Manual: Guidance for Writing Case-by-Case Permit Requirements for Municipal Sewage Sludge


Manual
Guidance for Writing Case-by-Case
Permit Requirements for
Municipal Sewage Sludge
U.S. Environmental Protection Agency
Office of Water Enforcement and Permits
Washington, D.C. 20460
DECEMBER 1989

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
DEC 19 1989
MEMORANDUM
OFFICE OF
WATER
SUBJECT: Final Guidance for Writing Case-by-Case Permit Requirements for
The purpose of this memorandum is to present to you the final Guidance for
Writing Case-by-Case Permit Requirements for Municipal Sewage Sludge.
The guidance document, as you may recall, was originally sent out in draft form
in September, 1988. Comments from Regions, States and other users of the document
were solicited and received over a one-year period. This final form of the document,
reformatted to make it more readable, incorporates those comments.
The purpose of the document is to provide: 1) a compilation of existing Federal
and State requirements for sludge; 2) a compilation of existing federal and State
guidance; and 3) recommendations for permit writers to consider writing into permits on
a case-by-case basis using their best professional judgment. In keeping with the Sewage
Sludge Interim Permitting Strategy, we have recommended that permit writers require
more frequent monitoring of the pollutants for which numeric limits have been proposed
for the proposed Part 503 regulations. In developing permit limits for POTWs, we
recommend that the primary source of information should be the Case-by-Case
Guidance and not the proposed technical standards, unless the permit writer can
independently establish their appropriateness. The language in the guidance on this
issue tracks the discussion in the Interim Permitting Strategy.
We are presenting you with a typewritten, xeroxed copy of the final document. In
the near future, the document will be published in a typeset, printed version that will be
distributed to Branch Chiefs, States and other interested parties.
If you have any questions about the Cbc Guidance or sludge permitting in
general, please call me at (FTS) 475-8488, or have your staff contact Martha Segall at
(FTS) 382-2696.
Attachment
James RyCfaef,
Officevdf Water
irector
Municipal Sewage Sludge
FROM:
Office/d? Water Enforcement and Permits
TO:
Water Management Division Directors
Regions I-X
cc: Martha G. Prothro
Susan G. Lepow
Michael J. Quigley

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sr"^
/ Q \	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I ^\t/2 ?	WASHINGTON, D.C. 20460
V PRO^
OEC 19 1989
OFFICE OF
WATER
MEMORANDUM
SUBJECT: Guidance for Writing Case-bv-Case Permit Requirements
for Municipal Sewage Sludge
FROM:	JamesT^^^tfie
Office of Water Enforcement and Permits
TO:	Users of the Guidance
This manual provides Regional and State permit writers with
technical guidance on the development of best professional
judgment (BPJ) sludge permit conditions to be incorporated into
permits in the interim before the 40 CFR Part 503 technical
sludge standards are promulgated.
The 1987 amendments to the Clean Water Act require that
prior to the promulgation of the sludge standards, EPA must
"impose sludge conditions in [NPDES] permits issued to publicly
owned treatment works [POTWs]... or take such other measures as
the Administrator deems appropriate to protect public health and
the environment from any adverse effects which may occur from
toxic pollutants in sewage sludge." Thus, the amendments direct
EPA to protect the environment from improper use and disposal
practices prior to promulgation of the technical standards.
To implement the Clean Water Act requirements, EPA has
developed a program outlined in the document entitled "The Sewage
Sludge Interim Permitting Strategy" (September 1989). The
interim program utilizes existing experience, expertise and
permitting processes to focus permitting efforts on the
facilities which, based on the available information, are thought
to present greater risk. The Interim Permitting Strategy
includes standard permit conditions, monitoring requirements, and
State/EPA coordination in the permitting process. In addition,
the Interim Permitting Strategy notes that case-by-case permit
requirements will need to be developed for certain POTWs. This
may mean more frequent monitoring or other site specific
conditions such as management practices or numeric limitations
developed on a case-by-case basis.

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The Guidance for Writing Case-bv-Case Permit Requirements
for Municipal Sewage Sludae ("Cbc Guidance") is the technical
companion to the Interim Permitting Strategy and is designed to
assist permit writers in developing these additional case-by-case
conditions. The manual presents: 1) a compilation of existing
federal and State requirements for sludge; 2) a compilation of
existing federal and State guidance; and 3) case—by—case
recommendations for permit writers to consider as appropriate.
It is important that the permit writer ensure that existing
federal and State requirements are incorporated into permits
issued to POTWs. Use of the Cbc Guidance will ensure that these
requirements are included in permits and should help to promote
timely compliance with the 40 CFR Part 503 technical sludge
regulations when issued. In addition, compliance with the
monitoring requirements specified will provide information on
sludge quality and the use and disposal practices at the POTW and
help identify potential problems.
The Cbc Guidance may be used by Regional and State permit
writers to assist them at arriving at appropriate permit
conditions and by the Region in reviewing State-issued permits.
EPA and States may take further action beyond that specified in
the guidance, where appropriate to protect public health and the
environment and where a basis for the requirement can be
established. This document should provide permit writers with
the tools necessary to develop sound and defensible permits
during the interim period.

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NOTICE
This document has been reviewed in accordance with the U.S. Environmental
Protection Agency's peer and administrative review policies and approved for
publication. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
ii

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Revised 12/1/89
TABLE OF CONTENTS
Page
1.	INTRODUCTION	1
1.1	PURPOSE AND USE OF THIS GUIDANCE	1
1.2	HISTORY OF SLUDGE REQUIREMENTS IN THE CLEAN WATER ACT....3
1.3	IMPLEMENTATION OF THE WATER QUALITY ACT OF 1987 	4
1.3.1 LEGAL BASIS FOR INTERIM SLUDGE REQUIREMENTS	6
1.4	PERMITTING REQUIREMENTS AND RECOMMENDATIONS	7
1.5	DEVELOPMENT OF IMS GUIDANCE	9
2.	APPLICABILITY OF THIS GUIDANCE	14
2.1	FACILITIES COVERED	14
2.2	FACILITIES NOT COVERED	15
2.3	PRACTICES COVERED	16
2.3.1	LANDFUUNG	16
2.3.2	INCINERATION".	17
2.3.3	SURFACE DISPOSAL	17
2 .4 PRACTICES NOT COVERED	18
2.4.1	OCEAN DISPOSAL	18
2.4.2	SLUDGE STORAGE	18
2.4.3	SLUDGE TREATMENT PROCESSES	19
2.4.4	SEPTAGE DISPOSAL	19
2.4.5	DISPOSAL OF HAZARDOUS WASTE	20
2.5 RELATIONSHIP BETWEEN SLUDGE PERMITTING AND
THE PRETREATMENT PROGRAM	21
3.	OVERVIEW OF SLUDGE TREATMENT PROCESSES AND THEIR EFFECT
ON SLUDGE PROPERTIES	22
3.1	INTRODUCTION	22
3.2	SLUDGE TREATMENT ALTERNATIVES	22
3.2.1	THICKENING	22
3.2.2	STABILIZATION			23
3.2.3	CONDITIONING	24
3.2.4	DEWATERING	25
3.2.5	COMPOSTING	26
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TABLE OF CONTENTS (Continued)
Page
3.3	PATHOGEN REDUCTION	27
3.3.1	PROCESSES TO SIGNIFICANTLY REDUCE PATHOGENS
(PSRP)	27
3.3.2	PROCESSES TO FURTHER REDUCE PATHOGENS (PFRP) 27
3.3.3	PSRP AND PFRP EQUIVALENCY	."29
3.4	EFFECT ON SLUDGE PROPERTIES	30
4.	SUMMARY OF PERMITTING PROCEDURES AND REQUIREMENTS	33
4.1	GATHERING INFORMATION	 33
4.2	SECONDARY INFORMATION SOURCES	"*36
4.3	SETTING PRIORITIES	 37
4.4	STANDARD PERMIT REQUIREMENTS	37
4.4.1	GENERAL	 37
4.4.2	MONITORING REQUIREMENTS	.'.".38
4.5	ADDITIONAL PERMIT REQUIREMENTS FOR CLASS I POTWs	40
4.5.1	CASE-BY-CASE SLUDGE CONDITIONS	40
4.5.2	CASE-BY-CASE MONITORING REQUIREMENTS	40
5.	LANDFILLING	41
5.1	INTRODUCTION	41
5.1.1 PERMITTING RESPONSIBILITIES	42
5.2	TECHNOLOGY GUIDELINES	 45
5.3	CHARACTERISTICS OF SLUDGES SUITABLE FOR LANDnLLLNG.......!51
5.3.1	SLUDGE POLLUTANT CONCENTRATION LIMITS	51
5.3.2	SLUDGE PHYSICAL PROPERTIES	51
5.3.3	LANDFILLING OF SLUDGES CONTAINING
RADIONUCLIDES	53
5.4	OPERATING CONDITIONS AND MANAGEMENT PRACTICES	54
5.4.1	ENDANGERED SPECIES PROTECTION	54
5.4.2	FLOODPLAIN RESTRICTIONS	55
5.4.3	GROUND-WATER PROTECTION	56
5.4.4	SURFACE WATER PROTECTION	63
5.4.5	SAFETY	66
5.4.6	AIR QUALTTY CONTROL	68
5.4.7	GAS CONTROL	69

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TABLE OF CONTENTS (Continued)
Page
5.4.8	PATHOGEN AND DISEASE CONTROL		71
5.4.9	OTHER STATE MANAGEMENT PRACTICES	!.'.."!!"73
5.5 MONITORING, REPORTING, AND RECORD KEEPING	73
5.5.1	SLUDGE MONITORING		73
5.5.2	GROUND-WATER MONITORING	 	74
5.5.3	GAS MONITORING	 	77
5.5.4	SURFACE WATER MONTTORING	 "77
5.5.5	MONITORING FOR HAZARDOUS WASTES	 *78
5.5.6	REPORTING AND RECORD KEEPING	.78
6. LAND APPLICATION	82
6.1	INTRODUCTION	82
6.1.1	AGRICULTURAL UTILIZATION		82
6.1.2	FOREST UTILIZATION (SILVICULTURE)	 	83
6.1.3	LAND RECLAMATION	 	84
6.1.4	DEDICATED LAND DISPOSAL	85
6.2	GENERAL REQUIREMENTS AND GUIDANCE FOR ALL FORMS OF
LAND APPLICATION	86
6.2.1	PERMITTING RESPONSIBILITIES	 86
6.2.2	CHARACTERISTICS OF SLUDGES SUITABLE FOR LAND
APPLICATION		90
6.2.3	OPERATING CONDITIONS AND MANAGEMENT PRACTICES... .99
6.2.4	MONITORING, REPORTING, AND RECORD KEEPING	108
6.3	ADDITIONAL REQUIREMENTS AND GUIDANCE FOR
AGRICULTURAL LAND APPLICATION	122
6.3.1	PERMITTING RESPONSIBILITIES	122
6.3.2	TECHNOLOGY	 124
6.3.3	CHARACTERISTICS OF SLUDGE SUITABLE FOR
AGRICULTURAL LAND APPLICATION	125
6.3.4	OPERATING CONDITIONS AND MANAGEMENT PRACTICES.... 136
6.3.5	ADDITIONAL MONITORING CONSIDERATIONS FOR
AGRICULTURAL LAND APPLICATION	140
6.4	ADDITIONAL REQUIREMENTS AND GUIDANCE FOR SILVICULTURAL
(FOREST LAND) APPLICATION	141
6.4.1	CHARACTERISTICS OF SLUDGES SUITABLE FOR
SILVICULTURAL LAND APPLICATION	141
6.4.2	OPERATING CONDITIONS AND MANAGEMENT PRACTICES
FOR SILVICULTURE	 142

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TABLE OF CONTENTS (Continued)
Page
6.4.3 ADDITIONAL MONITORING CONSIDERATIONS FOR
SILVICULTURE	143
6.5	ADDITIONAL REQUIREMENTS AND GUIDANCE FOR LAND
RECLAMATION	145
6.5.1	CHARACTERISTICS OF SLUDGES SUITABLE FOR LAND
RECLAMATION	145
6.5.2	OPERATING CONDITIONS AND MANAGEMENT PRACTICES
FOR LAND RECLAMATION	146
6.5.3	ADDITIONAL MONITORING CONSIDERATIONS FOR LAND
RECLAMATION	150
6.6	ADDITIONAL REQUIREMENTS AND GUIDANCE FOR DEDICATED
LAND DISPOSAL	150
6.6.1	PERMITTING RESPONSIBILITIES	151
6.6.2	CHARACTERISTICS OF SLUDGES SUITABLE FOR
DEDICATED LAND DISPOSAL	152
6.6.3	OPERATING CONDITIONS AND MANAGEMENT PRACTICES
FOR DEDICATED LAND DISPOSAL	152
6.6.4	ADDITIONAL MONITORING RECOMMENDATIONS FOR
DEDICATED LAND DISPOSAL	154
7. DISTRIBUTION AND MARKETING	157
7.1	INTRODUCTION	157
7-1.1 PERMITTING RESPONSIBILITIES	157
7.2	TECHNOLOGY GUIDELINES	158
7.3	CHARACTERISTICS OF SLUDGES SUITABLE FOR DISTRIBUTION
AND MARKETING	163
7.3.1	SLUDGE POLLUTANT CONCENTOATTON LIMITS	163
7.3.2	PHYSICAL PROPERTIES	171
7.4	OPERATING CONDITIONS AND MANAGEMENT PRACTICES	171
7.4.1	SURFACE WATER PROTECTION	171
7.4.2	GROUND-WATER PROTECTION			172
7.4.3	STORAGE	173
7.4.4	BUFFER ZONES/ACCESS CONTROLS	173
7.4.5	CROPUSEUMTTS	174
7.4.6	OTHER CONDITIONS	174
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TABLE OF CONTENTS (Continued)
Page
7.5 MONITORING, REPORTING, RECORD KEEPING AND
LABELING	174
7.5.1	POLLUTANT CONCENTRATION MONITORING	175
7.5.2	TREATMENT PROCESS MONITORING	177
7.5.3	SOIL MONITORING	177
7.5.4	REPORTING AND RECORD KEEPING	178
7.5.5	PRODUCT LABELING	178
8. INCINERATION	187
8.1	INTRODUCTION	187
8.1.1 PERMITTING RESPONSIBILITIES	187
8.2	INCINERATION TECHNOLOGY	188
8.2.1 DEFINITIONS.	190
8.3	CURRENT REGULATORY REQUIREMENTS	191
8.3.1	NEW SOURCE PERFORMANCE STANDARDS (NSPS)
(40 CFR Part 60)	191
8.3.2	NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS
AIR POLLUTANTS	191
8.3.3	TOXIC SUBSTANCES CONTROL ACT (TSCA)	192
8.3.4	NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS)
AND STATE IMPLEMENTATION PLAN (SIPs) (40 CFR Part 50).... 192
8.3.5	NEW SOURCE REVIEW STANDARDS (NSRS)
(40 CFR Pan 51.160)	194
8.3.6	PREVENTION OF SIGNIFICANT DETERIORATION (PSD)
(40 CFR PART 52.21)	194
8.4	CHARACTERISTICS OF SLUDGES SUITABLE FOR INCINERATION	196
8.4.1	POLLUTANT CONCENTRATION LIMITS FOR SLUDGE FEED
AND AIR	1%
8.4.2	SLUDGE PHYSICAL PROPERTIES	202
8.5	OPERATING CONDITIONS AND MANAGEMENT PRACTICES	203
8.5.1	GENERAL OPERATING CONDITIONS AND MANAGEMENT
PRACTICES	204
8.5.2	OPERATING GUIDELINES FOR SPECIFIC INCINERATION
TECHNOLOGIES	212
8.5.3	GUIDELINES FOR POLLUTION CONTROL SYSTEMS	214
Vll

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TABLE OF CONTENTS (Continued)
Eagc
8.6 MONITORING, REPORTING AND RECORD KEEPING	217
8.6.1	MONITORING		217
8.6.2	REPORTING AND RECORD KEEPING	^220
9. SURFACE DISPOSAL	224
9.1	INTRODUCTION		224
9.2	CHARACTERISTICS OF SLUDGES SUITABLE FOR SURFACE	
DISPOSAL	226
9.2.1	SLUDGE POLLUTANT CONCENTRATION LIMITS	 226
9.2.2	SLUDGE PHYSICAL PROPERTIES	'.''.'. '. '.'.217
9.3	OPERATING CONDITIONS AND MANAGEMENT PRACTICES	227
9.3.1	FLOODPLAIN RESTRICTIONS		227
9.3.2	SURFACE WATER PROTECTION	 	228
9.3.3	GROUND-WATER PROTECTION	 	229
9.3.4	BUFFER ZONES	 	231
9.3.5	ACCESS CONTROL		232
9.3.6	PATHOGEN AND DISEASE CONTROL	 	233
9.3.7	AIR QUALITY CONTROL		233
9.3.8	ENDANGERED SPECIES PROTECTION		233
9.3.9	EXPLOSIVE GASES	 	234
9.3.10	OTHER SLUDGE LAGOON RESTRICTIONS	.'..'..234
9.4	MONITORING, REPORTING, AND RECORD KEEPING	235
9.4.1	MONITORING		235
9.4.2	REPORTING AND RECORD KEEPING	237
LIST OF APPENDICES
APPENDIX A - SEWAGE SLUDGE INTERIM PERMITTING STRATEGY
APPENDIX B - REGIONAL AND STATE AIR, SOLID WASTE, AND GROUND-WATER
CONTACTS
APPENDIX C - DISTRIBUTION AND MARKETING LABELS Alto INSTRUCTIONS
APPENDIX D - 40 CFR 257 - CRITERIA FOR CLASSIFICATION OF SOLID WASTE
DISPOSAL FACILITIES AND PRACTICES
APPENDIX E - STATE REQUIREMENTS AND GUIDANCE FOR SLUDGE USE AND
DISPOSAL
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LIST OF TABLES
Tflblfi	Page
1 -1 SLUDGE MAINTENANCE REGULATIONS OF THE ENVIRONMENTAL
PROTECTION AGENCY	8
1-2 POLLUTANTS* SPECIFICALLY ADDRESSED IN THIS GUIDANCE	10
3-1	INCREASED METALS CONCENTRATION DURING PROCESSING
(mg/kg DRY WEIGHT)	31
4-1	INFORMATION GATHERING FOR WRITING SLUDGE CONDITIONS	34
5-1	40 CFR PART 257 REQUIRED MANAGEMENT PRACTICES FOR SLUDGE-
ONLY AND CO-DISPOSAL LANDFILLS, LAND APPLICATION SITES AND
SLUDGE LAGOONS AND STOCKPILES	43
5-2	MAXIMUM CONCENTRATIONS FOR CONTAMINANTS ANALYZED FOR
EP TOXICITY AND TCLP TESTS			79
6-1	40 CFR PART 257 PATHOGEN REDUCTION REQUIREMENTS FOR LAND
APPLICATION AND DISTRIBUTION AND MARKETING OF SLUDGES	91
6-2 HALF-LIFE OF RADIONUCLIDES WHICH HAVE BEEN IDENTIFIED IN
POTW SLUDGES	97
6-3 SAMPLE CALCULATION FOR SLUDGES THAT CONTAIN RADIUM	98
6-4 RECOMMENDED SLOPE LIMITATIONS FOR LAND APPLICATION SLUDGE. 107
6-5 SLUDGE MONITORING PROGRAMS FOR TWO AGRICULTURAL LAND
APPLICATIONS	112
6-6 SOIL MONITORING PROGRAMS FOR TWO AGRICULTURAL LAND
APPLICATION OPERATIONS	115
6-7 POTENTIAL CROP MONITORING PARAMETERS	117
6-8 40 CFR PART 257.3-5 CONTAMINANT LIMITS FOR SLUDGE USED ON
FOOD-CHAIN CROP LANDS	123
6-9 MAXIMUM PERMISSIBLE CUMULATIVE CADMIUM APPLICATION
TO A LAND APPLICATION SITE USED TO PRODUCE FOOD-CHAIN CROPS.. 126
6-10 SUMMARY OF CURRENT STATE ANNUAL CONTAMINANT APPLICATION
RATES FOR LAND APPLICATION	129
6-11 SUMMARY OF CURRENT STATE CUMULATIVE CONTAMINANT
APPLICATION RATES FOR LAND APPLICATION	130
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LIST OF TABLES (Continued)
Table	Page
6-12 MAXIMUM METAL APPLICATION1 (kg/ha) FOR UNAMENDED SOIL AT
INDICATED SOIL CATION EXCHANGE CAPACITY (CEQ	131
6-13 YEARS OF APPLICATION FOR CADMIUM AND NICKEL	132
6-14 YEARS OF APPLICATION FOR COPPER, LEAD, AND ZINC	133
6-15 RELATIVE ACCUMULATION OF CADMIUM INTO EDIBLE PLANT
PARTS BY DIFFERENT CROPS	135
6-16 RECOMMENDED DISTANCE TO SURFACE WATERS FOR AGRICULTURAL
LAND APPLICATION	137
6-17 GENERAL GUIDE TO MONTHS AVAILABLE FOR SLUDGE APPLICATION
TO DIFFERENT CROPS IN NORTH CENTRAL STATES	139
6-18 RECOMMENDED DISTANCES TO SURFACE WATER FOR SILVICULTURAL
APPLICATIONS	143
6-19 STATE SLUDGE CONTAMINANT CONCENTRATION LIMITS FOR
LAND RECLAMATION	147
6-20	STATE REGULATIONS FOR ANNUAL AND CUMULATIVE APPLICATION
RATES AND VARIANCES FOR LAND RECLAMATION	148
7-1	INCREMENTAL INDEX VALUES OF TOXICITY TO HUMANS	166
7-2 MAXIMUM METAL APPLICATION* (kg/ha) FOR UNAMENDED SOIL AT
INDICATED SOIL CATION EXCHANGE CAPACITY (CEQ	168
7-3 SUMMARY OF CURRENT STATE SLUDGE CONTAMINANT LIMITS
FOR DISTRIBUTION AND MARKETING	170
7-4 YEARS OF APPLICATION IN SI UNITS FOR CADMIUM AND NICKEL	180
7-5 YEARS OF APPLICATION IN SI UNITS FOR COPPER, LEAD, AND ZINC	181
7-6 YEARS OP APPLICATION IN ENGLISH UNITS FOR CADMIUM AND
NICKEL 	182
7-7 YEARS OF APPLICATION IN ENGLISH UNITS FOR COPPER, LEAD,
AND ZINC 	*	183
7-8	SAMPLE CALCULATIONS FOR YEARS OF APPLICATIONS	184
8-1	NATIONAL AMBIENT AIR QUALITY STANDARDS	193
8-2 HEALTH EFFECTS OF AIR POLLUTANTS	193

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LIST OF TABLES (Continued)
Table
8-3 LEVELS OF NET EMISSIONS INCREASE THAT QUALIFY AS MAJOR
MODIFICATIONS REQUIRING PSD REVIEW	195
8-4 FEDERAL CONCENTRATION LIMITS FOR CONTAMINANTS	198
8-5 SUMMARY OF SUGGESTED INCINERATION OPERATING GUIDELINES	208
8-6	PROHIBITED SLUDGE INCINERATION PRACTICES	211
LIST OF FIGURES
Figure	Page
3-1 EXAMPLE SLUDGE TREATMENT TRAINS	28
6-1 EXAMPLE LAND APPLICATION PROGRAM CONTRACT	88
9-1	COMPARISON OF WASTEWATER LAGOON AND SLUDGE LAGOON	225
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Acknowledgements
The draft Guidance for Writing Case-by-Case Permit Retirements for Municipal Sewage Sludge was
prepared by U.S. EPA's Office of Water Enforcement and Permits with the assistance of Camp, Dresser &
McKee Inc. The principal U.S. EPA authors were Tom Wall, Martha Segall, Greg McBrien, Debora Clovis,
Cristina Morrison, Robert Goo, John Melby and Catherine Crane. The principal Camp Oresser and McKee
authors were Chris Clarkson, Tom Broderick, Joe Wiseman, Bill Dowbiggin, and Anne Cole. SAIC authors
were Mary Waldron and Susan Moore. Stuart Miner, Claire Gesalman, Joe Spollen, Mary Hobson and
Flaminla Mangone of Roy F. Weston, Inc. developed the information on State sludge use and disposal
requirements.
Comments on a previous draft of this document were provided by EPA's Sludge Permitting Workgroup.
These reviewers included EPA Regions, a number of States, EPA's Office of Research and
Development, and representatives of a number of EPA Headquarters Offices with an interest in sludge
use and disposal. The efforts of these reviewers are greatly appreciated. In particular, we want to thank
Bob Bastian, Al Rubin, Joe Farrell, and Chuck Henry for their generous contnbutions. We would also like
to thank those who commented on the September 1988 draft.
xii

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CHAPTER 1
INTRODUCTION
1.1 PURPOSE AND USE OF THIS GUIDANCE
Section 405 of the Clean Water Act (referred to as the Art) requires thai EPA regulate the use and
disposal of sewage sludge to protect public health and the environment from any reasonably
anticipated adverse effects of these practices. In the Act, Congress directs EPA to develop tech-
nical standards for sludge use and disposal options and to incorporate these standards into National
Pollutants Discharge Elimination System (NPDES) permits issued to Publicly Owned Treatment
Works (POTWs) under Section 402 of the Act EPA has proposed an initial round of technical
sludge standards (40 CFR Pan S03) which are expected to be promulgated in 1991. Congress
also specified that sewage sludge use and disposal practices be regulated immediately. This
mandate initiated EPA's development of an interim program (Sewage Sludge Interim Permitting
Strategy) to control sludge use and disposal until all the necessary regulations are completed.
The purpose of this guidance document is to provide technical information and assistance to EPA
permit writers in developing interim sludge requirements on a case-by-case basis. The guidance
provides information on existing regulations for use in developing sludge permit conditions. It
also recommends additional permit conditions that are based on current Federal guidance as well as
State requirements and/or recommendations. Permit writers may consider including these addi-
tional conditions in permits on a case-by-case basis exercising their best professional judgment.
Separate chapters (5-9) address each major sludge use or disposal option and summarize all Fed-
eral and State requirements as well as recommendations. This guidance document also describes
monitoring and reporting requirements as well as standard permit conditions for inclusion in all
new or reissued POTW permits. Although this guidance document is addressed to EPA permit
writers, the information it contains should also be useful to State permit writers for developing
sludge permit conditions and identifying potential sludge use or disposal problems.
EPA intends this guidance to serve as the primary reference for writing interim, case-by-case
sludge requirements for POTWs. The need for writing interim sludge requirements will continue
until final promulgation of applicable technical sludge standards at 40 CFR Pan 503. Even after
promulgation of the standards, BPJ limits may be needed to address pollutants or management
practices of concern at a particular POTW that are not addressed in the technical standards. In
addition, the first round of technical standards may not address the disposal option employed by a
particular POTW. For example, sludge lagoons and other methods of surface disposal where
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sludge is retained for less than a year, which are addressed in Chapter 9 of this guidance, were not
covered in the first round of technical standards as proposed. For these situations, this guidance
will continue to be useful for permit writers.
The recommendations contained in this manual have been carefully reviewed for consistency with
the forthcoming technical regulations (40 CFR Part 503). This guidance is intended to help the
permit writer identify and address, through permits, existing a- potential problems with sludge use
or disposal, in the absence of promulgated technical standards. The guidance is not intended to
supplant the 40 CFR Part 503 standards or implement them before they are final In developing
permit limits for POTWs in the interim, the primary source of information for permit writers
should be the Case-by-Case Guidance. Information from other sources, of course, may be con-
sidered and evaluated by the permit writer in the exercise of his or her best professional judgment.
The proposed 40 CFR Part 503 standards are currendy undergoing revision in response to the
public comments recieved and peer review undertaken during the 180 day comment period. These
inputs, as well as the results of the National Sewage Sludge Survey, may result in final standards
that are significantly different from the proposal. In light of these circumstances, reliance on the
proposed standards should be limited. Permit writers should not rely on the proposed numeric
limits in 40 CFR Part 503 in developing case-by-case sludge conditions unless they can establish
independently the appropriateness of such conditions based on the circumstances of the particular
sludge practice at issue. Any sludge conditions other than those based on existing regulations,
must have a sound technical basis that is explained in the permit's fact sheet
Under the Sewage Sludge Interim Permitting Strategy, EPA may defer to State implementation of
the Interim Strategy pursuant to a State/EPA agreement When a State has assumed responsibility
for implementation of sludge requirements, EPA must review and approve permit conditions for
those POTWs which are considered permitting priorities. This guidance document can be used by
EPA Regional Offices to that purpose and, where appropriate, to develop supplemental
requirements. (See "Sewage Sludge Interim Permitting Strategy" in Appendix A for a fuller
explanation of the procedures for coordinating State/EPA permitting activities.)
Because of the multi-media impacts of sludge disposal and a history of* fragmented approach to
sludge regulation, writing interim sludge limits will require a great deal of coordination among
EPA offices and between EPA and the States. For example, determining appropriate permit
conditions for incinerators will require cooperation and support from EPA and State air program
officials. Similarly, determining what conditions to place in a permit for a POTW that disposes of
2

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Revised 12/1/89
its sludge in a landfill will require cooperation and support from EPA and State solid waste pro-
grams. This guidance document provides guidance on how, when, and with whom to coordinate
(see Appendix G for contacts in State and Regional solid waste and air program offices).
1.2 HISTORY OF SLUDGE REQUIREMENTS IN THE CLEAN WATER ACT
Over the past IS years, Congressional concern with the proper use and disposal of sewage sludge
has lead to increased attention in the Clean Water Act ("CWA"). In the Federal Water Pollution
Control Act Amendments of 1972, Congress prohibited the disposal of sewage sludge to navigable
waters without a permit (Section 405). It also directed EPA to issue regulations governing the
issuance of permits that would apply "each criterion, factor, procedure, and requirement applicable
to a permit issued under Section 402 [NPDES]...." Thus, initially Congress provided for the
regulation of sewage sludge in the same manner as other pollutant discharges to navigable waters.
In the 1977 amendments to the CWA, Congress expanded its concern about sewage sludge dis-
posal beyond discharges to navigable waters. The focus of these amendments was to encourage
the beneficial use of sludge, i.e., to treat the growing amounts of sewage sludge as a resource
rather than a disposal problem. To this end, Congress directed EPA in Section 405(d) of the CWA
to issue regulations that would identify: 1) use and disposal options; 2) factors to be taken into
account in determining the measures and practices applicable to each option; and 3) concentrations
of pollutants in the sludge that interfere with each option.
The 1977 amendments prohibited POTWs from disposing of sewage sludge by any method in
which Section 405 standards were established unless in compliance with such standards, but did
not require that the standards be implemented through Federally enforceable permits. In an
amendment to Section 307(b), Congress also explicitly linked sewage sludge disposal to the
pretreatment program by allowing for removal credits (i.e., credits given to industrial user for
pollutant removals achieved by the POTW) for toxic pollutants treated by a POTW, although
credits could be granted only if this would not result in violation of the sewage sludge use and
disposal requirements under Section 405. (See Section 54 of the CWA of 1977, P.L. 95-217)
The sludge use and disposal standards envisioned in the 1977 amendnfents to the CWA led to the
promulgation of 40 CFR Part 257 (under the joint authority of the CWA and the Resource Con-
servation and Recovery Act). 40 CFR Pan 257 (see Appendix D) established standards for
cadmium, PCBs, and pathogens in sludge applied to land and established general management
standards for solid waste landfills. Currently, these are the only sludge disposal standards
3

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Revised 12/1/89
promulgated under the authority of Section 405(d) of the CWA. (Other regulations promulgated by
EPA, however, govern various aspects of sewage sludge disposal. These are described later in
Chapter 2)
With the passage of the Water Quality Act of 1987 (P.L. 100-4) ("WQA"), Congress reaffirmed its
intent to have EPA comprehensively regulate the use and disposal of sewage sludge. Congress
again called for the promulgation of technical standards, and in Section 405(d)(2) placed new
emphasis on identifying and limiting those toxic pollutants in sewage sludge that may adversely
affect public health or the environment It also enacted strict deadlines for compliance with these
standards: within one year of promulgation unless construction of new pollution control facilities is
necessary, in which case compliance is required within two years. Congress further required that
EPA implement the technical standards through NPDES permits issued to POTWs and other treat-
ment works treating domestic sewage unless the standards were already included in a permit issued
under other Federal programs listed in Section 405(0(1) or under State programs approved by
EPA as adequate to ensure compliance with Section 405. Congress also directed EPA to begin
immediate regulation of sewage sludge use and disposal. The 1987 amendments state that:
Prior to the promulgation of the regulations required by paragraph (2) [technical standards],
the Administrator shall impose conditions in permits issued to publicly owned treatment
works under Section 402 of this Act or take such other measures as the Administrator deems
appropriate to pro tea public health and the environment from any adverse effects which may
occur from toxic pollutants in sewage sludge.
[Section 405(d)(4) of CWA added by the WQA of 1987.]
Thus, even before promulgation of the technical standards, EPA must begin to address sewage
sludge use and disposal in NPDES permits issued to POTWs. It must also identify other measures
that may be appropriate to ensure environmentally sound sludge disposal practices.
1.3 IMPLEMENTATION OF THE WATER QUALITY ACT OF 1987
EPA activities to fulfill the Congressional mandate under Section 405«an be divided into two
parts. One part involves the development of technical standards to regulate sewage sludge use and
disposal and the other involves the establishment of administrative procedures for incorporating
these technical standards into permits.
4

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Revised 12/1/89
Recent activities to establish technical standards have resulted in the proposal of two new regula-
tory packages. In 1988, EPA's Office of Solid Waste proposed new regulations (40 CFR
Pan 2S8) for operation and maintenance of municipal landfills which would cover codisposal of
sewage sludge with municipal solid waste. In 1989, EPA's Office of Water Regulations and
Standards proposed regulations (40 CFR Pan S03) which identify sludge quality requirements as
well as management practices for sewage sludge use or disposal by means of land application,
distribution and marketing, sludge-only monofills, incinerators, and surface impoundments.
To provide a mechanism for including the technical limits in permits, EPA promulgated regulations
designed to incorporate sewage sludge use and disposal requirements into permits as required
under Section 405(d) of the Clean Water Act On May 2,1989, (published at 54 FR 18716),
EPA issued final revisions to the regulations contained in 40 CFR Pan Parts 122 and 124 which
identify permit requirements under Section 402 of the Clean Water Act These regulations require
inclusion of sludge conditions in National Pollutant Discharge Elimination System (NPDES)
permits issued to municipal sewage treatment works. The regulations also authorize issuance of
permits to facilities which do not discharge wastewater under the NPDES program. In general,
these regulations which already addressed discharges of water, were expanded to cover the sludge
generated as a by-product of wastewater treatment operations.
EPA also promulgated regulations for State sludge management programs (40 CFR Part
Pans 501 and 123) (published at 54 FR 18716; May 2,1989). These regulations specify
procedures for States to receive approval to implement sludge management programs in lieu of the
Federal program. In order to receive program approval, a State must demonstrate adequate legal
authority and administrative procedures to issue permits and determine compliance with and
enforce Federal and State sewage sludge regulations and requirements.
To cany out the congressional directive to take immediate steps before promulgation of technical
regulations, EPA has developed a "Sewage Sludge Interim Permitting Strategy" (1989) (see Ap-
pendix A). EPA's Interim Permitting Strategy: 1) discusses the identification of permitting
priorities; 2) identifies minimum permit requirements; and 3) describes how EPA and the States
will coordinate interim permitting and other activities. The major goal^of the interim program is to
identify and control known or potential problem facilities and target these facilities for more site-
specific permit requirements, thereby facilitating compliance with the technical standards once
promulgated. This will be accomplished by; 1) ensuring that all NPDES permits issued or reissued
to POTWs after February 4,1987 contain certain minimum conditions, including a requirement
that the permittee comply with all existing Federal regulations governing the use and disposal of
5

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Revised 12/1/89
sewage sludge, and with applicable 40 CFR Part 503 technical standards when promulgated; 2)
requiring POTWs to perform sludge monitoring and reporting; and 3) providing case-by-case
permit conditions for POTWs which have been identified as a priority for sludge permitting (i.e.,
pre treatment POTWs and POTWs whose sludge or sludge use and disposal practices have the
potential to adversely affect the public health and environment).
1.3.1 LEGAL BASIS FOR INTERIM SLUDGE REQUIREMENTS
EPA's legal authority to include sludge requirements in NPDES permits for POTWs before
promulgation of technical standards cotnes directly from Section 405(d)(4) of the CWA. As
explained in the previous section, Congress clearly intended that EPA begin regulating sewage
sludge use and disposal immediately, prior to and in the absence of promulgated technical
standards. Also, as noted throughout this chapter, EPA's authority to take interim measures is
very broad and includes taking any measure "the Administrator deems appropriate to protect public
health and the environment from any adverse effects which may occur from toxic pollutants in
sewage sludge." Thus, EPA has a responsibility to identify and address problems caused by
contaminated sludge or poor disposal practices. EPA's authority under Section 405(d)(4) is
flexible enough to address known problems with sewage sludge use or disposal that may fall
outside the core objective to include interim sludge limits in new or reissued POTW permits. For
example, this authority allows the modification of existing permits to address sludge disposal
problems.
Where existing Federal regulations apply to a particular sewage sludge use or disposal practice,
Section 405(d)(4) of the CWA gives EPA the authority to implement the requirement through
NPDES permit conditions (which may simply be a matter of incorporating those requirements by
reference). In addition, 40 CFR Part 122.44(b)(2) requires that permits include standards under
Section 405(d). (This means that the 40 CFR Part 257 requirements, which were promulgated
under the joint authority of RCRA and Section 405 of the CWA, are to be implemented through
NPDES permits unless sufficiently covered in another permit)
In addition to the Clean Water Act, there are several other Federal law^diat provide authority for
regulating various aspects of sewage sludge disposal. These include the Clean Air Act (CAA);
Subtitles C and D of die Resource Conservation and Recovery Act (RCRA); the Marine
Protection, Research, and Sanctuaries Act (MPRSA); and the Toxic Substances Control Act
(TSCA). POTWs already are under an obligation to comply with existing Federal regulations.
Nevertheless, placing Federal regulations in the POTW's NPDES permit reinforces the importance
6

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Revised 12/1/89
of compliance for purposes of the Clean Water Act and helps to ensure that sludge disposal
practices will not threaten public health and the environment It also provides a more direct link to
pretreatment controls which are an important means of improving sludge quality. Table 1-1 lists
current Federal regulations that directly apply to sludge use and disposal. Permit writers should
consult with the program offices responsible for implementing these programs to see if NPDES
permit conditions aimed at improving sludge quality and disposal practices would help ensure
compliance with the existing requirements.
By providing for interim sludge permit conditions before promulgation of the technical standards,
Congress clearly indicated that reliance on the status quo would be insufficient For most, if not
all priority POTWs, existing Federal requirements will not be enough to provide for protection of
public health and the environment Where permit conditions based on existing regulations are
insufficient to protect public health and the environment from adverse effects that may occur from
toxic pollutants in sewage sludge, permit conditions should be developed on a case-by-case basis
using best professional judgment ("BPJ") to fulfill the statutory standard.
Using best professional judgment to develop interim sludge requirements follows the same general
principles used in developing best professional judgment effluent limits in NPDES permits. Permit
conditions developed using BPJ are based on the sound technical opinion of the pennit writer after
consideration of all reasonably available and pertinent data or information. Unlike the technology-
based BPJ effluent limits governed by the criteria in 40 CFR Part 125.3(c), however, BPJ sludge
limits are health-based, i.e., designed to protect public health and the environment from the adverse
effects of toxic pollutants in sewage sludge.
While BPJ authority gives the permit writer considerable flexibility in developing sludge require-
ments on a case-by-case basis, it also places a burden on him or her to show that the permit con-
ditions are based on a sound technical analysis and designed to protect public health and the
environment Like other permit conditions, interim sludge requirements may be subject to legal
challenge; therefore, the need for the permit condition and the basis for its establishment should be
clearly defined and documented (e.g., in the fact sheet for the permit).
1.4 PERMITTING REQUIREMENTS AND RECOMMENDATIONS
This guidance sets forth the existing Federal requirements in each of the major sludge use and
disposal practices. However, for many disposal options or situations, Federal requirements have
not been promulgated. Therefore, this guidance also includes recommendations for each disposal
7

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TABLE 1-1
SLUDGE MANAGEMENT REGULATIONS OF
THE ENVIRONMENTAL PROTECTION AGENCY
Coverage	Reference	Application
Polychlonnated
Biphenyls (PCBs)
Ocean Dumping
New Sources of
Air Emissions'
NESHAPs Mercury
and Beryllium
Cadmium, PCBs,
Pathogenic
Organisms
Extractor!
Procedure Toxicity3
40 CFR Part 761
40 CFR Part 220-
228
40 CFR Part 60
40 CFR Part 61
40 CFR Part 257
40 CFR Part 261
Appendix II
All sludges containing
more than SO
milligrams per kilogram
The discharge of
sludge from barges or
other vessels
Incineration of sludge
at rates above 1,000
kilograms per day
Incineration and heat
drying of sludge
Land application
(including distribution
and marketing) of
sludge, landfills,2
storage lagoons
Defines whether
sludges are hazardous
Source. Use and Disposal of Municipal Wastewater Sludae
(EPA 1984).
1	Revisions to this part were proposed on April 18, 1986 (51 FR
13424). EPA expects to issue a final rule in mid-1938 Additional
limits on air emissions may apply to particular facilities based on a
State Implementation Plan (SIP). SIPs are codified at 40 CFR
Part 52 Other air regulatory programs that may limit emissions
include National Ambient Air Quality Standards (NAAQS) (40
CFR Part 50), New Source Review Standards (40 CFR Part
51 18) and Prevention of Significant Deterioration (PSD) (40 CFR
Part 52.21).
2	Municipal Solid Waste Landfills will be regulated under 40 CFR
Part 258 when regulations are promulgated late m 1990.
3	Regulations are expected to be promulgated m late 1989 where
EP toxicity test will be replaced by TCLP test
8

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Revised 12/1/89
practice. These recommendations are provided to assist permit writers in developing contaminant
limits and management practice requirements on a case-by-case basis to protect public health and
the environment from adverse effects that may occur from toxic pollutants in sewage sludge.
Recommended contaminant limits and management practices are based on Federal guidance and/or
widely applied State requirements or guidelines. Specific recommendations based on State regula-
tions or guidelines alone were adopted after consideration by a work group and in light of
comments received from outside parties.
Table 1-2 lists all pollutants for which Federal or State limits or guidance have been identified for
sludge use or disposal. Limits are not recommended for all these pollutants. It is also important to
note that permit writers are not restricted to addressing these pollutants in writing BPJ limits. If a
particular pollutant is causing or threatening to cause a disposal problem, the permit writer may
place a limit for it in the permit As a general rule, only pollutants of concern (i.e., those which
exceed or potentially exceed the level appropriate to protect public health and the environment),
whether addressed in Federal or State guidance or regulations, should be limited in the permit
Generally, EPA permit writers should also include any applicable State requirements, unless they
are less stringent than what is required by Federal regulation (since Federal requirements must be
included as a minimum). This will help minimize disruption to existing State programs, especially
during the interim phase of implementing Section 405. Again, the permit writer should use best
professional judgment in applying State requirements and recommendations. While incorporation
of State requirements would be appropriate in most cases, permit writers should do as much as
possible to ensure that whatever requirements they adopt can be reasonably defended.
1.5 DEVELOPMENT OF THIS OUTDANCF.
The Office of Water Enforcement and Permits (OWEP) formed a Workgroup on Sludge Permitting
Issues to assist in developing policy and guidance materials. The Workgroup included
representatives from: EPA Headquarters offices with experience in regulating or providing
guidance on sludge use and disposal (including the Office of Water Regulations and Standards
(OWRS), Office of Municipal Pollution Control (OMPQ, Office of Research and Development
(ORD), Office of Solid Waste and Emergency Response (OSWER), alid other offices); all 10 EPA
Regional Offices; and several States (New Jersey, Iowa, Wisconsin, Connecticut, Missouri,
California, and Kansas). The Workgroup reviewed and commented on drafts of policy and
guidance and participated in key early decisions about such issues as permitting priorities.
9

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Poflutam
TABLE t-2
-WWCPOLLUTAMTS* SPECIFICALLY
ADDRESSED IN THIS GUIDANCE
Federal Sla»
Regula- Federal Require-
000
903
Aidrm

X
X
Aluminum

Arsenic
X*
X9
X
X
Barium

XS
X

aeruene

X
X
Bento(a)-pyrana

X
Beryllium
X«

X
X
Bis(2-etfty<-hexy4)<

X
phmalatt

Boron

Cadmium
X4 9
X9
X
X
Carton Monoxide
X«

Chtardane

X
X
CMorme

Chromium
X*
X»
X
X
Cobalt

Copper
X*
X
X
X
Cyanide

XI
x»

2.4-0

OOO/OOE/OOT

X
X
Dietdnn

X
X
Ometfryl-flrtrosamtna

X
Dioxm

X
X
Endnn

x«
X

Fiounda

X*
X

Heptachbr

X
X
(Continued)
* in addrton. parogen reduction standard* wiM apply to land
appttaaon and to dntnbuwn and marfcaong. Sea 40 CFR P*t
297, Appends II.
1 Procau 09t>gn Manual tor Muntao* Sfutfgt landfWa (EPA
1978) raoommanda mcnrtcnnq lor thaw parameter* at Iwidtt*.
2 Prxxau Oastgn Manual of Land Appfecatfort of Municipal
Sludgt (EPA tM3) recommend* monitoring lor tma paranetara
at land apphcaoon m
3 Sian WWnnq and ncortng requirements (or sludge and
compoet (EPA 1987).
4 Prepoaad tmanna to fee new source performance stttdttds to
sewage Mga oqwiui (40 Cf R Part 60) would requae ruta
tattng lor fteee metal*.
5 Maomum Qnoundwawr Contamm** Ur*a from 40 CFR P«t
257 Appendix C. Appendix C also providaa maximum
oontwwant krnta tar coMorm bactana. »*«Wun, aAtfum
and groaa alpha mkebon.
6 Naaonal gn*aawn Standard* lor Hazardoua Atr PoOutMta
(NESHAPJ (40 CFR Pal 61).
' Sewao* *udge ooneewifl over 90 m
-------
TABLE 1-2

(Continued)

Federal

State

Regula-
Federal
Require-
303
Pollutant
tion
Outdance
ments
Proposed
HeptacMor Epoxide

Iron

Load

X,X«
X
X
Lindane

X*
X
X
Uttiium

Manganese

Mercury
X«
x,x«
X
X
Methoxycftlor

XS
X

Mirex

Motyttdenum

X
X
Nickel
x«
X
X
X
Nitrogen Compounds
x«
x*
X

Nitrates

Oil & Greaae

Organcs

Phenols

Pesticides

Phosphorus

X»
X

Potasswm

PCBs
X'
x
X
X
Padium

x,xs
X

Radon

X
X

Selenium
x«
XS
X
X
Silver

x»
X

SiNei

Sodium

Total Hydrocartons

X
Total Org. Carton

Toxaphene

x»

Tnchioro-etftyiene

X
Uranium

x
X

Vinyl Chloride

X
X
Zmc
x«
"X
X
X
' in addrton, pathogen reduction standards will apply to land
appfaealon and to diatnOubon and maifcettng. See 40 CFR Part
237, Appends II.
1 P roc am Oeargn Manual for Municipal Sfadg* LtndMt (EPA
ivrQ) (nrnnmn fflonflonnQ lor vims pvtmowi« voMt.
' Process Oaatgn Manual of Land Apohcutan o t mumao*
Sludge (EPA 1903) recommends monrtonng lor these parameters
ai land appfccaiwn was.
1 State moneonng and reporting requirements lor sludge and
compoi»(€PA 1907).
* Pnipoeed remans to B* new source performance standarda tor
*a«aga Ajdgi incinerators (40 CFR Pan 00) waM requws ma
teaang tor fteee metals.
1 Maamum Groundwater Comamnani Unrti Irom 40 CFR Pan
2S7 Appendix C Appendix C also provides maximum
contamnam kmrta tor coMorro oactene. radium-220, and groae
alpha ra&aaon. i
' Nabonal Emission Standards tor Matenloua Air Potutanta
(NESHAP) (40 CFR Pan OH
r Sewags «udge contanng over SO mgAg PC8e must comply w«i
TSCA(40CFR Part 701).
* National Amo*m At QuaMy Standarta (NAAQ8) (40 CPU Part
SO).
4 «0 CPU Part 297.
11
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Revised 12/1/89
appropriate monitoring and other permit requirements for non-Class I POTWs, and the basis for
developing technical guidance for writing interim limits.
With assistance from OMPC and EPA Regional Offices, OWEP gathered and summarized
information on the technical requirements and guidelines of State sludge programs for use in this
guidance. Upon distribution of the draft guidance in September 1988, States were asked to review
information and submit any revisions or corrections to OWEP. Appendix E presents the
summaries that were revised to reflect this new information. These tables are designed for quick
reference and to direct permit writers to the source of State information. Appendix E reflects the
fact that it was not always possible to distinguish between requirements and recommendations.
The permit writer should be aware of this and should consult with State officials during the course
of a permit's development or review to clarify and distinguish State requirements from State
recommendations.
Similar efforts were undertaken to summarize current Federal requirements and guidance and
summarize other technical literature on sludge use and disposal. Based on the data collected,
OWEP developed draft permitting requirements and recommendations. These were reviewed by
and discussed with staff in OSWER, the Office of Air and Radiation (OAR), the Air Enforcement
Division of the Office of Enforcement and Compliance Monitoring (OECM), OMPC and OWRS
to ensure consistency with requirements of other EPA program offices and with the forthcoming
proposed technical standards under 405(d). OWEP then submitted a draft of this guidance
document to the Workgroup for review and comment EPA released the guidance in draft final
form in September 1988 to States, Regions and interested parties for use in writing POTW
permits. The present guidance has been revised in response to comments received since the release
of the draft final.
REFERENCES
EPA 1978. Process Design Manual for Municipal Sludge Landfills. U.S. Environmental
Protection Agency, EPA-625/1-78-010, October 1978.
EPA 1983. Process Design Manual for Land Application of Municipal"Sludge, U.S.
Environmental Protection Agency, EPA-625/1-83-016, October 1983.
EPA 1984. Use and Disposal of Municipal Wastewater Sludge. U.S. Environmental Protection
Agency, EPA 625/10-84-003, September 1984.
12
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Revised 12/1/89
EPA 1987. State Requirements for Sludge Management, U.S. Environmental Protection Agency,
Office of Municipal Pollution Control and Office of Water Enforcement and Permits, Washington,
D.C., 1987 (Revised 1989).
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Revised 12/1/89
CHAPTER2
APPLICABILITY OF THIS GUIDANCE
This chapter explains the scope of this guidance document and EPA's Sewage Sludge Interim
Permitting Strategy. It also refers permit writers to other guidance documents that might be useful
for addressing specific problems not covered by this guidance. In addition, it provides information
on coordinating with other offices on the development of permit conditions when the publicly
owned treatment works' (POTWs) sludge use or disposal practice may already be regulated under
other programs. Finally, it explains the relationship between sludge permitting and the
pretreatment program.
2.1 FACILITIES COVERED
Based on the language of Section 405(d)(4) of the Clean Water Act (CWA), EPA's Interim Per-
mitting Strategy focuses on POTWs with National Pollutant Discharge Elimination System
(NPDES) permits. Certain minimum requirements, such as compliance and notice provisions and
monitoring requirements, apply eo all new and reissued permits for POTWs. (See Chapter Four
and Appendix A). Ideally, permit writers should evaluate the need for sludge requirements in all
NPDES permits issued to POTWs. However, in the face of limited resources, EPA has identified
a subset of all NPDES POTWs which need to be targeted for more comprehensive permit
coverage. The Interim Permitting Strategy calls this group of POTWs "Class I sludge management
facilities" (this term is synonymous with the "priority" POTW designation used in the earlier draft
of the Interim Permitting Strategy).
Class I facilities are: all POTWs that are required to have an approved pretreatment program, any
other facility with known or suspected sludge problems, and any POTWs using sludge incineration
unless evidence exists to demonstrate absence of existing or potential problems (see Pan m.
Sewage Sludge Interim Permitting Strategy in Appendix A for discussion of "Class I" POTWs).
These facilities will need additional case-by-case sludge conditions unless the permitting authority
determines, based on information about the facility's sludge quality and use or disposal practices,
that the sludge is already adequately controlled. This guidance is primarily directed to the Class I
sludge management facilities.
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Revised 12/1/89
2.2 FACILITIES NOT COVERED
The following types of facilities are not covered by the Interim Permitting Strategy: non-NPDES
POTWs (i.e., POTWs that do not discharge their effluent to surface waters), Federal facilities,
sewage sludge treatment or disposal facilities that are not connected to wastewater treatment works,
privately owned sewage treatment works (including individual septic systems and septage
treatment facilities where septage is trucked in, treated, then land applied), and industrial facilities
that treat domestic sewage as pan of their wastewater treatment activities. However, these other
facilities may cause adverse effects to public health or the environment through sludge use or
disposal practice. The CWA provides EPA with broad authority to take interim measures to
address environmental or public health problems created by sludge quality or practices at these
other facilities. Permit writers should be mindful of the potential need for greater control at these
other facilities and may use this guidance where appropriate to address environmental concerns in a
permit.
This guidance document focuses primarily on sewage sludge generators, i.e., POTWs. However,
effective regulation of sewage sludge to prevent adverse environmental or public health effects may
require controls at the ultimate disposal site as well Permit conditions that address both aspects of
sewage sludge control can be developed when the POTW controls both generation and disposal of
sewage sludge. A POTW that generates sludge, but is not the end user or disposer of the sludge
presents a more difficult situation since the POTW may not be able to easily or effectively ensure
compliance with use or disposal requirements placed on the end users. For example, this could
occur when a small POTW transports its sludge to an incinerator owned and operated by another
POTW, or when a POTW sends its sludge to a privately owned solid waste landfill.
Since the technical standards authorized by Section 405(d) of the CWA will apply to users and
disposers of sewage sludge as well as generators, determining how best to regulate end users that
are not also generous is a significant issue. As a general rule, this guidance recommends that the
less control the POTW or permit authority has over the end use, the more stringent should be the
permit requirements regulating sludge quality. As reflected in the recommendations in this guid-
ance, permit conditions can be developed and applied to a POTW to help assure compliance with
use and disposal requirements by end users. For example, POTWs can be required to label sludge
products to inform the user of safe use practices and limitations that apply to use of the product. In
addition, the permit can prohibit the POTW from disposing of its sludge at a facility not in compli-
ance with applicable Federal requirements (e.g., a landfill that does not comply with 40 CFR Pan
257). EPA does not plan to institute a widespread regulatory program for end users as part of its
IS
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Revised 12/1/89
Interim Permitting Strategy. However, if problems due to the misuse of sludge by end users occur
and they cannot be addressed through POTW permit conditions, the Regions should use their
authority under Section 405(d)(4) of the CWA to take action to address the problem.
2.3 PRACTICES COVERED
This guidance document addresses five sludge use and/or disposal methods, each the subject of a
separate chapter
o Landfilling (Chapter 5);
o Land application (Chapter 6);
o Distribution and marketing (Chapter 7);
o Incineration (Chapter 8); and
o S urface disposal (Chapter 9).
The disposal methods of landfilling, incineration and surface disposal require further explanation to
define how these practices are specifically addressed by this guidance. An explanation of each is
provided below.
2.3.1 LANDFILLING
Guidance in Chapter 5 includes information on two types of landfills which may accept sewage
sludge; sludge-only monofills and solid waste codisposal landfills. Both are cuxrendy governed by
40 CFR Pan 257. EPA has proposed that in the future, monofills will be covered by 40 CFR
Part 503 and co-disposal landfills will be covered by 40 CFR Pan 258. These landfills may also
be regulated under State Subtitle D solid waste programs. Therefore, POTW permit writers and
solid waste offices should coordinate permit development and issuance to ensure that landfilled
POTW sludge is disposed of in an environmentally sound manner and that the landfill accepting the
sludge complies with existing requirements (e.g., 40 CFR Part 257) and is not endangering public
health and the environment As a general rule, this guidance recommends allocating responsibility
for regulating landfilled sludge (through permit conditions or enfoiceiqent actions) based on the
relative proportion of sludge in the landfill. Thus, when a POTW uses a sludge-only landfill
(monofill) for disposal, the POTW permit writer would determine appropriate permit conditions to
prevent the landfill from harming public health or the environment If the POTW sends its sludge
to a landfill that accepts wastes other than sewage sludge (co-disposal), the permit writer should
consult with the appropriate solid waste office on necessary measures when the sludge is a large
16
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Revised 12/1/89
proportion of the landfill (e.g., more than 30 percent) and generally defer to the solid waste office
if the sludge is only a small proportion of the landfill's volume (e.g., under 30 percent). These
guidelines are intended to prevent duplication of effort while making sure that NPDES permit
writers fulfill their responsibility under the CWA to take measures to protect public health and the
environment from problems caused by sludge disposal.
2.3.2 INCINERATION
Guidance in Chapter 8 covers incinerators that accept primarily sewage sludge. Many of these
facilities are subject to regulation under various Clean Air Act programs. Therefore, it is partic-
ularly important for permit writers to determine the current requirements applicable to the facility
for possible incorporation into permit documentation, and to work with air program offices to
develop appropriate permit conditions. If the permit writer determines that the incinerator is
already permitted such that it is not causing a problem to public health or the environment, the
permit writer may incorporate the existing permit into the NPDES permit. This procedure reduces
the duplication of effort
The guidance does not address municipal waste incinerators that may accept small amounts of
sewage sludge. Since sewage sludge is sufficiendy different from other municipal waste to dis-
courage most municipal incinerators from accepting it, the instances in which a POTW sends its
sludge to a municipal waste incinerator should be rare. In this situation, the permit writer should
take reasonable steps to ensure that the POTW does not send its sludge to a facility that is not in
compliance with existing requirements.
Disposal of the ash generated during the incineration will not be discussed in this guidance (or in
the 40 CFR Pan 503 sludge technical regulations) but will continue to be covered under 40 CFR
Part 257 (or 40 CFR Part 258 when promulgated) as a solid waste.
2.3.3 SURFACE DISPOSAL
A recent EPA survey of Solid Waste Disposal Facilities identified 19\500 surface
impoundments, of which 1,938 contain municipal sewage sludge (EPA 1986). EPA also has
information suggesting that some communities use surface impoundments for extended periods of
time suggesting that the practice is the community's method of disposal. In the proposed 40 CFR
Part 503, the Agency defined a "surface disposal site" as an area of land on which only sewage
sludge is placed for a period of one year or longer. The one year time period is used to differentiate
17
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Revised 12/1/89
surface disposal from treatment or temporary storage. During interim implementation and in the
first round of technical standards, EPA does not intend to address temporary sludge storage
practices (e.g. less than one year) or treatment processes. When used for long term storage or
disposal, however, surface impoundments may endanger the environment due to the same types of
problems created by poorly sited or operated landfills. As a general rale, the permit writer should
consider imposing conditions if sludge is held in a surface impoundment for more than one year
(see 54 FR 5824-25 for a discussion of the differences between landfills, surface impoundments,
non-agricultural land application to dedicated land, wastewater treatment lagoons, etc.).
2.4 PRACTICES NOT COVERED
2.4.1 OCEAN DISPOSAL
Ocean disposal of sewage sludge is not covered in the proposed technical standards and is not
covered in this guidance document. Ocean disposal of sewage sludge is regulated by the Marine
Protection, Research, and Sanctuaries Act (MPRSA) (40 CFR Part Parts 220-228). EPA's Office
of Marine and Estuarine Protection currently issues permits pursuant to the sludge disposal require-
ments of the MPRSA. In November 1988, Congress passed the Ocean Dumping Ban Act (PL100-
688), amending MPRSA. Among other things, the purpose of the amendment to this Act is to
terminate the ocean-dumping of sewage sludge by December 1991. At that time, POTWs that
currendy ocean dispose of their sewage sludge will have to implement land-based sludge
management alternatives, which will be subject to the jurisdiction of the CWA. If applicable
sludge standards have not been promulgated, permit conditions will have to be developed on a
case-by-case basis. In the interim, NPDES permits still must include boilerplate standard
conditions, e.g., nodce of changed disposal practice and a compliance provision (which includes a
reopener that would allow the NPDES permit to be modified upon promulgation of the technical
standards). State and Regional permit writers should work with the POTWs and MPRSA
authorities during this interim period to assess the quality of the sludge and assist the POTWs in
developing appropriate land-based disposal methods.
2.4.2 SLUDGE STORAGE
EPA does not intend to address temporary sludge storage practices (e.g. less than one year).
However, the Agency does intend (as included in the proposed 40 CFR Part 303) to regulate
"surface disposal sites." These are impoundments or areas of land on which only sewage sludge is
placed for a period of one year or longer. The one year time period is used to differentiate surface
18
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Revised 12/1/89
disposal from treatment or temporary storage. This guidance document does not cover temporary
storage practices such as sludge lagoons and other surface impoundments where sludge is held less
than one year. Currently, EPA has no evidence to suggest that short-term storage presents an
environmental threat warranting national concern. Nevertheless, EPA has the authority to address
problems created by short-term storage practices if warranted at a particular site. When a permit
writer suspects that problems with storage practices exist, he or she should include conditions to
address the problem in the facility's permit. Problems may occur, for example, at storage lagoons
holding sludges with high levels of contaminants, lagoons that are regularly emptied and
replenished, or those located at sites with particularly important or vulnerable ground-water or
surface water resources.
2.4.3 SLUDGE TREATMENT PROCESSES
Prior to the ultimate use or disposal of sewage sludge, POTWs generally use a combination of
biological, chemical, physical, and thermal processes to treat the sludge. These treatment pro-
cesses are designed primarily 1) to increase the solids content of the sludge by reducing its water
content and 2) to stabilize the sludge by reducing or eliminating pathogens, odors, and volatile
solids. Advantages of such treatment include an improvement in the characteristics of the sludge
for a particular use/disposal practice, an increase in the economic viability of using a particular
practice, and a reduction in the potential for public health, environmental, and nuisance problems.
Chapter 3 briefly describes the various treatment processes, their advantages and disadvantages,
and how they may affect final sludge quality or disposal options. Except in two situations covered
by existing Federal regulations (pathogen reduction requirements and NESHAPs) this guidance
does not cover or prescribe particular sludge treatment processes.
2.4.4 SEPTAGE DISPOSAL
Septage, or the pumpings from septic tanks, is a concentrated waste that may introduce significant
pollutant loads to the environment (particularly ground-water) when disposed on land. While the
trend has been toward discharging septage into POTWs for treatment, various land disposal
methods are still practiced. Under some existing Federal regulations, as well as under the
proposed 40 CFR Part 503 technical standards, septage disposal practices are subject to the same
standards as sewage sludge disposal practices. Currently, land disposal of septage is governed by
40 CFR Part 257. State and local law may also regulate septage disposal. However, septage
disposal is outside the scope of this guidance. Also, as with other facilities or practices that are
generally outside the scope of the existing NPDES permit program, septage disposal is not
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Revised 12/1/89
specifically addressed in EPA's Interim Permitting Strategy. Nonetheless, EPA has the
authority to address known problems with septage disposal. For guidance, permit
writers should refer to EPA's Handbook on Septage Treatment and Disposal (EPA
1984).
2.4.5 DISPOSAL OF HAZARDOUS WASTE
Neither the interim nor the long-term sewage sludge disposal program under Section 405 of the
CWA will govern sewage sludge that constitutes hazardous waste, as determined in accordance
with the RCRA regulations (40 CFR Pan 261). Instead, these sludges will continue to be
regulated under Subtitle C of RCRA (40 CFR Part 264/265).
Sewage sludge is not a listed hazardous waste. Moreover, available evidence from characteristic
tests suggests that POTW sludges are unlikely to be a characteristic hazardous waste. However,
the non-hazardous nature of POTW sludge cannot be assumed, and as sludge generators, POTWs
are required under 40 CFR Part 262.11 to determine whether or not their sewage sludge is a
hazardous waste by virtue of its characteristics.
A solid waste may be a characteristic hazardous waste if it exhibits characteristics of ignitability
(40 CFR Part 261.21), corrosivity (40 CFR Part 261.22), reactivity (40 CFR Part 261.23), or EP
toxicity (40 CFR Pan 261.24). Permit writers should require the POTW to submit the results of
any characteristic tests that have been ran on the POTWs sludge. Although sewage sludge
conceivably could exhibit the characteristics of ignitability, corrosivity, or reactivity, most concerns
about sewage sludge have focused on EP toxicity. Therefore, this guidance recommends that
permit writers include conditions in Qass I permits requiring the POTW to conduct an EP toxicity
test if factors are present indicating a likely EP toxicity problem (e.g., POTW receives significant
loadings of pollutants coveted by the test) and the POTW does not have current data showing that
the sludge is not a hazardous waste. (Note: EP toxicity test will change to Toxicity Characteristic
Leaching Procedure (TCLP) test when the TCLP regulations are promulgated in final. See
discussion, Chapter 5).
If a POTW sludge turns out to be a hazardous waste but is not currently being regulated under
RCRA, the permit writer should notify the RCRA office, which will be responsible for regulating
sludge generation and disposal. The permit wntcr need only include the standard sludge condi-
tions (e g., notice requirements, compliance provision) in the POTWs NPDES permit. (Note:
Where appropriate, these standard provisions may be added in conjunction with the effort currently
->n
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Revised i 2/1/89
underway to reopen permits of POTWs that are RCRA "pertnit-by-rule" facilities to add corrective
action requirements.)
2.5 RELATIONSHIP BF.TWEEN SLUDGE PERMITTING AND THE PRETREATMENT
PROGRAM
Reducing the amount of pollutants entering a POTW typically reduces the amount of contaminants
in sewage sludge. A major goal of die national pre treatment program is to ensure that non-domes-
tic discharges to a POTW do not interfere with the POTWs chosen sludge use or disposal practice.
Further, an objective of the pre treatment program is to improve opportunities for the reuse and
recycling of municipal effluents and sludges. POTWs that are required to have approved local
pre treatment programs and those that experience recurring sludge contamination problems may
have to develop or recalculate local discharge limits for their users in order to reduce the pollutants
in the sludge to acceptable levels. (See 40 CFR Part 403.5(c).) Therefore, if the POTW cannot
meet current sludge requirements because of high contamination levels, the permit writer could
consult with the pre treatment approval authority to consider requiring the POTW to develop
additional local limits. Additional information about detecting and remedying sludge contamination
problems can be found in two EPA guidance documents available from the Office of Water
Enforcement and Permits (OWEP): Guidance Manual for Preventing Interference at POTWs
(September 1987) and Guidance Manual on the Development and Implementation of Local
Discharge Limitations Under the Pre treatment Program (November 1987).
REFERENCES
EPA 1984. Handbook on Septage Treatment and Disposal U.S Environmental Protection Agency,
Municipal Environmental Research Laboratory, EPA 625/6-84-009, October 1984.
EPA 1986. Subtitle D Study Phase I Report. U.S. Environmental Protection Agency, EPA
1530/SW/86-054, October 1986.
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Revised 12/1/89
CHAPTER 3
OVERVIEW OF SLUDGE TREATMENT PROCESSES AND
THEIR EFFECT ON SLUDGE PROPERTIES
3.1 INTRODUCTION
The following section provides a brief discussion of sludge treatment processes. The processes
are outlined here since many NPDES permit writers have not been responsible for sludge
regulation in the past, and may be unfamiliar with sludge management practices. Processes used to
dewacer, stabilize, and condition the sludge may directly effect sludge quantity and quality, while
the type of wastewater treatment techniques used, such as chemical coagulation or lime addition,
will effect sludge characteristics and contaminant levels.
The quality of a sludge that does not comply with use or disposal guidelines can sometimes be
improved by more careful sludge processing or by the use of different treatment processes. In
other cases, users of the POTW will need to improve the pre treatment of their wastewaters or the
POTW may need to employ different use or disposal options.
3.2 SLUDGE TREATMENT ALTERNATIVES
Several techniques are commonly used to process sludge before ultimate use or disposal. Some of
the more widely used processes are discussed briefly below. For more detailed descriptions, see
the EPA Process Design Manual for Sludge Treatment and Disposal (EPA 1979).
3.2.1 THICKENING
Thickening is generally the first process in a solids processing train. It increases the solids content
of sludges by removing some of the water. Thickening typically increases the solids concentration
in the sludge two to ten times, thus reducing the volume of sludge to be treated in subsequent
processes to one-half to one-tenth the original volume. Because sludge processing and disposal
costs are gready affected by sludge volume, thickening can significant^ reduce capital and
operating costs of subsequent operations.
Process equipment that may be used to thicken sludge includes gravity thickeners, dissolved air
flotation thickeners, centrifuges, gravity-belt thickeners, and rotary screen thickeners. Sludges
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Revised 12/1/89
from primary, biological, and chemical wastewater treatment can be blended and mixed in common
thickeners or thickened separately.
3.2.2 STABILIZATION
Stabilization processes decrease volatile solids, offensive odors and pathogens in wastewater
sludges. Offensive odors are lessened by decreasing the volatile content of sludges or by changing
the sludge properties so thai the sludge decomposes less rapidly. Some stabilization processes,
especially aerobic and anaerobic digestion, also substantially reduce the quantity of suspended
solids in the sludge. Stabilization technologies include anaerobic digestion, aerobic digestion,
composting, lime treatment, and chemical fixation.
Anaerobic Digestion
Anaerobic digestion is a biological process that is widely used in municipal wastewater treatment
plants to stabilize sludge. The process is accomplished by maintaining the sludge at elevated
temperatures for about 10 to 30 days in the absence of free oxygen. The organic matter in the
sludge is biologically decomposed and the pathogen content is reduced The volatile content of the
sludge is typically reduced by about 50 percent, which in turn reduces the sludge volume by about
30 percent.
The two operational temperature modes of anaerobic digestion are mesophilic (90 to 95°F) and
thermophilic (120 to 13S°F). Thermophilic digestion requires a much shorter solids retention time
thus reducing the required digester capacity by about SO percent Thermophilic digestion also
reduces the pathogen content more than mesophilic digestion.
Aerobic Digestion
Aerobic digestion of sludge is similar to the activated sludge treatment of wastewater. Both of these
processes rely on biological treatment under aerobic conditions. The capital costs of aerobic
digestion systems are typically much lower than the capital costs of aa anaerobic digestion system.
Because a large amount of energy is required to provide oxygen for biological activity, aerobic
digestion is typically used in smaller plants where the reduction in capital costs more than
compensates for the increased energy requirements. Aerobic digestion is also generally easier to
operate by a small project staff.
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Revised 12/1/89
Lime Treatment
Adding lime to raw sludge to raise the pH to 12 or greater for two hours decreases the
concentration of pathogens and other organisms in the sludge and inhibits decomposition.
However, as the pH of the sludge drops after lime stabilization, biological decomposition will
resume, producing offensive odors.
The advantages of lime addition include lower costs and simplicity of operation. Nonetheless,
sludge remains stabilized only as long as the high pH is maintain^ Disposal costs are also
increased because the large quantity of lime added to the sludge increases sludge volume.
Chemical Fixation
In the chemical fixation process, chemicals are added to solidify the sludge mass, render it
inoffensive, and decrease the teachability of metals. Although there is no decrease in volume, the
sludge is made stable. Chemical fixation is best performed after dewatering, which reduces the
volume of sludge requiring final disposal.
The process is carried out by adding chemicals to a sludge, producing a colloidal solid that "sets"
into a semi-rigid mass. The product can be handled as a solid material that can be landfilled, or
used for landfill cover.
3.2.3 CONDITIONING
Sludge conditioning refers to physical and chemical methods for altering the properties of sludge to
improve its dewatering characteristics. In general the goal is to transform the hydrophilic, gel-like
solids into a porous material that will release water. Proper conditioning improves the efficiency of
the dewatering process. The two methods most commonly used are the addition of chemicals and
heat conditioning.
Chemical Conditioning
Common chemicals used before dewatering include inorganics, such as lime and feme chloride,
and high-molecular-weight organic polymers. Chemical conditioning is widely practiced
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Hmi Conditioning
The process involves heating sludge in a closed reactor to temperatures of 300 to 400°F. The
reactor is under pressures of 250 to 300 psig, and holds the sludge under these conditions for 20 to
30 minutes. Heat treatment makes solids coagulate, breaks down the gel-like structure, and reduces
the water in the sludge solids. As a result, the sludge is sterilized and readily dewatered, without
adding chemicals, to a solids content of 30 to 45 percent Heat conditioning is much less common
than chemical conditioning due to its high energy usage.
3.2.4 DEWATERING
Dewatering converts sludge from a flowing mixture of liquid and solids to a cake-like substance
more readily handled as a solid. Mechanical and heat drying techniques may be used In addition to
significantly reducing the moisture content, dewatering reduces sludge volume, increases the fuel
value of a sludge, and decreases transportation costs for final disposal. Dewatering also prepares
sludges for such forms of ultimate disposal as combustion, landfllling, or land application. For a
more detailed description of municipal sludge dewatering, see Dewatering Municipal Wastewater
SllldgCS (EPA 1987).
Mechanical Dewatering Methods
Mechanical devices for dewatering include vacuum filters, filter presses, centrifuges and belt filter
presses. Sludge cakes discharged from these units will generally be 12 to 45 percent solids,
depending on the sludge being dewatered, the type of conditioning employed, and the dewatering
device. In general, belt presses and centrifuges are preceded by polymer conditioning; fitter presses
are preceded by inorganic chemical, heat, or ash conditioning: and vacuum filters by any of the
above methods. Many wastewater treatment plants employ mechanical methods for dewatering
sludge.
Heat Prying
Heat drying is the process of evaporating water from sludge by thermal means. Hie units most
commonly used evaporate the water by direct drying, that is, hot air directly contacts the sludge to
be dried, as in a rotary kiln. The heat-dried products generally contain 10 percent moisture or less.
Heat drying is employed at a few treatment plants (e.g., Milwaukee, WI and Houston, TX), and is
usually used to produce products such as Milorganite and Huactonite.
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Multiple-Effect Evaporation
The Carver-Greenfield Light Oil Process (oil-medium dehydration) is a patented technique for the
evaporation of water from sludge. It produces either a sterile fertilizer or a dry (approximately 95
percent solids content) product capable of being utilized as an energy source. At the present time,
the Carver-Greenfield Light Oil Process is an innovative technology. Units are under construction
or starting up at four POTWs in the U.S.
Air Drying
A variety of natural solar evaporation techniques including sand drying beds, vacuum assisted
beds, paved beds, and lagoons are used by a large number of POTWs. Liquid sludge is naturally
dewatered by drainage and by evaporation to the air. Sludges are placed in drying beds or lagoons,
allowed to dry and then removed. However, the use of drying beds is generally limited to areas
with available land and suitable climates (i.e., annual evaporation rate exceeds annual rainfall
unless covered drying beds are used). Despite the limitations of natural solar evaporation
techniques, drying beds and lagoons are common at small POTWs throughout the country. Some
large POTWs, such as Chicago and San Diego, have used drying beds, lagoons and paved beds
for sludge dewatering.
3.2.5 COMPOSTING
Composting is a sludge stabilization process normally performed after dewatering. In composting,
the organic constituents of the sludge are aerobically decomposed. The decomposition of organic
matter as a result of heat produced by biological activity during composting of the sludge reduces
pathogens as well as volatile materials that cause odors. The final compost product is a humus-like
material suitable for use as a soil conditioner and low nutrient fertilizer
In general, the composting process consists of mixing dewatered sludge, either raw or digested,
with a bulking agent such as woodchips, sawdust or finished compost to increase the porosity and
to reduce the moisture content The mixture is then aerated for some time (11 to 15+ days) to raise
the temperature and further decrease moisture content through evaporation. The high temperature
(about 550O ensures pathogen destruction and aids in reducing the moisture content The compost
is then usually cured by storage at lower temperatures for extended periods. The compost product
is often screened to recover and reuse coarse bulking agents such as woodchips.
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Composting methods include windrow, static-pile, and a variety of in-vessel composting
techniques.
Three example sludge treatment trains are shown in Figure 3-1. Many other configurations are also
commonly in use. While some preliminary sludge treatment processes are designed for specific
final disposal methods, most preliminary processes can be used with a number of final disposal
methods. Permit writers should be familiar with the treatment processes being used at a particular
facility.
3.3 PATHOGEN REDUCTION
3.3.1 PROCESSES TO SIGNIFICANTLY REDUCE PATHOGENS (PSRP)
40 CFR Part 257, promulgated under the joint authority of the Clean Water Act and Subtitle D of
RCRA, requires that sewage sludge applied to land (either applied to the land surface or
incorporated into the soil) be treated by a process to significandy reduce pathogens (PSRP). In
addition, three site restrictions must be met: 1) public access to the land must be prevented for 12
months; 2) grazing by animals whose products are consumed by humans must be prevented for
one month; 3) no crops directly consumed by humans where the edible portion of the crop comes
into contact with the sludge amended soil may be grown for 18 months. (These restrictions do not
apply to sewage sludge that is disposed of by trenching or burial operations.)
Of the sludge treatment processes discussed above, aerobic digestion, air drying, anaerobic
digestion, composting, and lime stabilization are accepted as PSRPs in 40 CFR Part 257. In
addition to the processes discussed above, other sludge treatment methods may be acceptable under
40 CFR Pan 257 if pathogens and vector attraction of the waste are reduced to an extent equivalent
to the reduction achieved by the listed PSRPs. (See discussion on PSRP and PFRP equivalency
below.)
3.3.2 PROCESSES TO FURTHER REDUCE PATHOGENS (PFRP)
Under certain circumstances, sludge that is applied to land (on the surface or incorporated into the
soil) must be treated by a process to further reduce pathogens (PFRP), which is more stringent
than PSRP. 40 CFR Part 257.3-6 requires that sludge applied to land where crops for direct
human consumption are grown within 18 months of the sludge application, and the crops will
come in contact with the sludge-amended soil, must be treated by a PFRP. Where sludge is
27
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Figure 3-1. Example Sludge Treatment Trains
S6C0N0AWV SLU0Q6
mini t
(MSATTDCATUetn
LAACOIWOMt.
28
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Revised 12/1/89
treated by a PFRP, no public access or grazing restrictions apply.
Processes to Further Reduce Pathogens (PFRPs) destroy a greater number of pathogens than
PSRPs do. PFRPs include more extensive composting, heat drying, heat treatment, and
thermophilic aerobic digestion. PFRPs generally operate at higher temperatures than PSRPs.
Other methods or operating conditions may also be acceptable PFRPs if pathogens and vector
attraction of the waste are reduced to an extent equivalent to the reduction achieved by any of the
above PFRP methods. (See discussion of PSRP and PFRP equivalency below.) In addition, any
PSRP may be considered to be a PFRP if augmented by beta ray irradiation, gamma ray
irradiation, pasteurization, or other methods that result in an equivalent reduction to these add-on
methods.
3.3.3 PSRP AND PFRP EQUIVALENCY
As stated above, 40 CFR Part 257 acknowledges that other treatment methods or other operating
conditions may be acceptable if they reduce pathogen and vector attraction to an extent equivalent to
that achieved by the processes specified in the regulations. Equivalent methods may be
modifications to a named PSRP or PFRP, a new process, or a combination of processes.
The equivalency of these "other" processes are based on documenting equivalent treatment. For
PSRP the process must consistently reduce pathogenic viruses and bacteria densities by 1 log (base
10), and for PFRP the operating conditions must ensure pathogenic reduction to below detection
limits. In addition, PSRPs and PFRPs must reduce vector attraction to the same extent as the
reduction achieved by a good anaerobic digester.
A Pathogen Equivalency Committee (PEC) was formed by EPA in 1985. The committee reviews
and makes recommendations to EPA management on applications for PSRP and PFRP
equivalency. The Committee does not formally approve or disapprove methods or operational
conditions but rather provides guidance to the applicants on providing the necessary data to
determine equivalency.
Equivalency determinations in the past have shown most processes submitted to be equivalent on a
site-specific basis only. Generally, equivalency has applied only to a particular operation run at a
particular location under specified conditions. However, one process has demonstrated national
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equivalency because of its ability to consistently achieve the desired reductions in
pathogens and vector attraction under the variable conditions that could be encountered
around the country.1
An EPA document entitled Environmental Regulations and Technology. Control of Pathogens in
Municipal Wastewater Sludge (September 1989) describes the PSRP and PFRP processes listed
under current regulation, how equivalency is determined and the process and data needed when
submitting a method or operating condition for an equivalency determination.
3.4 EFFECT ON SLUDGE PROPERTIES
Some sludge processes have litde effect on the concentration of pollutants in the sludge while
others increase or decrease the concentration of pollutants. Simply removing water (as with gravity
thickening or dewatering) does not change the concentration (mass of pollutants/mass of solid) of
pollutants in the sludge solids. But digestion and other stabilization processes that decrease the
volatile fraction of the sludge increase the concentration of non-biodegradable pollutants. Table 3-1
shows how processes that reduce the volatile fraction of sludge increase the concentration of metals
in the remaining sludge solids. Conversely, the addition of materials such as bulking agents for
composting or chemicals for stabilization decreases the overall concentration of metals in the sludge
or sludge product
Some toxins can be biodegraded by stabilization processes or can be removed from the sludge by
volatilization. However, data on these mechanisms for loss of organic pollutants is very limited.
Changes in sludge pollutant concentrations are important since many sludge reuse or disposal
requirements are limited by contaminant concentrations and/or loading rates.
Advanced Alkaline Stabilization with Subsequent Accelerated Drying (AASSAD)
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TABLE J-1
INCREASED METALS CONCENTRATION
OURINO PROCESSING (m*hg dry
Raw Lagooned
Primary Sludge Sludge
Element (79% votanta) I5fl% vtnatiai
Chromium
no
220
Copoer
200
490
Nickel
4«
69
Zinc
020
1,400
No. Samples
9
30
NOTE. 1977 data, Sacramento County Central treatment plan.
CaWomt*
Source: EPA 1979.
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REFERENCES
EPA 1979. Process Design Manual for Sludge Treatment and Disposal, U.S. Environmental
Protection Agency, EPA 625/1-79-011, September 1979.
EPA 1987. Design Manual: Dewatering Municipal Wastewater Sludges, U.S. Environmental
Protection Agency, EPA 625/1-87AJ14.
EPA 1989. Environmental Regulations and Technology: Control of Pathogens in Municipal
Wastewater Sludge, U.S. Environmental Protection Agency, EPA 625/10-89-006, September
1989.
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CHAPTER 4
SUMMARY OF PERMITTING PROCEDURES AND REQUIREMENTS
This section gives the permit writer some basic guidance for developing permit requirements
for sludge. It addresses what application data are needed, the priority of permits to consider
for case-by-case development of sludge requirements, standard permit conditions for all POTW
permits, and recommended monitoring requirements.
41 GATHERING INFORMATION
At present, the Federal permit application forms for POTWs (Standard Form A and Short
Form A) ask for some information that may be useful in evaluating and developing permit
limits for sludge. These forms request information concerning basic influent and effluent
characteristics and use of wastewater treatment lagoons. However, they do not ask for specific
information on sludge quality, treatment, use, or disposal. The recently promulgated State
sludge management program rules and revisions to the NPDES regulations (54 FR18716,
May 2,1989) require the following application information when the POTW applies for
issuance or reissuance of its NPDES permit: annual sludge volume, other permits held or
requested, a topographical map extending one mile beyond the POTW's boundaries, a narrative
description of POTWs use and/or disposal practices, any sludge monitoring data the applicant
may have and any other information requested by the permit writer. [40 CFR Pan
122.21(d)(3)(H); 501.15(a)(2)!
Whether any additional information is necessary to write the permit will depend on such factors
as whether the POTW has been identified as a Class I facility, and on the type of sludge use or
disposal option(s) the POTW uses. Table 4-1 describes how information may be used by the
permit writer when establishing sludge requirements. To evalutate whether additional specific
information is needed, either to determine if the POTW should be treated as a Class I facility or
to develop case-by-case permit conditions, the permit writer will need to refer to the permit
requirements and recommendations under the applicable use or disposal option in Chapters 5
through 9. Permit writers should use this preliminary evaluation as a basis for developing a
"sludge fact sheet" for the POTW that can be used in permit development and preparation of the
permit fact sheet (for Class I permits).
The tables in Appendix E can serve as a tool for permit writers by identifying State require*
ments and recommendations. The permit writer will need to ascertain whether the practice cited
in Appendix E is a requirement or a recommendation because this distinction is not made in
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TABLE 4-1
INFORMATION GATHERING FOR
WRITING SLUDGE CONDITIONS
Oata Use
State or local bans or
prohibitions
0kng and Anafyaa Qudanca.
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TABLE 4«1 (continued)
INFORMATION GATHERING FOR
WRITING 3LUOQE CONOIDONS
Oata uaa
Chermcala used m dewaaermg
process
On-srte sludge storage
practtcn
Potential toxic contamination m
Hudga
Determine need for conditions for
long-term storage
When was sludge held on-srts
generated (eg., in wastewater
lagoons or sludge stockpiles)?
Sludge quality
Characteristic Hazardous
waste determination (e.g. BP
toxicity test)
Influent quality
¦ Influent flowstoadings
(BOO.TSS, priority "
pottutanis)
¦ Percentage of flow ant
loadings from mdustnal
sources
• Types o< industrial
contntxiWns
- Pretreatment used Dy
industrial contributors
Historical sludge management
prodlems in the
generator/transporter/
applcator/owner relationship?
Compliance history
¦ significant noncompkance
or c&an compianta due to
sludge uMMtapoul
Unuautf areumetances at
POTW ordapoeal «e (eg..
Mftaa
K Kudge • lantflWed, dwposal
in monoM or co-dopcsai
if sludge * land ..
of land (eg., croos grown)
Topographs rrap
Age of sludge may affect quaMy
Oevelop disposal plan for
wastewater lagoon sludge if
scheduled tor emptying.
Determine compliance with
use/disposal option requirements.
See Sections 4.4 & 4.5' for
recommended monitoring
requirements.
if sludge is a nazardous waste,
defer to RCRA regulation (see
Chapter 5).
Help estimate sludge quaMy and
Quantity.
Heio identify potential sludge
contammaaan problems and
sources.
Pretreatment information can help
permit writer and POTW
determine if needed improvements
m sludge Quanty are feastte
through additional pretreatment
May indicate need to develop
more comprehensive solution than
POTW permit conditions alone..
Determine need to dasarty m a
pnorrty or develop condAonsto
Determine need to ctaserty as a
pnonty or develop conaoona to
addrees problem.
For co-disoosal w* need to
consult mm sow mm officula
(Me Chapter 5).
Additional retirements apply to
food-chart cropland.
identidee locaeon of any sludge
management factoee and
potoneat s*ng proetema.
¦> e
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Revised 12/1/89
Appendix E. For example, California pollutant concentration limits for land application and
distribution and marketing are only recommended, not required.
Sampling and analysis data that may be needed for application purposes is discussed in
Sections 4.4 and 4.5.
4.2 SECONDARY INFORMATION SOURCES
Although the POTW has the burden of supplying the information needed to write the permit,
the permit writer can also use secondary sources of information to gain background data on
sludge practices and their potential impacts on public health and the environment Use of these
other sources may be helpful to supplement or confirm information received from the POTW.
Listed below are potentially helpful information sources.
o EPA's National Sewage Sludge Survey (FY90). 400+ POTWs were surveyed for
information on sludge use and disposal practices and 200 were sampled for actual sludge
quality data.
o State solid waste disposal program plans. POTW solid waste/sludge management plans;
State application forms.
o EPA Construction Grants program information. This includes the NEEDS base that
describes all treatment processes used at the POTW and other basic information about the
facility's design and operation. Construction grants staff may also be helpful in estimat-
ing expected sludge quality and quantity from particular plants and in evaluating whether
sludge use or disposal practices are designed and operated in an environmentally sound
manner.
o Pre treatment program information. Information such as types and amount of industrial
loadings to the POTW and past or present sludge quality problems can be found in the
POTWs pre treatment program application, annual reports, and audit reports.
o NPDES compliance inspections or diagnostic evaluations. Reports of these activities may
indicate problems that may adversely affect sludge processes or quality (e.g., problems
with settling may indicate the presence of sludge with too high a moisture content to be
used for practices requiring a relatively high percentage of solids).
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Revised 12/1/89
o Local or State health agencies, extension agencies, and university agricultural research
departments. These sources may be particularly useful to consult about particular site
characteristics or problems.
o Basin Plans and Water Quality Management Plans. These sources may help identify
sensitive disposal sites, e.g., wedands, drinking water aquifers, etc.
4.3 SETTING PRIORITIES
Before developing permit conditions, a permit writer must determine whether the POTW
should be considered as a Gass I priority facility for sludge permitting. The process for
identifying priority POTWs is explained in EPA's Interim Permitting Strategy (see Appendix
A). Briefly, Gass I sludge management facilities arc those POTWs with approved pre treatment
programs and any POTW designated as Gass I due to the greater potential for their sludge or
their sludge use or disposal practices to adversely affect public health or the environment (e.g.,
incinerators). In ascertaining whether a POTW, not subject to pre treatment regulations, should
be considered a Gass I or priority facility, permit writers will need to take reasonable steps to
collect and evaluate available evidence to determine if problems or potential problems exist.
Evidence consists of information received from primary and secondary sources during the
application process, together with information in this and other guidance on potential
environmental problems associated with POTW sludge use or disposal practices. See Section
m of the Interim Permitting Strategy for examples of potential Gass I sludge management
facilities beyond the pre treatment cities.
4.4 STANDARD PERMIT REQUIREMENTS
4.4.1 GENERAL
All reissued or new permits must include some general requirements for sludge use and
disposal, whether or not the facility needs additional case-by-case conditions. Most of the
provisions are required by the recently promulgated State sludge management program and
permitting regulations (54 FR18716). The four primary areas each permit must address are:
compliance with existing requirements and with 40 CFR Part 503 regulations when
promulgated; reopening the permit when die 40 CFR Pan 303 regulations are promulgated;
notification of change in sludge practices; and sludge quality monitoring.
37
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The first standard permit condition is that the permit must require the POTW to comply with all
existing requirements for sludge use and disposal. For example, those POTWs who land
apply sludge must comply with all applicable requirements under 40 CFR Part 257. The
permit writer should also ascertain if there are any existing peimits which govern the facility's
sludge use and disposal practices. If these are adequate to satisfy the requirements of Section
405(d), the NPDES need only reference the other permit, and add any additional requirements
necessary to protect public health and the environment. This compliance provision should also
notify the permittee that compliance with the final 40 CFR Part 503 sludge technical standards
by the deadlines established in the rule will be required regardless of whether or not the permit
is reopened
The reopener clause is another standard condition which must be included in the NPDES
permit It authorizes reopening of the permit to include technical standards if the technical
standards are more stringent or more comprehensive than the conditions in the permit. The
reopener provision notifies the permittee of future legal obligations under the CWA, and of the
potential need to modify the permit to incorporate 40 CFR Part 503 requirements once they are
promulgated. Note that the POTW is required to comply with applicable Part 503 requirements
whether or not such requirements have been incorporated in its permit.
The notification provision requires the permittee to give notice to the permitting authority when
a significant change in the sludge use or disposal practice is planned that could require modi-
fications to the permit. Notice of new use or disposal sites that were not previously identified
is also required.
In addition to the standard sludge boilerplate conditions described above, many of the standard
permit conditions that apply to effluent discharge activities will also apply to sludge use and
disposal activities (e.g.f duty to mitigate, duty of proper operation and maintenance, and entry
and inspection requirements). Other conditions have been modified to specifically address
sludge use and disposal (e.g., record keeping for 5 years). Conversely, a few of the 40 CFR
Part 122 regulations have been revised to limit their applicability only to effluent discharge
activities (e.g., anti-backsliding). Further discussion of these standard requirements can be
found in Appendix A.
4.4.2 MONITORING REQUIREMENTS
Current regulations require sludge monitoring and reporting at a frequency dependent on the
nature and effect of the permittee's sludge use or disposal activities, but at least once a year [40
38
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Revised 12/1/89
CFR Part 122.44(c)(2) as revised May 2, 1989]. This means that if the permit contains a
permit limit for a certain parameter, the permit must also require the permittee to sample and
analyze that pollutant at least once a year. Monitoring results should be reported on the
discharge monitoring report CD MR) or standard form identified in the permit.
Given the fact that few permits arc likely to contain pollutant limits, compliance monitoring will
not yield enough information to fully characterize the sludge quality. The Interim Permitting
Strategy (Appendix A) has put forth a sewage sludge monitoring policy in order to ensure that
permit writers have enough information on sludge quality to evaluate the impact of the
permittee's sludge use or disposal practices. The Interim Permitting Strategy recommends the
following monitoring:
o For Class I POTWs. an annual scan of the 126 priority pollutants, and more frequent
monitoring of the pollutants for which numeric limits have been proposed in the proposed
40 CFR Pan 503 regulations for the POTWs particular use or disposal practice.
o For non-Class I POTWs with industrial users, a priority pollutant scan at the time of
permit application, and annual monitoring of the pollutant for which 40 CFR Part 503
technical standards have been proposed
o For non-Class I POTWs with no industrial users, annual monitoring of six metals:
cadmium, copper, chromium, lead, nickel, and zinc.
A list of the pollutants for which technical standards have been proposed is contained in the
monitoring discussion for each disposal option, in subsequent chapters. Permit writers may
relax these monitoring requirements after the absence of particular priority pollutants (or
detection at low levels clearly show no cause for concern) has been established through
repeated testing. Future testing for those pollutants need not be required unless a change
occurs in thePOTW.
Permit writers need not require annual monitoring for POTWs that use wastewater stabilization
lagoons as their sole treatment process if the sludge will not be removed for disposal during the
permit term, unless the permit writer determines monitoring is needed. If such permit does not
require monitoring, it should contain a requirement that the permittee notify the permit authority
if it happens that the sludge is pumped out of the lagoon within a one year period. The permit
writer will then need to modify the permit to require monitoring and impose sludge use or
disposal conditions.
39
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Revised 12yi/89
Permit writers will also need to specify monitoring methodologies in the POTWs permit The
NPDES regulations specify that permittees be required to monitor sludge according to test pro-
cedures approved under 40 CFR Part 136 unless otherwise specified in 40 CFR Part 503,
when final, or unless test procedures are specified in the permit Permit writers should refer to
the FOTW Sludge Sampling and Analysis Guidance Document (EPA, August 1989) for
additional information on appropriate sludge sampling and analytical procedures.
4.5 ADDITIONAL PERMIT REQUIREMENTS FOR CLASS I POTWs
4.5.1 CASE-BY-CASE SLUDGE CONDITIONS
In addition to the standard permit conditions described above, permits for Qass I POTWs must
include any requirements (management practices and/or sludge concentration limits) developed
on a case-by-case basis that the permit writer determines may be necessary to protect public
health and the environment The basis for these limits should be explained in a fact sheet
modeled after the NPDES fact sheet developed for majors. Chapters 5 through 9 discuss
additional conditions the permit writer may want to include on a case-by-case basis.
4.5.2 CASE-BY-CASE MONITORING REQUIREMENTS
As stated earlier, the Interim Permitting Strategy recommends that Class I POTWs be required
to perform an annual priority pollutant scan and more frequent monitoring of the pollutants
proposed in 40 CFR Part 503. This monitoring would be in addition to the current NPDES
requirement for annual compliance monitoring for those pollutants limited in the permit There
are several circumstances for which permit writers should determine additional monitoring fre-
quencies and parameters on a case-by-case basis. More frequent monitoring might be appro-
priate, for example, where the POTWs influent varies considerably and safe use or disposal
depends on careful limiting of particular pollutants. In particular, permit writers should con-
sider requiring more frequent monitoring for commonly occurring metals (e.g., Cd, Cu, Cr,
Pb, Ni, Zn) since the harm posed by metals is well documented, there am more limits and
guidance on regulating metals, and analysis for metals is relatively inexpensive. Other types of
monitoring (e.g., ground water monitoring, soil sampling) may also be appropriate depending
on the specific conditions surrounding the use or disposal practice. Specific recommendations
for monitoring requirements are discussed in Chapters 5 through 9 for each disposal practice.
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Revised 12/1/89
CHAPTER 5
LAND FELLING
5.1 INTRODUCTION
According to current EPA estimates, 42 percent of municipal sewage sludge generated in the
United States is disposed of in landfills. This figure includes the 1 percent of sewage sludge
generated that is disposed of in sludge-only landfills (54 FR 5756). The two types of sludge
landfilling practices are (EPA 1978):
o Sludge-only disposal (or "monofilling") - sludge is buried alone, usually in trenches; and,
o Co-disposal - sludge is buried in a municipal solid waste (refuse) landfill
Non-hazardous municipal sludge is considered a solid waste residual generated during wastewater
treatment It is regulated at the Federal level by the Gean Water Act and Subtitle D of the Resource
Conservation and Recovery Act (RCRA). Subtitle D established a cooperative framework for
Federal, State, and local governments to control the management of non-hazardous solid waste.
As part of this framework, EPA promulgated criteria in 1979 that set minimum performance
standards for all solid waste disposal facilities. These "Criteria for Classification of Solid Waste
Disposal Facilities and Practices" (40 Part CFR Part 257) consist of location, design, and
operational performance standards that must be met by solid waste management facilities. The
landfill criteria pertain to endangered species, surface water, ground-water, disease, air quality,
public safety, and proximity to floodplains (EPA 1986b).
Currently, sludge-only monofills and co-disposal landfills are regulated a the Federal level under
the Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR Part 257).
In the future sludge-only monofills will be regulated under the new Standards for the Disposal of
Sewage Sludge regulations (40 CFR Pan 503), while co-disposal landfills will be regulated under
the Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) that are being developed by the
Office of Solid Waste. The Criteria for Municipal Solid Waste Landfills were proposed on August
30,1988 (53 FR 33314) and are expected to be promulgated in March 1990. 40 CFR
Pan 258 requires that the POTW sending its sludge to • landfill ensure that the sludge is
nonhazardous, that the sludge passes the paint filter liquids test, and that it goes to a State permitted
landfill. Until these new rules are promulgated, however, only the existing requirements of 40
CFR Part 257 have the force of regulation.
41
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Revised 12/1/89
5.1.1 PERMITTING RESPONSIBILITIES
Permits issued to POTWs that dispose of their sludge in sludge-only monofills or co-disposal
landfills must require that the POTWs use facilities that comply with existing Federal regulations
for solid waste disposal facilities (40 CFR Part 257). By including such a requirement, permit
writers can ensure that the POTW's sludge will be disposed of in accordance with existing
regulations, even if the POTW does not own or operate the landfill receiving its sludge. Where the
FOTW owns and operates the sludge-only monofill or co-disposal landfill receiving its sludge, the
permit writer should request certification that the landfill is in compliance with 40 CFR Pan 257.
When the sludge is being sent offsite to a monofill or co-disposal landfill that is not owned and
operated by the POTW, the permit writer should contact State, local and EPA solid waste officials
to ascertain whether the facility is in compliance with 40 CFR Part 257 requirements. The 40 CFR
Part 257 regulations which apply to sludge-only monofills and co-disposal landfills are
summarized in Table 5-1. A copy of the rule appears in Appendix D.
The criteria promulgated in 1979 (40 CFR Part 257) represent the minimum regulatory standards
that a State program must apply to solid waste management facilities. Many States have
incorporated these criteria into State solid waste management plans. Although EPA has approved
25 State solid waste management plans and partially approved six others (EPA 1986b), it has not
actively reviewed these State plans since 1981. There are a number of States without approved
programs which have comprehensive, well-staffed programs that may meet the minimum criteria
for EPA approval. In fact, a number of States have established regulatory requirements for their
Subtide D facilities that are, in many instances, more stringent than the existing Subtitle D criteria.
States which have approved solid waste management programs must meet the permitting
requirements as prescribed by RCRA. In States without approved programs, coordination may be
complicated by tfae presence of multiple permitting authorities that permit the landfill or situations
where control is divided between monofills and co-disposal landfills. State and local regulatory
agencies which may regulate landfills include: solid waste management agencies, water quality
control agencies, health departments* building departments, planning and zoning commissions and
board of county commissioners. Information on State sludge management requirements is
summarized in several tables presented in Appendix E Since State regulatory programs may
change from time to time, the permit writer should not assume that the information in Appendix E
is definitive. Rather, the permit writer should consult with the appropriate State agency to
determine current requirements and recommendations.
41
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TABLE 5-1
40 Cffl PART 297 REQUIRED MANAGEMENT PRACTICES FOR SLUOOS-ONLY ANO CO-DISPOSAL LANOF1U.S.
LANO APPLICATION SITES ANO SLUOQE LAGOONS ANO STOCKPILES
Environmental Concern
Management Practice
Ftoodpiams
Endwgerad Species
Surface Water
Ground Waw
Otsease
A*
Safety
FaoMee n floodpiaws shall not rennet me now of tfw 100-year Hood, reduce tne temporary water storage
capacity of the Aoodctfain. or resuft m washout of soM waste, so as to ooae a hazard to humac life, wildlife, or
land or water resources. (As a matter of policy, EPA expects thai if sludge ia land-applied to the surface 3fC
incorporated into the soil and rf vegetation is grown, the cntena should be satisfied See p. 40, A Guide to
Ae0uta0ons and Guidance for tttt Utilization and Disposal of Municipal Sludge. EPA 1960)
Faortea shall not cause or contribute to the taking of any endangered or threatened species of plants, fish, or
wildMe, and shall not result in the destruction or adverse modification of the enseal naortat of endangered or
threatened soectes.
Questions about the potential tar adversely affecting endangered or threatened species at a particuiv site
should be directed to the nearest Reganal office of the U.S. Fish and WMWe Service. (Now Nonces at draft
NPOES permits also are routinely sent to the U.S. Fish and Wildlife Services. See «0 CPA 124.10(c).)
FaoWes shafl not cause a discharge of pollutants into waters of the United Stales m votatwn of Section *02 of
the Clean Water Act shaH not causa a discharge of dredged or fW material m violation of Section 404 oi the
Act and shaH not cause non-port source pollution that violates an approved Section 208 water quality
management plan.
Facilities shafl not cont&rwate an underground drinking water source beyond the sofad waste boundary, or
beyond an alternative boundary Consult the regulation for procedures necessary to set alternative boundaries
(see Appendix 0) To determine contamination. Appendix l of 40 CFR Part 297 provides a list of contammwt
concentrations. Release of a contaminant to groundwater when would cause ire concentrations of that
substance to exceed the level listed in Appendix I constitutes contamination.
Disease vectors shaH be minimized through the periodic application of cover material or other techniques aa
appropriate to protect public health.
Fac*n« shafl not engage m open burning of readerroal. commercial, institutional, or industrial sohd waste.
Infrequent burring of agricultural wastes m the field, stvnculturat wastes lor forest management purposes, lend-
deanng debris, diseased trees, debns from emergency dean-up operations and ordnance is slowed.
i Exptosne gases generated by (he facMy shaH not exceed 29 percent of the lower explosive hma tor the
gases m facility structures and 100 percent of the lower exploave imvt at the property ime.
2. Faokties shal not pose a hazard ®the safety of persona or property from fires.
3. Faabuee withm 10,000 feet of any airport runway used by tortniet awrraft. or wttfen 9.000 «eet of any
avport runway used by piston-type aircraft shall not pose a brd hoard to aircraft
4. Facnes shal not allow uncontrolled pubbc access so as to sxpoee the pubhc to poiental health and safety
hazards at the disposal arte.
43
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Revised 12/1/89
When permitting POTWs that dispose of their sludge in monofills, the permit writer should consult
State, local and EPA solid waste officials for information regarding the monofills used by the
POTW. These authorities may also have permit and inspection/enforcement files that permit
writers should review. If the sludge-only monofill that a POTW uses is not in compliance with
existing Federal regulations, the permit writer, in conjunction with enforcement personnel, should
take action that will bring the POTW's sludge disposal into compliance. An example of such
action would be to develop and attach to the permit a compliance schedule that sets a date within the
term of the permit by which the POTW will dispose of its sludge in a sludge-only monofill (or any
other method) that complies with Federal requirements. While the appropriate term for compliance
depends on a number of factors, the potential for harm to public health or the environment should
be the primary consideration.
When permitting POTWs that use co-disposal landfills, permit writers should consult with State,
local, and EPA solid waste officials to determine if the co-disposal landfills that the POTW uses are
in compliance with existing Federal requirements. Approximately 80 percent of the nation's
municipal solid waste landfills are inspected at least once a year and 25 percent of these landfills
have ground-water monitoring systems in operation (EPA 1986b). Thus, facility performance data
may be available for many of these landfills. If a co-disposal facility is violating 40 CFR Part 257
requirements, the permit writer should pursue one of the following courses of action depending
upon the sludge/solid waste ratio of the landfill:
o If sludge comprises a small proportion of the fill sent to the co-disposal facility (e.g., less than
30 percent of total received mass), the permit writer should defer to solid waste regulatory
officials in determining an appropriate response.
o [f sludge comprises a substantial proportion of the fill disposed of in a co-disposal facility
(e.g., more than 30 percent), the permit writer should work with solid waste regulatory
officials in determining an appropriate response. An appropriate response will depend on the
availability of more protective use or disposal alternatives and, most importantly, the potential
for adverse effect on public health and the environment.
The recommendation that a proportion of 30 percent sludge to refuse in a co-disposal landfill serve
as a dividing line between deferring to and consulting with solid waste officials is just arule of
thumb. There is no scientific basis to this division. It is the permit writers responsibility to
determine whether sludge volumes in any amount are increasing the potential for environmental
degradation in each particular case.
44
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Revised 12/1/89
5.2 TECHNOLOGY GUIDELINES
Sludge-Onlv Monofills
Most sludge-only landfills consist of a series of trenches where dewatered sludge is deposited
below ground surface and covered with soil. Other sludge-only designs include area fill mounds,
area fill layers, and diked containment; each of these methods involves sludge deposition above the
ground surface. These above-ground methods are rarely used and will not be discussed further.
Additional information on all sludge-only disposal methods can be found in EPA's Process Design
Manual of Municipal Sludge Landfills fEPA 1978).
Both narrow trench and wide trench techniques are used for the burial of sludge. Narrow trenches
are defined as having widths less than 10 feet; wide trenches are defined as having widths greater
than 10 feet. The depth and length of both narrow and wide trenches are variable and dependent
upon a number of factors. Trench depth is a function of (1) depth to ground-water and bedrock,
(2) sidewall stability, and (3) equipment limitations. Trench length is virtually unlimited, but
inevitably dependent upon property boundaries and other site conditions. In addition, trench length
may be limited by the need to discontinue the trench for a short distance or place a dike within the
trench to contain a low-solids sludge and prevent it from flowing throughout the trench (EPA
1978).
A soil cover is normally applied over sludge the same day that it is received, although cover
application may be less frequent in some cases. The frequency of cover application optimizes odor
control; therefore, trenches are more appropriate for un stabilized or partially stabilized sludges than
other landfilling methods. The soil excavated during trench construction provides the material that
is required for daily cover. Acconiingly, soil importation is seldom required in trench applications
(EPA 1978).
Narrow Trench Method
As stated previously, a narrow trench has a width of less than 10 feet Sludge is usually deposited
in a single application and a single layer of cover soil is applied atop this sludge. Relevant sludge
and site conditions as well as design criteria for this form of disposal include (EPA 1978):
AS
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Revised 12/1/89
Sludg
e and Site Conditions for Narrow Trenches
Sludge solids content
- 15-20% for 2-3 ft widths

- 20-28% for 3-10 ft widths
Sludge characteristics
- unstabilized or stabilized
Hydrogeology
• deep ground-water and bedrock
Ground slopes
- <20%

Design Criteria for Narrow Trenches
Trench width
- 2-10 ft
Bulking required
- no
Cover soil required
- yes
Cover soil thickness
- 2-4 ft
Imported soil required
- no
Sludge application
- 1,200-5,600 yd3/acre
Equipment
• backhoe with loader, excavator, trenching machine
The main advantage of a narrow trench is its ability to handle sludge with a relatively low solids
content. As shown above, a 2- to 3-ft width is required for sludge with a solids content between 15
and 20 percent. Normally, soil applied as cover over sludge of such low solids would sink to the
bottom of the sludge. However, because of the narrowness of the trench, the soil cover receives
support from the solid ground on either side of the trench and bridges over the sludge. Cover is
usually applied in a 2- to 3-ft thickness (EPA 1978).
Sludge with a solids content of 20 to 28 percent is more appropriate for a 3- to 10-ft trench width.
Cover is usually applied in a 3- to 4-ft thickness and dropped from a minimum height to minimize
the amount of soil that sinks into sludge deposits (EPA 1978).
The main disadvantage of a narrow trench operation is that it is relatively land-intensive. As shown
above, typical sludge application rates in actual fill areas (including inter-trench areas) range from
1,200 to 5,600 yd3/acre. Generally, application rates for narrow trenches are less than for other
methods. Another drawback with narrow trench operations is that the installation of liners is
impractical (EPA 1978).
46
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Revised 12/t/89
Wide Trench Method
A wide trench has a width of ten feet or greater. Relevant sludge and site conditions as well as
design criteria are:
Sludge and Site Conditions for Wide Trenches
Sludge solids content
- 20-28% for land-based equipment

- 228% for sludge-based equipment
Sludge characteristics
- unstabilized or stabilized
Hydrogeology
- deep ground-water and bedrock
Ground slopes
- <10%

Desipi Criteria for Wide Trenches
Trench width
- >10 ft
Bulking required
- no
Cover soil required
- yes
Cover soil thickness
- 3-4 ft for land-based equipment

- 4-5 ft for sludge based equipment
Imported soil required
- no
Sludge application
- 3,200-14,500 yd3/acre
Equipment
- track loader, dragline, scraper, track dozer
As with narrow trenches, wide trenches should be oriented parallel to one another to minimize
inter-trench areas. Distances between trenches should be large enough to provide sidewall stability
and adequate space for soil stockpiles, operating equipment, and haul vehicles (EPA 1978).
One advantage of a wide trench is that it is less land-intensive than narrow trenches. Typical sludge
application rates range from 3,200 to 14,500 yd3/acre. Another advantage of a wide trench is that
liners can be installed to contain sludge moisture and protect the ground-water. When liners are to
be used, excavation may proceed closer to bedrock or ground-water than when narrow trenches
without such protection are used.
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Revised 12/1/89
One disadvantage of a wide trench is that a sludge solids content of 20 percent or above is needed.
A sludge solids content of 28 percent or greater is required to support equipment that may be
operated on the sludge itself. It should be noted that sludge with a solids content of 32 percent or
more will not spread out evenly in a trench when dropped from vehicles working outside of the
trench. Another disadvantage of a wide trench is the need for flatter terrain than that required for
narrow trench techniques.
Co Disposal Landfills
At co-disposal landfills, wastewater sludge is deposited in a landfill together with municipal solid
waste. In this way, the absorption characteristics of the solid waste and soil conditioning
characteristics of the sludge can complement each other. The solid waste absorbs excess moisture
from the sludge and reduces leachate migration. Sludge mixed with soil can also aid in
revegetation of the completed landfill.
Sludge/Refuse Mixture
In a sludge/refuse mixture operation, sludge is deposited at the working face of the landfill and
applied on top of the refuse. The sludge and refuse are then mixed as thoroughly as possible. This
mixture is then spread, compacted, and covered in the usual manner at a refuse landfill Relevant
sludge and site conditions as well as design criteria are presented in the following table (EPA
1978):

Sludge and Site Conditions
Sludge solids content
- J>3%
Sludge characteristics
- unstabilized or stabilized
Hydrogeology
- deep or shallow ground-water or bedrock
Ground slopes
- <30%

Design Criteria
Bulking required
- yes
Bulking agent
- refuse
Bulking ratio
• 4-7 tons refuse/wet ton sludge
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Revised 12/1/89
Cover soil required
Cover soil thickness
- yes
- 0.5-1 ft of interim
- 2 ft of final
- no
- 500-4,200 yd3/acre
Imported soil required
Sludge application
Equipment
track loader, track dozer
As shown above, sludges with solids content as low as 3 percent may be received in such
operations. Usually, such sludge is spray applied from a tank truck to a layer of refuse at the
working face. The bulking ratio for a 3 percent solids sludge should be at least 7 tons of refuse to 1
wet ton of sludge. Usually, only sludges with solids contents of 20 percent or more are mixed with
refuse in such operations and fewer operational and environmental problems may be expected than
when a 3 percent solids sludge is received. Also, less bulking agent is required with the higher
solids content sludge and ratios as low as 4 tons of refuse to 1 wet ton of sludge are successfully
practiced (EPA 1978). Some POTWs use sludge as a top dressing on landfills. For example, in
Chicago the sludge (65% solids) is layered into a total depth of 9 feet On at least one level, the
landfill is then sealed with a 2 feet clay layer.
Also as shown above, sludge application rates for sludge/refuse mixtures compare favorably with
other methods despite the fact that sludge is not the only waste being disposed on the land.
Application rates generally range from 500 to 4,200 yd3 of sludge per acre (EPA 1978).
State Requirements - Sludge/Refuse Mixture
Three States specify loading limits for sludge at refuse landfills. New Hampshire recommends a
4:1 volume ratio of refuse to sludge, and mandates that the ratio be no less than 3:1. In addition,
sludge must be dewatered to a minimum 20 percent solids. Washington requires that the refuse to
sludge ratio be between 4:1 and 5:1 such that the resulting mixture contain less than 40 percent
moisture. Hawaii requires that the sludge/refuse mixture be spread and compacted in layers not
exceeding 2 feet
Sludge/Soil Mixture
In a sludge/soil mixture operation, sludge is mixed with soil and applied as interim or final cover
over completed areas of the refuse landfill. This is not strictly a sludge landfilling method since the
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sludge is not buried. However, it is a viable option for disposal of sludge at refuse landfills that
could be used in many cases. Relevant sludge and site conditions as well as design criteria are
presented in the following tabulation (EPA 1978).

Sludee and Site Conditions
Sludge solids content
- *20%
Sludge characteristics
- stabilized
Hydiogeology
- deep or shallow ground-water or bedrock
Ground slopes
- <5%

Desian Criteria
Bulking required
- yes
Bulking agent
- soil
Bulking ratio
- 1 soil:l sludge
Cover soil required
- no
Imported soil required
- no
Sludge application
- 1,600 yd3/acre
Equipment
• tractor with disc
One advantage to a sludge/soil mixture operation is that it removes sludge from the working face of
the landfill where it may cause operational problems. Other advantages are that the mixture can be
used to support the growth of vegetation over completed fill areas, a savings in fertilizer can be
realized, and siltation and erosion problems can be minimized (EPA 1978).
A disadvantage to a sludge/soil mixture operation is that it generally has greater manpower and
equipment requirements than would be incurred by landfllling the same sludge quantity at the
working face. Another disadvantage is that since the sludge is not completely buried, odors may be
more severe than for sludge/refuse mixtures. For this reason, only well stabilized sludges are
recommended for use in sludge/soil mixture operations (EPA 1978).
50
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5.3 CHARACTERISTICS OF SLUDGES SUITABLE FOR I .ANTtFn T INC.
5.3.1 SLUDGE POLLUTANT CONCENTRATION LIMITS
Federal Regulations
There are no Federal pollutant concentration limitations for sewage sludge that is disposed of in
landfills. The only Federal requirement regarding sludge quality is that hazardous sludges must be
disposed of according to the requirements of RCRA Subtitle C. Any municipal sewage sludge that
is not a RCRA Subtitle C hazardous waste may be disposed of at an approved Subtitle D solid
waste facility, provided the practice is allowed by State law.
Case-bv-Casc Recommendations
A review of Federal guidance documents and State requirements for the disposal of sewage sludge
in landfills revealed no recommended or required sludge contaminant limits. Therefore, no
contaminant limit recommendations are presented. Pennit writers should set contaminant
concentration limits if they determine such limits are necessary to protect public health or the
environment (e.g. drinking water supply). The pennit writer will have to document this decision
in the permit fact sheet. The management practices and site characteristics of landfills receiving
sludges containing high concentrations of contaminants should be closely examined
5.3.2 SLUDGE PHYSICAL PROPERTIES
This section will cover recommended sludge dewatering and stabilization requirements for sludge-
only and co-disposal landfills.
Fftrieral RffgiilarWyy
Neither stabilization or dewatering of sewage sludge are specifically required by 40 CFR Pan 257
prior to landfilling.
Federal Guidance
Not all municipal sewage sludges are suitable for landfilling due to odors from insufficiently
stabilized sludge or operational problems arising from low solids content An assessment of the
51
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suitability of various sludge types for disposal in sludge-only monofills and co-disposal landfills
was discussed in Section 5.2 which provide information on landfill technologies.
As implied in Section 5.2, sludge with a solids content less than 15 percent are not suited for
disposal in sludge-only monofills. Sludges having solids contents less than 15 percent usually will
not support cover material. Obviously, the addition of soil to a low-solids sludge may act as a
bulking agent and produce a sludge suitable for disposal at sludge-only monofills. However, soil
bulking operations are generally not cost-effective on sludges with solids less than 15 percent.
Further dewatering should be performed at the treatment plant if sludge-only monofilling is the
disposal option selected.
If suitably designed and operated, co-disposal landfills can accept sludges with solids contents as
low as 3 percent However, sludge moisture should not exceed the absorptive capacity of refuse at
a co-disposal landfill. Accordingly, low-solids sludge should be received at such sites only if it
constitutes a small percentage of the total waste landfilled (EPA 1978).
Generally, only stabilized sludges are recommended for landfilling and some degree of stabilization
should occur if landfilling is the selected disposal option. Stabilization of sewage sludge reduces
odors and reduces vector attraction. Stabilization, however, is not required by all States.
Suggested procedures for landfilling unstabilized sludges can be found in EPA's Process TVsitrn
Manual for Municipal Sludpe Landfills (EPA 1978).
State Requirements
State sludge dewatering regulations vary greatly. A total of thirty-two Stales and Puerto Rico
require some degree of dewatering. Six States do not allow landfilling of sludges containing free
liquids. One Stale (Oklahoma) will allow free liquids if the site has a leachate collection system.
Thirteen States ^odfy minimum percent solids allowed: Alaska requires 10 percent, Idaho and
South Carolina require 15 percent, Massachusetts requires 18 percent, six States require 20
percent, two States require 30 percent, and Iowa requires 75 percent solids. Four States require
dewatering but do not specify to what degree, while Connecticut evaluates the need for dewatering
on a case-by-case basis.
Several States have dewatering requirements for specific types of sludge or landfilling options.
California requires a minimum of 20 percent solids for primary sludge and 15 percent for
secondary sludge or a mixture of the two. Texas requires a minimum of 15 percent solids in
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sludge-only trench and fill landfills. For filling above the ground surface, Washington requires IS
to 20 percent soficb. The sludge dewatering requirements for each State are listed in Appendix E,
Table E5-1.
Twenty States require sludge to be stabilized prior to landfilling. Only Kentucky mandates a
stabilization process or operational criteria (e.g., a certain temperature for a certain length of time).
Oklahoma requires that raw-sludge must be disposed of in remote locations. Individual State
requirements regarding stabilization can also be found in Table E5-1.
Casc-by-Casc RcwmmcndaiifiDa
In general, permit writers should require sludge solids content be consistent with the design
standards of the monofill or landfill. If the permit writer finds there is a potential for liquids to
leach into and contaminate ground-water, specifying a sludge solids content in the permit is
appropriate.
For co-disposal landfills, the proposed 40 CFR PART 228 regulation would prohibit the disposal
of bulk or non-containerized liquid wastes. Liquid waste has been defined as any waste that is
determined to contain "free liquids" as defined by the Paint Filter Liquids Test (as described in
'Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods," EPA Pub. No. SW-
846). Permit writers may want to consider requiring POTWs to perform the Paint Filter Liquids
Test on sludges with less than 20 percent solids.
5.3.3 LANDFILLING OF SLUDGES CONTAINING RADIONUCLIDES
POTWs that have hospitals or industries discharging wastes that contain radionuclides into their
system or those located in areas of the country where there are naturally occurring radionuclides in
their drinking and industrial waters can expect to see radkvuclidps concentrating in their sludges.
Specific radknaefites that are common in POTWs are-I'31 Ra*28, U23®, and Cs137. A more
comprehensive list is provided in Table 6-2 and a more indepth discussion is provided in Section
62. Two States, Illinois and .Wisconsin, have specific requirements for sewage sludges
containing radium and landfilling. These requirements have been included in Table E5-6.
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5.4 OPERATING CONDITIONS AND MANAGEMENT PRACTICES
This section conins Federal regulations and guidance, State requirements, and case-by-case
recommendations for the permit writer to use in developing permit conditions to regulate the
disposal of sewage sludge. This information can be applied to both sludge-only monofills and co-
disposal landfills.
Required Permit Conditions
At a minimum, the permit writer should include the Federal regulations in the NPDES permit,
unless they are already contained in another permit held by the POTW. The Interim Strategy
requires permit writers to evaluate Class I POTWs for the potential need to incorporate additional
case-by-case permit conditions. The permit writer should be aware that several of these
requirements and recommendations are restrictions that apply to the location of new landfills rather
than the operation and management of existing landfills. If the permit writer finds that the POTW
is disposing of its sludge in a landfill that is in violation of the Federal regulations for location, the
permit writer is limited to requiring the POTW to develop alternate sludge use or disposal options.
5.4.1 ENDANGERED SPECIES PROTECTION
Federal Regulations
Facilities or practices shall not cause or contribute to the taking of any endangered or threatened
species of plants, fish, or wildlife. The facility or practice shall not result in the destruction or
advene modification of the critical habitat of endangered or threatened species as identified in 50
CFR Part 17 (40 CFR Part 257).
Federal Guidance
In general, sludge ftndfills should not be located in environmentally sensitive areas when feasible
alternatives exist EPA has identified five environmentally sensitive areas where landfilling should
be avoided (EPA 1978). These include: wetlands, floodplains, permafrost areas, critical habitats of
endangered species, and recharge zones of sole source aquifers.
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State Rwuirenicntt
No State has specific regulations governing the protection of endangered species in their sludge or
solid waste regulations. Of course, all States that have adopted 40 CFR Part 257 into their State
solid waste management plans will have incorporated regulations covering endangered species.
Case-bv-Casc Recommendations
If the POTW is sending its sludge to an existing landfill thai is violating the endangered species
provision (40 CFR Part 257.3-2), the permit writer should require the POTW to develop an
alternate sludge use or disposal option. If the POTW is in the process of siting and constructing a
new landfill, the permit writer should prohibit placement in an environmentally sensitive area.
5.4.2 FLOODPLAIN RESTRICTIONS
Federal Regulations
Facilities or practices in floodplains shall not restrict the flow of the base flood, reduce the
temporary water storage capacity of the floodplain, or result in washout of solid waste, so as to
pose a hazard to human life, wildlife, or land or water resources (40 CFR Part 257).
Sate Rcguiremgms
Thirty-three States, the Virgin Islands and Puerto Rico have regulations governing the siting of a
sludge landfill in a floodplain. Seven of those States have adopted the intent of 40 CFR Part 257,
allowing sludge landfills in floodplains only if they are protected from flooding by levees or other
devices, and do not restrict the base flood. Fifteen States prohibit siting a sludge landfill in a
floodplain; ten of these specifically refer to the 100-year floodplain. Four other States require
official approvatfcr a sludge landfill to be sited in a floodplain. State regulations regarding sludge-
only and co-disposal landfills located in floodplains are summarized in Table E5-2.
«
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5.4.3 GROUND-WATER PROTECTION
Federal Reputations
40 CFR Part 257 protects ground-water by requiring that sludge-only and co-disposal landfills
shall not contaminate an underground drinking water source beyond the solid waste boundary or
beyond an alternative boundary determined in accordance with provisions in the regulation.
Ground-water contamination is defined an exceedance in the maximum contaminant levels in
Appendix I of the rule, an increase in the concentration of that substance in the ground-water where
the existing concentration of that substance exceeds the maximum contaminant levels specified in
Appendix I. Maximum ground-water contaminant levels are specified in Appendix I of 40 CFR
Part 257 which is presented as Appendix F of this document
It is well known that metals are more mobile in low pH soils than in high pH soils and that a soiL
pH of 6.5 is generally sufficient to prevent the movement of metals. Soil pH may be a moot
question in connection with landfills with lines and leachate collection systems. In reviewing
permits for unlined landfills, however, the permit writer should be fully aware of the possible link
between low pH soils, low pH refuse mixtures and adverse effects on ground-water quality due to
metal migration.
There are presently no existing Federal regulations specifically requiring liners and leachate
collection, a minimum depth to ground-water from the bottom of waste disposal areas, or a
minimum distance to nearby drinking water wells. However, the proposed regulations under 40
CFR Part 258 will require some design requirements such as a flexible membrane layer, compacted
earth, and leachate collection systems.
Federal Guidance
One of the primay environmental concerns about landfilling sewage sludge is the potential for
ground-water contamination. The overall EPA program for the protection of ground-water is
presented in the 1984 EPA Ground-Water Protection Strategy, and includes elements from other
Federal legislation. The elements that are most germane to the question of sludge disposal are
found in RCRA and in the Safe Drinking Water Act (SDWA).
$6
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Ground-Water Protection Strategy
The Ground-Water Protection Strategy (EPA 1984) provides for three ground-water classification
categories:
Class I - Special Ground Waters are those that are highly vulnerable to contamination because of
die hydrological characteristics of the areas in which they occur and are characterized by one of the
following two factors: (a) Irreplaceable, in that no practical, sufficient alternative source of
drinking water is available to substantial populations; or (b) Ecologically vital, in that the ground-
water contributes to maintaining the base flow for a particularly sensitive ecological system that, if
polluted, would destroy a unique habitat.
Class D - Current or Potential Sources of Drinlriny Water and Waters Having Other TWfiHal
Uses are all other ground waters currently used or potentially available for drinking water or other
beneficial use.
Classm- Ground Waters Not Current or Potential Sources of Drinking Water and of Limited
Beneficial Use are those (1) with a total dissolved solids (TDS) level over 10,000 mg/1 or (2) so
contaminated by naturally occurring contaminants or human activity (not associated with a
particular waste disposal or other site) that it cannot be cleaned up using methods reasonably
employed in public water system treatment, or (3) those where yields are insufficient to meet the
minimum needs of an average household.
The Agency released draft Guidelines for performing ground-water classification in December
1986.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) established the Wellhead Protection (WHP) program for the
protection of ground-water. Under this program. States are to determine the extent of wellhead
protection areas necessary to provide protection from contaminants th§£ may have an advene effect
on human health. The SDWA required States to submit an adequate program to EPA by June
1989.

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Some of the major requirements of a wellhead protection program are to:
o Determine the extent of the well head protection area based on hydrologic and other
information,
o Describe a program to protect the water supply within the WHP area from anthropogenic
sources of contaminants,
o Develop contingency plans for the provision of alternative drinking water supplies in the event
of well or wellfield contamination, and
o Require that all potential sources of contamination in a potential WHP area be taken into
consideration before the construction of new wells.
Guidance is available from the Office of Ground-Water Protection on the WHP program (EPA
1987b).
Except to the extent that monitoring may be incorporated into a wellhead protection program,
neither the SDWA or the Ground-Water Protection Strategy require ground-water monitoring in the
vicinity of solid waste disposal facilities.
Subtitle D of RCRA requires that the designers of a solid waste disposal facility take the proximity
to ground-water into consideration during facility design, and in the placement of observation wells
and sampling stations that may be installed. Monitoring requirements are not specified under
Subtitle D of RCRA, although they may be specified by State agencies that arfminigtw Subtitle D.
However, the proposed 40 CFR Part 258 regulation will require ground-water monitoring when
promulgated.
Under Subtitle C of RCRA, generators of hazardous waste must meet stringent disposal
requirements including stringent ground-water monitoring requirements. The general requirements
are described in 40 CFR Part 264.90 through Pan 264.100.
Assuming that the land application or landfilling of municipal sludge does not entail the disposal of
hazardous materials, ground-water monitoring requirements should be evaluated on a case-by-case
basis after reference to State regulation and in consultation with State Subtitle D program officials.
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Liners and Leachate Collection
Leachate enters the ground-water system by both vertical and lateral movement through the soil.
Careful site selection and attention to design considerations can prevent or minimize leachate
contamination of ground-water. The control of leachate may be accomplished through (EPA 1978):
o Natural conditions and attenuation by the soil
o Imported soils or soil amendments used as liners and/or cover
o Membrane liners
If a site design includes provisions for leachate containment (e.g., a liner) a leachate collection
system must be installed. The collection system may consist of a sump into which leachate collects
and is subsequently drained or pumped to a holding tank or pond. Leachate may also be collected
by a series of drain pipes or tiles that intercept and channel the leachate to the surface or to a sump
(EPA 1978).
Collected leachate may be handled or disposed of by one of the following methods (EPA 1978):
o Discharge to a wastewater collection system or haul direcdy to a treatment plant,
o Recycle through the landfill,
o Evaporation of leachate in collection ponds,
o On-site treatment and discharge to a receiving stream,
o Transport to chemical waste disposal site.
Depending on the leachate characteristics, volume, and local regulations, it may be possible to
discharge collected leachate to an existing wastewater system for subsequent treatment with
municipal wastewater. Local wastewater treatment plant personnel should be consulted for leachate
acceptability to determine special requirements for discharge to the treatment plant (e.g., large slugs
of highly contaminated leachate may have to be mixed with municipal wastewater to prevent plant
upset) (EPA 1978). In some cases leachate may have to be pretreated to reduce high organic and
heavy metal concentrations. An additional source of guidance is the r^nHanr* Manual <*i th*
Development and Implementation of Local Discharge Limitations under the Pretreatment Program
(EPA, December 1987). To obtain a copy of this manual contact the Office of Water Enforcement
and Permits (EN-336), Washington. D C. 20460.
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If discharge to the wastewater system is impractical or if the leachate is potentially disruptive to
treatment plant operations, on-site treatment or transportation to a chemical waste disposal site will
have to be utilized (EPA 1978).
On-site treatment may consist of recycling the leachate through the landfill, placing the leachate in a
shallow basin to allow it to evaporate, or installing a small (specially designed) treatment plant on
site. The latter alternative should be avoided if at all possible due to its high cost and the unpioven
reliability of such small plants (EPA 1978).
Leachate recycling has been shown to be useful because it:
o Promotes rapid development of anaerobic decomposition in the wastes,
o Increases the rate and predictability of biological stabilization.
o Reduces the volume of leachate to be handled by evaporation of the water during dry periods.
However, leachate recycling systems are not feasible at some sites; in particular, areas with high
rainfall and high application rates are not suitable. Its primary application should probably be
restricted to co-disposal sites in climates where the evaporation rate exceeds rainfall to a significant
extent (EPA 1978). Some States are presently considering a ban on leachate recycling.
A detailed discussion of natural attenuation and liner systems (soil and synthetic) and leachate
collection and treatment can be found in EPA's Process Design Manual for Municipal Sludge
Landfills (EPA 1978).
Depth to Ground-water
The technical literature recommends, and some States require, that a minimum thickness of soil be
maintained between the bottom of the waste disposal site and the seasonal high ground-water table.
This separation prevents ground-water from passing through waste cells and takes advantage of
attenuating properties of the underlying soil. Recommended minimum separation generally varies
from 2 to 5 feet. Greater separations may be required for higher than normal soil permeabilities or
sludge loading rates.
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Slate Requirements
Liners and Leachate Collection
Twenty-eight States and Puerto Rico specify some requirement for liners ai sludge landfills. "State-
of-the-Art" design criteria and requirements for liner systems have been adopted by some States, in
particular New Jersey and Massachusetts, in their solid waste regulations. Five States and Puerto
Rico impose liner requirements based upon case-by-case site evaluations. The remaining State
regulations vary widely and are not very specific. California requires liners with a permeability of
no greater than 1 x 10*6 cm/sec, or a 2-ft thick clay layer. Louisiana and Illinois mandate a material
of certain permeability and require a thickness of that material of 3 and 10 feet, respectively.
These, or equivalent, regulations should be consulted prior to design or review of any liner
system. State liner requirements are summarized in Table E5-3.
Twenty-seven States have some requirements regarding leachate collection. Massachusetts requires
leachate collection only at sludge-only landfills. Two States, Massachusetts and New Jersey, have
incorporated "state-of-the-art" leachate collection system design standards into their landfill
regulations. New York requires leachate collection if wet sludge comprises greater than 25 percent
of materials disposed of at the facility each day. Eleven States require leachate collection but do not
specify any treatment or management criteria. Alabama, Georgia, and Illinois require leachate
collection on a case-by-case basis. Table E5-3 contains a Statc-by-State listing of leachate
collection requirements. Five States specify that leachate should be treated. In Washington,
leachate treatment is required in areas receiving greater than 25 inches of rainfall per year. These
standards, or their equivalent, should be consulted before design or review of leachate collection
systems.
Depth to Ground-water
Twenty-three States presently have regulations requiring minimum separations between the bottom
of disposal facilities and the seasonal high ground-water table. The required separations and the
number of States mandating that separation are listed below:
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Revised 12/1/89
Depth to Seasonal
High Water Table (ft)
Number
of States
>1.7
>4
>5
>6
>10
7
9
2
4
The individual State requirements are listed in Table E5-2.
Distance to Wells
Sixteen States require a minimum distance between nearby drinking water wells and a sludge-only
or co-disposal landfill. Distances range from 200 to 1,200 feet, with most States requiring a 1,000
foot separation. Oklahoma requires disposal facilities to be 250 feet from private wells and 660 feet
from public water supply wells. New Hampshire requires a distance of 500 feet for community
wells and 1,000 feet for municipal wells. A complete list of each State's requirements is provided
in Table E5-2.
Twenty-two States require some type of soil analysis in conjunction with landfilling of sludge.
Michigan requires that the landfill soil have clay characteristics. Montana requires that the
percolation rate not exceed 1.5 in/hr.
Case-bv-Case Recommendations
The permit writer should evaluate site-specific conditions in determining whether it is appropriate
for sludges to be disposed of in sludge-only or co-disposal landfills that do not have liners and
leachate collection systems or adequate buffers between ground-water and drinking water wells.
Among the important factors to consider are sludge quality, the value of the ground-water
resource, the proximity of ground-water uses, ground-water flow direction and velocity, and
evidence of migration of contaminants from the landfill. Solid waste and ground-water program
officials should be consulted in determining the appropriateness of using a particular landfill for
sludge disposal.
Soil Type
62
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Depth to Ground-water
Generally, a minimum soil buffer (or overburden) of 4 feet is recommended between the bottom of
both types of landfills and the seasonal (annual) high ground-water table at the site. Typically,
disposal facilities that arc designed well and perform well would require less depth to ground-water
than poorly designed, poorly managed facilities.
Distance to Wells
While the appropriate distance to drinking water wells is a site-specific determination, generally, a
minimum distance of 500 feet between waste disposal areas at both types of landfills and drinking
water wells is recommended. Some of the more important factors to consider in determining an
appropriate setback from drinking water wells are sludge quality, direction of ground-water flow,
ground-water velocity and any evidence of migration of contaminants from the landfill into ground-
water. If no data are available for those factors, a conservative setback may be appropriate.
Additional Permit Conditions
In addition to site specific conditions, other recommendations for permit conditions that can help
minimize ground-water contamination include:
o Sludge pollutant concentration limits
o Sludge solids content requirements
o Compliance schedule for the POTW to identify alternate sludge use or disposal option.
5.4.4 SURFACE WATER PROTECTION
Federal Regulations
40 CFR Part 227.3-3 states that a facility or practice shall not cause a discharge of pollutants that is
in violation of the requirements of the National Pollutant Discharge Elimination System (NPDES)
under Section 402 of the Clean Water Act In addition, the regulation states that the facility or
practice shall not cause non-point source pollution of the waters of the U.S. No minimum
distances to surface waters are established.
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Buffer Zones
While the appropriate distance to surface water is a site-specific determination, a minimum distance
of 100 feet between waste disposal areas at both types of landfills and surface water is generally
recommended. In determining an appropriate setback from surface waters the permit writer should
consider the adequacy of systems to control precipitation run-on and run-off, the potential for
leachate migration through the underlying soil or ground-water into the surface water of concern,
and the slope and vegetative cover of the buffer zone.
Run-on/Run-off Controls
The technical literature generally recommends that all upland drainage be collected and directed
around the landfill to prevent run-off from contacting the sludge and/or solid waste and thereby
prevent surface water pollution or leachate generation. The drainage channels may be constructed
of earth, corrugated metal pipe, gunite-lined earthen ditches, or stone-lined (rip rap) ditches. If the
access or on-site roads of the landfill are paved, they may be used to channel drainage across the
landfill (EPA 1978). The dimensions for drainage structures should be based upon accepted storm
run-off calculation methods such as those developed by the U.S. Soil Conservation Service.
Systems to control and divert the 24-hour, 25-year storm around active disposal areas are
recommended.
On the landfill itself, all active and completed site working areas should be properly graded. The
surface grade should be greater than 2 percent to promote run-off and inhibit ponding of
precipitation, but less than 5 percent to reduce flow velocities and minimize soil erosion. If
necessary, siltatkM ponds should be constructed to settle the solids contained in the run-off from
the site. Straw bales, berms, and vegetation may be used in conjunction with ponds to control run-
off and siltation on the site (EPA 1978). In addition, leachate collection systems at the landfill help
mitigate the effects of run-on from storm events.
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State Requirements
Buffer Zones
Twenty-two States have limits on the distance between sludge disposal facilities and surface water.
The minimum distances and the number of States mandating the distance are listed below:
Distance Number
Surface Water (ft) of States
50 1
100 7
200 3
300 1
500 2
Wisconsin requires a distance of 300 feet to a river and 1,000 feet to a lake. The distance required
by Kentucky varies from 250 feet to 1,000 feet. Rhode Island does not allow facilities to be
in a water supply watershed. Connecticut sets the distance to surface water on a case-by-case
basis. The State requirements for the distance from sludge-only and co-disposal landfills to surface
water are listed in Table E5-2.
Run-on/Run-off Controls
Thirty-six States, Puerto Rico and the Virgin Islands require some form of run-off control at
sludge landfills; however, few States are very specific about their requirements. Alabama and
Delaware require a minimum 2 percent slope on the completed fill. Connecticut and Oklahoma
require slopes to be less than 4 percent, while Vermont and Mississippi require slopes to be less
than 5 percent and 8 percent, respectively. Alaska and Louisiana recommend the construction of
dikes, levees, or other diversion devices to control run-off. Finally, Montana, New Hampshire and
New Mexico require that controls be maintained to divert run-off away from active disposal areas.
State requirements for run-on/run-off controls are summarized in Table E5-3.
Case-bv-case Recommendations
Complying with the Federal requirement for surface water protection normally requires the
installation of proper run-on/run-off protection at landfills. In developing permit conditions to
protect surface water, the permit writer should evaluate the existence and adequacy of run-on/run
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Revised 12/1/89
off control structures, the type and size of buffer zones and management practices used at the
landfill. For instance, the daily cover application at a narrow trench type monofill may be
sufficient to protect surface water from contamination by sewage sludge because the cover material
forms a bridge over the sludge. However, daily cover at other types of landfills does not offer the
same degree of protection.
5.4.5 SAFETY
Federal Regulations
Existing Federal regulations (40 CFR Part 257) pertaining to safety at sludge landfills cover
explosive gases (methane), fires, bird hazards to aircraft, and access control. Methane gas
migration and control will be addressed separately; fires, bird hazards and access control are
discussed below.
Existing Federal regulations pertaining to fires, access control, and bird hazards to aircraft state:
o Fires - a facility or practice shall not pose a fire hazard to the safety of persons or property.
This may be accomplished through compliance with 40 CFR Part 257.3-7 (prohibition of
open burning) through the periodic application of cover material or other techniques as
appropriate, and control of generation of explosive gases.
o Bird hazards to aircraft - a facility or practice disposing of putrescible wastes that may attract
birds and which occurs within 10,000 feet of any airport runway used by turbojet aircraft or
within 5,000 feet of any airport runway used by only piston-type aircraft shall not pose a bird
hazard to aircraft
o Access - a facility or practice shall not allow uncontrolled public access as to expose the public
to potential health and safety hazards at the disposal site.
Federal Guidance
The technical literature suggests that water on-site for fire protection is a factor that should be
considered in the design and operation of a landfill. Insuring that solid waste and sludge are
covered at the end of each day is also a protective measure against fire.
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Revised 12/1/89
Access to landfills should be limited to one or two entrances with gates that can be locked when the
site is unattended. Depending on the topography and vegetation of the site and adjoining areas as
well as nearby population density, entrance gates may suffice to prevent unauthorized vehicular
access. At some sites it is desirable to construct peripheral fences to keep out any trespassers and
animals. Keeping trespassers and animals off sludge landfills is more important than for refuse
landfills because the sludge may not be sufficiently stable to support their weight (EPA 1978).
Fencing requirements will be greatly influenced by the relative isolation of the site. Sites close to
housing developments may require fencing to keep out children and to provide a visual screen for
the landfill. Establishing a buffer zone between the landfill and nearest dwelling also helps limit
public exposure to the landfill. EPA recommends at least a 250 foot buffer. Landfills that are in
relatively isolated rural areas may require a less sophisticated type of fencing or only fencing at the
entrance and other places to keep out unauthorized vehicles (EPA 1978).
Sate Requirements
Buffer Zones
Only six States require a buffer zone between sludge-only and co-disposal landfills and airports.
Two States have adopted the Part 257 standard of 5,000 feet from piston-type only airports and
10,000 feet from turbojet aircraft airports. Two States require 10,000 feet of separation between
landfills and all airports. A list of die State regulations regarding distances to airports is provided in
Table E5-2 under Buffer Zones.
Thirty-two States, Puerto Rico and the Virgin Islands require some form of access control at
sludge landfills. Seventeen States require either or both perimeter fencing and locked entrance
gates. One State mandates access by roadway only. A list of access control requirements for each
State is provided in Table E5-3.
Twenty-one States and the Virgin Islands require either a separation of landfilling operations from
the facility property line or a separation from the nearest dwelling, or fcoth. Four States require
property line setbacks of 50 feet. Three States require 100 foot property line setbacks. Texas
requires a 200 foot setback from the property line and Vermont requires a 300 foot setback. Idaho
will allow a separation ranging from 100 to 300 feet depending on vegetative screen.
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Revised 12/1/89
Separation requirements from the nearest dwelling range from 200 feet to 3/4 mile; 500 feet being
the most common (See Table E5-2). Nevada requires a separation from one-quarter to three-
quarters of a mile depending on the class of landfill.
Other requirements include a 100-foot separation from roads, and a 100-foot separation from
highways and parks. Table E5-2 contains each State's requirements for buffer zones.
Fire Protection
Only one State, Wyoming, mentions fire protection in its regulations. The State requires fire lanes
and other forms of fire protection at all sites.
5.4.6 AIR QUALITY CONTROL
Federal Regulations
A facility or practice shall not engage in open burning of residential, commercial, institutional, or
industrial solid waste (40 CFR Part 2S7). The facility also shall not violate applicable requirements
developed under a State Implementation Program approved under the Dean Air Act
Federal Guidance
The technical literature suggests that odors at sludge landfills can be a serious problem unless
preventive measures are taken. The sludge should be covered as frequently as necessary to
minimize odor. Sludge stabilization reduces odor. Lime or chemical masking agents can be
applied to reduce odors. An effective means of reducing odors is to limit storage of sludge at the
landfill. Ideally, sludge should be stored at the wastewater treatment plant (EPA 1978).
In areas where odor is of concern, sludge disposed of at both types of landfills should be
stabilized. Sludge stabilization processes are discussed in Chapter 3. Permit writers should
consider requiring sludge treatment processes that reduce volatile solids and vector attraction for
sludges that may be disposed of near airpoit runways.
68
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Revised 12/1/89
State Requirements
Only two States have regulations covering air quality or odors. Louisiana requires daily checks for
odor and monthly checks for amines and chlorinated hydrocarbons. Maryland requires that odors
not be excessive or persistent
5.4.7 GAS CONTROL
Federal Regulations
Federal regulations (40 CFR Part 257.3-8) pertaining to the monitoring and control of methane gas
migration at sludge-only and co-disposal landfills specify that the concentration of explosive gases
generated by the facility or practice shall not exceed:
o Twenty-five percent of the lower explosive limit for the gases in facility structures (excluding
gas control or recovery system components) and
o The lower explosive limit for the gases at the property boundary.
Federal Guidance
Gas is produced by the decomposition of organic matter in sludge and refuse. The primary gases
of decomposition are methane and carbon dioxide. Some nitrogen and oxygen are found. Traces of
ammonia, hydrogen sulfide, hydrogen, and volatile organic species are sometimes found in
landfills. The amount and composition of gases produced depends on the quantity and
characteristics of sludge deposited, the amount of moisture present, and other factors (EPA 1978).
Accumulation of particular gases in enclosed areas can result in explosions.
Methane, like carbon dioxide, is odorless; unlike carbon dioxide, methane is relatively insoluble in
water. However, when methane is present in air at between S and 15 percent concentrations, and is
confined in an enclosed area, it is explosive. The lower explosive limit is defined as the lowest
percent by volume of a mixture of explosive gases that will propagate a flame in air at 25°C and
atmospheric pressure. Thus, for methane, 25 percent of the lower explosive limit is 1.25 percent
methane in air, and 100 percent of the lower explosive limit is 5 percent in air. Methane can move
by diffusion through the sludge into the atmosphere where it is harmlessly dissipated. The gas can
also move laterally from the landfill into surrounding soils, especially if the cover material is
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Revised 12/1/89
relatively impermeable. Through lateral movement, methane could seep into nearby buildings or
utilities. A build-up of methane to a concentration exceeding the lower explosive limit is hazardous.
Migrating gas can also damage vegetation surrounding a sludge landfill by excluding oxygen from
the root zone (EPA 1978).
Installation of gas control facilities is not necessary if the site is isolated and will remain isolated
from inhabited structures. However, when inhabited structures are near the landfill and monitoring
wells indicate that a structure is threatened, gas migration controls are required. Migration can be
controlled by installing barriers to gas flow and/or by collection and venting the gas. Gas control
techniques can generally be classified into permeable and impermeable methods (EPA 1978).
Permeable Methods
Permeable methods of gas venting usually entail the installation of a gravel-filled trench outside the
filled area. The trench, which generally extends below the bottom of the fill area, intercepts
migrating gas and vents it to the atmosphere.
Gravel-packed well vents are often used in conjunction with lateral-surface vents buried below the
final cover in a gravel trench. Wall vents should penetrate into the upper waste cell. Waste gas
burners are also often installed above the well vents (Tchobanoglous 1977).
Impermeable Methods
Placing a barrier of very low permeability material around the perimeter of the landfill minimizes
lateral gas migration. The movement of gas through soils can be controlled by using materials that
are more impermeable than the surrounding soil (EPA 1978).
The most common material used for construction of gas barriers is compacted clay. A clay layer
approximately 2 ft thick is probably adequate. Often a thicker layer is required in order to ensure an
adequate seal if the side slope exceeds 50 percent To be effective, the clay layer must be
continuous. The clay liner should be constructed as the fill progresses because prolonged
exposure to air will dry the clay and cause it to crack. Synthetic membranes may be considered for
the control of migrating gas but their effectiveness has not been established. PVC is thought to be
the most effective (EPA 1978).
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Revised 12/1/89
Gas Extraction and Recovery Systems
An effective method of gas control in refuse landfills involves the placement of an impermeable
barrier combined with a gas extraction and recovery system via strategically located forced exhaust
vents. However, such systems are only feasible at larger landfills and may not be suitable for
sludge landfills because the high moisture content typically found in sludge does not permit gas
movement, and sludge can enter and clog the evacuation pipes.
State Ream

Thirty-eight States require some sort of gas monitoring or control program. Three States have set
concentration limits for methane. Refer to table E5-3 in Appendix E for more information on State
gas control management practices.
5.4.8 PATHOGEN AND DISEASE CONTROL
Federal Regulations
No facility or practice shall exist or occur unless the on-site population of disease vectors is
minimized through the periodic application of cover material or other techniques as appropriate so
as to protect public health (40 CFR Part 257).
Federal Guidance
Cover recommendations for sludge-only and co-disposal landfills were discussed previously in
Sections 5.1.2, These recommendations are summarized below:
Mfiftfid Recommended Cover Thickness
Narrow Trench 2-4 ft
Wide Trench 3-4 ft (for equipment working outside the trench)
4-5 ft (for equipment working inside the trench)
Sludge/Refuse Mixture 0.5-1 ft interim
2ft final
Sludge/Soil Mixture None
71
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Revised 12/1/89
Daily and final cover applications of 6 inches and 24 inches, respectively, are recommended at both
sludge-only and co-disposal landfills. Stabilization of sewage sludge prior to disposal is another
technique used to minimi?* vector attraction.
State Requirements
Twenty-nine States, Puerto Rico and the Virgin Islands have some requirement for daily,
intermediate, or final cover at landfills accepting municipal sewage sludge. Fourteen States require
6 inches of daily cover and one State (Iowa) requires 12 inches. Texas requires 6 inches of daily
cover over stabilized sludges and 2 feet over unstabilized sludges. Four other States require only
that solid waste and sludge be covered at the end of each day.
Intermediate cover is specified by three States. Mississippi requires 24 inches of intermediate
cover, while New York and Ohio require 12 inches.
Fourteen States specify a depth of final coven eleven States require 2 feet, Kentucky requires 2.5
feet, two States (Oklahoma and Texas) require 3 feet, and New York requires 4 feet The State
requirements for cover are listed in Table E5-3.
Twenty-three States indicate thai they have regulations covering pathogen control at sludge
landfills. However, only six States dictate specific means by which pathogens are to be controlled.
Montana, Virginia, Wyoming, Pennsylvania and Rhode Island require thai, prior to landfilling,
sludge be treated by one of the "Processes to Significantly Reduce Pathogens" (PSRP) which are
described in 40 CFR Pan 257, Appendix II, Section A. These processes include: aerobic
digestion, air drying, anaerobic digestion, composting, lime stabilization, or any other equivalent
method. The required operating parameters of each of these processes are described in Appendix II
of 40 CFR Part 2S7.
Illinois requires sludge to be digested at sites when used as or with a cover. West Virginia requires
that the sludge be demonstrated non-infectious. Alaska requires that sludge generated in permafrost
areas be disinfected prior to landfilling. The individual State regulations for pathogen and disease
control are listed in Table E5-3.
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Revised 12/1/89
5.4.9 OTHER STATE MANAGEMENT PRACTICES
A list of additional State management practices that were not listed in Tables E5-1 through E5-4 is
provided in Table E5-5.
5.5 MONITORING- REPORTING. AND RECORD KEEPING
5.5.1 SLUDGE MONITORING
Federal Regulations
The current NPDES regulations require sludge monitoring and reporting at a frequency dependent
upon the nature and effect of the permittee's sludge use or disposal activities, but at least once a
year for every pollutant limited in the permit. This means that if the permit contains a limit for
cadmium, the permittee must be required to monitor its sludge at least annually for this pollutant
Currently, there are no Federal regulations which require sewage sludge quality be monitored for
specific constituents a- characteristics prior to disposal in a monofill or landfill. The existing
Federal regulations stipulate that sewage sludge disposed of in a landfill shall not be hazardous or
cause the contamination of ground-water.
Federal Guidance
In addition to require compliance monitoring, the Sewage Sludge Interim Strategy recommends
annual monitoring of the 126 priority pollutants as well as more frequent monitoring of the
pollutants for which numeric limits have been proposed in the 40 CFR Part 503 Technical Sludge
Standards. For the disposal practice of monofills, these pollutants include:
Arsenic Methyl nitrosamine
Benzene Lead
Benzo(a)pyrene Lindane
Bis(2-ethylhexyl)pthalate Mercury
PaHmium Polychlorinated biphenyls
Chlorodane Nickel
Copper Toxophane
DDT/DDE/DDD (total)1 Trichloroethylene
73
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Revised 12/1/89
State Requirement*
Twenty-one States have regulations that stipulate sludge quality monitoring at sludge landfills.
Four States mandate that the sludge be tested to demonstrate that it is non-hazardous. Six States
require monitoring for specific contaminants and characteristics including: percent solids, pH,
nitrogen, ammonia, nitrates, PCBs, and metals (cadmium, copper, lead, selenium, and zinc are
mentioned).
Only four States specified the frequency with which sludge sampling must occur. Maryland and
Michigan require an initial testing with additional sampling required as needed based on quality or
use. Texas requires semiannual sampling, while New Hampshire varies sampling frequency based
upon the size of the treatment plant: plants larger than 1 mgd must be sampled 3 times per year,
plants smaller than 1 mgd must be sampled annually. Individual State requirements for sludge
quality monitoring can be found in Table E3-4.
If radionuclides in the sludge are a concern and need to be addressed by the permit writer, then
consideration should be given to at least annual monitoring of the sludge.
If the permit writer is unsure of the quality of the sludge or concerned about potential
contamination because sludge quality is poor and landfill design and operation is marginal, the
permit writer should develop concentration limits and/or monitoring requirements for pollutants of
concern.
5.5.2 GROUND-WATER MONITORING
Fwteral Rcyiilarinm
While existing Federal regulations prohibit contamination of ground-water, they do not specifically
require ground-water monitoring at sludge-only or co-disposal landfills.
1 DDT-2,2-Bis(chJorophenyl)-1,1,1-trichloroe thane
DDE-1,1 -Bis(chlorophenyl)*2,2-dichlofoethene
DDD-1,1 -Bis(chlorophenyl)-2,2-dichloroethane
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Revised 12/1/S9
Stag Rcquircmcnta
Thirty-six States presently have some policy in-place regarding ground-water monitoring at
Subtitle D landfills. Twenty-eight of these States require monitoring at all sites, while seven States
decide on a case-by-case basis; generally based upon individual hydrogeologic conditions.
Louisiana and Oklahoma specifically require a minimum of 1 upgradient and 2 downgradient
wells. New York requires a minimum of 1 upgradient and 3 downgradient wells. Maine requires a
minimum of three monitoring wells but does not specify their location. Four States require that a
ground-water monitoring plan be submitted as pan of a permit application. The individual State
requirements are listed in Table E5-4.
Of the thirty-six States that require ground-water monitoring, only three specify the frequency of
sampling. Michigan and Vermont require quarterly sampling; Louisiana requires annual sampling.
Only two States (California and Texas) list specific parameters that must be monitored. These
include: ground-water table elevation, temperature, specific conductance, pR, nitrates, COD,
sodium, chloride, iron, manganese, sulfates, phenol, and sulfur. One study cited in the literature
indicated that State requirements in Subtitle D landfills often include monitoring of pH, specific
conductance, TDS and organic carbon (EPA 1986b).
Case-bv-Case Recommendations
The permit writer should evaluate site-specific conditions in determining whether a monitoring
system is necessary. If monitoring is deemed necessary, the permit writer needs to write
monitoring system specifications (number of wells, well configuration, etc.) into the permit
The number of wells required to adequately monitor a sludge-only or co-disposal landfill is highly
site-specific, and generally depends oa the hydrogeologic conditions at the site and the goals of the
ground-water monitoring program. A qualified hydrogeologist should be consulted to assist in
determining the number of wells required and their location (EPA 1919). Solid waste and ground-
water program officials should be consulted when making determinations regarding ground-water
monitoring at landfills.
Regardless of number, monitoring wells should be placed both upgradient and downgradient of the
facility. Upgradient wells indicate the natural or background ground-water quality at the site while
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Revised 12/1/89
down gradient wells measure ground-water quality after it has passed beneath the facility to detect
any contamination. It is highly desirable to install all monitoring wells and begin sampling at least 6
months to a year before the site is activated to establish background quality, including any seasonal
fluctuations (EPA 1978).
Information about the ground-water flow system can be determined from monitoring wells.
Ground-water elevations should be measured at scheduled frequencies and the ground-water flow
gradient determined. Flow rate of ground-water can be determined using tracers in the monitoring
wells. This information is very valuable in the event of contamination and should be obtained and
utilized in consultation with a qualified hydrogeologist
The frequency of ground-water sample collection is dependent upon the specific characteristics of a
site; including aquifer flow rate and the resource value of the aquifer. Analyses of the initial and
second samplings may suggest an adjustment of the sampling frequency. Studies indicate that
leachates frequently are released in slugs, or high concentrations, at periodic intervals that are
seasonably or climatically influenced. This may dictate intensified sampling efforts at certain timet.
Quarterly sampling is most often recommended, however, sampling frequency is site specific and
should be adjusted if experience indicates that more frequent samplings are necessary (EPA 1978).
A phased approach is recommended for ground-water monitoring in sludge monofills. In Phase I,
samples should be analyzed for pH, TKN-N, Nitrates, TOC, and TDS. If Phase I indicates that
contamination is occurring, then more detailed Phase II monitoring should be required. Phase II
analytes should consist of iron, heavy metals (especially lead), chorides, and any other drinking
water parameters. Monitoring of ail contaminants for which drinking water standards [aka
Maximum Contaminant Levels (MGL's)] have been established (see Appendix I of 40 CFR Part
257) is recommended so that the extent and degree of ground- water contamination can be
determined Monitoring ground-water for contaminants found in an analyses of the sludge are also
recommended (EPA 1978).
The EPA Process Design Manual for Municipal Sludge Landfills (EPA 1978), recommends
monitoring for the following parameters as appropriate: pH, TDS, nitrate, chlorides, TOC and
heavy metals, and methylene blue-active substances.
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Revised 12/1/89
5.5.3 GAS MONITORING
Federal Regulations
The concentration of explosive gases generated by a Subtitle D facility shall not exceed 25 percent
of the lower explosive limit for gases in facility structures, and 100 percent of the lower explosive
limit for gases at the property boundary (40 CFR Pan 257).
Federal Guidance
The technical literature generally recommends that sludge-only and co-disposal landfills located
near structures conduct periodic gas monitoring to detect gas migration and accumulation. In most
cases, over 70 percent of the gas volume produced from the decomposition of solid wastes and
sludge consists of methane and carbon dioxide; methane is the gas of major concent
State Requirements
Thirty-seven States and Puerto Rico have some policy regarding gas migration and control at
Subtitle D facilities. Nine other States cite the limit of less than 25 percent of the lower explosive
limit in structures. A total of eight States do not have specific numerical standards, instead they
simply state that gas migration and accumulation should be prevented. Four States decide upon the
need for gas control on a case-by-case basis. Table E5-3 contains a summary of the gas control
policy for each State.
None of the thirty-seven States that have regulations governing landfill gas specify sampling
frequency.
5.5.4 SURFACE WATER MONITORING
State Requirements
Twenty States presently have some policy regarding surface water monitoring. A total of twelve
States require surface water monitoring at all sludge landfills. The remaining eight States have the
option of requiring surface water monitoring on a case-by-case basis.
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Revised 12/1/89
Only Maine specifies the number of surface water sampling stations; a minimum of two. Maryland
requires that a plan for surface water monitoring be proposed. The individual State requirements
are listed in Table E5-4. No States presently specify either the frequency of surface water
monitoring or the parameters that should be monitored in their regulations.
5.5.5 MONITORING FOR HAZARDOUS WASTES
In order to fulfill the stipulation that hazardous sludge not be disposed of in a nonhazardous
material landfill, the permit writer may want to require monitoring to demonstrate that the sludge is
not hazardous. An Extraction Procedure (EP) Toxicity test is generally performed to determine
whether or not sludge is hazardous. The EP toxicity test, which appears at 40 CFR Part 261,
Appendix II, involves the preparation of an aqueous extract of the suspected hazardous waste,
which is analyzed for the constituents in Table 5.2. The sludge exhibits the characteristics of EP
toxicity, and therefore is a hazardous waste, if the extract from a representative sample contains
any of the contaminants listed in the table at a concentration equal to or greater than the respective
tabulated value.
In it generally agreed that the EP toxicity test procedure is not sufficient for screening of potentially
hazardous materials because there are many more toxic substances that may appear in a suspected
hazardous waste than the 14 compounds to which the EP toxicity test applies. A new test, known
as the Toxicity Characteristic Leaching Procedure (TCLP) test, has been under development for
several years and is expected to be published in final form in late 1989. When finalized, the TCLP
test will replace the EP toxicity test An important difference between the two tests is that the
TCLP is designed to evaluate a greater number of compounds (particularly organics) than are
considered by the EP procedure. The constituents analyzed in the TCLP test are listed in
Table 5-2. Tests of the draft TCLP performed on 18 municipal sludges have shown that none of
the sludges contained hazardous levels of pollutants. Several of the sludges, however, had
contaminant concentrations at levels close to those defined by the TCLP test as hazardous (EPA
1987).
5.5.6 REPORTING AND RECORD KEEPING
Federal Regulations
The recently promulgated revisions to the NPDES Permitting Regulation (54 FR 18716) require
the POTW to report monitoring results with a frequency dependent on the nature and effect of the
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UKEM
MAXIMUM CONCENTRATIONS FOR CONTAMINANTS ANALYZED
UNDER EP TOXICITY AND TCLP TESTS
Contaminant
EP To*.
TCLP (Proposed)
Ma Cone (mart.)
Max Cone fmc/Li
Acrytonitnle
.
30
Arsenic
S.0
SO
Banum
100.0
100 0
Benzene
.
0 07
0iS<2-Chloroethy1)
.
0.03
ether

Cadmium
1 0
1 0
Cartm disulfide
.
144
Carbon tetrachloride
.
0.07
Chkxdane
.
0.03
CMorooennoe
.
1 4
Chtoroform
.
0.07
Chromium
3.0
3,0
o-Cresol
-
10.0
m-Cnaoi
-
10.0
O-Creaol
•
10.0
2.4-0
10.0
1.4
1,2-Dcmorobenjene
.
43
i ,4 -Oehioratieruene
-
10 8
i ,2-OicHtorootfvaoe
.
040
M-Defikyoetftyiene
.
0.1
2,4-Oinrtro toluene
.
0 13
Endnn
002
0003
Heptaehior (and its

0 001
hydremia)

HexacfJtoroCenrene
-
0.13
Heiacfiiorotxjtadtflne
-
0.72
Hexaenioroetftane
-
4.3
isobutanof
-
36
Lead
3.0
3.0
Lindane
04
0.00
Mercury
0.2
02
Methoxycfilor
100
1 4
Methylene chloride
.
SO
Methyl ethyl ketone
.
72
Nitrobenzene
.
0.13
PentacMorophend
.
36
Phenot
•
14.4
Pyridine
.
90
Setoraum
.
1 0
Scfver
3.0
30
i,i,U*Ten-

10.0
cMoroettMne

I.l.i2-Te»-

1 3
crtoroemene

0.1
2.3.4.8-Tetra-

1 5
cworophenol

Toluene
.
14 4
Toxapftene
0.9
0.07
i.i,i-Tnchioroetnane
.
30.0
t,i,2-Tfichioroetnane
.
1 2
Tncnioraettiywne

0-07
2,4.5-TncWOrophenol
.
3.8
2,4.8-TncMoropftenol
.
0-30
2.4,5-TP (S*«0
1 0
0.1*
v^eMonda
.
0.09
79
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Revised 12/1/89
sewage sludge ase or disposal practices, but in no case less than one a year [40 CFR Part
122.44(i)(2)]. The regulations also require that records of monitoring required by the permit for
the permittee's sewage sludge use and disposal activities must be retained for a period of at least 5
years [40 CFR Pan 122.21(p)].
State Requirements
Reporting and record keeping requirements vary widely from State to State. Thirty States require
some degree of reporting and record keeping at sludge landfills. Seven States require keeping
records of the source of sludge, and sludge quantity and quality. Ohio and Oklahoma require a log
of daily operations at the facility.
The frequency with which reports must be submitted varies from monthly to quarterly to semi-
annually. Only three States specify a reporting frequency in their regulations.
REFERENCES
EPA 1978. Process Design Manual: Municipal Sludge Landfills. U.S. Environmental Protection
Agency, Office of Solid Waste, 1978.
EPA 1984. Ground-Water Protection Strategy. U.S. Environmental Protection Agency, Office of
Ground-Water Protection, Washington, D.C., 1984.
EPA 1986a. State Subtitle D Regulations on Solid Waste Landfills. U.S. Environmental Protection
Agency, Office of Solid Waste and Emergency Response, Washington, D.C., 1986.
EPA 1986b. Subtitle D - Phase I Report U.S. Environmental Protection Agency, Office of Solid
Waste and Emergency Response, Washington, D.C., 1986.
EPA 1987. Cooperative testing of Municipal Sewage Sludges by the Toxicity Characteristic
Leaching Procedure and Compositional Analysis, Draft Report, U.S. Environmental Protection
Agency, May 18,1987.
EPA 1987a. State Requirements for Sludge Management, U.S. Environmental Protection Agency,
Office of Municipal Pollution Control and Office of Water Enforcement and Permits, Washington,
D.C., 1987(Revised 1989).
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Revised 12/1/89
EPA 1987b. Guidelines for Delineation of Wellhead Protection Areas. U.S. Environmental
Protection Ageocy, EPA 440/6-87-010, June 1987.
EPA 1988. Guidelines for Ground-Water Gassification Under the EPA Ground-Water Protection
Strategy. U.S. Environmental Protection Agency, Office of Ground-Water Protection,
Washington, D.C., 1988.
Tchobanoglous, G. ct al., 1977. Solid Waste, McGraw-Hill, New York.
81
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Revised 12/1/89
CHAPTER6
LAND APPLICATION
6.1 INTRODUCTION
Currently, about 18 percent of municipal sewage sludge is applied to the land (EPA 1987a). Land
application options include:
o Agricultural Utilization: Use of sludge as a source of fertilizer nutrients and/or as a soil
amendment to enhance crop production.
o Forest Utilization (Silviculture): Use of sludge on forested land to enhance forest
productivity.
o Land Reclamation Utilization: Application of sludge to strip mine lands, mine tailings, or
other disturbed or marginal land foT the purpose of revegetation and reclamation.
o Dedicated Land Disposal (DLD): Application of sludge to soils, with or without vegetation,
for the primary purpose of sludge disposal. This option differs from the others in that sludge
is generally applied at higher rates and system management is more intensive. Crop
production (if any) is of secondary importance.
This chapter describes the permit requirements and recommendations for land application sites.
This section briefly describes each of the different land application practices. Section 6.2 then
provides the general requirements and recommendations applicable to all forms of land application.
Finally, sections 6.3,6.4,6.5 and 6.6 address any additional requirements and recommendations
for agricultural utilization, forest utilization, land reclamation utilization and dedicated land
disposal, respectively.
6.1.1 AGRICULTURAL UTILIZATION
Hundreds of communities, both large and small, have developed successful agricultural utilization
programs. Agricultural utilization is especially common in New Jersey, Pennsylvania, Ohio,
Illinois, Michigan, Missouri, Wisconsin, and Minnesota. These programs benefit the municipality
generating the sludge by providing an ongoing, environmentally acceptable means of sludge
82
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Revised 12/1/89
disposal, and provide the participating farmer with a substitute or supplement for conventional
fertilizers.
Agricultural utilization assumes that the sludge is applied at "agronomic rates,'' defined as the
annual sludge application rate at which the nitrogen (N) and/or phosphorus (P) supplied by the
sludge and available to the crop does not exceed the annual N and/or P growth requirements of the
crop. Therefore, assuming contaminant concentrations are low, the amount of sludge applied to
the site is determined by the available N or P requirement of the crop to be grown.
Sludge application rates for agricultural utilization (dry unit weight of sludge applied per unit of
land area) are usually low relative to other land application practices. Thus, large land areas may
be needed, which may require the cooperation of many individual land owners. In addition,
because of planting, harvesting and delays caused by adverse climatic conditions, scheduling
sludge transport and application requires careful management.
6.1.2 FOREST UTILIZATION (SILVICULTURE)
Except for certain areas in the Great Plains and the Southwest, forested lands are abundant and
well distributed throughout most of the United States. Many major municipalities are located near
forests; in fact, it is estimated that close to one-third of the land within the standard metropolitan
areas is forested. Furthermore, approximately two-thirds of all forest land in the United States is
commercial timberland. Thus, the application of sludge to forest soils has the potential to be a
major sludge utilization/disposal practice.
Studies have shown that sludge application can greatly improve forest productivity (EPA 1984).
Forest soils have perennial root systems (which allow year-round application in mild climates),
large amounts of organic material (which immobilize metals in the sludge) and high infiltration
rates (which reduce run-off and ponding). Another advantage is that forest products such as wild
edible berries, mushrooms, game and nuts make up a very small pan of the average human diet
(EPA 1984). Studies in forests where sludge has been applied have suggested that there is no
accumulation of trace metals in the muscle tissue of wild animals (Haufler, Hest, 1985). Data have
also shown no statistical difference in metal accumulations (Zabowoski and Zasoski, 1986) in wild
berries grown on sludge amended soil. The primary environmental and public health concern
associated with forest application is pollution of water supplies (EPA 1984).
83
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Although silviculture is not yet a common practice, approximately 12 States have silviculture sites.
Silvicultural sludge application may be particularly beneficial to recently cleared land and newly
established (i.e., 3 to 10 years) forest plantations, as well as established forests. Municipalities in
Washington have particularly well developed programs, and the State of Washington has a
guidance document for forest land application (WDOE 1982).
6.1.3 LAND RECLAMATION
Surface mining, mineral exploration, and deposition of spoils and tailings from mining operations
have created over 1.5 million hectares (3.7 million acres) of drastically disturbed land. The
properties of these and other drastically disturbed and marginal lands vary considerably from site to
site. Their inability to support vegetation is the result of several factors:
o Lack of nutrients - The soils have low N, P, K, and/or micro-nutrient levels.
o Physical properties - Stony or sandy materials have poor water-holding capacity and low
cation exchange capacity (CEC). Clay soils have poor infiltration, permeability, and
drainage.
o Chemical properties - The pH of mine soils, tailings, and some drastically disturbed soils
range from very acidic to alkaline. Potentially phytotoxic levels of Cu, Zn, Fe, and salts may
be present
o Organic matter - Little, if any, organic matter is present.
o Biological properties - Soil biological activity is generally reduced.
o Topography - Many of these lands are characterized by steep slopes that are subject to
excessive erosion.
Historically, reclamation of these lands is accomplished by grading the surface to slopes that
minimize erosion and facilitate revegetation. In some cases, topsoil is added Soil amendments
such as lime and fertilizer are added, and grass, legumes, and/or trees are planted. Although these
methods are sometimes successful, numerous failures have occurred primarily because of the very
poor physical, chemical, or biological properties of these disturbed lands. .
84
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There have been a number of successful land reclamation projects involving the use of sludge or
sludge compost Most have been conducted on strip-mined land or mine tailings in the Eastern
coal States of Pennsylvania, Illinois, Virginia, West Virginia, and Alabama. No significant
ground-water degradation problems associated with sludge application have been documented at
any of these sites. Philadelphia has a program which regularly uses sludge in reclamation projects.
Typically, sludge is applied only once to land reclamation project sites. Therefore, an ongoing
program of sludge application to disturbed lands requires that a planned sequence of additional
sites be available for the life of the program. This objective may be achieved through arrangements
with land owners and mining firms active in the area, or through the planned sequential
rehabilitation of existing disturbed land areas. In some cases, reclaimed areas may be used for
agriculture production using agronomic rates of sludge application.
6.1.4 DEDICATED LAND DISPOSAL
Generally, a project utilizing land dedicated to sludge disposal has the following characteristics:
o The primary puipose is long-term sludge application. Any additional site activities or
benefits such as the production of agricultural crops or improvement of soil characteristics are
secondary to the sludge disposal activity.
o Normally, sludge application rates are substantially higher than for other options, e.g.,
agriculture, forest, etc. Obviously, higher application rates reduce the area of land required.
o Usually, the municipality owns or has a long-term lease on the land, which gives the
municipality substantial latitude in use of the land for sludge disposal.
o The site should be more carefully designed, managed, and monitored than sites where sludge
is applied at agronomic rates as a fertilizer amendment to cropland, forest land, etc. Access
restrictions should be in place at all times.
o Site design and operations are focused upon containing any environmentally detrimental
sludge constituents within the dedicated disposal site. Surface run-off, ground-water
leachate, and harvested crops (if any) are carefully monitored. Strict controls are almost
always required, both during operation and site closure. Some States require a notation on
the land deed that the site has been used for land application.
85
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A special case occurs when animal feeds are grown on land dedicated to sludge disposal.
Regulations generally require operators of these projects to implement an extensive facility
management plan to prevent adverse environmental impacts or human health.
6.2 GENERAL REQUIREMENTS AND GUIDANCE FOR ALL FORMS OF LAND
APPLICATION
6.2.1 PERMITTING RESPONSIBILITIES
Permits must state that sludge be applied to lands in accordance with the general 40 CFR Pan 257
requirements for solid waste disposal facilities and practices. (See Table 5-1 in the Landfill
Chapter.) These requirements address floodplains, endangered species, surface water, ground-
water, disease, air, and safety.
To ensure that sludge of an appropriate quality is applied to lands in a manner that protects public
health and the environment, three types of permit conditions are needed:
o Sludge quality. The permit should contain conditions to ensure that the quality of the sludge
is suited to the particular form of land application practice. It is particularly important that the
permit writer consider the metals content of sludges that will be applied to soils with a pH of
6.5 or less because metals tend to be more mobile in low pH soils than in high pH soils and
may have an adverse impact on ground-water quality.
o Selection of appropriate application sites. The permit should contain conditions ensuring that
only sites that are suited to sludge application are used. For example, it is generally not
appropriate to apply sludge within 200 feet of a drinking water well. As another example,
sludge should generally not be applied to agricultural sites where the slope exceeds more than
15 percent; and
o Management of application sites. The permit should require that application sites be properly
managed. For example, to protect surface waters, buffer strips should be maintained between
the sludge application site and surface water. To protect ground and surface waters, sludge
should not be applied during periods when the soil is saturated.
86
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As the sludge generator, the POTW is always responsible for sludge quality. However, ensuring
that sludge application sites are selected and managed properly is not always within the control of
the POTW. Many POTWs employ a contractor to select and manage sludge application sites. Some
POTWs provide sludge to a farmer who applies the sludge and manages the site.
To ensure that sludge application sites are selected and managed properly, permit writers should
consider requiring a POTW either
o To select and manage application sites itself, following the conditions set forth in the permit
and the guidelines in the POTW's general land application plan (discussed in the next
paragraph), EPA's Process Design Manual for Land Application of Municipal Sludge (EPA
1983), or State or local guidelines that the permit writer determines are appropriate; or
o To establish contracts with any parties who assume responsibility for site selection and site
management Contracts should specify how sites will be selected or managed (for example,
by reference to the sources described just above). Contracts should also address issues such
as when the sludge may be applied (for example, application by heavy vehicles when the soil
is wet may damage soil structure), how much sludge can be applied and under what
conditions sludge application can be terminated by one of the parlies to the contract (EPA
1984). An example contract, drawn from the 1984 EPA Intra-Agency Sludge Task Force
Report (EPA 1984) is presented in Figure 6-1.
A permit that does not require a POTW to select and manage land application sites itself, and that
does not require the POTW to have contracts with other parties who select and manage land
application sites, should be based on the recommendations for distribution and marketing of sludge
in Chapter 7.
During the life of the permit, a POTW may apply sludge to many individual sites. Thus, at the time
that it applies for a permit, the POTW may not be able to answer important questions such as:
where will the sludge be applied; how does the site compare to a good set of evaluation criteria;
what management practices should be employed? Permit writers should consider requiring
POTWs to develop an approvable plan, similar to a Best Management Practices (BMP) plan, that
sets guidelines for how sludge application sites will be selected and managed. These plans should
not only address the recommended permit conditions in this Chapter, they should also address a
number of other considerations such as those discussed in the Process Design Manual for Land
Application of Municipal Sludge fFPA 1983)
-------
Figure 6.1. EXAMPLE LAND APPLICATION PROGRAM CONTRACT
THIS CONTRACT, made this day of
hereinafter referred to as Owner, and
CONTRACT
19 by and between .
. hereinafter referred to as City, witnesseth that,
WHEREAS, Owner is the owner of a parcel of agricultural real property located in (PARCEL NO ) (TOWNSHIP) ICOUNTY)
Ohio, which can be reached as follows
.. and
WHEREAS, City operates a waste treatment or disposal plant which after processing produces a product known as sewage sludge, and
WHEREAS, Owner will allow sewage sludge from City to be placed or the above-mentioned real property only on the terms set out below,
NOW THEREFORE, Owner and City mutually agree as follows
1 The "Ohio Guide for Land Application of Sewage Sludge,"
Bulletin 538 of the Cooperative Extension Service of the Ohio State
University, as revised in May, 1978, shall be used as a guideline for
responsible management practices Hereinafter Bulletin 538 will be
referred to as "The 1976 Guide "
2 The City will deliver sewage sludge to the above-mentioned
property of Owner and will properly spread or otherwise deposit said
sewage sludge on said property without charge to the Owner City shall
be responsible for all equipment used to deliver and spread such sewage
sludge
3 The Owner and the City will mutually agree on the specific portion
of said property which is to receive sludge In the absence of unusual
factors, they will abide by the site election criteria of the 1976 Guide
4 The Owner or his representative may decline to receive sludge on
said property when, in Owners's or his representative's judgement, the
sludge application equipment would damage the soil structure because
of excessive soil moisture at the disposal site When possible, the
Owner will give the City notice of poor field conditions 24 hours prior to
the appointed application time However, the City does realize that this
is not always possible and that there will be some days when untimely
excessive rainfall will require termination of spreading activities at a
moment's notice on a given field
5 The Owner will notify City in writing of the dates between which
City may deliver and spread sewage sludge The City may deliver said
sewage sludge only during the period thus described The Owner will
make himself or his representative available to City or its employees
during such period to ensure said sewage sludge is deposited on the
proper location on said property
6 Owner shall specify the access to be used by the City when
sewage sludge is applied to a specific portion of said property The
Owner shall provide and maintain an access for use by the City without
charge to the City, and the City shall not be liable for any damages
thereto, except damage caused by City's negligence
OWNER
7 llsin* the criteria of the 1976 guide, the Owner and the City have
mutually Agreed on the rates and amounts per acre said sewage sludge
is to be ^>plied during the Contract penod For the term of this
Contract, the City wtt adhere to mutually agreed upon appRcation rates
listed in Attachment A which is included as a part of this Contract
8 The City shall property analyze its sewage sludge on a monthly
basis for the total nitrogen, ammonia and nitrate nitrogen, phosphate,
potassium, lesd, zinc, nickel, copper, and cadmium content. The results
of such analysis will be provided to the Owner or his representative
upon request without charge before sludge is applied to said property
9. City shall keep and maintain records of the following items, and
shall make such records available to Owner or his representative upon
request'
(a) All analyses of the composition of sewage sludge produced by the
City.
(b) All reports concerning the operation or production of sewage
sJudge by the City
Ic) All applications to agncultural land of sewage sludge produced by
City including dates of application, amounts applied, specified
rates of application, specific parcels of land upon which sewage
sludge has been applied.
(d) All required governmental permits or approvals for the application
of sewage sludge on agricultural land.
10. City will deliver and epply sludge which is well stabilized and
which does not present a severe odor nuisance to Owner or other rural
residents who live in the vicinity of the sludge disposal site The Owner
may refuse to accept any sludge which is exceptionally odorous.
11. The Contract shall continue in effect for a penod of three years
following the date first ebove written. The Parties hereto may renew this
Contract in wnting Either party may cancel this Contract by giving
written notice to the other party of the intention to do so. Cancellation
will be effective five days after receipt of such notice. Such notices shell
be delivered personally or by certified mat! to the address(es) listed at
the end of this Contract.
CITY
Address'
By _
Title
By _
Title
Address.
Source: EPA
09
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Revised 12/1/89
chat arc not listed in this Section as recommended permit conditions. In general, these
considerations are very site-specific in nature and are not easily summarized as a permit condition.
For example, site soil texture and parent geologic material should be evaluated because these
factors influence permeability, infiltration and drainage. However, while highly permeable soil
(e.g., sand) and highly impermeable soil (e.g., clay) may present design and operational problems,
sludge can be successfully applied to virtually any soil (EPA 1983).
Permit writers should require the POTW to develop the plan within a reasonable period of time
(e.g., four months) and submit it to the permit writer for approval. Permit writers should compare
the plan to this guidance, the Process Design Manual and any State or local guidelines. If
necessary, the permit writer should request that the POTW make changes to the plan to ensure that
sludge application sites are selected and managed properly. In Regions that have separate permits
and construction grants sludge coordinators, the construction grants coordinator may be able to
provide assistance in reviewing land application plans.
A land application plan may not be needed if: 1) the POTW provides with its application a list of
the sites it will use during the life of the permit, 2) demonstrates that the sites are appropriate, and
3) specifies the management practices that it (or a contractor) will follow. Also, a plan may not be
needed if a State or local agency evaluates land application sites using criteria that the permit writer
determines will adequately protect public health and the environment, and has an effective program
for monitoring compliance with appropriate site management practices.
Permit writers should require POTWs to keep records identifying the location and owner of each
application site, who applied the sludge, and what use is made of the site. For example, if a site is
used for agriculture, are fruits and vegetables grown, other types of food-chain crops, or non-food
chain crops only (e.g., turf ot ornamental plants)? With each subsequent permit application, permit
writers should require POTWs to submit a site-by-site summary of cumulative loadings of heavy
metals limited in the permit. Also, unless records are available from a State or local agency
showing site suability, the POTW should keep records that show, for each site, what evaluation
criteria were used to select the site, how the site compared to die criteria, and any site management
practices that were determined to be necessary.
When drafting permit conditions for land application, the permit writer should first ensure that
existing Federaland State requirements will be met. Next, the permit writer should consider
whether further conditions may be appropriate to protect public health and the environment. Then,
within this framework, he or she should encourage beneficial use/recycling (the ultimate selection
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Revised 12/1/89
of sludge use/disposal practices is up to the municipality). In many cases using sludge provides
environmental benefits, particularly when compared to current practices or sue conditions. For
example, if the sludge contains high levels of heavy metals, which may result in loadings of metals
that exceed the recommendations for agriculture, it may be appropriate to use it if it will clearly
improve the quality of ground-water or surface water run-off at a site that has been strip-mined and
is now barren (particularly if the site is clearly not suitable for agriculture, or the POTW can assure
that the site will not be used for food-chain crops during the life"of the permit and the metals
guidance would only be exceeded by a small amount).
Section 6.2.2 addresses the specific requirements and guidance concerning sludge quality and
Section 6.2.3 addresses the specific requirements and guidance concerning operation conditions
and management practices. Each topic discussion addresses applicable Federalregulations,
Federal guidance, and State regulations. Appendix E presents additional information on State
management practices. Table E6-5 summarizes State management practices for land application.
Additional land application management practices specified by only one or two States are presented
in Table E6-6. State requirements for site-specific considerations are summarized in Table E6-3.
State prohibitions for land application are presented in Table E6-7. Land reclamation management
practices are summarized in Table E6-8. Ohio, Arizona and Washington repotted management
practices for forest application (see Table E6-9). Texas reported management practices for land
treatment (i.e. dedicated lands) (see Table E6-10).
6.2.2 CHARACTERISTICS OF SLUDGES SUITABLE FOR LAND APPLICATION
Sludge Pollutant Concentration Limits
Federal Regulations
Pathogens
Permits must state that sludge applied to land will be treated by a pathogen reduction process that
meets the requirements of 40 CFR Part 257 (See Table 6-1). Briefly, Qathogen reduction is
¦N
required whether or not food-chain crops (as defined in 40 CFR Part 257) are grown. Among
other conditions, if public access to the sludge application site is controlled for twelve months, the
sludge must only be treated by a "Process to Significantly Reduce Pathogens" (PSRP) (e.g.,
anaerobic digestion, air drying for three months, composting which includes a minimum 4-hour
period during which the temperature exceeds 55 degrees Centigrade, and lime stabilization). If the
on
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TABLE 6-1
40 CFR PART 257 PATHOGEN REDUCTION REQUIREMENTS
FOR LAND APPLICATION AND DISTRIBUTION AND
MARKETING OF SLUDGES
• Sewage sludge or septic tank pumpings that are applied to the
land surface or incorporated into the soil must be treated by a
Process to Significantly Reduce Pathogens (PSRP) These
process include
• aerobic digestion at residence times ranging from 60 days
at 15°C to 40 days at 20°C with a volatile solids reduction of
at least 38%,
• air drying on underdrained sand beds or paved or unpaved
basins in which the sludge is at a depth of nine inches for at
least three months The average daily temperature must
exceed 0°C for two of these months;
• anaerobic digestion at residence times ranging from 60
days at 20°C to 15 days at 35-55°C with a volatile solids
reduction of at least 38%,
• composting at a minimum operating temperature of 40 °C for
five days. For four hours dunng this period the temperature
must exceed 55°C, and
• lime stabilizabon in which sufficient lime is added to produce
a pH of 12 after two hours of contact Other processes may
be acceptable if pathogens and volatile solids are reduced to
an equivalent level
• When sludge is treated by a PSRP, public access to the site
must be restricted for at least twelve months and grazing by
animals whose products are consumed by humans must be
prevented for at least one month.
• If crops for direct human consumption are grown within 18
months after sludge or septic tank pumpings are applied to a site
and the edible portion of the crop will contact the waste, the
sludge or pumpings must be treated by a Process to Further
Reduce Pathogens (PFRP) PFRPs include-
• composting at a temperature of at least 55 °C for three days
if the m-vesse) or static aerated pile methods are used Using
the windrow method, a temperature of at least 55 °C must be
maintained for 15 days and the pile must be turned five times
dunng this high temperature penod;
• heat drying dewatered sludge cake until the moisture content
is reduced to no more than 10%. Sludge particles must be
heated to at least 80 °C or the wet bulb temperature of the
gas stream in contact with the sludge must exceed 80*C at
the point where it leaves the dryer;
• heat treating liquid sludge to temperatures of 180°C for 30
minutes;
(Continued)
91
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TABLE 6-1 (Continued)
• thermophilic aerobic digestion at residence times of ten
days at 55-60 °C with a volatile solids reduction of at least
38%, and
• a PSRP followed by either beta or gamma ray irradiation at
a dosage of at least 1 0 megarad at room temperature (ca.
20°C) or pasteunzation for at least 30 minutes at a minimum
temperature of 70 °C Other processes may be acceptable rf
pathogens and volatile solids are reduced to an equivalent
level
• The Waste Water Solids Cntena Branch of the Office of Water
Regulations and Standards leads a Pathogen Equivalency
Committee which evaluates and makes recommendations on the
equivalency of proposed sludge treatment processes to the
processes identified in 40 CFR Part 257 The Committee also
provides technical assistance to persons prepanng proposals for
Committee review. For further guidance please consult "Environ-
mental Regulations and Technology Control of Pathogens m
Municipal Wastewater Sludge " (EPA September 1989)
92
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Revised 12/1/89
public will have access to the site within a year of sludge application, or if the edible portion of a
crop that is grown for human consumption within eighteen months of application will contact the
sludge (e.g., root crops such as beets and potatoes or low-growing crops such as bush beans and
strawberries), a "Process to Further Reduce Pathogens" (PFRP) is required (e.g., heat drying or
composting which includes a period during which temperature exceeds 55°C for at least three
days). 40 CFR Part 257 also states that a practice shall not occur unless disease vectors are
minimized through the periodic application of cover material "or other techniques as appropriate so
as to protect public health." Treatment of sewage sludge or septic tank pumpings by one of the
pathogen reduction processes described above (which substantially reduce the vector attraction of
sludge) should satisfy this requirement.
Polychorinated Biphenyls (PCBs)
Sludge containing concentrations of PCBs equal to or greater than 10 mg/kg (dry weight), but less
than 50 mg/kg, must be incorporated into the soil when applied to land used for producing animal
feed, including pasture crops for animals raised for milk. Incorporation of the sludge into the soil
is not required if it is assured that the PCB content is less than 0.2 mg/kg (actual weight) in animal
feed or less than 1.5 mg/kg (fat basis) in milk (40 CFR Pan 257).
Sludges containing greater than 50 mg/kg of PCBs must be treated under the requirements of 40
CFR Pan 761.60 which allow only incineration, disposal in a chemical waste landfill, or alternate
disposal method if approved by the Regional Administrator.
Other than the pathogen and PCB restrictions discussed above and a cadmium limit for food-chain
crops discussed further in the chapter, there are no Federalregulations on contaminant levels in
sewage sludge.
State Requirement!
Multi-Grade Pollutant Concentration Limits
At least six States define and regulate more than one grade of sludge. States with multiple sludge
grades define those grades according to contaminant levels. In Massachusetts, sludge grading
depends on contaminant levels, stabilization, and content of putrescible materials. Allowable uses
are specified for each grade along with the degree of State review required. New Jersey's grades
are based on metal concentration and the length of time a given concentration could be applied at
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Revised 12/1/89
agricultural rates before reaching cumulative loading limits. Colorado sets numerical limits for
each grade and specifies the types of use allowed for each grade. The contaminants and the
multiple grades of sludge quality regulated by these States are shown in Table E6-1.
Generally, the States allow certain uses such as land application only for better quality sludge,
Grades 1 and 2 in most cases. New Jersey, taking a resource-use approach, prohibits landfllling
of high-quality sludge. Allowed uses, application rates, and safeguards all may vary with sludge
quality. Grade 3 & 4 sludge cannot be used on food-chain crops, but usually is allowed for land
reclamation or other uses.
No States have specific contaminant limits for silviculture or dedicated lands. Some States allow
higher concentrations for land reclamation. See Table E6-2 for State sludge concentration limits
for use in land reclamation.
Pathogens
In addition to the contaminant concentration limitations listed in Table E6-1, thirty-four States have
regulations or guidelines addressing pathogen control. Twenty-one of these States have
requirements similar to the current Federalregulations. Eleven States did not detail their
requirements other than to acknowledge that pathogen control is required. Note that only the listed
processes in 40 CFR Pan 257 Appendix Q are acceptable methods of pathogen control to meet
PSRP and PFRP standards.
Physical Properties
The improvement of the characteristics of the sludge facilitates ultimate use or disposal For land
application, the degree of sludge stabilization is a very important characteristic. Stabilization refers
to a number of processes that reduce the potential for odor. Stabilization processes also reduce
pathogen levels and usually help to reduce the volatile solids content The most common methods
of stabilization include anaerobic digestion, aerobic digestion, lime stabilization, and composting.
Anaerobic digestion is the most common method of sludge stabilization and generally biodegrades
about SO percent of the volatile solids in a sludge. Because much of the organic matter has already
been eliminated, stabilized sludges tend not to cause odor problems. Low odor potential is
desirable and is sometimes required by States for land application.
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Revised 12/1/89
Another sludge characteristic of importance for land application is water content. Sludge water
content affects the design of a land application program because:
o The higher the sludge solids content, the lower the volume of sludge that will have to be
transported, stored, etc., because less water must be handled.
o The type of transport that can be utilized, e.g., type of truck, feasibility of pipeline transport,
etc. depends in pan on sludge water content
o The removal of water reduces the nitrogen content because much of the nitrogen appears as
ammonia (NH3+) and exists in the aqueous phase.
o The method of sludge application and sludge application equipment needed (e.g., type of
sludge application vehicle, need for incorporating the sludge into the soil, etc.), and the
methods available to transfer and store sludge depend in part on sludge water content
Treatment processes such as thickening, conditioning, dewatering, composting, and drying can
lower sludge water content and raise the percent solids.
Federal Regulations
There are no specific Federalregulations for sludge dewatering. The requirements for pathogen
control discussed previously dictate the degree of stabilization that is required.
State Requirements
Thirty one States require sludge stabilization prior to land application (see Table E6-5). Sixteen
States currently have regulations addressing sludge dewatering requirements for sludge that is to be
land applied. Alaska and Colorado have established minimum solids content percentages. These
are 10 and 16 percent, respectively.
o<
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Revised 12/1/89
Land Application of Sludges Containing Radionuclides
Case-by-Case Recommendations
In some areas of the country radionuclides in wastewater sludges has become an issue. Where
there is a significant level of radioactivity in POTW sludges, some simple requirements applied to
POTW wastes can reduce potential risks to public health and the environment
Any POTW that has a hospital or industry discharging wastes which contain radionuclides to its
system or is located in an area of the country that has naturally occurring radionuclides in drinking
or industrial source waters can expect to find radionuclides concentrating in wastewater sludges.
Fortunately most of the radionuclides used in hospitals have a short half-life, but this is not the
case with many naturally occurring radionuclides found in drinking water. The naturally occurring
radionuclides of concern are typically radium, uranium and radon. The half-life of some
radionuclides that have been identified in POTW sludges are shown in Table 6-2.
Because the sludges containing radionuclides are of concern in both landfilling and land
application, background soil information helps put the issues into perspective. The nationwide
average concentration of naturally occurring radionuclides radium-226, thorium-232 and uranium-
238 in soils are each about I pCi/g soil and virtually all State averages are less than 1.5 pCi/g soil
(EPA 1989b). Because the half-life of radium-226 is 1,620 years and the half life of thorium and
uranium isotopes are tens of thousands to billions of years, one cannot dismiss the importance of
these radionuclides where they are found in POTW sludges.
One way to obtain information regarding naturally occurring radionuclides is to check with the
States' water supply staff or obtain local community water supply information. If the water supply
has significantly less than the 3 pG/L which is the maximum contaminant level (MCL) for radium
(combined), then the permit may not need to address the contaminant If, on the other hand, the
radium level in water is a significant percentage of the MCL, then the permit writer should consider
putting specific conditions in the permit Another consideration is the concentration of
radionuclides received by the POTW from medical or industrial waste*which may also necessitate
specific permit conditions. For land application of sewage sludge containing radionuclides it is
recommended that the soil concentration of a particular radionuclide not be increased to a
significant amount above the background level of that radionuclide in the soil A sample
calculation using radium has been provided in Table 6-3.
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TABU 6-2
HALF-UFE OF RAOtONUCUOES
IDENTIFIED IN POTW SLUDGES
ISOttKM
Source
HatMjte
"'An
Smoke Alarm
Manufacturers
432 y
nil
Nuclear Medcine
8 04 d
»'Cr
Nuclear Medicine
278 d
"Se
Nuclear Medicme
120 d
99n«Tc
Nuclear Medicme
6 02 h
¦«Cs
Nuclear Fallout

*»Ra
Natural
1620 y
"«Ra
Natural
67y

Natural
49 x 10* y
SOURCE: EPA 1966b
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TABLE 8-3
SAMPLE CALCULATION
FOR SLUOOES THAT CONTAIN RADIUM
and J2fRa Concentration
Average Sludge Concentration
12 pCi/g
2 Sludge Application.
Typeal Example Sludge Application Rate (Nitrogen limited)
30,000 gaU acre
Typical Example % Solids
4 0%
Application Method
incorporation, i ft
3. Vearty Application Ra» of Radium:
- Application Rate * % Solids x Sludge Ra Concentration
- (30.000 gatfaere) * (i ft3/74a gal) * 62 4 ttvi * (1 kg/2.2 ib)
x (1000 ^1 kg) x (0 04) x (12 pCi/g)
¦ 54 * 10' pCi/yr
4 Weight of So*
1 acre-ft of sol weighs 1.639 X10® g
3 Maximum Increase Afcjwed m So*
The maximum concentration of radionuclides allowed m the sort should De
decided on a eaae-by-caae basa. Limits are set either as a maximum
concentration or as a maximum increase Guidance exists m Wisconsin,
Illinois, and EPA Office of Drinking Water
For purposes of Jus example only, the maximum increase allowed shall be
set at 0 1 pCtfg so*
6. Annual increase to Sol Radum:
» Radium Yearty Apcfecatxyi Rate / Weqht of Sod
- (3.4 * 10' pCifyr) / (1 #39 x to® g)
- 0 033 p&w ncrease
7 Number of Years Sludge Can be Apofaed at Raw
¦ Max. ncreeee of RA stowed m sari / Annual increase to Soi Ra
- (0.1 pc»w/(&033oC^yn
¦ 3-0 yeers
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Revised 12/1/89
EPA's Office of Drinking Water has developed draft guidance (September 1980) which is directed
towards the land application of drinking water sludges. Although this information was not
developed for wastewater sludge disposal or use, it may be useful in some instances. Permit
writers identifying a problem with radionuclides may want to consult this guidance.
State Requirements
Two States, Illinois and Wisconsin, have specific requirements for sewage sludges containing
radium. These requirements have been included in Table E7-11.
6.2.3 OPERATING CONDITIONS AND MANAGEMENT PRACTICES
This section addresses the operation conditions and management practices that are required and
recommended of those facilities that land apply their sludge. The conditions and practices are
categorized into the following eight groups: floodplains, surface water protection, ground-water
protection, endangered species protection, safety/access control, sludge application method and
storage.
Floodplains
Federal Regulations
Federalregulations (40 CFR Part 257.3-1) allow the location of land application sites in a
floodplain. However, these sites must not restrict the flow of the base flood, reduce the temporary
water storage capacity of the floodplain, or result in washout of solid waste, so as to pose a hazard
to human life, wildlife, or land or water resources. The base flood is defined as the 100-year
flood.
40 Part 257 requires that facilities or practices within the 100 year floodplain not "result in washout
of solid waste, so as to pose a hazard" to public health and the environment. EPA has determined
that this requirement should be satisfied if sludge applied to lands within the 100 year floodplain is
incorporated into the soil and vegetation is grown promptly (EPA 198Q).
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Revised 12/1/89
State Requirements
Twenty-seven States have regulations addressing land application of sludge in floodplains (see
Table E6-3). Nine States restrict application within the 100-year floodplain. Three of those States
indicate that application within the 100-year floodplain may be allowed if protective measures such
as diversion dikes are constructed. Eight States use the 10-year floodplain as the boundary within
which land application is prohibited. Two States allow application within the 10-year floodplain if
the sludge is injected or incorporated.
Surface Water Protection
Federal Regulations
Federalreguladons do not specifically address run-off controls for surface water protection.
However, 40 CFR Part 257.3-3 does state that a facility or practice shall not cause non-point
source pollution of waters of the United States that violate applicable legal requirements
implementing an area wide or Statewide water quality management plan that has been approved by
the Administrator under Section 208 of the Gean Water Act, as amended.
Federal Guidance
The EPA Technology Transfer publication Use and Disposal of Municipal Wastewater Sludge
(EPA 1984) recommends the use of good soil conservation practices and discourages application to
saturated, snow-covered, or frozen ground.
State Requirements
Thirty States have regulations or guidelines for run-off control (see Table E6-3). The types of
control measures include a minimum vegetative cover requirement or a requirement that the sludge
be incorporated, avoidance of application during rain or when soil moisture is high, limitation of
the quantity of sludge applied, and good soil conservation practices.
Two States relate run-off controls to particular storm events. Arizona references the 25-year, 24-
hour storm and Texas references the 10-year, 1-hour storm.
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Revised 12/1/89
Thirty-three Stales reported minimum allowable distances to surface waters (see Table E6-3). The
reported minimum setbacks from surface waters range from 25 to 3,000 feet and vary with the type
of surface water body and its use. For surface water bodies used for water supply, the required
setback is typically greater than 300 feet.
Case-by-Case Recommendations
Each facility should be designed to handle a defined storm event so as to minimize stormwater run-
off related problems. The permit writer should determine the design storm for a particular State. If
there is no State designated design storm, the 25-year, 24-hour storm is recommended.
Ground-Water Protection
Federal Regulations
Federal Regulations (40 CFR part 2513-4) require that land application facilities or practices not
contaminate an underground drinking water source or potential underground drinking water source
(any aquifer with less than 10,000 mgfl dissolved solids) beyond the outermost perimeter of the
solid waste boundary (projected in the horizontal plane) as it would exist at the end of disposal
activity. States may establish an alternate boundary if such a change would not contaminate
drinking water resources. Contamination of an underground drinking water source is defined in
40 CFR Part 257 as introducing a substance that would cause the maximum contaminant
concentration level specified in Appendix I of 40 CFR Part 257 to be exceeded, or that would
cause an increase in concentration of a contaminant that already exceeds the limit listed in Appendix
I of 40 CFR Part 257. 40 CFR Part 257 is presented in Appendix D of this document
State Requirements
Thirty-three States have rules addressing groundwater monitoring (see Table E6-4). Twenty of
these States indicate groundwater monitoring may be required in some cases. The criteria under
which monitoring would be required are generally not specified. However, some examples
include high seasonal groundwater levels, repeated applications at a single site, and application
rates in excess of the rate based on nitrogen uptake by crops. Thirteen States require groundwater
monitoring. Parameters measured include depth to water table, nitrates, metals, organics, pH, and
fecal coliform levels. Minnesota requires semiannual analyses.
mi
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Thirty-four States reported minimum allowable distances to wells (see Table E6-3). The distance
required varies with the use of the well. Land application sites must generally be 500 feet or more
from public water supply wells. The required setback from private water supply wells ranges from
100 to 500 feet
Thirty-five States reported minimum allowable depths to groundwater (see Tabic E6-3). The
minimum depths range typically from 1 to 10 feet, although Arizona requires that the mean annual
groundwater elevation be at least 40 feet below the surface. The lower end of the range in several
cases refers to the seasonal high water level. Illinois specifies a minimum depth of 10 feet for the
application of liquid sludge and 5 feet for the application of solid sludge and notes that permeability
is also a factor, and Texas allows a decrease in required depth from 4 to 3 feet if the soil has "slow
permeability."
Nine States reported minimum allowable depths to bedrock (see Table E6-3). The allowable depths
range from 20 inches to six feet.
Endangered Species
Federal Regulations
Land applicadon facilities or practices shall not cause or contribute to the taking of any endangered
or threatened species of plants, fish, or wildlife. In addition, the facilities or practices must not
result in the destruction or adverse modification of the critical habitat of a Federally-listed
endangered or threatened species (40 CFR Part 257.3-2).
State Requirements
No States were identified as having specific regulations or guidelines addressing endangered
species.
Safety/Access Control
Federal Regulations
Owners and operators of land application sites are required by 40 CFR Part 257.3-8 to limit
exposure of the public to any potential health and safety hazards. For sites where sludge has been
102
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Revised 12/1/89
treated by a process to significantly reduce pathogens, public access must be controlled for at least
12 months after sludge application, and grazing by animals whose products are consumed by
humans must be prevented for at least one month (40 CFR Part 257.3-6).
If crops for direct human consumption are to be grown within 18 months subsequent to sludge
application or incorporation, the sludge must be treated with a process to further reduce pathogens
(PFRP). These processes are listed in 40 CFR Part 257 Appendix II and Section 2.0 of this
document If the sludge will not contact the edible portions of the crop, pathogen reduction to
PSRP levels is acceptable (40 CFR Part 257). 40 CFR Part 257.3-8 requires that a facility or
practice within 10,000 feet and 5,000 feet of airport runways for turbojet and piston-type aircraft,
respectively, shall not pose a bird hazard to aircraft
Federal Guidance
The extent of access control needed to limit exposure to a land application site should be based on
these site-specific considerations: 1) the degree to which the sludge has been treated to reduce
pathogens, (2) the procedures used to apply and incorporate the sludge into the soil, (3) the
remoteness of the sludge application site from public use areas, and (4) the ownership of the site
area, whether private or public. In general, if there is potential for exposure of the public to health
or safety hazards, some sort of positive access control must be implemented, the exact means
dependent on those considerations listed above (EPA 1983).
State Requirements
Thirty-five States have requirements for access control and/or grazing restrictions (see Table E6-5).
The most common practice is the same as the Federalrequirement to control public access for at
least 12 months after sludge application. Twenty-one States have buffer zone requirements (see
Table E6-3). Six States reported minimum allowable distances to roads, ranging from 15 to 300
feet Twelve States reported minimum allowable distances to property lines, ranging from 25 to
500 feet The required distance is typically less for subsurface sludge application than for sludges
applied to the surface. The most frequently cited setback from property lines was 50 feet
The setbacks that States require from dwellings varies with the type of application and the density
or perceived sensitivity of nearby developments. The most commonly recommended setbacks
range from 250 to 500 feet. If the sludge is injected or incorporated, the required setback is
typically between 50 and 250 feet Setback requirements are generally greater near schools.
103
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institutions, recreational areas, or residential subdivisions. These setbacks range from 600 to
1,000 feet
Air Quality Control
State Requirements
Only three States have regulations or guidelines addressing maintenance of air quality and odor
control. Rhode Island, Washington, and Wisconsin reported rules requiring odor controls, but
methods for odor control were not specified.
Soil Characteristics
Soil characteristics can have a direct affect on both surface and ground-water. Soil characteristics
of concern for a land application site include soil permeability, soil pH, and soil cation exchange
capacity. Soil cation exchange capacity is an indirect measure of the soil's ability to capture
positive ions, the form in which most metals are found in the soil. High soil pH immobilizes most
metals and reduces their absorption by plants. However, it has not been demonstrated that pH
control is necessary on forested sites where soils are naturally acid (EPA, 1986a). Permeability
refers to the ease with which water is transmitted through soil. Soils with very low permeability
are poor candidates for land application due to ponding, potential for run-off problems, and
subsequent limitations in allowable loading rate. Soils with very high permeability are also ill-
suited to land application where leaching to the groundwater aquifers is a concern.
Federal Regulations
The only Federalregulation with regard to soil characteristics is the allowance of cumulative
cadmium application rates over 5 kg/ha on food-chain croplands in cases where the background
soil pH is greater than 6.5 and the soil cation exchange capacity is S meq/100 g or greater. If the
background soil pH is less than 6.5, the maximum allowable cumulative cadmium application rate
can still be greater than 5 kg/ha provided that the pH of the soil and sludge mixture is adjusted and
maintained at 6.5 or greater, or if the only food-chain crop produced is used solely for animal feed
and other requirements are met (See Appendix D).
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Revised 12/1/89
Federal Guidance
The Process Design Manual for Land Application (EPA 1983) contains the following guidelines
for the permeability of the most restricting soil layer above a 1-meter depth and its associated
degree of limitation for agricultural sludge application:
Soil permiability characteristics alone do not limit sludge utilization feasibility. This is important in
combination with other site conditions including slope, depth to groundwater, and rainfall patterns.
State Requirements
Only four States have specific numerical criteria for soil permeability (see Table E6-3). Minnesota
does not allow land application at sites where the permeability is less than 0.2 inches/hr (0.S cm/hr)
or greater than 6 inches/hr (IS cm/hr) throughout the top five feet of soil. Kentucky does not allow
land application where the permeability is less than 0.2 inches/hr (0.5 cm/hr) or greater than 20
inches/hr (51 cm/hr). Vermont and Wisconsin do not allow land application where the soil
permeability is greater than 6 inches/hr (15 cm/hr). Several States have requirements for a
minimum depth of permeable soil or the texture of the soils present at the site. In general, these
States require 2 feet of permeable soil. Texture requirements range from sandy loam to silty clay.
Twenty-five States have pH regulations (see Table E6-5). The most common requirement is that
the pH of the soil or sludge/soil mixture be at least 6.5. Four States specify that the pH must be
maintained at 6.5 or greater for a period of time after application (typically two years).
Permeability
<0.08
0.08 - 0.24
0.24 - 0.8
0.8 - 2.4
>2.4
Degree of Limitation
Severe
Moderate
Slight
Moderate
Severe
Topography
Topography influences surface and subsurface water movement, which in turn affect the soil
erosion and potential run-off of applied sludge. Topography can indicate the kinds of soil to be
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Revised 12/1/89
found on a site. Soils on ridge tops and steep slopes are typically well drained, well aerated, and
usually shallow. Steep slopes increase the possibility of surface run-off of sludge unless very
permeable soils are present Soils on broad flat lands frequently are poorly drained, and may be
waterlogged during pan of the year. The soils between these two extremes will usually have
intermediate properties with respect to drainage and run-off.
Federal Guidance
To protect surface waters, permit writers should require that the recommended slope limitations in
EPA's Land Application Manual, or similarly protective State or local guidelines, be followed
Table 6-4 presents those recommendations.
State Requirements
A review of State regulations indicates the same general slope limitations as presented in Table 6-4
(see Table E6-3). Thirty-six States have regulations/guidelines regarding the slopes allowable for
sludge application sites. The typical requirement is a maximum allowable slope ranging from 5 to
15 percent The maximum allowable slope typically is higher if the sludge is incorporated into the
soil or if "solid" or "cake" sludge is used rather than liquid sludge.
Sludge Application Methods and Seasonal Restrictions
State Requirements
A few States have specific provisions for sludge application methods. Michigan requires sound
agricultural practices (e.g. avoid soil compaction). New Jersey requires uniform applications for
land application. South Dakota specifies that the sludge application vehicles should have deflection
plates. West Virginia requires the equipment to have high flotation tires for land application.
Twenty-one States have requirements addressing incorporation of the applied sludge (see Table
E6-5). Four States specify incorporation if the PCB content of the sludge is greater than 10 ppm.
Five States require incorporation within 48 hours. Oklahoma requires incorporation at the time of
application.
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TABLE 6-4
RECOMMENDED SLOPE LIMITATIONS FOR LAND
APPLICATION SLUDGE
Slope
Comment
0-3%
Ideal; no concern for run-off or erosion of
liquid sludge or dewatercd sludge
3-6%
Acceptable; slight risk of erosion; surface
application of liquid sludge or dewatered sludge
okay.
6-12%
Injection of liquid sludge required for general
cases, except it closed drainage basin and/or
extensive run-off control. Surface application
of dewatered sludge is usually acceptable
12-15%
No liquid sludge application without effective
run-off control; surface application of
dewatered sludge acceptable, but
incorporation recommended
>15%
Slopes greater than 15% are only suitable for
sites with good permeability where the slope
length is short and is a minor pan of the total
application area.
Source: EPA 1983
Twenty-eight States have seasonal limits on land application of sludge (see Table E6-5). In
general, these regulations prohibit application during rainfall, on ground, or on ice/snow-
covered ground. Application to frozen or snow-covered ground is allowed in some States at sites
meeting certain slope restrictions. These restrictions usually require slopes less than 2 to 6 percent
i m
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Revised 12/1/89
Case-by-Case Recommendations
Sludge should not be applied during periods of inclement weather. In some States, sludge should
not be applied to soils that are frozen or covered with snow (see Table E6-5). Soil moisture is a
major consideration which impacts the timing of sludge application. Traffic on wet soils during or
immediately following heavy rainfalls may result in compaction and, in the case of agriculture,
reduced crop yields. Muddy soils also make vehicle operation difficult Application to frozen or
snow-covered ground with greater than 3 percent slope may result in excessive run-off into
adjacent streams.
Storage facilities are needed to hold sludge during periods of inclement weather, equipment
breakdown, frozen or snow-covered ground, or when access would damage the field or crop.
Federal Guidance
The volume of storage required may range from the equivalent of 15 days production in climates
where weather rarely prevents sludge application to 160 days in cold, damp climaies where sludge
application may be impossible over much of the year (EPA 1984). A very conservative design for
storage capacity is for 1 year's production (EPA 1983).
State Requirements
Three States have regulations regarding sludge storage needs. Indiana and Missouri require a
minimum 90-day and 30-day storage capacity respectively. Michigan limits field storage to less
than 7-days unless the sludge is covered and a seepage barrier provided.
6.2.4 MONITORING, REPORTING, AND RECORD KEEPING
This section discusses compliance and environmental monitoring requirements, repotting and
recordkeeping for land application sites. Elements of the land application system that may require
monitoring through the life of the project include the quality of the applied sludge, the soil, the
crop, groundwater, and surface water.
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Revised 12/1/89
Sludge Monitoring
Federal Regulations
The current regulations require sludge monitoring and reporting at a frequency dependent upon the
nature and effect of the permittee's sludge use or disposal activities, but at least once a year for
every pollutant limited in the permit. This means that if the permit contains a limit for PCB's for
example, the permittee must monitor its sludge at least annually for this pollutant <40 CFR Pan
122.44(c)(2)). Also a minimum of annual monitoring is obviously necessary to demonstrate
compliance with the 40 CFR Part 2S7 contaminant regulations for cadmium, PCBs, and
pathogens.
Federal Guidance
Regular sludge quality analyses are necessary to ensure that unacceptable quantities of sludge
constituents are not applied to the site. The frequency of sludge sampling will be a function of:
o System size - A larger system should sample more frequently.
o Historical variations in sludge characteristics - The greater the variability that has been found
in sludge physical and/or chemical characteristics, the more often the sludge should be
analyzed. Where no historical data exist, monitoring should be more frequent to build a
database.
o Land application option being used • Dedicated land disposal sites may require the same
frequency of monitoring as landfills. Land reclamation, forest application, and agricultural
application sites generally require intermittent monitoring (EPA 1983). The quality of
sludges applied to food-chain croplands should be frequently monitored.
o The industries discharging to the POTW.
o Problems and/or compliance history of the POTW.
Sludge should be analyzed periodically for pH, percent solids, nitrogen, phosphorus, potassium,
heavy metals, and any other contaminants listed in the facility permit. If die system used is
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Revised 12/1/89
sensitive to pathogens and/or priority orgastics, these parameters should also be measured (EPA
1983).
The Sewage Sludge Interim Strategyrecommends annual monitoring of the 126 priority pollutants
as well as nunc frequent monitoring of the pollutants for which numeric limits have been proposed
in the 40 CFR Part 503 Technical Sludge Standards. For the disposal practice of land application
these pollutants include:
Aldrin/dieldrin
Benzo (a) pyrene
Cadmium
Chlordane
Copper
DDT/DDE/DDD (total)
Heptachlorobenzene
Hexachlotobuiadiene
State Requirements
Thirty-six States have regulations addressing sludge monitoring. These regulations are
summarized in Table E6-4 (summary of State monitoring and reporting requirements). The
parameters typically monitored include:
o Percent solids
o pH
o Nutrients - nitrogen, phosphorus, potassium
o Metals - arsenic, cadmium, chromium, copper, lead, mercury, nickel, selenium, zinc
0 PCBs.
Other parameters monitored by some States are conductivity, benzene, and EP toxicity. The
frequency of sludge sampling is often related to the size of the treatment facility. In Kentucky, for
example, facilities less than 1 tngd in size are only required to sample annually. Facilities between
1 and 2 mgd must sample semi-annually. Facilities between 2 and lOmgd are required to sample
1 DDT-2,2-Bis(chlorophenyl)-1,1,1 -trichloroethane
DDE-1,1 -Bis(chlorophenyl>2,2-dichloroethene
DDD-1, l-Bis(chlorophenyl)-2,2-dichloroethane
Lead
Lindane
Mercury
Nickel
Polychlorinated biphenyls
Selenium
Toxaphene
Zinc
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Revised 12/1/89
quarterly. Facilities greater than 10 mgd are required to sample monthly. Three States require
sampling and analysis prior to each application of sludge. The testing and monitoring program for
sludges applied to land as part of Madison, Wisconsin's METROGRO operation and Salem,
Oregon's BIOGRO operation are summarized in Table 6-5. In both of these programs, digested
sludge is applied to privately-owned farmland.
Case-by-Case Recommendations
If a particular pollutant, such as radionuclides, is a concern, consideration should be given to more
frequent monitoring of the sludge for that pollutant Sludges applied to lands used for producing
food-chain crops should be monitored more frequently than is generally recommended in other
land application processes. The pH of the sludge-soil mixture should be measured each time
sludge is applied to food-chain croplands and whenever food-chain crops are grown. Once,
during the first year of the permit, the soil cation exchange capacity of food-chain croplands where
sludge is applied should be measured.
Soil Monitoring
Federal Regulations
There are no Federalregulations addressing soil monitoring at land application sites.
Federal Guidance
The need for soil monitoring depends on the site characteristics and the particular land application
option being used. In general, monitoring requirements for dedicated land disposal sites are more
extensive than for other land application options.
The major parameters of concern for agricultural land application are pH maintenance at 6.5
standard units or greater to reduce potential metal migration; cation exchange capacity (CEQ, and
soil nitrogen, phosphorus an4 potassium if optimum crop yields are ^project goal. If sludge is
applied at or below agronomic rates, EPA recommends analyses of the soil for pH every year
sludge is applied and for cation exchange capacity once during the life of die permit and every 2
years for other parameters (EPA 1983).
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TABLE 6-5
SLUDGE MONITORING PROGRAMS FOR TWO
AGRICULTURAL LAND APPLICATIONS
Constituent Measured
Frequency
Madison, WI
Salem, OR
Total Solids
Daily
Monthly
Dissolved Solids
—
Quarterly
Conductivity
Monthly
—
Total Nitrogen
Daily
Monthly
Ammonia Nitrogen
Daily
Monthly
Total Phosphorus
Bi-monthly
Monthly
Total Potassium
Bi-monthly
Monthly
pH
Bi-monthly
Quarterly
Total Sulfur
Semiannual
...
PCB
Bi-monthly
—
Aluminum
Semiannual

Arsenic
Bi-monthly
Quarterly
Boron
Semiannual
Quarterly
Cadmium
Bi-monthly
Monthly
Calcium
Semiannual

Copper
Bi-monthly
Monthly
Cobalt
Semiannual
—
Chromium
Bi-monthly
Quarterly
Iron
Semiannual
Quarterly
Lead
Bi-monthly
Quarterly
Lithium
Semiannual

Manganese
Semiannual
Quarterly
Magnesium
Semiannual
Quarterly
Mercury
Bi-monthly
Quarterly
Molybdenum
Bi-monthly
Quarterly
Nickel
Bi-monthly
Monthly
Selenium
Bi-monthly
Quarterly
Strontium
Semiannual
—
Zinc
Bi-monthly
Monthly
Priority Pollutant Scan
Annual
Monthly
Aldrin/Dieldrin
Bi-monthly
Benzene
Bi-monthly
—
Benzidine
Bi-monthly
—
Benzo(a)pyrene
Bi-monthly
—
Benzo(a)anthrecene
Bi-monthly
—
Bis(2-ethylhexyl)pthalate
Bi-monthly
—
Carbon Tetrachloride
Bi-monthly
—
Chlondate
Bi-monthly
---
Chloroform
Bi-monthly
—
Cyanide
Bi-monthly
—
3,3-Dichlorobenzidine
Bi-monthly
—
Dichloromethane -
Bi-monthly
—
2,4-Dichlorophenoxy Acetic Acid
Bi-monthly
—
112
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Revised 12/1/89
Constituent Measured
Frequency
Madison, WI
Salem, OR
Dimethyl Nitrosamine
Endrin
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Lindane
Malathion
Pentachlorophenol
Phenanthrene
Phenol
Tetrachloroethylene
Trichloroethylene
Toxaphene
2,4,6-Trichlorophenol
Vinyl Chloride
VSS Reduction
Fecal Coliform
Salmonella
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Bi-monthly
Source: EPA 1983, METROGRO 1989
113
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Soil constituents of interest in forest application systems include pH, metals, and nutrients. Forest
soils are typically more acidic than agricultural sites; soil pH values of 5.5 and lower are common.
Experience with sludge applications to forest soils in established forests indicates that the increased
metals available due to lower soil pH do not cause phytotoxicity in most forest plant species. In
addition, because forest products are not food chain crops, increased metal content of the plants
themselves is not a concern for public health. For these reasons, lower pH limits can be allowed
with forest application, if there is no danger of trace metal migration to useful aquifers (EPA
1983).
The Process Design Manual for Land Application of Municipal Sludge (EPA 1983) contains a
suggested minimal monitoring program for land reclamation sites. Elements of this program for
soils include:
o Collection of samples prior to sludge application. Samples of topsoil should be rellected
throughout the site and analyzed for buffer pH to determine lime requirements to raise the soil
pH to 6.5 and to determine the CEC. Samples from the complete soil profile should be
collected at depths from 0 to 6 inches, 6 to 12 inches, 12 to 24 inches, and 24 to 36 inches.
o Samples should be collected again one year following sludge application. These samples
should be taken at depths of 0 to 6 inches, 6 to 12 inches, and 12 to 24 inches.
Samples collected prior to application and 1 year following application should be analyzed for pH,
phosphorus, calcium, magnesium, potassium, sodium, iron, aluminum, manganese, copper, zinc,
chromium, cobalt, lead, cadmium, nickel, and Kjeldahl nitrogea At die end of the second year
after sludge application, surface soil samples should be collected and analyzed for pH to determine
if it is still at 6.5.
State Requirements
Twenty-three States have soil sampling/monitoring requirements for land application (see Table
E6-4). Generally, the States require pre-application soil sampling aixKbllow-up sampling after
application. The frequency of follow-up sampling varies. Three States require annual monitoring.
The parameters measured include pH, CEC, nutrients, metals, conductivity, PCBs, and organic
matter content Table 6-6 summarizes the soil analyses and sampling frequency for agricultural
land application operations in Madison, Wisconsin and Salem, Oregon.
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TABLE 0-6
SOIL MOMTORINQ PROGRAMS FOR TWO AGRICULTURAL LANO APPLICATION OPERATIONS
Monitoring Frequency
Soil-Plow Layer Soil-Subsori Layer
Constituent
Salem. OR
Madison, wi
Salem, OR
Madison. Wl
Alumnum
Pnor to applcation
-
Pnor to application
-
Boron
Prior to application
-
Pnor to application
-
Cadmum
Prior to application
-
Pnor to application
Every three years
Caioum
Pnor to application
-
Pnor to application
-
CEC
Pnor to application
One time
Pnor to application
-
Ctinxraum
-
-
-
Every three years
Conductivity
Pnor to application
-
Pnor to application
-
Copper
Pnor to application
-
Pnor to application
Every three years
Iron
Pnor to applcation
-
Pnor to application
-
Lead
Pnor to application
-
-
Every three years
Magneswm
-
-
Pnor to application
-
Manganese
Pnor to application
-
Pnor to application
-
Mercury
Pnor to application
-
Pnor to applcation
-
Motybdenium
Pnor to application
-
Pnor to application
-
Nickel
Pnor to application
-
Pnor to application
Every three years
Organic Matter
Annually dunng application
Every three years
-
-
pH
Annually dunng application
Every three years
-
-
Phosphorous: Available
Annually dunng application
-
-
-
Phosphorous: Total
-
Every three years
-
-
Potasaum: Available
Annually durmg application
-
-
-
Potasauta- Total
-
Every three years
-
-
Sodwn
Pnor to applcaoon
-
-
-
Zinc

Every three years
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Revised 12/1/89
Three States have separate requirements for soil monitoring at land reclamation sites. Arkansas
requires monitoring prior to application and then annually following application. In Illinois, the
monitoring program is proposed by the applicant at the time he seeks a permit for sludge disposal
at a land reclamation site. New Jersey requires soil monitoring.
Vegetation Monitoring
Vegetation monitoring is usually only necessary if heavy sludge application rates are used, as with
a dedicated disposal site, and there is concern that food chain vegetation being grown on the site
may be accumulating potentially harmful quantities of heavy metals, particularly cadmium, from
the sludge amended soil.
Federal Regulations
There are no Federalregulations addressing vegetation monitoring at land application sites.
Federal Guidance
Generally, if sludge is applied at low agronomic rates there is little need to sample and analyze the
vegetation. Table 6-7 contains a list of potential crop monitoring parameters fa* agricultural crops
(EPA 1983). Actual parameters monitored may vary from this list, depending on the sludge
constituents of concern.
State Requirements
Ten States have regulations addressing crop monitoring and plant tissue sampling and analysis (see
Table E6-4). Illinois and Maine indicate analyses may be required for some sites. Idaho requires
biennial analyses for metals.
116
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Revised 12/1/89
TABLE 6-7
POTENTIAL CROP MONITORING PARAMETERS
A. Heavy Metals
B. Macronutrients (optional)
Cadmium
Copper
Molybdenum
Nickel
Zinc
C. Other elements or Constituents*
Nitrogen
Phosphorus
Potassium
Antimony
Arsenic
Chromium
Iron
Manganese
Mercury
Selenium
PCB's
* The other constituents listed under C are analyzed only if there are significant quantities of those
contained in the sludge being applied, and the crop may enter the food chain.
Source: EPA 1983
Ground-Water Monitoring
Ground-water monitoring may be required to ensure that an application site is not contaminating
ground-water aquifers in the sludge application or sludge storage area. The constituents monitored
in a ground-water monitoring program depend on the goals of the program. Ground-water
monitoring is often required for dedicated land disposal sites. It may be required for forest
application or land reclamation sites over vulnerable aquifers. Ground-water vulnerability is
dependent on geologic and hydrologic factors including precipitation, depth to ground-water,
117
-------
Revised 12/1/89
physical and other characteristics of geologic material soils, etc. The permit writer may want to
consult a qualified geologist or hydrogeologist to evaluate ground-water vulnerability. Ground-
water monitoring is generally not required for agricultural projects if the sludge application rate is
limited by crop nutrient requirements. Ground-water monitoring programs to prevent
contamination of water supplies should include monitoring of indicator parameters (See Federal
Guidance below, and Appendix C of The Land Application Manual (EPA 1983), and The
Procedures Manual for Ground-Water Monitoring at Solid Waste Disposal Facilities (EPA
1977b)). If high concentrations of certain heavy metals, toxic chemicals, or fecal bacteria are
present in the sludge, they should be included in the ground-water monitoring program.
Federal Regulations
40 CFR Part 257 requires that sludge application not contaminate underground drinking water
sources (any aquifer with less than 10,000 mg/1 dissolved solids) with contaminants in
concentrations equal to or greater than the levels specified in Appendix I (40 CFR Pan 257).
Contamination is measured at the boundary of the application area as it would exist when the solid
waste disposal activity (sludge application) ceases, however, an alternate boundary can be set
which consider, among other factors, the natural attenuation and dilution characteristics of the
aquifer and the proximity and withdrawal rates of ground-water users (See Appendix D).
Federal Guidance
The following is a list of parameters generally included in a ground-water monitoring program
(EPA 1983):
o pH
o Electrical conductivity and/or TDS
o Total hanfaess
o Alkalinity
o Chlorides
o Sulfates
o Total organic carbons
o Nitrate-nitrogen
o Total phosphorus
o Methylene blue active substances (surfactants)
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Revised 12/1/89
o Selected metals or toxic organic substances
o Indicator microorganisms
State Requirements
Thirty-four States have rules addressing ground-water monitoring (see Table E6-4). Thirty-three
States require ground-water monitoring in some cases. Parameters measured include depth to
water table, nitrates, metals, organics, pH, and fecal coliform bacteria. Sampling frequency is
variable, with one State requiring semiannual analyses and another quarterly analyses. Twelve
States set ground-water monitoring requirements on a case-by-case basis. High seasonal ground-
water levels, repeated sludge applications at a single site, and application rates in excess of the rate
based on nitrogen uptake by crops are considered grounds for requiring ground-water monitoring.
The Madison, Wisconsin and Salem, Oregon land application programs require ground-water
monitoring prior to application and at three and five year intervals after application. The parameters
measured prior to application at Madison include dissolved solids, nitrates, total coliform, chloride,
and zinc. Follow-up analyses were conducted for dissolved solids and nitrates. At Salem, the
parameters measured prior to application and at 3 and 5 year intervals after application include
dissolved solids, nitrates, total coliforms, arsenic, and mercury.
Case-by-Case Recommendations
When a ground-water monitoring condition is written, permit writers should require the use of
Appendix C of the Process Design Manual for Land Application of Municipal Wastewater RliiHyf.
(EPA 1983) and the Procedures Manual for Ground-Water Monitoring at Solid Waste Disposal
Easiliiifis (EPA 1977b), or similarly protective guidelines, to design and operate ground-water
monitoring systems. Using lysimeters to detect leachate in the unsaturated zone above an aquifer
can provide early warning of potential future ground-water contamination.
Surface Water Monitoring
Federal Regulations
Federal regulations do not specifically address surface water monitoring. However, 40 CFR Pan
237.3-3 does state that a facility or practice shall not cause non-point source pollution of waters of
the United States that violates applicable legal requirements implementing an area wide or Statewide
-------
Revised 12/1/89
water quality management plan that has been approved by the Administrator under Section 208 of
the Gean Water Act, as amended.
Federal Guidance
Properly designed land application sites should be located, constructed, and operated to minimize
the chance of surface water run-off containing sludge constituents. For agricultural sites where
sludge is applied at agronomic rates, surface water monitoring is typically not required. Generally,
surface water monitoring should be considered in the following situations (EPA 1983):
o Surface water run-off from the site is collected, stored, and discharged to surface waters
outside the application area under an NPDES permit
o The sludge application site is in close proximity to surface waters that are sensitive (e.g.,
drinking water supplies, swimming areas, etc.), and monitoring is required to ensure that
migration of sludge constituents to these surface waters does not occur.
o It is desirable to alleviate community concern about surface water quality impacts.
Generally, the parameters of concern in a surface water monitoring program are those that may
affect public health, or those that may contribute to eutrophication, e.g., nitrogen and phosphorus.
An illustration of parameters that are often analyzed in surface water samples taken in connection
with sludge application site(s) monitoring is shown in the following list (EPA 1983):
o Fecal coliforms
o Total P
o Total N (Kjddahl)
o Dissolved oxygen
o BODorTOC
o Temperature
o pH
o Suspended solids
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Revised 1271/89
State Requirements
Twenty States have regulations addressing surface water monitoring (see Table E6-4). Six States
require monitoring on a case-by-case basis. Idaho requires baseline monitoring and follow-up
monitoring during the life of the project for nitrogen, metals, organics, pH, and fecal coliform
bacteria.
Reporting and Record Keeping
Federal Regulations
The recently promulgated revisions to the NPDES Permitting regulations (54 FR 18716) require
that the permit contain a requirement that the permittee report monitoring results with a frequency
dependent upon the nature and effect of the sewage sludge use or disposal practice but in no case
less than once a year (40 CFR Pan 122.44(i)(2). The regulations also require that records
pertaining to the POTWs sludge use and disposal activities (as set forth in 40 CFR Part 501.15
(2)(2)) be retained for 5 years (40 CFR Part 122.2l(p)).
Federal Guidance
Operational and monitoring data may be required by local, State, or Federal Agencies
Consequently, any municipality implementing a sludge application system should develop an
adequate record keeping program.
Management and reporting activities may include equipment use and maintenance recoids,
performance records, required regulatory reports, cost records, and public relations activities (e.g.,
complaints). These records can also be used as the basis for scheduling future site inspections and
evaluating the efficiency of operations.
Records on the sludge application portion of the program should contain at least the following:
o Sludge characteristics and amounts applied to specific locations,
o Major operational problems, complaints, or difficulties.
-------
Revised 12/1/89
o Qualitative and/or quantitative data related to the selection and operation of the land
application site, including monitoring data on ground and surface water, soils, and crops.
State Requirements
Thirty States have reporting/record keeping requirements (see Table E6-4). These States may
require the POTW to keep records of one or more of the following: the amount and quality of
sludge applied, the location at which the sludge is applied, the use of harvested crops, the amount
of lime or fertilizer required, and the results of all environmental monitoring analyses. The
required reporting frequency varies from monthly to quarterly, semi-annually, or annually. Three
States require deed records for land application sites. Kentucky requires a deed record regarding
cadmium application. Massachusetts requires a deed notice for land application sites receiving
sludge/seepage classified as type II or in under the State's sludge classification system.
Mississippi requires a deed record of the amount of PCBs and cadmium applied.
6.3 ADDITIONAL REQUIREMENTS AND GUIDANCE FOR AGRTCIILTI m at . t .a wn
APPLICATION
6.3.1 PERMITTING RESPONSIBILITIES
Unless a condition prohibits sludge application to lands used for producing food-chain crops, the
permit must state that the POTW will comply with the requirements of 40 CFR Pan 257.3-5 (See
Table 6-8). Briefly, these regulations set annual and cumulative loading limits for cadmium and
management practices (primarily, adjustment of the sludge-soil mixture as needed to attain pH 6.5
or greater at the time of sludge application and whenever food-chain crops are grown). The
regulations also require that sludges containing PCBs at levels equal to or greater than 10 mg/kg
(dry weight) be incorporated into the soil when applied to land used for producing animal feed,
including pasture crops for animals raised for milk. If the POTW can assure that PCB
concentrations in animal feed or milk are low, incorporation is not required.
Provided special restrictions are followed, 40 CFR Part 257.3-5 allows for cadmium applications
to exceed the generally required rates. However, these restrictions include pH maintenance, the
development of a facility operation plan which demonstrates how the animal feed (if grown) will be
distributed to preclude ingestion by humans and a stipulation in the land record or property deed
stating that food-chain crops should not be grown on the land. These kinds of restrictions
-------
TABLE**
40 CFR PART 237 3-5 CONTAMINANT LIMITS FOR SLUOQE
USED ON FOOO-CHAIN CROPLANDS
Cadmium
a The pH of the sludge and soil mixture must be greater
than 6 3 at me tune o' sludge application unless the
sludge contains leu than 2 mg/kg (dry weight) cadmium.
t>. The annual applcation of cadmium from sludge must not
exceed 0.3 kgfta for tobacco and food-cham crops,
c The cumulative application of cadmium from sludge must
not exceed tv following values wtrcft depend upon the
caoon exchange capacity (CEC) and background pH of
the sal;
'The cumulative application rates for toils with a
background pH equal to or qr««t«r than 6 5 may be
uwd if the pH of the solid waste and soS mixture Is adjusted to
and maintained at 6 S or greater whenever food-chain
crops are grown
d if animal feed is the only food-chain crop produced,
there is no limit to the cadmium application rate, as
long as the pH of sludge and toil mixture is 6 5 or
greater at the time of tludge application or at the
time the crop is planted, whichever occurs later, and
this pH level is maintained whenever food-chain crops
a re grown A plan must also be developed which
demonstrates how the animal feed will be distributed
to preclude human ingestion, and the measures to be
taken to safeguard against possible health hazards
from cadmium entering the food chain, which may
result from alternative land uses Future property
owners must alio be notified by a stipulation m the
land record or property deed which ttates that the
property received sludge at high cadmium application
rates and that food-chain crops, excapt for animal
feed, should not be grown due to possible health
hazards.
Sludge containing concentrations of PCBs equal or greater
than 10 mg/kg (dry weight) must be incorporated into the
soil when applied to land used for producing animal feed,
including pasture crops for animals raised for milk.
Incorporation is not required if it can be assured that the
PCB content is less than 0 2 mg/kg (actual weight) in animal
f««d or lea than 1 S mg/kg (fat basis) m milk (Sludge
containing more than $0 mg/kg PCBs must be disposed of
m a chemical waste landfill or incinerated under special
conditions (sae 40 CFR 761 Subpart 0 for PCB disposal
requirements).
' Tho cOwr conaatuents iistad under C art analysed only if —
agnfeant quannee of those contained m me oemg apphod
and crop may enter the load chaw
Source EPA 19*3.
CEC
pH megnOO g
£6 5 <5
5-15
>15
<65*
Maximum Cumulative Application
kgma
5
10
20
5
PCBs
-------
Revised 12/1/89
generally make high rate cadmium applications appropriate only in a dedicated land disposal setting
(EPA 1983).
If the permit writer incorporates conditions (discussed in the recommendations section below)
requiring that sludges be applied at agronomic rates (e.g., at a rate that will supply only as much
available nitrogen as the particular crop grown on an application site can assimilate), and
implementing the depth to ground-water and seasonal limit recommendations, the ground-water
provisions of 40 CFR Part 257.3-4 should be satisfied. When sludge is applied at agronomic rates
in agricultural settings, the access control provisions of 40 CFR Pan 257.3-8 should be satisfied
without writing a permit condition requiring fences or signs.
6.3.2 TECHNOLOGY
Methods of sludge application on agricultural land are dependent on the physical characteristics of
the sludge and soil and the crops grown. Liquid sludges can be applied by surface spreading or
subsurface injection. Surface application methods include spreading by farm tractors, tank
wagons, special applicator vehicles equipped with flotation tires, tank trucks, portable or fixed
irrigation systems, and ridge and furrow irrigation.
Surface application of liquid sludge is normally limited to sites with less than 6 percent slopes.
Surface application of liquid sludge is normally practiced when forage crops are grown. After
sludge has been applied to the soil surface and allowed to partially dry, it is commonly
incorporated by plowing or disking prior to planting the crop (i.e., coin, soybeans, small grains,
cotton, other row crops). Ridge and furrow irrigation systems can be designed to apply sludge
during the crop growing season but it is difficult to provide even distribution. Spray irrigation
systems generally should not be used to apply sludge to forage or row crops during the growing
season unless proper management is provided (e.g., application to recently harvested hay fields,
subsequent irrigation with fresh water) since the adherence of sludge to plant vegetation can reduce
photosynthesis and have a detrimental effect on crop yields. In addition, spray irrigation tends to
increase the potential for odor problems. Surface application of liquid sludge by tank trucks and
applicator vehicles is the most common method for agricultural croplands.
Liquid sludges can also be injected below the soil surface. Available equipment includes tractor-
drawn tank wagons with injection shanks (originally developed for liquid animal wastes) and tank
trucks fitted with flotation tires and injection shanks (developed for sludge application). Both
types of equipment minimize any odor problems and reduce ammonia volatilization by immediate
-------
Revised 12/1/89
mixing of soil and sludge. Sludge can be injected either before planting or after harvesting all
crops except forage crops that are cut and baled. Because some injection shanks can either ruin the
forage stand or create deep ruts in the field, specialized equipment should be used to inject sludge
into forage crop fields.
Dewatered sludges are applied to cropland by handling equipment similar to that used for applying
animal manures, limestone, or solid fertilizers. Typically, the dewatered sludge will be surface-
applied and then incorporated by plowing or disking. Incorporation is not generally used when
dewatered sludges are applied to forage crops.
6.3.3 CHARACTERISTICS OF SLUDGE SUITABLE FOR AGRICULTURAL LAND
APPLICATION
The constituents of a sludge have a direct bearing on the options available for sludge use and
disposal. For agricultural land application, the most important constituents are nutrients,
pathogens, metals, and certain toxic organic chemicals. The form and the concentration of the
nutrients nitrogen, phosphorus, and potassium in the sludge affect the fertilizer value of the sludge
for agricultural land application. The amount of available nitrogen in excess of plant requirements
is of concern for potential nitrate contamination of groundwater. Pathogen reduction is required
prior to agricultural land application to prevent potential human health problems. High metal
concentrations are of concern in agricultural land application because of their potential to
crops, and to enter the food chain. Certain toxic organic chemicals are of concern due to their
potential to enter the food chain or to infiltrate into groundwater.
This section summarizes current Federal and State regulations for the agricultural land application
disposal option. These are in addition to the requirements and recommendations contained in
Section 6.2.
Sludge Pollutant Concentration limit*
Federal Regulations
Current Federal regulations address cadmium, PCBs, and pathogens.
-------
Revised 12/1/89
Cadmium
Annual cadmium applications to sites growing food-chain crops for human consumption, including
tobacco, are limited to 0.5 kg/ha/yr (40 CFR Part 257). The cumulative application of cadmium to
a site is limited based on pH and soil cation exchange capacity according to the schedule listed in
Table 6-9.
TABLE 6-9
MAXIMUM PERMISSIBLE CUMULATIVE CADMIUM APPLICATION TO A LAND
APPLICATION SITE USED TO PRODUCE FOOD-CHAIN CROPS
Max. Cumulative Application (kg/ha)
Soil Cation Exchange Capacity Background Soil Background Soil
(meq/100 g) pH<6.5 pH>6.5
<5 5 5
5-15 5 10
>15 5 20
If the only crop produced is used exclusively as animal feed, then cadmium application rates are
not limited, provided that the following conditions are met:
o The pH of the sludge and soil mixture is maintained at 6.5 or greater whenever the crop is
grown.
o To preclude ingestion by humans and safeguard against possible health hazards from
cadmium entering the food chain, a facility operating plan is prepared that describes how the
animal feed will be distributed
o The land record or property deed states that the property received sludge at high cadmium
application rates and that food-chain crops, except for animal feed, should not be grown due
to possible health hazards. (40 CFR Part 257)
126
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Revised 12/1/89
Permit writers should use the recommendations for dedicated lands in Section 6.5 when cadmium
loadings will exceed the levels set forth in Table 6-9.
There are no current Federalregulations for cadmium loadings to crops that are non food-chain
crops as defined in 40 CFR Part 257.
PCBs
Sludge containing concentrations of PCBs equal to or greater than 10 mg/kg (dry weight), but less
than SO mg/kg, must be incorporated into the soil when applied to land used for producing animal
feed, including pasture crops for animals raised for milk. Incorporation of the sludge into the soil
is not required if it is assured that the PCB content is less than 0.2 mg/kg (actual weight) in animal
feed or less than l.S mg/kg (fat basis) in milk (40 CFR Part 257).
Pathogens
For agricultural land application, 40 CFR Pan 257 contains some specific requirements. If crops
for direct human consumption will be grown within 18 months subsequent to sludge application or
incorporation, the sludge must be treated with a process to further reduce pathogens (PFRP).
These processes are also listed in 40 CFR Part 257 Appendix II, Chapter 3 and Section 6.2 of this
document If the sludge will not contact the edible portions of the crop, pathogen reduction to
PSRP levels is acceptable (40 CFR Part 257).
State Requirements
Some States have set cumulative loading limits for contaminants in sludge applied to cropland (see
Table E6-2 in Appendix E). Where more restrictive State limits apply, permit writers should
determine the basis for these limits and consider incorporating them into the permit
Some States have set sludge contaminant concentration limits, primarily for heavy metals and
PCBs (See Table E6-1). One State has set limits for a number of pestieides. However, it appears
that these limits were based on analytical detection limits. At this time, EPA does not generally
recommend contaminant concentration limits beyond those in the Joint EPA/FDA/USDA Guidance
on Land Application of Municipal Sludges for the Production of Fruits and Vegetables (1981V
Permit writers should consider incorporating State limits after determining the basis for these
limits.
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Revised 12/1/89
State contaminant concentration limits are presented in Table E6-1. In general, the State "Grade I"
sludge limits in this table allow unrestricted agricultural use. States may impose restrictions or ban
use of lower grades of sludge for agriculture.
Table 6-10 summarizes existing State regulations for annual loading of sludge contaminants at
agricultural sites. Table 6-11 is a similar summary for the allowable cumularive loading of sludge
contaminants at agricultural sites. Table E6-2 presents all State annual and cumulative application
rate limits and variances for sludge contaminants.
Case-by-Case Recommendations
Contaminant Cumulative Loading Limits
In addition to the required limits for cadmium and PCBs, EPA and USDA have issued guidance on
the recommended maximum cumulative sludge metal applications for croplands (EPA 1977a,
1984; USDA 1984) (See table 6-12). For permits issued to POTWs applying sludge to lands used
for producing food-chain crops, permit writers should consider requiring POTWs or their agents to
not exceed these loadings of heavy metals. Permit writers also may want to set limits on cumulative
sludge metal loadings to lands used to produce non-food-chain crops (e.g., nurseries, Christmas
tree farms) so as to preserve future use of these lands for food-chain crops. Tables 6-13 and 6-14
show, for various sludge application rates, how many years sludges containing various
concentradons of heavy metals could be applied before exceeding recommended cumulative
application rates. These tables assume that sludge is applied to soils with less than 5 meq/100 g
cation exchange capacity. For sites with a CEC between 5 and 15 meq/100 g, multiply the number
of years that appear in the tables by a factor of two. For sites with a CEC of 15 meq/100 g or
greater, multiply the number of years by a factor of four. In the table, 0 mg/kg means that the
concentration does not allow for any application of sludge at that particular rate.
Contaminant Annual Loading Limits
Research has shown that crop uptake and plant toxicity are controlled by cumularive rather than
annual loading of heavy metals (EPA 1987b). Provided conditions ar»placed in permits 1)
requiring that sludge be applied at agronomic rates; and 2) limiting cumulative metals loadings,
incorporating limits on annual application of heavy metals (other than the required cadmium limits)
is not generally recommended Where applicable, permit writers should consider incorporating
State limits (summarized in Table E6-2).
128
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TABLE 0-10
SUMMARY OF
r£Vf??ENT STATE ANNUAL CONTAMINANT
APPLICATION RATES FOR LAND APPLICATION
No
States" Max- Annual Application Bate (ka/ha)
Constituent Regulating Median Mode
Arsenic
2
57
.
2-112
Cadmium
25
.5
.5
5-6
Chromium
4
47
.
27-56
Copper
6
18
14
9-56
Lead
5
53
56
22-252
Mercury
2
10
_
8-11
Nickel
6
11
.
5-63
Zinc
6
28
28
18-112
— ¦vonangea anoweo Dy many states ha«aH
upon cation exchange capacity (CEC). or m some states, for
other parameters
129
-------
TABLE 6-11
SUMMARY OF
CURRENT STATE CUMULATIVE CONTAMINANT
APPLICATION RATES FOR LAND APPLICATION
Max Annual Application Rate (kg/ha)
Constituent
Regulating
Median
Mode
Range
Arsenic
1
112
112
112
Cadmium
36
5
5
5-20
Chromium
6
313
140
140-560
Copper
31
140
140
84-560
Lead
32
530
560
200-2520
Mercury
2
3
-
6-6
Molybdenum
1
9
9
9
Nickel
31
56
56
341-627
PCB
2
1
-
1-2
Selenium
2
13
-
9-18
Zinc
31
280
280
168-1120
' See Table E6-2 for variances allowed by many states based
upon cation exchange capacity (CEC), or in some states, tar
other parameters
130
-------
table 6-12
CATION EXCHANGE CAPACITY (CEC)

CEC2

Metal
o-s
5-13
13
Cadmium
3
10
20
200
500
1.000
2.000
Ncfcei
Copper
Zinc
Lead
SO
125
250
500
100
230
500
1.000
CFR Pflirt A ™f0fC« 01 roguiaoon (40
^ 257) Annual Cd aopJcaoon should m
exceed 0 5 kgma. All weomSES *£
omy to soris ad)u3teo to pH 6 S when sludgew
W^odand maintained at no less than pH 6 5
2 me
-------
TABLE t-1]
YEAAS OF APPLICATION FOR CAOMIUM AND NICKEL
Yarn of Sludge Apphcaoon at
2 tonnea/hectare (dry weight)
0 9 tonaracre
ConcanBauon at Metal in Sludge (mg/kg)
Years of Sludge Application at
11 tonnevhectare (dry weight)
49 tons/acre
Concentration at Metal m Sludge (moftak
Mat* 900 400 200 90 60 30
Matal 600 400 200 90 60 10
Cd 4 6 12 27 41 83
N» 41 62 125 277 416 833
Cd 0 1 2 3 7 is
Nt 7 11 22 50 73 151
Years of Sludge Application at
20 tonneafhectare (dry wogm)
8.9 tons/acre
Concentration of Metal in Sludge (mg/kg)
Years of Sludge Application at
44 tonneaihectare (dry weight)
20 tors/acre
Concentration of Metal m Sludge (mg/kg>
Metal 600 400 200 90 60 30
Metal 600 400 200 90 60 30
Cd 0 0 1 2 4 9
4 6 12 27 41 83
Cd 0 0 0li3
Nl 1 2 5 12 16 3?
Years of Sludge A coca ton at
70 tonnes/hectare (dry wetgfu)
3i tons/acre
Concentration of Metal « Sludge (mgftg)
Years of Sludge Application at
112 tonnes/heciare (dry weight)
30 tona/acre
Concentration of Metal m Sludge (irxykg)
Metal 600 400 200 90 60 30
Metal 600 400 200 90 60 30
Cd 0 0 0 0 1 2
N» 1 1 3 7 11 23
Cd 0 0 0 0 0 1
Nt 0 1 2 4 7 1«
Years of Sludge Appfcaoon at
340 tonneaftiectare (dry wwght)
152 tons/acre
Concemra&on of Metal m Sludge (mgrtig)
Years of Sludge Appicaton at
900 tonnes/hectare (dry weqftt)
400 tona/acre
Concantrabon of Metal m Sludoa (mo/kai
Metal 600 400 200 90 60 30
Metal 600 400 200 90 60 30
Cd 4 6 12 27 41 63
Ni 41 62 129 277 416 833
Cd 4 6 12 27 41 63
f* 41 62 125 277 416 833
EttkMtad Sfcdg* AwOcatton in Dry WMgm far Oitfwwn Land Otapoul Option*
Otapoaal Option
TinePehodo#
_*EE525S2—
Reported Banga ol appfccaaon
wvha
Typcal Ra»
T/ac
mVha
T/ac
Agncunural
utteaaon
Foraat unizaMn
Land
nadamaoon
u«
Oedcaaad
Oopoaal&ft
Annual
i ftmaarat3-5
yaarrtarvala
Annual
2-70
10-220
7-430
220-900
1-30
4-100
3-200
100-400
11
112
340
s
20
SO
190
The fa— ara omy lor M aopfccaaon ma and do not maude area H» buflar rane, nudge seraga, or
cow araa requramenta. Th» tan aaajmet tn« nudga ¦* aooM to KM 9 tod IS it^iqiioo q, mulbpiy ihi numtnr of ywi tfutt apptf ^
ihattHle by a (actor of two. For sitae with a CEC of 15 mecyiOO g or greatar, munoiy T» nuneer of yaw* oy a
factor of tour.
-------
TABLE 6-14
YEARS OF APPLICATION FOB COPPER, LEAO, ANO 2tNC

Yearn of Sludge Appfacaoon at
2 tameamectare (dry weight)
0.9 tona/acre

Years of Sludge Aoohcauon at
i' tonneamectare (dry weight)
4 9 tons/acre

Concerttraoon of Metal m Sludge (mg/kg)

Concentration of Metd in
Sludge Imo/ka)

Metal
5400
3600
2700
1800 1500
1000
900
Metal
5400
3600
2700
1800
1500
1000
900
Cu
11
17
23
34 41
62
89
Cu
2
3
4
6
7
11
12
Pb
46
69
92
130 166
250
277
Pb
8
12
16
25
30
45
30
Zn
23
34
46
69 83
125
138
Zn
4
8
8
12
15
22
25

20 tonnes/hectare (dry weight)
S 9 tons/acre

Years of Sludge Application at
44 tonneaftectare (dry weight)
20 tona/acre

Concentration of Metal >n Sludge (mgfcg)

Concentration of Metal m
Sludge (mata)

Metal
5400
3600
2700
1800 1500
1000
900
Metal
5400
3600
2700
1800
1500
1000
900
Cu
1
t
2
3 4
6
6
Cu
0
0
1
t
1
2
3
Pb
4
8
9
13 16
25
27
Pb
2
3
4
8
7
11
12
Zn
2
3
4
6 8
12
13
Zn
1
1
2
3
3
5
e

70 tonne^hectare (dry wetgni)
3i toovacre

Years of Sludge Appkcaoon at
H2 tonneaftectwe (dry wngnt)
50 tonsracrv

Concsntratwn of Metal >n Sludge (mglcg)

Concentration of Metal in
Sludoe (mo/Ko)

Metal
5*00
3600
2700
1800 1500
1000
900
Metal
5400
3600
2700
1800
1500
1000
900
Cu
0
0
0
1 1
t
2
Cu
0
0
0
0
0
1
1
Pb
1
2
2
4 4
7
7
Pb
0
1
1
2
3
4
5
Zn
0
1
1
2 2
3
4
Zn
0
0
0
1
1
2
2

340 tonnes/hectare (dry wwgm)
152 tons/acre

Years of Sludge Application at
900 tonneaftoctare (dry vmgftt)
400 tona/acre

Concentration ol Metal n Sludge (mg/kg)

Concentraaon of
Metal it
Sludoe fma/kni

Metal
5400
3600
2700
1800 1500
1000
900
Metal
5400
3600
2700
1800
1500
1000
900
Cu
0
0
0
0 0
0
0
Cu
0
0
0
0
0
0
0
Pb
0
0
0
0 1
1
1
Pt>
0
0
0
0
0
0
0
Zn
0
0
0
0 0
0
0
Zn
0
0
0
0
0
0
0
Parameters
1 Sludge Loading Rate
2. Parameter concentration
3. Parameter cumulative loading limit
4 Parameter deposition Rate
5. Years of use at that rate
•(Site Ufa/Annual loading)
SI Unit Tables
English Unit Tables
2 tonne/hectare-yr
600 mg Cd/kg sludge
5 kg Cd/hectare
2 tonnes/ha-yr x 1000 kg sludge/tonne
x 0.0006 kg Cd/kg sludge
¦ 1.2 kg OtVhectare-yr
(5 kg Cd/ha)/(1.2 kg Cd/ha/yr)
- 4.1667 > 4 yr
(round to nearest Integer)
.9 tons/acre-yr
600 mg Cd/Vg sludge
5 kg Cd/ hectare
.9 ton/acre-yr x 010 kg/ton x 2.47
acre/hectare x 0.0006 kg Cd/kg sludge
-1.2 kg Cd/hectare/yr
(5 kg/ha x ha/1.2 kg Cd/hectara-yr)
- 4.119 > yr 1
(round to nearest imager)
-------
Revised 12/1/89
Sludge Pollutant Concentration Limits
The 1981 Joint EPA/FDA/USDA Guidance on Land Application of Municipal Sludges for the
Production of Fruits and Vegetables recommends that only sludges with less than 25 mg/kg
cadmium, 1,000 mg/kg lead and 10 mg/kg PCBs be applied to lands used to produce fruits and
vegetables (EPA 1981). Research has shown that, for cadmium and lead, these recommendations
are very conservative and provide a wide margin of safety (EPA 1987b). Based on the 1981
Guidance, permit writers should generally consider requiring that sludge applied to lands used for
fruits and vegetable production meet these contaminant concentration levels. In this case, sludge
with higher levels of cadmium and lead could still be applied to lands where grains or fodders are
grown. Within the restrictions imposed by 40 CFR PART 257.3-5, sludges with higher PCB
levels might also be used (See Appendix D).
In certain circumstances, it may be acceptable to allow sludges with somewhat higher amounts of
cadmium and lead to be used on lands for fruit and vegetable production. For example, public
health should be adequately protected if the permit writer
o Places a sludge cadmium limit of 38 mg/kg (dry weight) in the permit, and a lead limit of
1500 mg/kg (dry weight). These limits are 50 percent greater than generally recommended;
o Writes the recommended cumulative loading limits into the permit (per 40 CFR Part 257.3-5,
annual cadmium loading cannot exceed 0.5 kg/ha);
o Limits sludge application to the agronomic rate; and
o Requires that the sludge only be applied to lands where, for the life of the permit, crops with
low or very low heavy metal uptake rates will be grown. Table 6-15 presents the relative
cadmium uptake rates of various crops. Crop uptake rates for lead are much lower than for
cadmium.
Pathogen Control
To provide additional assurance beyond the pathogen reduction requirements of 40 CFR Part 257,
the 1981 Joint EPA/FDA/USDA Guidance recommends that in warm, moist climates, crops that
are customarily eaten raw or only partially blanched should not be planted within 36 months of
sludge application. Studies since 1981 have confirmed that certain pathogens can survive for long
134
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TABLE 4-16
RELATIVE ACCUMULATION OF CADMIUM INTO EDIBLE
PLANT PARTS BY DIFFERENT CROPS'
Hign
Uptake
Moderate
Uptake
Low
Uptake
Very Low
Uptake
Lettuce
Kate
Cabbage
Snapbean

family
Spinach
Coilards
Sweet com
Pea
Chard
LHW
Broccoli
Melon family
Escaide
Turnip
Cauliflower
Toma»
Endive
Raddtsh globes
Brusael sprouts
Pepper
Cress
Mustard
Celery
Eggplant
Tumip greens
Potato
Berry fruits
Tree fruits
Beet greens
Onion

Carrol

' The above classification is based uoon a* response of crooe grown
on aodc sola that have rece»ved a cumulative Cd application of 9
kgma. l the sod pH >s 6 3 or
grsaier at ihe tune of planting, since ffie tandency of me crop to
accunuiats heavy metals ui significantly reduced as me sod pH
increases above 0.3
Source: EPA 1983.
135
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Revised 12/1/89
periods of times (e.g., three years) if the sludge/soil mixture is not turned over at least two or three
times to expose these pathogens to air and sunlight which desiccate them.
6.3.4 OPERATING CONDITIONS AND MANAGEMENT PRACTICES
Federal Guidance
Sludge Application Races
Because of concerns about nitrate pollution of ground-water, permit writers should consider
requiring that sludges be applied at rates that do not exceed the nitrogen requirement of the
particular crop grown on the application site (the agronomic rate). When sludges are applied at
greater than agronomic rates, the recommendations for dedicated lands should be considered (EPA
1983). Some States (for example, Ohio) take a more conservative approach and limit sludge
application rates to plant phosphorus rather than nitrogen requirements (EPA 1984). Limiting
sludge application to the plant phosphorus requirement typically lowers permissible sludge
application rates by a factor of two to five (EPA 1983). EPA's Land Application Manual (EPA
1983) presents detailed information on how to calculate plant nutrient requirements and appropriate
sludge application rates. Permit writers should consider requiring that POTWs or their agents use
the Land Application Manual or protective State or local guidelines, where available, to calculate
sludge application rates.
Distance to Surface Waters
To ensure that sludge does not run off into surface waters, permit writers should require that
buffers be maintained between the sludge application area and water bodies. Buffers serve at least
two purposes: 1) they provide a factor of safety against errors during sludge application; and 2)
they provide treatment and filtering of sludge and/or run-off from sludge surfaces.
The condition of the ground surface of buffers is a critical factor in determining appropriate size
(for example, bare soil provides virtually no filtering while a grass surface offers fair treatment).
Thus, as illustrated in Table 6-16, the recommended size of buffers depends on the method of
sludge application, the type of surface water being protected and the condition of the ground
surface of the buffer.
136
-------
Revised 12/1/89
TABLE 6-16
RECOMMENDED DISTANCE TO SURFACE WATERS FOR AGRICULTURAL LAND
APPLICATION
Sludge Application Type of Water Body
Method/Buffer Continually
Condition Flowing Intermittent Ditches
Surface Applied:
Continually Vegetated Buffer 200' 100' 50"
Bare Soil Buffer 200' 200* 100'
Injected/Incorporated: 100' 50' 25'
If recommended conditions for sludge applicadon rates and slope restrictions are not included in
the permit, buffers should be wider.
Seasonal Limitations
To protect surface waters and ground waters, permit writers should prohibit sludge application to
saturated ground (EPA 1984). Permit writers should also require that sludge application cease
during storm events when precipitation exceeds 1/4 inch per hour (EPA 1983). In general, permit
writers should require that sludge not be applied to frozen or snow-covered ground because of
potential run-off problems (EPA 1984). However, it has been shown thai when proper
precautions are used, unsaturated frozen ground or snow-covered lands may provide some level of
benefit in stabilizing and dewatering sludges. If this form of treatment is a consideration, the
permit writer should require the permit application to demonstrate that a combination of slope
restrictions and ren-off control measures will protect surface waters.
The timing of sludge applications should confoim to farming operations, and is influenced by
crop, climate, and soil properties. In addition, sludge applications must be scheduled around the
tillage, planting, and harvesting operations for the crops grown. A general guide to allowable
times for surface and subsurface applications of sludge for North Central States is shown in Table
6-17. Individual States or local USDA-SCS extension personnel can provide similar information.
137
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Revised 12/1/89
Depth to Ground-water
To protect ground-water, permit writers should generally prohibit sludge application to sites where
ground-water is less than three feet from the surface of the soil. Seasonal perched ground waters
require less protection (EPA 1983). Fields that are normally flooded or saturated early in the spring
may be suitable application sites if depth to ground-water is at least three feet at the time that sludge
is applied and the field is not likely to be saturated during the growing season.
Distance to Wells Used for Drinking Water
Limiting sludge application to the agronomic rate and setting a minimum depth to ground-water
make contamination of ground-water unlikely. However, to provide an additional margin of safety,
permit writers should consider prohibiting sludge application within 200 feet of drinking water
wells (EPA 1983). Permit writers should consult with ground-water program officials to determine
if a State wellhead protection program has set other requirements.
Access Control
To lessen the possibility that humans will come into direct contact with pathogens that may be
present in sludge, permit writers should consider prohibiting application of sludge that has not
been treated by a Process to Further Reduce Pathogens within 300 feet of inhabited dwellings,
schools or playgrounds. If the property owner (and any tenant) agrees, it may be acceptable to
apply sludge closer to dwellings located on the application site.
In general, permit writers shook! prohibit sludge application within 30 feet of property lines. If the
adjoining property is another farm field or wooded lot, it may be acceptable to apply sludge within
30 feet of the property line.
State Requirements
Sludge application rates for agriculture are calculated based on crop n^eds, permissible sludge
constituent concentration (based on health and environmental effects), and soil characteristics.
-------
TABLE «-17
GENERAL GUIDE TO MONTHS AVAILABLE FOR SLUOQE APPUCATION TO DIFFERENT CROPS IN NORTH
CENTRAL STATES*
Small Grams*
Month
Com
Soybeans
Cotton*
Foraged
Winter
Spnng
January
Sr
S*
SA
s*
c
S*
February
S"
S"
SA
s*
c
S*
March
SI
SA
SA
s
c
S/t
Apr*
S/l
SA
P. SA
c
c
P. SA
May
P. SA
P, S/l
c
c
c
c
June
c
P. SA
c
H, S
c
c
July
c
c
c
H. S
H, S/l
H. SA
August
c
c
c
H. S
S/l
SA
September
c
H. S/l
c
s
SA
S/l
October
H, SA
s/l
SA
H, S
P, S/l
SA
November
SA
S/l
SA
S
c
SA
December
sr
s*
SA
S"
c
S'
* Application may not be allowed due to frozen or snow-covered sola m some states; S/l, surface or incorporated
application. S. surface apphcatmC. growing crop present P. crop planted; H, after crop harvested.
t Wheat, barley, oats, or rye.
' Cotton, only grown south of southern Mtsaoun.
* Established forages, legumes (alfalfa, clover, trefoil, etc). grass (orchard grass, trmotfiy. brome. reed canwy grass,
etc.), or legume-grass mixture.
Source: EPA 1983.
139
-------
Revised 1Z/1/89
Application rates are designed so chat the most limiting constituent sets the appropriate application
rate for the sludge. The two constituents that are usually most important to control are nitrogen and
cadmium. Nitrogen is typically the first sludge component to limit the rate of sludge application,
since adding excess nitrogen to soil may potentially contaminate ground-water with nitrates.
Typical sludge application rates for agriculture range from 1 to 30 dry tons of sludge per acre per
year in cases not restricted by high contaminant concentrations. (EPA, 1984). Twenty-one States
have maximum loading limits in accordance with crop nutrient requirements (i.e., agronomic rate
limitations). Seven States have maximum volumetric loading limits, which range generally from
10,000 to 30,000 gallons per acre per year. Eight States have maximum mass loading limits,
which range generally from 2 to 20 dry tons per acre per year.
A number of States place restrictions on animal grazing. The most common restriction is to control
animal grazing for at least one month after sludge application. In some States, however, access by
grazing animals is restricted for as much as 6 or 12 months. Three States require that fences and
signs be installed.
Forty-one States have crop use limitations (see Table E6-5). Thirty-five States reported mandatory
time delays after sludge application before planting human consumption crops. The delays ranged
generally from 1 to 3 years, and the most common delay was 18 months for human consumption
crops (specified by 10 States; typically includes tobacco). Twenty-four States reported that some
crops were not allowed. Three States (Arizona, Georgia, and Rhode Island) prohibit the
application of sludge to land that will be used to grow human consumption crops. Four more
States allow human consumption crops only if special conditions are met Five States do not allow
raw crops to be grown. Nine States do not allow contact with root crops, food plants, or low
fruits.
6.3.5 ADDITIONAL MONITORING CONSIDERATIONS FOR AGRICULTURAL LAND
APPLICATION
In addition to the monitoring requirements and recommendation discussed in 6.2.2, sludges
applied to lands used for producing food-chain crops should be monitored more frequently than is
generally recommended in other land application processes. The pH of the sludge-soil mixture
should be measured each time sludge is applied to food-chain croplands and whenever food-chain
crops are grown. Once, during the first year of the permit, the soil cation exchange capacity of
food-chain croplands where sludge is applied should be measured.
140
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Revised 12/1/89
6.4 ADDITIONAL REQUIREMENTS AND GUIDANCE FOR STLVICULTURAL (FOREST
LANmn APPLICATION
Forest land application rates are usually limited to the nitrogen needs of the trees. This rate is
typically 4 to 100 tons per acre in one single application or in a set of closely spaced applications
every 3 to 5 years. A typical application rate would be 18 tons per acre every 5 years, which is
equivalent to an average yearly applicadon rate slightly less than that for agricultural application
(EPA 1984). This section presents contaminant limits and management practices for silvicultural
applicadon of sewage sludge.
6.4.1 CHARACTERISTICS OF SLUDGES SUITABLE FOR SILVICULTURAL LAND
APPLICATION
Federal Regulations
The only Federalsludge quality limits are the pathogen reduction requirement of 40 CFR Part 257.
State Requirements
Two States reported regulations addressing maximum loading limits for forest land application in
cases not limited by high concentrations of contaminants.
Case-by-Case Recommendations
If the permit writer is concerned that a silvicultural sludge application site might be used at a later
date to grow food-chain crops, the permit writer should consider requiring that the POTW or its
agent comply with the contaminant cumulative loading limits recommended for food-chain
croplands. If sludge application is limited to the agronomic rate (discussed below), metal toxicity to
forest plants should not be a problem (EPA 1983).
141
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Revised 12/1/89
6.4.2 OPERATING CONDITIONS AND MANAGEMENT PRACTICES FOR
SILVICULTURE
Federal Regulations
There are no required permit conditions for sludge application to forest lands beyond the 40 CFR
Part 257 requirements that apply to all forms of land application (See Tables 6-1 and 6-2).
Recommended permit conditions to ensure that the surface water and ground-water provisions of
40 CFR Pan 257 are met are discussed in the Case-by-Case Recommendation section.
Federal Guidance
Sludge Application Rate
Because of concerns about nitrate pollution of ground-water, permit writers should consider
requiring that sludges be applied at rates that do not exceed the nitrogen requirement of the type of
forest on the application site (the agronomic rate). The forested floor often includes a layer of
organic matter high in carbon and low in nitrogen, which will temporarily immobilize nitrogen then
slowly mineralize in later years. It is this feature of forest soils that allows heavier, multi-year
applications. EPA's Process Design Manual for Land Application of Municipal Wastewater
Sludge (EPA 1983) presents detailed information on how to calculate nutrient requirements and
appropriate sludge application rates. Permit writers should require that POTWs or their agents use
this manual or protective State or local guidelines, where available, to calculate sludge application
rates. When sludges are applied at greater than agronomic rates, the recommendations for
dedicated lands should be considered (EPA 1983).
To protect the structure of forest soils from damage caused by heavy application vehicles and to
reduce costs, sludges are typically applied to forest lands in a single application (or closely-spaced
series of applications) once every three to five years. A typical application rate would be 40 metric
tons per hectare every five years, which is an average yearly rate slightly less than for agricultural
application (EPA 1984). Such an application scenario is acceptable, pwvided measures are taken to
ensure sludge does not run off into surface waters and that ground waters are protected.
-------
Revised 12/1/89
Distance to Surface Waters
To ensure that sludge does not run off into surface waters, permit writers should require that
buffers be maintained between the sludge application area and water bodies. Buffers serve at least
two purposes: 1) they provide a factor of safety against errors during sludge application; and 2)
they provide treatment and filtering of sludge and/or run-off from sludge surfaces.
The condidon of the ground surface of buffers is a critical factor in determining appropriate size
(for example, bare soil provides virtually no filtering while an undisturbed forest floor offers
excellent treatment). Thus, the recommended size of buffers depends on the method of sludge
application, the type of surface water being protected and the condition of the ground surface of the
buffer as shown in Table 6-18:
TABLE 6-18
RECOMMENDED DISTANCES TO SURFACE WATER FOR SDLVICULTURAL
APPLICATIONS
Type of Water Body
Sludge Application Large
Method/Buffer Continually Small
Condition Flowing Tributary Intermittent Ditches
Surface Applied:
Undisturbed Buffer 200' 100* 50* 25'
Disturbed Buffer 200' 200' 100' 50'
Injected/Incorporated: 100' 100' 50* 25'
If recommended conditions for sludge application rates and slope restrictions are not included in
the permit, buffo* should be wider.
Application Site Slope Limitations
Provided that the recommended buffers around surface waters are written into the permit and
sludge application is limited to the agronomic rate, application to forested sites with good
vegetative cover and slopes not exceeding 30 percent is acceptable. Permit writers should consider
defining a wet season and generally prohibit application on slopes greater than 15% during this
143
-------
Revised 12/1/89
period except where slope length is short, is a minor part of the total application area and is not
associated with streams, or where it can be demonstrated that management techniques are effective
in controlling run-off.
Seasonal Limitations
The seasonal limitations recommended for agriculture should be written into the permit.
Depth to Ground-water
High-rate sludge application once every three to five years (to maintain an agronomic rate over the
period between applications) may result in excess nitrogen being available in the first year or two
after application. Thus, to protect ground-water aquifers from nitrate pollution, permit writers
should prohibit sludge application in this manner on sites where ground-water is less than six feet
from the surface of the soil (EPA 1983). Seasonal, perched ground waters require less protection
(EPA 1983).
Distance to Wells Used for Drinking Water
To provide a margin of safety, depending on the geology in the area, permit writers should
consider requiring a minimum setback distance of 300 to 1,500 feet from drinking water wells.
(EPA 1983). Permit writers should consult with ground-water program officials to determine if a
State wellhead protection program has set other requirements and also with hydrogeologists for
site-specific considerations.
Access Controls
The setback distance for areas which will be used by the public will need to be considered on site-
specific basis depending on die potential exposure of the public to health and safety hazards. A
setback of at least 300 ft should be used when sludges that are treated by a PSRP are applied
(EPA 1983). This distance may be lessened in remote areas and/or if appropriate signs are posted.
Access should be controlled for ai least 12 months in all of the above Situations. Sludge that has
been treated by a PFRP should not require access restriction.
144
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Revised 12/1/89
State Requirements
For dedicated forest application sites, Ohio allows application at 5 to 10 times agricultural rates.
Washington limits application rates to the nitrogen needs of the forest crop.
6.4.3 ADDITIONAL MONITORING CONSIDERATIONS FOR SILVICULTURE
For additional safety, if the aquifer immediately under the application site is used as a source of
drinking water, permit writers should consider requiring ground-water monitoring. Nitrates will be
of particular concern where application rates exceed the agronomic rates.
6.5 ADDITIONAL REQUIREMENTS AND GUIDANCE FOR LAND RECLAMATION
To ensure that sufficient nutrients and organic matter are introduced into the soil to support
vegetation until a self-sustaining ecosystem is established, the amount of sludge applied at one time
during land reclamation can be relatively large, ranging from seven to 450 dry metric tons per
hectare (EPA 1984). Thus, the permit needs to address the potential for temporary pollution of
surface and ground waters. Permit writers should ask themselves, provided the requirements of 40
CFR Part 257 arc met and public health and the environment are protected, will using sludge
provide environmental benefits? If so, they should encourage use of sludge in land reclamation
projects.
6.5.1 CHARACTERISTICS OF SLUDGES SUITABLE FOR LAND RECLAMATION
Federal Regulations
There are no required permit conditions for sludge application for land reclamation beyond the 40
CFR Part 257 requirements that apply to all forms of land application. (See Tables 6-1 and 6-2).
Case-bv-Casc Recommendations
If the permit writer is concerned that a site where sludge is applied might be used at a later date to
grow food-chain crops, the peimir writer should consider requiring that the POTW or its agent
comply with the contaminant cumulative loading limits recommended for food-chain croplands. If
site conditions make it unlikely that the reclaimed land could be used to produce food-chain crops,
additional metals limits are noc needed, so long as soil pH is adjusted to provide the appropriate
-------
Revised 12/1/89
soil acidity for revegetation (discussed below). With pH adjustment (as needed), metal toxicity to
plants grown on the site should not be a problem (EPA 1983).
State Rcniiirements
Five States specified maximum loading limits for land reclamation sites in cases not limited by
specific contaminant concentrations. Florida limits applications to 30 dry tons per acre per year.
Illinois notes that loading limits are based on nitrogen and metals. New Hampshire limits
applications to 15 dry tons per acre per year. New Jersey bases its limit on the nutrient
requirements of the proposed vegetation. Pennsylvania limits application to 60 dry tons per acre.
State sludge contaminant concentration limits for land reclamation are specified in Table 6-19.
State regulations for annual and cumulative application rates and variances for land reclamation are
shown in Table 6-20.
6.5.2 OPERATING CONDITIONS AND MANAGEMENT PRACTICES FOR LAND
RECLAMATION
flase-hv-Case Recommendations
Soil pH Adjustment
Permit writers should consider requiring that the soil pH of the site be adjusted, as necessary, to
provide a suitable environment for revegetation. Most grasses and legumes along with many
shrubs and deciduous trees grow best in the soil pH range from 5.5 to 7.5 (EPA 1983). If the soil
pH becomes highly acid, phytotoxknty problems may be encountered from both the trace metals
applied in the sludge and native toxic elements found at the site (EPA 1983).
Sludge Application Rates
The appropriate amount of sludge to apply to a land reclamation site a highly site-specific (EPA
1983). As noted above, sludge application rates vary from seven to 450 dry metric tons per
hectare. A typical application rate is 112 metric tons per hectare (EPA 1983,1984). Permit writers
should ask permit applicants to specify how much sludge will be applied to a land reclamation site.
This information is used along with data on site features (soil pH, slope, depth to ground-water) to
146
-------
TABLE S-19
STATE SLUOQE CONTAMINANT
CONCENTRATION UMITS FOR LAND
RECLAMATION
Slate/Contaminant Umit*i»*i (m^fcg)
California

Cadmium
25
Lead
900
PC 8a
9
Randa

Cadmium
100
Copper
3.000
Lead
1.900
Nickel
900
Zinc
10.000
Source, EPA 1947c.
147
-------
TABLE ft-20
STATE REGULATIONS FOR ANNUAL AND CUMULATIVE APPLICATION RATES ANO VARIANCES FOR
LANO RECLAMATION
Limitation fkgrtia)
State Constituent Annual Cumulative Basia tor Standard Vananca A Bowed Commeoa
PA
Cadmium
67
336
Farming
5 8 kgrita
AR
Cadmium

3
C6C<9

CA
Cadmium
09
9
Sod pH, C£C<9
Max ¦ 20 kgfta when CEC> 19
FL
Cadmium
9
9

PA
Chromium
87 2
336
Famwig
960 kgfta stnefly land reclamation
AR
Cooper

129
CEC<9

CA
Copper

140
CEC<9
Max ¦ 900 kg/ha when CEC>19
PA
Copper
18.8
84
Reclamation tor Farm
140 k(ytia stnefly land redamaaon
FL
Copper
123
123

PA
Lead
87 2
336
Famwig
960 iqyha svedy land reclamation
AR
Lead

900
CEC<9

CA
Lead

400
CEC<9
Max - 800 kg/Tia wtan CEC > 9
FL
Lead
500
900

PA
Mercury
22
1 12
Farmng
i 88 k^tia stnctfy land reclamation
PA
Nickel
8.72
336
Farming
96 kg/Tia stncoy land redamaton
CA
Nickel

90
CEC<9
Max ¦ 20 ttac wflen CEC > 15
AR
Nickel

SO
CEC<9

FL
Nickel
125
129

CA
Zinc

290
CEC«9

AR
Zinc

290
CEC<9

PA
Zinc
33 6
188
Farmng
280 )<0Ti« stnctfy land radamtton
FL
Zinc
250
290
09*

Source EPA 1967c.
148
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Revised 12/1/89
determine appropriate measures to protect plants from metal toxicity (e.g„ liming) and to protect
surface and ground waters.
Distance to Surface Waters
Permit writers should consider using the agricultural buffer recommendations for land reclamation
sites. (The silvicultural recommendations assumed that a forest floor would be present to filter and
treat sludge and/or run-off.) When large amounts of sludge are used, wider buffers may be
appropriate. However, in some cases, sludge has been used to stabilize the banks of waterways
and, while probably causing a small, temporary amount of surface water pollution, resulted in
overall environmental benefits. 40 CFR Part 257 requires that sludge application not cause a
discharge of pollutants into waters of the United States in violation of NPDES requirements or the
requirements of a Section 208 water quality management plan.
Application Site Slope Limitations
In general, permit writers should prohibit application of sludge to slopes in excess of IS percent
(EPA 1983). When sludge use will provide clear environmental benefits and measures are taken
that will control run-off from the site, it may be acceptable to use sludge on somewhat steeper
slopes.
Seasonal Limitations
To protect surface and ground waters, permit writers should strongly consider using the seasonal
limitations recommended for agriculture.
Depth to Ground-water
The typical, one-dme, high-rate sludge applications used in land reclamation projects may result in
excess nitrogen being available in the first year or two after application. Thus, to protect ground-
water aquifers from nitrate pollution, permit writers should prohibit sludge application in this
manner on sites where ground-water is less than three feet from the surface of die soil (EPA 1983).
Seasonal, perched ground waters require less protection (EPA 1983).
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Distance to Wells Used for Drinking Water
To provide a margin of safety, depending on the geology in the area, permit writers should
consider requiring a minimum setback distance of 300 to 1,500 feet from wells used for drinking
water. (EPA 1983). Permit writers should consult with ground-water program officials to
determine if a State wellhead protection program has set other requirements. It may be appropriate
to require testing for nitrates in water drawn from nearby wells.
Access Controls
Permit writers should consider prohibiting application of sludge that has not been treated by a
Process to Further Reduce Pathogens within 300 feet of areas used by the public. Where permit
writers are concerned that members of the public who may not know that sludge has been applied
will use the site, they should consider requiring posting of signs stating that sludge has been
applied to the site. Sludge that has been treated by a PFRP should not require access controls.
State Requirements
Maryland requires even spreading for sludge application on marginal land and contour plowing.
A number of States have requirements for land reclamation (See Appendix E). Permit writers
should incorporate applicable State requirements where appropriate.
6.5.3 ADDITIONAL MONITORING CONSIDERATIONS FOR LAND RECLAMATION
For additional safety, if the aquifer immediately under the application site is used for drinking
water nearby, permit writers should consider requiring ground-water monitoring.
6 6 ADDITIONAL REQUIREMENTS AND GUIDANCE FOR DEDICATED LAND DISPOSAL
Dedicated land disposal uses land as a sludge treatment system. Soil microorganisms, sunlight and
oxidation degrade the organic matter in the sludge while the soil binds any metals that may be
present To protect surface and ground waters, precautions which may be necessary at dedicated
sites may include physical barriers to control run-off and leaching and careful monitoring for
contamination of ground and surface waters. Often, leachate and run-off water must be captured
and treated prior to release (EPA 1983,1984).
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In most cases, the POTW or its contractor owns the dedicated land disposal site. POTWs usually
take one of the following four approaches to dedicated land disposal:
1. All surface water run-off is contained within the site through use of dikes, lagoons, etc., and
disposed of through evaporation. All ground-water leachate is contained due to natural
impervious geological barrier; (e.g., impervious clay, bedrock, etc.) between the site and
any underground drinking water sources. No attempt is made to remove moisture or other
sludge constituents (e.g., nitrogen, metals) from the site;
2. Same as 1 above, except crops are planted to enhance removal of moisture and sludge
nutrients. In some cases, these crops are used as animal feeds;
3. Same as 1 or 2 above, except run-off is controlled and discharged in accordance with
NPDES permit conditions; or
4. Same as 1,2, or 3 above, except that groundwater leachate is intercepted, usually using
subsurface drain tiles, to prevent percolation into ground-water aquifiers. Under favorable
geological conditions, interceptor ditches, well point systems, deep well pumping or other
interception systems may also be feasible. Intercepted leachate may be removed by
evaporation, discharge to a sewage treatment plant, irrigation of site vegetation or discharge
directly to surface waters in accordance with a NPDES permit (EPA 1983).
6.6.1 PERMITTING RESPONSIBILITIES
Unless the permit prohibits use of the dedicated site for food-chain crop production, permit writers
should use the required permit conditions for agriculture. In this case, if the 40 CFR Pan 257.3-
5(a)(1) cadmium limits will be exceeded (5-20 Kg Cd/ha), only animal feeds can be grown, a
stipulation must be placed in the property deed notifying future owners that the property has
received high-rate cadmium applications and should not be used to grow food-chain crops, and a
facility operating plan must be prepared demonstrating how the animal feed will be distributed to
preclude ingestion by humans (See 40 CFR Pan 257, Appendix D). If food-chain crop production
is prohibited, permit writers should use the required permit conditions for silvicultural use of
sludge. All sludges applied to lands must be treated by a Process to Significantly Reduce
Pathogens.
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A number of Slates have requirements for dedicated land disposal (See Appendix E). Permit
writers should incorporate applicable State requirements where appropriate. There are no reported
State contaminant limits specifically for dedicated land use of sludge.
6.6.2 CHARACTERISTICS OF SLUDGES SUITABLE FOR DEDICATED LAND DISPOSAL
Sludge Pollutant Concentration Limits
Provided that the requirements of 40 CFR Part 257 are met, no additional contaminant loading
limits are recommended.
6.6.3 OPERATING CONDITIONS AND MANAGEMENT PRACTICES FOR DEDICATED
LAND DISPOSAL
Case-bv-Casc Recommendations
Sludge Application Rates
To ensure that run-off control and ground-water protection measures will protect public health and
the environment, permit writers should ask applicants to select a maximum annual sludge
application rate and write this rate into the permit.
Sludge application rates range from 100 to 400 tons per acre (220 to 900 dry metric tons per
hectare) per year, approximately 20 times those of agricultural lands. Dedicated sites where crops
are grown will have application rates toward the lower end of this range (EPA 1984).
Distance to Surface Waters and Run-off Control Measures
Permit writers should consider prohibiting application of sludge to a dedicated disposal site within
300 feet of any pond or lake used for recreational or livestock purposes and any other surface
waters (EPA 1983). Applying sludge to dedicated sites that are at leas^200 feet from intermittent
streams should be acceptable (EPA 1983). Permit writers should require permit applicants to
demonstrate that run-off control measures will protect surface waters from the 24-hour, 25-year
storm event
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Application Site Slope Limitations
Permit writers should consider prohibiting dedicated site disposal of sludge on slopes equal to or
greater than 12 percent (EPA 1983).
Seasonal Limitations
Unless the permit writer is assured that run-off control and ground-water protection measures will
adequately protect surface and ground waters, the permit writer should consider writing the
seasonal limitations recommended for agriculture into the permit.
Depth to Ground Water and Leachate Control
Generally, permit writers should consider prohibiting disposal of sludge on dedicated sites where
an underground drinking water source (any aquifer with less than 10,000 mg/1 of dissolved solids)
is less than 10 feet from the surface of the soil (EPA 1983). Seasonal, perched ground waters
require less protection (EPA 1983). Permit writers should consult ground-water protection staff
(Appendix B) with any questions regarding the classification of aquifers. Disposal on dedicated
sites with less than 10 feet of depth to ground water may be acceptable if appropriate measures are
taken to protect ground waters from leachate from the site.
To protect ground waters from contamination, permit applicants should be required to demonstrate
that leachate from their dedicated disposal site will be controlled in one of the following ways:
o The local climate is arid with a high net evaporation, and underground drinking water sources
are deep;
o An impervious geological barrier (e.g., bedrock or thick clay) lies between the site and the
underground drinking water source effectively preventing percolation of volumes of leachate
which could contaminate these sources;
o A below ground leachate interception system will be constructed (e.g., drain tiles, well
points, etc.) which will collect the leachate before it can percolate into the aquifer, or
o The volume of leachate reaching the aquifer is such a small percentage of the ground-water
aquifer flow volume that potential degradation is negligible (EPA 1983).
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Permit writers should require that any collected leachates be disposed of in a manner that complies
with all Federabequirements, and should consider requiring any additional measures that may be
necessary to protect public health and the environment.
Distance to Wells Used for Drinking Water
To provide a margin of safety, permit writers should consider requiring a minimum setback
distance of 1,000 feet from wells used for drinking water (EPA 1983). Permit writers should
consult with ground-water program officials to determine if a State wellhead protection program
has set other requirements. It may be appropriate to require testing for nitrates in water drawn from
nearby wells.
Access Controls
Permit writers should consider prohibiting application of sludge to dedicated disposal sites located
within 500 feet of areas used by the public. If residential dwellings or other heavy public use areas
are adjacent to the site, a 2,000 foot buffer is recommended (EPA 1983). Unless a dedicated
disposal site is located in a very remote area, permit writers should consider requiring that the site
be enclosed by a fence with locking gates.
6.6.4 ADDITIONAL MONITORING RECOMMENDATIONS FOR DEDICATED LAND
DISPOSAL
In general, to check for possible ground-water pollution from leachate, permit writers should
require ground-water monitoring. In addition, permit writers should consider requiring that any
crops grown for animal feed be tested periodically to ensure that PCBs, cadmium and other metals
that may be in high concentrations in the sludge do not pose a threat to the food-chain. If animal
feeds are grown, the sludge should be tested for contaminants more frequently than is generally
recommended.
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REFERENCES
EPA 1977a, Office of Water Program Operations Municipal Sludge Management Environmental
Factors. EPA 430/9-77-004. October 1977
EPA 1977b, Procedures Manual for Ground-Water Monitoring at Solid Waste Disposal Facilities,
EPA530/SW-611.
EPA 1979, Process Design Manual for Sludge Treatment and Disposal. EPA 625/1-79-011,
September 1979.
EPA 1980, Guide to Regulations and Guidance for Utilization and Disposal of Municipal Sludge.
U.S. Environmental Protection Agency, 430/9-80-015, September 1980.
EPA 1981, Land Application of Municipal Sewage Sludge for the Production of Fruits and
Vegetables: A Statement of FederalPolicy and Guidance. SW-905. U.S. Environmental
Protection Agency.
EPA 1983, Process Design Manual for Land Application of Municipal Wastewater Sludge. EPA
625/1-83-016, 1983.
EPA 1984, Environmental Regulations and Technology: Use and Disposal of Municipal
Wastewater Sludge. EPA 625/10-003,1984.
EPA 1986(a), Proceedings of the Workshop on Effect of Sewage Sludge Quality and Soil
Properties on Plant Uptake of Sludge Applied Trace Constituents. Las Vegas, Nevada, November
13-16, 1985, December 1986.
EPA 1986(b), Radioactivity of Municipal Sludge. US EPA Office of Water Regulations and
Standards. Washington, DC 1986.
EPA 1987(a), Regulatory Impact Analysis of the Proposed Regulations for Sewage Sludge Use
and Disposal. July 1987.
EPA 1987 (b), Proceedings of a workshop. Land Application of Sludge: Food Chain
Implications. A. L. Page et al., editors; Lewis Publishers Inc. 1987.
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EPA 1987(c), Stale Requirements for Sludge Management, U.S. Environmental Protection
Agency Office of Municipal Pollution Control and Office of Water Enforcement and Permits,
Washington, D.C., 1987. (Revised 1989.)
EPA 1989a, Environmental-Regulations and Technology: Control of Pathogens in Municipal
Wastewater Sludge for Application Under 40 CFR PART 257. U.S. Enviommental Protection
Agency, EPA 625/10-89-006. October 1989.
EPA 1989b, Draft • Suggested Guidelines for the Disposal of Naturally Occurring Radionuclides
Generated by Drinking Water Treatment Plants. US EPA Office of Drinking Water Criteria and
Standards Division, Washington D.C. 1989.
Haufler, J. and S. Hest 1985, Wildlife Responses to Forest Application of Sewage Sludge. In the
Forest Alternative for Treatment and Utilization of Municipal and Industrial Waste. P.H, Cole,
C.H. Henry and W.V Nutter, eds. University of Washington Press. Seattle and London.
USDA 1984 Use of Sewage Sludge Compost as a Soil Conditioner and Fertilizer for Plant
Growth, U.S. Department of Agriculture, Agricultural Information Bulletin No. 464. 1984.
WDOE 1982, Best Management Practices for Use of Municipal Sewage Sludge. State of
Washington Department of Ecology, Olympia, WA, 1982.
Zabowosid, D. and R. Zasoski. 1986. Toxic Efforts of Sludge: Mushrooms and Wildberries.
Col. Forest Res. Univ. of Washington, Seattle.
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CHAPTER 7
DISTRIBUTION AND MARKETING
7.1 INTRODUCTION
Distribution and marketing refers to the sale or give away of sewage sludge. Distribution and
marketing is similar to land application in that the sewage sludge product is generally applied to the
land, but is different in that with distribution and marketing there is little or no control over the end
use of the product While land application generally has some sort of a "contract mechanism"
between the POTW and the ultimate user which enables control of the end use, often distribution
and marketing sludges are sold or given away for "home use" (either bagged or in bulk form).
Because the POTW cannot be certain (in most cases) that users will comply with application rates
and management practices and because distribution and marketing sludges have a strong likelihood
of human exposure, strict contaminant concentration limits, pathogen controls and labeling
requirements are appropriate.
Many of the benefits and concerns associated with land application apply to distribution and
marketing (D&M) as well. The primary benefits of distribution and marketing relate to the soil
conditioning and fertilizer value of sludge, while its primary concern is the possible exposure of
the public to sludge contaminants either through direct exposure or introduction to the food chain.
Existing regulations allow the use of D&M sludge products for many different applications such as
lawns, shrubs, ornamental plants, and vegetable gardens. Products with moderate to high levels
of contaminants are not recommended for application to vegetable gardens, however, because the
amount of sludge that is applied cannot be controlled as well as it is in large-scale land application
programs. This lack of control raises the possibility that high levels of contaminants might be
applied to a given plot of ground. Sludges with low levels of heavy metals and toxic organic
compounds, therefore, are most appropriate for D&M programs because they pose less of a risk to
home gardeners (EPA 1984a). Three States currently prohibit the use of composted sludge on
vegetables or in home gardens. Five additional States prohibit applying sludge to food chain crops
in land application programs and may similarly restrict sludge use in D&M programs.
7.1.1 PERMITTING RESPONSIBILITIES
At present, while no Federal regulations are specifically tailored to the distribution and marketing
of sludge products, D&M is subject to the same regulations as land application (40 CFR Pan 2S7).
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The 40 CFR Part 257 regulations limit cadmium and PCBs in sludge applied to land used for
producing food-chain crops (Appendix D, 40 CFR Part 257.3-5). Briefly, these regulations set
annual and cumulative loading limits for cadmium, PCBs, and management practices (primarily pH
adjustment of the sludge-soil mixture to pH 6.5 or greater to reduce cadmium mobility). Due to the
practical difficulty for the PQTW in controlling proper application of D&M sludges, permit writers
should consider restricting D&M to sludges with very low concentrations of r-aHnmnm and PCBs,
unless the permit requires the POTW operator to provide a label or handout stating that the sludge
should not be used on food-chain crops. Additional permit recommendations for POTWs using
D&M programs are provided below under "Case-by-Case Recommendations".
The 40 CFR Pan 257 regulations also set pathogen reduction requirements for sludges that are
applied to land surface or incorporated into the soil (Appendix D, 40 CFR Part 257.3-6). Briefly,
pathogen reduction is required whether or not food-chain crops are grown. Among other
conditions, if public access to the sludge application site is controlled for twelve months, the
sludge must only be treated by a "Process to Significantly Reduce Pathogens" (PSRP) (e.g.,
anaerobic digestion, air drying for three months, composting at more than 55°C for four hours,
lime stabilization). If the public will have access to the site within a year of sludge application, or
if the edible portion of a food-chain crop that is grown within eighteen months of application will
contact the sludge (e.g., root crops such as beets and potatoes or low-growing crops such as bush
beans and strawberries), a "Process to Further Reduce Pathogens" (PFRP) is required (e.g.,
composting at more than 55°C for three days or heat drying). While it is possible that a D&M
sludge product will be used in a manner that will restrict public access for twelve months, because
of the uncontrolled use and frequent .human contact that characterize use of these products, sludges
used in D&M programs must be treated by a PFRP, unless the POTW can ensure that the
appropriate public access and food-chain crop restrictions will be met Examples of D&M
programs where PSRP treatment would be adequate are sale of sludge to the operators of a
commercial Christmas tree farm who restrict public access to the sludge application sites, or give
away of sludge to a parks and recreation department for use in areas where the public will not have
access for twelve months.
7.2 TECHNOLOGY C.lJTDF.I JNF-S
Due to the high potential for public contact in distribution and marketing operations, the
technologies applied to the distribution and marketing of wastewater sludge are primarily those
which meet the Federal criteria for Processes to Further Reduce Pathogens (PFRP) as defined in
40 CFR Part 257. If, however, the POTW can provide documentation that appropriate public
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access and food-chain crop restrictions will be met. Processes to Significantly Reduce Pathogens
(PSRP) may be considered. The PSRP criteria and procedures are outlined in Chapter 6. The
PFRP criteria and other design and operational criteria for specific distribution and marketing
technologies are presented later in this chapter. Heat-dried or composted sludges usually meet
PFRP criteria and are commonly used in D& M programs because they have high solids content
and are therefore easily handled by the user (EPA 1984a). Currently most POTWs with D&M
programs compost their sludge.
Composting
In 1983, there were 115 sludge composting facilities in operation in the United States (EPA 1984a,
1985a). Wastewater sludge composting operations entail mixing dewatered sludge with a bulking
agent, such as wood chips, straw, or previously composted sludge, and then allowing the mixture
to decompose aerobically to produce a humus-like product which may be used as a soil conditioner
or fertilizer. The purpose of the bulking agent is to lower the moisture content and to enhance
sludge porosity so that air can be drawn through compost piles (EPA 1984a).
General guidelines for efficient biological processes in composting include the following:
o The incoming sludge should be dewatered and have a solids content in excess of 25 percent
(Sludge Composting and Improved Incinerator Performance, EPA 1984b).
o The sludge-bulking agent mixture should have a volatile solids content greater than 50
percent, a moisture content no greater than 60 percent for static pile and windrow composting
and 65 percent for within-vessel composting, and a pH in the range of 6 to 9 standard units.
Composting is possible at higher pH values though more time is required (EPA 1985b).
o Sludge is normally composted for 21 to 30 days, during which time the temperature typically
reaches temperatures of 55°C or higher (EPA 1984a). The high temperatures (thermophilic
range of 50° to 70°Q provide efficient pathogen destruction. Within-vessel systems require
less composting time, typically 14 to 20 days.
o After composting, the product is allowed to cure for approximately 30 days, and then is often
stored for 60 to 90 days following curing to ensure that the final product is dry and has no
residual odors (EPA 1984a). -Within-vessel systems require less time for curing, typically 20
days (EPA 1984b).
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o The product Is typically screened before or after curing to recover as much bulking agent as
possible.
The three composting methods most often employed in the United States are (1) windrow
composting, (2) static aerated piles, and (3) within-vessel composting.
Window Composting
The window composting method involves placing die sludge-bulking agent mixture in long, open*
air piles. The sludge is turned frequendy to ensure an adequate supply of oxygen throughout the
compost pile and to ensure that all pans of the pile are exposed to temperatures capable of killing all
pathogens and parasites. Daily turning may be required at first when the system has a high oxygen
demand, but turning three times per week should be sufficient thereafter. Windrow composting
can be adversely affected by cold or wet weather and is difficult to control when raw sludge is used
(EPA 1984a).
Static Aerated Piles
For static aerated piles, the sludge-bulking agent mixture is placed in rectangular piles that are
supplied with air by blowers connected to perforated pipes running under the piles. The blowers
draw or blow air through the piles, assuring even distribution of air throughout the composted
sludge. An aeration rate of about 500 cubic feet per hour per ton of dry sludge is needed to
maintain the desired oxygen level of 5 to 15 percent throughout the pile (EPA 1979). The aeration
rate must be adequate to maintain aerobic conditions but may be decreased somewhat to prevent
cooling and maintain adequate temperatures for pathogen destruction. Aeration rates of 300 to 350
cubic feet per hour per dry ton are recommended and 1/3 hp blowers are typically used for up to 30
dry tons of sludge (EPA 1984b). Many static pile systems use 1 to 5 hp blowers that are cycled on
and off (EPA 1985b).
Placing a layer of previously composted sludge over the surface of the pile helps to insulate the pile
and assure that sufficient temperatures are attained throughout the pile. Because the piles do not
have to be turned, and because the sludge is insulated by an outer layer of previously composted
sludge, static aerated piles are less affected by cold and wet weather than windrow composting
(EPA 1984a).
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Within-Vessel Composting
This technique involves placing the sludge-bulking agent mixture in completely enclosed
containers, where environmental conditions such as temperature and oxygen supply can be closely
monitored and controlled. This process is particularly desirable in cold climates or where land is
limited.
The ratio of bulking agent to sludge is typically lower in within-vessel composting than with other
methods. Ratios of bulking agent to sludge range from 3:1 to 4:1. Within-vessel systems have
higher capital cost but allow better process control and often have lower operating cost (EPA
1984b).
Composting Processes to Further Reduce Pathogens
Composting operations must meet the following requirements to qualify as a PFRP as defined in
40 CFR Part 257:
"Using the within-vessel composting method, the solid waste is maintained at operating
conditions of 55°C or greater for three days. Using the static aerated pile composting
method, the solid waste is maintained at operating conditions of 55°C or greater for three
days. Using the windrow composting method, the solid waste attains a temperature of 55°C
or greater for at least 15 days during the composting period. Also, during the high
temperature period, there will be a minimum of five turnings of the windrow."
Monitoring is essential to ensure adequate composting performance. Parameters such as
temperature, air flow, and CQj and/or oxygen levels (with tubes in piles or in the off-gas or
within-vessel systems) should be checked regularly at a number of locations in the compost pile.
Air flow for static aerated piles and particularly for within-vessel systems may be adjusted based
on these measurements. An atmosphere containing 5 to 15 percent oxygen is required throughout
the pile to ensure aerobic conditions (EPA 1985b).
Product maturity may be gauged by pathogen levels or odor, or by tracking a number of other
parameters. These measures include COj, and the evaluation of changes in the caibon:nitrogen
(C:N) ratio (EPA 1984b).
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The composting conditions outlined in the regulations for PSRP and PFRP, when met, reduce all
pathogenic virtues, bacteria and parasites to the desired densities. However, composting under
these conditions may not adequately reduce vector attraction. Generally longer composting tunes
of 7 days or more for within vessel and 17 or more days for static aerated pile and windrow should
be sufficient to fully stabilize the sludge. (EPA 1989).
Heat Drying
Heat drying involves heating the sludge to a temperature of about 80°C for a short period of time
to destroy pathogens and to reduce sludge volume by removing most of the water. Heat-drying is
an expensive process and hence is typically used only where there is a good market for the
resultant product which is a good soil conditioner/fertilizer. Heat-drying is typically accomplished
with either a flash drier or a rotary kiln (EPA 1979). Heat-drying can result in contamination of the
air by particulates and volatile compounds to the point that air pollution control devices may be
necessary. Air pollution control equipment is discussed in Chapter 8. Since moisture creates an
environment favorable for re growth of organisms, heat-dried sludge should not be allowed to
become rewetted.
A heat drying facility must meet the following requirements to qualify as a PFRP as defined in 40
CFR Part 257:
"Dewatered sludge cake is dried by direct or indirect contact with hot gases, and moisture
content is reduced to 10 percent or lower. Sludge particles reach temperatures well in excess
of 80°C, or the wet bulb temperature of the gas stream in contact with the sludge at the point
where it leaves the dryer is in excess of 80°C."
Air Drying
Air drying of sludge is performed by placing sludge on under-drained sand beds, or paved or
unpaved basins in which the sludge is placed at a depth of approximately six to twelve inches
depending on factors such as: moisture content of the sludge; number drying beds available;
dewatering characteristics of the sludge, desired operating routine; and the weather (precipitation
and evaporation rate) expected for the site. Dewatering typically proceeds for a minimum of three
months with average temperatures over 0°C. Covered drying beds are preferred where annual
rainfall rates approach or exceed annual evaporation rates.
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Air drying is a fairly inexpensive and effective means of dewatering sludge. However, air drying
does not qualify as a PFRP see 40 CFR Part 257 Appendix II) and hence air-dried sludge may not
be suitable fa- many distribution and marketing programs without further treatment. Coupling air
drying with pasteurization, gamma ray irradiation, beta ray irradiation, or other approved pathogen
reduction methods can qualify as a PFRP.
Chemical Processes
Chemical processes may be used in conjunction with distribution and marketing operations to
provide the supplemental disinfection necessary to make a process such as air drying qualify as a
PRFP. Chemical processes such as CHEMFIX may also be used to solidify sludge into a cement
matrix. Whether or not a sludge that has been treated by chemical processes is suitable for
distribution and marketing will depend on the chemical properties of the sludge (pH, organic
content, availability of plant nutrients, etc.) as well as the contaminants that remain in the product,
and whether there is any market for this product.
7.3 CHARACTERISTICS OF SLUDGES SUITABLE FOR DISTRIBUTION AND
MARKETING
D&M uses of sludge take advantage of the soil conditioning and fertilizer value of sewage sludge
in a manner very similar to land application of sludge. Consequendy, the exposure pathways and
effects of sludge contaminants are similar for land application.
7.3.1 SLUDGE POLLUTANT CONCENTRATION LIMITS
Federal Regulations
The Federal regulations limit cadmium, PCBs, and pathogens in sludge applied to or incorporated
into the surface of the land (40 CFR Pan 257). Currently, no Federal requirements limit
contaminants in D&M sludge products that are used on non-food-chain crops. (Recommended
limits are summarized below.]
Cadmium
Federal regulations (40 CFR.Pan 2S7. 3 -5) provide a maximum allowable annual application rate
of 0.S kilograms of cadmium per hectare for all food chain crops including tobacco. The
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maximum allowable cumulative loading rate is S kilograms per hectare, (kg/ha). If the soil and the
mixture of soil and sludge has a pH of at least 6.5 standard units, the maximum allowable
cumulative loading is 5 kg/ha for soil cation exchange capacities (CECs) less than S meq/100 g, 10
kg/ha for CECs between 5 and 15 meq/100 g, and 20 kg/ha for CECs over 15 meq/lOOg.
Additionally, the pH restriction may be waived when the sludge contains raftminm at
concentrations of 2 mg/kg (dry weight) or less. It should be noted that with distribution and
marketing since the municipality typically has little control over what is ultimately done with the
sludge, it would be difficult to ensure compliance with the cadmium loading requirements unless
cadmium concentrations in the sludge were very low.
PCBs
The Federal regulation 40 CFR Part 257.3-5 stipulates that sewage sludge containing
concentrations of PCBs equal to or greater than 10 mg/kg (dry weight) must be incorporated into
the soil when applied to land used for producing animal feed, including pasture crops for animals
producing milk. Incorporation of the solid waste into the soil is not required if it is assured that the
PCBs content is less than 0.2 mg/kg (actual weight) in the animal feed or less than 1.5 mg/kg (fat
basis) in the milk.
If the concentration of PCBs is 50 ppm or greater, the sludge is subject to the requirements of the
Toxic Substances Control Act (40 CFR Part 761) and is not appropriate for distribution and
marketing operations.
Pathogens and Disease Vectors
The Federal regulations set pathogen reduction requirements for sludges that art applied to the land
surface or incorporated into die soil (40 CFR Part 257.3-6). Pathogen reduction is required
whether or not food-chain crops are grown. If public access to the sludge application site is
controlled for twelve months, and grazing by animals is controlled for one month, the sludge must
only be treated by a PSRP. If die public will have access to the site within a year of sludge
application, animals for human consumption will graze within one month, or if the edible portion
of a food-chain crop that is grown within eighteen months of application will contact the sludge a
PFRP is required.
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Federal Guidance
In the Summary of Environmental Profiles and Hazard Indices for Constituents of Municipal
Sludge: Methods and Results (EPA 1985a), EPA evaluated and prioritized the hazards posed by
various pollutants for a number of exposure pathways. The incremental index values of toxicity to
humans due to consumption of plants fertilized with sludge, or consumption of herbivorous
animals that have ingested plants fertilized with sludge are presented in Table 7-1. These axe
included to provide insight into the types of contaminants that may cause problems in land
application or distribution and marketing when they are present in high concentrations (incremental
index values less than 1.0 represent negligible toxicity risk or a cancer risk of less than one in one
million).
This list is not directly applicable to permitting, but it points out that wastewater sludges with high
concentrations of certain compounds, such as PCBs, hexachlorobenzene, chlordane,
benzo(a)pyrene, aldrin, dieldrin, and toxaphene should be given careful consideration before a
sludge is used in a distribution and marketing program. Additionally, careful monitoring of the
sludge product for pollutants with high hazard indices would be appropriate. The need for careful
monitoring is especially true for distribution and marketing because the municipality or its
contractor typically have little control over what is ultimately done with the sludge. Lack of control
over use of the sludge product is also an incentive to limit distribution and marketing to sludges
with low levels of heavy metals and toxic organic compounds (EPA 1984a).
Because in most cases the POTW cannot be certain that users will comply with application rates
and management practices and because distribution and marketing sludges have a strong likelihood
of human exposure, strict contaminant concentration limits, pathogen controls and labeling
requirements are appropriate.
The 1984 report of EPA's Intra-Agency Sludge Task Force, Use and Disposal of Municipal
Wastewater Sludye (EPA 1984a), recommends the following maximum heavy metal
concentrations for wastewater sludge composts that are distributed and marketed without
restriction:
Cadmium 12.5 -30 mg/kg (dry weight)
Copper 500 -900 mg/kg (dry weight)
Lead 285 -1,000 mg/kg (dry weight)
Nickel 100 -200 mg/kg (dry weight)
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TABLE 7-1
INCREMENTAL. INDEX VALUES OF TOXICITY TO HUMANS
Toncrty (nam Toxicity trom
Plan! Consumption Anima Ingestion
Compound incremental Index Compound Incremental Index
TC8s
14,933
Wfls
84.933
Hexacftiorobentene
4.293
He*acMorotwuene
1.343
Chlordane
3.100
Chlordane
1,093
Benzo(a)pyrsne
2.360

AkJnrvOieHnn
1.300
CMordane
160
Toxaphene
1.243
DOT
131

AWrtn/DieWm
100
Cadmium
99

DOT
31
Selenium
13.7
Zinc
164
HeptacMor
70
Heptactilor
13
Zinc
3.7
Nckal
119
Mercury
2.73
Lead
82
Cadmmm
29
Selenium
68

Arsenc
1 5

Iron
1 1

Mercury
1 0

Fluonde
04

Source: EPA 1985a.
166
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Revised 12/1/89
Zinc 1,250 -1,800 mg/kg (dry weight)
Mercury 5 mg/kg (dry weight)
To support these recommendations the Task Force cites the 1981 joint EPA, Food and Drug
Administration (FDA) and U.S. Department of Agriculture (USDA) Land Application of
Municipal Sewage Sludge for the Production of Fruits and Vegetables: A Statement of Federal
Policy and Guidance (EPA 1981), the Maryland Environmental Service operating manual for
sewage sludge compost for the Blue Plains wastewater treatment plant (MES 1984) and others.
EPA believes that these recommended limits for composts are suitable for other forms of D&M
sludge products as well (e.g., heat-dried sludges). Thus, with the exception of the lead limit
(discussed in the next paragraph below), permit writers should consider requiring POTWs to meet
the heavy metal concentrations recommended in the 1984 Task Force Report in all D&M sludge
products, unless the POTW provides labels or handouts stating that the sludge product is not to be
used on home vegetable gardens.
Since 1984, EPA has learned more about the subtle, negative effects of lead at very low
concentrations in the blood, and the Agency is concerned about the implications for sensitive
populations which include children and young adults. While it appears that the risk posed by lead
in D&M sludge products is low, particularly when compared to other sources of exposure to lead,
permit writers should consider imposing D&M lead limits at the lower end of the range
recommended in the Task Force report, unless the POTW provides labels or handouts stating that
the sludge product is not to be used on home vegetable gardens.
Another good source of Federal guidance is the 1984 USDA Agricultural Research Service
publication Utilization of Sewage Sludge Compost as a Soil Conditioner and Fertilizer for Plant
Growth. This document recommends maximum sludge metal applications for privately-owned
croplands as shown in Table 7-2. The document cites a 1982 paper by R.L. Chaney of the USDA
as a source for these recommendations (Chaney. 1982).
The guidance on annual and cumulative application limits will help the permit writer determine the
appropriate application rate for D&M sludges (as described more fully below in the section on
recommended management practices, the permit writer should consider requiring the POTW to
include application rate information in labels or handouts given to the user of D&M sludges.)
I At
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Revised 12/1/89
TABLE 7-2
MAXIMUM METAL APPLICATION1 (KG/HA) FOR UNAMENDED SOIL AT
INDICATED SOIL CATION EXCHANGE CAPACITY (CEC)

Metal
OA
Szll
15
Cadmium
Nickel
Copper
5
50
125
250
500
10
100
250
500
1,000
20
200
500
1,000
2,000
Zinc
Lead
Cadmium limits have the force of regulation (40 CFR Part 257). Annual Cd application should
not exceed 0.5 kg/ha. All recommendations apply only to soils adjusted to pH 6.5 when sludge
is applied and maintained at no less than pH 6.5 thereafter.
For toxic organic compounds in sludges applied to lands, the Federal government has only set the
regulatory limits for PCBs described above. The Intra-Agency Task Force report recommends that
distribution and marketing is most appropriate for sludges with low levels of toxic organic
compounds. However, it does not provide any recommended maximum contaminant
concentrations levels. The 1981 joint EPA/FDA/USDA policy on sludge use for producing fruits
and vegetables recommends a 10 mg/kg PCB concentration limit. This guidance assumes that
carrots are washed and peeled prior to consumption.
State Requirements
Pollutant Concentration Limits
Specific pollutant concentration limits addressed in State regulations are provided in Appendix E,
Table E7-1. Stale information is taken from the EPA sludge database (EPA 1987). Permit writers
should verify concentration limits with the State regulatory agency to ensure that the limirc are
current
Sludge Loading Limits
Seven States have loading limits for distribution and marketing. The reported loading limits
include*. 10 dry tons per acre with cadmium levels less than 25 mg/kg (Illinois); site approval
2meq/100 g.
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Revised 12/1/89
requirement if over 100 yd3 is to be used (New Jersey); 2 cubic yards per year-person
(Pennsylvania); a notation that loading limits are required for uncontrolled use (Texas); and 5 to 20
kg/ha of cadmium on food chain crops (Washington). Virginia and New Hampshire also have
restrictions on sludge loading.
Case-hv-Case Recommendations
The permit writer should review applicable State contaminant concentration limits for sludges used
in D&M programs (Table 7-3). For the heavy metals addressed by EPA, the median and mode of
State limits fall within the range of limits EPA recommends. For PCBs, the median and the mode
of eight States' limits is 2 mg/kg - 20 percent of EPA's management practice threshold for lands
used to produce feed for food-chain animals and recommended limit for fruit and vegetable
production. Nationally, EPA recommends that permit writers consider requiring D&M sludges to
meet a 10 mg/kg PCB concentration limit For POTWs in the seven States with stricter PCB limits
(California, Maryland, New Jersey, New York, Ohio, Texas and Wisconsin), permit writers
should consider imposing the State requirement but should consult with State officials to determine,
the basis for the more restrictive limit
At this time, EPA defines a high quality sludge as one with heavy metal concentrations that fall
within the ranges recommended in the 1984 Task Force Report (as noted above, lead
concentrations should fall below the low end of the recommended range). PCB concentrations
should not exceed 10 mg/kg (dry weight). However, if a POTW provides the user of its D&M
product with a label (bagged product) or a handout (bulk distribution) that clearly states that the
product is not to be used on food-chain crops, EPA believes that heavy metal and PCB
concentrations could safely exceed the levels recommended for high quality sludges by a factor of
two or three Oead concentrations should not exceed the 1984 recommendation by more than a
factor of 1.5).
Because of the lack of control over the end use of D&M sludges, permit writers should opt for
sludge quality limits rather than loading restrictions. Where this is not practical the permit writer
should require the POTW to label the sludge product with application or loading specifications
based on sludge quality. If pollutant concentrations are excessively high, the permit writer should
prohibit the uncontrolled distribution and marketing of the sludge.
-------
TABLE 7-3
SUMMARY OF CURRENT STATE SLUDGE CONTAMINANT LIMITS FOR
DISTRIBUTION AND MARKETING
No of States Max Product Cone, (mg/kg)
Contaminant
Regulating
Median
Mode
Range
Aldnn/Oieldnn
1
1
1
' 1
Cadmium
10
23
25
2-40
Chlordane
1
.1
.1
1
Chromium
2
1,000
1,000
1,000
Copper
8
800
500
500-1,200
DDT/DDE/DDD
1
25
0 25
25
Heptachlor
1
1
1
V 1
Lead
10
500
500
300-4,800
Lindane
1
1
1
1
Mercury
5
5
5
5-10
Molybdenum
1
10
10
10
Nickel
8
200
200
100-1,250
PCB
8
2
2
5-10
Toxaphene
1
1
1
1
Zinc
8
1,663
1,250
1,000-2,500
Source EPA 1987
170
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Revised 12/1/89
7.3.2 PHYSICAL PROPERTIES
Wastewater sludge should be dewatered prior to applying a process such as composting in order to
assure a product suitable for distribution and marketing. Six States are reported to require sludge
dewatering and five States are reported to require stabilization for distribution and marketing
operations (Table E7-4, State Sludge Treatment/Management Requirements).
7.4 OPERATING CONDITIONS AND MANAGEMENT PRACTICES
This section contains Federal regulations and guidance, State requirements and case-by-case
recommendations for the permit writer to use in developing permit conditions for the operating
conditions and management practices for distribution and marketing.
Distribution and markenng management practices reported by the States are presented in Table E7-
2, State Management Practice Requirements, and Table E7-3, State Site Specific Requirements.
7.4.1 SURFACE WATER PROTECTION
Federal Regulations
A facility or practice shall not cause a discharge of pollutants that is in violation of the NPDES
regulations, a discharge of dredged or fill material thai is in violation of Section 404 of the CWA or
cause non-point source pollution (40 CFR Part 257.3-3).
Federal Guidance
Runoff from compost facilities should be collected and treated. Sludge treatment facilities and
sludge disposal sites for treated sludge must not cause non-point source pollution of waters of the
United States or violate an areawide or Statewide water quality management plan that has been
approved under Section 208 of the Clean Water Act, as amended.
State Requirements
Seven States report requirements for the minimum distance to the nearest surface water (Table E7-
3). The reported requirements were a minimum distance of 200 feet (Illinois), 200 feet and not in a
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Revised 12/1/89
water supply watershed (Rhode Island), 50 to 200 feet (Utah), SO feet (Virginia), 25 feet for a
drainage ditch, and SO to 300 feet to a stream depending on its classification (Maryland).
Eleven States require run-off control (see table E7-2).
Case-bv-Case Recommendation
The permit writer should evaluate whether the imposition of buffer zones or run-off collection
structures are necessary to protect surface water.
7.4.2 GROUND-WATER PROTECTION
Federal Regulations
Federal regulation (40 CFR Part 257.3-4) forbids the contamination of existing or potential
underground drinking water sources by the disposal of non-hazardous solid waste, including
sludges generated by treatment of domestic sewage. Maximum ground-water contaminant levels
are specified in Appendix I of 40 CFR Part 257.
Federal Guidance
Composting operations (mixing, composting, curing, and storage) should always be performed on
impervious (i.e., concrete or asphalt) surfaces to prevent migration of leachate to the ground-water.
Leachate collection facilities and/or ground-water monitoring should be considered for facilities
where there is potential for contamination.
State Requirement*
Eight States report requirements on an acceptable distance between composting facilities and
nearby wells. The reported requirements for a minimum distance to a drinking water well range
from 100 feet in Virginia to 1,000 feet in Rhode Island.
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Revised 12/1/89
7.4.3 STORAGE
Federal Guidance
A significant amount of storage is provided by the composting operation itself. However, 6 to 9
months of additional storage may be necessary depending on site climate, seasonal fluctuation in
the compost market, and the potential need for further drying or reduction of odors. To maintain
product quality, storage facilities should protect the finished compost from contamination and
rainfall that would create run-off or leachate (EPA 1984a).
Some storage of sludge prior to composting may also be necessary to facilitate system operation
and to provide a back-up in the event of system problems.
State Requirements
Eight States have requirements for storage as a management practice (EPA 1987). States which
specify a minimum storage time are New Hampshire (30 days), New York (50 days), and Virginia
(60 days).
7.4.4 BUFFER ZONES/ACCESS CONTROLS
Federal Regulation
Federal regulations state that a facility shall not allow uncontrolled public access so as to expose the
public to potential health and safety hazards.
Eleven States require buffer zones/access control for compost facilities (see Table E7-3). The State
of Nevada requires a minimum buffer of 500 feet to the property line and 1000 feet to the nearest
road. The State of Rhode Island requires a minimum distance of 400 feet to the nearest dwelling.
Three other States reported minimum distance buffer requirements.
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Revised 12/1/89
7.4.5 CROP USE LIMTTS
State Requirements
Thirteen States reported crop use limits (Table £7-3). These limits apply primarily to human food
chain crops. The only reported numerical limit was a Maryland requirement that a product with
over 45 percent iron (dry weight basis) must be labeled to warn against use on pasture. An
example label is seen in Appendix C.
Case-bv-Case Recommendations
Information gathered by EPA (EPA 1987) shows that three States (New Hampshire, Arkansas and
Minnesota) prohibit use of D&M sludge products on vegetables or in home gardens. Three
additional States prohibit applying sludge to home gardens (Connecticut), to fruits and vegetables
(Oregon), or on all food-chain crops (Rhode Island) in land application programs, and may
similarly restrict sludge use in D&M programs. While States may place whatever restrictions on
sludge use they believe to be appropriate, as a national recommendation, EPA supports the use of
high quality sludges by home gardeners on all food-chain crops including fruits and vegetables.
7.4.6 OTHER CONDITIONS
Caso-bv-Case Recommendations
Allowing only specific contractors to distribute and/or market sludge products would provide much
better control over the final use than would general distribution to the public. Although this
requirement may limit the sis of the product market for the municipality, it may be appropriate
nevertheless where variability of sludge quality makes the screening or qualification of D&M users
a wise precaution in order to assure compliance with applicable requirements and the safe use and
disposal of the product
7.5 MONITORING. REPORTING. RECORD KEEPING ANT>1 AftnjNCi
Monitoring the sludge, the treatment process, and the sludge product quality is essential in a
distribution and marketing program from both an operational and marketability standpoint as well
as for protection of the environment and the public health. The primary concern with D&M
programs is contaminants in the sludge product and the subsequent public contact with the product
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Revised 12/1/89
From a regulatory standpoint, heavy metals, toxic organics and primary pathogens such as viruses,
bacteria, protozoa, and parasites, are the major public health concerns.
The success of a D&M program is largely influenced by the ability to produce a consistent product
quality, both physical (e.g., consistent moisture content) and chemical (e.g., consistently low
contaminant concentrations). Producing a consistent product involves periodic monitoring of the
sludge quality, the treatment process, and the final sludge product.
7.5.1 POLLUTANT CONCENTRATION MONITORING
Since composting is a biological process, it does not eliminate heavy metals. Any metals in the
sludge will be present in the compost in virtually the same quantities although some metals and
volatile organic compounds may be driven off in the off-gas from a heat-drying process. The
distinction to be made between quantity and concentration is thai while composting may cause the
concentration of a contaminant to change, because bulking agents have been adrfoH and the
moisture content has changed, the quantity of a conservative contaminant will remain essentially
the same as a given mass of sludge undergoes composting. The heavy metals and other
contaminants of concern in D&M sludge products were discussed in Section 7.2
Federal Regulations
The current regulations in 40 CFR Pan 122.44(c)(2) require sludge monitoring and reporting at a
frequency dependent upon the nature and effect of the permittee's sludge use or disposal activities,
but at least once a year for every pollutant limited in the permit. This means that if the permit
contains a limit for PCB's for example, the permittee, must monitor its sludge at least annually for
this pollutant
Federal Guidance
The Sewage Sludge Interim Permitting Strategy recommends annual monitoring of the 126 priority
pollutants as well as more frequent monitoring of the pollutants for which numeric limits have been
proposed in the 40 CFR Part 503 Technical Sludge Standards. For the reuse practice of
Distribution and Marketing, these proposed 40 CFR Part 503 pollutants include:
Aldrin/Dieldren
Benzo(a)pyrene
Arsenic
Cadmium
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Revised 12/1/89
Chlordane
Copper
Heptachlor
Hexachlorobutadiene
Lindane
Nickel
Selenium
Zinc
Chromium
PCBs
Toxaphene
DDT/DDE/DDD (total)!
Hexachlorobenzene
T
Mercury
It is suggested that heavy metals and toxic organics be monitored initially in the sludge to determine
the suitability of the sludge for distribution and marketing, and to decide if its use or distribution
should be restricted because of the concentration levels of certain contaminants.
State Requirements
Ten States require sludge and/or sludge product quality monitoring. Three States specify
parameters to monitor.
One State (Rhode Island) requires an annual EP toxicity test on the sludge.
Two States specify monitoring frequency. California bases sampling frequency on the size of the
treatment plant. Monthly monitoring of the compost is required by Ohio. Each of the State
monitoring programs for distribution and marketing are described in Table E7-5. State monitoring
and reporting requirements fa* sludge and compost are provided in Table E7-5.
Case-bv-Case Recommendations
The contaminants Hated below should be considered in any sludge or sludge product quality
monitoring program.
Cadmium Nickel Cyanide Pathogens
Chromium Zinc PCBs Salmonella
Copper Nitrogen Sodium
1 DDT-Z2-Bis(chlorophenyl)-1,1, l-trichkxocthane
DDE-lJ-Bi^chkirophenyl^-dichkxoethane
ODD-1.1 -Bis(chk*ophcnyl)-22-
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Revised 12/1/89
Lead
Mercury
Phosphorus BOD
Potassium pH
Permit writers should require monitoring for limited parameters in the sludge product rather than
the sludge used to make a product. Because of die limited control over use of D&M products and,
typically, the frequent human contact with these materials, monitoring should be required more
frequently than is generally recommended
7.5.2 TREATMENT PROCESS MONITORING
Federal Guidance
During the composting process, temperatures should be monitored regularly until temperatures
recorded in the compost (or off-gas from a heat-drying process) exceed the level and duration
required for adequate pathogen destruction.
Oxygen should also be monitored periodically to insure that aerobic conditions are maintained.
Operating parameters of other pathogen reduction processes should also be closely monitored.
Research has shown pathogen re growth to occur in compost and drying facilities. This kind of a
problem can be taken care of by additional composting, covering of the compost and additional
monitoring of total coliforms.
Four states have temperature monitoring requirements. As noted in the previous discussion of
technologies and operating guidelines, temperature monitoring is essential for composting and, of
course, heat drying. Temperature monitoring is necessary to demonstrate compliance with the
Federal requirements for Processes to Further Reduce Pathogens (PFRP).
7.5.3 SOIL MONTFORING
Nebraska, which requires semiannual soil analysis for leachate detection, was the only State to
report a soil analysis requirement
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Revised 12/1/89
7.5.4 REPORTING AND RECORD KEEPING
Federal Requirements
The recently promulgated revisions to the NPDES permitting regulation (54 FR 18716) require the
permittee to report monitoring results with a frequency dependent upon the nature and effect of the
sewage sludge use or disposal practice, but in no case less than one year. These revisions also
require that records of monitoring required by the permit for the permittee's sewage sludge use and
disposal activities must be retained for a period of at least 5 years [40 CFR Pan 122.21(p)].
State Requirements
Fourteen States require some form of reporting and record keeping. Most States require records
detailing who received the sludge, how much was received, and what the intended uses were.
Some States require maintenance of all sludge and sludge product analytical records. Oklahoma
requires all quantity, destination, quality, and use agreement records to be held for 5 yean.
Reporting frequency varies from State-to-State and consists of monthly, quarterly, annual, and
periodic reporting schedules (See Table E7-5).
Case-bv-Case Recommendation<;
POTWs should be required to report the amount of product distributed in bulk form and in bags.
Permit writers should also consider requiring POTWs to keep a log of persons or entities that
receive more than 10 cubic yards of material per month (approximately die amount that would fill
two large dump trucks).
7.5.5 PRODUCT LABELING
Federal Guidance
At a minimum, labels for bagged sludge or sludge products for D&M should specify the nitrogen,
phosphorus, and potassium content of the sludge or sludge product as a percent of the sludge or
sludge product's total weight The labels do not have to specify the concentration of contaminants
in the sludge but should state that the information is available upon request The POTW (or
retailer) should also be required to provide this information upon demand. The label should clearly
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Revised 12/1/89
state any unacceptable uses of the D&M product and recommend application rates. See Appendix
C for examples of D&M product labels.
State Requirements
Sixteen States require the labeling of D&M sludges. A compilation of these requirements is listed
below.
o Identify contents as a sludge product
o Provide an analytical identification of contents (e.g., N, P, K, metals)
o Place any necessary warnings or cautions in an obvious place
o List restrictions on use
o Recommend safe uses and application rates
West Virginia requires that the product be clearly labeled to indicate that it is not recommended for
use in vegetable gardens.
Case-bv-Case Recommendations
All bagged D&M products should be labeled. For products that are marketed as fertilizers (e.g.,
heat-dried sludge) rather than as soil conditioners (e.g., compost), labels should specify the
nitrogen, phosphorus, and potassium content of the product as a percent of the total weight. If the
product contains concentrations of contaminants exceeding the guidance for unrestricted
distribution, the label should state that the product should not be used on vegetable gardens.
When writing a permit for a POTW that markets sludge products that are not suitable for home
vegetable gardens (e.g., sludges with high levels of metals and PCBs), the permit writer should
consult Tables 7-4 through 7-8. These tables show, for a given sludge application rate and a given
heavy metal concentration, how many years a sludge product could be applied before exceeding the
guidance on cumulative metal loadings to privately owned cropland. Typical application rates and
sample calculations (for interpolating between the given application rales and metal concentrations)
are also provided. If a sludge product contains contaminants at levels that could potentially
preclude future use of the site as cropland after ten typical annual applications, or a single
application to establish a soil (i.e., provide a nutrient base) followed by five yean of use at
maintenance rates, the permit writer should consider requiring that the label state:
-------
TABLE 7-4
YSAflS Of APPLICATION IN SI UNITS FOR CADMIUM ANO NICKEL
Yeare of Sludge Application at
^ tonnashectare o) Heat-Oned Sludge
1 7 tonneohectare of Composted Sludge
Concentration of Metal m 04M Product (mg/kg)
Metal 600 400 200 90 60 30
Years of Sludge Application at
3 tonnes/hectare of Heat-Oned Sludge
3 tonnes/hectare of Composted Sludge
Concentration of Metal m 04M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 8 1 2 29 39 83 166
Ni 63 129 230 399 833 1.666
Cd 2 4 8 18 27 33
Ni 27 41 83 189 277 533
Years of Sludge Appieanon at
6 tonne^hectare of Heat-Oned Sludge
to tonne^hectare of Composted Sludge
Concentration of Metal m 0AM Product (mg/kg)
Metal 600 400 200 90 60 30
Years o< Sludge Application at
t3 tonnes/hectare of Heat-Oned Sludge
23 tonnes/hectare of Composted Sludge
Concentration of Metal m OAM Product (mg/kg)
Metal 600 400 200 90 30 30
Cd 1 2 4 9 13 27
Ni 13 20 41 92 138 277
Cd 0 0 1 3 3 11
Ni 3 8 16 37 39 111
Years of Sludge Application at
30 tonnes/nectars of Heat-Oned Sludge
50 tonne^hectare of Composted Sludge
Concentration of Metal in CAM Product (mg/kg)
Metal 600 400 200 90 60 30
Years of Sludge Application at
60 tonnes/hectare of Heat-Oned Sludge
tOO tonne^hectare of Composted Sludge
Concentration of Metal m MM Product (mgrtig)
Metal 600 400 200 90 60 30
Cd 0 0 0 1 2 3
Ni 2 4 8 18 27 39
Cd 0 0 0 0 1 2
Ni 1 2 4 9 13 27
Years of Sludge Appieaoon at
180 tonnes/hectare of Heat-Oned Sludge
300 tonnertwetare of Composted Sludge
Metal 600 «00 200 90 60 30
Yeara of Sludge Appkcawn at
300 tonnetfiectare of Heaf-Oned Sludge
300 tonnes/Hectare of Composted Sludge
Concentration of Metal
Ornamentals and Nursery CropaCaUMUt »W-4S0 tonnes producv*ectare (90-214 tona/aere)
Ornamentals and NuraaryCfOparttontananc* ifl-37 tonrwe product/hectare (8-18 torts/acre)
8aaad on recommended appfccaoon mm tor Mferganrta. a wioery avariaOtt neat-dried tudga, type* oaw raaaa tar heal*
dned sludge are;
Lawn Mamenance: up to 0 tormee product/hectare (2.7 ion«acr»-yr)
Ornamental* uplo2 4 tonne* product/hectare U i ton*acr»-yr|
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TABLE 7-9
YEARS OF APPLICATION IN SI UNITS FOR COPPCR, LEAO, AND ZINC
vean oi Sludge Application at
i tonneahecare of Heai-Oned Sludge
i 7 lonneaHectara of Composted Sludge
ConcenMlon of MaW m OAM Product (mg/kg)
Years of Sludge Application at
3 tonnes/hectare of Heai-Oneo Sludge
5 tonnes/hectare of Composted Sludge
Concentration of Metal m O&M Product (mg/ttg)
Met* 5400 3800 2700 1800 1900 '000 900
Metal 9400 3600 2700 1600 1500 1000 900
Cu 23 3* 4« 69 83 123 138
Pb 92 138 1 83 277 333 500 553
Zn 23 34 48 69 83 123 138
Cu 7 11 15 23 27 41 48
Pb 30 48 61 92 ill 168 183
Zn 13 23 30 48 S3 83 92
Years of Sludge Apptcason at
8 tonnea/nectare of Heat-Oned Sludge
10 tonneshectars of Compoatad Sludge
Concentration of Metal in O&M Product (mgrtig)
Year* of Sludge Appbcaoon at
15 tonnes/Hectare of Heat-Oned Sludge
23 tortne^hectare of Composted Sludge
Concentration of Metal m DAM Product (mgftg)
Metal 5400 3600 2700 1800 1500 1000 900
Metal 5400 3800 2700 1800 1500 1000 900
Cu 3 5 7 11 13 20 20
Pb 15 23 30 48 53 33 92
Zn 7 11 15 23 27 *1 48
Cu 1 2 3 4 3 8 9
Pb 8 9 12 18 22 33 37
Zn 3 4 8 9 11 18 18
Years of Sludge Application at
30 tonnesrtiectare of Heat-Oned Sludga
50 tonnes/Hectare of Composted Sludge
Concentration of Metal m 04M Product (mg/*g>
Years of Sludge Application at
SO tonnea/hectare of Heat-Oned Sludge
100 tonnesrtiectare of Compoatad Sludge
Concentration of Mew m MM Product (mykg)
Metal 5400 3600 2700 1800 1500 1000 900
Metal 5400 3600 2700 1800 1500 1000 900
Cu 0 1 1 2 2 4 4
Pb 3 4 8 9 11 18 18
Zn 1 2 3 4 5 8 9
Cu 0 0 0 112 2
Pb 1 2 3 4 5 8 9
Zn 0 1 1 2 2 4 4
Years of Sludge Apphcaaon at
180 tonneaftectare of Heat-Oned Sludge
300 connesrtiecwe of Composted Sludge
Concentration of Metal m 04M Product fmgftg)
Years of Sludge Appfcca&on at
300 tonneaftectare of Heat-Oned Sludge
500 tonneaftectare of Composted Sludge
Concentration of Metal in OftM Product (mg/kg)
Metal 5400 3800 2700 1800 1500 1000 900
Metal 5400 3600 2700 1800 1300 1000 900
Co 0000000
Pb 0 0 1112 3
Zn 0 0 0 0 0 11
Cu ooooooo
Pb 0000111
Zn 0000000
NOBS
Compoata tyfkcaNy conoan 40-50% moNU* by «wgm. TNa table assumes a 60% sohds oonwnL 0 5% wal Nrtrogen ano a
weigm of 28 pound* ptr cube loot
Heat-dnad jludgw nay oancn 3-10% moat** by **ght. This table assumes a 100% soMa content and 6.0% total Nitrogen.
Baaed on racmimwndtJ ^pimon mm kr Concyo. a
Ornamentals and Nurasry CfOpWMwwanoe 18-37 tonne* product/hectare (8*16 tona/acra)
Saaad on recommended apptcanon «m tor Mtar^anna. a widely avatiM han-dnad sludge, type* suramin rata* lor heai-
dned *udge are:
Latm Mamsnancec up to 6 tonnes producvboctara (0.83 tonai'acra-yO
Ornamental* up u 2.4 lonnaa producvTwctare (t t tontfacre-yr)
-------
TABLE 74
YEARS 0* APPLICATION IN ENGLISH UNITS FOR CAO Mill M AND NICKEL
Yeare o( Sludga Appkcatxm at
3 lyiOO sq ft of Heat-Oned Sludga
S lb/100 sq It of Composted Sludge
Concentration ol Metal m OAM Product (mg/kg)
Metal 600 400 200 90 60 30
Years of Sludge Application at
S ib/iOO sq It of Heat-Oned Sludge
8 ityiOO sq ft ot Composted Sludge
Concentration of Metal m O&M Product (mg/kg)
Metal 600 400 200 90 60 30
Cd 3 6 17 37 96 113
Ni 96 89 170 379 968 1.137
Cd 3 9 10 22 34 68
Ni 34 31 102 227 341 682
Years of Sludga Application at
19 tiytoo sq (t of Heat-Oned Sludge
29 l»yi 00 sq ft ol Composted Sludga
Concentration of Metal in O&M Produci (mg/kg)
MeW 600 400 200 90 60 30
Years of Sludge Application at
30 ib/iQO sq ft of Heat-Oned Sludge
90 lb/100 sq ft of Compostad Sludge
Concentration of Metal in O&M Product |mg/kgi
Metal 600 400 200 90 60 30
Cd 1 1 3 7 11 23
Ni 11 17 34 79 113 227
Cd 0 0 1 3 9 11
Ni 3 8 17 37 96 113
Years of Sludge Apphcanon at
60 W100 sq ft of Heat-Oned Sludga
100 i&nOO sq ft of Composted Sludge
Concentration of Metal «i 04M Product (mg/kg)
Metal 600 400 200 90 SO 30
Yean of Sludge Appbcaoon at
190 lb/100 sq ft of Haat-Oned Sludge
290 lb/100 sq ft of Compostad Sludga
Concentration of Metal m 0AM Product (mykg)
Metal 800 400 200 90 60 30
Cd 0 0 0 1 2 9
Ni 2 4 8 18 28 56
Cd 0 0 0 0 1 2
Ni 1 1 3 7 11 22
Years of Sludge Application at
420 itviOO sq It ol Heat-Oned Sludge
700 DV100 sq ft of Composted Sludga
Concentration of Metal m 0AM Product (mgfkg)
Years of Sludge Apptcaaon at
600 to/100 sq ft of Heat-Oned Sludge
t .000 to/iOO sq ft of Compostad Sludga
Concannation of Metal «t 04M Product (mg/kg)
Metal 600 400 200 90 60 30
Metal 600 400 200 90 80 30
Cd 0 0 0 0 0 0
Ni 0 0 1 2 4 8
Cd 0 0 0 0 0 0
Ni 0 0 0 12 9
Notac
Compoaa typcafy contest *0-60% raakn by wqnt Tta taoia atwriM a 60% sofcds comer*. 0 5% tow Nitrogen and a
weight of 28 pound* par o£c tool
Heat-dned sludgea ma* oontasi 9-10% moMur* by waqfu. This taM asaumes a 100% sohda content and 9.0% total Nircgan.
Based on recommendatf app8ra*rw mm tor Compgro, a mdety av«UM sewage sludge compost. type* compoai apctcatwn
rates anc
Lawv€stattaft{flna-*Tiet*gr>ratoaecl*aaonioOu*> a fertile so*): 223480 to product par 100 sq ft
LawrvMamsnanoac 33-119 to product par lOOsq ft
Ornamentals and Nunaiy CnpafiaUMart 2U-M2 to product par too sq ft
Ornamentals and Nursery C/WWamenanee: 38-70 to product par 100 sq ft
Baaad on recommended appteaaon rates tor Mfefganae, a «ndety avaMMa nwt-dnad sludga. typeal anptcaaon raiaa tor neat-
drod sludge are:
Lawi ManwnancK up to 12 to product par too sq ft-yr
Ornamentals: up to 9 to product par tOO sq ft-yr
-------
TABLE 7-7
YEARS Of APPLICATION IN ENGLISH UNITS FOR COPPER, LEAD, AND ZINC
Years at Sludgs Appfccaaon at
3 nytOO sq ft at Heat-Oned Sludge
9 bnOO sq ft of Composed Sludge
ConoenMton Of Mew «l OAM Product producviOO sq ft
LwvMartananoat 55-1191) productfiOO sq ft
Ornamentals and Nursery CropttCnafikalt 266-962 lb productM 00 sq ft
Omementaia and Nuraary Cope/Martenenoe: 36-76 fc producviOO sq ft
Saeed on lecommended appteaaon ram lor Mftygw*. a widely avertable hea-dned tfudge. lypcal appecaaon rvm tar neat-
dned sludge arc
Law Mamnanoe: uo to 12*) producviOO sqft yr
Omementaia: up to 91> producviOO sq ft-yr
-------
TABLE 7-6
SAMPLE CALCULATIONS FOR YEARS OF APPLICATION
SI Unit Tables English Unit Tables
Parameters
1. Sludge Loading Rate
2. Parameter concentration
3. Parameter cumulative loading limit
4. Parameter deposition Rate
5. Years of use at that rate
=(Siie fife/Annual loading)
1 tonne/hectare-yr
30 mg Cd/kg sludge
5 kg Cd/hectare
1 tonne/ha-yr x 1000 kg sludge/tonne
x 0.0006 kg Cd/kg sludge
» .03 Cd/hectare-yr
(S kg Cd/ha)/(.03 kg Cd/ha/yr)
» 166.86 > 166 yr
(rounded down to next Integer)
3 lb/100 sq ft-yr
30 mg Cd/kg 3ludge
5 kg Cd/ hectare
3 lb/100 sq fl x 0.045359 kg/lb
x 0.00003 kg Cd/kg sludge
=0 000041 kgCd/100 sqtt-yr
(5 kg/ha x ha/107640 sq ft)
/(.000041 kg Cd/100 sq ft-yr)
•113.29 > 113 yr (rounded down)
184
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Revised 12/1/89
The manufacturer/discributor certifies that this product meets the requirements specified under
Federal regulations at 40 CFR Part 2S7 and has been tested using U.S. EPA protocols.
Where the user desires to preserve future, private use of a site for producing crops, this
product should not be applied more than times at a cumulative amount of tonnes per
hectare ( tons per acre or pounds per 100 square feet).
All D&M product labels should provide directions for use and recommended application rates.
Appendix C contains a number of labels currently in use that provide good information. In
addition, permit writers should consider requiring that labels include a statement similar to the one
below:
As with any fertilizer or soil conditioner, this product should be used in a manner that will
prevent it from washing into sewer drains or surface waters.
Any D&M product distributed to the public in bulk form (i.e., not bagged) should be accompanied
by a flyer that contains the same information recommended for D&M labels. The POTW should
also take measures to ensure that any redistributor or broker of the D&M product meets these
recommendations for labels and flyers.
REFERENCES
Chaney 1982. Fate of toxic substances in sludge applied to cropland. International Symposium
on Land Application of Sewage Sludge, Tokyo, Japan, 1982.
EPA 1979. Process Design Manual for Sludge Treatment and Disposal. U.S. Environmental
Protection Agency, EPA 625/1-79-011, September 1979.
EPA 1981. Land Application of Municipal Sewage Sludge for the Production of Fruits and
Vegetables: A Statement of Federal Policy and Guidance. SW-905, U.S. Environmental
Protection Agency.
EPA 1984a. Environmental Regulations and Technology: Use and Disposal of Municipal Waste
Water Sludge, U.S. Environmental Protection Agency, EPA 625/10-84-003.
18S
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Revised 12/1/89
EPA 1984b. Sludge Composting and Improved Incinerator Performance, EPA Seminar,
Columbus, Ohio, July 11 and 12, 1984. U.S. Environmental Protection Agency, Municipal
Environmental Research Laboratory, Cincinnati, Ohio.
EPA 1985a. Summary of Environmental Profiles and Hazard Indices for Constituents of
Municipal Sludge; Methods and Results, U.S. Environmental Protection Agency (OWRS), July
1985.
EPA 1985b. Composting of Municipal Wastewater Sludges. U.S. Environmental Protection
Agency, EPA 625/4-85-014,1985.
EPA 1987. State Requirements for Sludge Management, U.S. Environmental Protection Agency,
Office of Municipal Pollution Control and Office of Water Enforcement and Permits. Washington
D.C. (Revised 1987)
EPA 1989. Environmental Regulations and Technology: Control of Pathogens
in Municipal Wastewater Sludge. U.S. Environmental Protection Agency, EPA
625/10-89-006. October 1989.
MES 1984. Operations Manual for Sewage Sludge Composting: Blue Plains Wastewater
Treatment Plant. Maryland Environmental Service, Annapolis MD, 1984.
USDA 1984. Use of Sewage Sludge Compost as a Soil Conditioner and
Fertilizer for Plant Growth. U.S. Department of Agriculture, Agricultural
Information Bulletin No. 464. 1984.
186
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Revised 12/1/89
CHAPTER 8
INCINERATION
8.1 INTRODUCTION
Chapter 8 provides the permit writer with a description of sludge combustion practices at POTWs,
and also summarizes Federal requirements and guidance and State requirements pertaining to
sludge incineration. The disposal of ash resulting from incineration is not covered by this
Guidance Manual because ash is a solid waste that will continue to be regulated under 40 CFR Pan
257 (or under 40 CFR Part 258, once promulgated, if disposed of in a municipal landfill).
Appendix E, Tables E8-1 through E8-3 present State requirements in more detail.
Based on a recent EPA survey, 166 POTWs currently own or operate sewage sludge incinerators
in the United States. While the aggregate human health effects of sludge incineration appear to be
low, information gathered by EPA indicates that of the methods employed to re-use or dispose of
sludge, incineration exposes the greatest number of people to levels of pollutants that may, over
many years of exposure, lead to adverse health effects. Studies performed in developing EPA's
proposed technical standards for sludge incineration indicate that about 140,000 people are
exposed to theoretical Most Exposed Individual Risks of 10' or greater. For this reason, the
Interim Permitting Strategy states that incinerators should be considered a "priority" (i.e., Class I)
for permitting purposes when available information shows cause for concern.
A complexity immediately arises when permit writers begin writing NPDES permits for POTWs
that incinerate the sewage sludge generated by wastewater treatment The Dean Water Act
provides the mandate for EPA to focus attention on potential threats to public health and the
environment (e.g., sludge incinerators) while the expertise in regulating emissions from these
sources rests with EPA, State or local officials who work in programs that have traditionally
implemented the Clean Air Act Regulating a POTWs incineration activities may be the most
difficult multi-media responsibility assigned to the NPDES permit writer.
8.1.1 PERMITTING RESPONSIBILITIES
Regulation of air emissions at the National level is complex and often comprised of different
requirements under different programs covering various pollutants, geographic areas, and
industries. Sludge permit writers should work with State and regional air management authorities
to ascertain which, if any, air emissions limits apply to the POTWs* incinerators. In some cases
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Revised 12/1/89
sewage sludge incinerators may not be permitted. This will depend on the facility's age. Any
incinerator which began operation before the air regulations were promulgated is not required to
have a permit unless it is planning major modifications. In addition, many of the early incinerator
permits do not contain emission limits or operation requirements. Whether emissions are formally
limited through an air permit or not, NPDES permit writers are responsible to ensure that the
ultimate disposal of sewage sludge is carried out in a manner that does not pose risks to public
health and the environment This will require considerable flexibility and coordination between
offices of water and air regulation to establish institutional arrangements to address sludge
incineration. At a minimum, for Class I POTWs, the NPDES permit writer should:
o Identify in the documentation accompanying the NPDES permit for a POTW that uses sludge
incineration, the existing Federal and State requirements for sludge incineration that apply to
the facility, or reference the air permit containing such requirements; and
o Consider writing additional recommended conditions into the permits for these POTWs
(e.g., as suggested in this guidance). Air Office officials should be consulted when
incorporating any of these recommendations. Arrangements between Air Office and Water
Office personnel wilt need to be made for monitoring compliance with these conditions. (For
a list of appropriate contacts, see Appendix B.)
o If, through consultation with the Air Office officials, a problem is identified with incinerator
emissions and this problem is a result of sludge quality, pollutant-specific numerical limits
may be developed with support from the Air Office and incorporated in the NPDES permit
8.2 INCINERATION TECHNOLOGY
Incineration is the complete combustion of materials in a single step in the presence of oxygen.
Incineration is the most commonly used combustion operation for destruction of wastewater
sludge. Approximately 20 percent of POTW sludge is disposed of via sludge incineration. There
are no Federal regulations specifying the type of incinerator that must be used to incinerate sewage
sludge. However, the State of Kansas requires a multi-chamber systeqp and Rhode Island requires
multi-chamber, multi-hearth, fluidi red-bed, or a cyclonic furnace.
The most common types of furnaces currently used for sludge incineration are the multiple-hearth
furnace and the fluidized-bed furnace. Although a few electric-infrared furnaces have also been
installed, the multiple-hearth furnace is the most widely used design, accounting for 75 to 80
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Revised 12/1/89
percent of the sludge furnaces in operation today in the United States. Fluidized bed furnaces and
electric-infrared furnaces account for approximately 16 and 4 percent, respectively, of the sludge
furnaces installed in the United States (EPA, 1985a). Two other methods — starved-air
combustion and co-incineration - are much less commonly used in the United. States.
Multiple-Hearth Furnace
The multiple-hearth furnace is a vertically oriented, refractory-lined, steel cylinder containing a
series of horizontal brick hearths, one above the other, and an air-cooled vertical shaft equipped
with radial arms cantilevered over the hearths. Sludge is fed at the top of the furnace and
sequentially scraped by plow-like blades mounted on the center-shaft arms across each health
before dropping to the hearth below. The countercurrent flow of rising exhaust gases and
descending sludge provides effective drying and combustion of the sludge.
Fluidized-Bed Furnace
The fluidized-bed furnace is a vertically oriented, refractory-lined steel cylinder that contains a sand
bed that, at rest, sits upon a base plate equipped with an array of fluidizing air diffusers. Air is
injected into the furnace through the diffusers at a pressure of 3 to 5 psig to lift and fluidize the
sand. The sludge feed is either above or directly into the bed. Ash is carried out the top of the
furnace with the exhaust gas.
Electric-Infrared Furnace
The electric-infrared furnace is a horizontally oriented, rectangular steel shell containing a moving
horizontal, woven-wire belt Sludge is fed into the electric-infrared furnace through a feed hopper
that discharges onto the woven-wire belt The layer of sludge moves under the infrared heating
elements, which provide supplemental energy for the drying process. Combustion airflow is
countercurrent to the sludge flow, and ash is discharged from the end of the belt to the ash
handling system.
Co-incineration
Co-incinerarion is the burning of municipal sludge and refuse together. Only about one percent of
the sludge incinerators in operation today are operated in a co-incineration mode. Co-incineration
facilities may be subject to current Federal regulations for sludge incineration, refuse incineration,
189
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Revised 12/1/89
and co-incineration depending on the relative amounts of material incinerated. In general, permit
writers should defer to air office officials in developing co-incineration permit conditions.
Starved Air Combustion
In starved-air combustion, sludge is burned in a two-step process. In the first step, the volatile
portion of the sludge is burned out leaving an ash, but there is insufficient oxygen to combust all of
the gaseous compounds pyrolyzed out of the sludge. In the second step, combustion of these
gases is completed in an afterburner chamber.
8.2.1 DEFINITIONS
Provided below are some definitions which may clarify some of the process-specific terminology.
Afterburner - pollution control equipment designed to bum hydrocarbons which have escaped the
incineration process. Sometimes the upper hearth of a multiple hearth incinerator can be used in
lieu of additional equipment
Excess Air - the process of incineration depends on having enough excess oxygen to interact with
the organic matter so that complete combustion will result Excessive amounts of oxygen cause
unnecessarily high gas velocities thereby increasing paniculate emission.
Feed Rate - flow of dewatered sludge into the incinerator. Monitoring sludge feed rate
continuously allows for more efficient incineration operation. A large increase in feed rate causes
the combustion zone of the multiple hearth furnace to drop to a lower hearth and causes increased
gas flow with increased panicle emissions. A large decrease raises the combustion zone to a
higher hearth which reduces residence time and increases the emission of unburned hydrocarbons.
Off gas - exit or exhaust gas from the incineration process.
Recombustion • the process to remove the products of incomplete combustion or the unburned
hydrocarbons from the off-gas of the incinerator. Afterburners function as recombustion
chambers.
190
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Revised 12/1/89
8.3 CURRENT REGULATORY REQUIREMENTS
The existing Federal regulations related to sludge incineration are summarized below. It should be
noted that State agencies can, and in some cases do, have requirements more stringent than the
minimum Federal requirements.
8.3.1 NEW SOURCE PERFORMANCE STANDARDS (NSPS) (40 CFR Part 60)
EPA's Office of Air and Radiation or its counterpart programs in the States enforce the NSPS.
Revised New Source Performance Standards were promulgated by EPA on October 6, 1988 (S3
FR 39412).
Any incinerators that bum municipal sludge and that commenced construction or modification after
June 11, 1973 are subject to NSPS. The rate of particulate discharge cannot exceed 1.30 pounds
of particulates per ton (0.65 g/kg) of dry sludge feed and the gas discharged cannot exhibit more
than 20 percent opacity (40 CFR Part 60 Subpart O). These requirements apply, even to co-
incineration facilities, if the facility burns wastes containing more than 10 percent sewage sludge
(dry basis) or charges more than 1,000 kg (2,205 lb) per day municipal sewage sludge (dry basis).
Coincineradon of sludge and municipal refuse in incinerators with a charging rate greater than 50
tons per day (45 metric tons/day) and with municipal refuse constituting 50 percent or more of the
charge that commenced construction or modification after August 17,1971, cannot emit more than
0.08 grains of particulates per dry standard cubic foot (0.18 g/dsm3 dry) corrected to 12 percent
carbon dioxide (Subpart E).
8.3.2 NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS
(NESHAPs) (40 CFR Pan 61)
EPA's Office of Air and Radiation or its counterpart programs in the States enforce the NESHAPs.
NESHAPs regulate mercury and beiylliutn. Any operation that bums or dries wastewater sludge
cannot discharge more than 3,200 grams of mercury per 24-hour period (Subpart E). Incinerators
that process beryllium containing waste shall not emit over 10 grams of beryllium over a 24-hour
period (Subpart C).
It should be noted that the analytical detection limit for Be is 0.2mg/L Thus the limit of 10 g/day is
only detectable if the flow into the incinerator is less than 13.2 mgd. For higher flows non-
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Revised 12/1/89
detectable levels would not ensure compliance. The analytical detection limit for Hg is also
0.2 mg/1. Thus the 3,200 g/day limit is detectable in all flows under 4,277 mgd, which ensure
detection at all currently operating sewage sludge incinerators.
8.3.3 TOXIC SUBSTANCES CONTROL ACT (TSCA)
EPA's Office of Pesticides and Toxic Substances is responsible for enforcing requirements for
incineration of sludge containing greater than 50 mg/kg PCB's. Incinerators burning sludges with
PCB concentrations greater than SO mg/kg must be approved by the Regional Administrator or
Assistant Administrator for Pesticides and Toxic Substances. Incinerators for sewage sludges
containing over 50 mg polychlorinated biphenyls (PCBs)/kg dry sludge solids must comply with
the specific design and operational requirements of the Toxic Substances Control Act (TSCA).
8.3.4 NATIONAL AMBIENT AIR QUALITY STANDARDS (NAAQS) AND STATE
IMPLEMENTATION PLAN (SIPs) (40 CFR Part 50)
The National Ambient Air Quality Standards (NAAQS) in 40 CFR Part 50 establish threshold
levels for air pollutants which pose the greatest overall threat to air quality. The "criteria
pollutants" include ozone, carbon monoxide, air borne particulates, sulfur dioxide, lead and
nitrogen oxides (See Table 8-1). For these pollutants, the regulations set primary standards to
protect human health (See Table 8-2) and secondary standards to protect "welfare" (crops,
livestock, vegetation). The Clean Air Act (CAA) requires each State to develop a State
Implementation Plan (SIP) for attainment of the standards. For those areas which are already
meeting NAAQS, the implementation plans must include a program for Prevention of Significant
Deterioration (PSD).
For those areas that are not in attainment for one or more of the criteria pollutants, SIPs provide for
emission controls, transportation controls, source monitoring, ambient air quality, monitoring, and
procedures for review and approval of new sources of air pollution prior to construction. Sewage
sludge incineration emissions may be limited under a SIP if that incinerator is identified as a major
source of the pollutant for which the area is in non-attainment
-------
Pofcjtant
TABLE 8-1
NATIONAL AMBIENT AIR QUALITY STANOAROS*
Avwragng Time Primary Standard Secondary Standard
Measurement Method
Carton Monand*
Nitrogen Ctaode
Sulfur Dioxide
Suspended particulate
matter
Ozone
Lead
8t*
ihr
Annual average
Annual average
24 nr
3 hr
Annual geometric mean
2 4hr
1 hr
3 months
10 mgfmi (9 ppm)
40 mg/m* (39 ppm)
100 (0 093 ppm)
80 iig/mi (0 03 pom)
369 mjrtnS (0.14 ppm)
79
260 inym)
239 wfrrP (0.12 ppm)
1 9
Same
1,300 ngrtn1 (0.9 ppm)
60
ISO vQlm*
Same
Same
Nondispersive infrared
spectroscopy
Coionmetnc using NaCH
Pararoaanitane memod
Hign-votume sampling
Chermtuminescerrt
method
' Standvda. other than those baaed on annual average or annual geometric average, are not to be axceeded more than once a year.
Note; National primary ambent a* quatty standards define levels of ar quafcty wh«h the Administrator judges are necessary, with an
adequate margin of saiety- ® protect the puttc health National secondary amtoent m quafaty standards define levels of or quality which the
Adnuvstrator pdgea necessary to protect the pubic welfare from any known or antapeftd adverse effects of a pollutant (40 CFR SO.2)
TABLE >-2
HEALTH EFFECTS OF AIR POLLUTANTS
Poiutant Levels
Ar Quality
Level
tsp so, co o,- noj (i-
(24-hr), (24-hr), (8-hr). (1-hr), hr),
ntym* wiftn* mtfm* volrn* wtfrn*
Effect
Oeacnptor
General Heelti EWscta Cauaonary Statements
Significant 1,000
harm
Emergency 879
Wamng
Alert
NAAOS
90 % ol
NAAOS
629
379
260
7S»
0
2.820
2,100
1.800
366
80*
0
97.9 1.200 3.750
40.0 1.000 3,000
34.0 800 2,280
170 400* t.130
10.0 240 *
10. 120
0 0
Hazardous
Premahjre death of i and
euerty. Heaflhy people m*
expenerce Adverse
symptoms thai affect the*
normal actmty
Premature onset of oertan
diseases m addrton to
s^nrtcant aggnviDon of
symptoms and i
i«
Very
S^mflcant aggrtvabon of
symptoms and decreased
exerase tolerance in
persons wufi heart or lung
symptome «i the heattiy
populaaon.
MM aggravabon of
symptom n suacepotte
unneaRns personal ^ncaaon
symptoms *» tfie heeMiy
Al persons should remam
indoors, keepmg windows
and doors dosed. All
persons should rmnnTwe
physeal exertion and avoid
traffic
Elderly and persons with
ensang osesaes should
stay indoors and avod
physeal exertion. General
populaaon should avod
outdoor actrvrty.
EWerty and persons with
easang heart or Iwg
disease should stay moor*
and reduce pftyscal
acavny
Persons with existing heart
or reapratory arimenta
should reduce physeal
exertnn and outdoor
actvtiy
Qood
• No wdex values raporM at concentaaon levels below rose ipaaM by 'Atari lmT cmsna.
t> Annual primary NAA08.
c 400 was used maad of *te Oj'Alert Lever of 200 ng^n*
191
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Revised 12/1789
8.3.5 NEW SOURCE REVIEW STANDARDS (NSRS) (40 CFR Part 51.160)
The new Source Review Standards require a preconsmiction review of all new construction of or
modification to stationary sources to determine if the source will meet all applicable emission
requirements of the SIPs and the EPA's Emission Offset Policy. If the permit writer finds the
POTW is planning new construction or modification to an incinerator, the air office should be
consulted immediately. 40 CFR Part 51.160 and Appendix S of 40 CFR Part 51 contain additional
information on the New Source Review Standards.
8.3.6 PREVENTION OF SIGNIFICANT DETERIORATION (PSD) (40 CFR Part 52.21)
The purpose of EPA's Prevention of Significant Deterioration (PSD) program is to preserve the air
quality of areas currently attaining NAAQS. PSD review is the responsibility of the Office of Air
and Radiation or its counterpart office in the States. The PSD regulation applies to sewage sludge
incinerators constructed or modified after August 7,1977 if the incinerator emits 250 tons per year
or more of any pollutant subject to regulation under the CAA. Any stationary source capable of
emitting 250 tons per year or more of any regulated air pollutant is defined as a major stationary
source. In addition, particular stationary sources (e.g., municipal incinerators capable of charging
more than 250 tons of refuse per day) which have the potential to emit 100 tons per year or more of
any regulated air pollutant are defined as a major stationary source and subject to PSD review.
Major stationary sources undergoing modifications that would result in a significant increase in
emissions of any of the pollutants listed in Table 8*3 would also be subject to PSD review.
PSD requirements for major stationary sources include:
o Installing Best Available Control Technology for each pollutant subject to regulation under
the CAA if the source would have the potential to emit thai pollutant in significant amounts.
o Demonstrating that the allowable emissions would not cause or contribute to air pollution in
violation of air quality regulations.
The permit writer should contact the appropriate air regulatory office to determine if that office has
performed a PSD review and required the incinerator install pollution control technologies.
-------
TASLES-9
LEVELS Of NET EMISSIONS INCREASE THAT QUAUFV AS
MAJOR MOOIFICATIOHS REQUIRING PSO REVIEW
•Carton moooaor. 100 «0M per year ((py)
• Nitrogan rades: 40 tpy
• Sufft* ttand* 40 tpy
•Partcultts mater. 23 (py
•Oror* 40 tpy of votaste organc compounds
•Lead 0.6 toy
•AjtwBe 0.007 tpy
• Barytfium: 0.0004 Ipy
• Mercury: 0.1 Ipy
•Vmy4 CNonde: i ipy
•FKxjndea: 3 tpy
• Sulfuric Aod Miat 7 tpy
•Hydrogen Sulfide (HjS): 10 ipy
•Total Reduced Sulfur (inducing HjS): 10 tpy
•Reduced Su/fur Compound* (mclubng HjS): 10 tpy
195
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Revised \2J\fc9
8 4 CHARACTERISTICS OF SLUDGES SUITABLE FOR TNCTMPP atto^
The properties of sludges suitable for incineration include an adequately high concentration of
combustible material, a low moisture content, and a low concentration of non-combustible
contaminants such as certain heavy metals.
8.4.1 POLLUTANT CONCENTRATION LIMITS FOR SLUDGE FEED AND AIR
EMISSIONS
Few regulations under the CAA specify sludge quality conditions, most address air emission
levels. This sub-section provides a listing of specific pollutants along with their current Federal
emissions or ambient air concentration limits (if any), and any general guidance and discussion of
contaminant limits from Federal literature. Limits for specific States (if any) are tabulated in
Appendix E, Tables E8-1 and E8-2.
In sludge incineration, the fate of heavy metals and chemical compounds depends largely on their
ability to associate with small particles. Volatile elemental metals include Hg, Cd, Pb, As and Zn.
These may be emitted at concentrations higher than the average of the bulk sludge ash if furnace
temperatures are set too high.
EPA s Office of Air and Radiation or designated State agencies administer five regulatory
programs that may limit sewage sludge incinerator emissions: National Ambient Air Quality
Standards (NAAQS) (40 CFR Part 50), NSPS (40 CFR Pan 60), New Source Review Standards
(40 CFR Pan 51.18), NESHAPS (40 CFR Pan 61) and Prevention of Significant Deterioration
(PSD) (40 CFR Pan 52.21). Permit writers should consult with the officials responsible for these
programs and should identify in the NPDES permit documentation any requirements imposed on a
municipal sludge incinerator.
Federal Reyiilarinqi
The only required pollutant concentration (or pollutant characteristic) limits for incinerated sewage
sludges are: 1) the sludge shall not be a hazardous waste; and 2) the sludge shall not contain more
than 50 ppm (mg/kg) of PCBs unless it is bunted in an incinerator approved by EPA to bum
PCBs. The Federal emissions limits and/or ambient air quality standards are described below.
Table 8-4 presents an outline of contaminant concentrations in the Federal regulations.
IQrf
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TABLE 8-4
FEDERAL CONCENTRATION LWITS FOR CONTAMINANTS'
Sulfur Carbon Nitrogen
Beryllium Lead Mercury Opacity Particulates Dioxide Monoxide Dioxide Ozone
Emissions
Ambient Air
Emissions
Emissions
Emissions
Ambient Air
Ambient Air
Ambient Air
Ambient Air
Limit of
Limit of
Limit of
Limit of
Limit of
Limit of
Limit of 10
Limit of
Limit of
to g per
t 5 yglm3
3,200 g per
20 percent
0 65 g/kg dry
80 iig/m3
mg/m3
100 ng/m3
235 iig/m3
24-hr penod
averaged
24-hr penod
opacity
sludge feed
(annual
(8-hr
(annual
(1-hr

over a

average).
average).
average)
average)

calendar

365 jig/m3
40 mg/m3 (1-

quarter

Ambient Air
Limit of
75 ng/m3
(annual
geometric
mean)
260 pg/m3
(24-hr
average.)
(24-hr
average)
hr average).

* Major stationary sources may also be subject to New Source Review Standards or Prevention of Significant Deterioration Regulations (see
Section 9 1 2)
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Beryllium
Incinerators that process beryllium containing waste shall not emit over 10 grams of beryllium over
a 24-hour period Beryllium containing waste is defined as material contaminated with beryllium
and/or beryllium compounds used or generated by extraction plants, ceramic plants, incinerators or
propellant plants that process beryllium ore, beryllium oxide, or beryllium alloys, or by machine
shops that process beryllium, beryllium oxides, or any alloy when such alloy contains more than 5
percent beryllium by weight (40 CFR Pan 61 Subpart Q.
Facilities may request a variance from this requirement provided that at least 3 years of data air
available to demonstrate that the future ambient concentrations of beryllium is the vicinity of the
stationary source will not exceed 0.01 ug/m3, averaged over a 30-day period (40 CFR Part
61.32(b)).
Carbon Monoxide
Emissions should not cause ambient concentrations of carbon monoxide in the vicinity of the
stationary source to exceed the NAAQS of 10 mg/m3 on an 8-hour average and 40 mg/m3, 1-hour
average. Additionally, New Source Review Standards or PSD may apply to large facilities.
Lead
Emissions of lead should not cause ambient concentrations of lead in the vicinity of the stationary
source to exceed the NAAQS of 1.5 ug/m3, averaged over a calendar quarter. Additionally, New
Source Review Standards or PSD may apply to large facilities.
Mercury
Subpart E of the NESHAPs states that sludge incinerators, sludge dryers, or combinations of these
facilities shall not emit more than 3,200 grams of mercury in a 24-hour period Unless a waiver of
emission testing is obtained under the general NESHAP waiver provisions (40 CFR Part 61.13),
each owner or operator shall determine mercury emission concentrations within 90 days of start-up
(existing sources were required to make the determination within 90 days of the rule's effective
198
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date in 1975). The determination shall be made either by stack gas sampling or by a calculation
based on sludgfrfeed sampling where it is assumed that all mercury in the sludge is volatilized.
Operators of incinerators with mercury emissions exceeding 1,600 grams/day are required to
monitor or calculate mercury emissions annually. Prior to any changes in operation that would
potentially increase emissions above that determined by the most recent source test, a new
emissions level must be estimated by calculation and the results reported to the Administrator.
Nitrogen Oxides
Emissions should not cause ambient concentrations of nitrogen dioxide in the vicinity of the
stationary source to exceed the NAAQS of 100 ug/m3 annual average. Additionally, New Source
Review Standards or PSD may apply to large facilities.
Opacity
Gas discharged from incinerators that bum municipal wastewater sludge shall not have more than
20 percent opacity. Where the presence of uncombined water is the only reason for failure to meet
the 20 percent opacity limit, such failure shall not be a violation of this requirement. (40 CFR Pait
60, Subpart O)
Ozone/Photochemical Oxidants
Emissions should not cause ambient concentrations of ozone in the vicinity of the stationary source
to exceed the NAAQS of 235 ug/m3 I-hour average. Additionally, New Source Review Standards
or PSD may apply to large facilities.
Particulates
Particulates discharged from incinerators that burn municipal wastewater sludge cannot occur in
excess of 1.30 pounds per toti dry sludge input (0.65g/kg dry sludge input) (40 CFR Part 60,
Subpart O). The standard applies to sludge incinerators that have been constructed or modified
after June 11,1973. During start-up of operations, incinerator operators must demonstrate
compliance with the standard. Incinerator operators must also install, calibrate, maintain, and
operate a flow measuring device that can be used to determine the mass or volume of sludge
charged to the incinerator. The flow measuring device shall have an accuracy of plus or minus 5
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Revised 12/1/89
percent over its operating range. For more information, consult Subpart A of the NSPS (40 CFR
Pan 60).
Co-incineration of sludge and municipal refuse with a charging rate greater than SO tons per day
(45 metric tons/day) and with municipal refuse comprising SO percent or more of the charge cannot
discharge more than 0.08 grains of particulates per dry standard cubic foot (0.18 g/dsm3)
corrected to 12 percent carbon dioxide (40 CFR Part 60, Subpart E).
Emissions should not cause ambient concentrations in the vicinity of the stationary source to
exceed the NAAQS of 75 ug/m3 annual geometric mean and 260 ug/m3 24-hour average.
Additionally, New Source Review Standards or PSD may apply to large facilities.
Polychlorinated Biphenyls (PCBs)
Incinerators that bum sludges containing more than 50 mg PCBs/kg dry sludge solids shall comply
with 40 CFR Part 761.70. This regulation has very strict emission requirements and must be
consulted if the permit writer needs to incorporate these requirements in the NPDES permit The
appropriate air regulatory authority should be consulted first
Sulfur Oxides
Emissions should not cause ambient concentrations of sulfur dioxide in the vicinity of the
stationary source to exceed the NAAQS of 365 ug/m3 24-hour average and 80 ug/m3, annual
average. Additionally, New Source Review Standards or PSD may apply to large facilities.
Federal Guidance
Arsenic
In the EPA listing of hazard indices to assess human toxicity/cancer risk resulting from the
inhalation of incinerator emissions, one of the compounds that posed the highest increase in human
health risk was arsenic (EPA,. 1985b). If there is reason to believe thafthere is arsenic in the
sewage sludge that is to be incinerated, the permit writer should consult with the appropriate Air
Office to determine the type of controls needed.
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Cadmium
In the EPA listing of hazard indices to assess human toxicity/cancer risk resulting from the
inhalation of incinerator emissions, one of the compounds that posed the highest increase in human
health risk was cadmium (EPA, 1985b). If there is reason to believe that cadmium is present in the
sewage sludge to be incinerated, the permit writer should consult with the appropriate Air Office to
determine the type of controls needed.
Chromium
In the EPA listing of hazard indices to assess human toxicity/cancer risk resulting from the
inhalation of incinerator emissions, one of the compounds that posed the highest increase in human
health risk was hexavalent chromium (EPA, 1985b). If there is reason to believe that there is
chromium in the sewage sludge that is to be incinerated, the permit writer should consult with the
appropriate Air Office to determine the type of controls needed.
Vinyl Chloride
Although vinyl chloride limits in 40 CFR Part 61 do not presently apply to wastewater sludge
incinerators, it is noteworthy that this regulation limits the vinyl chloride exhaust gas emissions to
10 ppm for vinyl chloride plants, polyvinyl chloride plants, and ethylene dichloride plants.
State Requirements
No State reported any specific maximum sludge contaminant concentrations above which
incineration would not be allowed. Alt repotted State requirements addressed emission levels.
Most State emissions standards for sewage sludge incinerators simply repeat the Federal
requirements. However, a few individual States have set other emission standards. State
standards are listed in Appendix E, Table E8-1.
Beryllium
New Jersey and New Hampshire report a beryllium emissions limit.
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Carbon Monoxide
Two States report a carbon monoxide limit.
Mercury
Georgia, Kentucky, New Jersey and Tennessee were the only States that reported requirements for
a mercury limitation (all reported a 3,200 grams mercury per day limit).
Opacity
The States of Alaska, Delaware, Georgia, Iowa, Kentucky, New York, Ohio, Oklahoma, and
Wisconsin reported a 20 percent opacity limit as a State regulation.
Particulates
Many States have limits for particulates. However, the reported limits vary both numerically and
in the specified units. For example, reported State limits range from 0.08 to 4.6 grains/dry
standard cubic foot (DSCF) (0.005 to 0.3 grams/DSCF), 1.3 lb/ton dry sludge input, 2 lb/100 lb
refuse, a limit of 0.S lb/million BTU heat output, and a range of 0.2 to 0.1 percent of the charging
rate.
8.4.2 SLUDGE PHYSICAL PROPERTIES
Federal Regulations
There are no current Federal regulations regarding the physical properties of sludges suitable for
incineration.
Percent Combustible Solids
Federal Guidance
The combustible content of the sludge affects the amount of fuel required for incineratioa. With
higher combustible content less fuel and/or dewatering are required and less material remains for
final disposal. Because wastewater sludge typically has an adequately high percent of combustible
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Revised 12/1/89
solids and a high heat content per unit weight of combustibles, the limiting factor in fuel
consumption is the moisture concent of the sludge.
State Requirements
There are currently no State regulations governing percent combustible solids.
Moisture Content and Dewateriny
Federal Guidance
Efficient dewatering is essential prior to sludge incineration to avoid high costs for supplemental
fuel. Sludge typically must be dewatered to between 25 and 35 percent solids to approach
autogenous (self-sustaining) combustion. Higher solids levels are needed for autogenous
combustion when the concentration of ash (or inert conditioners such as lime, ferric chloride, or
recycled ash) is high. The incineration of low percent solids sludge could require large amounts of
expensive supplemental fuel. It is important to avoid fluctuations in moisture content. An
equalization chamber in front of the incinerator would help with moisture content and feed rate
fluctuations.
State Requirements
The States of Kentucky and New Jersey reported requirements for sludge dewatering.
8.5 OPERATTNC, CONDITIONS AND MANAGEMENT PRACTICES
As Stated in the Sewage Sludge Interim Strategy, permit writers should consider any POTW that
incinerates its sludge a Cass I POTW for permitting purposes unless after considering the
following factors, a BPJ determination can be made that the incinerator emissions pose no threat to
human health and the environment The factors to consider are: POTW sludge quality, the
compliance history of the incinerator, height of the incinerator stack, whether there are tall
buildings in the vicinity of the incinerator that may cause a down wash of emissions, whether any
features of the surrounding geography are high enough in relation to the stack to cause the
emissions plume to contact the ground near the incinerator, and the population density downwind
from the incinerator in the direction(s) that prevailing winds blow.
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Revised 12/1/89
Permit writers should request the assistance of air office officials when evaluating the potential risk
posed by incinerators. Permit writers should also work closely with air office officials to determine
the appropriateness of the following operation conditions at a particular incinerator. Arrangements
between air office and water office personnel will need to be made for monitoring compliance with
conditions placed into NPDES permits.
Following is a description of various operadon conditions and management practices relevant to
incineration. The first section covers Federal and State requirements and recommendations. The
second section describes operating parameters specific to particular technologies and highlights the
differences in operating efficiencies between the different technologies. The third section describes
the different types of emission control technologies.
8.5.1 GENERAL OPERATING CONDITIONS AND MANAGEMENT PRACTICES
Emissions from a sludge incinerator vary depending on the type of incinerator technology. Other
factors effecting emissions include (1) physical properties of the sludge as described in Section
8.4.1 of this manual, (2) the sludge feed rate (3) temperature profile of the incinerator, particularly
the combustion and exhaust temperatures, (4) the amount of excess air used for incineration, (S)
combustion efficiency and residence times, (6) operator control, and (7) the type and operation of
emissions control system. Appropriate regulation of each of these parameters minimizes the impact
of sewage sludge incineration on public health and the environment.
Federal Guidance
Sludge Feed Rate
A constant sludge feed rate is desirable because changes in feed rate can cause smoke or increase
emissions. Loadings of wastewater skimmings, scum, grease and other materials with a high heat
content should be equalized to minimize high-temperature excursions and pockets of oxygen-
deficient combustion within the furnace. Equalization chambers added in from of the incinerator
will smooth out fluctuations in feed rate.
Permit writers should consider requiring POTWs that use incinerators to minimize fluctuations in
sludge feed rate. These POTWs should be required to report 25 percent or greater variations in
sludge feed rate in a one-hour period excepting start-up and shut-down of the incinerator. The
purposes of reporting large fluctuations in feed rate are: (1) to focus operator attention on an
204
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important parameter that can affect the proper setting of other operating parameters; and (2) to
focus EPA's compliance monitoring resources on incinerators that are operated in a way that has
the potential to increase emissions.
Combustion Temperature
A minimum combustion temperature of approximately 1,300 to 1,400°F is adequate for oxidation
of high molecular weight organics, and a maximum temperature of about 1,800°F is often
necessary to limit ash melting and damage to refractories. It has been observed that high
temperatures lead to increased emissions of metals. Operation of a fluidized-bed furnace at a
combustion temperature of 980°C (1,800°F) is reported to normally produce 200 to 400 percent
more emissions than operation at 760°C (1,400°F) (EPA, 1985a), although it should be noted that
most fluidized-bed furnaces are operated at 1,500-1,600°F to avoid bed defluidiz&tion.
Combustion temperature in particular affects the amount of NOx, CO, and hydrocarbons emitted.
Loadings of high heat content material such as wastewater skimmings, scum, and grease should be
controlled to minimize high temperature excursions and localized oxygen deficiency.
Most, if not all POTWs operating sludge incinerators monitor combustion zone temperature.
Permit writers should consider requiring POTWs (1) to operate within a combustion zone
temperature range of 1,350 to 1,650°F, and (2) to report periods when combusting zone
temperatures exceeded 1,625°F or fall below 1,375°F, excepting start-up and shut-down.
Excess Air
It is critical to supply enough air to ensure complete combustion; it is also important to limit the
amounts of excess air. When large quantities of excess air are used, the resulting high gas
velocities are believed to increase the total amount of suspended particulates in the exhaust gas.
Supplemental fuel requirements are also needed to heat excess air. Consequently, operators often
go to the other extreme and do not provide enough excess air for complete combustion.
Conventional sludge incineration systems typically use 20 to 150 percent excess air above the
theoretical amount needed for oxidation because it is virtually impossible to ensure complete and
even mixing of air and sludge (EPA, 1984). However, with careful operation, excess air flows
can range from 20 to 45 percent for fluidized-bed furnaces, and 29 to 70 percent for electric-
infrared furnaces (EPA,1985c). Multiple-hearth furnaces typically require higher levels of excess
air, depending on how carefully they are operated.
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Revised 12/1/89
Combustion Efficiency
Combustion efficiency measurement is one way to monitor and report upon proper incinerator
operation where frequent sampling for the specific contaminant is not feasible. Combustion
efficiency (calculated by dividing die concentration of carbon dioxide by the sum of the
concentrations of carbon dioxide and carbon monoxide in the off-gas) is a measure of the
percentage of completion of oxidation.
EPA requires a combustion efficiency of 99.9 percent for hazardous waste incinerators burning
over 50 ppm PCBs (40 CFR Part 761.70). However, this permitting approach has not been
applied to sewage sludge incinerators, and the correlation between combustion efficiency as
described above and destruction of certain pollutants in sewage sludges is not well established.
Operator Training and Controls
One of the most important factors in achieving and maintaining a low rate of emissions from a
sludge incinerator is having an experienced, well-trained, conscientious operator attend to the
incinerator at ail times that the incinerator is running. Depending on the composition of the sludge
(volatile solids and moisture content), which can vary by hour, day, or season, an operator may
need to adjust the temperature regime within the incinerator and the amount of excess air used.
Permit writers should consider writing a condition requiring that an experienced, well-trained,
competent operator attend to the incinerator at all times that the incinerator is on line. Also
important for achieving and maintaining low emissions is the ability of the operator to adject
parameters within the combustion process. Permit writers should consider writing a condition
requiring that the proper controls be provided.
Emission Controls
Approximately 20 pounds of uncontrolled particulates per ton of sludge and 0.0038 pound of
particulates per gallon of fuel oil are generated in multiple-heanh funufces. The Federal New
Source Performance Standard of 1.30 pounds of particulates per dry ton of sludge (0.65 g/kg) can
be met with modem high energy wet scrubbers, such as the venturi. Removal efficiency in
scrubbers is a direct function of particle size and the pressure drop across the scrubber system,
although some further gains in collection efficiency are claimed for some specific hardware
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Revised 12/1/89
configurations. For a pressure drop in excess of 30 inches of water, scrubbers will remove over
99 percent of particulates larger than 1 micron.
General guidelines for emissions control equipment include:
o Use after-burners where necessary to satisfy strict carbon monoxide and unbumcd
hydrocarbon emission limitations.
o Specify a minimum pressure drop across the scrubber system (e.g., 30 inches or greater
pressure drop for a venturi impingement tray water scrubber system) if exceptional control
levels for particulates are desired.
o Specify a maximum air/cloth ratio for fabric filter baghouses (such as the 3.0 maximum ratio
specified for the Hyperion Energy Recovery System in Los Angeles, CA; EPA, 1983a) if
exceptional emission control levels are sought. As above, one should consider the alternative
of performance specifications. -
Emission control equipment at existing incinerators subject to the NSPS for particulates and
opacity should be operated so as to maintain the operating conditions (e.g., pressure drop for
scrubbers, air/cloth ratio for fabric filters) during the facility's compliance determination test-burn.
If emission control equipment is in place at older incinerators not subject to NSPS, a permit
condition should be written requiring the POTW to maintain and operate the equipment so as to
optimize particulate removal efficiency. For POTWs planning to use new incinerators, language
should be inserted which will allow reopening the permit after the start-up compliance
determination. Emission control equipment operating parameters maintained during start-up would
then be mandated as a condition in the permit
Table 8-5 suggests a pattern of sludge incinerator operating parameters that should minimize the
emission of heavy metals, soot, and odorous/undesirable organic compounds. The most important
theme is the maintenance of a high degree of stability of conditions coupled with reasonable
sensitivity to the key stoichiometric and temperature criteria that provide a suitable combustion
environment to minimize both generation and emission (survival) of organic compounds. This
must be recognized by both POTW management and operational personnel as a plant
problem/challenge, not just a furnace problem. Close attention must be paid to tight and insightful
control of all aspects of the wet end of the process train in order to deliver the constancy in rate and
material (let alone superior performance in dewatering to minimize fuel usage) needed for good
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TABLE 8-5
SUMMARY OF SUGGESTED INCINERATOR
OPERATING GUIDELINES
Parameter Goal Reason Tolerance
Feed solids
content
keep it
constant
stabilize energy
balance in system
within 2%
of avg
Feed rate
keep it steady
stabilize system
within 10%
Temperature
keep it steady
keep it high
stabilize process
to burn organics
ol avg
within 50 "F
>1,400*F

keep it low.
to minimize metal
volatilization
<1,600 °F
Oxygen
content of
exhaust
gases
keep it low
keep it high
reduce fuel
consumption
assure oxygen lor
combustion
<10% o2
>7% 02
Scrubber
pressure drop
keep it high
collect fins
particulates
at/above
where
compliance
tested
Burning Zone
keep it steady
stabilize system
1 hearth
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Revised 12/1/89
furnace operation. Thus, cooperation among the operators of almost all aspects of die plant and the
incinerator is a critical ingredient in successful, minimum cost, and low emission sludge
incineration systems.
Storage Requirements
Sufficient sludge storage should be provided to allow for a constant feed rate to the incinerator and
to allow for an adequate amount of down-time for repairs and preventive maintenance.
Ash Disposal
Approximately 7 million dry tons of sludge are generated by U.S. municipal wastewater plants
each year. More than 1.3 million tons of this sludge are incinerated, resulting in about 400,000
tons of ash that must be disposed of in an environmentally acceptable manner (EPA, 1985a). Ash
is a solid waste that should be disposed of in accordance with the requirements of 40 CFR Part 237
(Appendix D). Permit writers should consider writing such a requirement into the permit
State Requirements
Combustion Temperature
Four States have minimum temperature requirements. Specific information was not provided by
Connecticut or Iowa, but Georgia requires 800°F Primary Temperature and 000°F Secondary
and Nevada requires 1,400°F for not less than 0.3 seconds.
Combustion Residence Time
The State of Nevada requires not less than 0.3 seconds at l,400°F, and Connecticut reported an
unspecified minimum combustion residence time requirement
Emission Controls
The States of Maryland, Nevada, New Hampshire, New Jersey, Ohio, Oklahoma, South Carolina,
Virginia, Washington, Rhode Island, and Tennessee impose special requirements relative to
emission controls; some specify that minimum air pollution control techniques such as "Best
Available Control Technology" must be applied. This approach may be panicularly appropriate
xw
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Revised 12/1/89
where certain pollutant emission levels are expected to be a problem (i.e., when the sludge has
high concentrations of the more volatile metals such as mercury, cadmium, lead, or zinc which
may be emitted at concentrations higher than the average of the bulk sludge ash if furnace
temperatures are set too high).
Management Practices
State agencies report a number of management practices in addition to the incineration and pollution
control guidelines previously discussed. These management practice requirements and/or
guidelines are summarized below and in Table E8-2. Management practices required by just one or
two States are presented in page four of Table E8-2. States with no reported management practices
are omitted from Table E8-2. Prohibited sludge incineration practices that were reported by
various States are summarized in Table 8-6.
Access Control
The States of New Hampshire, Oregon, and Wisconsin reported minimum requirements for access
control, such as fences and gates.
Air Monitoring
Nine States reported some requirements for air monitoring. Current Federal requirements and
funher discussion of potential monitoring requirements are presented later in this section.
Air Modeling
Air modeling may be desirable for large facilities or facilities that may pose a particular hazard.
The State of New Jersey (the only State to require air modeling) is reported to require air modeling
for carbon monoxide, SOj, NO^ total suspended particulates, lead, and VOCs.
Air Turbulence
Increases in air turbulence allow higher levels of pollutant emissions to be assimilated through
dispersion. However, providing for the effect of air turbulence in permit language may not be
possible except in locations where detailed air modeling is required. Iowa was the only State that
reported a requirement for addressing air turbulence.
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TABLE a-e
prohibited sludge incineration practices
Stsa
inctneraoon Practice
Massachusetts
Open burning prohibrtad
Man*
Ooen burning prohibited at landfills serving

over 1,000 person!
Tennessee
incineration prohiMsd without permit
Indiana
Open burning prohihtad
Kansas
Open burning prohibited
Nebraska
Open bummg prohibited without Kcensa
Colorado
Open bummg prohibited at lendffils without permit
Idaho
Open bumwg prohrtMad
Source: EPA 1987
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Revised 12/1/89
Site Development Plans
Twelve States reported requirements for site development plans.
8.5.2 OPERATING GUIDELINES FOR SPECIFIC INCINERATION TECHNOLOGIES
Multiplc-Hganh Furnace
Federal Guidance
Multiple-hearth furnaces are typically operated with high levels (100 percent or more) of excess air
to encourage complete combustion. If the flame of combustion is creeping up the hearths, the
temperature should be lowered or the feed rate should be changed. Exhaust gas temperatures
should be maintained at less than 900°F (482°C) to prevent distillation of odorous greases and tars
from the drying solids. Multiple-hearth furnaces may require afterburners (simple combustors
used to oxidate organic compounds not destroyed in the primary incinerator chamber) in cases
where there are very stringent emission limitations for unbumed hydrocarbons (EPA, 1979).
Where there is concern about organics emissions (e.g., large loadings of industrial organics),
sludge may be added to the third hearth of a multiple-hearth furnace, and the top two hearths may
be used as an afterburner.
Fluidizsd-Bcd Furnace
Federal Guidance
The quantity of excess air supplied to a fluidized-bed furnace is typically in the range of 20 to 45
percent The correct amount of airflow is critical with a fluidized-bed furnace. Airflow must be
sufficient to expand the bed by the appropriate amount, provide uniform distribution of fuel and
air, and provide the desired amount of excess air to ensure complete combustion. The fluidized-
bed furnace operates at lower excess air rates than typically required for multiple-hearth furnaces.
Normal operation of the fluidized-bed furnace produces exhaust temperatures in excess of 1,400°F
(760°C). Because the exhaust gases are exposed to this temperature for several seconds, carbon
monoxide and unbumed hydrocarbon emissions are usually very low, even without the use of an
afterburner (EPA, 1979). However, more particulates must be removed by the emission control
devices of fluidized-bed furnaces because ash is removed from the flue gas, unlike the multiple-
hearth and electric-infrared furnaces where ash is removed from the combustion chamber.
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Electric-Infrared Furnace
Federal Guidance
In electric furnaces, the sludge is not stirred or mixed during incineration, and the particulate
loading to the emissions control system is typically much lower than for fluidi zed-bed furnaces and
somewhat lower than for multiple-hearth furnaces.
Excess airflows for electric-infrared furnaces typically range from 29 to 70 percent (EPA, 1985a).
Since electricity is used to provide the supplemental energy, no fuel is burned in the primary
furnace although fuel is often burned in a post-furnace afterburner.
Starved-Air Combustion
Federal Guidance
In starved-air combustion, the amount of air in the furnace is less than the theoretical requirement
for complete combustion (30 to 90 percent of the stoichiometric requirement). This makes starved-
air combustion a fuel-efficient operation. When a starved-air combustion multiple-heaxth furnace is
combined with an afterburner, an overall excess air rate of 25 to 50 percent can be maintained, as
compared with excess air rates of more than 100 percent for conventional multiple-hearth
incinerators with an afterburner (EPA, 1984).
It has been demonstrated that starved-air combustion is an effective method for burning sludge in a
furnace, but it is still a relatively new technology that is not widely practiced
Co-incineration
Federal Regulations
Co-incineration facilities may be subject to current Federal contaminant regulations for sludge
incineration, refuse incineration, and co-incineration depending on the amounts of material
incinerated. Some co-incineration facilities may also be subject to Subpart D-{b), NSPS for
industrial boilers. No specific management practices are currently regulated. In general, unless the
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Revised 12/1/89
proportion of sludge to other material fed to a co-incineration facility is very high, permit writers
should defer to the Air Office.
Federal Guidance
Only about one percent of the sludge incinerators in operation today are operated in a co-
incineration mode, where wastewater sludge is burned with municipal refuse. Problems
encountered have been related to the different storage requirements of the two "fuels" (wastewater
sludge odor/septic problems) and to the different design requirements for the handling and
incineration equipment (municipal refuse may require equipment that can handle large objects,
rags, wires, etc. without clogging excessively and "hot" loads of plastics and paper without having
excessive temperature excursions). However, there are potential benefits from co-incineration,
such as reduced sludge dewatering requirements and reduction of municipal refuse volume.
8.5.3 GUIDELINES FOR POLLUTION CONTROL SYSTEMS
Federal Regulations
If the sludge contains more than 50 mg PCBs/kg of dry sludge solids then pollution control
devices for hydrochloric acid emissions are required under TSCA.
Federal Guidance
There is a considerable amount of Federal guidance on pollution control systems as presented in
the subsequent sections. These pollution control devices are required to attain emission limitations.
Descriptions of the various emission control technologies are presented below, followed by
guidelines for these pollution control technologies.
Wet Scrubbing Systems
The venturi scrubber with an impingement tray is one of the most cocjnon types of exhaust gas
scrubbers. The exhaust gas is cooled with water and then passes into a venturi section where
particles are removed from the gas stream by a fine mist of water. The exhaust gas is then passed
through a flooded elbow, an impingement tray separator, and a demister to separate the liquid
containing the panicles from the gas.
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Scrubbing water can be recycled, and supplemented with make-up water. Waste scrubbing water
from a multiple-hearth furnace is normally recycled into the main process train in a wastewater
treatment plant. An appreciable amount of volatile compounds or metals such as Cd, Pb, and Zn
may be concentrated in the scrubber wastewater and caution should be exercised in recycling
and/or disposing of this waste stream. Scrubbing water with a fluidized-bed furnace contains large
amounts of ash and is normally treated and sent to an ash lagoon.
The efficiency of scnibbers for particulate removal is related to the pressure drop across the
particulate removal equipment. Most incinerators now use a venturi impingement tray water
scrubber that develops 30 inches or greater of water pressure drop across the system (EPA 1985a).
Scrubber pressure drop typically falls in the range of 15 to 45 inches of water.
Wet scrubbing systems have the advantage of cooling the exhaust gases. Flue gas cooling and wet
scrubbing are effective in removing condensible particulates. Subcooling below the saturation
vapor temperature in the scmbber system will remove substantial amounts of water from the flue
gas and aid in steam plume suppression. Cooling the flue gases will also increase removal of polar
gas molecules that can be expected to dissolve in the water phase (EPA 1985a).
The EPA has evaluated the results of tests on nine sludge incinerators with wet scrubbing systems
in which the following metals were monitored: cadmium, iron, nickel, lead, chromium, silver,
copper, manganese, zinc, and arsenic (EPA 1985a). The findings of this investigation (reported in
1981, but not published) restated the findings of an earlier EPA task force that concluded in 1972
that "properly operated incinerators produce acceptable stack emissions of particulate matter,
nitrogen oxide, sulfur oxides, and odor" (EPA 1972). Only one of the eight incinerators
significantly exceeded EPA's new source performance standard for particulates of 0.65 g of
particulates per kg of dry sludge solids feed. Scrubbers showed very good removal for
particulates larger than 1 micron diameter. However, efficiencies ranged from 50 to 90 percent for
the 0.1 to 1 micron range. The level of heavy metal discharges to the atmosphere was found to be
insignificant when compared to ambient atmospheric concentrations unless the incinerators
operated at very high (1,700PF) temperatures where losses of the more volatile metals (Pb, Cd,
As) increase markedly. Removal of the metals corresponded somewhat to the removal of
particulates. Silver, zinc, cadmium, lead, and presumably arsenic had relatively high
concentrations in the fine particulate fraction of 0.1 to 1 microns, which was believed to account
for their lower removal efficiencies in the scrubbers (EPA 1985a).
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Filters
In the EPA evaluation of nine sludge incinerators discussed previously, it was suggested that the
use of a 0.1 micron filter downstream of the wet scrubbers would assure virtually complete
collection of metals except mercury (EPA 1985a). The fabric filter baghouse at the Hyperion
Energy Recovery System, Los Angeles, CA, was reported to exhibit particulate reductions to less
than 0.005 grams/m3 (0.002 grains/DSCF) using a maximum air/cloth ratio of 3.0.
Dry Scrubber Systems and Electrostatic Precipitators
Neither dry scrubbers or electrostatic precipitators are commonly used on sludge incinerators. A
multiclone is a typical dry scrubber system that may precede a fabric filter baghouse. Electrostatic
precipitators achieve considerable removal of particulates by ionising the particles between two
large charged plates (configured like an electric capacitor). The ionized particles migrate to the
oppositely charged plate and the fall out of the exhaust gas. The exhaust gas must be cooled to
250°C (480°F) prior to entering the electrostatic precipitators (EPA 1985a).
Stack Height
Adequate stack height assures dispersion of the exhaust plume by avoiding capture of the stack
discharge in the downwash eddy downwind of structures. "Good Engineering Practice stack
height" is defined in 40 CFR Pan 51.1 as the greater of:
o 65 meters, measured from the ground level elevation at the base of the stack;
o The height of nearby structure(s) measured from the ground-level elevation at the base of the
stack plus 1.5 times the lesser dimension (height or projected width of nearby structures); or
o The height demonstrated by an approved fluid model or a field study which ensures that the
emissions from a stack do not result in excessive concentrations of any air pollutants as a
result of atmospheric downwash, wakes, or eddy effects created by the source itself, nearby
structures, or nearby terrain features.
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8.6 MQNTTORfNn RFPORTTNO AND RFCORH KFFP!NP.
8.6.1 MONITORING
Federal Regulations
The current NPDES regulations require sludge monitoring ax a frequency dependent upon the
nature and effect of the permittee's sludge use and disposal activities but at least once a year for
every pollutant limited in the permit. This means that if the permit contains a limit for mercury, the
permittee must be required to monitor sludge at least annually for this pollutant
Particulates and Opacity
The monitoring requirements for particulates and opacity from Subpart O of the NSPS (40 CFR
Part 60) are:
o Install, calibrate, maintain, and operate a flow measuring device which can be used to
determine the mass or volume of sludge charged to the incinerator. The flow measuring
device shall have an accuracy of plus or minus 5 percent over its operating range.
o Provide access to the sludge charged so that a well-mixed representative grab sample of the
sludge can be obtained.
o Use the test methods and procedures in Appendix A of 40 CFR Part 60 to demonstrate
compliance with the limitations on particulates and opacity.
o The required frequency of monitoring is presently just a one-time analysis during system
start-up.
A one-time stack test for particulate emissions is all that is required forparticulates and opacity at
present due to the interference of uncombined water in the determination of opacity.
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Opacity
It is desirable to require facilities to monitor opacity to allow the plant staff to better track and
control incinerator performance.
Mercury
Monitoring requirements for mercury from 40 CFR Pan 61 Subpart E are as follows:
o Unless a waiver of emission testing is obtained under 40 CFR Pan 61.13, each sludge
incinerator owner or operator shall test mercury concentrations within 90 days of start-up.
The test shall either be stack gas sampling or sludge-feed sampling as described in 40 CFR
Pan 61 Subpan E.
o The required frequency of monitoring per 40 CFR Pan 61 is the one-time stack gas analysis
within 90 days of system stan-up plus annual monitoring of mercury emissions or sludge
concentration for sources for which mercury emissions exceed 1,600 g/day, demonstrated
either by stack sampling according to 40 CFR Pan 61.53 or sludge sampling according to 40
CFR Pan 61.54, which assumes all mercury in the sludge is volatilized.
Beryllium
Monitoring requirements for beryllium from 40 CFR Pan 61 Subpan C are as follows:
o Unless a waiver of emission testing is obtained under 40 CFR Pan 61.13, each owner or
operator of a facility incinerating a waste containing beryllium shall test beryllium
concentrations within 90 days of stan-up. The emissions test shall be performed according
to Method 104 or Method 103 of Appendix B of 40 CFR Pan 61.
o The required frequency of monitoring per 40 CFR Pan 61 is the one-time stack analysis
within 90 days of system stan-up, then every 30 days at an air sampling site located in such a
manner as is calculated.to detect maximum concentrations in the~ambient air.
The requirements for beryllium monitoring apply only to facilities receiving waste from plants
which process beryllium, beryllium ore, beryllium oxide, beryllium alloys, or beryllium-containing
waste.
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Poiychlorinated Biphenyls (PCBs)
Incinerators that burn sludges containing more than 50 mg PCBs/kg of dry sludge solids must
comply with the monitoring requirements of 40 CFR Pan 761.70.
Operating Parameters
Revisions to 40 CFR Part 60 require the monitoring of a number of key operating parameters.
They require all sludge facilities subject to NSPS to:
o Continuously monitor and maintain records of sludge feed rale, temperature profile of the
incinerator, excess air levels/oxygen content of the exhaust gas and pressure drop across the
emission control device, and daily monitoring of the moisture and volatile solids content of
the sludge being incinerated; or
Continuously monitor and maintain records of the incinerator exhaust gas volumetric flow
rate and the pressure drop across the emissions control device.
If the values of these parameters then deviate significantly from their values during the initial
testing for particulates, the facility would be required to report the deviation.
o Initially test the sludge total solids content, volatile solids content, and metals concentrations
(arsenic, cadmium, chromium, copper, lead, nickel, selenium, and zinc) by grab samples.
o Testing of metals content (arsenic, cadmium, chromium, copper, lead, nickel, selenium,
zinc, beryllium, and lead) in emissions (in addition to the present initial testing of particulate
content of emissions).
o Performance tests of monitoring devices after they are installed.
Federal Guidance
The Sewage Sludge Interim Strategy recommends that for Class I facilities, the permit should
require an annual property pollutant scan and more frequent monitoring of the pollutants limited in
the proposed Sludge regulations (40 CFR Pan 503). These pollutants include: arsenic, beryllium,
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Revised 12/1/89
cadmium, chromium, lead, mercury, nickel and total hydrocarbons. Some of the factors permit
writers should use in determining frequency of monitoring includes size, compliance history,
influent, industrial users, population density and sensitivity of ecosystems surrounding incinerator.
The reported State-by-State monitoring requirements are summarized in Table E8-3. States with no
reported monitoring requirements are omitted from Table E8-3. Monitoring and reporting
requirements are broken out in Table E8-3 into five categories: emissions, sludge, ash, sludge feed
rate, and incinerator temperature. Of the 16 States included in Table E8-3,10 have
monitoring/reporting requirements for stack emissions, 9 monitor the sludge itself, 2 monitor the
ash, 3 monitor the incinerator temperature, and 2 monitor the sludge feed rate.
Case-bv-Case Recommendations
On a case-by-case basis, permit writers should consider requiring POTWs that use incinerators to
conduct the same monitoring as is required under NSPS, if such monitoring is deemed necessary
to protect public health and the environment from incinerator emissions.
Any deviations of parameters for which monitoring is required should be reported as such at the
same times that the facility is required to submit Discharge Monitoring Reports (DMRs) to the State
or to EPA.
8.6.2 REPORTING AND RECORD KEEPING
Federal Regulations
The recently promulgated revisions to be NPDES permitting regulations (54 FR 18716) require
that the permit contain a requirement that the permittee report monitoring results with a frequency
dependent upon the nature and effect of the sewage sludge use or disposal practice but in no case
less than once a year (40 CFR Part 122.44(i)(2). The regulations alsajequire that records
pertaining to the POTWs sludge use and disposal activities (as set forth in 40 CFR Part
501.15(2)(2)) be retained for 5 years (40 CFR Part 122.21(p)).
The current Federal reporting requirements for particulates, mercury, beryllium, and PCBs are
discussed below.
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Particulates
The owner or operator must provide the Administrator at least 30 days prior notice of the stait-up
performance test and furnish the Administrator a written report of the results of the performance
test.
Mercury
The Administrator shall be notified at least 30 days prior to die stack emission test required within
90 days of start-up. The samples from this test must be analyzed and mercury concentrations
determined within 30 days after this test. All determinations must be reported to the Administrator
by a registered letter dispatched before the close of the next business day following such
determination.
A new emissions Level must be estimated by calculation and the results reported to the
Administrator prior to any changes in operation that would potentially increase emissions above
that determined by the most recent source test
Facilities required to perform sampling at least once per year shall have the samples from each test
analyzed and mercury concentrations determined within 30 days after the test, and all
determinations shall be reported to the Administrator by a registered letter dispatched before the
close of the next business day following such determination.
Beryllium
The Administrator shall be notified at least 30 days prior to the stack emission test required within
90 days of start-op. The samples from this source test shall be analyzed and beryllium
concentrations shall be determined within 30 days after this test AU determinations shall be
reported to the Administrator by a registered letter dispatched before the close of the next business
day following such determination. Beryllium air sampling site test results are to be repotted every
30 days.
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Polychlorinated Biphenyls (PCBs)
Incinerators that bum sludges that contain more than SO mg PCBs/kg of dry sludge solids must
comply with reporting and record keeping requirements of 40 CFR Part 761.70. Permit writers
should consult with the Office of Pesticides and Toxic Substances.
Revisions to 40 CFR Pan 60 require reporting of the following performance test data every six
months:
o Every period of 1S minutes or more for which the pressure drop of the emissions control
device falls below a specified value.
o Every period of 1 hour duration or more when oxygen content of the exhaust gas exceeds 10
percent (wet basis) and the corresponding one hour average oxygen content of exhaust
gases.
o Incinerators achieving compliance with the New Source Performance Standards in a
performance test with over 10 percent oxygen in the exhaust gas would be allowed to reach
oxygen contents 3 percent above that of the most recent performance test on a one-hour
average before the exceedance must be reported.
o Facilities monitoring pollution control device pressure drop, oxygen content of exhaust
gases, and temperature profiles would report for each day there is a decrease in pollution
control device pressure drop or increase in content of oxygen in exhaust gas, report
temperature profiles, sludge feed rate, fuel use averaged over an 8-hour operating period,
and moisture and volatile solids content of the sludge samples. Facilities monitoring
pollution control device pressure drop and exhaust gas flow rate would report for each day
there is a decrease in scrubber pressure drop or increase in exhaust gas flow. The report
would include hourly average pressure drop and hourly average exhaust gas volumetric
flowrate for the entire day either violation occurred.
State Requirements
The State of Connecticut requires reporting for particulates, SO^ NOj, CO, and hydrocarbons.
The State of Georgia requires reporting for particulates, SO2, NOj, CO, ozone, and hydrocarbons.
The State of Tennessee requires reporting for beryllium, lead, mercury, vinyl chloride, and
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"others". The States of New Hampshire, Oregon, and Iowa also noted reporting requirements.
The State of Kentucky requires reporting for mercury if emissions or sludge analysis is greater
than 1,600 g/d. The State of Maryland requires a permit from Air Management Administration and
Waste Management The State of Missouri requires performance testing with representative
samples of material to be burned. The State of New Jersey requires modeling for risk assessment
of arsenic, chromium, cadmium and nickel.
REFERENCES
EPA 1972. Sewage Sludge Incineration, U.S. Environmental Protection Agency, R2-72-040,
Washington, D.C., August 1972, 95p.
EPA 1979. Process Design Manual for Sludge Treatment and Disposal, Technology Transfer
Series, U.S. Environmental Protection Agency 625/1-79-011, Cincinnati, OH, September 1979,
1135p.
EPA 1984. Environmental Regulations and Technology: Use and Disposal of Municipal Waste
Water Sludge, U.S. Environmental Protection Agency 625/10-84-003, Cincinnati, OH, 1984.
EPA 1985a. Municipal Wastewater Sludge Combustion Technology, U.S. Environmental
Protection Agency 625/4-85-015, Cincinnati, OH, 1985.
EPA 1985b. Summary of Environmental Profiles and Hazard Indices for Constituents of
Municipal Sludge: Methods and Results, U.S. Environmental Protection Agency Office of Water
Regulations and Standards, July 1985.
EPA 1987. State Requirements for Sludge Management, U.S. Environmental Protection Agency,
Office of Municipal Pollution Control and Office of Water Enforcement and Permits. (Revised
1989.)
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CHAPTER 9
SURFACE DISPOSAL
9.1 INTRODUCTION
EPA has identified approximately 2,400 POTWs that use surface disposal sites (54 FR 5946).
Currently, these sites are regulated by 40 CFR Part 257 as solid waste disposal facilities or
practices. Like the other use and disposal options discussed in this manual, surface disposal was
identified as one of the options needing regulation under 40 CFR Part 503. The proposed 40 CFR
Part 503 defines surface disposal as an area of land on which only sewage sludge is placed for a
period of one year or longer. This disposal practice includes sludge lagoons and stockpiles. The
agency further decided to regulate surface disposal because when these practices are employed for
more than just temporary storage, they pose threats to public health and the environment that are
similar to those arising from improperly managed monofills.
For purposes of classification as surface disposal, sludge lagoons are impoundments where liquid
sludge is placed. Sludge lagoons by definition are not a pan of the wastewater treatment train.
They do not include stabilization ponds or final polishing ponds. The sludge use and disposal
regulations are not intended to regulate wastewater treatment Figure 9-1 illustrates the difference
between a wastewater treatment lagoon and a sludge lagoon.
Sludge stockpiles are frequently litde more than above ground piles of relatively dry sludge.
Sometimes these stockpiles have impervious surfaces under the sludge. They may or may not
have run-off control structures. Sludge may be stored in piles temporarily before final disposal or
indefinitely.
If improperly managed, surface disposal sites can contaminate surface water via run-off or
washout during stomas. Surface disposal practices contaminate ground-water by leaching through
the soil. As lagoons dry out, the seal formed by the bottom layer of sludge may crack and
migration of pollutants may occur. These practices can also cause public health and safety hazards.
Decomposition of unstabilized sludge can create explosive atmosphere Unstabilized sludge also
causes vector attraction which can increase transmission of disease and pose a bird hazard to
airports near surface disposal sites. It is because of these potential problems that surface disposal
operations need to be regulated if the sludge is left for more than one year.
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a) Wastewater Treatment
Lagoon

-Settled Sludge—
JbmucoL

-Settled Sludge
Initial Treatment Lagoon
Polishing Pond
b) Sludge Storage/Disposal
Lagoon
Primary Treatment
Secondary Treatment
Effluent
! ¦
Settled Sludge
Figure 9-1.
Sludge Lagoon
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Because most surface disposal sites were developed as a temporary or stop-gap sludge
storage/disposal facility. EPA does not consider them to be environmentally acceptable solutions
for ultimate disposal. The use of these practices for more than short-term storage should be
discouraged, particularly by POTWs with sludges that contain significant levels of contaminants.
In some circumstances, the permit writer should also consider evaluating the effects of surface
impoundments where sludge is stored for less than one year. Situations where a review might be
appropriate include lagoons that are continually replenished and almost always filled with sludge,
sludge quality is generally poor, or site conditions are conducive to migration of contaminants from
the lagoon. Sludge storage piles also have the potential for adverse effect
This chapter summarizes the tools available to the permit writer for regulation of surface disposal
practices. It discusses sludge quality and facility operation and management practices. For each
topic, Federal regulations and State requirements are identified Additional guidance is provided
for development of case-by-case permit conditions for Class I sludge management facility permits.
9.2 CHARACTERISTICS OF SLUDGES SUITABLE FOR SURFACE DISPOSAL
9.2.1 SLUDGE POLLUTANT CONCENTRATION LIMITS
Federal Regulations
There are currently no Federal regulations limiting specific contaminant in sludge that is placed in
surface impoundments. Two Federal regulations identify characteristics which require special
treatment of sludge: (1) if the sludge contains concentrations of PCBs equal to or greater than SO
ppm, provisions of the Toxic Substances Control Act (40 CFR Pan 761) apply; and (2) if the
sludge is a hazardous waste it must be disposed of in accordance with RCRA Subtitle C See
Section S.4 for a brief description of tests used to certify that sludge is not a hazardous waste.
State Requirement*
One State (New Hampshire) prohibits the mixing of hazardous, toxic, or oily waste with sludge in
a sludge lagoon.
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9.2.2 SLUDGE PHYSICAL PROPERTIES
Federal Regulations
There are currently no Federal regulations with regard to sludge physical properties.
State Requirements
Six States have regulations addressing sludge physical properties for stockpiled sludge:
Connecticut and Wyoming require sludge dewatering; Minnesota allows liquid sludge storage at
municipally controlled sites; Nebraska allows the stockpiling of sludge with greater than 60 percent
solids; New Hampshire requires sludge dewatering to at least 20 percent solids; and Vermont
requires stockpiled sludge to have at least 15 percent solids.
9.3 OPERATING CONDITIONS AND MANAGEMENT PRACTICES
Required Permit Conditions
As mentioned above, the existing Federal regulations that apply to sludge lagoons and stockpiles
are set forth in 40 CFR Pan 257. These regulations are summarized in Table 5-1. The permit writer
should consult the text of the role for details and definitions (see Appendix D). As minimum
Federal permit conditions for sludge, the permit writer should write into the permit or reference
these existing Federal requirements for Class I POTWs that hold sludge in lagoons or stockpiles
for more than one year. Rather than simply reference the 40 CFR Part 257 standards, permit
writers should reference a valid solid waste permit for the facility that includes these standards, if
one exists. The permit writer should be aware that many Federal regulations apply to the initial
siting rather than operation of the surface disposal facility. There may be some cases where the
permit writer will need to require the POTW to identify an alternate sludge use or disposal option
because the current option violates the Federal regulations.
9.3.1 FLOODPLAIN RESTRICTIONS
Federal Regulations
Federal Regulations (40 CFR Part 257.3-1) do allow the location of sludge lagoons in the
floodplain, provided they do not restrict the base (100-year) flood, reduce the temporary water
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storage capacity of the floodplain, or result in the washout of solid waste to the extent that a hazard
would be posed to human life, wildlife, or water resources.
State Requirements
As shown in Appendix E, Table E9-1,24 States have regulations addressing sludge
lagoons/stockpiles in floodplains. Thirteen States prohibit sludge lagoon/stockpile siting within the
100-year floodplain. Two States have restrictions based upon the 25-year and 10-year flood line.
Twenty-two States require some kind of controls on surface flow, usually by the use of dikes or
berms (see Appendix E, Table E9-1).
Case-bv-Case Recommendations
Surface disposal operations pose a variety of problems during flood conditions. Sludge lagoons
which utilize some of the storage capacity of the floodplain may increase the velocity of the flood
which may in turn cause greater damage downstream. Sludge stockpiles are especially vulnerable
to washout. Whenever possible surface disposal sites should not be located in a floodplain. If
they are, structures to prevent run-on and run-off should be constructed to eliminate the threat of
washout of sludge during a flood. These structures should be sufficient to control and divert the
24-hour 25 year storm.
9.3.2 SURFACE WATER PROTECTION
Federal Regulations
Federal regulations (40 CFR Pan 257.3-3) require that the facility shall not cause a discharge of
pollutants to surface waters that is in violation of the National Pollutant Discharge Elimination
System (NPDES) under Section 402 of the Clean Water Act, as amended. Discharges from sludge
lagoons to waten of the U.S. must have NPDES permits. If run-off from a sludge stockpile
constitutes a point source discharge, the stockpile must also have a NPDES permit. In addition, a
facility shall not cause a discharge of dredged or fill material that is in violation of the requirements
under Section 404 of the Clean Water Act, as amended. Lastly, a facility or practice shall not
cause non-point source pollution of waters that violates applicable legal requirements implementing
an area wide or Statewide water quality management plan that has been approved by the EPA
Administrator under Section 208 of the Clean Water Act, as amended.

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State Requirements
Based on a summary of State requirements for sludge use and disposal, there do not appear to be
any State regulations or guidance on the discharge of pollutants from sludge lagoons beyond the
normal NPDES requirements. Nine States have minimum requirements for the distance to surface
waters ranging from 50 feet in Virginia to 1,000 feet in Minnesota. Minnesota provides for a
variance if there is run-off control at the facility.
Case-bv-Case Recommendations
The appropriate distance to surface water is a site-specific determination. A minimum distance of
100 ft between the lagoon or stockpile and surface water is recommended, provided adequate run-
on and run-off controls are in place.
9.3.3 GROUND-WATER PROTECTION
Federal Regulations
40 CFR Pan 257.3-4 requires that a facility or practice not contaminate an underground drinking
water source beyond the solid waste boundary. The solid waste boundary is the outermost
perimeter of the solid waste as it would exist at completion of the disposal activity.
Contamination is defined as introducing a substance that would cause the concentration of that
substance in the ground-water to exceed the Maximum Contaminant Level (MCL) specified in
Appendix I of 40 CFR Pan 257, or to increase the concentration of a substance already exceeding
the maximum contaminant level specified in Appendix I.
See Appendix D of this document for the maximum contaminant levels specified in Appendix I of
40 CFR Pan 257.
State Requirements
Several States indicated that soil type had some importance for the operation of sludge disposal
facilities. To protect ground-water, Connecticut and Wyoming both require an analysis of soil
type; Maryland requires a soil with low to moderate permeability, or a soil that will be sealed by
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biological activity underlie the lagoon. Soil type requirements for Maine are rated by slope,
permeability, flooding, drainage, and depth to bedrock.
Twelve States require minimum depths to ground-water (see Appendix E, Table E9-2): 2 feet
(Maryland and Wyoming); 3 feet (North Carolina); 4 feet (Massachusetts and Nevada); 5 feet
above highest anticipated ground-water level (New York and California); 6 feet (Vermont); and 10
feet to annual high water level (Colorado). Minnesota requires 8-inches of water holding capacity
above the seasonal high water table. South Carolina requires a consideration of hydrogeologic
conditions in the design of a storage lagoon.
Twenty-five States have regulations addressing the need for liners for sludge lagoons (Appendix
E, Table E9-1). Ten States require some form of leachate collection. Minnesota waives loading
and permeability requirements if leachate collection is employed.
Case-hv-Case Recommendations
Many factors need to be considered with regard to ground-water protection when siting a lagoon or
stockpile. Stockpiles should be located on an impervious surface. Permit writers should evaluate
whether sludge lagoons should have liners or leachate collection systems. Important factors to
consider are sludge quality, distance to drinking water wells, depth to ground-water, ground-water
flow direction and velocity, aquifer classification based on the EPA Ground-water Protection
Strategy (see Chapter 6), and underlying soil type and permeability. Permit writers should seek
the advice of an experienced engineer/hydrologist.
A minimum soil buffer (or overburden) of 4 feet is recommended between the bottom of any
lagoon or stockpile and the seasonal annual high ground-water table. Some of the important
factors to consider in determining whether depth to ground-water is appropriate are sludge quality,
the presence/absence of liners or leachate collection systems, the permeability of the soil buffer,
and the value of the ground-water underlying the facility.
While lagoons may be theoretically self-sealing, in practice they are an unreliable means of
isolating contaminants from the environment If a lagoon is allowed » dry out, the seal formed in
the bottom layer of a sludge lagoon could crack. If the lagoon is subsequently refilled, those
cracks could allow the migration of sludge contaminants into the groundwater. For this and many
other reasons, sludge lagoons are not considered to be an environmentally acceptable solution for
ultimate disposal, and the use of lagoons for more than short term storage should be discouraged.
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particularly for for POTWs with sludges that contain significant levels of contaminants. In the
end, the pen nit writer will have to evaluate lagoons on a case-by-case basis taking into
consideration such factors as 1) the thickness of the bottom seal and the likelihood of drying and
cracking, 2) soil properties and their influence on contaminant migration, and 3) the properties of
the sludge itself.
9.3.4 BUFFER ZONES
Federal Regulations
Federal regulation regarding buffer zones is found in 40 CFR Part 257.3-8. This regulation
requires any facility or practice dispensing of putrescible wastes that is within 10,000 feet of a
runway used by turbojet aircraft, or within 5,000 feet of any airport runway used only by piston-
type aircraft shall take steps to avoid a bird hazard to aircraft
State Requirements
Buffer zones are required in many States to protect surface water, ground-water, and public safety.
State Requirements for buffer zones fall into four areas: distance to surface water, distance to the
nearest dwelling, distance to wells, and distance to property lines.
As was described in section 9.3 2, nine States have minimum requirements for the distance to
surface water. Nineteen States have a requirement for a minimum distance to the nearest dwelling.
Five States require a minimum of 500 feet and six States require a minimum of 1/4 mile to the
nearest dwelling. Other State requirements are included in Appendix E, Table E9-1.
Five States require minimum distances to the nearest well ranging from 300 feet in Maine to
2,500 feet in Massachusetts. Two States (Massachusetts and Arizona) specify greater distances
from public drinking water wells than from private wells due to the increased size of the cone of
depression during withdrawal. One State requires the consideration of local water supply wells in
the sludge lagoon design. These State requirements are summarized ^Appendix E, Table E9-1.
Five States require setbacks from the property line ranging from 25 to 375 feeL These State
requirements are summarized in Appendix E, Table E9-1.
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Casc-by-Casc Recommendations
In the absence of appropriate State requirements, the following minimum buffer zones from
lagoons and stockpiles are recommended:
o Nearest Dwelling - 500 feet
o Nearest Drinking Water Well -1,000 feet The appropriate distance to the nearest water well
will depend on site specific factors including those discussed in die section on liners, depth
to ground-water, and ground-water monitoring.
o Property Line - 50 feet
9.3.5 ACCESS CONTROL
Federal Regulations
Federal regulation regarding access to a sludge disposal area is found in 40 CFR Pan Part
257.3-8. These requirements state that a facility or practice shall not allow uncontrolled public
access that would expose the public to potential health and safety hazards at the site. Unless
prescribed by State requirements, specific measures for access restriction should be determined on
a case-by-case basis.
State Requirements
Eleven States seek to control access to a site by the required use of fencing, locks, gates, and/or
signs (see Appendix E, Table E9-2).
fW.hv.raw RTnmn^nHari^
Access control measures (e.g., fences, gates, locks, and signs) shoulckbe imposed based on the
population density of the surrounding area.
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Revised 12/1/89
9.3.6 PATHOGEN AND DISEASE CONTROL
Federal Regulations
To protect the public health, Federal regulations in 40 CFR Part 257.3-6 require that a facility or
practice minimize the on-site population of disease vectors through the periodic application of cover
material or other appropriate techniques. Although cover material would not be appropriate for a
lagoon, other techniques such as sludge stabilization might be appropriate in order to reduce the
presence of disease vectors at the facility.
State Requirements
No State requirements were noted in regard to the control of disease vectors. However,
Connecticut and Colorado require stabilization of sewage sludge that will be stored or disposed of
in lagoons or stoclcpiles.
9.3.7 AIR QUALrTY CONTROL
Federal Regulations
Federal regulation 40 CFR Pan 257.3-7 prohibits the open burning of sludge. This would not be a
concern for a sludge lagoon.
State Requirements
Only three States, New York, Virginia and Minnesota, place restrictions on air pollution from
lagoons. Although no specific information was provided, these restrictions probably pertain to the
control of odors.
9.3.8 ENDANGERED SPECIES PROTECTION
Federal Regulations
Federal regulation 40 CFR Pan 257.3-2 prohibits the establishment of a sludge lagoon that will
cause or contribute to the taking of any endangered or threatened species of plant, fish, or wildlife
(See Table 6-1 and Appendix D). In addition, the facility or practice may not cause the destruction
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Revised 12/1/89
or adverse modification of the critical habitat of endangered or threatened species as identified in 50
CFR Part 17.
9.3.9 EXPLOSIVE GASES
Federal Regulations
Federal regulation 40 CFR Part 257.3-8 requires that the concentration of explosive gas not exceed
25 percent of the lower explosive limit for the gases in facility structures (excluding gas control or
recoveiy system components) or 100 percent of the lower explosive limit for the gases at the
property boundary. Accumulation of explosive gases are not usually a problem at open-air surface
disposal sites.
Case-bv-Case Recommendations
If there is a potential for generation of explosive gases, the permit writer should require tnooitoaiig
and the development of a safety action plan for responding to unsafe levels of explosive gases in
the atmosphere.
9.3.10 OTHER SLUDGE LAGOON RESTRICTIONS
State Requirements
Other State restrictions of sludge lagoons not covered in the preceding sections are described
below.
Three states require a minimum freeboard for sludge lagoons (Idaho, Texas, and New York).
Seven States require a site development plan. Two States require sludge stabilization or pathogen
control. Two Saaes have a loading limit. Five States require a closure plan. Six States require the
emptying or inspecting of the sludge lagoons. Six States have miscellaneous requirements that are
shown in Appendix E, Table E9-1.
Case-bv-Case Recommendations
o If an existing or future sludge lagoon or stockpile is going to be used for ultimate disposal,
development of a closure plan is recommended. The closure plan should address access
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Revised 12/1/89
restriction, cover, and ground-water monitoring requirements (sec 40 CFR Pan 257,
Appendix I, for contaminants recommended for monitoring). Sludge lagoons and stockpiles
should be discouraged as ultimate disposal practices.
o Minimum freeboard: The sidewall of the lagoon should always extend at least two feet above
the level of sludge/supernate in the lagoon.
o Sludge stored for more than one year in stockpiles should be stabilized by one of the sludge
stabilization processes described in Chapter 2.0. Where odor is a concern, i.e., in populated
areas, sludge that is stockpiled or stored in a lagoon should be stabilized regardless of die
amount of time it is stored
9.4 MONITORING. REPORTING. AND RECORD KEEPING
9.4.1 MONITORING
Federal Regulations
The current regulations require sludge monitoring and reporting at a frequency dependent upon the
nature and effect of the permittees' sludge use or disposal activities, but at least once a year for
every pollutant limited in the permit. This means that if the permit contains a limit for PCBs, the
permittee must monitor its sludge at least annually for this pollutant (40 CFR Part 122.44(c)(2)).
Federal Guidance
For Class I sludge management facilities the Sewage Studge Interim Strategy recommends annual
monitoring of the 126 priority pollutants, as well as more frequent monitoring of the pollutants for
which numeric limits have been proposed in the 40 CFR Part 503 technical sludge standards. For
surface disposal sfeea, these pollutants include:
Arsenic Dimethyl nitrosanrine
Benzene !
Benzo(a)pyrene Lindane
Bis(2*ethylhexyl)phthalate Mercury
Cadmium Nickel
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Revised 12/1/89
Copper Polychlorinated Biphenyls
DDT/DDE/DDD (Total)2 Toxaphcnc
Trichloroethylene
State Requirements
As shown in Appendix E, Table E9-2, State monitoring and reporting requirements can be divided
into the following categories: sludge monitoring, ground-water monitoring, surface water
monitoring, and reporting.
Eleven States require sludge monitoring. Three States require annual monitoring (Colorado,
Illinois and Wisconsin). One State requires monitoring of metals, PCBs, and pathogens
(Connecticut). Maryland, Virginia, New Hampshire, New Jersey, Missouri and Wyoming also
have sludge monitoring requirements.
Eighteen States require ground-water monitoring (see Appendix E, Table E9-2). Eight Stales have
some sort of conditional ground-water monitoring requirement One State requires monitoring of
specific parameters (Vermont). One State sets specific site requirements for monitoring wells
(Maryland).
Case-bv-Case Recommendations
Based on a review of site conditions, permit writers should consider requiring installation of
properly sited upgradient and downgradient ground-water monitoring wells for those sludge
lagoons with the potential for contaminating valuable aquifers. The important factors to consider
are listed above under the liner and depth-to-ground-water paragraphs. See Section 5.4 for more
information on assessing the need for ground-water monitoring systems and on appropriate system
designs.
2DDT-2,2-Bis(diloraphenyl) - 1,1,1-trichloroethane
DDE-1,1 -Bis(chlorophenyl>2,2-dichloroethene
DDD-1, l-Bis(chloTDphenyl>2,2-dichloroethane
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Revised 12/1/89
9.4.2 REPORTING AND RECORD KEEPING
Federal Regulations
The recently promulgated revisions to the NPDES permitting regulations (54 FR 18716) require
that the permit contain a requirement that the permittee repot monitoring results with a frequency
dependent upon the nature and effect of the sewage sludge use or disposal practice but in no case
less than once a year (40 CFR Part Part 122.44(i)(2)). These regulations also require that records
of any monitoring information that is required by the permit must be retained for at least five years.
State Requirements
Thirteen States require reporting of some type for sludge lagoons. One State requires reporting for
only permanent lagoons (Iowa). Two States require a quarterly summary of management records.
Other State reporting requirements can be found in Appendix E, Table E9-2.
REFERENCES
EPA 1986. U.S. Environmental Protection Agency, Subtitle D Study, Phase I Report, October
1986.
EPA 1987. U.S. Environmental Protection Agency, State Requirements for Sludge Management,
U.S. Environmental Protection Agency, Office of Municipal Pollution Control and Office of Water
Enforcement and Permits, Washington, D.C., 1987.(Revised 1989.)
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APPENDICES
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APPENDIX A
SEWAGE SLUDGE INERfM PERMITTING STRATEGY
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APPENDIX A
SEWAGE SLUDGE INTERIM PERMITTING STRATEGY
The attached "Sewage Sludge Interim Permitting Strategy" (Interim Permitting Strategy) describes
EPA's plans to help ensure the safe use and disposal of sewage sludge prior to the promulgation of
technical sludge standards. This Interim Permitting Strategy implements Section 406 of the Water
Quality Act of 1987, PJL. 100-4 (codified at Section 405 (d)(4) of the Gean Water Act), which
provides that, prior to sludge technical standards, EPA must "impose sludge conditions in
(NPDES) permits issued to (POTWs)... or take such other measures as the Administrator deems
appropriate to protect public health and the environment from any adverse effects which may occur
from toxic pollutants in sewage sludge."
The Interim Permitting Strategy:
o Discusses how to identify priority facilities for sludge permitting and basic permit
requirements;
o Describes the permit writers' guidance document for writing interim sludge conditions;
o Describes EPA/State coordination of interim sludge permitting activities; and
o Provides model documents for use in implementing the Interim Permitting Strategy (boiler-
plate permit language and State/EPA agreements, etc.)
A copy of the Interim Permitting Strategy document, including Attachments, can be obtained from
the Permits Division (EN-336), 401 M Street S.W., Washington D.C. 20460. For further
information concerning the strategy, contact Martha Kirkpatrick (202) 475-9529.
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Sewage Sludge
Interim Permitting Strategy
Office of Water
Office of Water Enforcement and Permits
September 1989
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INDEX
SEWAGE SLUDGE INTERIM PERMITTING STRATEGY
STATEMENT OP POLICY
I. INTRODUCTION
II. GENERAL REQUIREMENTS FOR ALL POTW PERMITS
III. CASE-BY-CASE CONDITIONS FOR CLASS 1 POTWS
IV. STATE AND EPA COORDINATION ON INTERIM SLUDGE PERMITTING
ATTACHMENTS:
1. Boilerplate Revision# for Sludge
2. Expired and Expiring Permits for Pretreataent POTWs
3. All Sludge Incinerators
4. Pollutants Proposed to be Limited in 40 CFR Part S03
5. Model Certification of EPA Approval of State-Issued
Sludge Permits
6. Model EPA "Sludge Rider" to a State-Issued Permit
7. Model State/EPA Sludge Agreement
8. Clean Hater Act Section 40S, as amended by the
Water Quality Act of 1987
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SEWAGE SLUDGE INTERIM PERMITTING STRATEGY
STATEMENT OF POLICY
In order to implement the requirements of Section 405(d)(4) of
the Clean water Act, it is EPA policy that:
1. All NPDES permits issued or reissued to POTWs after February
4, 1987 shall at a minimum: require that the permittee
comply with all existing federal regulations governing the
use and disposal of sewage sludge, and with applicable 40
CFR Part 503 Standards for the Use and Disposal of sewage
Sludge when promulgated; contain a statement that upon
promulgation of 40 CFR Part 503 the permit may be reopened
and modified or revoked and reissued to incorporate
applicable requirements of 40 CFR Part 503; and require that
the permittee notify the permit authority of any significant
change in its sludge use or disposal practices.
2. Priority POTWs for the purposes of interim sludge permitting
are "Class 1 sludge management facilities," defined as POTWs
l) that are required to have pretreatment programs, or 2)
that have any other known or suspected problems with their
sludge. Sludge incinerators are presumed to have "known or
suspected problems" unless available information shows no
cause for concern.
3. All NPDES permits issued to priority POTWs after February 4,
1987 shall contain, in addition to the minimus conditions in
Paragraph 1, additional conditions developed on a case-by-
case tasia to ensure protection of the public health and
environment.
4. Permit writers should use EPA's "Guidance for Writing Case-
by-case Permit Requirements for Municipal sewage Sludge" for
developing case-by-case permit conditions for priority
POTWs.
5. All permits issued or reissued to POTWs should contain
sludge monitoring requirements in accordance with the Sewage
sludgs Interim Permitting strategy.
6. States are encouraged to participate to the fullest extent
possibls in interim sludge permitting.
7. The proposed 40 CFR Part 503 numeric limits for the use and
disposal of sewage sludge should not bm relied on for
developing interim permit conditions, because these numeric
limits may change as a result of public comment or pssr
review. However, other information and methodologies found
in the proposed Part 503 rule and preamble, and its
Technical Support Documents, may be used if the permit
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writer determines their appropriateness (or the sludge
practice at issue.
8. States may obtain formal approval of their sludge programs
prior to promulgation of the Part 503 standards. They may
also elect to participate in interim permitting through
agreements with their EPA Regional offices, pursuant to the
Sewage Sludge Interim Permitting Strategy.
9. Where the State is issuing sludge permits pursuant to an
agreement with the EPA Regional office, the Region will
review all permits issued to priority facilities to
determine if the permit meets CWA requirements. If the
permit satisfies the CWA, the Region shall so certify and
attach the certification to the permit.
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I
INTRODUCTION
Section 40S of the Clean Water Act embodies Congress'
concern with the environmental threats posed by unsafe sewage
sludge use and disposal. Congress re-emphasized its concern in
1987 by amending this section to require EPA to develop detailed
technical standards for sludge use and disposal that would be
adequate to protect public health and the environment from sludge
pollutants. The technical standards (to be codified at 40 CFR
Part 503) will, when promulgated, identify pollutant levels of
concern in sludge for the major use and disposal methods.
However, before the standards are finalized, we need a program to
identify and address potential problems that may be caused by
contaminated or improperly disposed sludge, and to prepare for
the implementation of the standards.
In the 1987 amendments to the Clean Water Act Congress
recognized the need to take immediate action to regulate sludge.
CWA Section 405(d)(4), as amended, requires that prior to the
sludge standards, EPA must "impose sludge conditions in [NPDESJ
permits issued to [POTWs] ... or take such other measures as the
Administrator deems appropriate to protect public health and the
environment from any adverse effects which may occur from toxic
pollutants in sewage sludge." Thus, the amendments direct EPA to
protect the environment from unsafe sludge, and initiat* sludge
permitting. This phase of the program, which began with passage
of the Water Quality Act on February 4, 1987, is referred to as
the "interim" sludge program and is the primary subject of this
Strategy.
The Act establishes a two-phase approach to regulating
sludge use and disposal. The first phase, interia implementa-
tion, commenced with the passage of the amendments. The second
phase, long-term implementation, begins with final promulgation
of the first round of the technical standards. Those standards
are to identify toxic pollutants of concern in sewage sludg#, and
specify numerical pollutant limits and management practices for
sludge to ensure environmentally-sound use and disposal. The
Clean Water Act requires that users and disposers of sewage
sludge comply with the standards within one year from promulga-
tion (two years if construction is required). The Act also
requires that the standards be incorporated into permits issued
to POTWs and other treatment works treating domestic sewage. The
proposed standards were published on February 6, 1989 at 54 £B
5746; final regulations are scheduled to be promulgated in
October 1991.
The purpose of interim implementation is to establish a
program for long-term implementation, and to ensure that the
environment is protected from improper sludge use and disposal
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prior to promulgation of the technical standards. This Strategy
provides the details of implementing the interim phase. The
requirement to take immediate action to regulate sludge use and
disposal takes on critical importance since technical regulations
are not scheduled to be promulgated until 1991.
This document explains EPA's approach to sludge permitting
prior to issuance of the technical standards. To best achieve
the objectives of the Clean Water Act, the interim program
utilizes existing experience, expertise, and permitting processes
to focus permitting efforts on the facilities which, on the basis
of available information, are thought to present greater risk.
There are three principal components to the Interim Strategy:
1. All NVDE8 permits issued to POTWs after February 4,
1987 are to contain certain basic requirements for
managing sludge. Many of these requirements were
included as part of the May 2, 1989 Sludge State
Program and Permitting Pinal Rule.
2. Por certain "priority" ("Class 1") POTWs, additional
permit conditions developed on a case-by-case basis are
needed to satisfy CWA section 405(d)(4).
3. Permits containing sludge conditions are to be issued
by EPA, or by a state pursuant to a state/BPA
agreement, or by a state program that has been approved
pursuant to 40 cm Parts 123 or sol, as appropriate.
Part II of this Strategy identifies pernit conditions that
are to be included in all POTWs' HPDES permits as they are
reissued. The most significant change in the final Interim
Strategy from the draft that was made available for public
comment in a May 31, 1988 Federal Register notice is the
discussion of standard permit requirements. The Sludge State
Program and Permitting Requirements Final Rule, aaong other
things, codifies the interim requirements of cwa Section
405(d)(4), and establishes standard requirements and application
deadlines for including sludge conditions in all POTW permits.
Thus, many of the permitting provisions in the draft Interim
Strategy arm nov regulatory requirements. Part II describes the
new requirements, additional recommendations, and sludge
monitoring provisions.
A discussion of "Class 1" POTWs and the development of
additional, case-by-case conditions for these facilities is found
in Part III.
Part IV discusses State/EPA coordination on sludge permit
issuance during this interim period. Many States currently have
sludge permit programs. One of the objectives of this Interim
Strategy is to build on these existing programs as much as
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possible, while meeting the requirements of the Act. The purpose
of this is to take advantage of the State experience and
expertise in sludge control and reduce redundant and unnecessary
permitting. Thus, where a State has a sludge permitting program
in place but is not yet seeking formal approval, the Strategy
provides for CWA Section 405(d)(4) interim permitting under a
State/EPA Agreement. These agreements should be in place by
December 30, 1989.
In summary, EPA and the States need to begin immediately to
identify and address potential sludge problems, to lay the
foundation for an effective permitting program that protects the
environment and promotes resource recovery. EPA's statutory
responsibility to take interim measures with respect to sludge
requirements for POTWs became effective upon enactment of the
Water Quality Act on February 4, 1987. This Strategy is designed
to carry out these objectives as quickly as possible, focusing on
the facilities of concern and building on existing experience and
expertise. Throughout the interim period, the office of Water
Enforcement and Permits (OWEP) will be providing additional
information and guidance on sludge program implementation through
permits. OWEP is currently providing both technical guidance and
contractor assistance to Regions and NPDES States to conduct
permit writing. OWEP also has been holding permit writers
workshops for the Regions and States on developing interim permit
conditions. Implementation of this Strategy not only enables EPA
and the States to carry out the immediate responsibilities under
the Act to protect public health and the environment, but also
furthers the objectives of facilitating compliance with the
technical standards whan promulgated and approving State programs
to carry out the requirements of Section 405.
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II
GENERAL REQUIREMENTS FOR ALL POTW PERMITS
This Part describes the requirements for sludge permitting
that were promulgated on May 2, 1989 (54 EB 18716) and became
effective on June 1, 1989. These regulations, called the sludge
State program and permitting regulations, among other things
codify the requirements for interim sludge permitting in CWA
Section 405(d)(4). (Sfifl 5122.1(g)(5)). in addition, this Part
contains some additional recommendations for standard interim
conditions for all POTWs. (Part III discusses additional permit
conditions for NClass 1" facilities.)
All reissued POTW permits must include some general
requirements for sludge use and disposal, whether or not the
facility needs additional case-by-case limits. These are the
minimum provisions necessary to begin permit coverage of sludge
use and disposal practices in anticipation of the long-term
program, and to enable sufficient oversight of these activities
in the interim. Most of these provisions are now required
specifically by regulation. See 54 £B 18716 (May 2, 1989). The
four primary areas each permit must address are: compliance with
existing requirements; reopening the permit when the 503
regulations are promulgated; notification of change in sludge
practices; and sludge quality monitoring. Attachment 1 contains
a list of NPDES boilerplate conditions revised to include sludge
conditions in accordance with the May 2, 1989 final rule,
establishing new sludge permitting requirements.
Application Ptadllnt
Section 122.21, which contains the NPDES permit application
requirements, was revised by the May 2, 1989 notice to include
permit application deadlines and application requirements for
sludge. Under 1122.21(c)(2), all POTWa with NPDES parmits must
submit information (including: sludge production, sludge use and
disposal practices, and existing information on sludge quality,
as set forth in 1501.15(a)(2)) with their application for NPDES
permit renewal, or 120 days after promulgation of the technical
sludge standards, whichever occurs first. (All other "treatment
works treating domestic sewage" do not need to submit an
application for sludge parmit coverage until 120 days after
promulgation of applicable sludge technical standards, unless
requested by the permit authority where necessary to protect
public health and the environment. 1122.21(c)(2)(ii).)
BollOTlatt Condition!
The first standard permit condition is a compliance
provision: the permit must require the POTW to comply with all
existing requirements for sludge use and disposal.
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§122.44(b)(2). For example, a POTW that applies its sludge to
land is subject to the applicable requirements of 40 CFR Part
257. This compliance must be required in the permit and
monitored by permit oversight.
Permit vriters should ascertain the existence of any other
permit governing the facility's sludge use or disposal practices
before developing sludge conditions for the NPDES permit, whether
the facility is a priority or not. Under the new regulations,
applicants are required to submit a list of other permits
governing their sludge management activities issued or applied
for under other laws (§122.21(d)(3)(ii); 5501.15(a)(2)(v)). For
example, an incinerator may currently be subject to a permit
under the Clean Air Act, a landfill under a RCRA permit, or the
facility may be subject to a State permit. If these are adequate
to satisfy Section 405(d), the NPDES permit need only reference
the other permit, and add any additional requirements if
necessary to protect public health and the environment. Also, in
the course of developing the other permit, the permitting agency
may have information on the sludge quality or use and disposal
practices that may save the NPDES permit writer considerable time
and effort.
This compliance provision also requires compliance with the
sludge technical standards by the deadlines established in those
standards. This provision restates (and puts the permittee on
notice of) the CWA Section 405 requirement that users and
disposers of sewage sludge comply with the technical standards
for sludge use and disposal by the statutory compliance deadlines
(i.e., within one year after promulgation of the standards, or
within two years if the standards require construction), even if
the permit has not been modified to include such requirements.
See S122.41(a) (1). Any "permit-as-shield" provision in the
permit also should be revised to indicate that compliance with
"interim" permit conditions does not excuse noncompliance with
subsequently promulgated technical sludge standards. See S122.5.
Another permit condition is a reopener clause, which
authorize* reopening a permit to include technical standards if
the technical standards are more stringent or more comprehensive
than the conditions in the permit. See 1122.44(b)(2) and (c)(4).
This enables, but does not require, reopening the permit if the
permit writer feels it is necessary to encorporate final Part 503
requirements. Consistent with the sludge State program and
permitting regulations, reopening the permit when the technical
standards are promulgated is discretionary with the permitting
authority, not mandatory. Thus, the permitting authority will
have flexibility to establish permitting priorities for
implementing the technical standards. OWEF anticipates issuing
additional guidance on this subject when Part 503 is promulgated.
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The reopener provision notifies the permittee of future
legal obligations under the Act, and of the potential need to
modify the permit to incorporate Part 503 requirements once they
are promulgated. The reopener provision also enables the
permitting authority to develop permit conditions to assure
compliance with the technical standards by the deadlines
established in Section 405(d)(2) of the CWA. Revisions to
§122.62(a)(7) now specifically authorize permit modifications
pursuant to the reopener provision. The statement of basis or
fact sheet for the permit should include a reference to the
compliance provision and any other provisions that are in the
permit to implement Section 405.
A notification provision, now codified in revisions to
§122.41(1)(1)(iii), must be included in all reissued permits.
This requires the permittee to give notice to the permitting
authority when a significant change in the sludge use or disposal
practice occurs (or is planned) that could require permit
modification under 40 CFR 122.62(a)(1). The permittee need not
notify the permit authority of every change, however slight, to
its sludge use and disposal activities. However, a change in the
POTW's sludge disposal methods, for example from landfilling to
land application, is certainly significant as it could be cause
for permit modification. Notice of, and possible permit
modification for, new use or disposal sites not previously
identified to the permitting authority (except land application
sites covered by an approved land application plan) is also
required (§122.41(1)(i)(iii)).
In addition to the standard sludge boilerplate conditions
described above, (see Attachment 1 for permit language), the
preamble to the recent revisions to the Part 122 regulations
explains that many of the standard permit conditions that apply
to effluent discharge activities will also apply to sludge use
and disposal activities (e.g., duty of proper operation and
maintenance ,• entry and inspection duties). Conversely, a fev of
the Part 122 regulations have been revised to limit their
applicability only to effluent discharge activities (e.g., the
"anti-backsliding" provision in §122.41(1)). Additionally,
several provisions remained unchanged because the existing
language was sufficient to include or exclude sludge use and
disposal activities, as appropriate. The preamble discussion at
54 ££ 18743 explains which provisions apply and do not apply to
sludge activities. Permit writers should make revisions to the
standard boilerplate conditions consistent with the revised
regulations.
Monitoring Conditions
Another important component of interim permitting is sludge
quality monitoring. Sludge monitoring to establish baseline data
on each facility for future permit requirements is especially
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critical as nost interim permits, at least in the beginning, will
contain few, if any, concentration limits for pollutants in
sludge (and therefore, compliance monitoring will yield only
limited information). Thus it is important for fulfilling the
statutory requirement to protect public health and the
environment that the permit writer have current information on
pollutant concentrations, to alert the permit writer as to
excessive loadings that may make a given sludge use or disposal
method unsafe.
The regulations now require sludge monitoring and reporting
at a frequency dependent on the nature and effect of the per-
mittee* s sludge use or disposal activities, but at least once a
year (1122.44(i)(2)). This means that where the permit contains
pollutant limits (e.g., the permit to a POTW that applies its
sludge to land must contain the 40 CFR Part 257 limits for
cadmium and PCBs, and pathogen requirements), the permit must
require the permittee to sample and analyze those pollutants at
least once a year. Beyond compliance monitoring, the regulations
do not specify which pollutants in sludge must be monitored in
the interim before promulgation of the technical standards,
similarly, the sludge application requirements do not specify
standard monitoring results which Bust be submitted for permit
issuance (although they do require applicants to submit all
available data).
Because the regulations only require compliance monitoring,
and because compliance monitoring, given the fact that few
permits are likely to contain pollutant limits, will not yield
enough information, the permit writer should require monitoring
of additional pollutants, based on his/her best professional
judgment. In some cases the perait may already require sludge
sampling and analysis, and the permit writer may have a good idea
as to the quality of the sludge and the levels of pollutants it
contains. In the absence of such information, EPA recommends
that at a minimum, the permit writer include the following
monitoring requirements in the permit:
o For Class 1 POTWs. an annual scan of the 126 priority
pollutants, and more frequent monitoring of the
pollutants for which numeric limits have been proposed
for the POTtf's particular use or disposal practice in
the proposed Part 503 regulations (see Attachment 4).
o For non-clan l row wltti Influatrlal unri, a priority
pollutant scan at the time of peniit application, and
annual monitoring of the pollutants for which numeric
limits have been proposed for the POTH's particular use
or disposal practice in the proposed Part 503
regulations (see Attachment 4).
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o For non-Class 1 POTWs with no industrial uset;fff annual
monitoring of six metals: cadmium, copper, chromium,
lead, nickel, and zinc.
Of course, monitoring requirements would be tailored to the
particular POTW and would take into consideration site-specific
factors, such as the types of industrial wastes the POTW
receives. At the discretion of the permit authority, if a
pollutant is not detected or is detected at low levels that
clearly show no cause for concern after repeated tests, future
testing for those pollutants need not be required unless a change
occurs at the POTW.
The reason for monitoring for the pollutants proposed to be
limited in the Part 503 proposed rules is so the POTW and the
permit authority will have sufficient information on sludge
quality with regard to those pollutants when the Part 503 rules
are finalized. This is particularly important in light of the
one-year compliance deadline mandated by the Clean Water Act.
(Note that once the Part 503 regulations are promulgated,
monitoring parameters will b« governed by those rules (and 40 CFR
Part 122.44(i)(2)). The Guidance for Writing Case-by-Case Permit
Conditions for Municipal Sewage Sludge (described in Part III)
contains further recommendations for developing conditions for
additional baseline monitoring for pollutants of concern and
compliance monitoring for each major use and disposal practice.
(A list of the pollutants proposed to be regulated in 40 CFR Part
503, by use or disposal method, is provided in Attachment 4.)
This Strategy recommends that non-Class 1 POTWs with no
industrial users at a minimum sample for six metals that are
commonly found in sewers at significant levels due to commercial
and domestic discharges to the treatment works. If the permit
writer has pre-existing data on the sludge quality of th«
facility that shows no cause for concern with particular
pollutants for that POTW's sludge practices (i.e., routine
readings of particular pollutants which are very low or not
detected), monitoring for that pollutant does not need to be
continued unless there is a change at the POTW. Another
exception is for POTWs that use wastewater stabilization lagoons
as the sole treatment process. For these facilities, where the
sludge will not b« removed from the lagoon during the permit
term, the permit need not contain any sludge monitoring
provisions unless the permit writer determines they are needed.
(If such permit does not require monitoring, it nhould contain a
requirement that the permittee notify the permit authority if it
happens that the sludgs is pumped out of the lagoon within a one-
year period.)
The permit should also specify appropriate sampling
protocols. To develop these requirements, permit writers are
directed to two sources. The first is entitled "POTW Sludge
10
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Sampling and Analysis Guidance Document," EPA, Office of Water
Enforcement and Permits, 1989. This document is designed to
provide information on the sampling and analysis of municipal
sewage sludge, and contains discussions of procedures and
protocols, and current developments on specific topics such as
pathogen equivalency determinations. The second document is
entitled "Sampling Procedures and Protocols for the National
Sewage Sludge Survey," EPA, Office of Water Regulations and
Standards, 1988. The sampling procedures and protocols included
in this document were compiled specifically for the National
Sewage Sludge Survey, which the Agency has initiated to gather
additional information on the pollutants in sewage sludge to
support the Part 503 rulemaking.
The permit also should specify the acceptable analytical
methods. A notice published at 53 39133 (October 5, 1988)
lists all pollutants, and the methods used to analyze them, that
were tested in the national sewage sludge survey. The question
of appropriate analytical methods for determining pollutant
concentrations in sewage sludge has been an ongoing one. Methods
624 and 625, found in 40 CFR Part 136/ are essentially adapted
from wastewater analytical methodologies. These methods have
been in longer use and thus are more widely available. EPA's
newer isotope dilution, gas chromatography/mass spectrometry
(GC/MS) methods 1624 and 1625 have been developed specifically
for sewage sludge. The permit writer may specify these methods
or other EPA-approved methods, or methods that are deemed
comparable based on their precision, accuracy, lab availability,
interlab variability, and the level of detection needed to
monitor compliance.
Most of the general monitoring and recordkeeping require-
ments in Part 122 apply to sludge monitoring and recordkeeping
(e.g., $5122.41(j) and 122.48). There are two important
differences, however. First, the regulations do not currently
prescribe specific monitoring reporting forms. Instead, the
permitting authority has discretion to determine an appropriate
form ($122.41(1)(4)(i)), which should be specified in the permit.
Second, the record retention time for sludge records is five
years, rather than the three-year period that applies to effluent
discharge recordkeeping. ($122.21(p) and $122.4l(j)(2)). (The
rule provides a longer record retention tine for sludge because
of the need to track cumulative loadings for metals in sludge
that is applied to land over a longer period. The five-year
record retention time will enable this information to be "carried
over" when the perait is reissued.)
Suaaary
In sua, to fulfill the objectives that Congress has
established in Section 405(d), we must begin as soon as possible
to establish permit requirements for sludge. All POTW permits
11
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must include compliance provisions, notification language, and
monitoring requirements as described above and specified in the
regulations, and should include sludge quality monitoring as set
forth in this Strategy. In addition, case-by-case permit
requirements will need to be developed as appropriate. This is
discussed in Part III.
12
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Ill
CASE-BY-CASE CONDITIONS FOR CLASS 1 POTWS
The previous section discusses basic permit requirements for
all NPOES permits issued or reissued to POTWs after February 4,
1987. There are situations, however, where more comprehensive,
site-specific permit coverage may be warranted. This may mean
more frequent monitoring or other site-specific conditions such
as management practices or numeric limitations developed on a
case-by-case basis. This gives rise to two questions: which
POTWa should receive more comprehensive permit coverage during
this interim period, and what should be included in the permits
issued to such facilities.
Identifying Permitting Priorities; Class 1 Sludge Management
Facilities
A major purpose of requiring case-by-case sludge limits only
for certain POTWs is to target available resources for sludge
permitting on critical sites. In earlier versions of this
Strategy, which generally referred to POTWs with known or
suspected problems with sludge quality or use/disposal practices,
or those warranting more comprehensive sludge permit conditions
for other reasons. The draft Strategy suggested that
pretreatment POTWs, POTWs incinerating their sludge, POTWs using
or disposing of sludge in ecologically-sensitive areas such as
estuaries, and new POTWs should be evaluated closely to determine
if tHey should be included in the priority category.
The recently promulgated sludge management regulations also
identify a group of POTWs targeted for closer oversight because
of the greater potential for their sludge use and disposal to
adversely affect public health or the environment. These are
called "Class I sludge management facilities." Thus, this
definition and the earlier "priority" POTW designation serve
similar purposes and are based on tha same rationale. To
facilitate long-ten implementation, "Class I sludge management
facilities" will ba presumed to need case-by-case sludge interim
limits (l.a«, they should be considered permitting priorities),
unless tlMi permitting authority determines, baaed on Information
about the facility's sludge quality and use or disposal
practices, that the sludge is adequately controlled already. In
this Strategy, the terms "priority" and "Class 1" facility are
used interchangeably.
A Class Z sludge management facility is defined ast
...any POTW identified under 40 C7R 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
13
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pursuant to 40 CFR 403.10(e)) and any other treatment
works treating domestic sewage classified as a Class I
sludge management facility . . . because of the
potential for its sludge use or disposal practices to
adversely affect public health and the environment.
Pretreatment POTWs were included in the definition of "Class I
sludge management facilityN in response to numerous requests for
more specificity in defining priorities. In addition, the same
factors that determine whether a POTW should be required to
develop a local program (i.e., size, industrial users subject to
pretreatment standards, or necessary to prevent pass-through or
interference with the POTW's operations) also suggest that
sludges from pretreatment POTWs have a greater potential for
having significant impacts on public health and the environment.
"Class I sludge management facilityN also includes other
treatment works with known or potential sludge problems. In
assessing the risks associated with the various sludge use and
disposal options, EPA has found that the potential risk levels
are highest for incinerators. In addition, in a recent Agency
study of comparative risks, sewage sludge incinerators were
identified as one of the potentially more harmful sludge use and
disposal practices. Overall, the risk was assessed to be in the
middle range in comparison to other environmental problems. See
"Unfinished Business: A Comparative Assessment of Environmental
Problems," U.S. EPA, Office of Policy, Planning and Evaluation,
February 1987. Because of this, POTWs using incineration should
be presumed to need case-by-case sludge permit limits, unless the
permit writer has information demonstrating that there is no
cause for concern. (Mote: Most POTWs incinerating their sludge
are also pretreatment POTWs. Therefore, only those POTWs using
incineration which are not required to have pretreatment programs
will need to be considered additionally. See Attachment 3.)
Attachment 2 contains listings of pretreatment permits that
have expired or expire in PY89 and FY90. A separate listing
shows the POTWs that incinerate their sludge and gives the
expiration dates for the NPDES permits.
Other POTWs may have kncvn or potential sludge use and
disposal problems. A POTW in non-compliance with existing
federal regulations (e.g., 40 CFR Part 257) is one example. When
the NPDES permit is due to be reissued, the permitting authority
will need to make a determination whether the facility will need
case-by-case limits. Case-by-case limits should not be rejected
simply because the permitting authority has no knowledge of any
sludge problems. Instead, the permit writer should take
reasonable steps to ascertain the nature of the facility's sludge
and sludge disposal practices. Under the May 2, 1989 sludge
management regulations, POTWs are required to submit basic
background information and available monitoring results on their
14
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sludge and use and disposal methods with their NPDES permit
renewal application. 40 CFR 122.21(c)(2). Other available
information also should be examined, such as pretreatment audit
reports and investigations into interference problems at the
POTW, to see if any problems with sludge have been identified.
Also, POTWs conducting sludge use or disposal in ecologically
sensitive areas, such as estuaries, may warrant more
comprehensive sludge permit conditions beyond the basic
boilerplate and monitoring requirements.
Permits issued to POTWs with new sludge treatment facilities
should also be carefully considered for development of case-by-
case sludge conditions. Although )cnown problems may not exist,
preventing problems through careful controls at new facilities is
generally easier for both the permitting authority and permittee
than talcing remedial action after a problem has developed.
(Note: this paragraph does not refer to situations where a POTW
has switched to another existing facility, for example, to a
different monofill, but rather, refers to treatment facilities
that are newly constructed.)
One commenter on the draft strategy suggested that the nine
sewerage authorities in New York and New Jersey that dispose of
their sewage sludge in the ocean should also be identified as a
"priority** for interim sludge permitting. The Marine Protection,
Research and Sanctuaries Act of 1972 (MPRSA) regulates ocean
disposal, and prohibits ocean dumping without a permit issued
pursuant to MPRSA. In November 1988, Congress passed the Ocean
Dumping Ban Act, amending MPRSA. Among other things, the purpose
of this Act is to terminate the ocean-dumping of sewage sludge by
December 1991. The significance of this legislation for the
implementation of Section 405 of the CWA is that after December
31, 1991, it will be unlawful to dispose of sewage sludge in the
ocean, and those POTWs that currently ocean-dispose of their
sewage sludge will have to develop land-based sludge management
alternatives, which will be subject to the jurisdiction of
Section 405 of the clean water Act. Prior to the termination of
dumping, State and Regional NPDES and sludge permit writers
should work with the POTWs and MPRSA authorities to identify the
quality of the sewage sludge and assist the POTWs in developing
land-based sludge use or disposal methods. This involvement is
not for purposes of regulating the practice of ocean disposal,
which will be effected through the MPRSA permit process, but
rather, to assist the facility in implementing land-based
disposal methods that will meet the requirements of CWA Section
405.
Case-bv-Case Permit Conditions
To assist permit writers in developing more comprehensive
permit conditions for Class 1 facilities, EPA has developed a
"Guidance for Writing Case-by-Case Permit Requirements for
15
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Municipal Swage Sludge" (*CbC Guidance1*). The purpose of the
guidance is to assist permit writers in developing appropriate
permit conditions for sludge and EPA permit writers in reviewing
State permits issued to Class 1 POTWs.
As stated earlier, the most important task for the interim
period is to ensure that existing requirements are written into
permits. Us* of the CbC Guidance ensures that existing
applicable federal and State requirements are incorporated into
permits issued to Class 1 POTWs. Its use should help to promote
timely compliance with the Part 503 sludge regulations when
issued, by those POTWs most likely to cause adverse effects from
pollutants in sewage sludge. (The Part 503 sludge regulations
will require compliance within one year from promulgation.) In
addition, compliance with the monitoring requirements specified
will provide information on sludge quality and the use and
disposal practices at the POTW, and help to identify potential
problems.
As a "best professional judgment1* guidance document, the CbC
Guidance presents: 1) a compilation of existing federal and State
requirements for sludge; 2) existing guidance; and 3) recommenda-
tions for permit writers to consider writing into permits on a
case-by-case basis using their best professional judgment. The
CbC Guidance sets forth existing requirements for each of the
major sludge use and disposal practices. Additionally, the
Guidance contains recommendations for further permit conditions.
In general these recommendations consist of management practices,
although some recommended numeric limits are given, based on
existing guidance. The CbC Guidance states that EPA permit
writers must write existing federal sludge requirements into
NPOES permits or Incorporate them by reference to other permits.
The Guidance may be used by Regional and State permit
writers to assist thea in arriving at appropriate permit limits
for priority facilities, and by the Regions in reviewing State-
issued permits. The fact sheet or statement of basis
accompanying the permit aust explain the basis for arriving at
the sludge requirements. BPA and States say take further action
beyond what aay be specified in the guidance, where appropriate
to protect public health and the environment where particular
problems are identified and a basis for the requireaents is
established*
Interim Conditions and the Proposed 503 Standards. BPA
recently proposed technical standards for the use and disposal of
sewage sludge (54 FR 5746; February 6, 1989). This rulemaking is
being developed to meet the requirement in Section 405(d) that
EPA promulgate regulations identifying sewage sludge use and
disposal methods and concentrations of pollutants that interfere
with each method. The proposed Part 503 regulations address
sewage sludge incineration, land application, landfilling,
16
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distribution and marketing, and surface disposal. EPA has also
developed technical support documents for each method.
The Interim strategy and the CbC Guidance are designed
primarily for use before issuance of the final technical
standards. The focus of the interia program is on identifying
and addressing, through permits, existing or potential problems
with sludge use or disposal, in the absence of promulgated
technical standards. In developing permit limits for POTWs in
the interim, the primary source of information for permit writers
should be the Case-by-Case Guidance, information from other
sources, of course, may be considered and evaluated by the permit
writer in the exercis* of his or her best professional judgment.
These include, for example, the proposed 503 rule and preamble,
its technical support documents, and available information from
the National Sewage Sludge Survey.
The proposed 503 standards are currently undergoing public
comment and peer review. These processes, as well as the results
of the National Sewage Sludge Survey may result in final
standards that are significantly different from the proposal. In
light of these circumstances, reliance on the proposed standardsl
should be limited. The permit writer should not rely on the
proposed numeric limits in developing case-by-case sludge
conditions unless the permit writer can independently establish
the appropriateness of such conditions based on the circumstances
of the particular sludge practice at issue. As previously noted,
any sludge conditions, other than those based on existing
regulations, must have a sound technical basis explained in the
fact sheet that accompanies the permit.
17
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IV
STATE AND EPA COORDINATION ON INTERIM SLUDGE PERMITTING
EPA seeks to encourage states with existing, effective
sludge management programs to carry out the program for
implementing interim sludge permitting under the CWA to the
extent that they are willing and able to do so. This Part
describes the minimum requirements necessary for state interim
permitting, and the procedures for establishing State/EPA
coordination in the permitting process.
EPA interprets CWA Section 405(d)(4) to allov State/EPA
coordination, whereby States with existing effective sludge
management programs could carry out interim sludge permitting.
This is beneficial for the national sludge program because States
with effective programs are more likely to know which particular
facilities or practices may be causing problems. Moreover,
involving States now serves the dual purpose of minimising
disruption to existing State programs and reducing duplication of
effort by EPA and the States.
The sludge State program and permitting regulations,
promulgated on May 2, 1989, provide for formal submission of
State sludge programs for review and approval by EPA. States
may, but do not need to, seek formal approval, pursuant to the
May 2, 1989 rules, during the interim phase to carry out interim
and long-term permitting. They may also opt to rely on more
informal arrangements with the EPA Regions, as this Part
explains. States that are not yet seeking formal approval are
encouraged to use this interim period to evaluate their programs
in light of the requirements for approvable sludge State programs
to identify areas where their programs may need to be changed or
augmented in order to be approved.
Establishing State/EPA Coordination
A. Minimum Requirements
The 1987 CWA amendments give EPA the flexibility to rely on
State sludge management activities to carry out the objectives of
the Act for interim sludge requirements. Where the State chooses
to participate in the interim program through an agreement, the
Agency vlll take steps to ensure that any measures are adequate
to protect public health and the environment by overseeing State
efforts. To accomplish this, this Strategy adopts a two-pronged
approach which targets facilities of concern for oversight.
For all NPDES POlKs that are defined as Class 1, the Region
will review the sludge requirements in each State-issued permit
(or other individual control mechanisms) to make sure they
incorporate existing federal requirements and meet the objectives
18
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of the Clean Water Act. The CbC Guidance is intended to asaist
the Region* in this review. The"review of the sludge conditions
could be built into the Region's process for reviewing State
permits issued to NPDES majors.
Section 405(d)(4) authorizes only the Adainistrator to
Impose conditions in NPDES permits or take other appropriate
measures. Thus, to be recognized under Section 405(d)(4),
conditions imposed by States must be approved/adopted by £PA. To
accomplish this, three steps are required. First, a State which
issues a Class 1 permit would state in the public notice of the
draft permit that the permit (or facility-specific plan) will
contain sludge requirements to implement the requirements of
Section 405 of the CWA and therefore will be federally
enforceable pursuant to Section 309 of the Act, Second, the
Region must review the permit and determine whether it satisfies
the requirements of the interim program. Finally, the Region
must affirmatively approve the permit by issuing a letter or
certification to the State permitting agency. This written
documentation of EPA approval should also be attached to the
permit. (A sample certification letter is in Attachment 5.)
Following these steps should enable EPA to take action to enforce
interim sludge requirements in these permits where appropriate
(e.g., joint enforcement actions with the State, cases of
national significance, etc).
The public notice and perait-by-perait EPA approval
requirements applicable to permits for Class 1 POTWa will not be
required for non-Class 1 POTW permits. However, for interim
implementation purposes, a State must be able to impose the
minimum requirements for these other permits set out in Part 11.
EPA will also oversee the State's activities in imposing the
minimum requirements on non-Class l permits. However, oversight
will not be required on a perait-by-permit, or individual POTW,
basis, but may be accomplished through other means, such as
periodic file or perait reviews and annual program reviews.
b. statt Eligibility
Any State with an effective sludge permitting prograa may
participate in the implementation of interia sludge requireaents,
regardleee of that State's NPDES participation or status. In
seeking State involveaent, EPA will need to deteraine the extent
to which the State ia willing and able to iapleaent this Strategy
for carrying out the responsibilities created by Section
405(d)(4). State participation should be encouraged to the
aaxiaua extent possible. Where States either cannot (for
exaaple, because they lack legal authority) or will not partici-
pate, EPA will reaain responsible for imposing1 sludge require-
aents. Where the state will not undertake sludge permitting and
EPA is the NPDES permitting authority, the EPA perait writer
19
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would simply include sludge requirements in the reissued npdes
permit. Where the State has NPDES authority, EPA would issue a
"sludge rider" to the State-issued NPDES permit or issue a
separate Section 405 sludge permit. (Attachment 6 contains a
model EPA "sludge rider".) Wherever possible, State and EPA
sludge permitting activities should be coordinated to assure
consistency and minimize duplication of efforts. (See, for
example, 40 CFR 124.4 on joint permitting procedures.) In most
cases, interim implementation will require the combined efforts
of States and EPA Regional Offices to protect the environment
adequately and put an effective sludge program in place. The
degree of participation will likely vary from State to State.
States need not assume full responsibility for interim permitting
in order to participate. For example, a State may currently
regulate only one disposal practice. In that case, the State
could agree to cover interim sludge permitting for that
particular practice, and EPA would issue permits for the other
use and disposal practices.
C. Procedures for Establishing State/EPA Coordination
Establishing State/EPA coordination in interim permitting
involves two steps: (1) the State must identify the extent to
which it is able and willing to participate; and (2) the State
and the Region would execute an agreement establishing the
responsiblities of EPA and the State in the interim sludge
permitting process.
Regional offices should contact each State about its
capacity to undertake interim implementation activities.
Execution of an agreement will be necessary with any State
that agrees to participate. This agreement could be part of
the Section 106 planning process or any other appropriate vehicle
that defines EPA/State roles in program implementation.
(i) statt'a Dtslarfltlgn
Initially, the State should identify the capacity of its
existing program to regulate the sludge use and disposal
practices of it* POTMs in comparison to the minimum requirements
established in ths CbC Guidance and Parts II and III of this
Strategy. Generally, EPA will rely on the State's declaration of
its capacity (i.e., resources and legal authority to impose and
enforce interim sludge requirements). As noted above, a State
need not assume full responsiblity for all sludge permitting in
order to participate. For example, a State taay currently
regulate only land application of sludgs. The Stats could agree
to be responsible for permitting only the POTWs which uss this
disposal method now. Later, if the State's program expands to
include regulation of other disposal options, it could expand its
role in interim implementation. EPA will encourage States that
cannot assume full sludge permitting immediately to increase
20
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their permitting capabilities over tine. Where a POTW uses more
than one disposal option and the State does not regulate all
options, EPA must "fill in the gaps" either by issuing a sludge
rider to the State-issued permit (see Attachment 6) or a separate
Section 405 permit. If known in advance, this specific situation
should be addressed in the State/EPA sludge agreement.
(2) State EPA Sludge Agreement
After the State has expressed its willingness to participate
in interim implementation, the Region should enter into an
agreement with the State establishing their respective responsi-
bilities for interim implementation of sludge requirements,
especially permitting responsibilities and information exchange
between the State and the Region. The agreement also may include
provisions about other aspects of EPA-State coordination of
sludge management activities as well (e.g., coordination of
inspections and enforcement actions). The agreement may be
flexible in many respects, but it should clearly identify
permitting responsibilities of the State and EPA in establishing
sludge requirements.
The agreement may be an annual workplan negotiated as part
of the Section 106 process, but the Region and State should
consider documenting longer tern understandings for development
of a full State program with EPA's assistance. The agreement may
be executed as a revision to an existing agreement or as a
separate agreement. In NPDES States, revisions to the NPDES
Memorandum of Agreement (MOA) may also be necessary if it
conflicts with any of the provisions described below. Also, if
the MOA waives EPA review of minor POTW permits, this waiver
would have to be modified to facilitate review of permits for
minor POTWs which are classified as Class 1 permits for sludge
purposes and thus require EPA review. See S123.24(d).
The state/EPA sludge agrssasnt should include provisions to
address the following:
o identification of the POTW permits the State will be
responsible for, those EPA will be responsible for,
and thoss for which EPA and the State will assume
joint responsibility)
o For permits for which EPA assumes responsibility, a
description of how the Region will issue the sludge
permit (i.s., by issuing a "sludge rider" to the State-
issued NPDES psrmit, through joint issuance of the
permit or by issuing a separate EPA NPDES sludge
permit);
o Provisions for joint issuance of permits, where
appropriate;
21
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o Provisions for EPA review and comment on all Class 1
permits drafted by the state, and agreement that if EPA
determines that State limits are not adequate in any
specific case, EPA will issue a "sludge rider" or separate
sludge permit to the POTW;
o For sludge Class I permits with sludge conditions the
State issues, agreement by the State to include in the
public notice of the draft permit, in addition to other
information that may be required by State or federal
requirements, a statement that the draft permit includes
conditions implementing interim sludge requirements
pursuant to Section 405(d) of the CWA and, therefore, will
be federally enforceable pursuant to Section 309 of the
CWA after review and approval by EPA (see Attachment 7 for
language);
o State's agreement to include in permits issued to non-
Class 1 POTWs the minimum conditions described in the
"Sewage Sludge Interim Permitting Strategy";
o Provisions that establish the State's compliance
monitoring and enforcement activities for the permits it
agrees to issue (See Attachment 7);
o An agreement to share, upon request, the results of
any sludge monitoring activities (e.g., self-monitoring
and inspection reports) ,*
o Provisions that recognize that the agreement is not
a substitute for formal program approval and that
EPA approval of the State sludge program will be
needed for purposes of long-term implementation (i.e.,
after final promulgation of the Part 503 technical
criteria, which is scheduled for 1991); and
o Any agreements concerning activities to build up the
State program in preparation for obtaining formal
prograa approval.
A model State/EPA sludge agreement is found in Attachment 7.
Even when a State with an existing sludge management program
does not actively participate in interim permitting, EPA permit
writers should look to the State as a valuable resource and
consider adopting by reference existing State permits and/or
requirements. As with State requirements affirmatively approved
by EPA, including State requirements in the NPDES permit means
that EPA is adopting those requirements as its own and therefore
must be be prepared to enforce and defend them.
22
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D. Timetable
It is crucial that Regions and States begin now to work out
the details for establishing State participation in interim
implementation. The State/EPA sludge agreements should be
executed as soon as possible, but no later than December 31,
1989. A copy of any agreements should be sent to the Cynthia
Dougherty, Director, Permits Division, Office of Hater
Enforcement and Permits.
23
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APPENDIX B
REGIONAL AND STATE AIR, SOUD WASTE AND GROUND WATER CONTACTS
-------
Regional and State Solid Waste Program Contacts
Phone Nnmhw
State
Name
cr
Ron Jennings
Barry Giroux
MA
WilUKuh
ME
David Boulter
NH
Thomas Sweeney
RI
John Quinn
VT
William Aheam

Michael Debonis
NJ
David Savetsky
Robert Confer
NY
David OToole, P.E.
PR
Raquel Cortes
VI
Alfred Williams

Thomas Merstti
DC
Byron Bacon
DE
Richard Folmsbee
MD
Georgina Havlik
PA
William Pounds
VA
Wlariimir Gulevich
WV
Roben Seip

Craig Brown
AL
Dewey Honeycutt
FL
Rick Wilkins
GA
James Dunbar
KY
Shelby Jett
MS
Bill Barrett
NC
Gordon Layton
SC
Haitsill Tniesdale, P.E.
TN
Doyl Rowland

Bill MacDoweil
IL
William Child
IN
Jacqueline Strccker
MI
DanMagoun
Tim Wright
MN
James Warner
OH
Nancy Moore
WI
Lakshmi Sridharan
FTS
Commercial
n
m
IV
8-833-1687
8-264-0002
8-264-0547
8-597-3159
8-257-3433
8-886-7452
617/573-9687
203/566-5712
207/289-2651
617/292-5980
603/271-2925
401/277-2797
802/244-8702
212/264-0002
212/264-0547
609/292-5196
518/457-2051
809/722-0493
809/773-0563
215/597-8990
202/783-3193
302/736-5060
301/225-5664
717/787-7381
804/225-2667
304/348-5935
404/347-3433
205/271-7761
904/488-0190
404/656-2836
502/564-6716
601/961-5062
919/733-2178
803-734-5200
615/741-3424
312/886-7452
217/782-6760
317/243-5015
317/232-4473
517/373-2730
612/296-7340
614/644-2956
608/266-0520
B-l
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Regional and State Solid Waste Program Contacts
Region
State
Name
FTS
Phone Number
Commercial
VI

CarlBolden
8-255-6760
214/655-6760

AR
Mark Withenpoon

501/562-7444

Gary Martin

501/562-7444

LA
Paul Miller

504/342-1216

NM
Raymond Sisneros

505/827-2775

OK
R. Fenton Rood

405/271-7159

TX
Minor Hibbs (TWC)

512/463-8173

T. A. Outlaw, JrM P.E. (DOH)

512/458-7271
vn

Carl Blamgren
8'-757-2856
913/236-2852

IA
Peter Hamlin

515/281-8852

KS
Ronald Hammerschmidt

913/296-1662

MO
Dennis Murphcy

913/296-1592

Jim Hull

314/751-3176

NE
Jack Sukoraty

402/471-4210
vm

Jerry Allen
8-564-1670
303/293-1496

00
Joan Sowinski

303/331-4830

MT
James Leiter

406/444-2821

ND
Steve Tillotson

701/224-2366

SD
Joel Smith

605/773-3153

UT
William Sinclair

801/538-6170

WY
David Finley, P.E.

307/777-7752
IX
AZ
AynSchmit
8-454-8141
415/974-8141

Alan Roesler

602/257-2249

CA
John Kems

916/323-2942

HA
Wilfred Nagaminc

808/548-6410

NV
Thomas Fronapfel, P.E.

702/885-4670

G
Jose Tec haira

671/646-8863/5

Am. S
Pad Faiai

633-2304

(overseas opr.)
X

Mike Bussell
8-399-6501
206-442-2857

AK
Steve Sharp
8-399-6517
206/442-6501

David DiTraglia

907/465-2666

ID
John Moeller

208/334-5829

OR
Michael Downs

503/229-5774

Steve Greenwood

503-229-5782

WA
Leighton Pratt

206/459-6259
B-2
-------
Regional and State Air Program Contacts:
For Sewage Sludge Incinerators
Region
State
Name
FTS Phone Number

(Commercial Prefix)
I
cr
MarHiultman
(203)
566-8230

MA
Donald Squire
(617)
292-5618

NH
Andrew Bodnarik
(603)
271-1370

RI
Doug Mc Vay
(401)
277-2808
Region
John Courcier (Control Technology)

835-3260

Lynne Hamjin (Air Regulations)

835-3246

(617)
565-3246
II
NJ
Ms. Iclal Atay
(609)
984-0491

NY
Jim Harrington
(518)
457-2044
Region

Steven Riva

264-4711

(212)
264-4711
in
MD
Carl York
(301)
631-3230

PA
Doug Lesher
(717)
787-9256

VA
Bill Millwood
(703)
644-0311

WV
Dale Farley/David Potter
(304)
348-4022
Region

Eileen M. Glen (PA & PSD/NSR Cooixl)
597-8379

James B. Topsale

597-6553

(215)
597-6553
IV
FL
Clair Fancy
(904)
488-1344

KY
Bill Dills
(502)
564-3382

GA
Marvin Lowry
(404)
656-6900

NC
Mike Sewall
(919)
733-3340

SC
Max Batavxa
(803)
734-4750

TN
Mav at Ahmed
(615)
741-3931
Region

Brian Beals (NESHAPS/NSPS)

257-2904

(404)
347-2904
V
IL
Terry Sweitzer's Assoc
(217)
782-2113

IN
John Doss
(317)
232-8427

MI
David Ferrier
(517)
373-7023

MN
Mr. Ohto Niemioja
(612)
296-7711

OH
Robert Hodanbosi
(614)
644-2284

WI
DaleZiege
(608)
266-0113
Region

Ron van Mersbergen (PSD/NSR;
legal and engineering)

886-6056

Rizalino Castanares (engineering)

886-6047

(312)
353-6047
B-3
-------
Regional and State Air Program Contacts:
For Sewage Sludge Incinerators
(Continued)
Region
State
Name
FTS Phone Number

(Commercial Prefix)
VI
AR
Cecil Herril
(501)
562-7444

LA
Larry DeVillier
(504)
342-8926

NM
Bruce Nicholson
(505)
827-0070

OK
Doyle McWhiiter
(405)
271-5220

TX
Lawrence Pewitt
(512)
451-5711
Region

John Hepola

255-7220

(214)
655-7220
vn
IA
Bill Youngquist
(515)
281-8924

KS
Lacey Hinther
(913)
296-1576

MO
Mike Stanfield
(314)
751-4817

NE
Glen Dively
(402)
471-2189
Region

Dan Rodriquez

757-2896

(913)
236-2896
vm

Region

John Dale (NSR)

564-1886

(303)
293-1886
IX
CA
Luis Woodhouse
(916)
445-2049

HI
Wilfred Nagamine
(808)
548-6355
Region
MikeStenburg (Chief Air Toxics)

454-8205

(415)
974-8205
X
AK
Len Veirelli
(907)
465-2666

WA
Jay Willenberg
(206)
867-7117
Region

Ray Nye (Incinerators)

399-4226

(206)
442-4226
NOTE:
Please call the State contact first They will refer you to a district office if necessary.
B-4
-------
Regional Groundwater Representatives

Phone Number

Region
Name

FYS
Commercial
I
Robert Mendoza
Office of Ground Water
Water Management Division
JFK Federal Building
Boston, MA 02203
- Rm. 2113
835-3600
617
565-3600
II
John Malleck
Office of Ground Water
Water Management Division
26 Federal Plaza
New York, NY 10278
- Rm. 805
264-5635
212
264-5635
ID
Stuart Kerzner
Office of Ground Water
Water Management Division
841 Chestnut Street
Philadelphia, PA 19106

597-8826
215
597-8826
IV
Stallings Howell
Office of Ground Water
Water Management Division
345 Courtland Street, N.E.
Atlanta, GA 30365

257-3866
404
347-3866
V
Jerri-Anne Gall
Office of Ground Water
Water Management Division
230 S. Dearborn Street
Mail Code 5WG-TUB9
Chicago, IL 60604

886-1490
312
353-1490
VI
Erlece Allen
Office of Ground Water
Water Management Division
1445 Ross Avenue
Dallas, TX 75202-2733

255-6446
214
655-6446
vn
Timothy Amsden
Office of Ground Water
Water Management Division
726 Minnesota Avenue
Kansas City, KS 66101

757-2970
913
236-2970
vm
James Dunn
Office of Ground Water
Water Management Division
999 18th Street - Mail Code 8 WMGW
Denver, CO 80202-2405
564-1796
303
293-1703
B-5
-------
Regional Ground-Water Representatives
(Continued)
Region
Name
Phone Numher
FTS
Commercial
IX
Patricia Eklund
Office of Ground Water
Water Management Division
215 Fremont Street
Mail Code W-l-G
San Francisco, CA 94105
454-0831
415 974-0831
X
William Mullen
Office of Ground Water
Water Management Division
1200 6th Avenue - M/S WD-139
Seattle, WA 98101
399-1216
206 442-1216
B-6
-------
APPENDIX C
DISTRIBUTION AND MARKETING LABELS AND INSTRUCTIONS
-------
Mm Wtight U Kilogram* (I iMj
NATURAL ORGANIC
FERTILIZER
Milorganite
Activated Sewage Sludge
Raad direction* carefully before using
For us* on lawns, shrubs
and ornamantals only
Long ''sting, will not burn
•The Golf Courts Cholcs'
•«C
-------
Rud direction* carefully More using
NAtVIBAL ORGANIC
F£«Tltl25^
Milorganite
Activated Sewaga Sludge
u
(*Ua.) 1
tfta ttwal Orpa*
IM9IK4
TMMtragaa . LM
ilk
9.5*
Wmplwhc km (*<*) in
tMkMlIU)
Iraa (Ft) 4.
rr
*+ • * «
Directions for use
Miiorgan-te 's an in.«' ¦»"!
»or tyf'gt^ases ai'O ca'y o* i • en
tals P'njniirmg plants equirc
suoulemeutai pnosonat* . 0 ootasr
in sere ^o'1!
NOTICE Milorganite should not be
used on vegetable* due to possible
uptake ot the n*a*y matai cadmium
Wtien home grown vegetables make
up a targa portion o( the annual diet
amrt period of many years. cadmium
Mf accumulate m the kidneys.
JNMtttnf )n possible dysfunction.
LAWNS
To assure an impressive »taa 'ow*ra
dense, Wealthy turf apply me on
tanta of this bag to 170 suuare <«ct
Oo tnij by aooiymg Mfiorqan'te r
1*0directions witft tie screida* v,":s
OOeir. The results win prowtoe .»ar
feeding.
"Ounea use naif rates Oui >n
aooiications. This >9 done ov set
img toreador to the largest oven
**0 4"u iooW caietuiiv in one cJirec
This a»q M,n tn«n cove» aoout
'« 4j« square 'e«t
J"®*1 M*»or graaaee #
AO "gifS 41 e lelQ n -a»c.- •• --
n-.t q'awing season ic M'-'
e; aw^s oei.ome progress»>*:iv uet
-(-« yiio'qanite «m *o: ourn trie 'n
Lawn Spreader Settings
fo' ^orinq. Fill mi "Winter lite
Mign«jt Quality
Sgmnir Sprsa4«f
• «Jiv 1 *««
iooo Qmmy
\ 0'oo#f Somas*
v t nr i»« ovkiw*
Ores Sprutar
Orsp Sptt*4v
Hr f uinmer igoKattoA
Somntr So'tJOH >»0 Sartliat
'o«« j'* 1
:ro*rh
ORNAMENTALS
c ] ic 5 'bs per 100 scu«»»
•-»t Scatter uniformly on tfHW14*
, • Adjfti i'iio t»>e son surface.
4 j o "oi'aa can noiw M**
MilO'Qanite
TREES
; *c "0 'M •?*
jiam-i-'r at ,:"iest
to 2 men diameter not"
ohea deeo. »paced i ^ ,
•rom tne tr*ifl* to bar00*
>D'«Ja o» dUMtCMe-
C-2
-------
vsr
RE-PQTTIN6 SOU MEDIA
odorless/unrestricted USE/
NO CHEMICALS!
AN ORGANIC - NATURAL -
POTTING SOIL

WHYUSEEKO-eompost?
NET WOO HI
si ivcnini pHHagMM
8=."- nn
•rOMMKA AMD MSCUI,
PAMUVUMtiSSt
C-3
-------
INSTRUCTIONS TO USE
EKO'COmpost*
RE-POTTIffG SOIL MEDIA
"EKOeompoat If a CONCENTRATED SOIL MEOIA
tnsrstora. you cm uk* the old root-ball of your plant.
"CPonm* '• ilfMiiMtKC "~
on
1 S^MownSy' ln,c ,h# EKOlln«t pot.
X Top-dress with al least on* Inch thick layer ol EKO-compoii.
4' ^0
-------
Indoor Follage«Hanging Baskets«FIc .vering Plants
."rTV; (?/ i)i*V-'«i/- C^TVfi

-------
K<$q#
HORTICULTURAL POTTING MIXES
Recognizing that no one potting mi* can satisfy the needs of ail plants,
Kellogg has developed a line of horticultural potting soil products.
These scientifically developed mixes provide the proper planting
medium for most plants tended by gardening enthusiasts. The
following mixes are complete, nothing neea Be UdM. and can be
used for indoor or outdoor containers.
POTTING SOIL—this general purpose potting soil can be used for
indoor foliage plants, patio containers, color plants m window boxes,
hanging baskets and other containers.
AFRICAN VIOLET MIX—this sod mix retains the much needed
moisture and nutrients required by these popular flowery plants.
ORCHIO MIX—this special mix provides the ideal soil environment
for growing terrestrial orchids such as eymbidiums.
POTTING SOIL
KtULOOG POTTING SOIL '* t mi«tu't 0< w»l»fi»l» wnicn ereviM «f» idaal toil •n»iranm«*t
10r growing giantl ifl containan P'a«tt naad a maOium IHat i» DQtOui. ytl ID*0'9««t 'Of
noiomg moiltura ice «nd nu(rt*nt* POTTING SOIL can M utM »or mOOOf 'onafl* ounu. patio
ceAiiiiM color pianu in window bom. nan^ing batkau and otfiar eottainar*.
OIRICTIONS
t*MCt I COM**** »M
•d tnam tor am** to*
for foot pow*i CiriMr
iwxf «wi •
Pwwi M to »• wo 01
ti>« Mm • uo«4«
fifmy 10 tUHtO* MTf* m
pecua
i*i tM 0am 0" • '•>*«
01 «|IIW • N»
-------
KELLOGG*S NITROHUMUS
1 1/2 Cubic Feet
KELLOGG'S NITROHUMUS*
Soil Conditioner
KELLOGG' S NITROHUMUS is one of the most widely used products
in the lawn and garden industry in the Southwest. It is an all
purpose soil conditioner used to improve the physical properties
of soils. Results from using this material are increased
workability, aeration and drainage of clay soils and increased
water and nutrient retention of sandy soils.
Bedding Plants, Cover planting beds with 1/2
Ground Covers, Bulbs to 1 inch of NITROHUMUS.
(1 1/2 CF covers 20 to 40
sq. ft.). Rototill or spade
to a depth of € to 6 inches
or use 1 cup per individual
plant or bulb mixed into
the planting hole.
Use L 1/2 CF of NITROHUMUS
and one 3 CF of KELLOGG
REDWOOD COMPOST for each
to to 100 sq. ft. Rototill
or spade into the top 4
to o inches of soil.
Cover newly planted seed
with NITROHUMUS at the rate
of 1 1/2 CF per 150 sq. ft.
Keep moist until, lawn is
established.
Add 1 to 2-inch layers of
NITROHUMUS to compost heaps
to increase the rate of
producing usable compost.
Ingredients: Composted, Centrifuged Sewage Sludge and Forest Products.
Total Nitrogen 0.5%
KELLOG SUPPLY, INC.
Carson, California 90745
Product of U.S.A.
C-7
Soil Preparation
Lawns:
Top Dressing
Making Compost
-------
KELLOGG*S AMEND
2 Cubic Feec
KELLOGG'S AMEND*
Vegetable and Flower Planting Mix
Enjoy the fruits of growing a successful garden through the use
of KELLOGG's AMEND. This fully composted blend of organic
materials improves water penetration and drainage and reduces
compaction Of soils. KELLOGG'S AMEND HELPS MAKE HARD CLAY
SOILS SOFT and sandy soils retain moisture and nutrients.
KELLOGG'S AMEND is used for planting vegetables, flowers, ground
covers and bedding plants.
VEGETABLE PLANTING
FLOWER GARDENS
AND BEDDING PLANTS
Spread one bag of KELLOGG's
AMEND and 1/2 lb. of KELLOGG's
KARE for Tomatoes and Vegetables
for each 15 to 20 square feet.
Rototill or spade to a
depth of 6 to 8 inches,
assuring adequate mixing.
Water lightly after planting
and daily during establishment.
Spread one bag of KELLOG'S
AMEND and two cups of
KELLOGG'S KARE for Roses
and Flowers for each 25
sq. ft.
Spade to a depth of 6 to 8
inches, assuring adequate
mixing.
Water after planting and
daily during establishment.
Apply a 1 to 2 inch layer
of GROMULCH after planes
are established.
GROUND COVERS
Spread a minimum of one
bag of KELLOGG'S AMEND
and 4 cups of KELLOGG'S
KARE for Blooming Plants
per 50 square feet.
Spade to a depth of 6"
to 3" at each planting
hole.
Water after planting and
dai^y during establishment.
C-8
-------
INDIVIDUAL PLANTS Prepare a mixture of 1/2
KELLOGG'S AMEND and 1/2
soil from the planting hole.
Focm a watering basin around
the base of the plant after
planting.
Water thoroughly and daily
during establishment.
INGREDIENTS: Ricfe Hulls and Nitrohumus (Composted, Centrifuged,
Sewage Sludge and Forest Products)
KELLOGG SUPPLY, INC
Car9on, California 90745
Product of U.S.A.
C-9
-------
GAJU»J CARE"
Quality Gar<)en Products
Professional Growing Media
Contents: 8 Dry Quarts (8.8 Litres)
Professional Growing Media
Directions for Outdoor Use
GARDEN CARE" A scientific blond of composted sludge, bark,
Perlite, Micro Nutrients, and other ingredients. Provides the
best possible grcwing environment for your indoor and out<1oor
ornamental plants. Hunjs ridi ooqpost, produce*! in a unique
process system, is the very essence of GARDOi CARE".
GARDEN CARE" is richer in natural nutrients than peat basal
dia, and its high humus content nourishes plants while
its friable texture i¦proves soil aeration to promote
stronger root growth. The increased cation exchange
capacity of GARDQi CARE" permits a more rapid and efficient
transfer of nutrients to your plants. Use GARDEN CARE"
and see the results. Stronger, healthier, more vibrant
plants than you've ever grown before.
Directions for Repotting
Selecting a Pot
- For plants in pots less than 10 inches in diameter,
select a pot at least I inch larger than the pot being
replaced. For plants in pots larger than 10 inches in
diameter, select a pot at least 2 inches larger than
the pot being being replaced.
- Always select a pot with aqple drainage, never use pots
that do not allow excess water to drain away.
- If the drainage hole is larger than I inch, use a piece
of broken pottery to partially cover the drain hole.
Repotting
- a moist roothall is easier to remove. Water plant
tltorouc^ily 2-4 hours before repotting.
When planting trees or shrulxs, use GARDEN CAKE"
mixed equally with top soil at the base ami arouml
your new planting.
For flowers and ground covers,
GARDEN CARE" IWPO HIE SOIL..
incorporate 2" of
- Water thoroughly after planting.
Helpful Hints for Houseplants
Avoid overwatering your plants. More plants die
from overwatering than from neglect.
Allow the potting medium to become «lry 1/2" to
1" deep. You can check this with your finger.
When watering use a sufficient amount so that some
drains out the bottom of the pot. However, never
allow the pot to stand in an excess of water.
Browning at the tips of older Leaves or h white
crust on the surface of the growing medium is an
indication of improper watering.
Salt accuBulations fostered by watering your plants
from the bottom or not watering thorou<£)ly. Flush-
ing the plant tliorou^ily from the top with a fa*
drops of detergent in the water will help clear up
these synptons.
Always place plants where they will receive suffi-
cient light* Flowering plants generally require
more li^it than Foliage plants.
-------
Repotting oont.
- no reuovo the plant from its i»t, place your hand over
the top of the pot and gently hold the stem between
your fingers.
- Turn the pot upside down and gently tap its top edge
on a table or bench.
- To encourage uore rapid root growth, make 4 uniform
cuts 1/2 inch deep throu$i the outsi<)e layer of roots.
TTven rewe as atich Loose soil as possible fram the
rootl>*tl.
- Place enoufji GARDEN CARE" in bottan of the pot to
bring the tcp of the root ball to within 1/2 inch
of tlie top edge of tlie pot.
- Center the rootball in the pot and fill in around the
outer siiJes with GARDEN CARE". Gently tap the repotted
plant on a flat surface to get rid of any air pockets.
Care of Your Repotted Plant
-Fill the newly potted plant with water and alLow it to
drain. If settling ocurs, add sore GARDEN CARE".
- Because GARDDi CARE" contains sufficient phospliorus, we
reumnend a low phosphorus fertilizer (25-5-20) such as
GARDEN CAKE" Fbc«aJla37 water soluble fertilizer.
Helpful Hints oont.
- Leam how to properly pinch back your plants. For
most plants pinching off the tqp ri<^it above a ltMf
encourages the development of side shoots and re-
sults in healthier, more vigorous plant growth.
- Removing dead flowers ami leaves from your plants
will help curb seed formation and encourage new
blocms.
- Periodically dunking the tops of plants in warm
soapy water wil help control insects. Keeping
the foilage dry at all other 'times will oontrol
roost diseases.
- For more information on the care and culture of
specific plants ami for the control of sj>ecific
insects and diseases visit your lixral gar
-------
CompGro
A proven, superior q*ialiLy soil amendment-
Nitrogen forLified, enriches soil
Helps aerate yonr soil, improves moisture reLention
Planting can begin 1 Mediately after appiication
Directions foe Use
Use

Ancrint of CoapGro
(cu.yd./l,000 sq. ft.)*
Instr'jctions
"Firfgrasses
Establ ishment
Surface
vilch
Maintenance
3 to 9
Approxiaately 1 1/4
3/4 to 1 1/2
Incorporate with top 4 to 6 inches of soil. Use
lower rate on relatively fertile soil and higher
rate on infertile soil.
Broadcast 'imformly on s'irface before seeding
small-seeded species (bl'iegrass) or after seeding
large-seeded species (fescies).
Broadcast 'imformly on surface. On cool -season
grasses, apply higher rate in fal1 and again in
spring.
Sod

3 to 6
Incorporate with tqp 4 to 6 inches of soil.
If »r aery
Crope and
OrnaaenUiB
Establishment
Maintenance
3 1/2 to 13
1/2 to 1
Incorporate with top 6 to 8 inches of soil. Do not
•ise where acid-soi 1 plants (azalea, rhododendron, etc.)
are to be grown.
Broadcast uniformly on s'irface soil. Can be worked
or 'ised as mrilch.
Mulch

1/2 to 1 1/4
Broadcast ooofwet- -uuformly on s'irface afLer seeding.
• 3 ci. yds- per 1,000 sq. ft. is eq-ial to a 1-inch layer spread over the surface.
-------
Use

Amo-inl of ConpGro
(ci. yd./1,000 sq. ft.)
Instr'ictions
PoU ing

Eq>ia1 ratio of
*I>»orcpjghly water and drain mixes several Limes
Mixes

material
before planting. Some reoonnended mixes are:

For floor standing plants - ConpGro, peal moss.

sand and Perlite (1:1:1:1) heavy mix.

For hanging plants - CcwpGro, peat moss and Perlite

(1:1:1) light mix.

CcwpGro and connerially available potting soil

(1:2)
Total Nitrogen: 1Kb*
pH: 6.5
Max! run
aoist'ire
content: 40»0%
Weight: Approximately 28
pcrnds per cribic foot
An extensive q-iality control program devel-
oped by East Bay tfrjmcipal Utility District
g-iarantees prod-ict •iniformity and reliabil-
ity. Oiring the prod-tcf ion process, weekly
analyses of 20 oonstit'ients are oondised in the United StaLes for
over 60 years. Sl'idge, mixed with bark chips,
is aonposted in large aerated piles for several
weeks. D>iring this time, compost temperatures
exceed 130* Fahrenheit. TTiis ens-ires that the
final prod*»ct is free of weed seed and all
harmf'jl soil organists. Finally, the ooqposL
is screened to remove coarse chips, leaving
a fine-grained, high-q-ial lty prod-ict-CcwpGro -
clean, li^pit-weight and odor-free.
Prod-K3ed by
East Bay M-uucipal Utility District
P.O. Box 24055
Oakland, CA 94623
(415) 465-3700
Packaged by Redi-Gro Corp.
8909 Elder Creek Rd.
Sacramento, CA 95828
-------
APPENDIX D
40 CFR 257- CRITERIA FOR CLASSIFICATION OF SOUD WASTE
DISPOSAL FACILITIES AND PRACTICES
-------
PART 2S7—CtlTKRIA Fd OASttW-
CATION Of SOUD WASTI DISPOS-
Ai FACILITIES AND PRACTtCIS
8«C.
287.1 Scope and purpose.
257.2 Definition*.
287.3 Criteria for classification of solid
vaite disposal facilities and practices.
287.3-1 Floodplalns.
287.3-2 Endancered spedes.
287.3-3 Surface water.
287.3-4 Groundwater.
287.3-8 Application to land used (or Uto
production of food
-------
9 2J7 J
btllty of adverse effect* on health or
the environment Unless otherwise
provided, these criteria are adopted
for purposes of both Section
1008(aK9> and Section 4004(a) of the
Act.
(1) Facilities falling to satisfy crite-
ria adopted for purposes of Section
4004(a) will be considered open dumps
for purposes of State solid waste man-
af ement planning under the Act.
(2) Practices falling to satisfy crite-
ria adopted for purposes of Section
1006(a)(3) constitute open dumping,
which Is prohibited under Section 4005
of the Act.
(b) These criteria also provide guide*
lines for sludge utilisation and dispos-
al under Section 405(d) of the Clean
Water Act. as amended. To comply
with Section 405(e) the owner or oper-
ator of any publicly owned treatment
works must not violate these criteria
In the disposal of sludge on the land.
(c) These criteria apply to all solid
waste disposal facilities and practices
with the following exceptions:
(1) The criteria do not apply to agri-
cultural wastes, including manures
and crop residues, returned to the soil
as fertilizers or soil conditioners.
(2) The criteria do not apply to over-
burden resulting from mining oper-
ations Intended for return to the mine
site.
(3) The criteria do not apply to the
land application of domestic sewage or
treated domestic sewage. The criteria
do apply to disposal of sludges gener-
ated by treatment of domestic sewage.
(4) The criteria do not apply to the
location and operation of septic tanks.
The criteria do, however, apply to the
disposal of saptic tank pumping*.
(5) The criteria do not apply to sottd
or dissolved materials In irrigation
return flows.
(5) The criteria do not apply to in-
dustrial discharges which are point
sources subject to permits under Sec-
tion 402 of the Clean Water Act, as
amended.
(7) The criteria do not apply to
source, special nuclear or byproduct
material u defined by the Atomic
Energy Act. as amended (68 Stat 939).
(8) The criteria do not apply to has-
ardous waste disposal facUltl which
40 CFt Ch. I (7-1-«3 Edition)
are subject to regulation under Sub-
title C of the Act
(9) The criteria do not apply to dis-
posal of solid waste by underground
well Injection subject to the regula-
tions (40 CFR Part 146) for the Under-
ground Injection Control Program
(UICP) under the Safe Drinking
Water Act as amended. 42 U.S.C. 3007
et seq.
(44 PR 534SO, Sept IS, 1979. u amended at
40 PR 47092.Sept. 23.19S11
9 287J Definition*.
The definitions set forth in Section
1004 of the Act apply to this part Spe-
cial definitions of general concern to
this part are provided below, and defi-
nitions especially pertinent to particu-
lar sections of this part are provided In
those sections.
"Disposal" means the discharge, de-
posit, Injection, dumping, spilling,
leaking, or placing of any solid waste
or hazardous waste Into or on any land
or water so that such solid waste or
hazardous waste or any constituent
thereof may enter the environment or
be emitted into the air or discharged
Into any waters, including ground
waters.
"Facility" means any land and ap-
purtenances thereto used for the dis-
posal of solid wastes.
"Leachate" means liquid that hss
passed through or emerged from solid
waste and contains soluble, suspended
or mlsdble materials removed from
such wastes.
"Open dump" means a facility for
the disposal of solid waste which does
not comply with this part
"Practice" means the act of disposal
of solid waste.
"Sanitary landfill" means a facility
for the disposal of sottd waste which
complies with this part
"Sludge" means any solid, semisolid,
or liquid waste generated from a mu-
nicipal, commercial, or Industrial
wastewater treatment plant, water
supply treatment plant, or air pollu-
tion control facility or any other such
waste having similar characteristics
and effect
"Solid waste" means any garbage,
refuse, sludge from a waste treatment
plant, water supply treatment plant
j
-------
Environmental Protection Agency
or Air pollution control facility and
other discarded material, including
solid, liquid, semisolid, or contained
gaseous material resulting from indus-
trial. commercial, mining, and agricul-
tural operations, and from community
activities, but does not Include solid or
dissolved materials in domestic
sewage, or solid or dissolved material
In irrigation return flows or Industrial
discharges which ere point sources
subject to permits under Section 403
of the Federal Water Pollution Con-
trol Act, as amended (86 Stat. 880), or
source, special nuclear, or byproduct
material as defined by the Atomic
Energy Act of 1954, as amended (68
Stat, 923).
"State" means any of the several
States, the District of Columbia, the
Commonwealth of Puerto Rico, the
Virgin Islands, Guam, American
Samoa, and the Commonwealth of the
Northern Mariana Islands.
(44 FR 93460. 8«pt. IS. 1979; 44 PR S8910.
Oct. 13, 19791
1287J Criteria for classification of solid
waste disposal facilities and prsctlcts.
Solid waste disposal facilities or
practices which violate any of the fol-
lowing criteria pose a reasonable prob-
ability of adverse effects on health or
the environment:
I237J-l Floodplalns.
(a) Facilities or practices in flood-
plains shall not restrict the flow of the
base flood, reduce the temporary
water storage capacity of the flood-
plain, or result In washout of solid
waste, so as to pose a hasard to human
life, wtldllle, or land or water re-
sources.
(b) As used In this section:
"Floodplain" means the lowland
*nd relatively flat areas adjoining
inland and coastal waters. Including
nood'prone areas of offshore Islands,
vtUch are Inundated by the base flood.
<3) "Washout" means the carrying
of solid waste by waters of the
base flood.
§ 357.3-3
(44 FR SI4S0. Sept. 13. 1979: 44 FR 64708,
Sept 31, 1979]
f 1S7J-I Endu(«rtd •peclts.
(a) Facilities or practices shall not
cause or contribute to the taking of
any endangered or threatened species
of plants, fish, or wildlife.
(b) The facility or practice shall not
result In the destruction or adverse
modification of the critical habitat of
endangered or threatened species as
Identified In 80 CFR Part 17.
(c) As used In this section:
<1) "Endangered or threatened spe-
cies" means any species listed as such
pursuant to Section 4 of the Endan-
gered Species Act.
(3) "Destruction or adverse modifica-
tion" means a direct or Indirect alter-
ation of critical habitat which appre-
ciably diminishes the likelihood of the
survival and recovery of threatened or
endangered spedes using that habitat,
(3) 'Taking" means harassing, harm-
ing, pursuing, hunting, wounding, kill-
ing, trapping, capturing, or collecting
or attempting to engage In such con-
duct,
12874-3 Sarfaee water.
(a) For purposes of Section 4004(a)
of the Act, a facility shall not cause a
discharge of pollutants Into waters of
the United States that is In violation
of the requirements of the National
Pollutant Discharge Elimination
System (NPDE8) under Section 403 of
the Gean Water Act, as amended,
(b) For purposes of Section 4004
-------
§257.3-4
found in the Clean Water Act. as
amended, 33 UJS.C. 1251 et seq., and
ImplemenUnc regulations, specifically
33 C7R Put 333 (43 7R 37123. July
19. imi
[44 FR 91440. Sept. 13. 1979. u amended it
46 FR 47063. Sept. 29.19811
1257 J-4 Ground water.
(a) A facility or practice shall not
contaminate an underground drinking
water source beyond the solid waste
boundary or beyond an alternative
boundary specified In accordance with
paragraph (b> of this section.
(bXl) For purposes of Section
1008(aX3) of the Act or Section 405(d)
of the CWA. a party charged with
open dumping or a violation of Section
409(e) may demonstrate that corapll-
ance should be determined at an alter-
native boundary In Ueu of the solid
waste boundary. The court shall estab-
lish such an alternative boundary only
If It finds that such a change would
not result in contamination of ground
water which may be needed or used
for human consumption. This finding
shall be based on analysis and consid*
eration of all of the following factors
that are relevant:
(1) The hydrogeologlcal characteris-
tics of the facility and surrounding
land, including any natural attenu-
ation and dilution characteristics of
the aquifer.
(11) The volume and physical and
chemical characteristics of the leach-
ate:
(ill) The quantity, quality, and direc-
tion of flow of ground water underly-
ing the fadllty;
(1 v) The proximity and withdrawal
rates of ground-water users;
(v) The availability of alternative
drinking water supplies;
(vl) Ttao existing quality of the
ground water, including other sources
of contamination and their cumulative
Impacts on the ground water;
(vii) Public health, safety, and wel-
fare effects.
(2) For purposes of Sections 4004(a)
and lOOKixj), the State may estab-
lish an alternative boundary for a fa-
cility to be used in Ueu of the solid
waste boundary only if it finds that
such a change would not result in the
contamination of ground water which
40 CF« Ch. 1 (7-145 Edition)
may be needed or used for human con-
sumption. Such a finding shall be
based on an analysis and consideration
of all of the factors identified in para-
graph (bXl) of this section that are
relevant.
(c) As used in this section:
(1) "Aquifer" means a geologic for-
mation. group of formations, or por-
tion of a formation capable of yielding
usable quantities of ground water to
wells or springs.
(2) "Contaminate" means introduce
a substance that would cause:
(1) The concentration of that sub-
stance in the ground water to exceed
the maximum contaminant level speci-
fied in Appendix I. or
(U) An Increase in the concentration
of that substance in the ground water
where the existing concentration of
that substance exceeds the maximum
contaminant level specified In Appen-
dix L
(3) "Ground water" means water
below the land surface In the zone of
saturation.
(4) "Underground drinking water
source" means:
(I) An aquifer supplying drinking
water for human consumption, or
(II) An aquifer in which the ground
water contains less mm 10.000 mg/1
total dissolved solids.
(9) "SoUd waste boundary" means
the outermost perimeter of the solid
waste (projected in the horizontal
plane) as It would exist at completion
of the disposal activity.
[44 FR 83460. Sept 13. 1979. ts amended at
46 PR 47063.8ept. 33. IM11
1157.3-5 Application to land Mtd for the
production of food-efcsia crops (inter*
Im final).
(a) Cadmium. A facility or practice
concerning application of soUd waste
to within one (peter (three feet) of the
surface of land used tor the produc-
tion of food-chain crops thaU not exist
or occur, unless In compliance with all
requirement* of paragraph (axi) (I)
through (Ul) of this section or aU re-
quirements of paragraph (aX2) (1)
through
-------
environmental Protection Agoncy
except (or solid waste containing cad*
miuin at concentrations of 2 mg/kg
(dry weight) or less.
The ff*""*1 application of cadmi-
um from solid waste does not exceed
0.8 kilograms per hectare (kg/ha) on
land used for production of tobacco,
leafy vegetables or root crops grown
for human consumption. For other
food-chain crops, the annual cadmium
application rate does not exceed:

Amu* C4
ThopaM
rata (kg/
*0
Prmnt to Jurw 90. 1M4
2.0
My t IM410 Oac 31 iff
1.39
Jan 1 *94?
09

(111) The cumulative application of
cadmium from solid waste does not
exceed the levels In either paragraph
(axixiUXA) of this section or para-
graph (axlXiliXB) of this section.
(A)

Madmum eunMrtv*
¦PPteMun
Sola
Jon
(maq/tOOgi
Bart-
gmM mi
pH tan
Ml U
Sack*
ground tot
pH mm
«*an«J
lm •**
«i
s
9
9 to i).

s
10
»
Mare M

(B) For soils with a background pH
of less than 6.5. the cumulative cadmi-
um application rate does aot exceed
the levels below: Provided, That the
pH of the solid waste and soil mixture
Is adjusted to and maintained at 6.9 or
greater wheamr food-chain crops are
grown.
Safl colon aacftanfi
naaaafr <>wq/100#
aanum*
¦flMaon
WW
Laaa man •
«
Ski 13
10
»
Mar* nan it

(2X1) The only food-chain crop pro-
duced is animal feed.
(11) The pH of the solid waste and
soil mixture is 6.5 or greater at the
time of solid waste application or at
§ 257.3-5
the time the crop is planted, whichev-
er occurs later, and this pH level Is
maintained whenever food-chain crops
are grown.
(ill) There Is a faculty operating
plan which demonstrates how the
animal feed wUl be distributed to pre-
clude ingestion by humans. The facul-
ty operating plan describes the meas-
ures to be taken to safeguard against
possible health hazards from cadmium
entering the food chain, which may
result from alternative land uses.
(iv) Future property owners are noti-
fied by a stipulation in the land record
or property deed which states that the
property has received soUd waste at
high cadmium appUcation rates and
that food-chain crops should not be
grown, due to a possible health
hazard.
(b) PolvchlorinaUd SiphenyU
(PCSt). SoUd waste containing concen-
trations of PCBs equal to or greater
than 10 mg/kg (dry weight) is Incorpo-
rated Into the soU when appUed to
land used for producing animal feed.
Including pasture crops for animals
raised for milk. Incorporation of the
solid waste Into the soU is not required
if it is assured that the PCB content is
less than 0.2 mg/kg (actual weight) in
animal feed or less than 1J mg/kg (fat
basis) in milk.
(c) As used In this section:
(1) "Animal feed" means any crop
grown for consumption by animals,
such m pasture crops, forage, and
grain.
(2) "Background soU pH" means the
pK of the soU prior to the addition of
substances that alter the hydrogen Ion
concentration.
(3) "Cation exchange capacity"
means the sum of exchangeable ca-
tions a soU can absorb expressed in
milU-equlvalents per 100 grams of soU
is determined by*sampling the soU to
the depth of cultivation or solid waste
placement, whichever Is greater, and
analyzing by the summation method
for distinctly add soils or the sodium
acetate method for neutral, calcareous
or saline soils ("Methods of SoU Anal-
ysis, Agronomy Monograph No. 9." C.
A. Black, ed„ American Society of
Agronomy. Madison, Wisconsin, pp
891-901.1948).
-------
5 257.3-6
(4) "Food-chain crops" means tobac-
co, crop* grown lor human consump-
tion. and feed (or animals
whose products are consumed by
humans.
(9) "Incorporated into the soil"
means the injection of solid waste be-
neath the surface of the soil or the
mixing of solid waste with the surface
soil
(6) "Pasture crops" means crops
such as legumes, grasses, grain stubble
and stover which are consumed by ani-
mals while grazing.
(7) "pH" means the logarithm of the
reciprocal of hydrogen ion concentra-
tion.
(8) "Root crops" means plants whose
edible parts are grown below the sur-
face of the soil.
(9) "Soil pH" is the value obtained
by sampling the soil to the depth of
cultivation or solid waste placement,
whichever is greater, and analyzing by
the electrometrtc method. ("Methods
of Soil Analysis. Agronomy Mono-
graph No. 9," C-A. Black, e
-------
Environmental Protection Agency
compaction of soil or other suitable
material over disposed solid waste at
the end of each operating day or at
such frequencies and In such a manner
as to reduce the risk of fire and to
Impede vectors access to the waste.
(5) "Trenching or burial operation"
means the placement of sewage sludge
or septic tank pumplngs in a trench or
other natural or man-made depression
and the covering with soil or other
suitable material at the end of each
operating day luch that the wastes do
not migrate to the surface.
144 FR 83490, Sept II, 1979: 44 FR S4708.
Sept. Si. 19791
9 2874-7 Air.
The facility or practice shall not
engage In open burning of residential,
commercial. Institutional or Industrial
solid waste. This requirement does not
apply to Infrequent burning of agricul*
tural wastes in the field, silvlcultural
wastes for forest management pur*
poses, land-clearing debris, diseased
trees, debris from emergency clean-up
operations, and ordnance.
(b) For purposes of Section 4004(a)
of the Act, the facility shall not vio-
late applicable requirements developed
under a State Implementation Plan
(SIP) approved or promulgated by the
Administrator pursuant to Section 110
of the Clean Air Act. as amended.
(c) As used in this section "open
burning" means the combustion of
solid waste without (1) control of com-
bustion air to maintain adequate tem-
perature for efficient combustion, (3)
containment of the combustion reac-
tion In an enclosed device to provide
sufficient residence time and mixing
for complete combustion, and (3) con-
trol of the emission of the combustion
products.
(44 FR 91490, Sept 13. 1979; 44 FR S4708.
Sept. 31. 1979. as amended at 44 FR 47041
Sept. IS. 1991]
I1STJ4 Safety.
(a) Sxvlotiva paxes. The concentra-
tion of explosive gases generated by
the facility or practice shall not
exceed:
(1) Twenty-five percent (38%) of the
lower explosive limit for the gases In
facility strictures (excluding gas con*
Sisrm
trol or recovery system components);
and
(2) The lower explosive limit for the
gases at the property boundary.
(b) Fines. A facility or practice shall
not pose a hazard to the safety of per-
sons or property from fires. This may
be accomplished through compliance
with I 287.3-7 and through the period-
ic application of cover material or
other techniques as appropriate.
(c) Bird hazard* to aircraft A facili-
ty or practice disposing of putresclble
wastes that may attract birds and
which occurs within 10.000 feet (3,048
meters) of any airport runway used by
turbojet aircraft or within 8,000 feet
(1.834 meters) of any airport runway
used by only piston-type aircraft shall
not pose a bird hazard to aircraft
(d) Access. A facility or practice shall
not allow uncontrolled public access so
as to expose the public to potential
health and safety hazards at the dis-
posal site.
(e) As used In this section:
(1) "Airport** means public-use air-
port open to the public without prior
permission and without restrictions
within the physical capacities of avail-
able faculties.
(3) "Bird hazard" means an Increase
In the likelihood of bird/aircraft colli-
sions that may cause damage to the
aircraft or Injury to Its occupants.
(3) "Explosive gas" means methane
(CB«).
(4) "Facility structures" means any
buildings and sheds or utility or drain*
age lines on the facility.
(8) "Lower explosive limit" means
the lowest percent by volume of a mix-
ture of explosive gases which will
propagate a flame in air at 28'C and
atmospheric pressure.
(8) "Periodic application of cover
material** means the application and
compaction of soil or other suitable
material over disposed solid waste at
the end of each operating day or at
such frequencies and In such a manner
as to reduce the risk of fire and to
Impede disease vectors' access to the
waste.
(7) "Putresclble wastes" means solid
waste which contains organic matter
capable of being decomposed by micro-
organisms and of such a character and
7
-------
f 257.4
proportion a* to be capable of attract*
inc or provldlnc food lor bird*.
0 2874 Effective date.
These criteria become effective Oc-
tober IS. lfTt.
Aman>ix X
The maximum contaminant levels promul-
lated herein are for use In determining
whether solid waste disposal activities
comply with the ground-water criteria
<1297.1-1). Analytical methods for these
contaminants may be found In 40 CFR Part
141 which should be consulted in its entire-
ty.
i. Maximum contaminant levels for inor-
panic chemicaU. The following are the max-
imum levels of inorganic chemicals other
than fluoride:
Commnani
iMl
. .
0M
t
¦jam
r.ilmfc—
0.010
AOS
aos
ooos
to
001
aos

Satanhjn

The maxhninn contaminant levels for flu-
oride arc
Tunpumi' am
frintaT

iMl
imsaaia
vmrnm
537 and btkm
tirtbsw
111 M 14 f
14
U
as
1.8
14
1.4

14? Is MM

MltifPI ,

MfkMI

'Am* emngsef tm
2. Maximum contaminant levels far or-
ganic chemical*. The following are the max-
imum contaminant levels for organic ehsmi*
cals:
40 CFK Ch. I (7-1-13 Edition)

Lmi

ImMgram*
P* Wl
Undww

hmnii
^snmt mow

o nu
iwe—i
*jr (1.1,1-THcNa
iphwy) eeenef .
(p.
V. MM
0.1
Touphan
> (C^HwOrTactn
Ll*i_L_UJ
MCNoraphar
na. ST to OS prar
t CMUIW)
om

2.4-0 0.4

Jtfe
0.1
2.4J.TF
SAm (2.4^-TncM9raphw am-

T Iftlf

0.01

1- Maximum microbiological contaminant
levels. The maximum contaminant level for
collfonn bacteria from any one well is ss fol-
lows
(a) using the membrane filter technique:
(1) Four oollfonn bacteria per 100 millili-
ters If one sample is taken, or
<21 font collfonn bacteria per 100 minni
ten in more than one sample of all the sam-
ples analysed In ooe month.
(b> Using the five tube meet probable
number proceduie. (the fermentation tube
method) in accordance wtth the analytical
recommendations set forth in "Standard
Methods for Examination of Water and
Waste Water". American Public Health As-
sociation. 12th Ed. pp. 662-481. and "-*~i a
Standard sample, each portion being one
fifth of the sample:
(1) If the standard portion Is 10 milliliter1!,
eoUfonn in any five consecutive samples
from a weU shall not be present in three or
more of the 28 portions, or
(2) If the standard portion Is 100 miUUi-
ten. eollform In say five consecutive sam-
ples from a well shall not be present In five
portions la any of five samples or la more
than fifteen of the 28 portions.
4. Maximum contaminant levels for
radium-Hi, radlum-229, and gross alpha
particle radioactivity The following are the
maximum contaminant levels for radium-
228, radium-221, and gross alpha particle ra-
dioactivity:
(a) Combined radiua-238 sad radium-
228-4 pO/t
(b) Grass alpha particle activity (Including
radium-236 but excluding radon and urani-
um)—18 pCl/L
AcrnroixII
b(ijUAiflilMeatfionXT"
M.4CM.M.H ocmyisn I,
to Significant!* Reduce
Aerobic digestion: The process Is conduct-
ed by agitating sludge with air or oxygen to
maintain aerobic conditions at residence
18 ds at 18* C to 4ft
D-8
-------
environmental Protection Agency
days at 20* C. with ft volatile sollda reduc-
tion of it taut 31 percent
Air Onriv liquid sludge Is allowed to
drain and/or dry on under-drained sand
beds. or pared or tmpaved basins In which
the sludge Is at a depth of nine Inches. A
minimum of three months Is needed, two
months of which temperatures averace on a
dally basts above 0* C.
Anaerobic digestion: The process Is con-
ducted In the absence of air at residence
times ranging from 80 days at 30* C to IS
days at 34* to 88' C, with a volatile solids re*
ductlon of at least M percent
Composting; Using the wlthin-vessel,
static aerated pile or windrow composting
methods, the solid waste Is maintained at
minimum operating conditions of 40* C for 8
days. For four hours during this period the
temperature exceeds 88* C.
Lime Stabilisation: Sufficient Itme is
added to produce a pB of 12 after 3 hours of
contact
Other method* Other methods or ope rat-
ine conditions may be acceptable If patho-
tens and vector attraction of the waste
(volatile solids) are reduced to an extent
equivalent to the reduction achieved by any
of the above methods.
B. Proceue* to farther Reduce Pathogens
Composting: Using the wl thin-vessel com*
posting method, the solid waste Is main-
tained at operating conditions of 88* C or
greater for three days. Using the static aer-
ated pile composting method, the solid
waste Is maintained at operating conditions
of SS* C or greater for three days. Using the
windrow composting method, the solid
waste attains a temperature of 88* C or
greater tor at least 18 days during the com*
posting period. Also, during the high tern*
perature period there will be a of
five turnings of the windrow.
Heat drying: Dewatered sludge cake Is
dried by direct or Indirect contact with hot
gases, and moisture content Is reduced to 10
percent or lower, nudge particles reach
temperatures weO In excess of 80* C. or the
wet bulb temperature of the gas stream In
contact wtth the sludge at the point where
It leaves the dryer is In excess of 80* C.
Heat treatment- Liquid sludge is heated to
temperatures of 180* C for 30 minutes.
Thermophilic Aerobic Digestion: Liquid
sludge Is agitated with air or oxygen to
maintain aerobic conditions at residence
times of 10 days at 88-80* C with a volatile
solids reduction of at least 38 percent
Other method*• Other methods or operat-
ing conditions may be acceptable if patho-
gens and vector attraction of the waste
(volatile solids) are reduced to an extent
equivalent to the reduction achieved by any
of the above methods.
Any of the processes listed below, if added
to the processes described la Section A
Pari 260
above, further reduce pathogens. Because
the processes listed below, on their own. do
not reduce the attraction of disease vector*,
they are only add-on In nature.
Seta rag irradiation: Sludge Is irradiated
with beta rays from an accelerator at dos-
ages of at least 1.0 megarad at room temper-
ature (ca. 20* C).
Gemma ray irradiation: Sludge Is irradi-
ated with gamma rays from certain Isotopes,
such as "Cobalt and '"Cesium, at dosages
of at least 1.0 megarad at room temperature
(ca. 20* C>.
Pa»te%riMation: Sludge is maintained for
at least 30 minutes at a minimum tempera-
ture of TO* C
Other method* Other methods or operat-
ing conditions may be acceptable If patho-
gens are reduced to an extent equivalent to
the reduction achieved by any of the above
add-on methods.
-------
APPENDIX E
STATE REQUIREMENTS AND GUIDANCE FOR SLUDGE USE AND DISPOSAL
-------
TitM ES»t. LandfllUng • Sludge TrMtnynVM«n»q«rnfrnt
Slats
Sludge Oewateong
Sludge Stabilization 1
AiaBama
Yes
Yes 1
Alaska
> 10% solids
Yes 1
Arkansas
>30% solids
1
California
20% solids if primary sludge
19% solids if secondary or mixture of sludge

Colorado

No raw sludge or sec tags 1
Connecticut
Yes: case-ty-case
Yes 1
Flonda
For codupoaat
1
Georgia
res
Yes 1
Idaho
Solids content >13%
I
Illinois
For some landfills

lowa
> 73% solids
Yes I
Kentucky
Yes - no free water
Yes - PSRP I
Louisiana
No free liquids
1
Maine
Minimum 20% solids
I
Maryland
No free liquids • may mix with sod and retest
I
Massachusetts
> 18% solids
SpeoaJ handling required it not stafrUtt 1
Missoun
No free water
Yes |
Nebraska
Special aporov* needed to take sludge eomamg moistur*.
If moisture >60% lagoon storage required.

New Hampshire
Minimum 20% solids
No I
New Jersey
>20%
Yas 1
New Mexico
Yes
I
New Yorv
To 20% SOWS
Yea I
Norm Carolina
Yea. mmmum 20%. no coaapoan
«ntf> sew wests after 3/i/CT
Yes 1
Ohio
Yes
Yea, to tna pom mat the maanat. while oonesr* I
and viscoua. stowty flows or loses its shaoe when |
uncontlned, and does not reeKy reieaae kqwds 1
under normal condrtnna |
Oklahoma
No fre» kquda untees leacha* collected and muad wMh
Oukngmaanat
Raw tfudQe must t» dopoaed of remoteiy 1
Pennsytvama
Pass Mar test
Yea 1
Puerto R«o
Yes
Yea J
Rhone island

Not meet hazardous warn arena I
SouJi Can*ria
Must be >is% sotda
Yea 1
Tennessee
Mnmum 20% seeds
Ye* J
Texas
19% mrwnun sotda
(trench and ft* m «udge-onty tandM)
Reqme special handkng
-------
TaW £5-1. UntfWnq • Sfcidgi Tr—tmnvManagment (Continued)
State
Sludge Oewatemg
Sludge StaMizaaon
utan
Sludge vnth no free moisture o20% hWx minimum erf 8.1 sohtissfudQe raao
Yea
Virgin isUrxio
Pendmg

Wasfungmn
iS-20% tar fid afiove surface; i 1 MdgKjal ratio

west Virgna
Must have >30% scwa
Yea
Wyoming
Yes - no One or standing watar

-------
I • Sfltfflc COHSMeretlona
Down (o
Ground Water
Buffer Zonew
Nearaat Oweiiiny
Distance to Waiia
Sort Type
50 ft to site boundary
Naanwt aw«(ttfTg .
Minimum 9 ft above
">gft6a» anticipated
QW elevation
0«»9ned.
oon®njctea< operated.
rnar|tained to prevent
*«**«. Oiveraon
strvicturee.
Sitae prcrotad m
"oodpiams
Airports
Cue by-caae
determtnaaon
Minimum 3 n to
man mum nigh water
table
Cannot nestncr tow at
Hood or cauae
waahout - no jpacrtfc
proftitmon
i .000 ft to wells
"••rwtdweifcng.-a
100 ft
20 incftes froni
seasonal high QW
200 ft
« A?'*a,,Wnjnw«w
3.000 ft tor r'nneHi
900 ** C nearest «M|
Mwimun of 9 ft
on so4 type
>00 ft to sta boundvy
"2 mt to pnvate wefl
2 on to ouefce weH
A»0w«d only w«h
approval
.nnXiT"' Darm,MW>
'00-300 ft mm vegetative
screen
Notm 100-yr
feottam
Indiana
Can't be
1000 ft to
300 ft to nearest dwefcug
Kentucky
230*1000 ft
«R(BOW
2 Kiobednoc*
Nolwthn 10-yr
"oodHM
290*1000 ft to walls m
Wwnum s ft above
ftgh
100 ft ts Quote roads
property i**ee
1000 ft»
«
-------
Taflte E5-2. LancWng»SWa Spacttlc Conaldaratlona (cortinmd)
Stat*
MiMtMppI
Surface Wa
Oactn to
Qreund Water
10-13 ft
&*Type
Fiooddaw
Restrictions
Yet - Protect from
100-yr flood by levees
Bufter Zone*
Nearest OweNin^
Distance to We#s
90 ft to property im*; 2 r
to iet «nxxt 1 9 ft
Oaptfi to »sasons%
hqh ground waar
atto > 3ft
raoompactad day knar
piue a aynrnaoc knar
Sgitattecovw
maienai nd. loam,
sandy loam. aNy
town, em loam, *¦
ty day orotfw
mat-
Pro»*&»d«a
regulatory floodpian
•Koepttiy maane ot a
wanargranMby
OtaoCPA
WHMMM
hwwq a low par-
T>aaO*ty to water,
good compart*-
Mty. coftaarvanaai
and maavaty
unrformta*U»
i .000 ft from a waiar wet >n 1
aanenca on me aa* ma
plana ware receded by tha
Ohn EPA axcaot by means
of a wanar granted by 0*o
EPA drector
Caaa-Oy-caaa tar nearest
Oklahoma
100 d®
9ft»season«»gft
i00*yaar flood
290 ft Dprwua
600 ft io ouQfcc
goo *»
Oregon
FaeMydtonoi
tea ot baa* toad.
200 ft e
-------
TaMES-2.
¦ Site Specfflo CawaMecationa (continued)
Stats
OMmD
Surfeoe Waar
Oeptfi to
Ground Water
So* Type
Ptaodda*
Reatncoors
Bufler Zones/ 1
Nearest OweHm^ 1
Distance to Wets 1
Psrnjytvarua
100 ft to streama
3 ft beneaiti finer
system

100-year Hood
1/4 mi upgradiant. 300 It 1
oowngradieni to surface 1
water 1
Puerto Rco
Case-t>y-caae
determination

Yea
Caae-by-caae
Oeaqned. constructed
10 prevent washout
dweraun arvjctue
Caae-ey-caae distance to 1
we* determmaaon 1
Rhode island
200 ft and not m a
water supcfy
watersneo
4 ft to togneat water
tatte or (war
Yea
100-yr floodrtam
1.000 ft to we#a 1
400 ft to any non-nta 1
Duikhng 1
Sou* Carolina

Cannot Mma 100-yr
floodpttn

Tennessee

Not subject to ftoodvig

Texas

Sari sampkng:
Cd. Cu, Ptj, S«. Zt\,
Cr. N, Fe. Mn

200 It tram properly 1
ime to landM 1
Utrt

Yea
Yea

Vermont
300 ft
10 ft from level of
landM to suaonaJ
nqh watar taUe

Not in 100-year
tooapan
1.000 ft n««ai I
Minnnum 300 ft B 1
orooarry ime 1
Vugroe
100ft
J ft to mawnum
seaaonal watar taae
Yea
Cannot oe m a
AooOoutn
200 ft to nearest
-------
ES-3
Gas
Control
Runofl
Control
Liners
Case-by-case-
¦Mtenno permeab*ty
Yea - structures must
not atom gas to
cotect
Yes
Final slope < 2%
Yes
Ym
Dikes
Yes
PermeatoMy nd
> W0« cm/sec
it hazardous
>2 It »*cfc day
Yes
CompaUble wth
istfift to be recewed
2S% ol L£L tor
methane
Yes
Ym - pii»—tmnni
¦ •«!
Yes
ist allow lor it and
control on stte
A1 taactiate ootecbon
(Mcttes and ponds
muflhaw
n^ierrneaUe knars
kfcrv 2% slope on
completed M.
precludes eraeon.
Conkol 4 not rearWy
Case by case
Yas - depends on
type
Yes
Yea
211
No regulator) Out
50% do (l anyway
Yea
Ym
Yes. case-oy-caaa
Depends on material
Sets ma>
permaatoMy
10 ft tocfc ttaMub (X
tos material
Addressed *»
apptcauon ReqMire
com* and plana tor
evatuabon
ym
do
no* migrate oil
site
so*
-------
Tablt EH. LandWUna - Management Practices (continued)
Gas
Control
Yes
Only in readential
areas
Yas
1 k ear*) cowering at
end ol day
Grade tar runoN and
25% LEL m structure
or property hne
Yes
<25% LEL m
structures
MOT ?***** dOSltfO
Yes
Yes
Yes
Yes
Oariy 6 rt. hnat 30 M
Mt>t a day
Control measures
must to mptameniBd
Mb
organc malarial
connect ID gas
ooaecaon system
AM
3 It ol natural clay ol
staled permeatMUy. or
less, uher
Construction ol
Mas. canals, and
otoer dNetsnn
25% ol LEL lor oases
si taokiy structures, at
waste lacAfy
Yes
Plan lor preventing
GVtf poluwin
Yes
Collection witt
"sludfponly* landWls
yes - ieactiaie conuoi
Yes
Oouble kners
required, day or soil
Must meet
permeataMy req.
Yea
Sea
Rewtraduoe or treat
Prevent lateral travel
and accumulaaon in
structures
Seems to be an
after name
Yea
Yes
LEL <25%
Yes - wtiare needed
to protect OW
Surface drainage
controls
Mas 8% slope
and
Yes • land appfccau*1
onto finished cover ot
treatment and
discharge undei
NPOES permit
Prevent hazard «rftere
necessary
Yea
Yas
Aestrcted entrance
-------
TiM> tM. I andfWtlng • fcUr»g>nn« Pracltc— (conUouad)
State
Conor
PaM0M
Control
Access
Control
RunoK
Control
Lrors
Gas
Control
Leactate
CoMacbon
UanlMi

PSRP/PfRP
vanous mattiods
Fancmo
Keep runoa out oi
ftotpnitflt flfflft
Case-by-caae basis
membrane knars
Caaa-toy-casa

MUrin ¦

Musi not migrate ofl-
Site
Yaa
IMa

Yes
For hquri sludge

R-M-d

fenced au
Yes ¦ proven! (ram
entering trench

nmhmpm*
Fm oo»m dapti 21
NoattMMftOArf
oed^wePfWe
Fence and oate
Yas piua runon
control
ParmeabAiy o<
1 *10*
<24% of lower
eiptosMkmtol
mettane
Rearctiaie or keat
ofl-ate
1
*
1
Ym
Yaa
V«
Yes
Yes
Yea
Yes
NwVqA
Odirtn
Innrwftain U a
fMtan
Vector control
Fenono. oakta.
•QM
Yaa
Double compoate
knar system lor
ooduposai tare**,
case apeafcc lor
sludge-only landM
Coraroted
25% LEL m
structures
LEL ai boundary
When sludge net
MOigru >25% Ot
landli materials per
day
Nor* Carat**
y«wnun»2ft

Fence. gate. ate
Yas
Saa-spaofcc
Not >26% LEL m
structures
< ioo% LEL ai
boundary
Yes
Om
Ot% • «
iiMnnm t k
fMtl*
inlacaoua weeks
Yea
Yaa
ftecompactad day
knar plus syitfhefcc
knar
Gas iDonaormo
Required

1 —
o»*r •*
wwy:» w
fMtsa
Vector control
Fanono. locked
gates
No slope >4%
Hydraufcc oonductMty
kmaed
25% LEL m bufcftngs
100% LEL at property
boundary
Yes
—

Parvneter barrar
To flMr«mue poiuiani
flow to aurfaoa wator

Methane kmds <25%
LEL m structures,
< 100% LEL at
boundary
Yes
—
ik*r**

Penmeter barner.
lenca
Yes. E 4 S control
plan
so im
Yes
Racked
-------
Eft-3. UwdtMMng • Manapefni P»ctlc— (continued)
Runoff
Control
Liners
Construction at
dwenaon devices
UsuaKy not a profctom
Yes
Yes. grada/prevent
Yes
Yes
Yes
Yes
Yes
petmeabtty ol
< iiIO^crimc and
at tnast 2 it *m*
Yes
OouMe knots raqured
Aspltaft. concrete.
Md tool i (actty not
PSHP
Yes
And treatment if
average ramla» >25
*vy
Vent or tedvect
Prevent
tundadt wotafcona
Screen
Yes
be
to be
Yes
Yes
Yes
Yes pfOftbted born
entenng waters
Ak
Yes
Case-by case
-------
Tab* LandtBMng • Monitoring and Reporting
Staa
fllQWfVMntl
Onound-WaJer
Monitoring
Surface-water
Monitoring
Sludge Quality
Monitonng
Os*elopment
and Closure Plana
Alabama

Yea
Yea • Development
and Closure
Alaska
-------
Trttf* E5-4. LudWng»Mcmtertwg and BepoUng (continued)
sum
R««iranNnt)
Qround-water
Monitonng
Surface-water
Monitoring
Sludge Quality
Monitoring
Site Development
and Closure Plans
Maine
Ml
manual
Minimum of 3
sample ports
Minimum of 2 sample
pants
Development plan
Closur* within SO
days after active use
ends
Maryland
Quantity per month,
% capacity used.
protected **m to
read) capacity
Propose program
Propose program
As needed Aisopre-
appxaaon (% sows.
pH. N, ammonia,
nitrate. metals. PCS.
etc.) Before acceptance
(dry weight cone or %
38 APPR)
Oevetooment plan
desenpson and
operating plan
Massachusetts
Yes
Case-by-caae basis
| Comply wrth 40CFR297
Case-Oy-case
monoonng
Mcfwgan
Hydrogeological study
as pan o*
application process
Quarterly monitoring
To assess adequacy
oi teacnaa and
runoff control
imtafc sohds. nutrients,
mews, other tones
Follow-up: based on
quafcty, use
Development plan
Miussw
Bunai site must meet
sanitary landltil
requirements
Yes. site-specific
Ctaeure: speotfbunai |
and temnnaie 4U)ge
Vftf iwy whin
heavy meutt *0 3
max. UVL
Missoun
Upon request
Propose « plan
NPOES permit and
morutonng stormwatar
and leacha*
Development plan
Closure plan
Montana
Oispont rate (vol)
and percent jonds:
quarterty reporting
Caee-oy-case
Caae-ey-caae
Development pians
required, no
closure plans
Nevada
Development plan
New Hampafwe
Name, volume,
source, anatyaa.
method, deVmeong
May be required
May oerequred
>1 mg& 3 ameeryr
<1 mgd: i itmeryr
kk mewa. sows, on, r«
Oevctopnenc
provuona tor wwtter
storage reqwred
New Jersey
Yes
Yea
Yea
New Yort
Mranumof«
3
Estattsfc
corxnons and
' if
E* (sooty teet
venfy m it«
Operaang plan
Closure plan
Norm Caronn«
Oependrgon leowy
Yea. Jepenongon
facMy <
Site-ipecac
OMidpmeni plan
Closure pien. not as
sucn. ctoau*
pnxeduree neoM
Ohio
OarfytoBOf
Hv*eg**0QC study.
wetmaoMHn. and
mortfonng are
reqwnd.
Caae-by
Csae Or
Development plan
openaonal pro-
cedures and detated
plant am requeed aa
pan oi landM penM
i Closure plan: wed I
ae part <* two*
pemtto meufl
OUanoma
Darty log at operaaan
and waaa/ecewed
sufrnttt manWy
2 «e*s downstream
OW tarmaton
at dry
volume*
Oevetopment pun
Cioeure pun
-------
Tie* ES-4. uwdWBwq • MowMortng and Reporting (continued)
State

Ground-Water
Monitoring
Surtace-Waw
Monitoring
Sludge Ouahty
Monitoring
Site Development and
Closure P^ana
Oregon

May be required
May be required

Closure permit
inctudmg plan/financial
assurances, ex.
Rnode Island
Codiaposal approval
required
Yea • number of
mom ton ng wetia
approved by director

Site development and
operaang plan
Closure plan:
mom tormy hjodtng
South Carakna
Yea
Yea
Yes

Site devetopment plan
Tennesaee
Yes
Yea
Caae-ty-case
Comply witn
~0CFR257
Maatar otan (or site
and area
Te*aa
PerndK
Annua* Na. CI, Fe.
Mn, SO* pftenoi

Semi-annual s*npnng:
Cd. Cu. Ptt. S«. Zn. N
Site development plan
Closure plan
Utah

Approved sanitary
landM
Vermont
Monitoring
recommended and
quality at sludge
(vtdfWed
Moratonng weNa
required on an sites
Sampling; a omewyr

% aohds. pH, nutnenta,
necvy metals
Site development plan
doaure plan
Virginia
Volume disposed o<«
soM wests f«*ly
Yea. fortandM

Yes
Approv«d tatoy
landfii
Virjn islanda

Yes and closure
wMntnQQn

Ptw (or OW and tor
poMuoon control

west v*gm*

To be estaoashed

Musi m demonstrated
non-taiardous and non-
intsewua

Wiaconan
Volume rtupoaed at at
soM waste te*ty
May t» reqwred
May be rtqurad

Closure plan
Wyomng

Yes
CtM-Oy-cas*

YSS
S
-------
TMif EM. LandMBnq • Other State Management Practice Requlremawa
SUM
Management Pracoce I
Alabama
Other ¦ RCRA Stanovt 1
Arkansas
Landfill Now Cannot M disposed of m Claaa 3 or * permitted landfill without ax* aocrova J
California
Types o( Landfills • Class 1: Uqiad and SoUd Hszaroous Waste I
Types of Landfills - Claaa M undewatered sludge (land treatment units) 1
Types ot Landfills • Class ill: Oewaarad sludge and accaotaM mcweraar ash I
Colorado
No codisooaal without county aoorovat ]
Connecocut
Leachaia Testing • Anafyss rmsurwo |
Delaware
Comoacwn ¦ Sokd wast* must Da tonad and compacted m layers not exceeding 2 ft dooms 1
Fionda
Lsachats Toasng - imphed; Zorwig Contormance - Yae 1
Georgia
Other - Sort geology anafysa and hydrotogc tfialysw |
Plant samphng/crog: csat-by-csss [
Soil sampling momtortng: cast-by-can specified m management plan I
Hawas
Compaction • Mavmum 2 ft oeon 1
Idaho
No® ¦ EPA Pan 257 Raguiaaona I
Kansas
Operation pronftited unless permit issued specifically for sludge 1
Kentucky
Reeord-keepmg - amount oi waste deooeat Laacnass Teaang - Yes 1
Lousana
Ar Momtonng ¦ Darfy checks tor odors. monthly cheeks tar armnee. cMomatad hydroctfUons I
Leachaia Tesang • Monrtomg wens measure aftact of control system used 1
Mam
Other - handing srte 1000 ~ ft away from avoort mnways 1
Maryland
Equipment • Must oe aue to hand* sludge 1
Note • Saasly al condraons ol COMAA 10.17 ti I
Odor Comal • Not aeaesrw or persotsnt 1
Permits - Ooerws m comoMnca w»th vakd refuse dopoeal permits 1
Massachusetts
Has codtsocss) rags. MonoM gudstnee. Ooutte bner raqurad 1
Miampp
Oeed Record ¦ Use se a land* |
Maaoun
Deed Record - Record of contents and need tor consnued mamenanoe 1
NewHamptftre
Applesfton nm - one ame appicaaon not to exceed 30 nwacn lor redamaaon. 1
CodMooaai • 4:i raso raftjn d Judgst not <3:1 |
N«w Yorfc
Uftt»ght to Itmmnum I
Nonh Carolina
Record keaotg. deed tvoonftngt and rauana ttudgs analyse 1
Ouanoma
Compacting ¦ layers not o aseead * ft compacaon 1
Rhode i stand
CocMooesl • Approval requrad 1
Vermont
Prelerred Meted By sraaow mndt.waiennedUm»B-Ne)andM Stowed eiOa* A wear** |
V<9W
Loadng wtms •' 9 ttudge to sofcd waeM rata otfw • scad waeta management reguiaeons 1
wiMiiyui
LoadngLjnMS • i 4 to i S tfudgtsoM waste rasa nvsw* <40* 1
-------
TaW EM. LandfMnq - Ottwr ton Mwjwwt Practlca RacMrawma (oonthmti)
Stata
Managamem Pfacaca
W« Vwgma
Oa*g»vcoflmictiocvOPft-6PA's grocMi daaqn manual - mum Sudgi tawmia
loaong bmi'3 - sudga < 30% of wasta landMad. uniaaa it a a oetbcatao imh
Standaroa - Part 237 raga
Wucormn
Laacftata Tasting • Yaa
No landMa m wntanda, critical naMst
WyorrwiQ
Fm Protection • Fir* lanaa and ovtar forma ct (Ira crowction
-------
SfcdgaQuaMy
IIUTKM
J*f»a and J2*Ra Combned
Wiscorwn
"•BaOmy
3 2 pCt/q

May 0» tinooaoa ot at WONS • kaancad laiwfiH
s 9 pcvg
May bo diapoaed of at lEPA-pamvitsd landM
•
>^nd a SO pCt/g
t

Sludge rtwpoaed of m isolated area
Saonary landM require* approval of WONR wd
WOHSS and leactata collection
10 ft uncomartwatad cover
Baaon (ja» prowcoor
Mm «
-------
T»W EH. una AppMcrton • Sim MuW-ar»d« Study Cowtiwfcwrt Co»ic««mtton Umfta
flagion
Sua
Contaminant
Contaminant Limit (mq/kg)
OracM t Siudg*
Qrada 2 Shxtga
Oracle 3 SHjdqa
Qrada « Sludge
NJ
Akjrm
0.1
0 1
0 i
MO
Alum mom
20.000
NJ
IA
Ml
MO
Arsanc
10
90
<100
490
10
100-2000
10
>2000
MO
BatyHium
490
WY
MA
MO
VA
WV
Boron
i 29
<300
900
100
100
<300
>300
1
10
9
1
1
7
1
2
8
3
9
a
3
10
1
3
4
MA
WA
Ml
ME
NH
IA
HI
NJ
SD
VA
CA
CO
MO
OR
VT
WV
FL
Caflmtum
M«aan
Mod*
<2
2
<9
10
10
19
19
20
20
20
29
29
29
29
29
29
30
20
29
<29
9-129
>29
>129
70
100
89
N/A
129
100
113
129
NJ
Chiordam
0.10
0.10
9
7
I
1
1
2
2
3
3
1
Ml
IA
MA
ME
NH
NJ
NY
PA
VA
VT
MO
Chromium
Com
<90
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1 000
I 000
290
90-9000
1.000
1.000
1.000
>000
>9.000
1.000
1.000
N/A
-------
Tift» E6-1. Lmd App*c*Bon • Sttt» MuW-Qr»2.000
3.129
3.129
3.000
1.000

Median
Mod*
1.000
1.000
1.429
1.690
3.000
3.129

2
NJ
Orttom
O.iO
0.10

I
7
MO
Ocxm
0.001
•
•
I
2
NJ
Endrwt
010
0.10
-
1
7
MO
FKjOtc*
«.ooo
•

1
2
NJ
Hepucwor
0.10
0.10
•
|
2
NJ
HepUBrtOf Epoxide
0.10
0.10
•

1
5
1
9
1
1
8
4
7
3
2
10
3
a
a
a
3
3
3
2
Rl
Ml
MA
CA
ME
NH
CO
Fl
IA
MO
NY
OR
PA
SO
TX
UT
TX
VA
VT
WV
NJ
load
M9QV>
Mod*
9
<290
300
500
700
700
1.000
<1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1.000
1 000
1.000
2.400
1.000
1 000
290 2000
1.000
2.900
1.900
2.900
4.aoo
2.000
2.900
>2.000
1.000
5.000
>1.900
9.000
2.000
9.000

2
NJ
U4an«
0.10
0.10

I
7
MO
UfMTI
900
•

I
7
MO
tftmwii
2.900
-
-
1
-------
TaWe EH. Land Apptotlon • SUM MultfrOrade Sludgt Contaminant CamemraUOH Unnte (continued)
Region
Contamnant
Contammaru Umti fmg/iq)
Grade i Sluoge
Qraoe 2 Shjoga
Grade 3 Sludge
Grade « Sludge
Ml
Rl
IA
MA
MO
ME
NH
Nj
MY
PA
SO
VA
VT
wv
MO
Mareury
Median
Mode
<2
9
10
10
10
10
10
10
10
10
10
10
10
IS
900
10
10
2-10
10
10
10
10
>10
10
10
10
NJ
MemoxycNor
0.29
0 25
NJ
Mw
0.29
0.29
MA
Ml
VA
MO
MdyManum
Mode
10
<10
20
40
20
10
10
10-90
20
N/A
10
>90
30
N/A
10
Ml
R.
on
IA
MA
MO
ME
NH
NY
PA
Rl
VA
VT
WV
CO
UT
NJ
Nckei
<29
100
100
200
200
200
200
200
200
200
200
200
200
200
290
290
US
200
200
29-1000
900
200
080
680
1.290
900
200480
>1.000
300
200
1.290
1.290
790
1 290
MQ
NJ
p. p'-oo«
0.2S
0.29
NJ
p.p'-ogt
0.29
029
NJ
P. P'-TOC <000t
0 29
0.29
M0
10
NJ
22
22
-------
Tatto E8-1. Land *ppf iltton • State Muftt-Grade Sludge Contaminant CowcwwtnMlow Umrta (continuad)

Contaminant Urmt (rmykg) I
Region
Sim
Contaminant
Grade i Sludge
Qraoa 2 Sludge
Qraoa i Sludge |
Qraoa 4 siuaga |
a
wy
Selenium
02

.
I
5
IL

-
I
9
Ml

10
10-30
>60
|
T
MO

¦
1

Median
7

Mot*
Nona

I
2
NJ
Total PCBe
0.9
0.9
.
I
9
Ml

<1
1-10
>10
1
3
VA

1
1
MA

]
a
rx

I
3
PA

|
9
CA

I
a
CO

9
10
10
I
8
UT

9
10
10
1
10
AK

1
3
IN

|
4
KY

I
3
MO

|
1
ME

1
7
MO

1
4
MS

I
1
NH

1
2
NY

I
8
OK

I
1
Rl

|
8
SO

I
9
MN

1
4
SC

1
s
Wl

Median
10
10
10
I

MoO*
10
10
10
I
2
NJ
To*aehane
1
1
•
1
1
NH
Z*K
200

.
I
9
Ml

<730
790-9.000
>9.000
>9.000 1
2
NJ

1,200
2.400
-
I
8
CO

1.290
3.329
6.290
I
8
UT

1290
3.323
0.290
I
4
FL

1.800
10.000
10.000
I
7
IA

2.000

1
1
ME

2.000

1
10
OR

2.000

I
I
Rl

2.000

1
3
VA

2.000

1
1
MA

2.900
2.900
2.900
I
3
MO

2.900

I
2
NY

2.900

I
3
PA

2.900

I
1
VT

2.900

1
3
WV

2.900
•

uedan
2.000
2J79
9.929
I

Mod*
2.900
3.339
6.290
¦
-------
TiMt EM. Und • SUU lUgulitlon* For AimmiiI and CwwUltw AppUcilton Hat— Md Variance*
State
Constituent
Limoation (kofttai
Annual Cumutaiive
Basts lot Standard
Variance Alowed
Comments
MO
Alunwtum
10%/yr 4.4800

Case -by-case

ft.
Ankmony
7B4 0

1 Mi
MO
HJ

2 24
112.0
tO** 104
CEC>S
CEC X MAC
EPAM30/9 77404
Writ hwmiw higher rales
Case-by-case
None
Consult Slate lor loading kmts
MO
Baryftum
iniuyr nao

Caseby-case

MA
MO
WV
Boron

USOA Exkanaon

Apphcaaon rate lo avoid loucaty
033 to >37ft Macrange
AK
AL
Alt
A2
CA
CO
a
OA
»
k.
M
KV
LA
MA
MO
Mi
MM
MO
M8
NC
NH
MJ
OH
OK
Oft
PA
M
ac
so
TN
TX
UT

OlM SjO
0-8
80
Oft 84
Oft 60
096 88
500 0 8 0
Oft 84
Oft ftO
22 <*2
105 80
Oft »o
86
Oft 80
04& 8 0
08
048 4 8
ft6
06 ftO
Oft 60
0-81 80
2ft
ft! 112
Oft »o
Oft 60
ftO
04 3.4
1 12
Oft
.46
80
Oft
06
CEC <5
C£C8
CEC<8
C£C<6
CCC s ft
CEC <5
CEC IS
CEC <6
CEC <5
Bafcar 6 Cftanay
CEC < ft. or 1% Zinc
CEC < ft
EPA Bag
CEC <6
fad. Standards
CEC<8.pH»6ft
Man " 20 kftta when CEC > 15
tUa * 20 kQitia whan CCC > IS
Max - 20 Mac when CEC > i&
Man • 20fc©l»awhenCEC»i5
Max - 20 Mac whan CEC > IS
Mai * 20 uac whan CEC > (ft
Mai - aOhgff«ailCEC> ift
W* corurter higher rates
Max ¦ 20 kgffia when CEC > 15
e*cepaon - arwnal teed crop
Mai - 20 when CEC > ift
um * 8 9 Mac when CEC > 5
Mai * 6 fcortie when CEC > IS
Mai - 20 Mac when CEC > IS
• 20 Mac when CEC > Ift
Mai * 20 k(^ta when CEC > IS
Mai » 9 Mac when CEC > 15
Variance bom km* not granted
Mai * 17 84 Mac when CEC> IS
CEC »1ft, pH>6 5.20 Mac OK
Ua« . 5 toiac when CCC » IS
Mai * 0 KVac when CCC » 5
Cant kmrt lor anmal toed
Mai • 18 Mac when CEC >16
Loacfcng bmus lor Grade II sludge
for permit by rule
2 n^Ao tor commercial lerUuer
S«ne MMs apply to margwal land
0 S htfha lor lood Cham crops
Al values are mai levels lor grade
2 Mac yr i not on tobacco, lealy or root crop
As CEC rereaaes, up to 20 kgtia at CCC > 15
Cadmium <8
40 CCR 257. 3 5. 3 6
-------
TMt £(•]. Land ApptttH'f' - Sw lUgulHtOM Fot Annual and Cumulative Application Rat— md Vittoncw (conliniwa)

Limitation

State
Constituent
Annual
Cumulative
Basis lor Standard
Variance Allowed
Comments
VA
VI
IMA
Wl
WY
Cadmun (art)
05
OS
05
2ft
56
50
50
58
CEC < 5, USOA-
Be«sv*e
Sari Type Loamy Sand
CEC <5. EPA
pH>6 5. CEC <6
CEC
Mai » 9 *Vac when CEC >15
20 ItVac ¦ day soris
Vat lor animal teed use. pH
Ma> « 20 kQtha when CEC> is
Man » 20 Ib/BC when CEC > IS
Agronomic rale, nitrogen, metal kmus, CEC.
sari pH, sludge pH. lot at caniamnanis
10 bac • line loams
It CEC ¦ 5-15, max ¦ lOkgfta
Range (ram 0 5 la 20 MVac
«.
MO
Ml
Chamum
4U
10%/yr
§ 1
Hexavaient
CEC <5
CECxMAE
Trnraient vs Hexawalani
Mai - 2.250 kgrtta when CEC > 15
Hex"493 kg"**. Tn-3.920 k^wcuta
(49 ft 96 Annual)
Hexavalent vs Tnvateru not
Const* Slate lor laatkig fcmris
IA
MJ
ME
NH
NV
PA
VJ

44.3
20%
07 2
250.0
140J>
uu
3304
<400
EP 430/8 77 004
CEC<5
CEC< 5
Agnc. tod group ' 3
Sari type - loamy sand
None
Man • 1,000 kg/lta when CEC >15
Max - 500 lUac when CEC > 15
500 k&Ua lot Ague group 4 10
500 Mac - clay soils
250 tt/ac • line loains

Aft
A2
CA
CO
Ft
OA
*
' to
ft.
M
KV
LA
MA
MO

14 0
8.0
« ^ V « m y» « « # «
&S&8383!. StS&KfcS
eoooooo eooeoo
CEC<5
CEC <5
CEC <5
Of ado II
CEC <5
CEC <6
CEC <6
CEC>5
CEC <5
CEC <5
CEC<5
CEC <5
CEC*S
Max - 500 Mac when CEC >15
Mai * 500 fc15
Um - 500 &ac when CEC > 15
Mam - 500 ktfha when CEC > 15
ua. m soOkiS
WJ consider tagher rales
Max - 500 kgAw when CEC >15
a 500 ttfac when CEC > 15
• 500 &tc when CEC > IS
CEC>5 - 250ttfac
um • 250 tuac when CEC > 5
Orade 1 bntied by Nitrogen content
250
Znc kmt, no nd. source allowed corn
war » 2.000 ppm
ME
Ml
MN
MO
MS
MC
NH
NJ
NV
OH
OR
PA
RJ

10%/yt
20%
160
t250
1400
140 0
I2S0
14005
1400
2300
•40
1400
1250
134 0
1400
CEC <5
CEC m MAE
CEC 15
Mai - 500 ttyac w»*»n CEC > 15
Max • 560 kf^ta at CEC > 15
Max * 500 tyac when CEC > 2S0
Mu - 500 Mia (560 kgrtta) wten
CEC >15
yj. . 500 ttac when CEC> 15
Vwiwtce h(vn html not granted
125 htfta to tot group *¦ >0
Max - 500 Uac when CEC > 15
uj. • soo when CEC >15
Max - SCO mO* CEC > 15
Max ¦ 281 kg/tia tar airports, Lfs, parts
Var it ^ organic carbon commit I 6 4 B. >* 8
-------
TiM E4-2. 1 fif - Stat* RiqiiIiikim for Annul wfl Cumulative Appliatlon BUM and VmUbcm (continued)

Limitation
(kurtia)

State
COfUhtuOOl
Annual
Cumulaawo
Basts lot Standard
Vananee Allowed
Comments
SO
80
TM
UT
VA
VT
WA
Wt
WY
Coppw (COM)
140 0
1400
1250
1400
I2&0
1400
ISCjO
IMA
MO^O
CEC <5
CEC<5
C£C<5
CEC <5
CEC <5
Sort type - loamy sand
BMP Manual
CEC <5
CEC
Mai • 250 Mac when CEC >5
Mai - 500 tyac when CEC > ts
Mai • *46 ttfac when CEC > 15
Mai - 500 la/ac when CEC > 15
Mai » 445 tVac when CEC > 15
Mai » 500 ttfac - day aote
Mai - SOOkQfta wtenCEC> IS
Mai - 500fcoi5
CEC 2000 X5
Grade U1 3,125 mgfkg
250 tvac - hne loam*
II CEC - 10-15. Mai 250 hglha
Range Irom 1 25 to 500 Uk
MO
(koun
10%V
(MM02

Sari not >00003 ppm

MO
Fbn*
10%/yr MM

Cam fty-caae

AR
AZ
CA
CO
fL
OA
O
«.
M
KY
LA
MA
MO
Mi
Ml
MN
MO
MS
NC
) NH
Mi
I MY
OH
OR
PA
M
SC
SO
TM
TK
UT
VA
VT
UK
60.0
10%/yi
1120
20%
•7 0
M0
oooo
MObO
400.0
MOO
MOO
5000
5000
1.1200
5000
5000
5600
500 0
5M0
5000
5600
5M0
5000
M0.19
560.0
11200
337 0
560 0
5000
3M0
5600
5600
5600
5000
704 0
2800
5000
2000
CEC <5
CEC<5
CEC <5
CEC <5
CEC <5
C£C<5
CEC >5
C£C<5
CEC <5
CEC <5
CEC <5
CEC <5
CEC <6
CECkMAF
CEC <5
CEC <5
CEC<5 (USOA/SCS)
CEC <5
CEC <5
03 EPA PAD 4QCFR257
Agnc. group t-3
CEC>15. <5.pHl6 5
CEC<5
B*a» & Chaney
CEC <5
CEC<5
CEC <5
CEC <5
Ptotaci lood cropa
CEC <5
CEC<5
Sod type - loamy sand
Mai - 2.000 vac whan CEC >15
Mai - 800 fcgftia whan CEC > 5
Mai - 2.000 Wac whan CEC >15
Mai - 2.000 t*« whan CEC > 15
Mai - 2.000 kg/ha rf CEC > 15
WA consider higher rates
Mai - 2.000 kQffta whan CEC >15
Mai • 2.000 tttc when CEC > IS
Mai - 2.000 ttac when CEC > IS
CEC >5 - 6001Vac
Mai » 1.000 fe/ac whan CEC >5
Mai • 2.000 Mac when CEC > 15
Bated on oomammaw tov«
Mai • 2.000 tvac when CEC > 15
Mai - 2.250 kgAta when CEC > is
Mai • 2.000 turn: whan CEC > 15
Mai - 2.000 tyac (2240 kgAta) Mien
CEC >15
Mai - 2.000 fete: whan CEC > 15
Vviwct fcom hM noi granted
pHx65
Mai " 2.000 kfytia when CEC > 15
unr m | ooo Mac whan CEC > 5
Mai • 2.000 tvac when CEC > 15
Mai ¦ 1.782 ttfac when CEC > 15
Mat • 2.000 tyac when CEC >15
Mai - I.7M Vac when CEC>15
Mai » 712 fcfac - day
Not to BOO kg/ha tor lood chain crops
AtnoluiamaA • ?15 ta/ac
Mai- 1.123 kfl^akv airports. Lfs. paito
Var d soi org&uc carbon content 16 4 a. >*8
714 tyac kieune ma* lor truweg apfAcaK*
A#*es lo arwnal teedmg 8,033
40 CFR 257. 3 5. 3 6
Grade Ul mai - 500 mQAO
356 tyac - Ima loams
-------
T«M| tH. Land AppMcatton • Sw W»flul«iton» for Annual »nd Cumulative Application Him and Vinmcw (continued)
Stale
Oontiuuonl
Limtalion
1^1
Annual
CwikilM
Oasis lor Standard
Variance Allowed
Comments
WA
Wt
WY
(cony
5000
500.0
560.0
BMP
CEC <5
cec
2,000 kftitia when CEC >15
2.000 kgfoa when CEC > IS
CEC 200 > 15
It CEC »10-15. max- ISOOkgfta
Range iram 500 to 2.000 (Vac
MO
Uhum
H.2
Case-by-case
Apphcaton tate to avoid luoy
MO
I0%*r
ifi0*A
EPA Loadnga. CEC>5
Case-bycase
MO
MH
NJ
PA
N
SO
VT
? JU
tu
022
OM
56
CEC >5
CEC<5
EPA 430W-77-004
EP Toxicity
Sari type - loamy sand
Wi conadei itgm tales
Max • 2.000 KVac when CEC > 15
Nona
Max • 20 KVac lot clay sots
Consult Agency
Apphcation rate to avoid toxicity
For animal leedmg e»ea#
10 Itvac fcne loams
MO
Matyooenum
)0%/yr
B0
Case-by-case
Consult Agency to loadug imw
AA
A2
CA
CO
tt.
OA
IA
O
tL
M
KV
LA
MA
MO
MO
MS
NC
MH
NJ
NV
OH
56
6 06
tOWyr
20%
500
560
500
560
1260
500
500
1120
1250
500
560
560
1400
900
560
1400
1250
5602
560
2600
340
1400
CEC <5
CEC<5
CEC <5
CEC <5
CEC <5
CEC<»
CEC >5
CEC<5
CEC <5
C£C<6
CEC <5
CEC<5
CEC <5
CEC mMAF
CEC <5
CEC<5
CEC < 5 (USOA/SCS)
CEC <5
CEC<5
83 EPA P6D 40CEH257
Agrc group 1 5
CEC <5
200 kQftta when CEC > 15
> 200 Uac whan CEC > 15
200 ktfha whan CEC > t5
• 200 hue whan CEC > 15
Mai * ZOO kgAta when CEC > 15
Max - 200 kotia •* CEC > 15
W4 conatfar rxflhai rales
m 300 k^toa whan CEC > 5
• 200 KMC whan CEC > 15
> 200 ttac *tan CEC >15
CEC >5 • 100 tuac
• 2S0 fc«c when CEC > 5
u». m 200 ktftil *hen CEC > 15
Max " 200 n/ac when CEC > 15
Max • 560 kflitva when CEC » 15
Max • 200 ID/ac when CEC >15
« 200 k(^ha xrtienCEC > 15
Max - 200 BVac when CEC > 15
Variances bun hot are not granted
50 k^Aia kar AS grot4> #4-10
Max • SOQ b/sc whan CEC > 15. pH t o 5
Mdi' 168 kurtw tor *rp«*i. &*• Pa,ks
-------
((-]. Land Application - StM* Baflmauona For Annul Md Cunwliiwi Application Rim wd VwIiikm (cowtnuM)
State
Constituent
Ljnjiajionj^igfria^
Annual
Cumulative
Baas lor Standard
Variance Allowed
Comments
on
PA
w
sc
so
TM
UT
VA
VT
MA
Wl
WV
<00nt)
6 7
500
340
960
1400
960
900
SIjO
n«
CEC <6
Baker A Chaney
CEC <5
C£C<5
CEC <5
CEC IS
Ua* - 200 Ib/ac il CEC > tS
' 250 tVac when CEC >5
200 Mac when CEC > is
Max • 178 twac when CEC >19
200 ttac when CEC > 15
178 Mac when CEC >15
Max - 200 mix ¦ day sate
205 tgffla when CEC > 15
200 ktftia when CEC > 15
Max - 200 k 15
Var il organc carbon content 1 6-4 a, >4 8
Grade 111 Max - 1.250 mgftg
100 Ibrac - tma loams
II CEC - 10-15. Mai - ISO ktfha
Range fcom SO to 200 tVac
AZ
H
OA
IA
ft.
M
MA
ME
NC
OH
MS
»MinytKM<
96041
200
Agranomc rate
Agranomc rata
Agronomc rata
Agranomc rata
Agranomc rata
Agranomc rata
Agronomic rata
Agranomc rata
Agranomc rata
Agranomc rata
Agranomc rata
Agranomc rata
Agranomc rata
Agranomc rata
N most hkety kmtmg lacior
Agranomc rata
Crapnaada
Agronomic rata
Crapnaada
Agranomc rata
Sot tatfuraMQaiabon cover
Orada I or u sludge kmiad by nitrogen content
10% on dry wl basis
Agronomic rate
Agronomc rata
Agronomic rale
Loadings cannot exceed crop needs
Cannot exceed crop needs
Most l*aly kmtng factor on annual basis
Agranomc rale
100% ot crop requirement lor morQanc N
Ay
-------
Tatote £1-2 land ApptcWKin • Sun Btgulitiont for Annual and CumtilaUv* Application lUw and VwUwcw (coniwud)

Limitation

State
ConsUueni
Annual
CumUabve
Basis lor Standard
Variance Allowed
Comments
Wl
NJ
PnanoK
•
NJ merfcan sludge qu

Case-by-case
Rel from SmQh. A. Chase. H P & Maris, H L
CO
IA
IL
MN
pkmimim
4480
4480
44*0
Avatatte Pdsal
Agronomc rate
Sandy sola
So4 aikiciatito P
800 ItVac non :«jndy sods
6 8% on dry wl bata
IA
a.

-
Agronomc iata

0 8% on dry wl baaa
Case-by-casa
*.
Ml
MO
WY

10%/p
as*
1/4
CEC>S
CEC* MAE
USOA Extension
W* oormdar tkgher rates
Caae-by case
Case by case
Consul) Stale lor toackng Wrma
Range Irom 0 I 10 0 S Ryac
IL
Saw
ZOOjQ

AX
iA
Tom PCS*
¦
-

II rcorporaied
NoPCBs n waste stream
MA
Mi
MN
MO
MS
MY
At
SO
Wl

iovjv
22
1 1
Recommended
RCRA
ManaganiaM plan J
PCS > so
10 n^fcg must be incorporated immettaiely
Case -by-case
> to mgrtig il incorporated
EPA approval * PCS > SO mgdg only
Consult Slate lor loading limits
Regulatory
Also tOppm
Dry Weight
Animal toed related
Utcorp d> 10 mytg on dairy grazmg land
1 ah
I AZ
CA
CO
a
OA
IA
0
L
04
KV
LA
MA
Znc
29 0
17ft
004000 oooooo
C£C<5
CECS
CEC <5
cec<6
CEC <5
CEC <5
Ma* " 1,000 k|yha when CEC >15
Max • 1,000 li^ha when C£C > IS
Max " 1,000 k^ytia when CEC > IS
Max • 1.000 brae whan CEC > l S
Max " 1.000 k<)Aia when CEC > IS
Max " 1,000 k^Tia when CEC > IS
W4 consttef higher fates
Max » • .000 k{yft4 when CEC » 15
ui. » 1,000 kmc when CEC >15
Max • 1.000 kg*>a when CEC > IS
cec>s - soo «vac

-------
E8-2. » AffNcillon - SUM lUflulaliona For Antwl am) Cnwutottw tppllciiion (tot— iwd Vartanca* (continiwdl
Svatfi
Conswueni
Lirnaahon (kg/ha)
Annual
Cumulative
Basts lor Standard
2800
' CEC <6
28041
CEC <6
.
CECxMAF
2800
¦CEC <5
280.0
CEC <5
250-0
CEC < 5 (USOA/SCS)
2*0.1
CEC <5
MOO
CEC<5
680-0
83 EPA PAD 40CFR257
16M
Agnc. tot group 13
280it
CEC«6.pHlfi&
290.0
CEC <5
IMA
Baker 4 Chaney
2804
CEC <5
280.0
CEC <5
280.0
CEC <5
260-0
CEC <9
2800
CEC<&
2500
CEC <5
2800
Soriiype • loamy sand
290.0
BMP Manual
290 0
CEC <5
280 0
CEC
Variance Allowed
Comments
MO
ME
MO
MS
NC
NV
OH
OA
PA
M
SC
SO
TN
UT
VA
VT
WA
Wt
Zmc (oont)
Man
imwyf
U4
* S00 Uac when CEC > IS
1.000 kgfta when CEC >15
1.000 ttfac when CEC > 15
Max - 1.120 kgfta mitten CEC > 15
' 1,000 itfac whan CEC > IS
1,000 IVac (1120 ko/ha) when
CEC >15
Mm - 1.000 fctac when CEC >15
SOOktftalorAg group 4-10
290 kgftia lor Ag group 4-10
Max - 1^000 twacwtton CEC > IS
pHc65
Mai - 1.000fcgAtawhenCEC>15
Mai " 1.000 IWac when CEC >15
Max - 900 »Wac when CEC > 5
Mai - i.OOOWac when CEC >15
Mat ¦ SSI «yac when CEC > 15
Mai • 1.000 iirac wtian CEC >15
Max ¦ 880iVacwhenCEC>l5
Max - 1.000 • clay sorts
Max • 1,000 li^ha whan CEC >15
Max " 1,000 fcgrtta whan CEC > 15
II CEC *10-15. Zn 5 500 koAa
1.000 KVac when CEC > 15
Var lor corn level • 4,000 ppm
Variances bom knui are no( granted
Max - 581 kgrtva tor a« ports, lanOtta. parts
Var 4 organic carbon content 16-4 8, >4 8
Class Ul max - 6,250 mgfcg
SOU KVac - line loan is
Range Itom 250 io 1.000 mac
-------
Table Eft-3.
Land AppilcaUow • Site Spactltc Conldfattona
State
Sol Type
Slope/Grade
Deptfi 10
Ground
Watorrttodrnrt
flunolt
Control
Sae
Development
Plan
Distance 10
Surface
Water
Floodptain
Rasuioons
Distance
to Wats
Neatest
Oweftng
Butter Zones
6 ft lo ground
Yes
MwMbe
IM
fi ft mm lo
ground water
Ye#
100 II mm
Anton*
Sal must tw
anatynd
tmMtif bafcxo
*•%
Moappfacabon
•Mt mean
annual ground
24-fir - 25-y»
storm
Cannot have
washout ai
Approval by
local toodptam
adfimst/ator
needed
Water wef -
250 ft raqured
Uun wei -
1000 tl
500 It
2S ttlo pufahc
road
25 It to
properly kne
Chock
Yes
Yes
Yes
Yes
Yes - deptt to
ground
Ye*
Musi not
run oM wib
3*10
ground
500(1
50 CI to stream
bed lor Class I
recreation
waters
I mi to pubkc
water supply
¦uafce
Yes
kfctv 3 It Irom
annual hgh
ground-water
tMtS. 20
mranuntar
UuSt
determine soi
type, ground-
50 h rf surface
Muted. 25 n *
sutwmrtanw
Fkmda
2ft<*
1%
2IU
Yes
Yes
wot
3.000 It to
Class l
ZOOntoomer
waters
IO-y«. 1-hr
event
300 It lor
shallow,
private wells
50011 lor
pubkc water
supply wens
300 II (except
tor composted/
processed
sludge)
-------
TOO E*-V Land ApfHcMln* ¦ Sto Sprite Conatdftftona (coBtemd)
State
Sod Type
Slopa/Grade
Dapii 10
Ground
WatwAadroch
Runofl
Control
Site
Development
Plan
Distance lo
Swrtaoe
Water
Fkoodptam
Rastnckons
Oisiance
10 Watts
Nearest
Dwelkng
Bufler Zones
Surface
<5% tfapa,
tnoorporaaon
- >»%«(•
tin
ground
Yes
100 h
1.000 ft lor
spray
apphcatoons
Yes
1000 ft lor
water.
500 II lot
private water
900 A
(incorporation)
1.000 II
tspiath ptatei
4 tawv la
Yea
300 <1
No apphcabon
wiftn 10 yi
1.000 ft-
pufikc
500 n private
300 It
Mkumad
<•%
UvriMB*"
Mllftvauid
Yes
naqwMon •
«»%
Sota*- <•%
For
reclamation
projects
200-1,000 H
No apptacaaon
to 10-yr
loodptatf
200 II
depemkig on
geology and
type ol wett.
streams, or
waterways
2oi. ooo n
dependbngon
metnodol
rata* vary by
CeO range,
owl 20-n
id
<8%. untMt
runoN oonkol
auto
ground
4 ImndipO
300 h unless
runoioonaoi
300 A unless
njnoD control
200 n mm
soon
Apply or* »
S% ma* wtoan
gpouidMfcOMn
or
Yes
son
10 yr
Boodpiam
incorporaaon
requred
Downgradtfinl
(200 HI Worn
SW. men
mpctador
surface- appbed
200 n
10 ft to ground
250-1.000 ft
250-1.000 II
Not m 10-yt
250-1.000 ft
ground
75%
vegeiatme
cowma
Of
incorporate
100 H Irom
perimeter ol
land
appkcaaon site
30-1001! 10
road
30 100 It lo
properly hie
280 1.000 II K>
a anhhoie
-------
TMM Et-3
Land AfiptcMKm - Stw Sptolw
ConwtorMiOM
(continued)
Sum
Soi Type

Oepftt 10
Ground
Waw«edrocfc
Runotl
Caobol
Site
Development
Plan
Distance to
Surface
Water
Ftoodpiam
Restrictions
Distance
lo Wefts
Nearest Dweihnu
Bufte< Zones
Control to
prevent
•Satodaptr
logiiMid
Closure plan
requred
UMwmtym
Ikt oi 20 to
Avoid afifi-
hcfluon
Anngran
Sue analysis.
aod analysis,
topograph
map. laofely
des«n. dudoe
analysis,
management
plan
Oramaoe
gulhes 25 It
Ponds,
streams, takes
- 300 ft
Inter rratent
SOU
Case by-case
300 ft
300 ft
Maryiand
IS*
lor
2 M10 ground
Contour
pfcHMOQ J
required
outcrop;
SOftlor
surface appl.
2S ft tor
90(1 ¦ surtace
appl.
26 ft
subsuftaco
anri .
15 fl 10
drartaQO duch,
surface appl.
10 ft to
drMUQO dktdi.
strfMurlaca
appl
too It-
pmaMa
25 ft
nonpotable
200 (I ¦ occupied
oflsde surtace
ftppl ,
100 n - occ4>p«art
subsurtace
appl.
100 (I - ocnyiert
onsita surtace
apt*.
SOU ¦ oocupiail
ortsda vrfvjurtara
appi
25 ft la ioad
and 50 It to
property kne
lor subsurtace
afyl (
15 It to ioad
and 25 It to
proparty Ime
lor sifyjurtara
appi
AntfyeM requred
to, Type Hand Ml
sand.
190ft
>30 at bom
0 12%
SO ft - mtecaon
<200
P
300 ft lor Type
U car IU (studo*
septaoe)
2.500 ft lor
pubtc water
supply wefts
150 ft
surface and
v^acfcon
500 ft - suilaoe
appl.
100 ft - section.
300 H to eju&tmg
150 A to
property ina
tar surface
appl-.
25ii»
property kne
lor inaction
-------
Tim em
Land Application - Stta Specific Constdarattorn (continued)
Sum
Sod Type
Slopa/Giade
Oopth ia
Qround
WanrAadrack
ftunofl
Control
Site
Oevtitoprnenl
Ptan
Distance lo
Surface
Water
Ftoodptam
Rasirdans
Distance
lo Walls
Neatest
Owelng
Butler Zones
Notonorganc
aoMpeau*rt>
sutoeurtaoe
dri
6% • ourtaoe
ud.
12% -aub-
•utiacaappi
Achy.mn'
pondmQ-
Noi lot land
At least 3 ft trom
waonal high water
(able, at toast 6 N
fcem bedrock.
Noappkcabon
badrock has
or crack*
6 Hot
•uriace
Must (ACtlldO
sde diaract-
eruakon, site
management
ioo n
ir>tetm»aam
streams,
600 h -
200 A - rivers
dapendrtg on
sod type and
fame ot year
200 a - private
i.ooo n
<02 n*v or
>6 «wiv
•wougAout
Rptk
60011
trom
re&danli^
or
recreabon
el area
2000
Irom
habuafcort
100114
i«ecW

Maa. •%
Ala
hDh
Yes. no^fH.
on lamm
ground
Yes
No appfacaimn
on 100-yr
•oudpiam
soon
ISO II10
adpnng
property
2 m lo airport,
SO II to
piapeny kne
for
7 12%
ayacMnonly
>12% *
managed
Avoid
7AIMM
in
potenaal karat
regaone and atw
baduredi
Ttacfc stand*
gra*araqM*ad
motskjre
taghteapect
ram
PanolNPOES
perrrat
OotMert plan 4
> 10 dry IV
generated (500
PE)
25 n
dramaoe ducn
SO 300II
stream
(depends on
stream
ciasaAcaaon)
Case-by-case
150-300 ft.
depends on
geology and
we*
conatrucfcon
Case-by-
case
ROMbation.
protect
stthtales.
dramooufse,
pond.
50-300 H
butler /one
In 10-yr
trmrtptan.
Mfaction or
noorporaaon
raqpred
200 ft mm
Recommend
500 ft to
private weBs.
1.000 II to
put*c water
supply<
soon
MM. 2 ¦ Ol
Ma 2 M io
labia
Max Aftiobadrw*
(HUlair
uHMatt
Yea. wuft
apptcatoonlor
perm* Teat
pits, crape, etc
Closure plan
atao (aguned
100 ft
surface appL.
SO li -
mcorporatad
protaMed
Munapal wet
- 1.000 II
Prwaie we* -
300ft
Community
we> soon
100 n to road
AppL ratas IS
dry l/ac/yi near
ItglMrays
50(110
property kne
-------
TlUt Ek-3 Land Appfcratiort - S*f Specilic ConatdaraUOn» (continued)
Sims
Sod Type

Depm to
Ground
WatarAedroc*
Runoff
Control
Sue
Development
Plan
Distance to
Surface
Water
Ftoodptain
Resmcums
Distance
to Weds
Nearest
Dweamg
BuIIm Zones
Mow J«Hy
Ym

Yea
Yes
200 ft

300 ft
1500 h bom
pubkc water
suppty

1,500 Hiram
pubtc water
(UDntv
• tl
New York
Ym

Mmv 2 ttto
bodrocfc
Rsqurad
Same day
ocorporat
onntoul
Include oops lo
be grown, appt
and fwvesi
actiedute
Topo maps
200 n
No appltcaiton
aoodpiams
20011
SOOIl
200II10
pottblawel
SOOtl to
property fane
Mortt
CMtM
SolMkiiHn
till 10% wMA
fcU»10% whan
MnSMMo
When
aurtace
mc.
required
M»«24
IM
LMMiad
appfecaaon
during
inctement
waatier.
ie. do not
aw*y 24
hra altar
1/2*
rarta*
Provide
descr*>bon
w/appkcaaon
Agronomist's
recommendation
legantngcnw
cap Chack
auaatofctyoi
appt rales

Apptcauon
«wt*n 100-yr
floodptom
proMMed
10011
400 ft wften
sudace
200 ft whan sub-
syfUnl
100 ft to
property kne.
100 ft to any
drainage
ways it
surface
apphedor SO
Itit
subsurface
Om
UnutoMby
•orfiype
Afft*caaon^
>12%
piflhMHt
• 12% 480%
JXMMlwfl
iHQHtnn rif
««acMn uMd
15 adepenckno
on amount
appeadand
percoiaaon rate
Am* protWMftil
where bedroc*
Olhm
lurtexdeptito
wioniiyhgn
OW ia 2-3 •
dapandmgan
tiniiaati*iy.
MP* to perched
waiaiiaNa *' "
* depend** on
amount apphed
and dr«n«0e
Yea
Yea
26 100 II (0
It w4t barrier)
dapendmgan
applend
type at water
Profttoued n
areas «(m
10-yr lood
elevaaon wrihn
2 mo ot
S68S0n3l
200-30011
100 300«
dependng on
sludge type and
apphc rale

-------
Tato» tt-1 Land Application • Sw Spacihc Conaldafatlona (comirmad)
State
Sot Type
Slope/Grade
Depth to
Qtound
WaterAedrock
Runoff
Control
Site
Devetapmeril
Plan
Distance to
Surface
Water
Floodplam
Retmckmt
Distance
to Wets
Nearest
Dwefcng
Butler Zones
OUtam

6%
10% tor
rtn matured. (fcrect
moorpmaon or
2ftto
seasonal high
wale* lafeto

100 ft
Protection Irani
wastmiii ii
within 100-yr
Moodptan U
Level U slurry,
must apply
betore rainy
season
250 ft

Distance to
tarpon runway.
10.000-pi
5400-pop
Oragon
24 n roomg
dapfti
SUMkMuat noi
I2%ta)u*l
•iudoa. feata aa*
ap»a«i inwn
dry. wonporMMl
fcqud dudo up to
30%onwa«-
dravMd waalam
OMgoniM
niumMM
l ft to lamp.
4«tO
Where
needed

son
Re&uicted
apphcaum
pared
Soi
incorporated
AmmI area
200 II
0 It - injected,
0-50 ft ttucfc
spread;
300-500 n -
«ngabon,
sofcd wasta
rags. 0 25 mi d
urtpasted and
UMweorpor alert
wMhm S days

PA
ftanga kom
•and* loam to
a* loam
15%. aoma
lor
20 «l to
seasonal togh
water lattfs or
4kiopMa
2ft ft to
Urw
««*«»
guanWy to
prewar*
runoft. larm
coneerva
ton plan

100 ft.
300 it to water
MW
Not apphed id
areas subject
to loodmg
iooo n
upgratfcant
Irom surface
water aouroe
300 k
50 It 10
property kne

outcrop

rn>«
Vm
N >3% reguva
aroauo oonkd
# /
t.6 a
Max. aori
toaa <3
T/ac
Ye* delated
Me. sate.
anaiyM.
oparaang pan
Closure plan
atao.
200 A and not
«i water supply
water tfxxl
100 yr
Moodplarfi
1,000 ft-
pubhc wells
and not *i
recharge area
oi pubfcc water
supply we*

Soutt
Caaaftna
Ctay »•%
up to 20 •)
aandyaais
•% urtfaaa
roorporaMd -
twn 12% OK
3ft. A«Od
tacharg* areas
for
defeated
mentoring,
bvitng
200 h

10011
500 n ii
odorous, 1,000
tl or unacted
100 It 10
property kne
-------
TaMa Eft-3.
Land Application - SWa Spaclltc CoMmmUM (continued)
Sute
Sol Type
SlopesQrade
Depth lo
Ground
WaterAtedrock
Runofl
Control
Site
Development
Plan
Distance to
Surface
Water
Floodpftam
Restrictions
Distance
id Wets
Neatest
Dwekng
Bullet Zones
Sout)
Noorganc
ao2lhck.
fHSt
300 N ¦
private.
500 h
schools,
institutions
300 it
i.ooo it -
rofetuiions
SO tl 10
property
boundary
Background
analysis
kUi 12%
frozen ground
ouu 6%
S*
200 ltd
tawicarporaied
50 ltd
¦tcorporated
30011
Vermont
Anatyiad lor
pM.P.K.MQ
Surf appi s%
Incorporate mo
mi up k> 1S%
prorated at
Ciaaa l or 2
100 Ii
Pernruied in
Noodpiam but
must be
incorporated
aMhm 4at*
300 ft to
drinking water
source
SO flk> load
sonto
property kne
<«Mh)
so It tt road
200 It burnt
toon
Not toaioaad
12%
100 yr
unless site
protected
vagna
< 16% unless
roorporatad
¦atwi 24 hr
20% d shrdga is
18% soads
-------
Tatoto EM.
Cud Appttcattoo - sa» SpucUte ConatdTaiiona (continued)
Sum
So* Type
SlopetfGiade
Oepti to
Onunt
Watei&ockock
Runofl
Control
Site
Development
Plan
Distance to
Surface
Water
Floodptam
Reslnckons
Distance
to Wats
Nearest
Owelbno
Butler 2ones
Waoonw
PormoataMy
MM. >6 MM
pWftlWK)
12% Mi U)ud
riudQS.e-12%
tapci). C*a
6 13%
3 ft man to
groundwater
or bedrock
Prevention
c— by
12% <
100 tl kom
&u earns. ponds
and
channeled
watarways, SO
flrf
mcorporatad.
25 R trom
or dry
run
ProMkUxi
200 It-pnwale.
1.000 ft-pufchc
0 25 n»200fl
incorporated,
SOOn-Guft
appt (toss il
owner agrees)
at:
••12%
Qui 1
NO
4 Mops >fl%and
wtta*M">2%
untoMpnot
•flpniMi
obund Mo
landaprMAng on
>12%

RunoM
control ptan
raqured
Yea. abo
weeataton
management
plan
-------
Tawa EH. land Appacaflon • Monttortnq and Bapocitng
Sttta
flaporwg
Paqwramams
Plant
Sampling/Crop
Monitoring
Soil Samphngf
Monitoring
Ground-
wjw
Monitor**}
Surfaca
water
MoniUnng
Alabama
Yea
Alaska
Per permrt
Per permit
Arizona
Anafyw must 00
done 1 mo pnqrto
appfceanon • most
contaminants
Montniy report of
record of applications
at eacft sta (quality
and quantity)
Fields sampled pnor
to appftcaaon
if sludge applied
lass man *01 to
ground water.
Madam the
vienrty of tna
Mds ara sam-
pled at 9-mo
intervale tar
maun total
coWcrm and
nitraaa. Not
raquvad >' sludge
aootmd m
accordance
sludge
gwdeimae.
Arkansas
Y« ¦ preapofacanon
Pmappfccaaon and
annual mormonng
California
Cd.Ptt.Zn.Cu.N4,
PCS. Tow N.
sohda. Frequency
dependant on sm ol
treatment iMnt
Analyses, opersang
rooofd
Colorado
Total N. organs N.
NH*. NO], oM, K,
conductivity. Ar, A(,
Cd. Cr, etc.
Morwonng results
every « mo. Amount
appfaad and
tocaaona.
Plant tissue
montonng
fdemrfy annual
h^n ground
r rf

quaMy standards
vioiaaona
Georgia
Annua* tar «H%
vol naoMfcPliCd
Caae-oy-caae
idano
PC8.P.C4CU.N1.
Zn
Amount,
CftanQM A
quaMy. ua* at
loop*
Starvxafy tor
IdtmQpmeaMt
n. imm,
. PK
during protect He
N. mean
OH,
% scant, vet
venom
Montwy w annual
reports daparvtnQ
on plant sua
reqwred
CfC-5-tM
pH»«.Soruae
hlayba
plant sua Jesanwnaa
frequency (mortWy-
annual)
6 moand 1 yr i
-------
TaMa EK Land Appicadon • Monitoring and Raporting (contmuad)
Stm
Skjdga
Monnrng
Raporong
Aaqwemana
Plant
SampfcngfCrao
Monitoring
Sail Samgiiny
Monitor ng
Ground-
water
Monitonng
Surface 1
Wanr 1
Monitonng 1
Indiana
% jotda nh«, NOj,
Tot* N. P. K. Pb.
Zn.Cu.Cd.Ni.
PC0a
Annual raport of
weekly application
rataa and sta
conch boos

Pra-appHcaoan,
annual it pH < 8 3

low*
N. P. K. Aj. CO. Cr.
Cu.Hg.Ni.Pb.Zfl
Long-range plan
required

Kanaaa
Cd.Cu.Pb.Ni.Zn.
Cr.Aa.ScP

May be raqutrad

Kannxky
POTW< 1 mgd •
ivyr
P0TW»1 and <3
mgd - 2vyr
PQTW>2 and <10
mgd • **/yr
POTW»10 mgd -
ivmo
Oaadraeord-
raganfengCd
appieaiion
Annual report of al
recorda

Annual mcnucrmg
Qaoiogcal data
uaaaaad;
specific
paramewe
maaaurad
Y9S 1
Louisiana
Semiannual, pH,
CEC, N, salta,
organic mat*.
siudga/Mtfma
Annual (test raaufta).
land area. etc.

Man*
Nutnam* matala,
iwonutnanta.
others (N> iniW
Quanarty dxxon
tasting during flr*
yaar tor POTWt
>25 mgd. POTWa
raqwrad lo anact
individual pratraai-
mant program,
POTWa comareng
pulp, paoar. unnary,
tarta-raiaiad addna
td waanwatar rnouti
MomNy, quarterly. or
yaarty. Analyst. J*ne
added, dtatneuton.
ate.
Analyewol
plant taaua
may o*
raquvad lor
soma staa
Ana^M tor
background level of
Cd, Cr, Pb, Hg. *,
Zn. Standard m
taet betare each
apply, afton

29 ft to property I
knee andpubkc 1
roada 1
Maryland.
At rwadad. Alao
praappteaaon (%
sofada). oH, N.
ammonia. mil an.
matatt, PCS, me.
Amount, wfcara
appM. amours ol
km*. Aa raqurtd.

Aaraqund
Aaraowrad I
M(M-
CtUMQS
1-4 mo mariaia
NuflMa^i%
PCScbMdon
wMMIfll
MW».
momohng Ijf
organca raqund
AnnuA not tar Typa
I iudgfcMudeod
notot • Typo h and
i« «udgwaaptag»

vaa • P, CdL Cr, Cu.
Pb, ffc, Hg, Zn, PCS
Oaonmay
raqua*
monrtonng

Mdkgan
inufcaoui
nutnandmMMi
otMrtma
Pdla«Hjo MHd on
outfty. uat
'MonWy • by
ffwnapMy; Judge
quafety, amount
•arokar raourad
Qanara*y no
raqwvd
Amiaiy
No-but
nydralopcti
ibtfymayb*
Notundar
nonnal
caounauncaa
-------
Taaie 68-4. Land Apgioaflon • Manttortwg wd Reporting (continued)
Sta»
Reporting
Requirements
Plant
SafnouoyCroo
Monitoring
Sod Samoh«
mithmho^cm by
Mm ot 9 wefts.
Semiannual
sampfeng unless
facility meets a*
reourements tor
lanospreading
wee
At oiacreoon ot
director
Missuspp
Yes
when Cd not
the man
comamnam
Permanent record of
volume frata) and
location.
Tissue monitonng of
vegetation.
Oeed record •
amount of PCBs and
Cd applied.
Annual soil sampfang
for metals, nutrients
As required
Missoun
Sludge and sod
characteristics, and
volume applied
Daly records: %
solids, volume.
locaoon.
Annual report
Dedicated sites
pH. CEC pnor to
appacanon and
every 4-j yr
Nutrients • annual
uniesa >3 vyr.
OedKatsd sites
Nebraska
Sotds, N. P. metaia.
Za Cd. Ni. Cu. Cr,
ate. Report n
application for maior
facAtiee
Annually at minimum
lor maior facilities
NO
Yea. tor some
facttea. manly tor
Yea, but only
onetaoMy
Nevada
Only regulated m |
somecaaes
New
Hampshire
Nutnents. vOC's. *
sows, pH. metals
> 1 mgd 3 tfyr
< 1 mgd 1 wyr
Case-by-case
Caae-Oy-caae
Yes; pH. hme,
organes
May be reqwred I May be required
New Jersey
Yea
Yae
wnere
maaa
Yea
New Menoo
(ftecfierge plan
nequred
As requred
As requred
New York
Cd.Cu.PtLM.Zn,
PC&MMpn
senea. K, P, pH, Ht
sokda, at voMIe
Annual report
Judge mt gutty
, orop grown.
N. K. P. Ph. Cd. Cu.
Cr. Hg. M. P&. Zn
In
In
Carohna
Sous, metals, N, P.
K. CH. EP. toooty
and vol tor new A
MonWytorvct,
and nutrients
Piter io „
tor pH 4 CSC
Aaraqured
-------
TaW EH Land AppMcaflon • Monitoring and Reporting (continued)
Sta»
Repoiwg
Requrenwnts
Plant
S«nokng/Crae
Monitoring
Sod Samotmg*
Morvtonng
Ground-
water
Monitoring
Oho
Sludge. x* ana OW
& SW runoff may to
required on caae-6y-
caae baau. plant
analyst not
generally requwed
wften arffUptaMe
sludge >• jppMd at
Not generally
required for
acceptable
stuoge appHrt
at agronomc
OH, CEC. metals,
etc.
Yes
quaMy, total appfced
Oregon
Pfc, Zn. Cu, N«. Cd
N (total, NO* NH,).
P, K, pH. XMl
Frequency
dependent on plant
Quantity and lypa -
montwy
OMR rulea requre
penode samptangof
sludge ouaMy
Caae-by-eaae.
Test we*s «rf*re
icpaed «
pH, SOhda, M, P. K.
Cu, Zn, P^ N
Amuafe tfudgattc*
TaattorKpHtej-
75)
tAmf be oqund M«y be reqi*eo |
Texaa
CdC*#fc*Zn.
H.K,
tar
0H.nu-
Eapeoafy at
tang-arm i
met** PCS
tor propoaad (and
apptcaaon uaeac *•
qwee oanflcaaon ol
Mgi management
putte
and M
-------
TatXa Land UppMcrtow • Mcnttorinq and Reporting (continued)
State
Sludge
Momonng
Keoorw}
Requirements
Plant
Sampling/Crap
Monitonng
Sort Sampta"?
Monitonng
Ground-
water
Momomg
Surface
Water
Monitonng
Virginia
Cjmpo—at
an«y«e<*one based
on twaa
Montftty. quarterty. or
annually. deoends on
sue
Yea. for annual
ace»ea&on
pH. metals, CEC.
texture, etc.
YU
Yes. (or annual
aocfccanon and
storage tagocn
Washington
N. metala

WM Vtrgru
At IMA annually

wooonsn
Nearty gverythmg
monnored: lee
comamnanta
-------
Table Eft-6.
l»< AppBcmow • MMiBMma Pcecttcee
Sum
Sludge
OMMMfMtQ
Ptfhogen
Control
Siab*uwm
Incorporation
pH Level
Seasons
Lnws
Loaded
Utms
Crap Use Lams
Oiamg
Reancuons
Access
Control
PFRM»SflP
npca>io
ppm
No contact «m»
lood plants.
A»ori load
chaw crap tof
IB ma
Nogramglor
t ma
Yes • l» 12 mo
>10%
Vanou*
dopamine on
P8MWfflf
Cd cannot
ejicaed 0 5
HWac/yt or 4 &
tvac total.
PCB< 10
mg*g
Access ol
graang animals
connoted lor i
motoiowng
Pubkc access
condoled ior
12 mo toSowmQ
Aaamt
PSfWFW
Not <66
Moan* to
Iroian, snow-
cower ad, or
ground
PfRP lood
Own, dMV
PSAP - pasture
ifKVHlMVt.
non-tood che*
0Mrtac*nr>
AtfcuSI 1066
10% ol
coniammanl
hm«yr
Mas Itydraufec
toadmg 27,000
gaVacSdry
tons/year
Mtrate toadng
lo QW or Cd
uptake or mas
matala -
wtMChewer most
resinowe
Not to be
apt*"** dunng
or precadng
Cannot grow
human-
consumpaon
crape
No hay/gram
harvesangfor
30 days after
apptrawn
May not oe
appfeed dvecHy
onto any
groaang lood
ctun crop
Maynoiplani
lood craps unU
3 yr alter appl
(non-agested
Judge)
Oraang
restnctadlor I
mo altar appi
Fence/signs
requrad
Animals lor
human
consumpaon - i
mo alter appi
Daay carte - >2
mo altar appL
Not alowed tor
carte used to
produce
ur^tasteurued
at*.
PutAc access
restnctadlor 12
mo alter
appkcaaon
Pubkc access
should tie
prevented lor
12 moil
irthantoded
sludQa
-------
[ajjO»E6-5 Land Application • Mnugaimnl Practices (continued)
Sidle
Sludge
Dewwing
Kdihayen
Control
Sludge
SldbUualion
Incorporation
pH Level
Appl restricted
l6%
not aMowed
Loading
Linus
Based on sod
pH and CEC.
lor Cd. Cu.
Pb.Ni. Zn
Ciop Use
UmiU>
Cannot apply lo root
crops or low buits
Grazing aSowed 30
days after appl d
PSRPolPFRP
included.
Granny
Resircuons
No gracing,
lactaimg livestock
unless condrtnns
met
Access
Control
Colorado
Sow#
> 16% dry
WMQtH

Yes

Cannae-
tacul
Vm
Ym

Ottmmmm

PSf¥>4fRP

>6.5 at appl
tone maintained
at >60
Noappbcabon
during ran.
runoN. periods
when ground
saturated,
Iroran, snow-
cowered

No lood crops

ftardt

Septate and
load sorvce
sludge
Snpiago and
lood nran
dudga
No yeofcc
requvemam

< 500 Kvac (6
dry tyi2 iiio
• Grade 1
Meials/N •
Grade II
30 days gracing
60 day human
lood.No root crop,
leal, vegetable or
tobacco

Fur 12 mo -
except lor
pf0C6S60d/
composted
sludge
Oaorg*

PSRP
pur
40CFR257
Yes
On slopes
>&%
40 CFR
Part 257

Metals 40
CFR Part 25/
Total N
No appl lor human
consumption lor 18
mo after application
Animals OK
Grazing OK l
mo aliei appl
Public dCCfiSS
aUowud dtkx
12 mo
HMa

Not lor vegetables
lor human
consumpton

Idaho

Ym
t
Ym
PCfl > 10 ppm
an pattura/
arwnalUnd
Mantam aorf
pH>6 S
Mnfflufl) 20 in
depth o) perm
sort

Sludge must be
Yes

Maintain sot
pH >6 5
Mo appbeabon
to ice or
snow-cower od
land, during
ranlal or on
aaktamri
ground
SjwiiinKi per
site II CEC
< 5. use 1/2
iiKUal taints, at
of btriiM
agronomic N
ft P rale
Land reclamation
protects not lor
truck larmmg Ifutts
aid vegetables

_ _ r

-------
IlMEM
Lend Application • M«niQ«nMnl Practice* (continued)
Stale
Sludge
OMMMnna
Patftogan
Control
Sludge
Statehzafcon
Incorporation
pH Level
Seasonal
Limits
Loadbng
Lams
Crap Use
Lands
Grazing
Bmiiicmiu
Access
Control
PSAP/PfRP
per 40 Cf R
297 3-404
So4pH6S
unless no
tood cham
Appkcaton
proMtted 4 sod
lamp < 32*f Of
moaiure-hakfcno
capattly oicoodfid
No Iroaan ground
appfccaaon unless
<2% slope and
management
practceeare
employed
Dary
grating
proMMed lor
30 days
alter
appfccabon
ponrfvpfnr

WMM4SIV0I
Sod must
be at»awnrt
10 6 5;
Applcahon to
Irozen or snow
covered ground
should be anrfkded
2 tons/acre/yr
N. P. K not to
exceed needs ol
must be
art»BMwl 10
60-7 ft
Only stowed on
<&% slope
No appkcanon to
land lor commercial
production ol lood
crops lor human
coneumpfaon. Not
permood on land
lor commercial
production
PioMttd
lor 2 moruhs
d not
tftcorporaied
Apphcamn n
pari*,
schools, other
pubhc spaces
reQuuas 2 mo
amwft
restnction
So4
pH>6 ft
Hemcuky
VM
PSAP.aae
Yes
Vea. w*nn2
hous lor odor
control
No snows toien
ground apptraaon
NoTSCA
regulaied wastes.
S dry Tiac. 0 5m
atch. N. Cd. PCS
tamang.
No loalftooi crops
lor 12 ma
Sorts vrth Cd tatted
toanmallead
crape. Not near
tobacco, ft yi wait
Pubtc access
flowed after
12 mo
12 mo
wad 1 mo
Food cftam crops
18 mo alter appfc-
mo before
feedmghay
W«wi 3 ft ol
surface
Edtile crops. plant
12 m o altar appl
Grazing wait 1 mo
altar appl
Appl rates based
on agronomic
needs ol plants,
sad fcffttafcorts
Not on Irozen.
snow-covarad. or
uSrtM) ground.
6 5 oi
Yes. except tor
pastures and
PfiflP wAom
AlfcuSl *
Maryland
ttymo.
Daly unless
Pf ftp. odor
control etc
Not on frozen
ground unless
<5% slope and
400 h to weis. Hot
4aoi saturated ar
snow cowered •
cannot ^corporate
Cd.Cu.Ni.Pb.
in. N agronomic
rata, ti/ac depends
onC£C. Nor
t mo giazong
(human use
producwm)
3 yr - dMect human
tood chan unless
PFflP
12 mo unless
pfHP
-------
Tltlt El i
Land - Mwmimih Practice* (continued)
State
now—fig
Pathogen
Control
Stabfczahon
Incorporation
pH Level
ftaayinai
Umtfs
Loadng
Limits
Crop Use
Lmrus
Giaimg
Restrictions
Access
Control
PSAP(ma)
PFW»
crape
Yea
Wrihtn 48 hf
lor Type U or
IU unless
attMued
Ram, l/oian sort,
snow, ca
PCB< 2 ppm on
pasture
For Type 11 or 111. no
grazing lor 30 days.
No crops except
sludge Type I or
siabkxedU and III
For 12 mo attar
appt Fenang
andagna.
Mcfagan
Per fidni
VM
Wrfwiafihr
Mm 6 5
tor lood
aopa
Winter genarafty
ufidocopiatote
N. P. Cd
Agronomc rates
tor N No overload
lor P t/20 to 1/50
ol man cumuiaiive
motaia.
No lood cham crop
tor IB mo
30 days
PSHP |mev)
PFHP lood
crap*
>6 5 (sari
andaluc
mu|
No appl to (allow
land unless sod
»W».
prec^Makon. and
N krratstnei
N. P 25.000
- coarad
textura,
15,000 gavac ¦
med. texture.
10,000 gavac ¦
line texture N •
agronomc rale
II lofeage mmmai, can
apply to pasture or
lor age crape
Agronomic rate
Sol and
No spreacfcng on
snow-cowered,
frozen, or net
ground.
Mi 30 days lor crape
miaded lor nckrect
human consumpaon
Wat IB mo lor oops
intended lor daect
human consumpbon
VagataM cower
unless plowing
Grazing
animate
permtted
afler 30
days alter
apf*
For 12 mo after
appL
Bouidaries
must be
conspcuously
marked
Putttc access
permuted 12
mo attar appl.
PSKPor
For farmland
>12% dope
¦bagewtft
|4«*I
6 5 mm af
appl
Mamimn
lor 2 yr
alter
Reduce ratas on
kozen. snow-
covered. or wet
ground
N requirement ol
craps. Cd. Cu. Cr.
Pti. Ni. Zn 10%
ol cumulative tmV
yr oater param-
eters tor pretreat
ment city, reduced
retjuiramanls lor
ratas i 2 dry
vyeat. dedrawrt
sues not recom-
mended but
conadered
No appl to'aw
crape. Wat 30 days
alter appl lor harvest
Appl toveg-
etaUesftiome gardens
not recommended
unia&s composted.
30 days
alter appl,
1 yr lor
lactahng
dairy
ownals-
Barriers or
ramoianess
Corner slicks
maintained
iDrough growmg
season lor
boundary
demarcation
-------
TaM»Et-S
Lana Application - MmiqwiiiiI Precue— (eoniinmdl
Sum
SludQB
OMNIMMS
PMhOOBO
Central
Studgo
SuMMunn
Incorporation
pH Laval
Seasonal
L«ws
Loadmg
Limits
Crop Use
Lotus
Qiaano
Reancmns
Access
Control
No, not even
n guHtencs
Piohbftona
on um (root
crape, torn-
Uniiaated sludge may
not be appted lo root
crops 01 tcM-groiMng
trials. VaooUbln
may be grown i yr
alter appfceaaon Not
used m parks
No
NMMqumd
PSHP
Noapptcakon
¦¦owed 10
IronrttAow-
covered or poorly
drarod sod
Must have
vegetated oower
unless mcorpo-
latud Max. appL
rate 10 dry l/ac/yf
No use on home
Oraang lo>
animals. 12
mo ma
wart
Pubic 12 mo
aharapf*.
No
P8RP4*FftP
lo control
odor/pain
Maybe
reqiared
Not on saturated,
frozen. or mum-
cowered corf
Crop N
requirementsftnetal
toadno (vrfuctmer
reaches tor* fast)
II only PSRP, IB mo
lor (teect human
consumpkon
Yes
12 mo (signs)
PSRP or
app*y B c%
Yes
Oortmmrt stt
mm. PffV
lor
tgicduil
land lobe
>VdA
Not to be appked
ontaten. smm-
covered ground,
or star rams
Based on N aval
and heavy maiai
conoentrauna
No use on lood cropa
tor (tract human
consumpkon arthm
18 montfis
For 12 mo -
lercas. gales,
and s«ps
Mm PSRP
Putofcc access
30 days
Aponoimc rales
Pratabrtad aunno
retement
awl 6 5
12 ma alter
W*Ml24
Limns apply lo lood
etiam crop lor leed.
pH. maintenance. and
plants lor human uae
-------
Ei-6. Land Application - Manapamant Prectica* (continued)
Stale
SUgg
Oowatanno
Pathogen
Control
Sludge
SiaUuiion
lncorpci»ai«oo
pH Level
Seasonal
LMiHta
Loadmg
Lmius
Ciop Use
Limls
Glaring
Restrictions
Access
Control
OM
Caae by-
Yes
5 Vac on frozen
or snow covered
ground wdh rwn.
slope (< 2%)
N. metals
toucs, other
nutrients
considered
Wait 1 yi after aft*, lor
grazing and vepBtafite crops
to be eaten raw
Wau t yr
alter appi
lor dairy
grarmg
Ohiahoma
PSftP/
At apphcaaon
N. P, Cd. PCB
Agronomic rates
No human lood cham crops
lor 18 mo
Wad 30
days alter
appl tor
dairy
graimg
ftfUtau-
kMallldudga
UwIMn
Oregon
Vaa
Hate requved lor
max annual plan)
yield Mth no
narogan or
phosphorous
awasaea. vanes
tor CEC (lor long
term sae ta&dng)
Annual based on
crop agronomic
loadtfig rates
6 mo. uncftgested sludge, 30
days, air-dried sludge Mot on
raw IruiVwegeiablesoa mo
witfvn gudetnes)
No gramg
- 30 days
For 12 mo
aber apfl
unless
compost, heal
dry. or
eqjtvatoru
PA
PSKP/
MW
pfpr
Sot
Noappl a
pH>6 5
•trusted
ground
saturated.
and
trcuen. snow, or
maniam
ran Htaty
d2y»
Some aanwanne
tar fccutm

ground

iyparairf^'
>fi ft lor
Not on
toodcham
Irotervsnow-
crop.
oovered soa
<6S lor
unlaaa aroann
(ton-lood
control
cnam
measures m
crap, total
place
<& vac

H. metals - rates
consistent wah
OER guKlaknes
30,000
ga^ac/yr
< to Vac.
< 4i nitrogen
leguaomtjrH ol
crop
Noappl to root/uncoohed
cropa, no lood crops
Noda*y
grazing tor
2 mo
toUrwwng
appl
Yes lor 12
mo after appi
-------
Tim em.
Cud A»pltcHoi> • Mwgiwwl Practtc— {continued)
6um
SiudQB
OtiMMnng
Patfiogan
Control
Siatehufaon
Incorporate*)
pH Laval
Lkihis
Loading
LmtU
Crop Use
Lnnts
Grating
Restrictions
Soul)
CuakM
Yee
PSHP/
PFRP
To be rd at
vector* and
odor*
Matals - 10%/yi,
Nutrients -
agronomc tales
unfto&ft dodbcatod
sua
Fa dedicated sue
i mo
12 mo •
pubkcaccaas
PSHP/
pH6a
dumg
No appfecafaon to
fcotensnow-
covarad ground
or saturated
ground
Coarse sol
23.000 galtac.
Med. »L 15.000
gaVac. Ira sod
10,000 gatfac, no
pasture 4 fogh Pb.
Cd, N by crop, so4
type, yield, EPA
p.-IT' tor otters
Not tor leafy vegetates
unless apptOMed twougti crop
ksaue analysts
Sludge >
lOOOmgftg
Pt. oi 20
nngikgCd.
or 10 019*4
PCB. not to
beappked
to forage
crops
where sur-
face con-
lamnadan
may lead u
d»ect n
geswn by
toeckng
annuls
TN
PSAP/
PfRP per
40CFR
Part 287
Yea
Noappl on
snow or trozen
ground or dunng
amanrtart ram
12 mo
MMhn46lv ol
WDIO
PSHPI
PfRP per
No. appi dunng
raru or to IroMn
Wltfttu
Calc based on
metals toadmgs
(tong-torm) and
nutoents (snon-
term).
12.500 gatacsappi
orfttfcy tfae/yr
700 Mac - vertfy
Avoid tobacco, teaty
vegatawna. toot oops lor t
yr pH. aokd*. N. P. K. Co.
Zn. Pb. Ht. Grazing - mom
Oetore appi. wad unU atudge
gone Oary - wad 6 12 ma
No dory grazing tor 12 mo
Oo not apply mfrn 2 «*» ol
planing
A tod on growing plants
pH>Sa
-------
TNMt Et-& Land Application - Min»g«w*i>i Practices (continued)
StMB
Sludge
OMHUmg
Pathogen
Control
Sludge
Stabttaiion
Incorporation
pH Level
Seasonal
L«mu
Loading
Limits
Crop Use
Luruls
Grazing
Restrictions
Access
Control
Vermont
PSflP
Noi on bo/en or
snow-covered
land
Controlled by
agronomic N
demand and
mams
accumulation
Ai least 5 wk req'd between
sludgaappl and harvest
Land cannoi be used lor
human consumpum lor 36
mo alter appi.
Noi lor fi
mo attar
gKrffQg ^)pi
fanoaa/agns
may to rsq'd
Accra*
control »2 mo
Vagm
Yaa
tMhMd
Yes. except
pasture
pH>6S
Best fame is prior
10 pianfcng
N balance and
15 vac ma*
0 5 KVac cadmium
Yes - grawig restrictions, qo
bufc appfccakon to veg.
gardens, avoid totiacco.
root crape lor humans
1 mo beat
and 2 mo
dairy
grazing
Ye*taM2
ma Mar
WA
PSflP
PCBsri >(0
«0*0<*y
H requirements ol
crop Calc. ol
metals content and
rate
Pathogens, metals. Root
crops and raw vegetables
may not be grown lor IS mo
altar appt
1 mo lor
grazing
animals
t2motf
PSflP. unti
dneO i PfRP
WmI
PSAP/
PfRP
Ogeaaon.
hermsl
reducMft. or
cnsmcat
Raw crape/
so* •
4A hr
SoripH
K>6 2
No appi to
Irozen ground
Not on crops wdh erMita
portion underground. Not on
leal crape or oops not
processed. Ckp pastures
Mheoorurt
Ves
PCO* * > 10
dry «*
N. Cd.Cu.P6.
M. Zn touts
(see
contamnants).
agronomc rale
tor N.
65 unless
Cd<2
mgftg
pH 6 0
Dec I Mar 31
may apply lo
slopes s2%
mK> approval
Approval req'd
tor appi to
slopes up to 6%
N. Cd, Cu. Pb. N*.
Znfcmos(see
comamnanu).
agronomc rata lor
N
WytMMW
PSRP/
PfRP
fid K>
BOOt/l.OOO
IB mo lor human use crops.
2 mo lor cereal strains, post
appi. dary gru. I mo
odsigru 2«*a
Food ctan crops so* @ pH
65o>> and max annual
- 5»Vac
Wau 1 mo
altar appi
lor daay
graang. 2
wk lor oner
grazing
Access
restricted lor
6 mo after
appi
-------
TaM EM. Land Appacai
ion • Other SIM Management Practice Raquir»m*rts
StaM
Managanani Pracaoe
Alabama
Raferance n Part 23?
Alaska
Cam - irnmadma
Florida
Tachneai Cntan«Compoa» • EPA-62sn-79-0i 1, Process Ota/git Manual for S/udja Traatmtfit and
Oisoeaat, Cnactar 12 adopted by rataraoca. Soma affaranca m grades t and 2 required.
likros
Sits montionng - sitee< 9 yrs A with Sudga «wh mmmat mduroat waste loads
induna
Storaga - Mirwnwn 90-day caoacrty
Kantucky
Deed recort - cadmum appbcaaon
RflyMttQrt ¦ Aegwtared landfarmmg faofctiee* operator's certflca&on
louswna
QC System • Conformance at meomng waste intti pormt
Offnr • 200 it distance to dnniung warn
Maryland
Truck washing
Massachusetts
Studgs Classricaoorr. i - can be used add. dwtnfiuted wittiout approval; it - can oe used. x*d. Astrfeuted only
with prior department aocroval; III • same as II but cannot t» usad to grow food ctian crap
Mctttgan
Sound Agncutturn Practice - For example. avod so* compacton
Storaga • F«id storage must Da >asa fvan r days unteaa covered md crowded mm seepage ban*
Mnneaota
Faekiy Oesqn Cntena • Yaa
Mwapp
Sittng oparaaonat crura - yaa
-------
Ttttto EM. Land AppWcattow • Other Stttt Management Practlca Requirements (continued)
Slate
Management Practice 1
Misaoun
Reference to Pan 237 and Stats exceptions (or remote snm and restnctad access in i«u ot PSRP 1
Reduced requirements for rates < 2 dry try* I
Oedeated sites not recommended but considered 1
Montana
Omar - seotage regs only
Nebraska
Notify state and complete quesoonnare
New York
Sound agronomic practice, specie calculation methods
Storage facilities - 6 mo mm if uaM
Ohio
Compost Exemption • Ctaaa I Composted sludge ooee not require ate inspection/authorization. Clasa II
composted Sudgi may require s» inspectnn/autnonza&on
Contract • permitted, sludge permit issued »treaanent pant owner
Rhode >* mithmnos oer cm
Tennessee
Oetteated -may not ac&y as to aoproval - case-by-------
TafaiO e»T. Land ApptcHow • State ProhttWone
Scan
PfWiMon |
Alaska
Permafrost otwam 1
Arkansas
PromtMsd on produce crops. home gardens, recreations areas, 'etc.* 1
Connecticut
No dome garden use of sludge products 1
Delaware
No aepbcsBon to tobacco croc lands 1
Florida
No use where human contact possible. Ouifer 200 ft |
Kentucky
No raw «udge application. 1
Notonstooea > 12% 1
Mara
Not over 'significant aquriers" without variance 1
Maryland
No sewage on toeacco I
Massachusetts
Must not apply Type u or ill sludge unieea -------
Tattle EM. Land Reclamation • Mwmww Practices
Sua
Management Practice 1
Arkansas
Sludge Monitonng - Pre-acdeation ]
Sals Analysis - Pnor to apoheaoon and annually 1
Site Development Plan - Warn management ptwi 1
Access Control • Public i year, f anew sign j, no human contact foe 30 days 1
Croc Use Limits ¦ No food chain far I year, no use on home gardens/vegetaoies 1
California
incorporation • »a hr 1
Sludge Stabilization • Yea I
Access Contra • 12 mo I
Loading Limits • Metals, pathogens it might oe used lor food eft am crops, same as land aooieation 1
Oeiaware
Cover - Not less Mr 30% revegetatm 1
Crop use limits - No harvest tor food Chan 2 yrs 1
Incorporation - 2* rtr» j
Seasonal limits - Snow, frozen or saturated land, no appxaaon 1
Oct 1S - April 13 unless caver crap is estaoftsned I
Sort testing for agricultural land I
Florida
Distance to Surface Water • 300 ft ]
StocwQrade • Yes 1
Mining Law ¦ Must Da m compliance •< »pf I
Revegetata Area ¦ Must slant turf, grow grass after 3 mo cessation 1
Nearest Oweilmg - 300 ft I
Access Control • Yes 1
Surface Water Monitoring • if violations I
Runoff Control - Yes 1
Loading Limits • 30 dry vac/yr. iifeome metal aceumuiaacn ram* ¦ '0% lor 2 yr 1
Crop Use Units • no rtuman food I
idano
Similar to land appucaaon rates, case-Oy-caet, consrter future im loading ]
Illinois
Reporting Reowrementa • Annual Operating Report • Amount, use oI crope. analyse 1
Buffer Zones ¦ Yea 1
Mmng Law Compfcance • Yea I
Plant Tissue Monitoring • Appfccant propose 1
So* Monitoring • Apptcant propose 1
Site Development Plan - Sits cnaractensocs I
Nearest Dwa*ng - Yea 1
Surface Waiar Uontowg • Appacant propoee I
Qround-waar Monitoring • Appkcant propose I
Loadmg Lmvts ¦ N, mm*, propoee r noctcanon 1
Maryland
Erevan * Segment eroenn cm i vol prw®ons are reputed j
Sludge Monrtonng • Aa raquwad, sludge anatyw ¦ for appKaaon tor pamw (same aa (and mtem e.g., as |
needed and pre-appseaaan tor percent joMk pM. N. ammoru. mtaa, metals. PCS. 'etc.* 1
Loadng Rata - > 30 vac may da stowed I
incorporation • Unieea PfRP and approved |
Even spreadng. marked mat truck deartng I
Record Keepng • Yea I
pH Laweia • Adtuatmant «o 6.3 < <9 9 |
Site Development Plan • Oparaeonaf I
Access Control -12 mo urteaaPPRP I
Surface water Monitoring ¦ Aa ngund 1
Qrtxjnd-waar Momonng - Aa nquM 1
LoetSng Raise • Sludge: 30 dry vac metate same aa land apptraarm -------
Tattle tM. Land Reclamation • Man»gem«nt Prectlcee (continued)
State
Management Pracoce

Norm Canana
Loadingnam -SO Oy tons/acre. cumulative metalsor same uland aoobcason «x) is CEC-dependent so*
ch is maintained at S.S and limited to one-sme apoteaoon
Pennsylvania
Sludge Monitoring - Moistwe, N, P, K. BOO. pH, CN. Na, metals, toxics, oatnogens
Distance to Surface Waw • 100 n. 300 fl tor water suopi«a
Oistanee to Bedrock Outotve • 23 it
Oistanee to Property Une - 90 *
Incorporation • 24 hr
PoHueon Control - No ground-waaer/surface water pollution
Site Dffvetoomem plan ¦ Revegetason plan
Nearest Oweftng 300 ft
Surface Water Monionng • May Be required
Qround-water Momtcnng ¦ May be required
Sort Type - pH acftusted to 8 5 Oy second year, maintam tar 2 yr after application
Loading Omits ¦ Metals (06R gmdehnes), 60 dry vac and t wvwk, prevent ponding
Seasonal Units ¦ No application 2 it (seasonal wear uoai
Loadwg Raa-for N
At im* 2 R dwh e imeaimewe sai
Slop* ¦
-------
TaWEfrlfl. Land Treatment Management Practtcee
Stata
Management PracBCB |
T«aa
Sludga Mcmtonng - initial (metaia, pesticides, cnemcaia) and jami-annually (N. Cd. Cu, Cr, PQ, Zny
AocKaoon Mathoda - Soeafied far liquid vs. dewatered
Suffer Zone • 200 ft to sua boundary
Sludga Stabtuason ¦ Unieaa aooroved ctnermse
Access Control - Yea
Ground-water Monitor ng • Unsaturated icne otan and ground-water montonng semiannuatty
Runoff Controf • Aopheanon rataa to prevent
Seasonal Urn eta • Not wnen frozen below oWw line
Crop Umita - No human food ow unlea aoproved
-------
Sludge Quafcty
Illinois
Wiaconan
s 2 pOg sludge
•
No special requirements lor "9Ra
£ 2 oCi/g

Limit soil 1MRa to 2 oCtfg
No winter application
Cannot grow tobacco
incorooraoon/lniacMn
Sort OH 6 S • 7 3
Mm so* CSC 10 metyiOO g
Mm soil day con tart ia%
Mm sort organic content 12 tonvac
i sopo/g
Limit sol mcrsaaa to 0.1 pCt/g
•
k 90pCi/g
Uirut sod increase to 0 t pCtfg
IEPA and libra* Oapi at Nuclear Sartty review
Lmit radon gas emission to less mart 9 oCi/m'/s

-------
Taw E7-t. OWttutWw and Mottmg • Staw Contaminant Cowcawtration umHa (pom)
Sta»
Cadmum
Coppw
lead
Mercuiy
NcMM
Total PC 8a
Zinc
California
90

300

Maine
10
(.000
700
10
200
10

Maryland
12.3
500
500
5
100
3
1.230
Massacfiuastts
2
1.000
300
10
200
2
2.500
New Hampartw
10
1.000
700
10
200
to
2.000
New Jersey
40
1.200
4,800
10
1.230
03
2.400
New vort
23
1.000
1.000
to
200
10
2.500
Oho
12.3
500
1.000

100
3
1 300
South Carohna
20
700
830

130
10
1 523
Texas
23
1.000
500

200
2
2.000
utan
23
623
500
3
200
2
1.230
west Virginia
30
900
1,000
3
200

<300
Wisconsin
10

230

Number
Rang*
Mod*
13
2-50
10/23
11
300-1.200
1.000
13
230-4.800
500
a
3-10
10
11
100-V290
200
12
0 3-10
2
10
1.000-2.900
1 230-2.300
-------
Tatxa E7-3. OttWButtBw »nd MHwBnq • State Management Practice Requirements
Sua
Alabama
Patngsn
Const*
from oomposang
mould Da non-
patftogene
Runoff
Control
Buffer Zones/
Acces Control
Temperature
Monitoring
Storage
Cabtamia
Yea
For com costing facilities
Hawaii
PSRP/PFRP
Illinois
Digested sludge must
be used
Yea
Yea
Restricted
Mame
PFRP
300 B for
we«s. surface wataro.
90 ft to intermittent
streams. 29 ftto prop-
arty hne A putftc roads
impervious pad
Maryland
PFRP
Missouri
PFRP
NPOES permit for
comppsong facilities
Yes
Yea
Nebraska
None
None
No
Nevada
For composting
For compost plant
¦ 900 fl to prop, i me
• i 000 ft to road
New Hampsiwe
PFRP, crop use
control • not lor use
on food. oH >8.9.
Yes
Required tor
composing
30 days
New Jersey
Limited to PFRP
May be required
90 ft srte-spacific use
only
Yea
Mey oa required
New York
PFRP Minimum
Yes
90 ft to property line
23 ft to dramage swale
Yea | Minimum total detention ome
of 90 days
Oft o
No
Oklahoma
PFRP
PennsyivAua
Oetarfed cnerracal
analyss required
betore disposal
Temporary noragetoee
prowded by generw
Rhode island
PFRP (40 CFR 297)
*00 ftlOi
dweihn^ Acceee
control.
Souin Carakna
Tenneuea
Yes
Y«
Texas
PSA* in* mv tor
Access control lor ta
mo altorappL
-------
T*Qte E7-2. OUtrttKftton «nd Mtrtwtnq • Sttf Mwynnw Pr»ct>o» R«qulfm*rt» (comlrwd)
Stat*
Ptifiogdrt
Control
Runoff
Control
SuNer Zoom/
Acces Control
TefTtoaratura
Monitoring
Storaga
Ulan
P8MP
-------
Tattle E7-J. Oiaattutton and MartwBng • SMw SKa-Spedflc Raqulramanta
Stan
losing
Limits
Croo Um
Limits
Ground-water
Protection
Distance to
Surtaca Wattr
Oistanea to |
wots
Arkansas
Pronifictsd on produce
crow, homo gardens,
recreational areas,
etc.
Minos
For DUt»C
dwrntjuoon:
< 10 dry vac
Cd<25 mgrtqj
Recommend against
use for ieafy/roct
crops
200 ft
200 K
depending
on gootogy
and type o< I
Mam
Impervious pad.
ieactia»
collection ¦
inctuoea
treatment
Not allowed on
floodolams
Maryland
If >45% Fa (dry
**gm) label to say do
not use on pasture
Missouri
N requirements of
crops; Cd. Cr. Cu.
Ni. Zn ¦ 10% of
cumulative land ap-
plication limit par yr
other parameters
for pratraawent cny
No appi. to raw crops.
wait 30 day* after
aooi. for harvest Appi.
to vegetal*
noma gardens not
recommended uniasa
cam posted.
Groundwater
monitoring at
dadicatad stes
25 ft drainage
drtCh, 50-300 ft
to stream
depends on
sream
daaaficaaon
150-3001
depends
on geology I
and won
construe-
son
Naeraaka
Nona
Nona
Now Hampshire
Site-specific
approval rf
mecnantcatfy
aopned C0< 5
kg/hay* 'OcJT/ac
noi *or noma
vagetaue garden use
Monrtowg may
oe required
100 ft
100 ft
munttoai.
300 n
pnvaie.
500 ft
commwiy
Now-Jorsay
Site approval
nacaaaary if >100
cu yd to 0* used;
Srte-speaAc
requ*ements lor
unteanaad maianal
Yea. Mt*
Speofct,
orvy
for
Srte-
HMO AC
requrv-
mannal
New York
Ctaaa I: puttcdot
Qaaa II non-lood
eftasicrope
200 1
200 ft
leacftato
conacwn
ONO
Owe away approval
requree management
plan 4 > i/2 dry
eorwyr
Claaal: compo
Ctaaa it: non-tood
cftan
Class III- approvavmgt
plane
2 cu ydefyrvperaon
-------
TaMe E7-3. OtatrttutlOA and Martetfan • Sliti Stf-SpecHIc Requirements (conttowed)
Sen
Loadng
Una
Croc use
Limits
Qrouna-wasar
Protection
Distance to
Surface Water
Distance as 1
Wens
Omer I
Rhode Island

Ground-water
monitoring,
leacnate
collection and
treatnw*
200 ft and not
in a water
supply
watershed
t.ooo n
private wen
(also. min.
4 ft tO
ground
wateo
FitndOan 1
restrictions 1
A '00
cutxc yds to be
used
Use m home gardens
prohibited
Q round- and
surface-water
morn Bring
required it
stockprte on
ground-was*
surface
son
100 ft

Wiaooran

Cannot be used on
cenamcrope

Washington
C<* 9-20 Kflitw
cumutaove on food
cftancropa
Unless rrwtata low. not
recommended tar food
chawi crops

SoiKtfpe ¦
ptraton
capacity to
prevent
overland flow
-------
T«Me E7-4. Oftrtpirtow tnd Marfcaflnq - State Stuaqe TreetmenVMeneqemerrt Btqulmimw
Stan
Sludge Dewatenng
Sludge Sta&hiafion
Cahferma
Yaa
Yes
Illinois
Only dry 4udge may be distributee to the pcac
Yes
Massacfasetts

Yes
New Jersey
Product sftouid be 60% sotcs oy completion

New York

Yes
Ohio
Must be in cake form for giveaways
Yes
Texas
Maximum 10% moiature for home use: 69% tor
commercial use

utan
OneO lor pubbc distnOuMri

Virginia
Must be m compost form tor giveaways
PFRP
-------
TstHe 67-1 OtatrtbuMon *nd Marketing • SW Monitoring and Repotting Requirements
State
OuaKy Mowtonng
Reporting and
Record Keeang
Product Labeling
Legal flsteases
l<« Development ana 1
Operational Plan l
California
Monenr Mgi tor Co.
Pfc Cu. W. N. PCS.
MM N, SOWS;
frequency depends on
sue of plant
Reorasentanve
samp>es collected/
analyzed 'or suita&iity
Show nature of
contents witn warning
at obv23cuyd
Over 1300 dry tons per
year requires permit By
Brokers

Maryland
as requested, pre-
permit
'Regulator* keep aN
testa and distnDution
records
instructions, identity.
May require
mstncwns and
eaunona.

Maisacnusera

Recordkeeping •
annually who, now
rr.ucfi. ate.
Generator - annually;
wfto. now mucn.
User - annuatfy* snee
aopiied. amount,
crops, etc
'Approval of
suita&Wy" tar specific
use. warning if > to
ppm moiyodenum.
>300 pom of ooren
could cause
pnytptoxoty
Type I & 10. use
instruction*
Type it/ill: analyse,
results, amt nonce
legal use
Land appi certificate tor
use of Type ii/til

Misaoun
Metata and orgawcs
Caae-oy-caae
if to oe used on
vegetaMrgarden
crops, restriction on
mewarorgamce
Sahd waste permit
ferwaer permit and
NPOES permit
Solid waste permit. 1
site development and I
operation |
Neorasfca
None
None
None
None
NO 1
Nevada

Only requirement is mat
puOfeC knows ongm ot
sludge
Yes 1
New Hampsmre
No gm. screening* or
grease allowed
Record ot users and
quantum taken
No
Not for nome garden
use • acknowledge
conwnta
Design and operating 1
pun for comoosang I
New Jersey
Compost teeang,
vaneMe frequency
(sludge t* generator)
Y
Anafyacat reeuta.
temperature.
dMuton, etc.
Yea, per Nj comm.
ferrx. sod corxt act
t970. conditwn of
use. generatfy -------
TiBte C7-8. onwaudow snd MarteMnq • iwt Mowrtortng wd Reporting Requirements (continued)
StWB
Mcnrtonng
Reporting and
Record Keeping
Product Labeling
1 Site Owveiooment vn |
Legal Releasee 1 Operational Plan 1
Onto

Montniy analysis (or
compost wno
receded the comoost
a giveaway sludge:
monthly lor compost
(anatyso/quanmy) par
NPOES permit (or
giveaway

1 Management pi** tor 1
| all Type in comoost |
and giveaway dry 1
sludge exceeding t/a 1
dry tonsfyr to any 1
I person I
Oklahoma

For 5 yr • da*,
amount where
snipped, use
agreements, quality,
etc.
Qanarator to inform
user ol uuafcty. safe
usee, etc.
Agree to usa sludge 1
according to regulations 1
Oregon

Ongmmustba
revealed

Permsytvania
For Sudge, monitor:
moisture, N. P, K,
800. pH, CN. Na.
metals, toxics,
patfiogens. PC8s

Instruction sheet
deacntxng material
aooi rates,
recommended uses,
profwMed uses
Permit tor treatment I |
plant I
Rhode istand
EP toncrty yearly and
appendix vi items for
cured compoat

Ooeratmg pm. 1
Cioaure pMB • 1
montonng and 1
fundng. 1
Texaa

Parade, wnonaa
received it > i vtim*
insmjcoons on use,
rates, and identify as
siudg*. Seders must
mdude resmcnons.
recommend on usee.

utan

Yea
1
Virgvua
Required for
composting product
Annual summary of
operations
User mfomason on
use restrictions and
misuse wanwiga
I Composting evaluated |
on case-Oy-caae 1
1 04i* 1
waafcngmA

n. P. K. rf sold aa
femtaer

West Virgin*

Oatttuaon and
nMtduM
Must dearty ndicaai
tfw erodua < not
recommended for
vegetaHe gardens.
Anaiyacai
idamflcason.

Wiscorsn

Vdurtw sold •
commercial
-------
TiOM Eft-1. Indneratton • Allowable Contaminant levels In Exhaust Emtwlom
Stat*
Be

Opacity
<%)
PartculauM
SO,
CO
Comments 1
Alaska

<20
0 33

Flow measurement 1
Florida

0.1 granvcu it (Existng > 79
Vd);0 08 grwvOSCF
(New > 90 t/d)

Georgia

3200
gf24 hrs
20
Emong -0 2 ton 00 net
sludge.
New-i 3 id/ton dry sludge

NSPS adopted ey reference 1
40 CFR 60 suooan E 1
Illinois

0 08 grauvSCF (A 12% CO})
for <80.000 itsmr
0 1 gram/SCF • other.

300 ppm <@
90% excess
sr) >2,000
iWhr refuse

Indiana

PSO regs may apply (Pb 0 8 1
tfyr NSPS) I
Ooen Owning piohOrtsd |
(OHM

20
< 0 89 grtcg dry sludge input

I
Kansas

0 i-0 3g/0SCF

Ooen burning noftfrim |
Kantcuky

3200
g/dT
Max 20
0 85 dry sludge kw

Open burrxng nnftMaa 1
Louisiana

Per A PC lowa |
Maryland

Meet ai at quality contra |
rags and guidelines |
Michigan

0 2 itvi 000 iQ gas

I
Minnesota

Regs (or sludge monerason
incomplete

Particulates, regs lor sludge I
mcmeraDon incomplete |
Mmaooi

0 2 grarvSOCF

1
Misaoun

0.2 grartOCF exhaust gas
0.3 if >200Nyhr

12%

Nevada

3 «yt dry refuse if < 2,000
tbftr

Comply «un NAC 449.430 I
(0 449 844 I
New Hampshire
Yes

1
New Jersey
lOgtt
1200
SM

0.1 gwvOSCF o 12% CO,
1 2

New York

20
02-110 ittfv oeoencfcng on
charging rata

1
-------
TattaEM. liiOnfitton • AHowabta Contaminant Lava+a in Exhauat Emtaatona
State
Be
HO
Opaerty
<*>
Parocutataa
SO,
CO
Com marts 1
Oto

20
2 Itvioo ID TOfuM < 100 t/hrl
IbMOO lb >100 Wtr

Exemption it oart ol WW rP 1
not regulated/ 1
licensed separably |
Oklahoma

Pennjytvana

Conform to pwvartng state
and local ragutaoona

Conform to staarioeai rags I
Rhode island

i 3IM dry sludge input

Soum Carot*w

0 9 itvto* Btu naat input

Tarmessaa

3.200
0/24 hr

0.2% of ctafgwg rate 2.000
itytv

PSO limits may apply 1
Virginia

Meet a PC requirements ]
Wiscocari

« 300 IWhr
no permit
raq.. examp-
ban alsopos-
sW it rnewa
leveiemet
1 3Wt input

< 900 Ituhr no pern it 1
required: exemption also 1
oosaOa it metala low 1
-------
TaW Incineration • Management Practlcee
Slats
Eimssona Control
Minimum
ramp/Time
Air Monitoring
AStl OiSCOSM
Site Devwopment
Plan
Other |
Alabama

Sanitary LanffW

Arizona

Solid waste unit
aooroves »te
development and
ooorationaJ plans:
air quality
aooroves stack
omissions
standards

AAaruaa

Plana tor disooaal
needed

Colorado

Open burning in I
LFs oroflitaad 1
witnout permit I
Connactxxrt

Mm temp.
Mm time
Yea
Yea

Oetaware

Hg ¦ Yearly ii Hg
6mis*on >1.600
qld

Florida

Leacnw |
collection - meet 1
WQ9 I
doagrvoomon 1
by 17-2 4 174 1
(aoMy; |
funort control • 1
yes: 1
surf wat momt - I
yes [
Georgia

800*F Prwnaiy
tamo: l.SOO'F
Secondary

in proper landM

Hawaa

Prevent odor/duat
nwaance

idano

No OOan Oummq I
lllmota

SaaOapiarZ
Aega/Ruiee 203-
E

lowa

Min. amp.
Hg-towa
PfliuwnConrol
Ruiea
Yaa

Am tufiuUnca I
csntrota 1
Kentcufcy

hq >« amnawrn or
stuoga anniM
>t OOOgM

Sludge J
dawawwQ, 1
drying |
Loutsan*

ParmtMft
faoMy

Mama

Opanounwg I
oranMMal/i |
serving > tOOO 1
(MTtOrit 1
Maryland
Mual maatal ar
Tutty conra
reg*9tad«hnM

Oo*ra*e plan.
Mdaaonpaon,«
orMntneaat
naiarfe ar*r.
oagraMonor
*eaaHnuaene»

-------
Tattle ES-3. Indneratfcn • Management Pf»ctte— (continued)
Sia»
CinWoM Control
Minimum
Tamp/fime
Air Monitoring
Ash Disposal
Site Development
Plan
Other |
Misaoun

Special was*
landM permit or
NPDES permit
Yes

Nebraska

Permits' 1
Ash may be land-1
appMd >f non- 1
tow |
Open burring 1
without license 1
prohibited |
Nevada
Mm airpoHuaon
technology. Must
use best avanatM
technology at
tune of
construcoorvmodrf
tcaoon
1.400'F for not
less than 0.3 sec

if on an approved
land disposal site
Yea

New Hampshire
Yea

Yea
Samotag and
analyse of ash
compoartion
Case-oy-caae
t»M
Access control 1
Runoff control I
Vector control |
New Jersey
Sia»-of-the-art
required

^reconstruct if
existing data
inadequate, stack
lasts, continuous
montpmq of 0},
CO,
nydreearfiona;
mm 0]
concentrations:
4% !H*fcnd tod
LandM analyzed
(or hazardous
matena^nature

Oiatanoau 1
surface •mtm- |
20° (MClMEhaM |
control 1
*jflge dewaMhng 1
North Carokna

Approved santary
landM. dead
shoMuae of Cd.
Oh »«.3 urtesa
Cd<2 mgflig,
PC8
-------
r«t*a es-2. iumxnaon • mwqwww Pracacea (continued)
StMB
EflvMom Control
Mninum
Temo/Tima
Air Monitonng
Ash OiSpOSal
Sit# Oavakjpmam
PlWt
09W I
Rhode island
orgarioaDaracuat
M

Closure plan
Soutn Carolina
S (b*m*on BUI
heal input

Tennessee
Mm. ar poHuoon
control tor Be.
lead, Hg, vinyl
cfiicnde, "others*
PSO limits

8a.P0.Zn, vmy)
chlonde, 'others*
"In a unitary
manner*
Araa and i»wy
C*an

Texas

Operating plan.
Tnat bums.
Was» anatyso.

Virg«ua
Maw A PC
requirements

Buned/spreed on
land, aeoroved By
DOH «H) wca -
Not tor LancK*
disposal

Washington
Mm. at ootkjwn
technology •
conform to
OR/WA stds
(10/23/721 (0€-
72-21 see 173-
301 390)

Approved sanitary
larxJM

Watar control • an
drams ana
process waar to
WWT plant
Wtsconsn

Not w exceed
desgnemoian
imta
Maawdune •
licensed sokd
waste disposal
faoMy
vaa
Access contra
Wyoming

Yea

-------
Ttft- mcHufBon • MowWoring and Reporting
Stale
GfMMQftS
Siudga
Ash
Siudga Food Rats
inonorator 1
tomporatura 1
Corwoeocut
NO*, partadam SO]

Oetawara

Georgia
CO. hydrocartwna,
NOj, partcutaias. SO],
oxona

Yea
Monitor 1
Iowa
Reoorflng

1
Kentucky
Hg if annaacna or
sludge anatyw
> 1.900 g/d
Sludga monitonng

Yea

Maryland
VaM perrw (rem A*
Management Admin,
and Waata
Management
Sludga momonng (%
tthda. pH. N. NMj, NOj.
metals. PCS*. *«c."

Michigan

Sludge monitoring same
as land appfcc. pemape
annually

MiMOUfl
Performance tessng
wnh rsprBawnanv*
samp* of material to M
Oumed
Sludga monitoring
Monitoring osoonde
on dispoaal metfnd

Nm Hampaftre
State regygudaenee

Anatymol salt
compoaten

New Jersey
Modakng torn*
asaeeamenta for
araane. Cr. Cd Mi
Monitor sludga (or
surtaMty to montrm

Required 1
Oregon
As 0€0 requree

Pennsylvania

Sludga anatyan tar
waaaa flat craaa
specific environmental
prottema

Tenneeaea
Laad, Hg, 8a. wnyl
cwonda. *«nar»*

Taxaa

inonvnng •
wanfy that it
-------

State
FiOOdptM)
RaalncMna
Surtace
water
QW Piotuctaon
Lmers
Oeptfi 10
OW
QW Leachaie
CoteOon
RunorVRunofl
Cannot
Butter Zones
Access
Other
Anion*
PwaOCfft
PM267
Per 40 CFfl Part
257
Caaa-by-caae
Yea
Stockpiles at
latmanoB only
500 It to nearest
dwelhna* 25 ft to
prapi kne or
road; 250 It la
water wei.
1.000 ft to
muvopal wel;
subOW
protection
Vea
Av ngtwiMier kgiu
storage - 72 to at
autjaatoQw
pratocton. parmtung
A ptfe w**c«*cn
* totaled on WWTP
property, approval
kom lactk review unit
andOW quatay
pratsckon permt from
permits
la^ind.
AA

Yes
CaMorna
Ye*
S II atxAW
hgM
anmpatadOW
Yas
Yes
Design to
prevent
For Class I
to ft to annual
*g>»
Cmmkwu
Outrw
oi
Yea
Yes
fcmi |iofl>
Compacted
day/aoriaw«i
permeab*ty
t x tO4 or leas
or
manufactured
I H tO7
permeabtty
ftonoa
5 It above
highest
^opalfid GW
Yes
Various criteria lor
sludgs stabduaiion
I yt storage aiowed
lor kquad or sam-
dewaiered, 2 yis lor
dowotorert
Yes
stabthzabon
requ«ad; parogen
control requred
1000 It to
nearest ctaelkng.
Oeptmay
reduce
Temporary storage
saasttned 7 days
Lagoons lor ismp
storage only
(< i? nos)
-------
liM E*-1. fpoow and SiocltprtM • Sum Man»Q*«wni Practice Requirements (conttowd)
State
Floodptan
Raalnckona
Surface
Water
QW Protection
- Inert
Depth u
QW
GW Leachats
Collection
RunoaVRunoti
Control
Butter Zones
Access
Outer
KUDO
Must pi event
Freeboard requred
•dm

AMy Irom potwrtn
totoodtfio
ftotatrvoty
impermeable
miionf
Siockptas
For sloctptes
ol dried sludge
"M&umue*
'sulboonHy*
separated Irom
nearest dweftng
Fence. warning
signs, and
reduced
yiaibtty
No s*ng m
I.OOOfttOweiS.
500 II bom
nearest dwethng
Odor antral to ofl-
Mn.
ale No
permit (tad Hudge
stored <2 ma Muat
past no Mndung
tfiMbdoiid,
|qu«l
Oas venkng -dosed
storage ot kqud
anaerotac;
hqwd storage - an
lagoons require
permit,
ptHerniation storage
requaed,
time kmts - 2 men
wfo approval
K«r*ucfcy
2ft li torn dranag*
300 ¦ man
500 A to nearest
dwaftng. 300 k
DMl
Sue development
plan-storage capacity
of 60 days reoomm.
(Mmer stor)
Closure plan
requred Inspector*
weekly and aflar
storms.
Tamp sioraoa OK i
>19% aokds
-------
TaMa £•¦».
¦nd SIpcIhiHh • Sim Mwimwini Pnalot fWqiiWamanU (oowtlwwd)
Floodplaan
Suttee*
Water
OW Protacfcon
- Unora
Oapto la
OW
aw i oftin
Cotacsort
Aun-onAunod
Control
Butter Zones
Access
09ier
ftteViMd
Evefciw
hydraukc
ion
(I 001 tow
permeatahty
2ft
land own*
NotafeMMd
mtood-
<5% slope
usoatty ISO 0
lorfclch.
Bermed lo
prevent runon.
Storage ol 25
yr 24-hr event
1.000 ll to
storaQe/
procasang area
Yes
100-yr
100-yr
aooa Mm pond a
asoofttaNi
4 n
2.500 It (rom
pubfec water
supply. 500 II
bom pr>vaie we*
Tocomp^Mt)
Section 0(2)
Temp storage
itwrngat OK onty
m* HffUliit haft
Sae development
plan req'd i storage
>42 days n any 6
mo* period Storage
watartght
MMMoaou
1.000 It fcom
10-yr
1.000 II to i
water. 200 It
runoff control
Meoop ape rate
>S00flP 2
V»s.
odor control per ar
pol, rags,
kquid sludge storage
at munc continued
sites possMa.
sod type same as
landspreartng.
unrestnctad A <30
days (short-term)
100-yr
CaeeOycaa*
Yea
CaoKvc
«MOtt0MOn
Caae-by-caso
GaseOy-case
Fence and
(nriwi gaie
MP DCS pet ma -
active, closure plan
required I lagoon is
not fcnai doposaL
-------
Ct-1
and fllorhrHaa - Sum UimaiwiiU Pi»cUc» Wequlraratnia (continued)
FtoodpUm
Surface
Water
OW Protecfcon
- Latere
Oepmto
aw
QW I WftftW
CdachM
Run-orvRunod
Control
Bultor Zoms
Accoss
Other
100 k Irom aurleoe
Required tor
Not lequxed lor
No
Yas
on
100-y*
500 It bom
nearest dwetbng.
260 ft Irom
puttc mad
Fence |im 3-
R ftgh) Locked
Penm requred
Yea
May be
required
Yea
Yea
Yea
&gnaand
1500 It tram
nearest dwefcng
YeatO'
200* tram
SPCC plan
requared d barm
frQhar dm
awroundtftg
ground
la
tout not
For kqurt
4 «
Yea
1M-3M mt

100 ¦<
Yea. storage
lor 2S y» 24-h*
i*riat e*em
400 It to naaraal
tukhng
Stockpthng prior lo
tanrtaprwartng not»
exceed Smo«
taafcne tamed to S
OT40T.
2*f •
raq*d
Empty teca^r ¦ once
« apmg. onoem (aft
empty and raped
onoafyr, AO-day
atoraga parttM. land
appkcaunoompoat
appr 4 »iOyda»
2 It Ireeboard
required Storage
capactfy 6moa,
dean/empty eirary 6
mo mm.
lagoon depti 2-6 ll
man.
m montonrv
ntmmue odora, not
violate AOS
-------
Pnalom Rftquirwrantt (oonflnwd)
StOCfcpNM * Sl>K
Surface
Butler Zones
Othet
ftaw aJudge generally
unacoepaMa tar
MoraQS
-mo ttxiQB may
and
as
m 100
2 >80 days
Mo dacha* 0ft to
utaoi mm 900
-------
T«M» E*t.
mi) Stocftpitee ¦ &uu
Podic* Raqtiiramtitt (conlktu*d)
Fkwdptam
Surface
Water
GW Protecton
- Um
Depth to
QW
QWIoartiate
Cdtacttn
Rurvorvftunofl
Control
Butter Zones
Access
Other
190 ft to aurtec*
Um.fi ft
too-
parfflMMly ID
lO'cmfr
impound bottom
and Ikgh water
500 ft k> any
water supply.
600II tram
Fancmetagns
ID control pU*c
Impoundment mutt
twamptodoMary#
mo
structures 300 h
irom prop, kne
•Oftl
Beg wad tor
100-
2 II mm u
aaMonathgh
groundwater
2,000 ft K>
natron
raadanoa, 375-
ftbuler zona
Fanong wrilt
locked gate and
agna to prawem
pubtc access
lagoons cdmM Mlt
mm. 2t oowar after
akjdo* ramM«t
doiura 0m caqurad
MMMgun
May to
Maybe
Odorineect
Praveru heatti
(gudance)
hazard
Closure plan
required. screening
raqured: gat vanimg
requred Mh
monaonng. arte
develop, pun
oqund
MM
10-*
2ft
vaa
600 k tram
nearest dwstng
Pafttogen control
raqured raqo* chap
VWal WO <*» rules
and rage.
-------
TaMa £1-3. Laooone and S>B cliplln ¦ »HW Monitoring and Reporting Rt^ulwwirti
Stele
Mqnomj '
Oreund-water Monrtomg
Surface W«w Monnormg
Reoortng Reqwrementi 1
Colorado
Aiwueiy (met.)
Quarterly

Conrncocut
MMl PCSe. paragons
Y»«
Yse
Yee 1
Delaware

Mr a we*a (one upgiadwnt)
- may be waived lor afiov*-
ground manufacture lau*uee

OeorQW

Only for new requirement*, 1
not lor enesng I
ithnoa
Amuaty, at time of lagoon
deanout
If n arees of poroua so* or
nock taaurae

low*

Omy tor permanent lagoons 1
Louiaana

vee

Mana
Aa per land appkca&on
license

Summary of management 1
records quarterly 1
Maryland
Sam sa land appfacatmn •
pre-pemw
2 down, t upqradwnt

Mcfegan

Hydrotogcal study es part of
apptcanon proceae

Misaoun
Pnor to final duposal
Case-by-caea
NPOCSparmt
Permits and doeura plane 1
New Hampsfw*
POTW »1 mgd 3Vyr
P0TVW<1 mgd i*/yr
Yee • lagoone
No ¦ nocfcprfee
CompKanoa «
uogreoent two
dcwngradMnt
When rsquved Oy
depervnem
Annual report requfed 1
North Carofcrva

Ciee Hy-caae

Norm Oakota

Caee-Cy-caee tmm (or
lagoone

Yea |
ONo

NPOCS 1
Oregon

It hgft wOMr Mle

AaOtQfequree |
S
-------