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-
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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-
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(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.
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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.
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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
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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.
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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.
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