sr<^
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                           WASHINGTON. D.C. 20460

                                             Construction Grants
                                             Program Operations Memorandum
                                             POM 80-4
SUBJECT:  The Effect of the Hazardous Waste Regulations
          on Management,of Municipal Sewage-Sludge

FROM    :  Eckardt C. Beck, Assistant Administrator for
          Water and Waste Management (WH-556)

TO      :  Regional Administrators
          US EPA Regions I - X
PURPOSE

     To summarize the effect of the Resource Conservation and Recovery
Act (RCRA) hazardous waste regulations upon^construction grant activities
and management of. municipal sewage sludge.  The term management.includes
the generation, transport, treatment, storage, utilization and disposal
of municipal sewage sludge.

BACKGROUND
     Under the proposed hazardous waste regulations issued on December 18,
1978 in the FEDERAL REGISTER, municipal sewage sludges were excluded from
coverage under.Subtitle C of RCRA.  Subsequently, in the Final regulations
promulgated in the FEDERAL REGISTER on May 19, 1980, municipal sewage
sludes were no longer excluded from coverage and thus are potentially
subject to control as hazardous waste.

     The final hazardous waste regulations are very comprehensive and
complex.  This leads to both actual and perceptional impacts upon
municipal sewage sludge management including its utilization and disposal.

     Domestic sewage and any mixture of domestic sewage and other wastes
that passes through a sewer system to a publically owned treatment works
for treatment is not considered a solid waste [40 CFR Part 261.4(a)(l)].
Under all circumstances, however, municipal sewage sludge that is
separated from the sewage during treatment is considered a solid waste
[261.2(a)].  In general, a solid waste is a hazardous waste if it has
been listed as such by the Administrator or if it exhibits any of the
defined characteristics of a hazardous waste [261.3(a)].

-------
  %   The Administrator has not listed municipal sewage sludge as hazardous
waste.  Regulations have been and will be issued under the authorities
of Section 405 of the Clean Water Act (CWA), Section 4004 of RCRA, and
other acts which will address the proper utilization and disposal  of
municipal sewage sludge.

     While not included in the Agency's listing of hazardous wastes
under Subpart 0, of Part 261, specific municipal sewage sludges will be
considered hazardous if they exhibit any one of the four characteristics
of hazardous waste (261.21 through 261.24 i.e., ignitabilHy, corrosivity,
reactivity, and EP toxicity).  Specific municipal  sewage sludges would
also be considered hazardous if they were mixed with any hazardous waste
other than those entering the publicly owned treatment works (POTVJs)
through a sanitary sewer system [261.3(a)(2)(ii) and 261.4(a)(l)(ii)].

SUMMARY OF REGULATORY REQUIREMENTS

I.   Determining-Whether Sludges Are Hazardous

     (a)  The Administrator has not listed municipal sewage sludges
          as a hazardous waste.

     (b)  Therefore, municipal sewage sludges are not considered hazardous
          unless tested and shown to be hazardous.

     (c)  Municipalities do have an obligation to determine if their
          sludge meets the definition of a hazardous waste.  This  does
          not mean that each POTW must test their sludge.  Rather,
          POTW's or other waste handler must make a determination  that
          the waste is not hazardous based upon knowledge of the waste
          including the contaminants, etc.  In cases where there is
          real doubt as to whether the sludge exhibits one or more of
          the hazardous waste'characteristics, the waste would require
          testing  according to the appropriate test methods.  In
          effect this means that if the POTW has reason to believe
          that their sludge might fail any of the hazardous tests  (i.e.,
          exhibit any of the hazardous waste characteristics), they have
          an obligation to test to verify whether or not they should
          enter the hazardous waste control  program.

     (d)  The characteristic most likely to cause a sludge to be hazardous
          would be toxicity determined fay the extraction procedure (EP).

     (e)  In very limited tests by EPA, cadmium is the only known'element
          that has caused a sludge to fail the EP, i.e., be considered
          hazardous (See Attachment I3 page i for additional discussion
          of this  point).
                                   -2-

-------
Summary Table

    Ranges of Total Contaminant Levels in Municipal  Sewage Sludges
     that Were Found Hazardous and Non-Hazardous by the EP Test*
                         Total Contaminant Concentrations in Municipal
                                    Sewage Sludge, mg/1
     Contaminant         	

                           15 sludges tested and      1  sludge tested and
                            found not hazardous         found hazardous
 Cadmium                             16-282                      771

 Arsenic                            <4-155

 Chromium                            18-6900

 Lead                                74-3520

 Barium                              54-662

 Selenium                            7-69

Caution:  THIS INFORMATION IN THE TABLE WAS FOUND IN LIMITED EPA TESTS
          AND CAN MOT BE USED AS A CONCLUSIVE DETERMINATION AS  TO
          WHETHER OR NOT A SPECIFIC SLUDGE WILL PASS THE EP TEST.
* The nature of the tests is described on page i>  Attachment I and  the
  EP test data corresponding to these total  concentrations is given in
  Attachment I, Appendix Tables A-l to A-S.

II.   Requirements for Municipal Sewage Sludges Which Have Been Found to be
     Hazardous by Testing or Where Final  Determinationof Hazardousness
     Has Not Been Made

     (a)  Any POTW that generates or transports a  municipal  sewage  sludge
          which it believes to be hazardous  and who plans to continue to
          generate, transport, treat or dispose of more than 1000 kg of
          such sludge per month or store more than 1000 kg at any time,
          must notify EPA of their activity  by August 18, 1980 (FEDERAL
          REGISTER, Part IV, February 26, 1980) (EPA Form 8700-12).   Any
          POTW that generates, treats, transports, stores, or disposes  of a
          hazardous municipal  sewage sludge  without filing the notification
          is subject to civil  or criminal penalties.

     (b)  A POTW, which is only a generator  of a hazardous municipal
          sewage sludge and that does not also treat, store, or dispose of
          the sludge, does not require a hazardous waste permit.  This  POTVI
          generator, however,  does have a major responsibility and  has  to
          follow all the provisions of 40 CFR Part 262.

                                   -3-

-------
     (c)  A POTW would also require a hazardous waste permit if it engaged
          in treating, storing, or disposing of hazardous municipal sludge
          in the quantities described above.  As part of this permitting
          process, an existing POTW must obtain Interim status as a hazardous
          waste treater, storer, or disposer.  To obtain this interim status
          the applicant POTW would have to notify EPA by August 18 and submit
          a completed Part A permit application to the appropriate EPA
          regional office by November 19, 1980.

DISCUSSION

     A detailed discussion of the regulatory requirements is contained in
Attachment I*.  Also included are a number of tables with EP toxicity test
results.

     A second attachment (Attachment II) consists of questions and answers
that should be helpful to individual POTWs.  These will  be available within
two weeks in booklet format and mailed directly to FOTWs.

CONSTRUCTION GRANTS ACTIVITIES

     Facility planning activities must include consideration of whether or
not the sludge produced by a POTW will possibly be a hazardous waste.   A one
time EP toxicity test is an allowable cost for active and future construction
grant projects when it is believed that the POTWs sludge may be hazardous
and that the design of sludge disposal facilities, being funded through the
grants, would be affected by. such a determination.  EPA estimates that the
cost of one complete EP toxicity test, including sampling costs, may be as
high as $2,500.   One commercial laboratory, however, is  charging approximately
$325.00 per complete EP toxicity test not including sampling or any replicate
analysis.

IMPLEMENTATION

     This POM is effective upon issuance because of the  need for possible.
actions by POTWs as a result of the hazardous waste regulations.  However,
comments on the content are invited, and the POM will be revised and
reissued if comments indicate that such action is warranted.

Attachments
  Italicized references are contained within this Program Operations
  Memorandum.
                                   -4.

-------
ATTACHMENT I.  DETAILED REGULATORY REQUIREMENTS



I.   Determining Whether Sludges Are Hazardous

     The characteristics of hazardous waste include:

     (a)  ignitability (261.21)
     (b)  corrosivity (261.22)
     (c)  reactivity (261.23)
     (d)  EP toxicity (261.24 and Appendix II)

     The characteristics of ignitability, corrosivity, and reactivity
are generally not of concern with municipal sewage sludge, and few if
any municipal sludges are likely to be hazardous due to these factors.
The extraction procedure (EP) toxicity characteristic will probably be
the only one by whicn municipal sludges might be determined to be a
hazardous waste at this time.

     EPA has run partial EP toxicity tests on 15 municipal sewage
sludges and one ash of an incinerated sludge. »These tests were conducted
by two separate EPA research laboratories, one in Cincinnati, Ohio and
one in Las Vegas, Nevada.  There was considerable variability in the
results of these tests; however, both laboratories found that all 15
sludges tested passed the EP toxicity test for the six metals measured,
i.e., were found not to be hazardous wastes in accordance with the EP
toxicity characteristic.  These measured metals included As, Cd, Cr, Pb,
Ba, and Se (Appendix tables A-l to A-4*).  Cadmium (Table I) was the
metal which most closely approached the threshold concentration (Table
2) that would cause the sludge to fail the EP test.   A recent EP test by
a POTW of its municipal sewage sludge showed that the sludge failed,
i.e., was hazardous, on the basis of cadmium in the EP extract being in
excess of the threshold concentration.  The total cadmium content of
that sludge was over 700 ppm (Appendix Table A-S).
* Italicized references are contained within this Program Operations
  Memorandum Attachment.

-------
                               Table  1

Maximum Percentage of EP Threshold Concentrations Found  in  EP  Extract
                     of Tested Municipal Sludges
Contaminant
Heavy metal
As
Cd
Cr
Pb
Ba
Se
Maximum percentage of
EPA-Cinn
(15 sludges)
]%
211
10%
0.5X
—
—
EP threshold concentrations found by^
EPA-las Vegas
(7 sludges)*
IX
51!i
22
23
115
1 ?'
i ,J
 EPA-Las Vegas only tested._7 of the 15 sludges,
                                   n

-------
                                  111
                                Table  2

                     Threshold Concentrations'of Contaminants
           in EP Extract of the Waste for Characteristic of EP Toxicity
EPA
hazardous
waste
number
D004
D005
D006
D007
D008
0009
0010
oon
DO! 2
Contaminant
Arsenic (As)
Barium (3a)
Cadmium (Cd)
Chromium (Cr)
Lead (Pb)
Mercury (Hg)
Selenium (Se)
Silver (Ag)
Endrin (1,2,3,4,10,10-
Threshold
concentration*
yg/i
5,000
IOC. 000
1 ,000
5,000
5,000
200
1 ,000
5,000
20
DO! 3
DO! 4
DO! 5
DOT 6
0017
  Hexachloro-1 ,7-epoxy-
  1 ,4,4a,5,6,7,8,8a-
  octahydro-1 ,4-endo, endo-
  5,8-.dimethano naphthalene).

Lindane (1,2,3,4,5,6-
  Hexachlorocyclohexane,
  gamma isomer. )

Methoxychlor  (1,1,1-
  Trichloro-2,2-bis [p-
  methoxyphenyl Jethane) .
Toxaphene
  Technical chlorinated
  camphene, 67-69 percent
  chlorine) .

2, 4-0, (2,4-
  Di chl orophenoxyaceti c
  acid) .

2,4,5-TP [S11vex](2,4,5-
  Trichlorophenoxypropionic
  acid).
   400
10,000
   500
10,000
 1 ,000
 * If  concentrations  of these  contaminants  in  the  EP  extract  of  the
 waste equal  or  exceed  these values,  then  the  waste is  hazardous.

-------
     Factors that are thought to be associated with increasing the
concentration of heavy metals in the EP toxicity test extract include:

     (i)  high total content of heavy metal  in the sludge

     (ii) high total solids content of the sludge

    (iii) low alkalinity (high acidity) of the sludge

     (iv) high oxidation state of the sludge

An examination of the EP toxicity test data  for municipal sludges (Table
3) reveals that there may be some correlation between the ratio of
cadmium concentration in the E? toxicity test extract to the total
concentration of cadmium in the sludge and one or more of these factors.
However, the data currently available are insufficient to draw any
definite conclusions.

     The data on EP toxicity testing, Which  EPA has collected so far,
suggests that few municipal sludges will be  hazardous based upon the EP
toxicity characteristic.  On the other hand  the tests are incomplete and
the EP extracts of the municipal sludges have not as yet been tested for
the metals mercury and silver, and the six pesticides and herbicides for
which thresholds have been established.  With the limited information we
have at this time on the concentrations of these untested contaminants in
municipal sTudges and on their chemical properties, we do not expect that
these contaminants will result in concentrations which exceed the hazardous
threshold values in the EP toxicity test extracts.

     Notwithstanding this general discussion, municipalities do have an
obligation under 262.11 to determine if their sludge meets the definition
of a hazardous waste.  This does not mean that each- POTW must test their
sludge.  Rather 262.11 allows the POTW or other waste handler to make a
determination that the waste is not hazardous based upon knowledge of
the waste including the contaminants, etc.  In cases where there i_s_
real doubt as to whether the sludge exhibits one or more of the hazardous
waste characteristics, the waste would require testing according to the
appropriate test methods set forth in 261.21 through 261.24.  In effect
this means that if the POTW has reason to believe that their sludge
might fail any of the hazardous tests (i.e., exhibit any of the hazardous
waste characteristics), they have an obligation to test to verify whether
or not they should enter the hazardous waste control program.  When the
testing is undertaken by the municipality or other party, a representative
sample of the sludge should be collected [261.20(c) and Appendix I*] and
tested (Appendix II*).  If the results of these tests indicate that the
sludge clearly passes the EP toxicity or other tests (and is therefore
not hazardous), no further testing should be needed unless the sludge
quality appreciably changes.  If a hazardous test is failed, the sludge
should be considered hazardous.
* Appropriate sampling and analysis methods are described in SW-846 "Test
  Methods for the Evaluation of. Solid Waste."
                               iv

-------
                                               Table 3.

                            The  RelationsiiiDs  Among Sludgs Solids Csntsnt. on
                                     of Oxidation,  rota!  Sludfje Cadmium,
                                        and £P Sludge Cadniun.
Location jH*

°i--sturi»
Cefijnce
•',r
23.0 H "aw primary
_ inaerobic
95 -,,iner,tor ^
O.'S 59
0.33 * d.naer^ic
0.02 99 raw heat dried
31
0. 1 3 ~ raw orimary
! biological
9
0.20 6
0.10 39
39
3-3oer::?s
Total* E3*
,"-< r ,
j fl / Q •__ T i ,
70 <0.i
'3 3.5
102 <0.5
20 3.0
33 . 10.3
13 1 .3
SO 16
1 i 0 270
150 2
'30 «
223 5
32 2.i
232 5
41 15
S3 7
70 81
160

P.acio :
E? "1 '.3

0.3007:J
0.019"
0.000190
0.3130
j 0231
0.0021
5.0575
3.2155
3.30S25
O.Q477
0.002S
0.0016
0.0018
3. 034 1
0.0080
O.US7

Analysis by £MSL - Las Vegas, wOAc required  iurlnq  £P  fest
Analysis by MEftL - Cinncinati.

-------
     Hazardous municipal sewage sludges must be disposed.   It is possible
that some hazardous sewage sludges might be recycled by means such as
spreading on land.  Certain types of municipal  sludge landspreading
activities may constitute the type of use, reuse, recycling,  or reclamation
that is intended to be exempted from coverage under section 261.6 of the
hazardous waste regulations.  EPA will provide further guidance on this
issue later.  In any event the sludge transporter and/or the  storage facility
for the waste prior to recycling are covered by the bulk of the hazardous
waste regulations (IV.B.3 and 4, 261.6).

II.  Requirements for Municipal Sewage Sludges  Which Have  Been Found to  be
     Hazardous by Testing or Where Final Determination of'Hazardousness
     Has Not Been Made

     Any POTW that generates or transports a municipal sewage sludge
which it believes to be hazardous and who plans to continue to generate,
transport, treat or dispose of more than 1000 kg of such sludge per
month or store more than 1000 kg at any time, must notify EPA of their
activity by August 18, 1980 (FEDERAL REGISTER,  Part IV, February 25,
1980).   EPA Form 8700-12 should be completed and sent to the  appropriate
Regional EPA office for this purpose (Appendix 3).  Any POTW  who generates,
treats, transports, stores, or disposes of a hazardous municipal sewage
sludge without filing the notification is subject to civil  or criminal
penalties.

     A POTU, which is only a generator of a hazardous municipal  sewaga
sludge and that does not also treat, store, or dispose of  the sludge,
does not require a hazardous waste permit.  This POTW generator, however,
does have a major responsibility and has to follow all the provisions of
40 CFR Part 262 including the identification of disposal facilities that
will be used and initiation and completion of the specified manifest
system.

     A POTW would also require a hazardous waste permit if it engaged in
treating, storing, or disposing of hazardous municipal sludge in the
quantities described above.  As part of this permitting process the POTW
must obtain interim status as a hazardous waste treater, storer, or
disposer.  To obtain this interim status the applicant POTW would have to
notify EPA by August 18 and submit a completed  Part A permit  application
to the appropriate EPA regional office by November 19, 1980.

     Any facility (where EPA discovers that hazardous municipal  sewage
sludge is treated, stored, or disposed), that does not file a notification
during the 90 day period following the initial  publication of the Section
3001 regulations, will not fae allowed to continue hazardous sludge
treatment, storage, utilization, or disposal activities until  it obtains
a hazardous waste permit.  Similarly, a new facility that  plans  to
treat,  store, or dispose of hazardous municipal sewage sludge must
obtain a hazardous waste permit before commencing operations.
                                VI

-------
     Submission of EPA Form 8700-12, is not an admission that the sewage
sludge is hazardous.  In cases where the final determination of hazardous-
ness has not been made, the appropriate entry in Section IX (e) of EPA
Form 8700-12 would be to check box 4 and if desired to add the words
"municipal sewage sludge - a final determination of hazardousness has
not been completed."  Submission of EPA Form 8700-12 does not compel the
sewage sludge manager to file the Part A application for permit for
hazardous waste activity by November 19, 1980, if the sewage sludge is
determined not to be hazardous.  Filing for the permit by the November 19
deadline is only required when the sludge is known to be hazardous.
Beginning on November 19, the sewage sludge manager would be obligated
to comply with the interim status standards so long as the sludge was
hazardous; however, the standards would not apply to the management of
any sewage sludges managed in that facility whenever they were not
hazardous .and. not mixed with hazardous wastes.

     EPA will send an acknowledgement to each notifier indicating that
their notification (EPA Form 8700-12) has been received.  The acknow-
ledgement will include the notifier's EPA Identification Number.  This
number is to be used on shipping manifests for transporting hazardous
waste, on reports that are to be filed with EPA, on applications for a
Federal Hazardous Waste Permit, and on all other communications with EPA
regarding the notifier's hazardous waste.

     Through future modifications to the hazardous waste regulations,
EPA may change its procedures for identifying hazardous waste, or may
revise the list of hazardous wastes.   If any municipal sewage sludges
are identified or listed as hazardous by an amendment to the Section
3001 regulations (40 CFR Part 261), a notification covering these wastes
must be filed within 90 days after the amendment is promulgated.

     If a facility begins to generate a hazardous municipal sewage
sludge and has not previously filed a notification, it must comply with
the regulations for obtaining an EPA Identification Number published
under Section 3002 of RCRA (40 CFR Part 262) before it transports the
hazardous sludge or offers the hazardous sludge to a transporter.

     Similarly, if a transporter desires to transport a hazardous
municipal sewage sludge and has not previously filed a notification, the
transporter must comply with the regulations for obtaining an EPA
Identification Number published under Section 3003 of RCRA (40 CFR Part
263) before any hazardous sludge is accepted for transport.

     Conditions applicable to all RCRA hazardous waste permits are
specified in section 122.7 and 122.28 of the Consolidated Permit
Regulations as promulgated in the FEDERAL REGISTER on May 19, 1980.  These
specify a wide range of provisions concerning the hazardous waste
facilities including proper operation and maintenance [122.7(e)], monitoring
and records [T22.7(j)J, inspection rights [122.7(1)], reporting requirements
[122.7(1)], etc.
                                vii

-------
     POTWs, which accept a hazardous waste for treatment (by means otner
than what may come into the POTW in the sanitary sewer system),  would be
required to obtain a RCRA permit as a hazardous waste treatment  facility.
However, if the POTW [122.26(c)] meets the following conditions, it shall
be deemed to have an acceptable RCRA hazardous waste permit without
applying,  (This does not apply to the treatment storage and disposal of
the POTWs own sludge that originated from sewage entering the POTW in the
sanitary sewer system).

     (1)  Has an NPDES permit:

     (2)  Complies with the conditions of that permit;

     (3)  Complies with the following regulations:

          (i)   40 CFR Section 264.11, Identification number;
          (ii)  40 CFR Section 264.71, Use of manifest system;
          (.iii) 40 CFR Section 264.72, Manifest discrepancies;
          (.iv)  40 CFR Section 264.73 (a) and (b)0), Operating  records;
          (v)   40 CFR Section 264.75, Annual report;
          (yi)  40 CFR Section 264.76, Unmanifested waste report;  and

     (4)  If the waste meets all Federal, State, and local  pretreatment
          requirements which would be applicable to the waste if it were
          being discharged into the POTW through a  sewer, pipe,  or
          similar conveyance.

     General standards and interim status standards for owners and
operators of hazardous municipal sewage sludge or other hazardous  waste
treatment, storage, and disposal facilities are contained in Parts 264
and 265, respectively, of the. hazardous waste regulations.   However, the
requirements-of Parts 264 and 265 do not apply to a person who treats,
stores, or disposes of hazardous waste in a State with an authorized
RCRA hazardous waste program (authorized under Subparts A and B  of Part
123 or with a RCRA Phase II hazardous waste program authorized under
Subpart F of Part 123 of this Chapter).

     An outline of the content of the final permit  standards and the
interim status standards (Parts 264 and 265) has been included as  Appendix
C to this Program Operations Memorandum to provide  an idea of the  necessary
requirements for complying with the regulations if  a municipal sludge is
found to be hazardous.  The final permit, standards  (Part 264) have not
been fully developed.  When completed later this year, the provisions of
the final permit standards will parallel the content of the interim
status standards.
                              vm

-------
      APPENDIX A
                               Table A-l
             Total  Metals Content (HNCH -  C104 Digestion)
      of 15 Sludges and One Sludge Incinerator Ash    (EPA-Cincinnati  Results)
Location
As
          Cd
Cr
Pb
Pittsburgh
Defiance
Marion
Toledo
Cincinnati {filter cake)
Cincinnati (digested)
Cincinnati (incinerator ash) Mtll Creek
Chicago (landfill)
Chicago (Fulton)
Chicago (heat dried)
Kokomo
Dallas
Jones Island
South Shore
Tulsa
Fountain  Valley
                                                     ,ug/9  (dry wt.)
20
          70      3200      1740
          18        13       420
20       102       840       700
40        20      1740       300
 9        38      1000      1300
13        48      1260      1400
          8Q      2340      3520
13       110       920       434
14       160      2200       404
13       130      2080       3U
 4       228      1230      1560
<4        52       416       720
<4       282      6900       410
10        44      1372       700
 4        88       274       300
18        70       600       500

-------
     APPENDIX  A

                               Table  A-2

     Metals  Concentration  in  EP Extracts  of  15 Sludges
           and One Sludge  Incinerator Ash   (EPA-Cincinnati Results)


Location                                     As         Cd        Cr         Pb


Pittsburgh
Defiance
Marion
To 1 edo
Cincinnati (filter cake)
Cincinnati (digested)
Cincinnati (incinerator ash) Mill Creek
Chicago (landfill)
Chicago (Fulton).
Chicago (heat dried)
Kokomo
Dallas
Jones Island
South Shore
Tulsa
Fountain Valley
Fountain Valley (reanalysis)


<4
<4
<4
60
41
20
<20
21
14
<20
<2Q
<20
<20
<20
<4
<20
34

	 -Ug/
<0.5
3.5
<0.5
3.0
10.8
1.0
46
270
2
62
6.Q
2.4
5
15
7
81
160

1 -.-----,
<2
14
10
14
14
5
510
10
60
36
12
2
41
25
6
2
40


<0.5
<0.5
<0.5
<0.5
21
<0.5
12
12
11
f

-------
                                                       Table A-3


              Total Metals  Content in 7 Sewage Sludges  (IINf^-H^O^ Digestion by 1-l-A) Las Vegas--Tripl icate Analysis
Sample
Designation

Cincinnati, OH
sewage sludge
Chicago, IL
landfill sludge
Chicago, IL
Fulton County, digested
Chicago, IL
heat dried
Dallas, TX
primary sludge
Tulsa, OK
combined sludge
Fountain Valley, CA
sludge
As

M9/9
155

37

55

10

<9

18

51


S.D.
30

5

1

1

	

1

3

Ba

i'9/9
248

83

622

80

223

408

54


S.D.
37

5

40

17

74

6

16


M9/0
47

251

177

65

16

102

201

Cd

S.D.
2

26

4

12

3

1

9

Cr

pg/g
1182

1458

2222

528

162

277

904

Pb

S.D.
115

278

251

110

9

13

75


U9/9
1805

603

646

74

121

244

666


S.D.
126

189

34

12

4

17

13

Se

i'9/g
69

33

57

6.8

8.4

13

23


S.D.
9.2

2.7

5.7

1.6

0.9

0.6

2.5

S.D. - Standard Deviation
                                                                                                                            rn
                                                                                                                            ._,

                                                                                                                            o
                                                                                                                            i—i
                                                                                                                            x

-------
                                                        Table A-4

         Metals Concentration in EP Extracts of 7 Sludges by EPA-Las Vegas  --  Average  of  Triplicate  Extractions
Sample
Designation
Cincinnati, OH
sewage sludge
Chicago, IL
landfill sludge
Chicago, I'.
Fulton County, digested
Chicago, IL
heat dried
Dallas, TX
primary sludge
Tulsa, OK
combined sludge
Fountain Valley, CA
sludge
* "\innlp nut.lvinn us 1 IIP not
As Ba Cd
/jg/1 S.D. ^g/1 S.D. /ig/1 S.D.
31 00 530 180 18* 2
20 -- <450 — 275 93
31 6 <450 -- <20
30 12 <450 — 116 19
<20 -- 500 160 7* 3
<20 -- <450 -- <20
34 13 <450 -- 601 414
inrlnfifH in nipan
Cr
/jg/i S.D.
50 20
<40
<40
123 10
60 20
<40
70 30
Pb
/jg/1 S.D.
80 30
<70
<70
<70
<70
<70
<70
Se
yug/1 S.D.
20 10
37 1
<20
<20
30 20
<20
20 10
j»
-o
-o
m
S.O. = Standard Deviation.                                                                                            2
                                                                                                                     X

-------
APPENDIX A
                                   Table A-5

          Total and EP  Extract Contaminant Levels of one POTW Sludge*
                             {Analysis by the POTW)
Contaminant
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Sel enium
Sil ver
Copper
Iron
Nickel
Zinc
Cyanide
Minimum
EP Toxicity
Characteristic
mq/1
5.0
100.0
1 .0
5.0
5.0
0.2
1 ,0
5.0
__
__
--
--
—
EP Extract
of POTW si
Test A
6/3/80
<0.01
0,9
1 .55
0.04
0.17
0.0002
<0.01
--
..
..
--
--
--
Concentration
udqe, mg/1 Mean**
total cone.
Test 8 in POTW sludge
6/9/30 mq/1
._
1 .0
2.27 771
^0.04 1876
0.19 340
1801
--
--
4065
33700
335
8869
462
       *   Contents  of total  solids,  total  volatile  solids, and calcium
       oxide were 20, 55  and  15%  respectively.

      **   Mean  of 23  determinations  made  in  1979.

-------