirements. The speaker explained that an attorney from the Board of Public Works was assigned exclusively to the s orage authority for the negotiation and compilation of contracts. Thia helped to ensure that the authority was in compliance with city requirements during every step of the pr000as When the authority went before the Board of Public Works with l recO imendatlons, the city attorney was present and handled all legal questions, testst ang to the compliance of the re- commendations with all city procurement requirements. The landfill dispoesi process also described in detail, addressed truck-hauling logistice that included establishing routes, monitoring, weighing, spill-response plans, schedules, costs, and loading facilities The guest speaker emphasized that using multiple contractors established a competrtr e environment that promoted better performance and re abilrty. 3.2.1 4 Aiternative Selection The sewerage authorities discussed various sludge management technologies currently available and the possibility of newer and better technologies being developed. The New Jersey authorities raised a concern that their choic für meeting the legislative requirements to end ocean dumping might not be the best long- tern alternatives with respect to the environment and public hesith They commented that the consent decree schedules might not allow than enough time to thoroughly investigate all possible alternatives. There ls little time for the sewerage authorities to effectively work together, sharing their knowledge of new technologies and options and developing potential regional project alternatives that might result in signrficent cost savings. In addition to the consent decree scheduling constraints, there are other pressures to move quickly into long-tern programs. For mple. the high eicpenee of the intenm solution necessitates the changeover to a long-term solutlon as quickly as possible. Also, it ia not known how long landfills will continue to be available: before the limited space filled, sewerage authorities must have alternative solutions In place. EPA belIeves V ’wt the negotiated agreements allow sufl .clent tlme for the selection of long-term land-based technologies. Some of the guest a rage authorities disagreed, based on their pest cperlences in researching and Implementing related programs. The group discussed further the reality of the cOnsent decree estrainte In regard to making choices and the problems of changing alternatives In m streem. With reference to technologi- osi assessments It wes pointed out that the public often questions 1-18 Attachment 1 ------- *t y the authomi do not look at other technolo cal &terr ative It was sugg ed that EPA might become involved in the research and assessment of hriologies on a riatlonai lava Such involve- ment wou hslp all sewerage authorities in the development of long-term programs that are accepteble to the public NRDC stated t it would support ailowrng more time for long-term deosions if potential technologies could be adequately analyzed 3.22 Focus Group B: S ng w Pe thng The two Focus Group B sessions centered on the challenge of sating arid implementing sludge management systems that adhere to both te agency permitting procedures and the consent decree acheduls. NIJOEP and NYSDEC differ in their required deadlines for the sewerage authorities to identify their long-term sludge management solutions and the degree of support given to the authorities in this process. Descriptions of the efforts made and time frames involved in devsioping and implementing sludge management projects by the Seattle and Phi’adelphia guest speakers emphasized the need for adequate time and flexibility to suffloerttly analyze new technologies or multple systems. The New Jersey statute imposes a ngid March 17, 1991. deadlIne (Which NJDEP is not authorized to change) to cease ocean dumping. The guest speakers presented some worthWhile strategies for expediting the perrnittrng and siting of new faolities. 322.1 Slate Requirements The New Jersey sewerage auttio.ltee were required by NJOEP to identify both their interim and long-term sludge management plans by Aplil 19w. Five out of the sax sewerage authorities h&ve identified inonerabon as their long-term opbon. Their n step involves going through th te permitting process, Which will address the environmental and public health impacta of the proposed teciftbes. These sewerage authorities behe.e that this mandate and thor consequent commibTieni to inoneration predudes them from further pursuing other technologies and benefloal reuse The sewerage authonties indlceted that private contraators have been unwilling to commit the ne ary large sums of money in advance for protects with development schedule durations of l ewi 1.5 to 2 years. UnfoaturieWy, that type of schedule is flat within the tlme constrainta of the consent deoree&eriforcemervt agreements. NJDEP stated tl t the sludge management plans submItted in April 1999 cen be mxftfled only if there is a strong demonati’atlon that a dlf!erent alterristlve I prOerable and the designated schedule w not be sçnlflcently disrupted. The sewerage authontles ted that they feel pressure to implemerfl their currently designated technologies In order to meat the mandated Attachment 1 1-19 ------- schedules and are thus unable to explore oti ’ier lOng-tei’m alternatives. NYSDEC requires its sewerage authorities to complete an enwOnrnentaj impact statement before they designate their long- terni alternatives. NYSDEC acknowledged that the sewerage authorities do need to have schedules in place to effectively implement long-term plans. However, NYSDEC also recognizes that there cou be events. such as the pending Federai 503 sludge regulations, that wou necessitate flexibility in enforcement of the consent decrees. To rnmodate such potent changes. they will monitor the Sit 8tlon, and be flexible dunng the planning process. The planning process. however, cannot stop due to pending changes In technology and regulations NYSDEC representatives emphAsised that they recogrnze the difficulties that the municipal authorities will encounter, and that they are fully committed to overcoming the gridlock in the permit process, particularly in venturing into new areas of technology - Both states noted their inability to be involved in siting issues, neither NYSDEC nor NJDEP has the authority to locate sites or to overrule local zoning except in the case of hazardous wastes NJDEP requsres under the State Solid Waste Management Act, that each of the counties. in the solid waste districts. site sold waste facilities. The responsibilrty for siting lies witti the sewerage authorities until such time as the counties can implement the sludge management components of its solid waste management plans. None of the affected counties have yet implemented these plans. 3.222 Time Constraints The expenencee a land-based sludge management related by the guest speakers suggested a realistic time frame for implementing the New York and New Jersey sewerage authorities’ programs. Much of the necessary permitting has aireedy been accomplished by New Jeraey s sewerage authorities: all six authoritIes have received d atering permits and have implemented pretreatment programs. In genera, me amount of time required for guest speaker authorTtles to obtain all of the state and local permits necessary for both sites and full-scale facility operations was a crucial factor For mp4e, the gu speaker from Phuledelpt ia ted that me authority anticipated a ban on ocean dumping in the 1970s and thus began developing a 10-point alternatrve program dunng 1977. In 1979, when its ewatar b’eaunem plant facilities were required to be upgreded to secondary treatment, the city in tuted atnngent Pretreatment programs. Over a 5-year perIod, research was funded on vetious projects such as strip-mine reclamation: a paridand od factory’ protect, using compost on city facilities; an un u 6&ul liqu nd appl tion: and trying an Eco-rock process of fusing dewatered 1-20 Attachment 1 ------- sludge with mun apaJ refuse to produce pavement aggregate Thu& in 1980, w1 en Philadelphia was Informed tliat the city cou no longer dump in the ocean, the city was prepared, these test programs allowed the city to determine their most effective alternative and to Subsequently implement these alternatrves. The gu speaker from Seattle stated that the authorrty faced similar challenges in 1972 when the city was forced, under ngt it time constraints, to end ocean disposal At the time, it had a lagoon with only a 1-year sludge storage capacity arid was looking at Innovative ways of dewatenng sludge. M RFP was issued to solicit private seCtor propo a The University of Washington, which had a small pilot sludge application program under way on forest land, cam . forward with a 2-year proposal to taIe Seattles sludge and. In tam, use the monies received to perform resaercri and answer public health questions related to land application In 1973, Seattle ceased ocean dumping with only the university research program under way: the lagoon was used as a backup disposal option From that time through 1982, Seattle continued its efforts to find addrt;onal sludge management methods. By 1984, strip mines were taking 25 percent of Seattle’s sludge for use in land reclamation. In 1988, Seattle awarded a contract to a private company for sludge d atenng It now owns and manages for land that is used to recycle sludge and has contracts with a private company to apply sludge to the company s property Overall, Seattle’s strategy has been to avoid high-cost facilities and to keep options open. Seethes Current sludge management program has taken 17 years to ewolve. In concluding, Seattle stated that sludge management costs money, requires enormous amounts of time to pursue, and 8 very challenging in terms of budgeting. 3 2 2.3 Public Accept8ilce and Siting Strategies The guest speakers discussed numerous public acceptance and siting strategies. The following points were stressed 1. Keep alert to opportunities and have a planning process that contains some fiexibilfty for change. 2. If poselbie, find and use a sate that Is already owned by the authority. 3. For an out-of-state elte, secure a local sponsor who wante the material and will personally represent the pr eot and pursue any neceasery pe 4. Advertise In other localities for available sites. 5. Regional cooperation necessary for siting and Attachment 1 1-21 ------- ng iii of state landfills, meet iriformaily wrtti elected and appointed officials early-on ri the process 6. Maintain contacts with key regulatory agency staff members to ensure that permit applications receive pnorTty attention and expeditious handling 7 Obtain clear directions from the appropriate states regarding requirements for facility permitting & Obtain support of state and local agencies to coordInate and allow for expedrtous handling of permr 9. Pursue public education through a cooperative regional effort 10 Take a proactive stance to address misinformation spread by project opponents, to help generate positive press, find sympathetic arid knowledgeable reporters and take them to model operations. 11. Work with the state regulators and legislators to redefine sludge classifications, current classification of sludge as solid waste generally limits management options and creates a negative public image 12. Produce appealing public displays of sludge products to hep provide a positive image and promote beneficial use 3.3 ROUND 3: REAUST1C ACT)ONS TO PURSUE The sludge management roundtable addressed the concerns arid challenges presented by all of the groups involved in the struggle to implement land-based sludge management alternatives. (1) the city, state, and federal legislators who will make, or have made, decisions on sludge management. (2) the regulators who enforce the legislative decisions, (3) the sewerage authorities responsible for implementing sludge management altamatrves (4) the private contractors employed for sludge management, (5) the en- wonmentai and public health activists, and (6) the public, who, in many in ncee, beli e that their health and personal properly may be jeopardized by the recommended sludge management methods. The roundtable provIded EPA. the te agencies and NRDC with an increased sensitivity to the ieaues being ed by the New York and New Jersey sewerage authorIties in pursuing and implementing interim and long-term alternatives. The sewerage authorities benefitted from the in-depth information 1-22 Attachment 1 ------- exchange that took place during the roundtable, as many strategies and POssible endeavors were the ssed . In ed irtion to the strategies diso’ss 1 in the Permitting and Siting secton (Section 322), the following sugg ons were mede. 1. Establish as, information deennghouse. possibly by or with support from EPA. 2. Continue the network poces that began 8t this roundtab le. 3. Seek cooperation at all leials: federal, state. locel, and pnvate sector. 4. Consider the po 8ibdlty of regionaiization in the development of long-term solutions. 5. Increase sewerage authority staffs for the negotiation and management of multiple contracts with the private sector 6. Use multiple contractors and diversilicetion in sludge management options. 7 Involve a city attorney knowledgeable in the oca permitting regulations for negotiating contracta 8. Inc-ease public awareness of the sewerage authorities’ decision-making processes and sludge management acv .itiee along with the effect on public health and the environment, possibly through more involvement by EPA. The New York and New Jersey sewerage authorities expressed their gratitude to EPA for holding the roundtable arid reiterated a firm commitment to meeting their deadlines arid succe ulty terminating ocean dumping. The sewerage authorities strongly voiced their desire to implement the most environmentally sound sludge management alternatives arid expressed a willingness to remain open-minded arid f exibie in their implementation plans. They also expressed the hope that the regulators maintain the seine open-mindedness and flaiab4lfty. Attachment 1 1-23 ------- APP€ND X A ROUNDTAELE PL N NG GROUP MD Fe er i Bruce Kiselica Enwonmentei Protection Agency Region I I Ekzabeth Lonoff Enwonmentej Protection Agency Region II Karen Kiima Office of Marine & Estuarine Protection Sandy Germann Office of Mailne & Estuanne Protection Lee Pasarew Office of Municipai Pollubon Control Bob Bastian Office of Muniapai Pollution Control State Helen Pettrt New Jersey Department of Environmental Protection Penny H ferty New Jersey Department of Environmental Protection Bob Hampston New York State Department at Environmental Conservation Consultanis Car ton Hunt Battelle Memorial Institute. Duxbury Operations Eksabeth Smoiski Battelle Memorial Institute. Duxbury Operations Linda Hanrfin Hanifin Aseociatee, Inc. Nola Sparks Han n Associatee. Inc. 1-24 Aflacflment I ------- APP D X B ROUNOTABLE ATTEICEES Name Organizat ion DISCUSSION PARflC IPANTS : FACIIJTATORS. Primary & Focus Group B Roger Dolan Central Contra Costa Sewerage DistrIct Focus Group A Urida Hanrfin Hanrfin Associates, Inc. SPEMERS Eric Buehrens Massachusetts Water Resources Authority Peter Machno Municipality of Metropo1rtas Seattle Gary Gagnon Mitwaukee Metropolitan Sewerage Digtnct Michae’ J Wallis East Bay Muniopal Ubilbes DistrIct Thomas E. Walton, III formerly with City of PhiledOphia Ray Kearney City of Los Mge ee SEWERAGE AUTHO 1Y OFFICIALS & C Edward 0 Wagner NY City Dept of Environmental Protection Steven A Fangrnann Nassau County Dept. of Public Worica Nicholas R. Smolney Middlesex County Udkbee Authority Jerome Sheehan Bergen County Utilthee Authority Richard P Tokarskl Rahway Vafley Sewerage Authority Michae’ J. Brinker, Jr. Joint Meeting of Essex end Union Counties Gary G Fare Linden Rosalie Sewerage Authority Joseph La Vigna Westchester County Dept at Ervv. Facilftlee Sheldon Lipice Peesaic Valley Sewerage Comm aionera Nina M. Sankovitch Natur i Resources Defense Council lliam R. Dl nond EPA HO ftJanRub n EPAHO Robert Bastlan EPA HO Martha KrkpatncM EPA HO Richard Caspe EPA Region N Charles E. Hoffmann EPA Region N Attachment 1 1-25 ------- ROUNDTA8LE ATT DEES Name Organization RESOIJRCE PEOPLE (continued) Bruce K se1ice EPA Re on II Robert G. Hampston NY State Dept of Enwonmental Coneervaton Richard J Hammond NY State Dept. of Enwonmentai Conserveton Helen Pettit NJ Dept of Environmental Protection OBSERVERS Robert E Adams.’i Borough of Brooktyn Kelley Augustine NJ Dept. of Environmental Protection Iclal Atay NJ Dept of Environmental Protection Nicholas Bartilucci Dvirka & Bartilucci Diane Black Leegue of Women Voters Marci L Bortman U.S House of Rep. Committee on Merchant Manne & Fisheries Laurel Bryant U S. House of Rep. Committee on Merchant Manna & Fisheries Marjorie Bryant New York City Coun l Julian Capik Middlesex County Environmental Coalition Henry J. Chiupsa Ovirka & Bartilucci Chris Clark Apex Resources/NSI Don Clark Cornucopia of New Jersey James I Collins Industrial Innovatons, Inc.. Kevin Cant Demetrakis, Sinisi & Carn el Vincent Corrado Pas8aic Valley Sewerage Commtss oners C J Crumm Foster Wheeler USA Rutgers University/Cook College John Dedyc Seelye, Stevenson, Value & Knecht Bonnie Delaney Asbury Park Press Chris Dollase U.S. House of Rep. Committee on Merchant Mailne & Fisheries Arid rew L Do 1e Rahwey Valley Sewerage Authority jennifer Epp NY State Senate Subcommittee on Long Island Mailne D stnct Hugh Ettinger Bedminster Bioconversaon Corporation Tracy Faulkner Chem x Technologies, Inc. Rod Fujrta Environmental Defense Fund Sandy (3ermann EPA HO Karen J. GlroL Rutgers University/Cook College Penny Hitferty NJ Dept of Environmental Protection Canton Hunt Battelle Memorial Institute, D ury Operations Thomas & Immerso N* ii County Dept of Public Works Stephen Johnson Pennaytvania O.E.M. Natasha Kaplan Thomas E. Walton Associates, L . 1-25 Attachment 1 ------- AOUNDTA&E AT1D4C€ES Name Or an,zation OBSERVERS (continued) Herbert L Kaufman Clinton Bogert Associates Carl Koch Greeley & Hansen Engineers Ernest A. KoIIr des Dehydro-Tecti Corporation Bob Kukenbecger Blasland, Bouck & Lee Ellen Lane Gannett Westchester Newspapers Elizabeth LOI’ir Sludge Newsletter Elizabeth Lonoff EPA Region II AIlonso Lopez NY City Dept. of Enwonmental Protection Per A. Loren en, Jr Global Energy, Inc George Lutzic NY City Dept of Environmental Protection Larry McClure Bergen County Utilities Authority Wilkam Mikul Blasland, Bouck & Lee Percival Miller NY State Legislative Commission on Sold Waste Management Fred Munson Greenpeace USA Barbar Novick League of Women Voters Lee Pasarew EPA HO John J Pascucci Nassau County Dept of Public Works Herman P Phillips, Jr EPA Region II Mahest Podar EPA HO Robert L Raab City of Long Beach, NY Gerald 0 Rennerts Sludge Disposal International, Ltd Kevin Richardson Star Laiga’ Peter Ruffier Association of Metro Sewerage Agencies He4rnut W Schulz Global Energy, Inc. Irving F Shaw Mayor, Village of East Rockaway, NY Tim Shea Engineering Science. Inc. Elisabeth Smoiski Battefle Memonai Institite, Duxbury Operations Nola Sparks HanMn Asaociate , Inc. William C Sullivan, Jr Gordon, Gordon & Haley Pate Tortonci Bay Park Civic Association Judith Wells U S. Houae of Rep Committee on Merchant Manne & Fisheries Vicki W___ HanifIn Associates. Inc. Can Wild J Dept. of Enwonmental Protection Attachment 1 1-27 ------- ATTACHMENT 2 MAJOR REFERENCE DOCUMENTS PREPARED BY EPA ON SLUDGE MANAGEMENT ISSUES April 1990 U. S. Environmental Protection Agency Office of Marine and Estuarine Protection Washington, DC 20460 ------- EPA 1989 EPA’s Policy Promoting the Beneficial Use of Sewage Sludge and the New Proposed Technical Regulations Office of Water, U S Environmental Protection Agency, Washington DC EPA 1989 Environmental Regulations and Technology Control of Pathogens in Municipal Wastewater Sludge EPA 625/10-89-006 Center for Environmental Research Information u S Environmental Protection Agency, Cincinnati, OH EPA 1989 Summary Report In-Vessel Composting of Municipal Wastewater Sludge EPA 625/8-89- 016 Center for Environmental Research Information, U S Environmental Protection Agency. Cincinnati, OH EPA 1989 Start-up and Operation of Chemical Process Technologies in the Municipal Sector The Carver-Greenfield Process for Sludge Drying EPA 430/09-90-007 Office of Water, U S Environmental Protection Agency, Washington, DC Epstein, E and J Alpert 1987 Composting Municipal Sludge. A Technology Evaluation Water Environmental Research Laboratory, U S Environmental Protection Agency, Cincinnati, OH EPA 1987 Dewatering Municipal Wastewater Sludges Design Manual EPA 625/1-87-014 Center for Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH Page. A L, I Logan and J Ryan (eds) 1987 Land Application of Sludge Lewis Publishers, Inc. Chelsa, MI (EPA sponsored) Cole, W D. Henry. C L and W L Nutter (eds) 1986 The Forest Alternative for Treatment and Utilization of Municipal and Industrial Waste. University of Washington Press, Seattle, WA (EPA sponsored) EPA 1985 Handbook Estimating Sludge Management Costs EPA 625/6-85-010 Water Environmental Engineering Laboratory and Center for Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH Kowal, N E 1985 Health Effects of Land Application of Municipal Sludge EPA 600/1-85-015 Health Eftects Research Laboratory, U S Environmental Protection Agency, Research Triangle Park, NC EPA 1985 Composting of Municipal Wastewa’ter Sludges (Technology Transfer Seminar Publication) EPA 625/4-85-014 Center for Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH EPA 1985 Composting of Municipal Wastewater Sludges (Technology Transfer Seminar Publication) EPA 625/4-85-014 Center for Environmental Research Information, U. S. Environmental ProtectIon Agency, Cincinnati, OH EPA 1985 Handbook Estimating Sludge Management Costs. EPA 625/6-85-010. Water Environmental Engineering Laboratory and Center for Enwonmental Research Information, U S Environmental Protection Agency, CincinnatI, OH EP& 1984 Municipal Sludge Combustion Technology (Technology Transfer Seminar Publication) EPA 625/4-85-015 Center for Environmentai Research lrrformation, U S Enwonmental Protection Agency, Cincinnati, OH Attachment 2 2-1 ------- EPA 1984 Municipal Sludge Combustion Technology (Technology Transfer Seminar Publication) EPA 625/4_35.-015 Center for Environmental Research Information, U S Environmental Protection Agency. Cincinnati, OH EPA i984 Environmental Regulations and Technology Use and Disposal of Municipal Wastewater Sludge EPA 430/10-84-003 Intra-Agency Sludge Task Force, Washington, DC EPA 1984 Septage Treatment and Disposal Handbook EPA 625/6-84-009 Municipal Environmental Research Laboratory and Center for Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH Page, A L. T L Gleason, III, J E. Smith, Jr. I K Iskandar and LE Sommers (eds) 1983 Proceedings of the 1983 Workshop on Utilization of Municipal Wastewater and Sludge on Land University of California, Riverside, CA (EPA sponsored) EPA 1983 Land Application of Municipal Sludge Process Design Manual EPA 625/1-83-016 Center for Environmental Research Information, U S Environmental Protection Agency, Cincinnati. OH Sapper. WE, E M Seaker and R K Bastian (eds) 1982 Land Reclamation and Biomass Production with Municipal Wastewater and Sludge The Pennsylvania State University Press University Park PA (EPA sponsored) EPA 1982 Sludge Recycling for Agricultural Use EPA 430/9-82-008 Office of Water Program Operations U S Environmental Protection Agency, Washington, DC. EPA 1982 Sludge and the Land The Role of Soil and Water Conservation Districts in Land Application of Sewage Sludge EPA 430/9-82-007 Office of Water Program Operations, U S Environmental Protection Agency, Washington, DC CAST ‘1981 Effects of Sewage Sludge on the Cadmium and Zinc Content of Crops. EPA 600/8-81- 003 Municipal Environmental Research Laboratory, U S Environmental Protection Agency, Cincinnati, OH EPA 1980 Innovative and Alternative Technology Assessment Manual EPA 430/9-78-009 Office of Water Program Operations, U S Environmental Protection Agency, Washington, DC, and Center for Environmental Research Information, U. S. Environmental Protection Agency, Cincinnati, OH Brittcn, G, B L Damron, G.T Edds and J M Davidson 1980. Sludge - Health Risks of Land Application Ann Arbor Science Pubi Inc /The Butterworth Group Ann Arbor, Ml (EPA sponsored) EPA 1980 Evaluation of Sludge Management Systems: Evaluation Checklist and Supporting Commentary EPA 430/9-89-001. Office of Water Program Operations. U S. Environmental Protection Agency, Washington, DC Sapper, W E and S N Kerr (eds). 1979. Utilization of Municipal Sewage Effluent and Sludge on Forest and Disturbed Land The Pennsylvania State Unr ersity Press. Universdy Park, PA. (EPA sponsored) 2-2 Attachment 2 ------- EPA 1979 Sludge Treatment and Disposal Process Design Manual EPA 625/l79. 0i 1 Municipa’ Environmental Research Laboratory and Center for Environmental Research Information U S Environmental Protection Agency, Cincinnati, OH EPA 1978 Municipal Sludge Landfills Process Design Manual EPA 625/1-78-010 Center for Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH EPA 1978 Sludge Treatment and Disposal EPA 625/4-78-012 Vols 1 & 2 Center for Environmental Research Information, U S Environmental Protection Agency, Cincinnati, OH NAS 1978 Multimediurn Management of Municipal Sludge Vol IX Analytical Studies for the U S EPA, National Academy of Sciences, Washington, DC (EPA Sponsored) C A S T 1976 Application of Sewage Sludge to Croplarid Appraisal of Potential Hazards of the Heavy Metals to Plants and Animals EPA 430/9-76-013 (MCD -33) Office of Water Program Operations. U S Environmental Protection Agency, Washington, DC EPA 1977 Municipal Sludge Management Environmental Factors EPA 430/9-77-004 (MCD-28) Office of Water Program Operations, U S Environmental Protection Agency, Washington, DC Attachment 2 2-3 ------- |