Industrial Waste
Management
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This Guide provides state-of-the-art tools and
practices to enable you to tailor hands-on
solutions to the industrial waste management
challenges you face.
WHAT'S AVAILABLE
• Quick reference to multimedia methods for handling and disposing of wastes
from all types of industries
• Answers to your technical questions about siting, design, monitoring, operation.
and closure of waste facilities
• Interactive, educational tools, including air and ground water risk assessment
models, fact sheets, and a facility siting tool.
• Best management practices, from risk assessment and public participation to
waste reduction, pollution prevention, and recycling
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;NOWLEDGEMENTS
The rdowing members of the Industrial Waste Focus Group and the Industrial Waste Steering Commiw are grateUy
acknowledged far al of their time and assistance in the development of this guidance document
Current Industrial Waste Focus
Group Members
Paul Bar*, The Dow Chemical
Company
Walter Carey. Nestle USA Inc and
New Miltord Farms
Rama Chaturvedi Bethlehem Steel
Corporation
H.C. Clark. Rice University
Barbara Dodds, League of Women
voters
Chuck Feerick. Exxon Mobil
Corporation
Stacey Ford. Exxon Mobil
Corporation
Robert Giraud OuPont Company
John Harney Citizens Round
Tabte/PURE
Kyle Isakower. American Petroleum
Institute
Richard Jarman, National Food
Processors Association
James Meiers, Cinergy Power
Generation Services
Scott Murto. General Motors and
American Foundry Society
James Roewer, Edison Electric
Institute
Edward Repa. Environmental
Industry Association
Tim Savior, International Paper
Amy Schaffer. Weyerhaeuser
Ed Skemofc, WMX Technologies. Inc
Michael Wach Western
Environmental Law Center
David Wens, University of South
Wabnms Medical Center
Pat Gwn Cherokee Nation of
Oklahoma
Past industrial Waste Focus
Group Members
Dora Cetofius. Sierra Club
Brian Forrestal. Laidlaw Waste
Systems
Jonathan Greenberg. Browning-
Ferris Industries
Michael Gregory, Arizona Toxics
Information and Sierra Club
Andrew Mites The Dexter
Corporation
Gary Robbins, Exxon Company
Kevin Sail. National Paint & Coatings
Association
Bruce SteJne. American Iron & Steel
Lisa Williams, Aluminum Association
Cuircnt Industrial Waste Steering
Committee Members
Keiiy Catalan Aaaocauon oi Slate
and Territorial Solid Waste
Management Officials
Marc Crooks, Washington State
Department ot Ecology
Cyndi Darling. Maine Department of
Environmental Protection
Jon DilDard Montana Department of
Environmental Qualty
Anne Dobbs. Texas Natural
Resources Conservation
Commission
Richard Hammond New York State
Department of Environmental
Conservation
Elizabeth Haven California State
Waste Resources Control Board
Jim Hul Missouri Department of
Natural Resources
Jim Knudson, Washington State
Department of Ecology
Chris McGuire, Florida Department
of Environmental Protection
Gene Mitchell Wisconsin
Department of Natural Resources
William Pounds, Pennsylvania
Department of Environmental
Protection
Bijan Sharafkhani Louisiana
Department of Environmental
Qualty
James Warner, Minnesota Pollution
Control Agency
ittustrial Waste Steering
Pamela um*. nianie
Environmental Protection
NormGumenik Arizona Department
of Environmental Qualty
Steve Jenkins, Alabama Department
of Environmental Management
Jim North Arizona Department of
Environmental Quality
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Industrial waste is generated by the production
of commercial goods, products, or services.
Examples include wastes from the production
of chemicals, iron and steel, and food goods.
-------
United States
Environmental Protection
Agency
Solid Waste
and Emergency Response
(5306W)
EPA530-R-97-002
September 1997
http://www.epa.gov
Source Reduction Program
Potential Manual
A Planning Tool
DRY CLEANER
$$ Printed on paper that contains at least 20 percent postconsumer fiber.
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Contents
About This Manual v
Glossary v
Chapter 1: Introduction 1
What Is Source Reduction? 1
What Is Program Potential? 1
What Is a Program Potential Factor? 2
Chapter 2: Program Potential 3
Gathering Data 3
Calculating Program Potential 3
Chapter 3: Residential Source Reduction Options 5
National Program Potential 5
Grasscycling 5
Home Composting—Food Scraps 6
Home Composting—Yard Trimmings 7
Clothing and Footwear Reuse 8
Chapter 4: CII Source Reduction Options 11
National Program Potential 11
Office Paper Prevention 11
Reducing Office Paper Through Duplex Copying 12
Reducing Office Paper Through Computer Networking 12
Converting to Multi-Use Pallets 13
Paper Towel Reduction 14
Chapter 5: Local Applications 17
Introduction 17
Program Potential Factors 17
Scenarios 17
Scenario 1: Anywhere 18
Scenario 2: Commuterburgh 19
Scenario 3: Fullville 20
Chapter 6: Worksheets 23
in
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List of Tables
Table 2.1 The 1994 National Solid Waste Stream 3
Table 3.1 National Program Potential for Residential Source Reduction Options 5
Table 4.1 National Program Potential for CII Source Reduction Options 11
Table 5.1 National Program Potential for Six Source Reduction Options 17
Table 5.2 Program Potential Factors 18
Table 5.3 Default Waste Composition (Percent by Weight)—National Default Data 18
Table 5.4 Waste Generation—National Default Data 18
Table 5.5 Anywhere—Waste Composition 19
Table 5.6 Anywhere—Program Potential 19
Table 5.7 Commuterburgh—Grasscycling 19
Table 5.8 Fullville—CII Waste Composition 20
Table 5.9 Fullville—CII Program Potential 21
Table 5.10 Fullville—Net Savings of an Office Paper Prevention Program 22
Table 6.1 Standard Program Potential Factors 27
List of Figures
Figure 2.1 The Procedure for Estimating Program Potential for Source Reduction 4
Figure 3.1 Program Potential for Grasscycling 6
Figure 3.2a Program Potential for Home Composting Food Scraps 7
Figure 3.2b Program Potential for Home Composting Yard Trimmings 8
Figure 3.3 Program Potential for Clothing and Footwear Reuse 9
Figure 4.la Program Potential for Office Paper Reduction (Duplexing) 12
Figure 4.1b Program Potential for Office Paper Reduction (Networking) 13
Figure 4.2 Program Potential for Converting to Multi-Use Pallets 14
Figure 4.3 Program Potential for Reducing Paper Towels 15
IV
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About This Manual
his manual is designed to help local solid waste managers determine the potential impact of
various source reduction options. The manual examines the program potential, or the portion
of a waste stream category that could be addressed by a specific source reduction program.
Analyzing program potential can help solid waste managers decide whether to include source
reduction in their integrated solid waste management plans.
Using data on the national municipal solid waste stream, this manual calculates the program poten-
tial for six source reduction options: three residential options (grasscycling, home composting, and cloth-
ing reuse) and three commercial, industrial, and institutional options (office paper reduction, converting
to multi-use pallets, and paper towel reduction). It then shows managers how to calculate program
potential locally by applying their own data.
While the manual acts as a planning guide for source reduction programs, it does have some limita-
tions. First, the manual is limited to estimating the potential of source reduction programs. The actual
tonnage reduction achieved by a source reduction program will depend on the effectiveness of the pro-
gram's implementation. Second, the manual is not a "how to" document for designing and implement-
ing a source reduction program. Finally, the manual does not specifically address reducing the toxicity
of the waste stream.
To make it easier to calculate program potential, companion software is also available. To order, call
the Resource Conservation and Recovery Act Hotline at 800 424-9346.
Glossary
he following is a list of terms that appear frequently throughout this manual. Readers may
wish to keep this list handy so they can refer to it as they proceed through the document.
Applicability Factor: This factor narrows the tonnage of the general waste category to that of the specif-
ic waste category relevant to the source reduction option.
CII: Solid waste activities associated with the commercial, industrial, and institutional sectors.
Feasibility Factor: This factor narrows the tonnage of the specific waste category to reflect only the por-
tion that could feasibly be reduced.
Program Potential: The portion of a waste stream category that could be addressed by a specific source
reduction program.
Program Potential Factor: A percentage that, when applied to the tonnage of a general waste category,
yields the program potential of a specific source reduction option.
Source Reduction: Activities designed to reduce the volume or toxicity of the waste stream, including
the design and manufacture of products and packaging with minimum toxic content, minimum volume
of material, and/or a longer useful life.
Technology Factor: This factor accounts for any waste that might remain in the waste stream, as a result
of technical or physical limitations, even after the source reduction option is implemented successfully.
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Chapter 1
Introduction
n February 1989, the U.S. Environmental
Protection Agency (EPA) published the report
The Solid Waste Dilemma: An Agenda for Action.
This report called for the adoption of "a new
solid waste management ethic" reflected in what
has come to be referred to as the "solid waste man-
agement hierarchy." While acknowledging varia-
tions in local conditions, the hierarchy established
a preferred order to municipal solid waste (MSW)
management. Source reduction was at the top of
the hierarchy, followed by recycling (including
composting) and disposal (including combustion
and landfilling).
What Is Source
Reduction?
EPA defines source reduction as activities
designed to reduce the volume or toxicity of waste
generated, including the design and manufacture of
products with minimum toxic content, minimum
volume of material, and/or a longer useful life.
Source reduction is fundamentally different from
the other elements of the solid waste hierarchy.
Recycling and disposal options all come into play
after goods have been used. Source reduction, in
contrast, takes place before materials have been
identified as "waste." To implement source
reduction, solid waste managers need to promote
practices that reduce waste before it is generated.
A variety of practices exist to promote source
reduction in local communities. These practices
affect both the residential and the commercial,
industrial, and institutional (CII) sectors. This
manual focuses on six source reduction options:
Residential Sector Options:
» Grasscycling
« Home composting
« Clothing and footwear reuse
CII Sector Options:
» Office paper reduction
» Converting to multi-use pallets
» Paper towel reduction
These six options were chosen because they
have been implemented in communities across the
country and, in some cases, have contributed sig-
nificantly to local solid waste management efforts.
What Is Program
Potential?
Before implementing a source reduction pro-
gram, managers need to determine the portion of
their waste stream that could be addressed by
source reduction. This manual refers to this por-
tion as "program potential."
Understanding program potential helps man-
agers determine whether a specific source reduc-
tion program makes sense for their community.
This decision is ultimately based on whether a
program has the potential to reduce a significant
portion of the waste stream in a cost-effective
manner. Calculating program potential is the first
step in determining whether to implement source
reduction programs locally.
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Chapter 1
What Is a Program
Potential Factor?
This manual develops program potential fac-
tors, or percentages, based on the national pro-
gram potential results. To calculate the program
potential for their local waste stream, solid waste
managers can multiply the tonnage of a specific
component of their local waste stream by the cor-
responding program potential factor from Table
5.2. For example, the grasscycling calculation in
Chapter 3 identifies the national tonnage of yard
trimmings that could be prevented if homeowners
left their grass clippings on the lawn. The program
potential factor represents the national program
impact in tonnage, 9.1 million tons, as a percent-
age, 33.1 percent, assuming that all homeowners
left their grass clippings on the lawn.
Using this percentage, or program potential fac-
tor, managers can convert their waste stream gen-
eration tonnage into program potential. For
example, by multiplying the tonnage of yard trim-
mings generated locally by 33.1 percent, managers
can estimate the program potential for diverting
grass clippings from the waste stream in their
community. Managers interested in customizing
the analysis to better reflect local conditions may
want to review the assumptions underlying the
calculation of the national program potential and
make adjustments to the program potential fac-
tors, as appropriate. The worksheets in Chapter 6
will help managers with these calculations.
Program Potential
Factors
Program potential factors represent the
impact of a source reduction program
option as a percentage rather than as a
tonnage. To arrive at a quick estimate of
program potential, solid waste managers
can multiply the tonnage of a specific
component of their local waste stream by
the corresponding program potential fac-
tor. For managers interested in developing
customized program potential factors
based on local data, Chapter 5 describes
the method for calculating program
potential factors.
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Chapter 2
Program Potential
o calculate program potential, solid
waste managers will need to:
» Gather or estimate data on the tonnage and
composition of their MSW stream.
» Apply a set of program potential factors to their
local waste stream data.
Gathering Data
Program potential can be calculated using
either national or local data. Chapters 2,3, and 4
of this manual explain how to calculate program
potential using national data. Chapter 5 and the
companion software show managers how to calcu-
late program potential using local data or a combi-
nation of national and local data.
The basic source of national data on the MSW
stream is EPA's Characterization of Municipal Solid
Waste in the United States: 1994 Update (the '94
Update,) and 1995 Update (the '95 Update). These
documents present current information on the vol-
ume and composition of MSW, as well as projec-
tions for the future. Table 2.1 summarizes the
information for 1994 presented in the '95 Update.
Most of the information in the '95 Update is not
based on direct measurement (i.e., sampling mea-
surement). Instead, it is developed from a "cradle-
to-grave" analysis of the materials flow in the U.S.
economy. Managers unfamiliar with this approach
may wish to consult the '95 Update. Understanding
the methods used in the '95 Update is not required
for using this manual.
Calculating Program
Potential
Program potential can be calculated using the
equation shown in Figure 2.1. This equation limits
the tonnage of a general waste category to the por-
tion of a specific waste category that could be
addressed by a source reduction program, or the
program potential.
Table 2.1. The 1994 National Solid Waste Stream*
General Waste
Category
Paper and
paperboard
Glass
Metals
Plastics
Wood
Food scraps
Yard trimmings
Other
Total
Residential Waste
Generated
(Million Tons)
36.4
10.7
10.3
15.3
3.5
7.0
27.5
10.0
120.7
CM Waste Generated
(Million Tons)
44.9
2.5
5.5
4.5
11.1
7.1
3.1
9.6
88.3
All
Waste Generated
(Million Tons)
81.3
13.2
15.8
19.8
14.6
14.1
30.6
19.6
209.0
* EPA's Characterization of Municipal Solid Waste in the United States: 1995 Update.
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Chapter 2
For example, consider a source reduction pro-
gram intended to keep grass from entering the
MSW stream. Grasscycling programs simply
encourage homeowners to leave grass clippings
on their lawns rather than bag and dispose of
them. To develop an estimate of program poten-
tial for grasscycling, the first step is to narrow the
tonnage of grass in yard trimmings that is resi-
dential. Next, the applicable grass tonnage is fur-
ther narrowed to reflect an estimate of the portion
of grass cut with nonmulching mowers and the
portion of grass clippings left on the lawn under
current grasscycling programs. Finally, technolog-
ical limitations must be taken into consideration.
The program potential calculation yields a value
representing the amount of material available for
source reduction by a given program.
The program potential equation shown in
Figure 2.1 involves four steps:
» Step 1: Identify the general waste stream cate-
gory relevant to the source reduction option
being considered and specify its tonnage. For
example, when estimating the program
potential for grasscycling, the general waste
stream category is yard trimmings. Its ton-
nage is shown in Table 2.1.
» Step 2: Multiply by an "applicability factor."
The applicability factor reduces the tonnage
of the general waste category to a specific
waste category directly relevant to the option
under consideration. For grasscycling, this is
the portion of yard trimmings that is grass
generated by the residential sector.
» Step 3: Multiply by a "feasibility factor." This
factor reduces the portion of the specific
waste category to the tonnage that feasibly
could be reduced through source reduction
efforts. For grasscycling, this involves esti-
mating the portion of grass reduced through
current grasscycling programs.
» Step 4: Multiply by a "technology factor."
This factor takes into account any technical or
physical limitations to the option under con-
sideration. For grasscycling, there are no limi-
tations—that is, all of the portion identified in
Step 3 could be addressed by a source reduc-
tion program.
Multiplying the general waste category ton-
nage by these three factors results in a tonnage
of waste that could be addressed by a source
reduction program, assuming 100 percent
participation in the program.
Calculations performed in Chapters 3 and 4
make use of national data to estimate program
potential; local data may differ. Chapter 5 pro-
vides an opportunity to incorporate local data
into the calculations.
Figure 2. 1. The procedure for estimating program potential for source reduction.
General Waste
Stream Data
Detailed Information on Waste Stream
and Potential Program Participants
Limitations of the
Technology
I
General Waste
Category
I
Technology
Factor
Program
Potential
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Chapter 3
Residential Source
Reduction Options
National Program
Potential
.-•" ; .,•
his chapter presents estimates of national
program potential for three residential
source reduction program options: grasscy-
cling, home composting, and clothing
reuse. As Table 3.1 shows, the national program
potential associated with these three options in
1994 is 23.7 million tons.
Grasscycling programs are one of the simplest
ways to divert organic materials from the MSW
stream. This manual focuses on how mulching mow-
ers are used in residential grasscycling programs.
Grasscycling programs encourage homeowners
to leave grass clippings on their lawns rather than
bag and dispose of them. According to the
Composting Council and many other community
programs, grasscycling not only diverts a signifi-
cant portion of the waste stream, but also
provides an excellent source of nutrients for the
lawn. Grasscycling can be accomplished with the
help of mulching mowers. Mulching mowers' fine
chopping blades help speed up grass clipping
degradation. Many mowers sold today are capa-
ble of mulching, and old mowers can be retrofit to
mulch or re-cut grass clippings.
Historically, most grasscycling programs rely on
public education to encourage households to
grasscycle. This typically involves developing and
distributing pamphlets that explain the various
benefits of grasscycling. These benefits include
decreasing homeowners' fertilizer and water bills,
saving the time and energy spent bagging and
hauling grass clippings, and reducing the amount
of material in the waste stream. Press releases,
brochures, and newspaper, radio, and television
advertisements are all means of communicating
the benefits of grasscycling programs.
Program Potential
• General Waste Category. The general waste cat-
egory addressed by grasscycling is yard trim-
mings. As shown in Table 2.1, the yard
trimmings tonnage reported in the '95 Update is
30.6 million tons.
Table 3.1. National Program Potential for Residential Source Reduction Options
Source Reduction
Option
Component of MSW
Reduced
Program Potential
(Million Tons)
Grasscycling
Yard trimmings
9.1
Home composting
Food scraps & yard
trimmings
13.0
Clothing and footwear reuse
Other
1.6
Total
23.7
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Chapter 3
Applicability Factor. This factor reduces the
general waste tonnage to reflect only the ton-
nage of grass generated by the residential sec-
tor. Data in the '95 Update show that
approximately 50 percent of yard trimmings
are grass clippings. The '94 Update states that
90 percent of the grass clippings are generated
by the residential sector. Therefore, the applic-
able portion of yard trimmings is 45 percent
(0.5x0.9).
Feasibility Factor. Since there are no national
data on the number of households that cur-
rently grasscycle, several assumptions must
be made to take current practices into
account. First, the lawn mower manufacturer
Toro estimates that 99 percent of residential
households use power mowers to mow their
lawns. According to Toro, 26 percent of the
power mowers used are mulching mowers.
In addition, local grasscycling programs
encourage people without mulching mowers
to grasscycle. Lacking any national data on
these programs, it is assumed that 10 percent
of the people currently using nonmulching
mowers are grasscycling. Therefore, the por-
tion of residential grass feasible to be source
reduced through grasscycling is 66 percent
(0.99x0.74x0.9).
Technology Factor. The technology factor
is 100 percent, because all grass that is left on
lawns is removed from the waste stream.
Program Potential. The national program
potential is 9.1 million tons per year.
Home composting programs are an increas-
ingly popular residential source reduction pro-
gram option. By composting, households can
divert large percentages of their food scraps and
yard trimmings from the waste stream.
Home composting programs are typically
organized at the county or city level and involve
educating homeowners about proper compost-
ing practices and encouraging the diversion of
all organic materials. Many communities with
backyard composting programs implement pub-
lic education and outreach programs to encour-
age homeowners to compost. These entail
distributing flyers and brochures, producing
videos and radio advertisements, and display-
ing home composting bins with instructions and
information at public events, gardens, and home
gardening stores.
In addition, many communities develop
"Master Composter Programs." In these pro-
grams, a compost specialist trains a group of vol-
unteers, who become "Master Composters."
They in turn train others in the community on
proper composting techniques.
Program Potential
Unlike the other source reduction options
considered in this manual, home composting
applies to two major categories of the waste
stream—food scraps and yard trimmings. To
estimate the program potential for home com-
posting, the contribution of these two categories
Figure 3.1. Program potential for grasscycling.
General Waste
Category
Yard trimmings
generated
Applicability
Factor
Grass as percentage
of yard trimmings
generated by
residential sector
Feasibility
Factor
Percentage of grass
that is not currently
grasscycled
Technology
Factor
All grass left
on a lawn is
source reduced
Program Potential
9.1 million tons
per year
30.6 million tons
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Residential Source Reduction Options
needs to be addressed separately. The calculation
for food scraps, shown in Figure 3.2a, is presented
here in detail. The analysis for yard trimmings,
shown in Figure 3.2b, is summarized at the end of
this section.
« General Waste Category. The general waste cat-
egory addressed by home composting is food
scraps. As shown in Table 2.1, 14.1 million tons
of food scraps were generated by the residential
and commercial sectors in 1994.
• Applicability Factor. This factor reduces the
waste tonnage to reflect only the tonnage of
residential food scraps that are compostable.
According to a waste composition study by
William Rathje, Director of the Garbage
Project at the University of Arizona, 72
percent of food scraps are compostable. This
exempts meat, fish, cheese, milk, and fats and
oils. In addition, the '94 Update estimates that
50 percent of food scraps are generated by the
residential sector. Therefore, the portion of
waste that is generated by the residential
sector and is compostable is 36 percent (0.72 x
0.5).
• Feasibility Factor. The residential tonnage is
narrowed further to reflect only food scraps that
could feasibly be home composted. According
to the Statistical Abstract of the United States,
approximately 75 percent of the population
lives in one to four unit residences and is likely
to have the space to home compost. Absent
actual data on food scrap composting, it is
assumed that 1 percent of households in the
nation currently compost in their backyard and
that 99 percent do not. Therefore, the portion of
food scraps that feasibly could be reduced is 74
percent (0.75x0.99).
Technology Factor. The technology factor is 100
percent, because backyard composting removes
all of the food scraps that are composted from
the waste stream.
Program Potential. The program potential for
home composting of food is therefore 3.8 mil-
lion tons per year.
In the analysis of home composting of yard
trimmings, only the general waste category and
applicability factor need to be changed. The yard
trimmings tonnage, as shown in Table 2.1, is 30.6
million tons. Based on the '94 Update, 90 percent
of yard trimmings come from the residential sec-
tor. Making a 10 percent allowance for large items,
such as tree trunks and large limbs that are not
easily compostable, the applicability factor for
yard trimmings is 81 percent (0.9 x 0.9). The feasi-
bility and technology factors developed for food
scraps apply equally well to yard trimmings. Also,
for this example, the 9.1 million tons of program
potential for grasscycling is excluded to avoid
double counting. The national program potential
for composting yard trimmings is 9.2 million tons
(30.6x0.81x0.74x100-9.1).
Combining the program potentials for home
composting of food scraps (3.8 million tons) and
yard trimmings (9.2 million tons) yields a
national program potential for home composting
of 13.0 million tons. However, if the program
potential for grasscycling is not excluded, the
national program potential for yard trimmings is
22.1 million tons a year.
Figure 3.2a. Program potential for home composting food scraps.
General Waste
Category
Food scraps
generated
Applicability
Factor
Percentage of
compostable
food scraps
generated by the
residential sector
Feasibility
Factor
Percentage of
residences that
could feasibly
home compost
but currently
do not
Technology
Factor
All composted
food scraps are
source reduced
Program Potential
3.8 million tons
per year
14.1 million tons
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Program Potential
A residential textile collection program
provides an efficient and convenient opportuni-
ty for residents to extend the useful life of
unwanted textile goods, such as clothing and
footwear. Communities can establish drop-off
collection sites, offer periodic curbside
collection, or integrate textiles into their on-
going curbside collection programs. This manual
assumes that all collection approaches for
textiles have the same source reduction program
potential.
This manual focuses solely on the collection
of clothing and footwear for reuse. Most
residential collection programs, however, collect
other textiles as well, such as sheets, towels, and
draperies. Reuse opportunities for clothing and
footwear include reuse as secondhand clothing,
both domestic and foreign, and as wiping or
polishing rags.
Local agencies that have instituted residential
textile collection programs concur that public
education is a key component to success. Many
communities encourage residents to first donate
items to local charities, and then give what these
nonprofits cannot use to the local collection pro-
gram. This often results in increased donations to
charities, as well as a high level of residential
collection.
General Waste Category. The general waste
category addressed by textile collection is other
waste. As shown in Table 2.1, 19.6 million tons
of other waste were generated in 1994, as
reported in the '95 Update.
Applicability Factor. This factor reduces the
general waste tonnage to reflect the portion of
other waste consisting of residential clothing
and footwear that is currently not recovered.
According to the '95 Update, 4.5 million tons of
clothing and footwear are generated annually,
representing approximately 23 percent of other
waste. The '94 Update estimates that 60 percent,
or 2.7 million tons, of clothing and footwear is
generated by the residential sector.
According to the Council for Textile Recycling
(CTR), approximately 1.25 million tons of
postconsumer textiles are recovered annually.
This figure represents all types of textiles from
various sources. CTR describes the flow of
textiles as first being donated to nonprofit,
charitable organizations, such as Goodwill
and Salvation Army, which in turn sell any
unusable textiles to businesses, such as textile
dealers and brokers.
Of the 1.25 million tons of textiles recovered, the
portion that is only clothing and footwear donat-
ed by households must be derived. Goodwill
estimates that 95 percent of the textiles it receives
Figure 3.2b. Program potential for home composting yard trimmings.
General Waste
Category
Yard
trimmings
generated
30.6
million tons
Applicability
Factor
Percentage of
compostable yard
trimmings
generated by
residential sector
Feasibility
Factor
Percentage of
residences that
could feasibly
home compost
but currently
do not
Technology
Factor
All composted
yard trimmings
are
source reduced
National
program
potential
for
grasscycling
9.1
million tons
Program
Potential
9.2
million tons
per year
*excluding the national program potential for grasscycling.
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Residential Source Reduction Options
consists of clothing and footwear. In addition,
Goodwill also estimates that 90 percent of its tex-
tile donations come from households. Applying
this figure for all nonprofits accepting textiles,
85.5 percent (0.95 x 0.90) of the textiles recovered
is clothing and footwear from households, which
translates to 1.07 million tons annually. By sub-
tracting the amount of clothing and footwear
donated by households from the total amount of
residential clothing and footwear generated, 1.63
million tons, or 60 percent, could be targeted for
a source reduction program. Therefore, the
applicable portion of other waste generated is 8.3
percent (0.23x0.60x0.60).
Feasibility Factor. To derive the feasibility
factor, the portion of recovered residential cloth-
ing and footwear that is available for reuse
must be calculated. Of the clothing and
footwear donated to nonprofits, a portion is
reused and the remainder is sold to businesses.
Goodwill estimates that 50 percent of the cloth-
ing and footwear received is sold in its stores
and reused. The remaining 50 percent is sold to
businesses. What these businesses do with the
textiles must also be considered. CTR estimates
that these businesses reuse and reprocess 94
percent as secondhand clothing, wiping and
polishing cloths, or are used to make similar
textile items. Thus, the feasibility factor is 97
percent [0.50 + (0.50 x 0.94)].
Technology Factor. The technology factor is
100 percent, since clothing and footwear cap-
tured via a residential collection program
and reused is removed from the waste
stream.
Program Potential. As shown in Figure 3.3,
the national program potential for a residen-
tial clothing and footwear collection program
is 1.6 million tons per year.
CASE STUDY:
Montgomery County,
Maryland
In 1993, Montgomery County, Maryland, ini-
tiated a textile collection program consisting
of a drop-off site for residents and "curb-
side" collection for five charities. The county
developed a brochure that described the
program and also listed charities, shelters,
consignment shops, and used clothing stores
accepting textile donations. The brochure
was made available at libraries and county
offices and also mailed to residents upon
request. The county collects approximately
156 tons of textiles annually. Dumont, a tex-
tile dealer, pays the county a flat rate of
$80.00 per ton for the collected textiles.
Figure 3.3. Program potential for clothing and footwear reuse.
General Waste
Category
Other
waste
generated
19.6 million tons
Applicability
Factor
Percentage of other
waste that is
residential clothing
and footwear
X
Feasibility
Factor
Percentage of
residential clothing
and footwear
recovered that can
be reused
X
Technology
Factor
Percent of
residential clothing
and footwear that is
diverted by
recovery and reuse
Program Potential
1.6 million tons
per year
-------
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Chapter 4
CII Source
Reduction Options
National Program
Potential
his chapter presents estimates of national
program potential for three CII source
reduction program options: reducing
office paper, converting to multi-use
wooden pallets, and reducing paper towels. Table
4.1 shows that, for 1994, the national program
potential associated with these three options is 3.1
million tons.
Table 4.1. National Program Potential for CII
Source Reduction Options
Source Component of Program
Reduction MSW Reduced Potential
Option (Million Tons)
Office paper
prevention
Paper and
paperboard
1.3
Converting to
multi-use
pallets
Wood
1.6
Paper towel
reduction
Paper and
paperboard
0.2
Total
3.1
To calculate the program potential for reducing
office paper, two source reduction strategies were
assumed:
» All office copy paper could be subject to a
duplex copying initiative.
» For those businesses that have some computer
network capability, the amount of paper cur-
rently used in laser printers can be reduced
through electronic mail, electronic postings, and
document sharing via common files. While
increased use of networking could itself reduce
the demand for copying, this manual does not
include the effect of this complex interaction.
The results from the two strategies are com-
bined to represent an approximate total program
potential for reducing office paper.
Office paper reduction programs often entail
setting a corporate goal for paper reduction, publi-
cizing that goal through posters, flyers, and com-
pany newsletters, and encouraging employees to
adopt specific paper reduction strategies.
CASE STUDY:
U.S. Environmental
Protection Agency
Launched in 1994, EPA's Paper-Less Office
Campaign set a goal to reduce the amount
of white office paper used throughout the
Agency by 15 percent. The campaign
encouraged employees to use specific
strategies such as making duplex copies
and increasing the use of computer net-
working. EPA exceeded its goal in 1995 by
reducing photocopying by 16.1 percent.
11
-------
Program Potential
General Waste Category. The general waste cat-
egory addressed by office paper reduction is
paper and paperboard. As shown in Table 2.1,
the paper and paperboard tonnage reported in
the '95 Update is 81.3 million tons.
Applicability Factor. This factor reduces the
waste tonnage to reflect only the tonnage of
paper and paperboard used for photocopying.
According to CAP Ventures, a trade association
that tracks office paper use, 2.12 million tons of
office paper were used in photocopiers in 1994.
This represents about 2.6 percent of the paper
and paperboard waste reported in the '95
Update. Therefore, the portion of applicable
paper is 2.6 percent.
Feasibility Factor. The office paper tonnage is
narrowed further to identify the portion of copi-
er paper that could be duplexed easily.
According to INFORM Inc., a nonprofit research
organization, 1.1 percent of copier paper is used
in copy machines that have no duplex capabili-
ties. An additional 26 percent of copier paper is
used by copiers with limited duplex capabili-
ties, so only 73 percent of copier paper is used
in machines with complete duplexing capabili-
ties. Also, 20 percent of copies from machines
with duplex capabilities have already been
printed on both sides. Therefore, 58 percent
(0.73 x 0.8) of copier paper could feasibly be
source reduced.
Technology Factor. With maximum participation,
an office could use approximately 50 percent less
paper by duplexing instead of single-siding copies.
Therefore, the technology factor is 50 percent.
Program Potential. As shown in Figure 4.la, the
program potential for reducing office paper use
through duplex copying is 613,000 tons per year.
Program Potential
General Waste Category. As in the analysis of
duplex copying, the general category of waste
addressed by office paper reduction through
computer networking is paper and paperboard.
As shown in Table 2.1, the paper and paper-
board tonnage reported in the '95 Update is 81.3
million tons.
Applicability Factor. This factor reduces the
waste tonnage to reflect only the tonnage of
office paper used in laser printers. According to
CAP Ventures, 1.3 million tons of paper were
used in laser printers in 1994. This represents
about 1.6 percent of paper and paperboard gen-
erated. Thus, the portion of applicable paper is
1.6 percent.
Feasibility Factor. This factor reflects the per-
centage of businesses that have computer net-
working capabilities. Based on the information
from a 1994 survey by the Electronic Messaging
Association, 65 percent of the branch offices of
Figure 4.1a. Program potential for office paper reduction (duplexing).
General Waste
Category
Paper and
paperboard
generated
81.3 million tons
Applicability
Factor
Percentage of
paper and
paperboard that
is used in
photocopiers
Feasibility
Factor
Percentage of
copier paper
used in copiers
with good duplexing
capacity that is
not duplexed
Technology
Factor
Duplexing copies
saves half the
amount of paper
used for
single-sided
copies
Program Potential
613,000 tons
per year
12
-------
CII Source Reduction Options
Fortune 2000 companies have local area net-
works (LANs). In the absence of data on
networking capabilities throughout the CII
sector, the 65 percent figure is used to represent
networking capabilities in offices. It is further
assumed that 10 percent of computer printer
paper use is already being prevented by compa-
nies' use of networks to reduce printing.
Therefore, 59 percent (0.65 x 0.90) of printer
paper can feasibly be source reduced.
Technology Factor. It is assumed that 90 percent
of paper used in laser printers can be reduced
through computer networking, leaving 10 per-
cent of a company's documents as being neces-
sary to be printed out for review, distribution,
or similar purposes. Therefore, the technology
factor is 90 percent.
Program Potential. As shown in Figure 4.1b, the
program potential for reducing office paper
through the use of increased computer network-
ing is estimated to be 690,700 tons per year.
Wooden pallets are used extensively in trans-
portation packaging. Most of these pallets are
designed to be used a number of times, yet a sub-
stantial number are still "single-use." This section
focuses on promoting the replacement of single-use
wooden pallets with reusable or multi-use wooden
pallets.
Multi-use wooden pallets are typically used in
closed-loop delivery systems, such as in grocery
stores—the largest users of multi-use pallets. Closed-
loop systems help guarantee that the multi-use
pallets, which are more durable and expensive than
single-use pallets, are reused as often as possible. The
nature of a delivery system places constraints on
whether a multi-use pallet is a feasible alternative to
single-use pallets. These limitations are addressed in
the discussion below. Recent studies by the National
Recycling Coalition and other organizations have
mentioned alternatives to pallets, including strap-
ping and slip sheets. While these do represent
options for source reduction, the analysis here is
focused on reductions associated with converting to
multi-use pallets.
Program Potential
• General Waste Category. The general waste cate-
gory addressed by converting to multi-use wood-
en pallets. As shown in Table 2.1, the wood ton-
nage reported in the '95 Update is 14.6 million tons.
« Applicability Factor. This factor reduces the
waste tonnage to reflect only the fraction of
national wood generation that is wooden pallets.
According to the '95 Update, 70 percent of wood
generated is wood packaging. Further, 94 percent
of wood packaging generated is pallets. Thus,
the amount of applicable wood waste is 65 per-
cent (0.70 x 0.94).
• Feasibility Factor. The wooden pallet tonnage is
narrowed still further to identify the amount that
feasibly could be reduced. According to the '95
Update, about 48 percent of pallets are single-use.
In addition, not all single-use pallet users can con-
vert to multi-use pallets due to various con-
straints. In theory, all single-use pallets could be
reused. In reality, however, one of the major logis-
tical limitations to developing a multi-use pallet
program is the back hauling necessary to reuse
Figure 4.1b. Program potential for office paper reduction (networking).
General Waste
Category
Paper and
paperboard
generated
81.3 million tons
Applicability
Factor
Percentage of paper
and paperboard that
is used in laser
printers X percentage
of paper used by
CII sector
Feasibility
Factor
Percentage of
businesses/
agencies connected
to LANs that are not
using them to
source reduce
Technology
Factor
Percentage of office
paper that can be
avoided through
networking
Program Potential
690,700 tons
per year
13
-------
pallets within a closed-loop system. Based on this
limitation and similar logistical requirements
involved with establishing such a program, it is
estimated that 50 percent of single-use pallet users
can convert to multi-use pallets. Thus, the portion
of wooden pallets that could feasibly be source
reduced is 24 percent (0.48 x 0.5).
Technology Factor. According to the U.S. Forest
Service Laboratory, multi-use wooden pallets
have a 15 percent loss rate. Single-use pallets,
by definition, have a 100 percent loss rate.
Therefore, a system using only multi-use wood-
en pallets will require only 15 percent of the
pallets of a system using only single-use pallets.
This does not mean that reusable pallets have a
technology factor of 85 percent; an adjustment
must be made for the fact that reusable pallets
are heavier than single-use pallets. According to
the National Wooden Pallet and Container
Association, a multi-use pallet is twice as heavy
as a single-use pallet. The technology factor for
multi-use wooden pallets is 70 percent (1.00 -
[0.15x2.0]).
Program Potential. As shown in Figure 4.2, the
program potential for converting to multi-use
pallets is 1.6 million tons per year.
The CII sector can prevent waste by looking
into paper towel options in restrooms. Source
reduction efforts can include installing roll paper
towel dispensers, cloth towel dispensers, or hot air
dryers. This manual focuses on the program
potential for using roll paper towel dispensers as
one example of a paper towel reduction program.
CASE STUDY:
Cambridge,
Massachusetts
The city of Cambridge, Massachusetts,
recently performed a study to calculate
the potential paper and cost savings for a
paper towel reduction program imple-
mented at its city offices, where it employs
2,605 people. Currently, the city uses
multi-fold paper towels. It estimated that
in order to switch to roll paper towels, it
would need to install 135 dispensers, at
$35.00 each, including the labor required
to install them. The total cost of imple-
mentation would be $4,725.00. Potential
cost savings were estimated to be
$12,488.00 per year. The amount of waste
prevented would be 1.68 million square
feet of paper towels, or 7.5 tons.
Program Potential
General Waste Category. The general category
of waste addressed by paper towel reduction is
paper and paperboard. As shown in Table 2.1,
the paper and paperboard tonnage reported in
the '95 Update is 81.3 million tons.
Applicability Factor. This factor reduces the
waste tonnage to reflect only the tonnage of
national paper and paperboard generation that
is paper towels. According to the American
Forest & Paper Association, 2.0 million tons of
paper towels were produced in 1993. This
Figure 4.2. Program potential for converting to multi-use pallets.
General Waste
Category
Wood
generated
14.6 million tons
Applicability
Factor
Percentage of wood
that is wooden
pallets
Feasibility
Factor
Percentage of
wooden pallets that
are single-use
pallets that can
be replaced by
multi-use pallets
Technology
Factor
Percentage of
savings in wood
tonnage if substitute
multi-use for
single-use pallets
Program Potential
1.6 million tons
per year
14
-------
CII Source Reduction Options
represents about 2.4 percent of total paper and
paperboard waste generation. According to the
'94 Update, 40 percent of paper towel waste is
generated by the CII sector. Thus, the portion of
applicable waste is 1 percent (0.024 x 0.4).
Feasibility Factor. The paper towel tonnage is
narrowed further to identify the percentage that
feasibly can be reduced. According to paper
towel distributors, approximately 60 percent of
paper towel production for the CII market are
multi-fold towels. It is also assumed a small
percentage of establishments will not switch to
roll towels for a variety of reasons. Therefore,
the portion of paper towel waste that could fea-
sibly be reduced is 60 percent.
» Technology Factor. The technology factor
reflects the amount of paper towel reduction
due to switching from multi-fold to roll paper
towels. In a 1994 newsletter article by the
Building Owners and Managers Association
(BOMA) of New York, a paper industry offi-
cial presented a method for estimating the
waste preventable by switching from multi-
fold to roll paper towels. It is estimated that
switching to roll paper towels could reduce
waste by up to 50 percent.
» Program Potential. As shown in Figure 4.3, the
program potential for reducing paper towels by
replacing multi-fold towels with roll paper tow-
els is estimated to be 243,900 tons per year.
Figure 4.3. Program potential for reducing paper towels.
General Waste
Category
Paper and
paperboard
generated
81.3 million tons
Applicability
Factor
Feasibility
Factor
Percentage of
multi-fold paper
towels feasible
to target
Percentage of
paper towels that
are multi-fold
Technology
Factor
Percentage of
paper saved by
switching from
multi-fold to roll
paper towels
Program Potential
243,900 tons
per year
15
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Chapter 5
Local Applications
Introduction
he results presented in Chapters 3 and 4
indicate that the program potential for
source reduction at the national level
could be quite large. Table 5.1 summarizes
the national program potential for the six source
reduction options discussed in this manual.
Chapter 5 builds on the previous chapters by
examining how national program potential can be
applied at the local level. This chapter provides
three examples illustrating how solid waste man-
agers can calculate the source reduction program
potential for their own local programs.
Program Potential Factors
The first step in calculating local estimates for
source reduction program potential is to develop
program potential factors. Program potential fac-
tors are derived by dividing the national program
potential for a specific source reduction option
(e.g., grasscycling), as shown in Table 5.1, by the
total waste generated from the corresponding
waste category (e.g., residential yard trimmings),
as shown in Table 2.1. Therefore, the program
potential factor for residential grasscycling is 33.1
percent, or
9.1 million tons (national program potential) \
27.5 million tons (residential yard trimmings)/
Table 5.2 presents the program potential factors
for all MSW, residential waste, and commercial
waste.
With these program potential factors in hand,
local managers can use any mixture of national
and local data to estimate source reduction pro-
gram potential for their communities. Tables 5.3
and 5.4 provide default data taken from the '94
Update. Managers will need to use these tables as
they proceed to develop their local source reduc-
tion program potential estimates.
The following three examples help illustrate
how program potential factors can be applied to
local conditions. They explain how to estimate
local waste stream composition, and then how to
compute local program potential.
Table 5. 1. National Program Potential for Six Source Reduction Options
Source Reduction Option
Grasscycling
Home composting
Clothing reuse
Office paper prevention
Converting to multi-use pallets
Paper towel reduction
TOTAL
Component of MSW
Yard trimmings
Food scraps & yard trimmings
Other
Paper and paperboard
Wood
Paper and paperboard
National Program Potential
(Million Tons per Year)
9.1
13.0
1.6
1.3
1.6
0.2
26.8
17
-------
Chapter 5
Table 5.2. Program Potential Factors
Source Reduction General Waste
Option Category
Program Potential Factors (Percent) for
All MSW Residential Commercial
Waste Waste
Grasscycling
Home composting
Clothing reuse
Office paper prevention:
Duplexing
Networking
Total
Converting to multi-use
pallets
Paper towel reduction
Yard trimmings
Food scraps
Yard trimmings
Other
Paper and paperboard
Wood
Paper and paperboard
29.7
26.9
30.1
8.2
0.8
0.8
1.6
11.0
0.3
33.1
54.3
33.5
16.0
1.4
1.5
2.9
14.4
0.5
Table 5.3. Default Waste Composition (Percent by Weight)—National Default Data
Composition (Percent)
Waste Category
Residential
CM
All MSW
Paper and paperboard
Glass
Metals
Plastics
Wood
Food scraps
Yard trimmings
Other
30
9
9
13
3
6
23
7
51
3
6
5
13
8
4
10
39
6
8
9
7
7
15
9
Total
100
100
100
Table 5.4. Waste Generation—National Default Data
Generation Rate (Tons/Year)
Sector
Per Person
Per Household
Residential
0.5
1.3
All MSW
0.8
2.2
Scenario 1: Anywhere
Background: In Anywhere, the local solid waste
manager handles the entire MSW stream amounting
to 40,000 tons a year. The manager has no local data
on waste stream composition. However, as its name
suggests, Anywhere's waste stream can be expected
to be similar in composition to the national average.
The manager can apply national waste composition
data to the program potential factors for 'All MSW
to estimate program potential for the six options.
Determine the Waste Composition: Because
Anywhere's solid waste manager does not know
the current waste composition, he can use national
waste composition data from the '95 Update (see
Table 5.3) to estimate local waste composition. The
solid waste manager applies the percentages to the
40,000 tons to determine his annual waste composi-
tion. The results are presented in Table 5.5.
18
-------
Local Applications
Table 5.5. Anywhere — Waste Composition \
General Waste Waste Waste
Category Composition Composition
(Percent) (Tons)
Paper and
paperboard 39 15,600
Glass 6 2,400
Metals 8 3,200
Plastics 9 3,600
Wood 7 2,800
Food scraps 7 2,800
Yard trimmings 15 6,000
Other 9 3,600
Total 100 40,000
Apply the Program Potential Factors: The manager
estimates the local program potential for the six
source reduction options included in this manual by
applying the 'All MSW program potential factors
from Table 5.2 to the waste composition calculated in
Table 5.5. His calculation is shown in Table 5.6.
Program Potential: The total program potential
for Anywhere is 4,702 tons, or about 12 percent of
Anywhere's waste stream.
The only subtle point in Table 5.6 is the devel-
opment of the tonnage of yard trimmings avail-
able for home composting. To avoid double
counting, the 1,782 tons of grass that might be
grasscycled is removed from the 6,000 tons of yard
trimmings to which home composting might oth-
erwise apply.
The general approach taken for Anywhere
does not depend on managing all MSW. This
two-step approach can also be taken if the local
Table 5.6. Anywhere — Program Potential
Source Reduction General Waste
UP"°" Category
Grasscycling Yard trimmings
Home composting Food scraps
Yard trimmings
Clothing reuse Other
Office paper prevention Paper and paperboard
Converting to multi-use Wood
pallets
Paper towel reduction Paper and paperboard
Total
Table 5.7. Commuterburgh — Grasscycling •
Population 50,000
Tons per person per year x 0.5
Waste generation (tons) = 25,000
Yard trimmings (percent) x 0.23
Yard trimmings (tons) = 5,750
Program potential factor (percent) x 0.331
Program potential for grasscycling (tons/yr) = 1,903
Program Program
Potential Potential
Tonnage Factor (Percent) (Tons)
6,000 29.7 1,782
2,800 26.9 753
4,218 30.1 1,270
3,600 8.1 292
15,600 1.6 250
2,800 11.0 308
15,600 0.3 47
4,702
manager knows the tonnage from the residential
or CII sectors. Waste composition percentages
and program potential factors for the 'residential'
or 'CII sector' would simply be used in place of
the 'All MSW' data.
Scenario 2: Commuterburgh
Background: In Commuterburgh, population
50,000, a group of local citizens is interested in
promoting grasscycling to reduce the residential
19
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Chapter 5
waste stream. The group can use national data on
generation, composition, and source reduction,
together with their limited local data, to evaluate
the savings possible from grasscycling.
Determine the Waste Composition: Without any
information on local waste generation available, the
group can use national data to estimate the local
program potential for grasscycling. The composi-
tion and generation data used in Table 5.7 are taken
from Tables 5.3 and 5.4.
Apply the Program Potential Factors: The group
then multiplies the total tons of yard trimmings by
the program potential factor for residential grass-
cycling to estimate the program potential.
Program Potential: The program potential for grass-
cycling in Commuterburgh is 1,903 tons per year.
Scenario 3: Fullville
Background: In Fullville, the local solid waste
manager is responsible for residential and CII
waste. She is interested in applying several of the
CII program potential factors to the 10,000 tons of
CII waste she manages. Unlike the manager in
Anywhere, the manager knows the composition
data and even knows that there are 200 tons of
pallets in the waste stream.
Determine Waste Composition: The development
of the CII waste composition for Fullville is shown
in Table 5.8.
Apply Program Potential Factors: In Table 5.9, the
tonnage of general waste is drawn from Table 5.8.
With the exception of converting to multi-use pal-
lets, the program potential factors are the CII fac-
tors from Table 5.2. For multi-use pallets, the
program potential factor needs to be customized
to reflect the fact that there are 200 tons of pallets
in the local waste stream.
Based on the information from Chapter 4,
Figure 4.2 shows that the program potential for
converting to multi-use pallets is the product of
applicability, feasibility, and technology factors.
The applicability factor is the "percentage" of
wood that is wooden pallets. Here the manager
knows the actual tonnage. To figure the percent-
age, the manager divides the total number of tons
of pallets by the total number of tons of wood
waste. Based on the waste composition shown in
Table 5.8, 19 percent (200 + 1,060 = 0.19) of the
wood waste is pallets. Multiplying by the feasibili-
ty (24 percent) and technology (70 percent) factors,
and dividing by the percent commercial waste cat-
egory (see Table 6.1) or 76 percent, the manager
figures the custom program potential factor of 4.2
percent shown in Table 5.9.
Program Potential: For Fullville's CII waste, the
local program potential for three source reduction
programs is 249 tons per year.
Having completed the analysis of program
potential, the manager also wishes to consider the
Table 5.8. Fullville— CII Waste Composition
General
Waste
Category
Paper and
paperboard
Glass
Metals
Plastics
Wood
Food scraps
Yard trimmings
Other
Total
Waste
Composition
(Percent)
60.0
2.5
4.6
4.1
10.6
6.5
3.3
8.4
100
Final
Composition
(Tons)
6,000
250
460
410
1,060
650
330
840
10,000
savings that might be achieved if a source reduc-
tion program were implemented for office paper.
In preparing an analysis of cost savings, Fullville's
manager needs to estimate the following:
* The percentage of the program potential that
could be achieved during the first year of
implementation. Based on experiences with oth-
er source reduction programs, the manager feels
that Fullville could achieve 30 percent of the
program potential for the community.
» The cost of the source reduction program.
Fullville's manager has budgeted $500.00 for
the costs of an office paper prevention program.
» The avoided system costs of a source reduction
program. A source reduction program will
affect the tonnage of materials recycled and dis-
posed of. For instance, the revenue currently
being generated in Fullville for its office paper
recycling program will decrease after a source
20
-------
Local Applications
Table 5.9. Fullville—CII Program Potential
Source Reduction
Option
Office paper prevention
Converting to multi-use
pallets
Paper towel reduction
Total
"Custom program potential
General Waste
Category Tonnage
Paper and paperboard 6,000
Wood 1,060
Paper and paperboard 6,000
factor (see page 20).
Program
Potential
Factor (Percent)
2.9
4.2*
0.5
Program
Potential
(Tons/Yr)
174
45
30
249
reduction program is in place. Whether this lost
revenue is included in the net savings calcula-
tion depends on the perspective of the program
implementor. Other costs, such as collection and
processing costs, may also fluctuate, since there
will be fewer materials for trash and recycling
crews to collect. These costs will vary in each
community, and will have to be estimated by
managers if actual figures are not available.
In order to estimate the net savings of a pro-
gram, Fullville's manager will also need to ana-
lyze the following:
— The percentage of office paper that is current-
ly recycled. Fullville estimates that it is recy-
cling 20 percent of its office paper.
— The price per ton (revenue or net benefit)
from an office paper recycling program.
Fullville is receiving $10.00 a ton for office
paper.
— The tipping fee or disposal costs for the com-
munity. The tipping fee at Fullville's landfill
is $35.00 a ton.
When estimating net savings, the manager
begins with the local program potential factor for
office paper prevention. The program potential for
office paper prevention in Fullville is 174 tons.
Based on her professional judgment, Fullville's
manager feels that the community could achieve
30 percent of the program potential. To derive the
potential tons preventable, the manager multiplies
the program potential by the percent achievable to
obtain 52.2 tons (174x0.3).
To determine the financial impact of an office
paper program, Fullville's manager considers the
current waste management costs.
The Fullville manager decides that the collec-
tion costs are insignificant and is not factoring in
these costs. Collection costs could include labor,
vehicle maintenance, gasoline use, and other bud-
get concerns.
Then, the manager considers avoided disposal
costs. Since Fullville currently recycles 20 percent
of its office paper, it is assumed that 80 percent is
disposed of. Therefore, 80 percent of the estimated
source reduction of office paper, or 41.8 tons (52.2
x 0.8), will not be disposed of. Given a tipping fee
of $35.00 a ton, the Fullville manager multiplies
the amount of paper source reduced by the dispos-
al cost, which equals $1,463.00 (41.8 tons x $35.00).
The Fullville manager knows that the business
community recycles 20 percent of its office paper.
To derive the amount of paper that will no longer
be recycled due to a source reduction program, the
manager multiplies the amount achievable by the
percent currently being recycled. This is 10.4 tons
(52.2 tons x 0.2). She also knows that the paper
recycling program is profitable, generating a net
revenue of $10.00 a ton. Once the source reduction
program is implemented, Fullville will no longer
receive the revenue from this portion of the paper
reduced. Thus, with the office paper source reduc-
tion program in operation, Fullville will not gener-
ate $104.00 (10.4 x $10.00) a year in revenues.
21
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Chapter 5
Table 5.10. FuHvifle—Net Savings of an Office Paper Prevention Program
Net Savings Calculations
Source Reduction Option:
Program Potential
Percent Achievable
Amount Preventable
Impact on Current Waste Management Costs:
Impact on collection costs
Impact on disposal costs
Impact on revenues from recycling
Total
Program Costs
Total:
Net Savings
Office Paper Prevention
174 tons
30%
52.2 tons
$0.00
$1,463.00
($ 104.00)
$1,359.00
($ 500.00)
$ 859.00
Next, the manager plans to engage in a pro-
gram of educational outreach, informing the busi-
ness community about the savings it could achieve
through office paper reduction. She budgets
$500.00 for the first year's program.
Finally, the manager computes the net impact of
the source reduction program, taking into account
the loss of recycling revenues as well as the avoid
ed disposal costs. The result is $1,359.00 ($1,463.00
- $104.00). Subtracting the program costs, the man-
ager finds that the town will save $859 per year
($1,359-$500).
In accounting for current waste management
costs, the cost for composting would be similar to
those for recycling. First, the manager would esti-
mate the percentage of materials that are currently
being composted. This percentage, multiplied by
the tonnage to be prevented by a source reduction
program (52.2 tons) would yield the total tonnage
composted. The associated cost impact can be
found by multiplying the tonnage composted by
the net cost or revenue due to composting the
paper. This cost would be added to the estimate of
the program impact on current waste management
cosls.
22
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Chapter 6
Worksheets
Introduction
The five worksheets included in this chapter are
used to calculate:
» Waste generation
» Waste composition
» Program potential
» Net savings
» Custom program potential factors
The first three worksheets are designed to help
managers calculate the local program potential for
source reduction. The last two worksheets allow
managers to evaluate associated savings and
develop 'custom' program potential factors. For a
copy of the companion software that allows the
user to perform these calculations automatically,
contact the RCRA Hotline at 800 424-9346.
These worksheets enable managers to calculate
the tonnage of waste generated in the sector (e.g.,
residential, CII, or all MSW) they are analyzing.
Managers have three options for developing this
tonnage:
1. Estimating generation directly.
2. Adding estimates of the tonnage recycled, com-
posted, and disposed of as trash.
3. Estimating the tonnage based on either the pop-
ulation or the number of households in their
locality. This option can be used only if man-
agers are analyzing the residential sector or all
MSW.
Options 2 and 3 require simple calculations.
Worksheets Al and A2 are provided for this
purpose.
Managers who use the third option will need to
specify the unit (population or households) on
which the calculation will be based. Their choice
will be based on the availability of local data. Tons
of waste generated per resident (or per household)
can be based on the national EPA default data, as
shown in Table 5.4, or on local data.
This worksheet enables managers to develop
waste composition data for the sector they are
analyzing.
Worksheet B has been designed to make use of
available local data on generation and waste stream
composition. At the bottom of the column headed
'Final Composition,' managers should enter their
estimate of the total tonnage of waste generated.
Next, the number of tons collected for any of the
eight waste categories, if known, should be entered
in the 'Known Composition' and 'Final
Composition' columns. If managers know the ton-
nage for each of these categories, they are finished
with Worksheet B once they enter the tonnages in
the 'Known Composition' and 'Final Composition'
columns.
Managers lacking local data will need to rely on
default data. Table 5.3 provides national default
data on the percent of the waste stream for each
waste category. In the column headed 'Default
Composition (Percent by Weight),' managers
should enter the default percentage for each waste
category. They can then multiply each percentage
by the total tonnage (shown at the bottom of the
'Final Composition' column) and enter the results
in the column headed 'Default Composition
(Tons/Year).' They are then finished with
Worksheet B.
23
-------
Chapter 6
C:
This worksheet enables managers to develop
estimates of program potential for the sectors they
are analyzing.
To use Worksheet C, managers should first
enter the waste tonnage to which each source
reduction option will apply. This tonnage can be
taken from the 'Final Composition' column on
Worksheet B. In the case of home composting,
managers may wish to adjust the composition
data. They can decide whether food scraps are
included in the home composting program. They
can also decide to reduce the portion of yard trim-
mings included in the program, by adjusting to
avoid double-counting with grasscycling, for
example. To do this, managers will need to com-
pute the program potential for grasscycling and
subtract the results from the tonnage of yard trim-
mings available for home composting.
Once the tonnage for each waste category is
specified, completing Worksheet C simply requires
selecting the program potential factors, as shown
in Table 5.2. Alternatively, managers can develop
custom factors for some or all of the source reduc-
tion options using Worksheet E.
gs
This worksheet allows managers to estimate the
net savings they might expect through source
reduction. The worksheet is designed to address
one source reduction option at a time. The
Fullville scenario (see pages 20-22) takes the reader
through a step-by-step analysis of how to com-
plete this worksheet.
This worksheet provides an opportunity to
develop 'custom' program potential factors that
can be used in place of the standard factors shown
in Table 5.2. Solid waste managers may want to
develop custom program potential factors to
reflect local data or information. For instance, a
manager might want to change the technology fac-
tor in order to capture known information on a
community's current yard trimmings program. In
order to develop custom factors, managers must
change the inputs, or the applicability, feasibility,
or technology factors, in the standard program
potential factors. These inputs, as well as the
resulting standard factors, are shown in Table 6.1.
Continuing with the yard trimmings scenario, a
manager knows that he would want to change the
technology factor from 100 percent to 80 percent.
In order to customize the program potential factor,
the calculation is computed as follows:
0.45 x
(Applicability
factor)
0.66 x
(Feasibility
factor)
0.80 = 0.238
(Technology (All MSW
factor) factor)
To develop a residential program potential
factor for yard trimmings, the "All MSW" factor
must then be divided by 90 percent (to reflect the
percentage of yard trimmings generated by the
residential sector in Table 6.1), or 0.90, as
follows:
0.238 + 0.90 = 0.264
(All MSW factor) (Residential) (Residential grasscycling
factor)
If a manager wanted to develop a yard trim-
mings program potential factor for CII, then the
"All MSW" factor would then be divided by 10
percent.
Any of the other program potential factors pre-
sented in this manual may also be customized to
take advantage of known local data and expertise.
24
-------
Worksheets
Worksheet A1. Waste Generation
Total tonnage of garbage collected
Total tonnage of recyclables collected
Total tonnage of compostables collected
Total waste generated
Worksheet A2. Waste Generation
Number of units in your jurisdiction
Tons of waste generated per unit per year
Total tonnage of waste generated
X
Worksheet B. Waste Composition
Default Default Known Final
Waste Composition Composition Composition Composition
Category (Percent by Weight) (Tons/Year) (Tons/Year) (Tons/Year)
Paper and
paperboard
Glass
Metals
Plastics
Wood
Food scraps
Yard trimmings
Other
Total
Worksheet C, Program Potential
Source Reduction
Option
Grasscycling
Home composting
Clothing reuse
Office paper
Multi-use pallets
Paper towels
Total
General
Waste
Category Tons
Yard trimmings
Food scraps
Yard trimmings
Other
Paper and paperboard
Wood
Paper and paperboard
Program
Potential Program
Factor Potential
25
-------
Chapter 6
Worksheet D. Net Savings
Net Savings
Source Reduction Option
_tons
tons
Source Reduction Option:
A Program Potential
B Percent Achievable
C Amount Preventable
Impact on Current Waste Management Costs:
D Impact on collection costs $
E Impact on disposal costs $
F Impact on revenues from recycling (including composting) $
Total $
G Program Costs ($
Total:
H Net Savings $
Footnotes
A=Program potential estimate.
B=User estimate of first year program impact.
C=AxB
D=User estimate of the impact of the source reduction option on collection costs.
E=User estimate of the impact of the source reduction option on disposal costs.
F=User estimate of the lost revenues from recycling (including composting) due to the estimated impact of the source reduction
option.
G=Annual source reduction option operating cost or budget estimate.
H=D+E-F-G
26
-------
Worksheets
Table 6.1. Standard Program Potential Factors
Waste Stream Data
General
Source Waste
Reduction Option Category
% of General
Waste Category
Residential or Applicability Feasibility Technology
Commercial Factor Factor Factor
Program Potential Factors
(Percent) for
All Residential Commercial
MSW Waste Waste
Residential
Grasscycling
Home composting
Clothing reuse
Yard trimmings
Food scraps
Yard trimmings
Other
90%
50%
90%
51%
45
36
81
8.3
66
74
74
97
100
100
100
100
29.7
26.9
30.1*
8.2
33.1
54.3
33.5*
16.0
N/A
N/A
N/A
N/A
Commercial
Office paper
Duplexing
Computer networks
Total
Multi-use pallets
Paper towels
Paper/paperboard
Wood
Paper/paperboard
55%
55%
76%
55%
2.6
1.6
65
1
58
59
24
60
50
90
70
50
0.8
0.8
1.6
11.0
0.3
N/A
N/A
N/A
N/A
N/A
1.4
1.5
2.9
14.4
0.5
* excluding the national program potential for grasscycling.
Worksheet E. Custom Program Potential Factors
Waste Stream Data
General
Source Waste
Reduction Option Category
Program Potential Factors
(Percent) for
% of General
Waste Category
Residential or Applicability Feasibility Technology All Residential Commercial
Commercial Factor Factor Factor MSW Waste Waste
Residential
Grasscycling Yard trimmings
Home composting Food scraps
Yard trimmings
Clothing reuse Other
Commercial
Office paper Paper/paperboard
Duplexing
Computer networks
Total
Multi-use pallets Wood
Paper towels Paper/paperboard
27
-------
-------
-------
National Flood Insurance Program
Community Status Book
Federal Emergency Management Agency
Federal Insurance Administration
Washington, B.C. 20472
Section I
Section I of this book lists communities PARTICIPATING in the
National Flood Insurance Program. Flood insurance policies for
residential and commercial properties and their contents located
in the communities listed may be purchased from any insurance
agent or broker licensed to sell property or casualty insurance
and in good standing in all the states in which the agent is
licensed. Agents may obtain information about coverage, rates,
etc., by calling the National Flood Insurance Program toll
free at 1-800-638-6620, by calling the Telecommunication Device
for the Deaf (TDD) toll free at 1-800-447-9487, or from any
private sector property insurance company participating in the
Write Your Own (WYO) Program.
the community number (or COMMUNITY PANEL NUMBER)
appearing on the FIA flood map for the community. The
alphabetic suffix at the end of the number indicates
whether the currently effective map is a revision of
an earlier map (e.g., "A" normally indicates a first
edition, "B" a first revision, etc.). This number and
the suffix, if any, must be written on all flood
insurance policies.
- (COMMUNITY NAME). This indicates the name of the
community, followed by the name of the county in which
it is located. When the community is a county, only
its unincorporated areas are referred to; incorporated
areas are listed individually as township, city,
village, etc.
- This indicates THE DATE OF THE COMMUNITY'S ENTRY
INTO THE REGULAR OR EMERGENCY PROGRAM of the National
Flood Insurance Program. The symbol (R) following the
date indicates Regular Program; if no parenthetical
symbol appears after the date, the community is
participating in the Emergency Program.
- This indicates
EFFECTIVE FLOOD
also appears on
If there is no
THE EFFECTIVE DATE OF THE CURRENTLY
MAP OF THE COMMUNITY. This date
the flood map of the community.
date in this column, a flood map for
the community has not yet been published, but the
community is still participating in the National
Flood Insurance Program.
If a date appears in both columns, then the purchase
of flood insurance is reguired as a condition of
Federal or federally related financial assistance
for construction or acguisition of buildings located
within the special flood hazard areas as shown on
the FIA flood maps. (including FHA and VA mortgage
guarantees, mortgage loans from federally regulated
lending institutions, Federal disaster assistance,
etc. )
Section II
Section II of this book lists communities which are
NOT PARTICIPATING in the National Flood Insurance Program, but
which have an FIA flood map delineating the special flood
hazard areas in the community.
-------
Symbols
NSFHA -
HAZARD AREA IDENTIFIED. This is the effective date
of the first FIA flood map of that community. There
may be other, more recent maps for the community.
DATE ON WHICH SANCTIONS APPLY. Effective on this
date, no direct Federal assistance (including FHA or
VA mortgage guarantees) can legally be provided for
the acguisition or construction of buildings in the
special flood hazard areas shown on the FIA map
of this community. To obtain up-to-date information
on whether the sanction on Federal assistance still
applies for their community, call the Federal
Emergency Management Agency (202) 646-3444.
The community has no special flood hazard areas
and a flood map for the community has not been
published. Although it may not be subj ect to the
100-year flood, floods of a greater magnitude could
occur there. In addition, certain structures may be
damaged by local drainage problems. The community is
ALL ZONE C for flood insurance rating purposes.
Minimally Flood Prone, with Flood Hazard Boundary
Map converted to Flood Insurance Rate Map by letter,
no change in flooding shown on map, no elevation on
map.
Minimally Flood Prone, no elevation on map.
Entry date into Regular Program.
Suspended from the National Flood Insurance Program.
Effective Map is a Flood Insurance Rate Map. Note,
however, that the " Hazard Area Identified" date
denotes the date of original identification of the
special flood hazard area and is not necessarily the
date of the most recent Flood Insurance Rate Map.
The community has withdrawn from the National Flood
Insurance Program. No flood insurance available. Other
sanctions apply. For up-to-date information after
suspension date, call the above number.
after the date of
This community has a map with a 10-digit ID number.
Each map with such a number will be published as one
or more Z-fold panels (like road maps). Each map
having more than one panel also has an index showing
which panels apply to the various sections of a
community. Since the 10-digit system permits the
revision of individual panels rather than the entire
map, the index also shows the correct suffix of the
most current panel for a particular location in the
community.
Each time a panel is revised and published, the map
index is also revised and republished with a new
effective date to reflect the panel revision. For
community maps with 10-digit ID numbers, the Status
Book gives data relating to the index only. The index
must be consulted for information on individual
panels.
This book is published
separately bound copies
information is needed,
Copies are free; to get o
semiannually and is available in
for each state, or, if nationwide
_n a bound copy for the entire Nation.
i the distribution list or change your
Ordering Flood Maps
FIA flood maps and/or indices may be ordered from:
Federal Emergency Management Agency
Flood Map Distribution Center
6730 (A-G) Santa Barbara Court
Baltimore, Maryland 21227-6227 or call
National Flood Insurance Program
Telephone: 1-800-358-9616
-------
v>EPA
United States
Environmental Protection
Agency
Office of Water
Washington, D.C.
EPA 832-F-99-022
September 1999
Storm Water
Management Fact Sheet
Non-Storm Water Discharges to Storm Sewers
DESCRIPTION
Identifying and eliminating non-storm water
discharges to storm sewers is an important and very
cost-effective Best Management Practice (BMP) for
improving runoff water quality. Non-storm water
discharges can include discharges of process water,
air conditioner condensate, non-contact cooling
water, vehicle wash water, or sanitary wastes, and
are typically the result of unauthorized connections
of sanitary or process wastewater drains to storm
sewers. These connections are common, yet often
go undetected. Typically these discharges are
significant sources of pollutants, and, unless
regulated by an NPDES permit, they are also illegal.
Environmental impact evaluations have shown that
the elimination of non-storm water discharges is an
effective BMP, because such discharges may
contain a significant loading of pollutants.
Several studies exist on the contents of non-storm
water discharges. Pitt and Shawley (1982) reported
that non-storm water discharges were found to
contribute substantial quantities of a variety of
pollutants, even though the individual
concentrations of each pollutant were not high.
During extended periods of base flow conditions,
the lower concentration was offset, leading to a
substantial loading of pollutants. Gartner, Lee and
Associates, Ltd. (1983) conducted an extensive
survey of non-storm water discharges in the Humber
River watershed (Toronto). Out of 625 outfalls,
about 10 percent were considered significant
pollutant sources. Further investigations identified
many industrial and sanitary non-storm water
discharges into the storm drainage system.
Sources found in industrial areas included liquid
dripping from animal hides stored in tannery yards,
and washdowns of storage yards at meat packing
facilities. Therefore, it is anticipated that elimination
of non-storm water discharges will be a highly
effective BMP.
Identifying and eliminating non-storm water
discharges has rarely been done at industrial
facilities. Part of the problem is education: many
facility operators are unaware of what constitutes a
non-storm water discharge and what the potential
environmental impacts of these discharges are.
Compliance with NPDES permit requirements for
the presence of non-storm water discharges will
greatly improve the implementation of this BMP.
APPLICABILITY
Almost every industrial facility that has not been
tested or evaluated for the presence of potential
non-storm water discharges should be so evaluated.
Typically NPDES permit certification includes:
• Identification of potential non-storm water
discharges.
Results of a site evaluation for the presence
of non-storm water discharges.
• The evaluation criteria or test method used.
• The date of testing and/or evaluation.
• The on-site drainage points that were
directly observed during the test and/or
evaluation.
This certification must be signed in accordance for
the facility's NPDES storm water permit. A sample
certification form is shown in Figure 1.
-------
ADVANTAGES AND DISADVANTAGES
Identifying and eliminating non-storm water
discharges can be an easy and cost-effective method
for preventing runoff contamination and pollution of
receiving water bodies. However, identifying these
discharges may be problematic. Possible problems
in identifying non-storm water discharges include:
A non-storm water discharge may not occur
on the date of the test or evaluation.
• The method used to test or evaluate the
discharge may not be applicable to the
situation.
• A lack of available data on the location of
storm drains and sanitary sewers, especially
in older industrial facilities, may make
identifying an illicit connection difficult.
KEY PROGRAM COMPONENTS
Key program criteria include identifying and
locating non-storm water entries into storm drainage
and investigating their sources.
For any effective investigation of pollution within a
storm water system, all pollutant sources must be
included. For many pollutants, storm water may
contribute the smaller portion of the total pollutant
mass discharge from a storm drainage system. In
addition to conventional storm water runoff
associated with rainfall, pollutant sources may
include dry-weather entries occurring during both
warm and cold months and snowmelt runoff.
Consequently, much less pollution reduction benefit
will occur if only storm water is considered in a
control plan for controlling storm drainage
discharges.
The investigations may also identify illicit point
source outfalls that do not carry storm water.
Obviously, these outfalls also need to be controlled
and permitted. Figure 1 can be used as a sample
worksheet to report non-storm water discharges.
There are four primary methods for investigating
non-storm water discharges.
Visual Inspection
The simplest method for detecting non-storm water
connections in the storm water collection system is
to observe all discharge points during periods of dry
weather. Key parameters to look for are the
presence of stains, smudges, odors, and other
abnormal conditions.
Sanitary and Storm Sewer Map Review
A review of a plant schematic is another simple way
to determine if there are any unauthorized
connections to the storm water collection system.
A sanitary or storm sewer map, or plant schematic,
is a map of pipes and drainage systems used to carry
NON-STORM WATER DISCHARGE
ASSESSMENT AND CERTIFICATION
Date of Test or
Evaluation
Outfall Directly
Observed During
the Test (Identify as
indicated on the site
map)
Method Used to
Test or Evaluate
Discharge
Worksheet Comple
Title:
ted By:
Date:
Signature:
Describe Results
from Test for the
Presence of Non-
Storm Water
Discharge
Identify Potential
Significant Sources
Name of Person
Who Conducted
the Test or
Evaluation
Source: U. S. EPA, 1992.
FIGURE 1 SAMPLE WORKSHEET FOR RECORDING NON-STORM WATER DISCHARGES
-------
process wastewater, non-contact cooling water, and
sanitary wastes. These maps (especially as-built
plans) should be reviewed to verify that there are no
unauthorized connections. However, a common
problem at many sites is that they often do not have
accurate or current schematics.
Dye Testing
Another method for detecting improper connections
to the storm water collection system is dye testing.
A dye test can be performed by simply releasing a
dye (either pellet or powder) into either the sanitary
or process wastewater system. Discharge points
from the storm water collection system are then
examined for color change.
Sampling and Chemical Analysis
Sewer mapping and visual inspection are also
helpful in identifying locations for sampling.
Chemical tests are needed to supplement the visual
or physical inspections. Chemical tests can help
quantify the approximate components of the
discharge mixture at the outfall or discharge point.
Samples should be collected, stored, and analyzed in
accordance with standard quality assurance and
quality control (QA/QC) procedures. Statistical
analysis of the chemical test results can be used to
estimate the relative magnitudes of the various flow
sources. In most cases, non-storm water discharges
are made up of many separate sources of flow, such
as leaking domestic water systems, sanitary
discharges, ground water infiltration, automobile
washwater, etc. Key parameters that can be helpful
in identifying the source of the non-storm water
flows include biochemical oxygen demand (BOD),
chemical oxygen demand (COD), total organic
carbon (TOC), specific conductivity, temperature,
fluoride, hardness, ammonia, ammonium, potassium,
surfactant fluorescence, pH, total available chlorine,
and toxicity screening. It may be possible to
identify the source of the non-storm water discharge
by examining the flow for specific chemicals.
Just as high levels of pathogenic bacteria are usually
associated with a discharge from a sanitary waste
water source, the presence of certain chemicals is
generally associated with specific industries. Table
1, includes a listing of various chemicals that may
be associated with a variety of activities.
IMPLEMENTATION
Identification of non-storm water discharges should
be part of every facility's maintenance program.
Facilities should conduct annual inspections for
non-storm water discharges, even if previous tests
have found no such discharges. New processes,
building additions, or other plant changes may have
brought about unauthorized connections to the
storm water conveyance system.
COSTS
The above methods are mostly time-intensive;
therefore, the cost is dependent on the level of effort
employed, and on the level of expertise. Visual
inspections are the least expensive of the three. Dye
testing may be more cost effective for buildings that
do not have current schematics of their sanitary and
storm sewer systems. The cost of disconnecting
illicit discharges from the storm water system will
vary depending on the type and location of the
connection.
The full use of all of the applicable procedures is
most likely necessary to identify all pollutant
sources. For example, attempting to reduce costs
by examining only a certain class of outfalls, or
using inappropriate testing procedures, will
significantly reduce the utility of the testing
program and result in inaccurate conclusions.
REFERENCES
1. California Environmental Protection
Agency, Draft, 1992. Staff Proposal for
Modification to Water Quality Order No.
91-13D WQ Waste Discharge Requirements
for Discharges of Storm Water Associated
with Industrial Activities.
2. Gartner, Lee and Associates, Ltd., 1983.
Toronto Area Watershed Management
Strategy Study, Technical Report No. 1,
Number River and Tributary Dry Weather
Outfall Study. Ontario Ministry of the
Environment, Toronto, Ontario.
-------
TABLE 1 CHEMICALS COMMONLY FOUND IN INDUSTRIAL DISCHARGES
Chemical
Acetic Acid
Alkalis
Ammonia
Arsenic
Chlorine
Chromium
Cadmium
Citric Acid
Copper
Cyanides
Fats, Oils
Fluorides
Formalin
Hydrocarbons
Hydrogen Peroxide
Lead
Metcaptins
Mineral Acids
Nickel
Nitro Compounds
Organic Acids
Phenols
Silver
Starch
Sugars
Sulfides
Sulfites
Tannic Acid
Tartaric Acid
Zinc
Industries
Acetate rayon, pickle and beetroot manufacture
Cotton and straw kiering, cotton manufacture
Gas and coke manufacture, chemical manufacture
Sheep-dipping, felt mongering
Laundries, paper mills, textile bleaching
Plating, chrome tanning, aluminum anodizing
Plating
Soft drinks and citrus fruit processing
Plating, pickling, rayon manufacture
Plating, metal cleaning, case-hardening, gas manufacture
Wool scouring, laundries, textiles, old refineries
Gas and coke manufacture, chemical manufacture, fertilizer plants,
Manufacture of synthetic resins and penicillin
Petrochemical and rubber factories
Textile bleaching, rocket motor testing
Battery manufacture, lead mining, paint manufacture, gasoline
Oil refining, pulp mills
Chemical manufacture, mines, iron and copper pickling, brewing, textiles
Plating
Explosives and chemical works
Distilleries and fermentation plants
Gas and coke manufacture, synthetic resin manufacture, textiles,
Plating and photography
Food, textile, wallpaper manufacture
Dairies, foods, sugar refining, preserves, wood process
Textiles, tanneries, gas manufacture, rayon manufacture
Wood process, vicose manufacture, bleaching
Tanning, sawmills
Dyeing, wine, leather, and chemical manufacture
Galvanizing, plating, viscose manufacture, rubber process
Source: Pitt et a/., 1992.
-------
7.
Pitt, R. and G. Shawley, 1982. A
Demonstration of Non-Point Pollution
Management on Castro Valley Creek,
Alameda County Flood Control District
(Hayward, California) and U.S. EPA,
Washington, DC.
Pitt, R., D. Barbe, D. Adrian, and R. Field,
1992. Investigation of Inappropriate
Pollution Entries Into Storm Drainage
Systems - A Users Guide, U.S. EPA,
Edison, New Jersey.
Pitt, R., and R. Field, 1992. Non-Storm
Water Discharges into Storm Drainage
Systems. NTIS Report No. PB92-158559.
U.S. EPA, 1992. Storm Water
Management For Industrial Activities:
Developing Pollution Prevention Plans and
Best Management Practice. EPA 833-R-
92-006.
Washington State Department of Ecology,
February, 1992. Storm Water Management
Manual for the Puget Sound Basin.
Northern Virginia Planning District Commission
David Bulova
7535 Little River Turnpike, Suite 100
Annandale, VA 22003
Southeastern Wisconsin Regional Planning
Commission
Bob Biebel
916 N. East Avenue, P.O. Box 1607
Waukesha, WI53187
The mention of trade names or commercial products
does not constitute endorsement or recommendation
for the use by the U.S. Environmental Protection
Agency.
ADDITIONAL INFORMATION
Center for Watershed Protection
Tom Schueler
8391 Main Street
Ellicott City, MD21043
King County, Washington
Dave Hancock
Department of Natural Resources, Water and Land
Resources Division, Drainage Services Section
700 5th Avenue, Suite 2200
Seattle, WA 98104
State of Minnesota
Lou Flynn
Minnesota Pollution Control Agency
520 Lafayette Road North
St. Paul, MN 55155
For more information contact:
Municipal Technology Branch
U.S. EPA
Mail Code 4204
401 M St., S.W.
Washington, DC, 20460
IMTB
Exceience fh compliance through optftnal technical sotrtroru:
MUNICIPAL TECHNOLOGY
-------
Water Quality Criteria and Standards Plan - FACTSHEET - Priorities for the Future file:///G|/CD-ROM/planfs.html
© C DA United States __ t ., - f \ •*• v
\XCnrAEmiraimienlalPratMlicriAgency FA("T *^HFF I" ^ r,f 'itif* k'
jn^-jj ? t \f s ' ^^*^- i k-'ntu. l \ rf( \ii>&»_ A^
Office of Water * ' ^S; - -
United States Office of Water EPA-823-F-98-011
Environmental Protection 4304 April 1998
Agency
Water Quality Criteria and Standards Plan—Priorities for the Future
The U.S. EPA, Office of Science and Technology in the Office of Water announces a Plan
for working together with the States and Tribes to enhance and improve the water quality
criteria and standards program across the Country.
What is the Plan?
The Plan, called the "Water Quality Criteria and Standards Plan—Priorities for the
Future", describes six new criteria and standards program initiatives that EPA and the
States and Tribes will take over the next decade.
The Plan presents a "vision" and strategy for meeting these important new initiatives and
improvements. The Plan will guide EPA and the States and Tribes in the development and
implementation of criteria and standards and will provide a basis for enhancements to the
Total Maximum Daily Load (TMDL) program, National Pollutant Discharge Elimination
System (NPDES) permitting, nonpoint source control, wetlands protection and other
water resources management efforts.
The Plan helps to prepare the foundation for many of the clean water initiatives announced
in the President's Clean Water Action Plan in February 1998.
The "Vision" of the Plan
The water quality criteria and standards program will fully integrate biocriteria, nutrient
criteria and microbial pathogen control with improved chemical-specific and whole
effluent toxicity criteria into a water quality criteria and standards program that better
ensures the protection of human health and the maintenance and improvement of the
Nation's waters. Possible future criteria initiatives for excessive sedimentation, flow and
wildlife will be investigated.
Priority Areas of the Plan
The Office of Water will emphasize and focus on the following priority areas for the
Criteria and Standards Program over the next decade:
0 Developing Nutrient Criteria and assessment methods to better protect aquatic life
and human health
Iof3 9/18/01 9:31 AM
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Water Quality Criteria and Standards Plan - FACTSHEET - Priorities for the Future file:///G|/CD-ROM/planfs.html
0 Developing criteria for Microbial Pathogens to better protect human health during
water recreation
0 Completing the development of Biocriteria as an improved basis for aquatic life
protection
° Maintaining and strengthening the existing Ambient Water Quality Criteria for
water and sediments
0 Evaluating possible criteria initiatives for Excessive Sedimentation, Flow Alterations
and Wildlife
° Developing improved water quality Modeling Tools to better translate water quality
standards into implementable control strategies
0 Ensuring Implementation of these new initiatives and improvements by the States
and Tribes in partnership with EPA
Why is the Plan Necessary?
The National surface water quality protection program is at an important juncture. The
initiatives described in the Plan are needed to better protect aquatic life and the
recreational uses of the Nation's waters. Over the past two decades, State and Tribal water
quality standards and water quality-based management approaches have relied upon
aquatic life use designations and protective criteria based primarily upon narrative,
chemical-specific and whole effluent toxicity methodologies. Using these approaches,
outstanding progress has been made. However, not all of the Nation's waters have
achieved the Clean Water Act goal of "fishable and swimmable", and significant water
pollution problems still exist. Approximately 40 percent of the Nation's waters still do not
meet water quality goals and about half of the Nation's 2000 major watersheds have water
quality problems.
Given these facts, there is an essential need for improved water quality standards. Adding
nutrient criteria and biological criteria to the water quality criteria and standards program
ensures further improvements in maintaining and restoring aquatic life. Improved human
health criteria will better protect against bioaccumulative pollutants and new microbial
pathogen controls will better protect human health (especially that of children) during
water related recreation. Better tools also are needed for controlling excessive
sedimentation, flow alterations and for protecting wildlife. The new initiatives discussed in
the Plan also will help to promote water resources management on a watershed basis in
support of the President's Clean Water Action Plan.
What Does the Plan Say?
The Plan briefly describes the water quality issues and concerns that the new criteria
initiatives will address. For each initiative, the Plan explains the key objective(s) to be
accomplished, the critical activities necessary to achieve the objectives, and the roles of
the States and Tribes in implementing the Plan. The Plan commits that all objectives and
2 of 3 9/18/01 9:31 AM
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Water Quality Criteria and Standards Plan - FACTSHEET - Priorities for the Future file:///G|/CD-ROM/planfs.html
activities will be accomplished by the end of the decade.
More Information on the Plan
For more information on the Plan please contact:
William F. Swietlik
U.S. EPA - Office of Water
Office of Science and Technology
Health and Ecological Criteria Division (4304)
401 M Street, SW
Washington, DC 20460
swietlik.williamfa),epam ail.epa.gov
or
Jennifer Wigal
U.S. EPA - Office of Water
Office of Science and Technology
Standards and Applied Science Division (4305)
401 M Street, SW
Washington, DC 20460
wigal.jenniferfa),epamail.epa.gov
OST HOME | EPA HOME | WATER HOME | COMMENTS | SEARCH
URL: http://www. epa. gov/waterscience/standards/planfs.html
Revised September 28, 1998
3 of 3 9/18/01 9:31 AM
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4>EPA
United States
Environmental Protection
Agency
Office of Water (4503F)
Washington, DC 20460
EPA841-S-00-001
June 2000
The Quality of
Our Nation's Waters
A Summary of the National Water Quality
Inventory: 1998 Report to Congress
States, territories, tribes, and interstate commissions assessed 23% of the nation's
3.6 million miles of rivers and streams for their 1998 water quality assessment
reports to EPA. Of the assessed stream miles, 55% are rated as good, 10% good
but threatened, and 35% impaired. States and other jurisdictions assessed 42%
of the nation's 41.6 million acres of lakes, reservoirs, and ponds and reported
that 46% of assessed lake acres are rated as good, 9% good but threatened,
and 45% impaired. States and other jurisdictions assessed 32% of the nation's
90,500 square miles of estuaries and reported that 47% of assessed estuary
square miles are rated as good, 9% as good but threatened, and 44% as
impaired. Principal pollutants causing water quality problems include nutrients,
siltation, metals, and pathogens.
-------
Why Do States
and Other
Jurisdictions
Assess Water
Quality?
Section 305(b) of the Clean Water Act
requires states, territories, tribes, and
interstate commissions to assess the
health of their waters and the extent
to which their waters support state
water quality standards and the basic
goals of the Clean Water Act. The goals
of the Clean Water Act are to achieve
and maintain water quality that provides
for healthy communities of fish and
shellfish and that allows for recreation
in and on the water. States collect data
and information that allow them to
characterize whether water quality
meets these and other uses for their
waters which are expressed in standards
that each state sets.
States and other jurisdictions such
as territories, tribes, and interstate
commissions submit their water quality
assessments to the U.S. Environmental
Protection Agency (EPA) every 2 years.
EPA summarizes this information in a
biennial report to Congress. The
National Water Quality Inventory: 1998
Report to Congress is the twelfth biennial
report to Congress and the public
about the quality of our nation's rivers,
streams, lakes, ponds, reservoirs,
wetlands, estuaries, coastal waters,
and ground water.
States' Section 305(b) assessments are
an important component of their water
resource management programs. These
assessments help states:
-------
I H6 Under Section 303(d), the Clean Water Act includes a second reporting
*yf\r- /|~\ / requirement—that states provide a prioritized list of all their impaired
^*J*J \UJ' waters. Current requirements are that states submit these 303(d) lists
to EPA every 2 years. The most recent set of 303(d) lists were submitted
_ to EPA in April 1998.
VxVSI II Idrll\Jt I These lists of impaired waters are then used to prioritize state restoration
activities. One of the most important restoration tools is the development
of Total Maximum Daily Loads (TMDLs)—calculations of the amount
of a pollutant that a waterbody can receive and still meet water quality
standards. A TMDL is the sum of all available loads of a single pollutant from
all contributing point and nonpoint sources. It includes reductions needed
to meet water quality standards and allocates these reductions among
sources in the watershed.
The 305(b) and 303(d) reporting processes are connected, state
305(b) data is used to assist in the identification and priority ranking of
303(d) waters, although for their 303(d) listings, states may supplement
the 305(b) information with other assessments or choose only that data
in which they have the highest confidence. As a result, the findings on
impaired waters reported by the states in their 303(d) lists build on, and
are, in general, consistent with their 305(b) reports to EPA. Both sources
find similar amounts of impaired waters and conclude that siltation,
nutrients, bacteria, and metals are among the top pollutants causing
impairments.
EPA and the states continue to work to improve and harmonize both these
assessments through better and more extensive monitoring. Our goal is
comprehensive monitoring of all waters for all applicable water quality
standards—a challenging task given the demands placed on limited state,
tribal, and federal resources, but a particularly vital one because of the
important and costly water resource management decisions that depend
on high quality water data.
This National Water Quality Inventory report reflects incremental
progress toward the goal of comprehensive assessment, it includes
information submitted by all 50 states, the District of Columbia, and 5
territories, 4 interstate commissions, and 9 Indian tribes. In addition, the
amount of waters assessed for this report has increased slightly since the
previous report. States assessed 150,000 more river and stream miles and
600,000 more lake acres in 1998 than in 1996.
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How Do States
and Other Juris-
dictions Assess
Water Quality?
Water quality assessment begins with
setting goals through water quality
standards adopted by states, tribes, and
other jurisdictions such as territories.
These standards must then be approved
by EPA before they become effective
under the Clean Water Act.
Water quality standards have
three elements:
1 Designated uses. The
Clean Water Act envisions that
all waters be able to provide for
recreation and the protection
and propagation of aquatic life.
Additional uses described in the Act
that can be adopted in standards by
states and tribes include drinking
water supply and fish consumption.
^ Criteria. Criteria help protect
designated uses. For example,
criteria include chemical-specific
thresholds that protect fish and
humans from exposure to levels that
may cause adverse effects. They may
also include descriptions of the best
possible biological condition of
aquatic communities such as fish
and insects.
Q Antidegradation policy. This
policy is intended to prevent waters
that do meet standards from
deteriorating from their current
condition.
After setting water quality standards, states then assess their
waters to determine the degree to which these standards are
being met and report this information in their 305(b) reports.
Currently states use two categories of data to assess water
quality. The first and most desirable category is monitored data.
This refers to field measurements, not more than 5 years old, of
biological, habitat, toxicity, and physical/chemical conditions in
water, sediments, and fish tissue. The second category, frequently
used to fill information gaps, is evaluated data. Evaluated data
includes field measurements that are more than 5 years old and
estimates generated using land use and source information,
predictive models, and surveys of fish and game biologists. This
type of data provides an indicator of potential water quality.
Because evaluated data varies in quality and confidence, it is
used for different purposes by different states. Most states use
evaluated data to supplement monitoring data for their 305(b)
reports. This information helps states identify waters that need
additional monitoring.
After comparing water quality data to standards,
states, tribes, and jurisdictions classify their
waters into the following general categories:
Attaining Water Quality Standards
• Good/Fully Supporting: These waters meet applicable
water quality standards, both criteria and designated uses.
• Good/Threatened: These waters currently meet water
quality standards, but water quality may degrade in the
near future.
Not Attaining Water Quality Standards/Impaired
• Fair/Partially Supporting: These waters meet water
quality standards most of the time but exhibit occasional
exceedances.
• Poor/Not Supporting: These waters do not meet water
quality standards.
Water Quality Standards Not Attainable
• Not Attainable: The state has performed a use-
attainability analysis and demonstrated that support of one
or more designated uses is not attainable due to specific
biological, chemical, physical, or economic/social conditions.
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How Many
of Our Waters
Were Assessed
for 1998?
This report does not describe the health
of all U.S. waters because states and
other jurisdictions have not yet achieved
comprehensive assessment of all their
waters (see Figure 1). Therefore, this
report summarizes the health of only
the subset of waters that states assessed
in their individual 1998 water quality
inventories: 23% of river and stream
miles, 42% of lake acres, 32% of estuary
square miles, 5% of ocean shoreline
miles, and 90% of Great Lakes
shoreline miles.
Oceans, coral reefs, wetlands, and
ground water quality are poorly
represented in state monitoring
programs. In part, this is due to the
fact that few states have adopted water
quality standards for these resources.
EPA's wetlands and ground water
protection programs continue
to work with states to develop
assessment methods and water quality
standards and to improve monitoring
coverage. EPA is initiating a coastal
monitoring program, Coastal 2000,
that will provide a national baseline
characterization of coastal waters and
data needed to assist in development
of water quality standards (particularly
biological and nutrient criteria) for
these waters.
Figure 1
Percentage of Waters Assessed
for the 1998 Report
Rivers and Streams Hi 842,426 miles = 23% assessed
Total miles: 3,662,255 (of which 35% are perennial,
excluding Alaska)
Lakes, Ponds,
and Reservoirs
Estuaries
Ocean Shoreline Hi 3,130 miles = 5% assessed
Waters Total miles: 66,645, including Alaska's 44,000 miles
of shoreline
Hi 17,390,370 acres = 42% assessed
Total acres: 41,593,748
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Figure 2
What Is the Status
of Our Assessed
Waters?
Rivers and Streams
The United States has a total of
3,662,255 miles of rivers and streams.
States and other jurisdictions assessed
23% of these river and stream miles,
focusing primarily on perennial streams
(i.e., those that flow year round).
Altogether, the states and other
jurisdictions reported that of the 23% of
assessed stream miles, 65% fully support
designated uses and 35% are impaired.
They also report that 10% of the
assessed rivers and streams are fully
supporting but are threatened for one or
more uses (Figure 2). Aquatic life use is
the most frequently impaired individual
use in assessed rivers and streams
(Figure 3).
According to the states and other
jurisdictions, siltation and bacteria are
the most common pollutants affecting
assessed rivers and streams (Figure 4).
Siltation alters aquatic habitat and
suffocates fish eggs and other bottom-
dwelling organisms. Excessive siltation
can also interfere with drinking water
treatment processes and recreational use
of a river. Bacteria provide evidence of
possible fecal contamination that may
cause waters to be unsafe for swimming
and other recreational activities. Both
pollutants raise the costs of drinking
water treatment to remove them.
States and other jurisdictions reported
agriculture as the most widespread
Summary of State Assessments
of Rivers and Streams
Total Rivers and Streams
3,662,255 miles
ASSESSED Rivers and Streams
840,402' miles
10%
Good, but
Threatened
85,544 miles
35%
IMPAIRED
291,263 miles
"Includes miles assessed as not attainable.
States assessed 23% of river and
stream miles for the 1998 305(b)
report. For the subset of assessed
waters, 55% are rated as good,
10% as good but threatened,
and 35% as impaired.
Individual Use Support in Rivers and Streams
Percent
Good Good Fair Poor Not
Designated Miles (Fully (Threatened) (Partially (Not Attainable
Use Assessed Supporting) Supporting) Supporting)
Aquatic Life Support
<1
435,807
13
This figure presents a tally of the river and stream miles for each
key designated use. For each use, the figure presents the
percentage of assessed waters in each water quality category.
-------
Figure 4
source of pollution in assessed rivers
and streams. Agricultural activities may
introduce siltation, nutrients, pesticides,
and organic matter that deplete oxygen
in surface water. Nutrients and pesticides
can also leach into and contaminate
ground water. While the impact of
agricultural activities is significant, it
should be considered in context of the
amount of land supporting agricultural
activities. According to the 1997 Census
of Agriculture, 41% of the continental
United States, about 900 million acres,
is used for agricultural production.
Other leading sources of pollution in
assessed rivers and streams include
hydromodifications such as flow
regulation and modification,
channelization, dredging, and
construction of dams—which may
alter a river's habitat in such a way
that it becomes less suitable for aquatic
life—and urban area runoff and storm
sewer discharges.
Lakes, Reservoirs,
and Ponds
There are a total of 41,593,748 acres
of lakes, reservoirs and ponds in the
United States. In 1998, states and other
jurisdictions assessed 42%, or about
17.4 million acres. Altogether, states
and jurisdictions reported that of the
42% of lake acres assessed, 55% fully
support all of their uses and 45% are
impaired. They also reported that 9%
of the assessed acres are fully supporting
but threatened for one or more uses
(Figure 5).
Leading Pollutants and Sources
Impairing Assessed Rivers and Streams
Leading Pollutants/Stressors
Miles
Siltation
Pathogens (Bacteria)
Nutrients
Oxygen-Depleting Substances
Metals
Pesticides
Habitat Alterations
Thermal Modifications
Percent of IMPAIRED River Miles
10 20 30 40 50
5 10 15
Percent of ASSESSED River Miles
20
Leading Sources
Miles
Agriculture
Hydromodification
Urban Runoff/Storm Sewers
Municipal Point Sources
Resource Extraction
Forestry
Land Disposal
Habitat Modification
10
Percent of IMPAIRED River Miles
20 30 40 50 60
70
170,750
57,763
32,310
29,087
25,231
20,020
19,928
18,451
5 10 15 20
Percent of ASSESSED River Miles
25
These bar charts present the leading pollutants and sources reported by the
states. The percent scale on the lower axis compares the miles impacted to
the total ASSESSED miles. The upper axis compares the miles impacted to
the total IMPAIRED miles.
Figure 5
Summary of State Assessments
of Lakes, Reservoirs, and Ponds
Total Lakes
41.6 million acres
ASSESSED Lakes
17.4 million* acres
9%
Good, but Threatened
1.6 million acres
45%
IMPAIRED
7.9 million acres
"Includes acres assessed as not attainable.
States assessed 42% of lake, reservoir, and pond acres for the 1998
305(b) report. For the subset of assessed waters, 45% are rated as
good, 9% as good but threatened, and 45% as impaired.
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More lake, reservoir, and pond acres were
reported as impaired for aquatic life use
support than any other assessed use (Figure
6). However, where fish consumption use
was assessed, it was responsible for a higher
percentage of impaired acres. (Many states
did not evaluate fish consumption use
support in lakes because they have not
included this use in their water quality
standards.) Through separate tracking of
state fish consumption advisories, EPA
estimates that about 6.5 million lake acres
were under fish consumption advisories in
1998.
According to the states and other
jurisdictions, nutrients are the most
common pollutant affecting assessed lakes,
reservoirs, and ponds (Figure 7). While
healthy lake ecosystems contain nutrients
in small quantities from natural sources,
too many nutrients disrupt the balance
of lake ecosystems. Nutrient overenrichment
can initiate a chain of impacts that includes
algal blooms, low dissolved oxygen
conditions, fish kills, foul odors, and
excessive aquatic weed growth that can
interfere with recreational activities.
Metals are the second most common
pollutants in assessed lake acres, mainly due
to the widespread detection of mercury in
fish tissue samples. The mercury problem is
especially complex because it often includes
atmospheric transport from power-generating
facilities, waste incinerators, and other sources.
The most widespread source of pollution
reported for assessed lakes is agriculture,
followed by hydrologic modification, urban
runoff and storm sewers, municipal point
sources, and atmospheric deposition
(Figure?).
Individual Use Support in Lakes, Reservoirs, and Ponds
Percent
Good Good Fair Poor Not
Designated Acres (Fully (Threatened) (Partially (Not Attainable
Use Assessed Supporting) Supporting) Supporting)
Aquatic Life Support
This figure presents a tally of the lake, pond, and reservoir acres
assessed for each key designated use. For each use, the figure
presents the percentage of assessed waters in each water quality
category.
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Figure 7
Leading Pollutants and Sources Impairing
Assessed Lakes, Reservoirs, and Ponds
Leading Pollutants/Stressors
Acres
Nutrients
Metals
Siltation
Oxygen-Depleting Substances
Suspended Solids
Noxious Aquatic Plants
Excess Algal Growth
Percent of IMPAIRED Lake Acres
10 20 30 40
50
3,454,361
2,111,056
1,172,738
1,101,936
802,270
665,575
626,514
5 10 15 20
Percent of ASSESSED Lake Acres
25
Leading Sources
Acres
Agriculture
Hydromodification
Urban Runoff/Storm Sewers
Municipal Point Sources
Atmospheric Deposition
Industrial Point Sources
Habitat Modification
Land Disposal
Percent of IMPAIRED Lake Acres
10 20 30 40
50
2,417,801
1,179,344
931,567
866,116
616,701
502,760
417,662
381,073
5 10 15 20
Percent of ASSESSED Lake Acres
25
These bar charts present the leading pollutants and sources reported by the
states. The percent scale on the lower axis compares the acres impacted to
the total ASSESSED acres. The upper axis compares the acres impacted to
the total IMPAIRED acres.
Figure 8
Summary of State Assessments of Estuaries
Total Estuaries
90,465 square miles
ASSESSED Estuaries
28,687 square miles
9%
Good, but
Threatened
2,766 square
miles
44%
IMPAIRED
12,482 square
miles
States assessed 32% of estuary square miles for the 1998 305(b) report.
For the subset of assessed waters, 56% are rated as good, 9% as good
but threatened, and 44% as impaired.
Coastal Resources—
Estuaries, The Great Lakes, Ocean
Shoreline Waters, and Coral Reefs
The United States' extensive coastal
resources include nearly 67,000 miles of
ocean shoreline, more than 5,500 miles
of Great Lakes shoreline, about 90,500
square miles of tidal estuaries, and
extensive coral reef areas.
Estuaries
There are 90,465 square miles of
estuaries in the United States. Estuaries
are where rivers meet oceans, and they
include bays and tidal rivers. They serve
as nursery areas for many commercial
fish and most shellfish populations,
including shrimp, oysters, crabs, and
scallops. States and otherjurisdictions
assessed 32% of the total square miles of
estuaries in the country (Figure 8).
Altogether, states and otherjurisdictions
reported that of the 32% of estuarine
square miles assessed, 56% fully support
designated uses and 44% are impaired.
They reported that 9% of the assessed
square miles are fully supporting but
threatened for one or more uses. Aquatic
life use is the most frequently impaired
individual use in assessed estuaries
(Figure 9).
States reported that bacteria (pathogens)
are the most common pollutants
affecting assessed estuaries. Most states
monitor indicator bacteria, such as
Esherichia coli, which provide evidence
that an estuary is contaminated with
sewage that may contain numerous
viruses and bacteria that cause illness in
people. Humans can become exposed to
-------
Individual Use Support in Estuaries
Percent
square Good Good Fair Poor Not
Designated Miles (Fully (Threatened) (Partially (Not Attainable
Use Assessed Supporting) Supporting) Supporting)
L
Aquatic Life Support
This figure presents a tally of the estuary square miles
assessed for each key designated use. For each use, the
figure presents the percentage of assessed waters in each
water quality category.
these pathogens by consuming contaminated
fish and shellfish or contacting or ingesting
contaminated water during swimming.
In addition to pathogens, the states also reported
that oxygen depletion from organic wastes, metals,
nutrients, thermal modifications, PCBs, and priority
toxic chemicals impacts more square miles of
estuarine waters than other pollutants and
stressors.
Municipal point sources and urban runoff and
storm sewers are cited as the most widespread
sources of pollution in assessed estuaries
(Figure 10). These urban sources are significant
contributors to the degradation of estuarine waters
because large cities are located near most U.S.
estuaries.
The Great Lakes
There are 5,521 miles of Great Lakes shoreline in the
United States. The Great Lakes contain nearly one-
fifth of the fresh surface water on earth. Despite
their large size, the Great Lakes are sensitive to the
effects of a broad range of contaminants that enter
the Lakes from polluted air, ground water, surface
water, wastewater discharges, and overland runoff.
For the 1998 report, five of the eight Great Lakes
states assessed conditions of 90% of the nation's
total Great Lakes shoreline miles (Figure 11). The
states reported that of the 90% of assessed
shoreline miles, 4% fully support designated uses
and 96% are impaired. They also report that 2%
of the assessed waters are fully supporting but
threatened for one more uses.
The reporting states indicated that the greatest
impacts to Great Lakes shoreline are on fishing
activities (Figure 12). The states bordering the
Great Lakes have issued advisories to restrict
consumption of fish caught along their entire
shorelines. Depending upon the location, mercury,
PCBs, pesticides, or dioxins are found in fish tissues
10
-------
Figure 10
Leading Pollutants and Sources
Impairing Estuaries
Leading Pollutants/Stressors
Miles
Pathogens (Bacteria)
Oxygen-Depleting Substances
Metals
Nutrients
Thermal Modifications
PCBs
Priority Toxic Organic Chemicals
Percent of IMPAIRED Estuarine Square Miles
0 10 20 30 40 50 60
L
I
I
05 10 15 20 25
Percent of ASSESSED Estuarine Square Miles
5,919
5,185
3,431
2,880
2,222
1,315
806
Leading Sources
Miles
Municipal Point Sources
Urban Runoff/Storm Sewers
Atmospheric Deposition
Industrial Discharges
Agriculture
Land Disposal of Wastes
Combined Sewer Overflow
Percent of IMPAIRED Estuarine Square Miles
0 10 20 30 40 50
3,528
0 5 10 15 20 25
Percent of ASSESSED Estuarine Square Miles
These bar charts present the leading
pollutants and sources reported by the states.
The percent scale on the lower axis compares
the square miles impacted to the total
ASSESSED square miles. The upper axis
compares the square miles impacted
to the total IMPAIRED square miles.
Figure 11
Summary of State Assessments
of Great Lakes Shoreline
Total Great Lakes Shoreline
5,521 miles
ASSESSED Great Lakes Shoreline
4,950 miles
10%
Not
Assessed
2% Good, but
Threatened
103 miles
States assessed 90% of Great Lake shoreline miles for the 1998 305(b)
report. For the subset of assessed waters, 2% are rated as good, 2% as
good but threatened, and 96% as impaired.
11
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at levels that exceed standards set to protect
human health.
Priority organic chemicals, pesticides, and
nonpriority organic chemicals are the most
common pollutants affecting the waters
along the Great Lakes shoreline, according
to the three states that reported on
pollutants and sources (Figure 13). These
states reported that atmospheric deposition,
discontinued discharges from factories that
no longer operate, and contaminated
sediments are the primary sources of these
pollutants.
Ocean Shoreline Waters
There are 66,645 miles of ocean shoreline
in the United States, including Alaska.
Our ocean shoreline waters provide
critical habitat for various life stages of
commercial fish and shellfish (such as
shrimp), provide habitat for endangered
species (such as sea turtles), and support
popular recreational activities, including
sport fishing and swimming. Despite their
vast size and volume, oceans are vulnerable
to impacts from pollutants, especially in
nearshore waters that receive inputs from
adjoining surface waters, ground water,
wastewater discharges, and nonpoint
source runoff.
Fifteen of the 27 coastal states and territories
assessed conditions in 5% of the nation's
total ocean shoreline miles (Figure 14).
The states and territories reported that of
the 5% assessed, 88% of ocean shoreline
miles fully support designated uses and 12%
are impaired. They report that 8% of the
assessed miles are threatened for one or
more uses.
Figure 12
Jii
^ore,(-ne( '
! miles
assessed.
Individual Use Support in the Great Lakes
Good Good Fair Poor Not
Designated Miles (Fully (Threatened) (Partially (Not Attainable
Use Assessed Supporting) Supporting) Supporting)
Aquatic Life Support
This figure presents a tally of the Great Lakes shoreline miles
assessed for each key designated use. For each use, the figure
presents the percentage of assessed waters in each water quality
category.
12
-------
Figure 13
Leading Pollutants and Sources
Impairing Great Lakes Shoreline
Leading Pollutants/Stressors
Miles
Priority Toxic Organic Chemicals
Pesticides
Nonpriority Organic Chemicals
Nutrients
Pathogens (Bacteria)
Oxygen-Depleting Substances
Metals
Percent of IMPAIRED Great Lakes Shoreline Miles
0 5 10 15 20 25 30
1,391
1,017
1,017
234
186
175
143
05 10 15 20 25 30
Percent of ASSESSED Great Lakes Shoreline Miles
Leading Sources
Miles
Atmospheric Deposition
Discontinued Discharges from
Pipes*
Contaminated Sediments
Industrial Discharges
Urban Runoff/Storm Sewers
Agriculture
Municipal Point Sources
Percent of IMPAIRED Great Lakes Shoreline Miles
0 5 10 15 20 25
l_
I
I
I
I
1,017
1,017
684
140
134
133
120
0 5 10 15 20 25
Percent of ASSESSED Great Lakes Shoreline Miles
These bar charts present the leading
pollutants and sources reported by the
states. The percent scale on the lower
axis compares the miles impacted to the
total ASSESSED miles. The upper axis
compares the miles impacted to the
total IMPAIRED miles.
Figure 14
States assessed 5% of ocean
shoreline miles for the 1998
305(b) report. For the subset
of assessed waters, 80% are
rated as good, 8% as good
but threatened, and 12% as
impaired.
Summary of State Assessments
of Ocean Shoreline
Total Ocean Shoreline
66,645 miles
ASSESSED Ocean Shoreline
3,130* miles
95%
Not 5%
Assessed ASSESSED
8%
, Good, but
Threatened
257 miles
12%
IMPAIRED
377miles
'Includes miles assessed as not attainable.
13
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Swimming was the most frequently
assessed use in ocean shoreline waters
(Figure 15).
Bacteria (pathogens), turbidity, and excess
nutrients are the most common pollutants
affecting the assessed ocean shoreline.
The primary sources of pollution to
assessed shoreline miles include urban
runoff and storm sewers and land disposal
of wastes (Figure 16).
Coral Reefs
Coral reefs are among the most
productive ecosystems in the ocean.
They are inhabited by a wide variety
of fish, invertebrates, and plant species
and provide important economic
opportunities, primarily in terms of fishing
and tourism. Coral reefs are found in three
states—Hawaii, Florida, and Texas, and
five U.S. territories—American Samoa,
Guam, Northern Mariana Islands, Puerto
Rico, and the U.S. Virgin Islands
(Figure 17).
Recent evidence indicates that coral reefs
are deteriorating worldwide. To prevent
further deterioration of coral ecosystems,
President Clinton signed Executive Order
13089 on Coral Reef Protection. This
order created the U.S. Coral Reef Task
Force, composed of representatives from
the states and territories with coral
resources. In response, these areas have
initiated or increased efforts to identify
the causes of coral reef degradation and
approaches to prevent further loss.
Efforts are under way in Hawaii, Florida,
and American Samoa to assess the status
of coral reefs and identify pollutants
and stressors to coral reef ecosystems.
Individual Use Support in Ocean Shoreline Waters
Percent
Good Good Fair Poor Not
Designated Miles (Fully (Threatened) (Partially (Not Attainable
Use Assessed Supporting) Supporting) Supporting)
Aquatic Life Support
This figure presents a tally of the ocean shoreline miles assessed
for each key designated use. For each use, the figure presents the
percentage of assessed waters in each water quality category.
14
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Figure 16
Leading Pollutants and Sources
Impairing Ocean Shoreline
Leading Pollutants/Stressors
Miles
Pathogens (bacteria)
Turbidity
Nutrients
Suspended solids
Siltation
PH
Metals
10
Percent of IMPAIRED Shoreline Miles
20 30 40 50 60
70
80
Percent of ASSESSED Shoreline Miles
Leading Sources
Urban Runoff/Storm
Sewers
Land Disposal
Municipal Point Sources
Spills
Industrial Point Sources
Agriculture
Recreation and
Tourism Activities
Construction
Percent of IMPAIRED Shoreline Miles
10 20 30 40 50 60
Percent of ASSESSED Shoreline Miles
These bar charts present the leading pollutants and
sources reported by the states. The percent scale on
the lower axis compares the miles impacted to the
total ASSESSED miles. The upper axis compares the
miles impacted to the total IMPAIRED miles.
10
Miles
70
236
117
96
65
52
48
40
34
10
Figure 17
United States Coral Reef Areas
/Texas <1%
^U.S. Virgin Islands 1%
Guam 1%
Florida Keys 2%
American Samoa 2%
Puerto Rico 3%
'Other Pacific Islands 4%
N. Mariana Islands 3%
15
-------
The findings will be used to develop management
actions to protect coral reefs in these areas. Coral
reef stressors identified to date include invasive
species, marine debris, petroleum spills, nutrient
runoff, and septic discharges.
Wetlands
Wetlands are intermittently or permanently flooded
areas that are the link between land and water. The
functions and values of healthy wetlands include the
following:
• Storage of water - Wetlands help prevent
flooding by storing and slowing the flow of
water through a watershed.
• Storage of sediment and nutrients -
Wetlands act like filters that purify water in a
watershed.
• Growth and reproduction of plants and
animals - Wetlands produce a wealth of natural
products, including fish and shellfish, wildlife,
timber, and wild rice.
• Diversity of plants and animals - Wetlands
are critical to the survival of a wide variety of
plants and animals, including numerous rare or
endangered species as well as many species of
great commercial value to man.
It is estimated that over 200 million acres of
wetlands existed in the lower 48 states at the time of
European settlement. Since then, extensive wetlands
acreage has been lost, with many of the original
wetlands drained and converted to farmland and
urban areas. Today, less than half of our nation's
original wetlands remain. Recent federal studies
estimate an average net loss of wetlands around
100,000 acres per year in the contiguous United
States. Although losses continue to decline, we still
have to make progress toward our Administration's
goal of an annual net gain of 100,000 wetland acres
per year by the year 2005 and every year thereafter.
Eleven states and tribes listed sources of recent
wetlands loss in their 1998 305(b) reports. Eight states
cited agriculture as a leading source of current losses.
Other losses were due to construction of roads,
highways, and bridges; residential growth and urban
development; filling and/or draining; construction;
industrial development; commercial development; and
channelization.
The states and tribes are making progress in
incorporating wetlands into water quality standards
and developing designated uses and criteria specifically
for wetlands. But many states and tribes still lack
wetland-specific designated uses, criteria, and
monitoring programs for wetlands. Without criteria
and monitoring data, most states and tribes cannot
evaluate use support.
Ground Water
Ground water—water found in natural underground
formations called aquifers—is an important component
of our nation's fresh water resources. About 77,500
million gallons of the nation's ground water are
withdrawn daily for use in drinking and bathing,
irrigation of crop lands, livestock watering, mining,
industrial and commercial uses, and thermoelectric
cooling applications (Figure 18). Unfortunately, this
valuable resource is vulnerable to contamination,
and ground water contaminant problems are being
reported throughout the country. Ground water
contamination can occur through relatively well
defined, localized pollution plumes emanating from
specific sources such as leaking underground storage
tanks, or it can occur as a general deterioration of
ground water quality over a wide area due to diffuse
nonpoint sources such as agricultural fertilizer
and pesticide applications, septic systems, and
urban runoff.
Based on results reported by states in their 1998
305(b) reports, ground water quality in the nation is
good and can support the many different uses of this
16
-------
resource. However, despite these positive results,
measurable negative impacts to aquifers across the
nation have been detected, and they are usually traced
back to human activities.
States identified leaking underground storage tanks as
an important potential threat to our nation's ground
water resources. This was based on the sheer number
of underground storage tanks and the risk posed to
human health and the environment from releases.
States also report that the organic chemicals found in
petroleum products such as gasoline are common
ground water contaminants. Other potential sources of
ground water contamination include septic systems,
landfills, industrial facilities, fertilizer and pesticide
applications, accidental spills, surface impoundments,
and animal feedlots. Contaminants occur in the form
of organic compounds, metals, and nitrate.
Assessing the quality of our nation's ground water
resources is no easy task. An accurate and
representative assessment of ambient ground water
quality requires a well-planned and well-executed
monitoring plan. Although the 305(b) ground water
program is improving, there is still much to be done.
States need to increase their monitoring coverage and
focus on collecting ground water data that are most
representative of the resource.
Figure 18
National Ground Water Use
Irrigation 63%
Commercial 1 %
„—-Thermoelectric 1%
Livestock Watering 3%
Domestic Supply 4%
Mining 3%
Industrial 5%
Public Supply 20%
Source: Estimated Use of Water in the United States in 1995.
U.S. Geological Survey Circular 1200,1998.
How Does Impaired
Water Quality Impact
Public Health and
Aquatic Life?
Water pollution threatens both public health and
aquatic life. Public health may be threatened directly
through the consumption of contaminated food or
drinking water or indirectly through skin exposure to
contaminants present in recreational and boating
waters. Aquatic organisms can be affected by the
presence of toxic chemicals in their environment and
are also particularly susceptible to changes in the
physical quality of their environments, such as changes
in pH, temperature, dissolved oxygen, and habitat.
Public Health Concerns
The 1998 EPA Listing of Fish and Wildlife Advisories
listed 2,506 advisories in effect in 47 states, the District
of Columbia, and American Samoa (Figure 19).
Mercury, PCBs, chlordane, dioxins, and DDT (with its
byproducts) caused 99% of all the fish consumption
advisories in effect in 1998.
In their 1998 305(b) reports, 11 of the 27 coastal
states and jurisdictions reported shellfish harvesting
restrictions in over 2,300 square miles of estuarine
waters. These areas are monitored for bacteria as part
of the National Shellfish Sanitation Program.
Advisories were also issued to warn the public about
health risks from water-based recreation. Sixteen states
and tribes identified 240 sites where recreation was
restricted at least once during the reporting cycle.
The states and tribes identified sewage treatment plant
bypasses and malfunctions, urban runoff and storm
sewers, and faulty septic systems as the most common
sources of elevated bacteria concentrations in bathing
areas.
17
-------
Thirty-eight states, tribes, and other
jurisdictions provided information about
the degree to which drinking water use is
met. Of the 23% of river and stream miles
assessed, only 3% do not support drinking
water where it is a designated use; of the
42% of lake and reservoir acres assessed,
5% do not support drinking water use.
Increasingly, states are coordinating
their efforts under the Safe Drinking
Water Act (SDWA) and the Clean Water
Act (CWA) to assess sources of drinking
water. SDWA requires states to determine
the susceptibility to contamination of
drinking water sources, while the CWA
calls for them to assess the ability of
waters to support drinking water use.
Assessments under both laws will provide
the information necessary for states to
develop tailored monitoring programs
and for water systems to work with states
and local governments to protect drinking
water sources.
Aquatic Ecosystem Concerns
A fish kill is one of the most obvious
effects of pollution on aquatic life. This
phenomenon is normally attributed to
exceptionally low dissolved oxygen
levels—usually due to excessive nutrients
in the water—or to the discharge of toxic
contaminants to the water column. A
more insidious impact of pollution on
aquatic organisms is the development of
growths, lesions, and eroded fins, or
increased body burden of toxic chemicals.
The most common impact of pollution on
aquatic life is the shift of a waterbody's
naturally occurring and self-sustaining
population from one type of aquatic
Figure 19
Fish and Wildlife Consumption Advisories
in the United States
Number of Advisories in Effect
•& American Samoa (December 1 998)
I 1 1-10
I 1 11-20
I 1 21-30
^M 31-50
I 1 51-100
^M >100
* Statewide Advisory
Note: States that perform routine fish tissue analysis (such as the Great Lakes
states) will detect more cases offish contamination and issue more
advisories than states with less rigorous fish sampling programs. In many
cases, the states with the most fish advisories support the best monitor-
ing programs for measuring toxic contamination in fish, and their water
quality may be no worse than the water quality in other states.
community to another. An example is the shift of a cold
water trout stream to a warm water carp-dominated stream.
Changes in aquatic community structure and function may
occur due to a variety of reasons, but the most common are
an elevation of temperature, a lowering of available
dissolved oxygen, and an increase in sedimentation due to
land use practices within the watershed.
The persistence of chemicals in bottom sediment poses risks
to both aquatic life and humans. These chemicals may be
toxic to bottom-dwelling aquatic organisms. Some of these
chemicals, like mercury and PCBs, bioaccumulate in fish
tissue and pose a potential threat to humans and other
organisms that consume the fish. In their 1998 305(b)
reports, 11 states and tribes listed 115 separate sites with
contaminated sediments. These states and tribes most
18
-------
frequently listed metals, PCBs, pesticides, PAHs, and
other priority organic chemicals as the source of
contamination. They identified industrial and municipal
discharges (both past and present), landfills, resource
extraction, and abandoned hazardous waste disposal
sites as the primary sources of contamination.
What Is Being
Done to Restore
and Maintain
Water Quality?
Public polls consistently document that Americans
value water quality. In addition to its economic
benefits, clean water provides recreational and
aesthetic benefits. As a result, local, state, and federal
agencies, the private sector, and other organizations
are working to improve water quality. According to
President Clinton's Clean Water Act Initiative: Analysis
of Costs and Benefits, these partners spend between
$63 billion and $65 billion dollars each year to
improve and protect water quality.
This study estimated that private sources spend a
combined total of about $30 billion per year on
pollution prevention and control efforts. Agriculture
spends another $500 million per year on activities
that reduce its impact on water quality, including
implementation of best management practices to
control the effects of nonpoint source runoff.
Municipalities spend a total of $23 billion per year,
primarily on wastewater treatment plants, drinking
water treatment, and storm water pollution control.
State governments dedicate almost $500 million and
federal governments dedicate almost $10 billion to
water resource protection and restoration efforts each
year. These efforts include developing and revising
water quality standards, monitoring and assessing
water quality, characterizing causes and sources of
impairment, developing total maximum daily loads
and allocating these loads to point and nonpoint
sources, implementing permitting programs to address
point sources, and developing and implementing best
management practices to control nonpoint source
pollution.
Significant resources are dedicated to restoring and
maintaining water quality. Water quality monitoring
and assessment is a critical tool to help ensure that
these resources are used effectively to achieve water
quality goals. EPA and state environmental agencies
recognize that water quality monitoring and
assessment programs need continued strengthening
to be able to evaluate the effectiveness of water quality
protection and restoration efforts.
EPA continues to work with states and other partners
to increase the quality and comprehensiveness of water
quality monitoring and assessment programs. This is
achieved through data sharing and development of
consistent monitoring designs and assessment criteria.
EPA provides technical assistance, guidance, and
resources for monitoring design and implementation.
EPA and its partners including states, tribes, other
federal agencies, and other public and private
monitoring organizations are developing a
Consolidated Assessment and Listing Methodology
(CALM) that will provide a consistent approach for
characterizing water quality under both Sections
305(b) and 303(d) of the Clean Water Act.
For more information on CALM, visit EPA's website at
www.epa.gov/owow/monitoring/wqreport.html.
19
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For More Information
For more information about the National Water Quality Inventory:
1998 Report to Congress, visit EPA's Office of Water 305(b) website
at http://www.epa.gov/305b, call EPA's Assessment and Watershed
Protection Division at (202) 260-7040, or contact:
U.S. EPA (4503F)
Assessment and Watershed Protection Division
401 M Street, SW
Washington, DC 20460
For a copy of the National Water Quality Inventory: 1998 Report to
Congress (EPA-841-R-00-001) or related materials, call 1-800-490-
9198, fax your order to EPA's National Service Center for
Environmental Publications at (513) 489-8695 (include EPA number
and document title), or send your order to:
National Service Center for Environmental Publications
11029 Kenwood Road, Building 5
Cincinnati, OH 45242
Q National Water Quality Inventory: 1998 Report to Congress
(434 pages) (EPA841-R-00-001)
Q National Water Quality Inventory: 1998 Report to Congress
Appendixes (diskette) (EPA841-C-00-001)
Q Water Quality Conditions in the United States: A Profile from the
National Water Quality Inventory: 1998 Report to Congress
(2 pages) (EPA841-F-00-006)
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MF-2274 • Organic Waste
DEPARTMENT OF AGRONOMY
Considerations
for Direct Land
Application
of Organic
Waste Products
William M
Extension Specialist
igh costs and
capacity pressures on
landfills and wastewater
treatment systems have
caused many managers of
these systems seek
alternatives for organic waste. Composting has become
a popular option, but it can be expensive and does not
work well for processing high-moisture waste. Increas-
ingly, direct land application of organic waste is seen
as a low-cost option that allows a waste product to be
used beneficially for crop production.
Many types of organic waste products are being
directly applied to land. Agricultural waste such as
manure and livestock bedding has been land applied
for centuries. Land application is the primary method
of utilizing sewage sludge biosolids from more than
130 Kansas wastewater treatment systems. Farmers are
accustomed to dealing with manure, and sewage sludge
application is highly regulated. Today however, waste
products considered for land application include yard
waste, supermarket
vegetable waste,
restaurant and
institutional food
waste, grain handling
waste, a wide variety
of waste products
from the food
processing industry,
and many other
sources. Most farmers
are unfamiliar with
Eberle
, Land Resources
MANAGING WASTE
land applying these
products that are, for the
most part, unregulated, or
for which specific stan-
dards are not established.
Organic waste prod-
ucts tend to vary widely in content. It ranges from
nearly dry products to materials that are mostly water.
The only thing the products have in common is that
they all contain at least some organic material, and they
may contain from minute to significant amounts of
nutrients beneficial to plants.
Organic waste products also may contain compo-
nents that can be detrimental to crop production and
soil health, such as soluble salts, fats, weed seeds, and
pathogens, and may vary in pH (relative acidity or
alkalinity). Some may have a wide carbon-nitrogen
ratio (C-N) so that microbial action may temporarily tie
up plant available nitrogen in the soil water. Wastes
from processing operations could potentially, though
rarely, contain heavy metals and many other com-
Know the product. Know the soil Know the crop.
1. Get analysis of waste product.
2. Determine potential harmful components.
3. Obtain soil tests.
4. Determine crop needs.
5. Estimate benefits and costs.
6. Investigate need for required permits.
7. Establish application methods and timing.
Kansas State University Agricultural Experiment Station and Cooperative Extension Service
-------
pounds, depending on the particular process and
product. Some products may result in objectionable
odors or may attract rodents, birds, or other animals.
Because of the wide variation in composition, it is
impossible to make specific recommendations that
apply to all organic waste products. Nevertheless, there
are some general factors that should be considered in
making land application decisions.
Nutrients
Know what nutrients are present in the organic
residue. Have the material tested for nitrogen, phospho-
rus, and potassium. This, along with soil tests on the
land where application is intended, will provide the
information needed to determine the appropriate applica-
tion rate. If too little is applied, it will be necessary to
add other fertilizer for optimum crop production. If too
much is applied, nutrients may be wasted and, in some
cases, be environmentally harmful. Nitrogen supplied in
excess of crop needs can result in residual nitrates that
have the potential to leach into the groundwater given
the right soil and climate conditions. Excessive phospho-
rus may move with runoff water and contaminate
surface bodies of water.
Nitrogen is usually of greatest concern. It may occur
in several forms in organic material. Plants utilize
nitrogen either as ammonia or nitrate. Usually nitrate
nitrogen is present in only small amounts in organic
waste. Ammonia is most likely to be present in high-
moisture waste products. Most nitrogen, however, will
be in organic compounds.
Soil microorganisms break down organic material,
using carbon compounds as an energy source and
nitrogen compounds for synthesis of proteins that are
part of the organisms' bodies. When an organic waste
with a wide C-N ratio (low nitrogen) is applied to the
soil, microorganisms will satisfy their nitrogen needs
for protein synthesis by using nitrogen already existing
in the soil in the nitrate form. As microorganism
numbers increase, nitrogen is tied up or immobilized.
With time, as the carbon source is depleted and micro-
organisms die, that immobilized nitrogen will mineral-
ize into the form needed by plants. However while of
rapid decomposition of high-carbon material, nitrogen
available for plant use may be limited unless supple-
mental nitrogen is supplied.
When organic waste with a narrow C-N ratio is land
applied, nitrogen in excess of what the microbes and
crop need has the potential to leach into the groundwa-
ter as nitrate. Ammonia nitrogen can be lost or volatil-
ized into the atmosphere, especially when high mois-
ture waste products are applied to the surface and not
immediately incorporated into the soil. Nitrogen should
not be applied to soil in excess of expected crop
utilization. The Kansas Department of Health and
Environment, Bureau of Water, has developed a
worksheet used in calculating the nitrogen agronomic
rate for sewage sludge biosolids application. This
worksheet should work equally well with other land
applied materials containing nitrogen (Contact the
Kansas Department of Health and Environment,
Bureau of Water, 785/296-5520, for a copy of the
agronomic rate calculation worksheet "LA-ANR")
Some wastes have very low nutrient content and
contain little organic matter. Those that are mostly
water may only have value as supplemental irrigation
water. Though the substances may not be harmful,
farmers will have to decide whether applying low
nutrient content materials is worthwhile without special
compensation.
Soluble salts and pH
Some organic waste products, particularly food
processing waste, can contain considerable soluble
salts. Soluble salts in the soil are measured by deter-
mining the capacity of a solution extracted from a
saturated paste of a soil sample to conduct electricity.
Salt concentration is directly related to electrical
conductivity, usually expressed in millimhos per
centimeter (mmhos/cm). Crops commonly grown in
Kansas are not significantly affected on soils with salt
levels of 0 to 2 mmhos/cm.
Growth of most plants is progressively reduced as
the salt level in the soil increases. Some areas of
Kansas have large areas of soil naturally high in
soluble salts. Both the soil and the waste should be
tested for soluble salts before application. High-salt
wastes should be applied with care to soils that are
already above the 2 mmho/cm level. For other soils,
regular soil tests for soluble salts should be used to
ensure that salt levels do not rise to a level that limits
plant growth.
Most crops prefer a fairly neutral soil pH level. At
normal application rates, organic waste usually will not
have a major impact on soil pH. Nevertheless, to be
safe, test both the soil and the waste for pH to ensure
that the applied material will not further aggravate an
existing very high or low soil pH.
-------
Other contaminants
Most organic waste products will probably be
relatively free of heavy metals and chemical com-
pounds. However, manufacturing processes could
introduce contaminants into some organic waste
products that may be harmful to plant growth or the
environment. It is important to ask a lot of questions
about the source of the material and how it was pro-
duced. If in doubt, ask for a laboratory analysis of the
heavy metal content of the material. Standards have
been developed for metal concentrations of sewage
sludge biosolids allowable for application to agricul-
tural land. It is recommended that those same standards
be used in determining the suitability of other organic
wastes that are land applied. (Contact the Kansas
Department of Health and Environment, Bureau of
Water, 785/296-5520, for "Kansas Sludge Reporting
Forms" used in determining allowable biosolids
application rates based on metal content.)
Odors, pests, and pathogens
Odors can be a problem when some organic wastes
are applied to land. Some material may have inherent
unpleasant odors. Other material may become more
odorous after it is applied and begins to decay. It is
helpful to immediately incorporate any applied mate-
rial into the soil. Some material applied in large
amounts or containing large pieces, may require
several tillage passes for incorporation. Pre-shredding
may be necessary. Subsurface injection of liquid
materials, usually to a depth of six or more inches, will
significantly reduce odor problems. Sometimes odors
are difficult to avoid, but complaints can be minimized
by providing adequate buffer zones between the
application area and residences or other human activ-
ity. Transportation routes should be followed that avoid
passage though concentrated residential areas.
Some organic material, especially food waste, may
attract rodents, birds, and other animals. Again, incor-
poration into the soil is the best practice.
Effective composting destroys most weed seeds and
pathogens. Farmers should be aware that some di-
rectly-applied untreated organic waste products may
contain one or both. Pathogens are most likely to be
present in untreated processing wastes, especially those
containing animal products. Weed seeds may be found
in unprocessed plant materials, such as yard waste. Be
aware of the source of the waste material and be
prepared to manage it accordingly.
Application equipment
Frequently, application of waste material will
require the use of specialized equipment not available
on many farms. Liquid materials can often be injected
directly into the soil. Injectors will need to be adjusted
or specially adapted to the type of material. Very wet
solids can be difficult to spread evenly. Typical manure
spreading equipment may work for this type of mate-
rial, but will often require adjustment or adaptation,
especially if the material contains large pieces, as in
some food waste. Bulky materials, such a yard waste,
also can present special challenges in application. The
best approach may be to require the provider of the
waste material to be responsible for application in
accordance with procedures set by the farmer.
Effects on the soil
Of course, the goal of applying waste residues to
land usually is to improve the soil. In the best of
worlds, the application process will add useful nutri-
ents to enhance plant growth or increase organic matter
that will have a positive effect on soil physical and
biological characteristics. However, even the applica-
tion of beneficial material also can have a negative
effect on the soil.
Land application of wastes will usually mean more
trips across the land with machinery. A major concern
is soil compaction, which can be minimized by follow-
ing several steps: 1) Make as few trips across a field as
possible, 2) Keep large trucks and other road transpor-
tation equipment off the field if possible, 3) Use field
equipment that minimizes soil compaction, and 4) Do
not apply waste products when the soil is wet.
Land application of waste can have an impact on
residue management. Incorporation activities will often
destroy much of the surface crop residue, leaving the
soil more susceptible to wind and water erosion. Even
injection destroys a significant amount of residue. It is
recommended that most land application requiring
incorporation be done on less erodible land and, if
possible, near the time a crop will be planted.
Laboratory analysis
The farmer should not hesitate to ask for a laboratory
analysis of any material for which there is concern about
what it may contain. Typically such analysis would
include, at a minimum, the nutrients nitrogen (total,
organic, and ammonia), phosphorus, and potassium, and
pH. Percent organic matter or organic carbon also may
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be useful. Electrical conductivity should be included if
high salts are suspected. If it is a limey material, infor-
mation about the calcium carbonate equivalent would be
helpful in proper management. For high-solids organic
waste products, request information on the carbon-
nitrogen ratio. Finally, if there is any reason to believe
that heavy metals may be present in the material, ask
that they be included in the analysis.
Permits and regulations
Being aware of possible regulations that may apply
to land application of various types of waste is impor-
tant. Land application of any material containing
sewage sludge biosolids and wastewater is highly
regulated and permits will be required. Land applica-
tion of agricultural waste, including manure, is not
highly regulated. Questions about materials containing
either biosolids or animal waste relating to permits,
rates, or environmental concerns, should be addressed
to the Kansas Department of Health and Environment,
Bureau of Water (785/296-5500). Permits may be
required for application of material normally consid-
ered part of the municipal solid waste stream. This
includes food waste, yard waste, processing or indus-
trial waste, and other waste products that have been
traditionally disposed of in landfills. Questions relat-
ing to those materials should be addressed to the
Kansas Department of Health and Environment,
Bureau of Waste Management (785/296-1600).
Kansas State University Agricultural Experiment Station and Cooperative Extension Service
Issued in furtherance of Cooperative Extension Work, acts of May 8 and June 30,1914, as amended. Kansas State University, County Extension Councils,
Extension Districts, and U.S. Department of Agriculture Cooperating, Richard D. Wootton, Associate Director. All educational programs and materials
available without discrimination on the basis of race, color, national origin, sex, age, or disability.
File Code: Environment & Pollution Control 8 MS8-97—2M
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COMPREHENSIVE NUTRIENT MANAGEMENT PLANNING
TECHNICAL GUIDANCE
DECEMBER 1, 2000
United States Department of Agriculture
Natural Resources Conservation Service
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The U.S. Department of Agriculture (USD A) prohibits discrimination in its programs on the basis of
race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, and marital
or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require
alternative means for communication of program information (Braille, large print, audiotape, etc.) should
contact USDA's TARGET Center at (202) 720-2600 (voice and TDD).
To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326W,
Whitten Building, 14th and Independence Avenue, SW, Washington, DC 20250-9410 or call (202) 720-
5964 (voice and TDD). USDA is an equal opportunity provider and employer.
11
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION
3
2.0 DEFINITION ..
2.1 Conservation Planning Process
3.0 OBJECTIVE ..
4
4.0 CRITERIA ..
4.1 General Criteria
4.2 Element Criteria
4.2.1 Manure and Waste water Handling and Storage
4.2.1.1 Criteria That Must Be Met for Manure and
Wastewater Handling and Storage
4.2.3 Nutri ent Management
4.2.3.1 Criteria That Must Be Met for Nutrient Management ...
4.2.3.2 Consideration for Nutrient Management
4.2.4 Record Keeping
4.2.5 Feed Management
4.2.6 Other Utilization Activities
6
4.2.1.2 Considerations for Manure and Wastewater
Handling and Storage 7
4.2.2 Land Treatment Practices
4.2.2.1 Criteria That Must Be Met for Land Treatment Practices
9
9
10
11
12
13
5.0 CERTIFICATION ..
14
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TABLE OF CONTENTS
APPENDICES
Page
A. THE NRCS CONSERVATION PLANNING PROCESS AND CNMP
DEVELOPMENT
16
B. TECHNICAL REFERENCES, HANDBOOKS, AND POLICY
DIRECTIVES
NRCS NUTRENT MANAGEMENT POLICY
20
22
C. COMPREHENSIVE NUTRIENT MANAGEMENT PLAN
FORMAT AND CONTENT
35
D. CONSERVATION PRACTICE STANDARDS
NUTRIENT MANAGEMENT (CODE 590)
WASTE STORAGE FACILITY (CODE 313)
WASTE UTILIZATION (CODE 633)
38
39
45
51
E. NRCS FIELD OFFICE TECHNICAL GUIDE
54
F. BACKGROUND INFORMATION AND CURRENT RESEARCH
ON RESOURCE CONCERNS
Air Quality ..
Pathogens ...
Nutrient Management
55
55
57
59
G STATE OFFICES
64
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COMPREHENSIVE NUTRIENT MANAGEMENT PLANNING
TECHNICAL GUIDANCE
1.0 INTRODUCTION
USDA's goal is for animal feeding operation (AFO) owners/operators to take voluntary
actions to minimize potential water pollutants from confinement facilities and land
application of manure and organic by-products. To accomplish this goal, it is a national
expectation that all AFOs should develop and implement technically sound, economically
feasible, and site-specific Comprehensive Nutrient Management Plans (CNMP)
In general terms, a CNMP identifies management and conservation actions that will be
followed to meet clearly defined soil and water conservation goals, including nutrient
management, at an agricultural operation. Defining soil and water conservation goals and
identifying measures and schedules for attaining the goals are critical to reducing threats to
water quality and public health from AFOs. The CNMP should fit within the total resource
management objectives of the entire farm/animal feeding operation.
The Comprehensive Nutrient Management Planning Technical Guidance is a document
intended for use by those individuals (both public and private) who develop or assist in the
development of CNMPs. The purpose of this document is to provide technical guidance for
the development of CNMPs, whether they are developed for USDA's voluntary programs or
as a means to help satisfy the United States Environmental Protection Agency's (USEPA)
National Pollutant Discharge Elimination System (NPDES) permit requirements.
This technical guidance is not intended as a sole-source reference for developing CNMPs.
Rather, it is to be used as a tool in support of the conservation planning process (see
Appendix A), as contained in the USDA Natural Resources Conservation Service (NRCS)
National Planning Procedures Handbook (NPPH) and NRCS Technical References,
Handbooks, and Policy Directives (see Appendix B).
2.0 DEFINITION
A CNMP is a conservation system that is unique to animal feeding operations. A CNMP is
a grouping of conservation practices and management activities which, when implemented
as part of a conservation system, will help to ensure that both production and natural
resource protection goals are achieved. It incorporates practices to utilize animal manure
and organic by-products as a beneficial resource. A CNMP addresses natural resource
concerns dealing with soil erosion, manure, and organic by-products and their potential
impacts on water quality, that may derive from a animal feeding operation. A CNMP is
developed to assist an AFO owner/operator in meeting all applicable local, tribal, State, and
Federal water quality goals or regulations. For nutrient impaired stream segments or water
bodies, additional management activities or conservation practices may be required by
local, tribal, State, or Federal water quality goals or regulations.
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The conservation practices and management activities planned and implemented as part of
a CNMP must meet NRCS technical standards. For those components included in a CNMP
where NRCS does not currently maintain technical standards (i.e., feed management,
vector control, air quality, etc.), producers must meet criteria established by Land Grant
Universities, Industry, or other technically qualified entities. Within each state, the NRCS
State Conservationist has the authority to approve non-NRCS criteria established for use in
the planning and implementation of CNMP components.
2.1 Conservation Planning Process
Conservation planning is a natural resource problem-solving process. The process
integrates ecological (natural resource), economic, and production considerations in
meeting both the owner's/operator's objectives and the public's resource protection needs.
This approach emphasizes identifying desired future conditions, improving natural resource
management, minimizing conflict, and addressing problems and opportunities.
The NRCS' NPPH provides guidance in the application of effective conservation planning
procedures in the development of conservation plans. This Comprehensive Nutrient
Management Planning Technical Guidance does not replace the NRCS NPPH
requirements, rather, it provides complementary guidance in applying the NRCS planning
process specific to the development of CNMPs. (See Appendix A, Conservation Planning
Process and CNMP Development.)
3.0 OBJECTIVES
The objective of a CNMP is to provide AFO owners/operators with a plan to manage
manure and organic by-products by combining conservation practices and management
activities into a conservation system that, when implemented, will protect or improve water
quality. The elements of a CNMP should be developed by certified specialists.
4.0 CRITERIA
This section establishes the minimum criteria to be addressed in the development and
implementation of CNMPs.
4.1 General Criteria
Comprehensive Nutrient Management Plans will meet the following criteria:
• Provide documentation that addresses the outlined items provided in Appendix C
(Comprehensive Nutrient Management Plan Format and Content).
• Document the consideration of the following CNMP elements (It is recognized that a
CNMP may not contain all of the six following elements; however, all six elements
need to be considered by the owner/operator during plan development, and the
owner/operators decisions concerning each must be documented):
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1) Manure and Wastewater Handling and Storage
2) Land Treatment Practices
3) Nutrient Management
4) Record Keeping
5) Feed Management
6) Other Utilization Activities
• CNMPs will contain actions that address soil erosion and water quality criteria for the
feedlot, production area, and land on which the manure and organic by-products will
be applied (i.e., as a minimum the plan would address CNMP elements 1, 2, 3, and
4 listed above). For AFO owners/operators who do not land apply any manure or
organic by-products, the CNMP would only address the feedlot and production areas
(i.e., address CNMP elements 1, 4, and 6 listed above).
• Meet requirements of NRCS Field Office Technical Guide (FOTG) conservation
practice standards for practices contained in the CNMP.
• Meet all applicable local, Tribal, State, and Federal regulations.
• When applicable, ensure that USEPA NPDES or State permit requirements (i.e.
minimum standards and special conditions) are addressed.
4.2 Element Criteria
Each of the CNMP's elements will address specific criteria. The degree to which these
elements are addressed in the development and implementation of a site-specific CNMP is
determined by the General Criteria in Section 4.1 and the specific criteria provided for each
element. The elements will address the following specific criteria:
4.2.1 Manure and Wastewater Handling and Storage
This element addresses the components and activities associated with the production
facility, feedlot, manure and wastewater storage and treatment structures and areas, and
any areas used to facilitate transfer of manure and wastewater. In most situations,
addressing this element will require a combination of conservation practices and
management activities to meet the production needs of the AFO owner/operator and
environmental concerns associated with the production facility.
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4.2.1.1 Criteria for Manure and Wastewater Handling and Storage
• Provide for adequate collection, storage, and/or treatment of manure and organic
by-products that allows application during favorable weather conditions and at
times compatible with crop management. Collection, storage, treatment, and/or
transfer practices shall meet the minimum requirements as addressed in the
following NRCS conservation practice standards (See Appendix D), contained in
Section IV of the NRCS FOTG, as appropriate:
• Waste Storage Facility (Code 313)
• Waste Treatment Lagoon (Code 359)
• Manure Transfer (Code 634)
• Heavy Use Protection (Code 561)
• Comply with existing federal, Tribal, State, and local regulations, associated with
the following activities:
• Disposal of dead animals
• Disposal of animal medical wastes
• Spoiled feed or other contaminants that may be regulated by other than a
NPDES or State concentrated animal feeding operation (CAFO) permitting
program
NRCS does not have national conservation practice standards that address all
these activities. Generally, federal, Tribal, State and local regulations dictate
acceptable procedures; however, NRCS in some States has developed
standards that address the disposal of dead animals by incineration or freezing.
• Documentation of the following:
• Types of animals and phases of production that exist at the facility.
• Numbers of each animal type, average weight, and period of confinement for
each phase of production.
• Total estimated manure and wastewater volumes produced at facility. Where
historical manure and wastewater production volumes are not documented,
an estimate may be made using the procedures and table data provided in
the NRCS Agricultural Waste Management Field Handbook (AWMFH),
Chapter 4, "Waste Characteristics".
• Manure storage type, volume, and length of storage. For more information
on storage and treatment systems, how they function, their limitations, and
design guidance see NRCS AWMFH, Chapter 9, "Animal Waste
Management Systems", and Chapter 10, "Component Design".
• Existing transfer equipment, system and procedures.
• Operation and maintenance activities that address the collection, storage,
treatment and transfer of manure and wastewater, including associated
equipment, facilities and structures.
• Nutrient content and volume of manure, if transferred to others.
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An emergency action plan that addresses spills and catastrophic events.
4.2.1.2 Considerations for Manure and Wastewater Handling and Storage
There are additional considerations associated with CNMP development and
implementation that should to be addressed. However, NRCS does not have specific
technical criteria for these considerations that are required for CNMPs.
Air Quality
AFO operators/owners need to consider the impact of selected conservation
practices on air quality during the CNMP development process. Air quality in and
around structures, waste storage areas and treatment sites may be impaired by
excessive dust, gaseous emissions such as ammonia, and odors. Poor air quality
may impact the health of workers, animals and persons living in the surrounding
areas. Ammonia emissions from animal operations may be deposited to surface
waters, increasing the nutrient load to these regions. Proper siting of structures and
waste storage facilities can enhance dispersion and dilution of odorous gases.
Enclosing waste storage or treatment facilities can reduce gaseous emissions from
AFOs in areas with residential development in the region. Background information
on the current state of the knowledge, research gaps, and on-going research
projects being carried out on air quality at USDA are provided in Appendix F.
Pathogens
AFO operators/owners need to consider the impact of selected conservation
practices on pathogen control during the CNMP development process. Pathogenic
organisms occur naturally in animal wastes. Exposure to some pathogens by
humans and animals can cause illness, especially for immune-deficient populations.
Many of the same conservation practices used to prevent nutrient movement from
animal operations, such as leaching, runoff and erosion control are likely to prevent
the movement of pathogens. Background information on the current state of the
knowledge, research gaps, and on-going research projects being carried out on
pathogens at USDA are given in Appendix F.
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4.2.2 Land Treatment Practices
This element addresses evaluation and implementation of appropriate conservation
practices on sites proposed for land application of manure and organic by-products from an
AFO. On fields where manure and organic by-products are applied as beneficial nutrients,
it is essential that runoff and soil erosion be minimized to allow for plant uptake of these
nutrients. An understanding of the present land use of these fields is essential in
developing a conservation system to address runoff and soil erosion.
4.2.2.1 Criteria for Land Treatment Practices
• An on-site visit is required to identify existing and potential natural resource
concerns, problems, and opportunities for the conservation management unit
(CMU).
• Identification of the potential for nitrogen or phosphorus losses from the site.
• As a minimum, the conservation system developed for this element will address
water quality and soil erosion NRCS Quality Criteria, found in Section III of the
FOTG. (See Appendix A for an example of how a conservation system is
developed within the framework of the NRCS conservation planning process.)
Typical NRCS conservation practices, and their corresponding NRCS
conservation practice standard code number, used as part of a conservation
system to minimize runoff and soil erosion are:
• Conservation Crop Rotation (Code 328)
• Residue Management, No Till and Strip Till (Code 329A)
• Residue Management, Mulch Till (Code 329B)
• Residue Management, Ridge Till (Code 329C)
• Contour Buffer Strips (Code 332)
• Cover Crop (Code 340)
• Residue Management, Seasonal (Code 344)
• Diversion (Code 362)
• Windbreak/Shelterbelt Establishment (Code 380)
• Riparian Forest Buffer (Code 390)
• Filter Strip (Code 393)
• Grassed Waterway (Code 412)
• Prescribed Grazing (Code 528A)
• Contour Stripcropping (Code 585)
• Stripcropping, Field (Code 586)
• Pesf Management (Code 595)
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• Terrace (Code 600)
Notes:
The FOTG, Section IV, contains a complete list of NRCS conservation practices
and the criteria associated with their design and implementation.
The conservation practice physical effects of individual practices on the natural
resources (soil, water, air, plants, and animals) are found in the FOTG,
Section V.
• Comply with existing, federal, Tribal, State and Local regulations or ordinances
associated with soil erosion and runoff.
• Document the following:
• Aerial maps of land application areas
• Individual field maps with marked setbacks, buffers, waterways, and other
conservation practices planned
• Soils information associated with fields (i.e., features, limitations)
• Design information associated with planned and implemented conservation
practices
• Identification of sensitive areas such as sinkholes, streams, springs, lakes,
ponds, wells, gullies, and drinking water sources
• Other site information features of significance, such as property boundaries.
• Identification of operation and maintenance (O&M) practices/activities.
4.2.3 Nutrient Management
This element addresses the requirements for land application of all nutrients and organic
by-products (e.g., animal manure, wastewater, commercial fertilizers, crop residues, legume
credits, irrigation water, etc.) that must be evaluated and documented for each CMU.
Land application of manure and organic by-products is the most common method of
manure utilization due to the nutrients and organic matter content of the material. Land
application procedures must be planned and implemented in a way that minimizes potential
adverse impacts to the environment and public health.
4.2.3.1 Criteria for Nutrient Management
• Meet the NRCS Nutrient Management Policy as contained in the NRCS General
Manual, Title 190, Part 402, dated May 1999. (See Appendix B)
• Meet criteria in NRCS conservation practice standard Nutrient Management
(Code 590) and, as appropriate, Irrigation Water Management (Code 449). (See
Appendix D)
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• Develop a nutrient budget for nitrogen, phosphorus, and potassium that includes
all potential sources of nutrients.
• Document the following:
• Planned crop types, cropping sequence, and realistic yield targets
• Current soil test results (nitrogen, phosphorus, potassium, heavy metals, and
sodic condition)
• Manure and organic by-product source testing results
• Form, source, amount, timing and method of application of nutrients, by field
• Description of application equipment and method used for calibration
4.2.3.2 Considerations for Nutrient Management
There are additional considerations associated with CNMP development and
implementation that should to be addressed. However, NRCS does not have specific
technical criteria for these considerations that are required for CNMPs.
Air Quality
AFO operators/owners should consider the impact of selected conservation practices
on air quality during the CNMP development process. Air quality on land application
sites may be impaired by excessive dust, gaseous emissions such as ammonia, and
odors. Poor air quality may impact the health of workers, animals and persons living
in the surrounding areas. Ammonia emissions from animal operations may be
deposited to surface waters, increasing the nutrient load to these regions. Soil
incorporation of manure and organic by-products on land application sites can
reduce gaseous emissions. Background information on the current state of the
knowledge, research gaps, and on-going research projects being carried out on air
quality at USDA are given in Appendix F.
Pathogens
AFO operators/owner should consider the impact of selected conservation practices
on pathogen control during the CNMP development process. Pathogenic organisms
occur naturally in animal waste. Exposure to some pathogens by humans and
animals can cause illness, especially for immune-deficient populations. Many of the
same conservation practices used to prevent nutrient movement from animal
operations, such as leaching, runoff and erosion control, are likely to prevent the
movement of pathogens. Background information on the current state of the
knowledge, research gaps, and on-going research projects being carried out on
pathogens at USDA are given in Appendix F.
Salt and Heavy Metals
Build up of salt and heavy metals (i.e., arsenic, selenium, cadmium, molybdenum,
zinc) in soils can create a potential for human and animal health problems and
10
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threaten soil productivity and crop marketability. Federal and State regulations do
not address the heavy metal content associated with agricultural by-products. In
developing a CNMP, the build-up of salt and heavy metals should be tracked through
soil testing. Additional guidance on salt and heavy metal contamination from
manure is available in the following:
NRCS Agricultural Waste Management Field Handbook, Sections 651.1103
and 651.0604(b), deal with the salt content of agricultural waste.
NRCS Agricultural Waste Management Field Handbook, Sections
651.0603(g) and 651.0605(a and b), deal with the heavy metal content of
agricultural waste.
USEPA Title 40 Part 503 - Standards for the Use or Disposal of Sewage
Sludge, Section 503.13, contains pollutant limits for biosolids heavy metal
content and cumulative loading rates. This rule does not address resident
levels of metals in the soil.
4.2.4 Record Keeping
It is important that records are kept to effectively document and demonstrate
implementation activities associated with CNMPs. Documentation of management and
implementation activities associated with a CNMP provides valuable benchmark information
for the AFO owner/operator that can be used to adjust his/her CNMP to better meet
production objectives. It is the responsibility of AFO owners/operators to maintain records
that document the implementation of CNMPs.
Documentation will include:
• Annual manure tests for nutrient contents for each manure storage containment.
• Application records for each application event, including (this also applies to
commercial fertilizers that are applied to supplement manure):
• Containment source or type and form of commercial fertilizer
• Field(s) where manure or organic by-products are applied
• Amount applied per acre
• Time and date of application
• Weather conditions during nutrient application
• General soil moisture condition at time of application (i.e., saturated, wet,
moist, dry)
• Application method and equipment used
• Crops planted and planting/harvesting dates, by field.
• Records that address storage containment structures:
• Dates of emptying, level before emptying, and level after emptying
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• Discharge or overflow events, level before and after event
Transfer of manure off-site or to third parties:
• Manure nutrient content
• Amount of manure transferred
• Date of transfer
• Recipient of manure
Activities associated with emergency spill response plan.
Records associated with any reviews by NRCS, third-party consultants, or
representatives of regulatory agencies:
• Dates of review
• Name of reviewer and purpose of the review
• Recommendations or follow-up requirements resulting from the review
• Actions taken as a result of the review
Records of maintenance performed associated with operation and maintenance
Plans.
Nutrient application equipment calibration.
Changes made in CNMP.
4.2.5 Feed Management
Feed management activities may be used to reduce the nutrient content of manure, which
may result in less land being required to effectively utilize the manure. Feed management
activities may be dealt with as a planning consideration and not as a requirement that
addresses specific criteria; however, AFO owners/operators are encouraged to incorporate
feed management as part of their nutrient management strategy. Specific information and
recommendations should be obtained from Land Grant Universities, industry, the
Agricultural Research Service, or professional societies such as the Federation of Animal
Science Societies (FASS) or American Registry of Professional Animal Scientists (ARPAS),
or other technically qualified entities.
An example of the effective use of feed management is presented as follows:
"If a dairy cow is fed 0.04 percent above recommended levels of dietary phosphorus she will
excrete an additional six pounds of phosphorus annually. For a herd of 500 cows, this is an
additional 3,000 pounds of phosphorus per year. In a single cropping system, corn silage is
about 0.2 percent phosphorus on a dry matter basis. For a field yielding 30 tons of silage per
acre, at 30 percent dry matter, this is 3 6 pounds of phosphorus in the crop. If an additional
3,000 pounds of phosphorus are recovered in manure it takes considerably more land for
application if manure is applied on a phosphorus basis. " Dr. Deanne Meyer, Livestock Waste
Management Specialist, Cooperative Extension, University of California.
12
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Specific feed management activities to address nutrient reduction in manure may include
phase feeding, amino acid supplemented low crude protein diets, and the use of low phytin
phosphorus grain and enzymes, such as phytase or other additives.
Feed management can be an effective approach to addressing excess nutrient production
and should be encouraged; however, it is also recognized that feed management may not
be a viable or acceptable alternative for all AFOs. A professional animal nutritionist should
be consulted before making any recommendations associated with feed ration adjustment.
4.2.6 Other Utilization Activities
Using environmentally-safe alternatives to land application of manure and organic by-
products could be an integral part of the overall CNMP. Alternative uses are needed for
animal manure in areas where nutrient supply exceeds available land and/or where land
application would cause significant environmental risk. Manure use for energy production,
including burning, methane generation and conversion to other fuels, is being investigated
and even commercially tested as a viable source of energy. Methods to reduce the weight,
volume, or form of manure, such as composting or pelletizing, can reduce transportation
cost, and create a more valuable product. Manure can be mixed or co-composted with
industrial or municipal by-products to produce value-added material for specialized uses.
Transportation options are needed to move manure from areas of over supply to areas with
nutrient deficiencies (i.e., manure brokering).
More efficient and cost-effective methods are needed for manure handling, treatment, and
storage. Areas in need of targeting include: (1) improved systems for solids removal from
liquid manure; (2) improved manure handling, storage, and treatment methods to reduce
ammonia volatilization; (3) treatment systems that transform and/or capture nutrients, trace
elements, and pharmaceutically active chemicals from manure; (4) improved composting
and other manure stabilization techniques; and, (5) treatment systems to remediate or
replace anaerobic lagoons.
As many of these alternatives to conventional manure management activities have not been
fully developed or refined, industry standards do not always exist that provide for their
consistent implementation. Except for the NRCS conservation practice standard
Composting Facility (Code 317), NRCS does not have conservation practice standards that
address these other utilization options.
This element of a CNMP should be presented as a consideration for the AFO
owner/operator in his/her decision-making process. No specific criteria need to be
addressed unless an alternative utilization option is decided upon by the AFO
owner/operator. When an AFO owner/operator implements this element, applicable
industry standards and all federal, Tribal, State, and local regulations must be met.
5.0 CERTIFICATION
13
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Providing conservation planning and other technical assistance to AFO owners/operators
through voluntary programs or to help satisfy regulatory requirements presents a potentially
tremendous workload. NRCS traditionally has been the primary provider of conservation
planning and other technical assistance to agricultural producers. In an effort to build
capacity to meet this potential workload, NRCS will establish a process for certifying
approved sources of conservation assistance. An individual who is appropriately certified
through an USDA-recognized certification organization is referred to as either a "certified
specialist" or a "certified conservation planner."
Certifying organizations (approved sources) can come from the private or public sectors.
Private consultants, employees of agribusiness, and others who hold appropriate
certifications through an approved independent certification organization or state licensing
agency can be approved as certified specialists. Employees of natural resource
conservation agencies, departments, or other entities organized under federal, Tribal, State,
or local law who have planning and technical assistance functions as part of their assigned
responsibilities can also be approved as certified specialists. Other non-commercial
sources, as determined by the NRCS state conservationist, also can be approved.
Individuals can be recognized as providers of conservation planning assistance by obtaining
a certified conservation planner designation, or as providers of technical assistance for
developing components of a conservation plan by obtaining a certified specialist
designation. An individual that is qualified to develop a complete CNMP would be
designated as a certified conservation planner. To develop a specific element of a CNMP
would require a certified specialist designation. (For specific requirements associated with
establishing a certification process, and the minimum national demonstrated competencies
associated with obtaining a certified specialist designation, see the NRCS General Manual
180 Part 409.)
In the development of a CNMP, as a minimum, the elements Manure and Wastewater
Handling and Storage, Land Treatment Practices, and Nutrient Management must be
developed by certified specialists. Because of the diversity and complexity of specific skills
associated with each element of the CNMP, most individuals will pursue "certification" for
only one of the elements. Therefore, to achieve a CNMP could require the interaction of
three separate certified specialists, each addressing only one of the three elements.
It is envisioned that a certified conservation planner, assisting the AFO owner/operator,
would facilitate the CNMP development process, with "certified specialists" developing the
more detailed specifics associated with the element they are certified to help produce.
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APPENDIX A
THE NRCS CONSERVATION PLANNING PROCESS AND CNMP DEVELOPMENT
This Appendix describes the NRCS conservation planning process and shows how a
comprehensive nutrient management plan (CNMP) is developed using this established
planning process.
Conservation planning is a natural resource problem-solving process. The process
integrates ecological (natural resource), economic, and social considerations to meet both
the owner's/operator's objectives and public resource protection needs. This approach
emphasizes identifying desired future conditions, improving natural resource management,
minimizing conflict, and addressing problems and opportunities. The NRCS National
Planning Procedures Handbook (NPPH) provides guidance in the application of effective
conservation planning procedures in the development of conservation plans.
The conservation planning process has not been changed by the introduction of CNMPs.
However, public scrutiny of the conservation planning process has increased as a result of
the introduction of CNMPs. It is essential that individuals providing technical assistance to
develop CNMPs be well versed in the conservation planning process, have the skill to
recognize resource concerns, and have the tools necessary to develop and evaluate
treatment alternatives.
The Comprehensive Nutrient Management Planning Technical Guidance does not replace
the NRCS NPPH, nor does it relieve the planner from offering conservation alternatives that
address all of the resource concerns: soil, water, air, plants, and animals. Development of
CNMPs will rely on the planning process and established conservation practice standards.
Conservation plans are developed with individual clients or with a group of individuals
functioning as a unit. These plans are site-specific, comprehensive, and action-oriented. A
conservation plan contains natural resource information and a record of decisions made by
the client. It describes the schedule of operations and activities needed to solve identified
natural resource problems and take advantage of opportunities. A conservation system
(CS) addresses treatment needs that meet the NRCS Field Office Technical Guide (FOTG),
Section III, Quality Criteria, for each identified natural resource concern.
Quality criteria, in Section III of the FOTG, are quantitative or qualitative statements of
treatment levels required to prevent resource degradation and enable sustained use for
identified resource considerations for a particular land area. Quality criteria are established
in accordance with local, State, Tribal, and federal programs and regulations in
consideration of ecological, economic, and social effects. Table 1 contains typical quality
criteria as presented in the FOTG, Section III, for soil and water resources, specifically soil
erosion and surface water quality.
The scale of planning associated with the development of a CNMP is the Conservation
Management Unit (CMU). A CMU is a field, group of fields, or other land units of the same
land use and having similar natural resource conditions, treatment needs, and planned
management. A CMU is defined by the planner, to simplify planning activities and to
facilitate CS development. A CMU has definite boundaries, usually natural resource
15
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boundaries, such as drainage ways, vegetation, topography, or soils, but also can be based
on land use.
Table 1. Example Quality Criteria
Resource
Resource Problem
Quality Criteria
Soil
Erosion: Sheet and Rill - soil erosion caused
by overland water flow.
The soil loss is reduced to tolerance
"T" for the soil map unit, as listed in
Section II of the FOTG.
Water
Quality: Surface - pollution problems that
result from the handling and use of applied
nutrients, especially nitrogen, phosphorus,
and total organic carbon.
Collection, transfer and storage of
agricultural waste and fertilizers do not
contribute contaminants that adversely
affect surface water. Application of
nutrients and organics are in balance
with plant requirements - considering
all nutrient sources, soil characteristics,
optimum yields and runoff loss
potential of nutrients dissolved in the
runoff and/or attached to soil particles
transported by water and wind.
A CNMP is a CS for animal feeding operations that addresses water quality as the primary
resource concern. For AFOs that will land apply manure, the CNMP also will need to
address soil erosion, condition, and deposition as a primary resource concern.
In working with an AFO owners/operators, alternatives are developed that address various
treatment levels of the resources of concern. Alternatives developed for a CNMP will meet
the FOTG quality criteria for soil and water concerns within all CM Us impacted by the
collection, storage, and application of animal waste and organic by-products. The AFO
owner/operator, as decision-maker, selects from these alternatives to create a CNMP that
best meets his/her management objectives and environmental concerns.
Figure 1 is a typical representation of the conservation effects of alternative resource
management systems for cropland on the key soil and water resource concerns. The rating
system used is a relative impact representation. A plus (+) sign indicates a positive impact
in addressing the resource concern; a negative (-) sign indicates a negative impact in
addressing the resource concern; a zero (0) indicates no significant impact, either positive
or negative. The accompanying numeric representation (+3) serves to indicate how much
of a positive or negative influence the conservation practice has on addressing the resource
concern. The effect of each conservation practice on each of the resource concerns is
found in the NRCS FOTG, Section V, "Conservation Practice Physical Effects." The
numeric representations of each of the conservation practices in an alternative system are
not additive in determining the overall effect of the system; rather, they are to be used as a
qualitative tool by the certified conservation planner in deciding if the overall effect of the
system is positive or negative. In order for a system to be an acceptable alternative, its
overall impact on the resource concerns must not only be positive, but it must also satisfy
the quality criteria for the RMS level, as described in the FOTG, Section III.
16
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A broad range of technically feasible alternatives should be developed with the client. It is
not merely enough to ask the producer what is being done and make a record of that as a
CNMP. Alternatives need to achieve the objectives of the client, solve identified problems,
and treat the resources to defined quality criteria. Alternatives may include a mix of
structural and/or management practices, within restrictions defined by ordinances or
regulations. It is important that the client be actively involved in the formulation of these
alternatives.
CNMP implementation may require additional design, analysis or evaluations. This is
particularly true for structural practices and nutrient management. Dynamics of operations,
nature, infusion of real-time measurements or other unknowns may cause changes in
amount, size, timing, or distribution of nutrients. These inputs may even cause complete
revisions to planned alternatives. It is important for the certified conservation planner to
maintain a relationship with the producer throughout CNMP implementation to address
changes or new challenges.
Evaluation of the effectiveness of the CNMP may begin during the implementation phase
and not end until several years after the last practice is applied. Follow-up and evaluation
determines whether the implemented alternative is meeting the client needs and solving the
conservation problems in a manner beneficial to the resources. If the evaluation
determines that this is not taking place, adjustments to the CNMP probably will be needed.
17
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Figure 1. CROPLAND RESOURCE MANAGEMENT SYSTEMS (RMS)
Soil
These soils are best for production of common field crops.
They are deep to very deep, nearly level to gently sloping
[0-8%] soils on uplands. Drainage classes are well,
moderately well, and excessively well drained. The soils
have loam, slit loam, loamy sand, fine sandy loam, and
sandy loam textures. They can erode easily if not managed
properly. Land capability Classes are 1, 2E, 2S, and 2W.
Major soils include: Adelhia, Butlertown, Matapeak,
Sassafras, Bourne, Croom, Rumford, Woodstown
Resource Management System Alternative
RMS alternatives to treat the resource concerns
Present Farm Systems
328-Continuous Corn Soybeans
Conventional tillage & no crop residues
- Up/down
slop farming
- No nutrient testing
- Pesticides use when insects seen
Present System - General Effects:
Alternative 1 RMS
328-Conservation Cropping Sequence:
Continuous Com / Soybeans
329- Conservation Tillage
585-Contour stripcropping
342-Critical Area Planting
412-Grassed Waterway
590-Nutrient Management
595-Pest Management
Alternative 1 - General Effects:
Alternative 2 RMS
328-Conservation Cropping Sequence:
Continuous Com/soybeans
329- Conservation Tillage
412-Grassed Waterway
590-Nutrient Management
595-Pest Management
600-Terraces
. Alternative 2 - General Effects:
Resource Concerns
The resource concerns found on the landscape are:
-sheet and rill erosion
-ground contaminants - nutrient and pesticides
-ephemeral gully erosion
-surface water contaminants - nutrients
-soil compaction
-plant pests
-offsite sediment deposition
-wildlife cover
-water
Resource Concerns and Effects of RMS Implementation
Soil
Erosion
Sheet
and Rill
-1
-3
+1
0
-3
-1
+2
+2
+1
+0
+1
0
+3
-1
+3
+1
+1
0
+3
.+2
Ephem-
eral gully
-1
-3
0
0
-3
-1
+1
+1
+3
+3
+1
0
+1
-1
+2
+3
+1
0
+2
.+1
Condition
Compaction
-1
0
+1
-1
-1
-1
+3
+1
+0
+1
+1
+1
+3
-1
+3
+1
+1
+1
0
.+1
Deposition
Offsite
Sediment
-1
-3
+1
0
-3
-1
+2
+2
+3
+2
+1
0
+3
-1
+2
+2
+1
0
+1
.+1
Water
Quality
Groundwater
Contaminants
Nutrients
-1
+2
-2
0
-1
-1
-1
+1
+1
0
+3
0
+1
-1
-1
0
+3
0
.+1
Pesticides
-1
+2
0
-3
-1
-1
0
-1
+1
-1
0
+3
+1
-1
0
+1
0
+3
-2
_+0
Surface Water
Contaminants
Nutrients
-2
-3
-3
0
-3
-2
+2
+2
+2
-1
+3
0
+2
-2
+2
+1
+3
0
-1
.+1
APPENDIX B
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TECHNICAL REFERENCES, HANDBOOKS, AND POLICY DIRECTIVES
Technical References and Handbooks
The Natural Resource Conservation Service has numerous technical references and handbooks that it
uses to assist in the development of conservation plans and it various components. Listed below are
those technical references and handbooks generally associated with the development of
comprehensive nutrient management plans (CNMPs):
United States Department of Agriculture, Natural Resource Conservation Service, Comprehensive
Nutrient Management Planning Technical Guidance is available on the NRCS website at
http://wmv. nhq. nrcs. usda.gov/PROGRAMS/ahcwpd/AFO. html.
United States Department of Agriculture, Natural Resource Conservation Service (NRCS), National
Engineering Handbook, Part 651, Agricultural Waste Management Field Handbook. This
handbook is available on the NRCS website at http://www.ncg.nrcs.usda.gov/tech_ref.html or a
paper copy of this publication can be purchased from the National Technical Information Service,
U.S. Department of Commerce, 5285 Port Royal Road, Springfield, VA. 22161, telephone: 1-800-
553-6847. Order NTI Publications Numbers: PB230819 and PB97167753.
United States Department of Agriculture, Natural Resource Conservation Service,
National Agronomy Manual. The National Agronomy Manual establishes policy for agronomy
activities and provides technical procedures for uniform implementation of agronomy tools and
applications. This manual is presently under revision and is scheduled for release in the fall of 2000.
The draft version is available on the USDA server in Ft. Worth, Texas at
ftp://ftp.ftw. nrcs. usda.gov/pub/NAM/.
United States Department of Agriculture, Natural Resource Conservation Service,
National Planning Procedures Handbook (NPPH). The purpose of this handbook is to provide
guidance on the planning process the Natural Resources Conservation Service (NRCS) uses to help
develop, implement, and evaluate conservation plans for individuals, and areawide conservation
plans or assessments for groups. This handbook is available on the NRCS website at
http://policy.nrcs.usda.gov/scripts/lpsns.dll/EDS/RTFList.htntl, or from the NRCS, Conservation
Operations Division, by contacting the Director, Conservation Operations Division, Natural
Resources Conservation Service, 12th and Independence SW, Washington, D.C. 20013.
United States Department of Agriculture, Natural Resource Conservation Service, "Conservation
Planning Course." The Conservation Planning Course consists of nine modules. Part 1 of the
Conservation Planning Course contains Modules 1-5, which cover the background and framework
for conservation planning. These modules are included in a computer-based, self-paced version of
the course. Part I of the course is available on the NRCS website at
http://www.ncg.nrcs.usda.gov/start.htm. Part 2 of the course contains Modules 6-8, which are a
hands-on field application of the conservation planning process, that involves classroom and field
exercises. Part 3, Module 9, is the individual application of the conservation planning process
utilizing the information learned in Parts 1 and 2. Part 3 is to be completed at the participant's work
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location with the assistance of a coach. For more information on the availability of training on Parts
2 and 3 of the Conservation Planning Course , contact your NRCS State Conservationist.
United States Department of Agriculture, Natural Resource Conservation Service, "CORE 4
Conservation Practices Training Guide." The purpose of this workbook is to enhance the
technical knowledge of individuals that will assist landowners in effectively using conservation
tillage, nutrient management, pest management, and conservation buffers. This training guide is
available on the NRCS website at http://www.nhq.nrcs.usda.gov/BCS/agro/CORE4.PDF.
United States Department of Agriculture, Natural Resource Conservation Service,
"Agronomy Technical Notes." These technical notes address a wide variety of agronomy issues
and are available on the NRCS website at http://www.ncg.nrcs.usda.gov/tech_notes.html.
Following is a list of the Agronomy Technical Notes found at this website:
Note 1: Cover Crops Note 6: Legumes and Soil Quality
Note 2: Conservation Crop Rotation Effects Note 7: Effects of Soil Erosion on Soil
on Soil Quality Productivity and Soil Quality
Note 3: Effects of Residue Management, Note 8: Liming to Improve Soil Quality in
No-Till on Soil Quality Acid Soils
Note 4: Effect of Soil Quality on Nutrient Note 9: Managing Conservation Tillage
Efficiency
Note 5: Herbicides Note 10: Sunn Hemp, a Cover Crop for
Southern and Tropical Farming
Systems.
United States Department of Agriculture, Natural Resource Conservation Service (NRCS), National
Range and Pasture Handbook. The National Range and Pasture Handbook constitutes NRCS
basic policy and procedures for assisting farmers, ranchers, groups, organizations, units of
government, and others working through conservation districts in planning and applying resource
conservation on non-Federal grazing lands throughout the United States. This Handbook is available
on the NRCS website at http://www.ncg.nrcs.usda.gov/tech_notes.html, or a paper copy of this
publication can be purchased from the National Technical Information Service, U.S. Department of
Commerce, 5285 Port Royal Road, Springfield, VA. 22161, telephone: 1-800-553-6847. Order NTI
Publication Number: PB2000105483.
Policy Directives
NRCS policy is contained in Natural Resources Conservation Service General Manual. The index
for the entire manual can be found at NRCS website
http://policy.nrcs.usda.gov/national/gm/index.htm. Listed below are those policy directives,
contained in the General Manual generally associated with the development of comprehensive
nutrient management plans:
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Natural Resources Conservation Service, General Manual Title 450, Technology, Part 401,
"Technical Guides". This part of the General Manual is available at the NRCS website at
http://policy.nrcs.usda.gov/national/gm/title450/part401/index.htm.
Natural Resources Conservation Service, General Manual. Title 190, Ecological Sciences, Part 402,
"Nutrient Management". This part of the General Manual is available at the NRCS website at
http://www.nhq.nrcs.usda.gov/BCS/nutri/gm-190.html. Following is the NRCS Nutrient
Management, as of, November 24, 2000:
CONTENTS
PART 402 - NUTRIENT MANAGEMENT
Sec.
402.01 Policy 1
402.02 Definitions 1
402.03 Certification 2
402.04 Nutrient Management Plans 2
402.05 Soil and Plant Tissue Testing 4
402.06 Nutrient Application Rates 6
402.07 Special Considerations 9
402.08 Record Keeping 11
21
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402.02(a)(5)
402.01 Policy.
(a) The guidance and procedures contained in this section are applicable to all
technical assistance that involves nutrient management and/or the utilization of organic by-
products, including animal manure, where nutrients are applied to the land. All NRCS
employees will follow these procedures when providing such technical assistance. Third party
vendors and other non-NRCS employees will use these procedures when assisting with the
implementation of Federal conservation programs for which NRCS has national technical
responsibility and that include plans for nutrient management.
(b) Plans for nutrient management are developed in compliance with all applicable
Federal, state, and/or local regulations. Federal, State, and/or local regulations take precedence
over NRCS policy when more restrictive.
(c) NRCS at the State level will supplement this guidance to make it applicable to
local conditions as appropriate.
402.02 Definitions.
(a) The following definitions apply to terms used in this section.
(1) Conservation Management Unit (CMU): A field, group of fields, or
other land units of the same land use and having similar treatment needs and planned
management. A CMU is a grouping by the planner to simplify planning activities and facilitate
development of conservation management systems. A CMU has definite boundaries, such as
fence, drainage, vegetation, topography, or soil lines.
(2) Nutrient: Any of the elements considered essential for plant growth,
particularly the primary nutrients; nitrogen, phosphorus, and potassium.
(3) Nutrient Management: Managing the amount, source, placement, form,
and timing of the application of nutrients and soil amendments to ensure adequate soil fertility
for plant production and to minimize the potential for environmental degradation, particularly
water quality impairment.
(4) Nutrient Management Plan: A documented record of how nutrients will
be used for plant production prepared for reference and use by the producer or landowner.
(5) Nutrient Management Specialist: A person who provides technical
assistance for nutrient management and has the appropriate certification.
402-1
22
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402.02(6)
(6) Nutrient Source: Any material (i.e. commercial fertilizer, animal
manure, sewage sludge, irrigation water, etc.) that supplies one or more of the elements
essential for plant growth.
(7) Other Organic By-product: Any organic material other than animal
manure, sewage sludge, or urea applied to the land (e.g. food processing waste).
(8) Resource Management System (RMS): A prescribed combination of
conservation practices and management identified by land or water uses that, when implemented,
prevents resource degradation and permits sustained use by meeting quality criteria established in
the FOTG for the treatment of soil, water, air, plant, and animal resources.
(9) Third Party Vendor: An individual (excluding NRCS employees,
extension specialists, and conservation district employees) who has been certified by an
approved certification organization as being qualified to provide specified types of conservation
assistance, and whose certifying organization participates in the USDA Approved Vendor
Process outlined in Part 504, "Conservation Assistance from Third Party Vendors" of the NRCS
Conservation Programs Manual. Third Party Vendor certification programs may include, but are
not limited to:
Agronomy.
(i) Certified Crop Advisor (CCA) Program of the American Society of
(ii) Land Grant University certification programs.
(iii) National Alliance of Independent Crop Consultants (NAICC).
402.03 Certification.
(a) All persons who review or approve plans for nutrient management will be
certified through a certification program accepted by NRCS in the State involved.
(b) NRCS should identify all certification programs, available within the State, it
judges to be acceptable methods for becoming certified.
(c) USDA recognized programs for certifying third party vendors are recommended
for use in states that have or use no other recognized certification program.
402-2
23
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402.04(d)
402.04 Nutrient Management Plans.
(a) Plans for nutrient management may be stand alone or be elements of a more
comprehensive conservation plan. When plans for nutrient management are part of a more
comprehensive conservation plan, the provisions for nutrient management are compatible with
other provisions of the plan.
(b) Plans for nutrient management are developed in accordance with technical
requirements of the NRCS Field Office Technical Guide (FOTG), policy requirements of the
General Manual (GM), procedures contained in the National Planning Procedures Handbook
(NPPH), and technical guidance contained in the National Agronomy Manual (NAM).
(c) Plans for nutrient management will include the following components, as
applicable:
(1) Aerial site photographs or maps and a soil map.
(2) Current and/or planned plant production sequence or crop rotation.
(3) Soil test results and recommended nutrient application rates.
(4) Plant tissue test results, when used for nutrient management.
(5) A complete nutrient budget for nitrogen, phosphorus, and potassium for
the plant production system.
(6) Realistic yield goals and a description of how they were determined.
(7) Quantification of all important nutrient sources (this could include but not
be limited to commercial fertilizer, animal manure and other organic by-products, irrigation
water, etc.).
(8) Planned rates, methods, and timing (month & year) of nutrient application.
(9) Location of designated sensitive areas or resources (if present on the
conservation management unit).
(10) Guidance for implementation, operation, maintenance, and record keeping.
(d) When applicable, plans for nutrient management should include other practices or
management activities as determined by specific regulation, program requirements, or producer
goals.
402-3
24
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402.04(e)
(e) States are encouraged to adopt protocol for the format and appearance of
nutrient management plans that is in accordance with the National Planning Procedures
Handbook (NPPH) and other State developed guidance.
(f) If the Conservation Management Unit lies within a hydrologic unit area that has
been identified or designated as having impaired water quality associated with nitrogen or
phosphorus, plans for nutrient management include an assessment of the potential for nitrogen or
phosphorus transport from the field. The Leaching Index (LI) and/or Phosphorus Index (PI), or
other assessment tools accepted by NRCS, may be used to make these assessments.
(1) When such assessments are made, nutrient management plans will
include:
(i) A record of the site rating for each field.
(ii) Information about conservation practices and management actions
that can reduce the potential for phosphorus movement from the field.
(2) The results of such assessments and recommendations are discussed with
the producer as a normal part of the planning process.
(g) Review and Revision of Nutrient Management Plans.
(1) Plans for nutrient management should be reviewed periodically to
determine if adjustments or modifications are needed. Annual reviews are highly recommended.
The results of such reviews should be documented in the plan, as well as the identification of the
person who made the review.
(i) States are encouraged to develop procedures for periodic reviews
so that they may be completed by the producer or the representative of the producer.
(ii) When a review indicates that a revision of the plan is needed, the
revised plan is approved by a certified nutrient management specialist.
(2) A thorough review of nutrient management plans is done on a regular
cycle not to exceed 5 years. This review should coincide with the soil test cycle.
402.05 Soil and Plant Tissue Testing.
(a) Current soil test information is used in the development of all plans for nutrient
402-4
25
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402.05(c)(3)
management. As a minimum, tests should include information for pH, phosphorus, and
potassium. Tests for other elements may be required when needed to develop plans for nutrient
management or to comply with State or local requirements.
(1) Current soil tests are those no older than 5 years, or
(2) Are less than 5 years old if required by the State.
(b) Soil Sampling.
(1) Soil samples are taken and handled in accordance with Land Grant
University guidance or standard industry practice if accepted by the Land Grant University within
the State.
(2) In situations where there are special production or environmental
considerations, the use of other sampling techniques is encouraged. For example:
(i) Sub-soil sampling for residual nitrate in irrigated crop production
systems.
(ii) Pre-sidedress Nitrogen Test (PSNT) and/or Pre-Plant Soil Nitrate
test.
(iii) Sampling of the surface layer (0-2 inches) for elevated soil
phosphorus or soil acidity when there is permanent vegetation, non-inversion tillage, or when
animal manure or other organic by-products are broadcast or surface applied and not
incorporated.
(c) Soil test analysis is performed by laboratories that are accepted in one or more of
the following programs:
(1) State Certified Programs.
(2) The North American Proficiency Testing Program (Soil Science Society of
America).
(3) Laboratories participating in other programs whose tests are accepted by
the Land Grant University in the State in which the tests are used as the basis for nutrient
application.
402-5
26
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402.05(d)
(d) The use of tissue analysis and other such tests should be recommended when
needed to ensure acceptable nutrient management.
(e) The nutrient content of animal manure and other organic by-products is based on:
(1) Laboratory analysis of the material.
(2) Accepted book values recognized by NRCS in the absence of
laboratory analysis.
(3) Historic records for the operation if they exist and give an accurate
estimate of the nutrient content of the manure.
402.06 Nutrient Application Rates.
(a) Soil amendments are recommended, as needed, to adjust and maintain soil pH at
the specific range of the crop for optimum availability and utilization of nutrients.
(b) Recommended nutrient application rates are based upon Land Grant University
guidance or standard industry practice if recognized by the Land Grant University. Current soil
test results, realistic yield goals, producer management capabilities, and other pertinent
information are considered when determining recommended nutrient application rates.
(c) The planned and actual rates of nutrient application shall not normally exceed
recommended rates when commercial fertilizer is the only source of nutrients being applied.
When site specific conditions require that either planned or actual rates of application differ from
or exceed recommended rates, the records for the plan shall document the reason.
(d) Producers shall be advised that the planned rates of nutrient application (nitrogen,
phosphorus, and potassium) may exceed recommended rates when custom blended commercial
fertilizers are not available, or when animal manures or other organic by-products are used as a
nutrient source. When custom blended commercial fertilizers are not available, the planned rates
of application shall match recommended rates as closely as possible. When animal manure or
other organic by-products are applied, the following guidance shall be used for determining
planned application rates:
(1) Nitrogen Application. Manure may be applied to legume crops at a rate
equal to the estimated nitrogen removal in harvested plant biomass.
(2) Phosphorus application will be in accordance with one of the following
options.
402-6
27
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402.06(d)(2)(iii)
(i) Phosphorus Index (PI): When the PI is used, phosphorus may be
applied at rates consistent with Table 1.
(ii) Phosphorus Threshold: When soil specific Phosphorus Threshold
(TH) values are available, phosphorus may be applied at rates consistent with Table 2.
(iii) Soil Test Phosphorus: When soil test phosphorus levels are used,
phosphorus may be applied at rates consistent with Table 3 or Figure 1.
Table 1 *
Phosphorus Index Rating Phosphorus Application
Low Risk Nitrogen Based
Medium Risk Nitrogen Based
High Risk Phosphorus Based (e.g. crop removal)
Very High Risk Phosphorus Based (e.g. no application)
* See 402.06(d)(2)(v)
Table 2 *
Soil Phosphorus Threshold Level Phosphorus Application
<3/4 TH Nitrogen Based
=> 3/4 TH, < 1 1/2 TH Phosphorus Based (e.g. crop removal)
=> 1 1/2 TH, < 2 TH Phosphorus Based (e.g. 1/2 crop removal)
=> 2 TH Phosphorus Based (e.g. no application)
* See 402.06(d)(2)(v)
Table3 *
Soil Test Phosphorus Level Phosphorus Application
Low Nitrogen Based
Medium Nitrogen Based
High Phosphorus Based (e.g. 1.5 times crop
removal)
Very High Phosphorus Based (e.g. crop removal)
Excessive Phosphorus Based (e.g. no application)
* See 402.06(e)(2)(v)
402-7
28
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402.06(d)(2)(iii)(iv)
Figure 1
**
Increased Potential for
Phosphorus Transport
(Phosphorus based nutrient management)
< Soil Test Phosphorus >
** See 402.06(d)(2)(vi)
(iv) State developed guidance for using Tables 1, 2, and 3 and
Figure 1 will be used to establish criteria for a Resource Management System (RMS) level of
nutrient management. State developed guidance will include input from the State Technical
Committee and be coordinated across State lines to ensure compatibility and consistency with
guidance developed in adjoining States.
(v) When using Tables 1, 2, or 3, States determine acceptable
phosphorus based application rates as a function of estimated phosphorus removal in harvested
plant biomass. Rates of application should decrease as soil phosphorus levels or the risk of
transport increase. Guidance may include recommendations for no application. The application
rates shown in the tables are provided as guidance. Both the State Technical Committee and
Land Grant University should be involved in developing these rates.
(vi) When using Figure 1, States determine soil phosphorus levels at
which nitrogen based manure application is acceptable and when phosphorus based manure
application is recommended. Phosphorus based manure application rates shall be developed as a
function of estimated phosphorus removal in harvested plant biomass. Phosphorus application
rates should decrease as available soil phosphorus levels increase. Guidance may include a
recommendation of no application. Both the State Technical Committee and Land Grant
University should be involved in developing this guidance.
(vii) Accommodation may be made for a single application of
phosphorus applied as manure at a rate equal to the recommended phosphorus application rate or
estimated phosphorus removal in harvested plant biomass for the crop rotation or multiple years
in the crop sequence. Multi-year phosphorus applications will not be at rates which exceed the
annual nitrogen recommendation of the year of application or on sites considered vulnerable to
402-8
29
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402.07(a)(3)(i)
off-site transport of phosphorus unless the appropriate conservation practices, best management
practices, or management activities are used to reduce vulnerability.
(3) Potassium Application.
(i) Excess potassium will not be recommended in situations in which
it causes unacceptable nutrient imbalances in crops or forages.
(ii) When forage quality and animal health are issues associated with
excess potassium application, State standards will be used to set forage quality guidelines.
(e) Other plant nutrients should be applied as needed.
(f) Starter fertilizers containing nitrogen, phosphorus, and potassium may be
recommended in accordance with Land Grant University guidance or industry practice if
recognized by the Land Grant University within the State.
402.07 Special Considerations.
(a) Plans developed for nutrient management that include the use of manure or other
organic by-products will:
(1) Identify the size of the land base needed to enable plan implementation
based on phosphorus, even when initial implementation will be based on nitrogen, unless other
provisions that do not involve land application are made for utilizing the manure.
(2) Document the soil phosphorus level at which plan implementation on a
phosphorus standard would be desirable.
(3) Include a field-by-field assessment of the potential risk for phosphorus
transport from the field. This assessment may be made using the Phosphorus Index (PI) or other
assessment tool recognized and accepted by NRCS.
(i) When a phosphorus assessment is completed, the plans will
describe:
A record of the ratings for each field.
Information about conservation practices and management
activities that can reduce the potential for phosphorus transport from the field.
402-9
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402.07(3)(ii)
(ii) The results of a phosphorus assessment and recommendations will
be discussed with the producer as a normal part of the planning process.
(4) Recognize that some manures contain heavy metals and should be
accounted for in the plan for nutrient management.
(b) Progressive Planning.
(1) The National Planning Procedures Handbook, Part 600.1, provides
guidance for progressive planning designed to assist producers who cannot initially plan for a
Resource Management System (RMS).
(2) The progressive planning process may be used to help existing
producers achieve an RMS level system when an RMS cannot be immediately implemented.
Such plans shall include:
(i) A description of the RMS level system which the producer will be
working to achieve.
(ii) Conservation practices, management activities, and milestones
(installation schedules) that demonstrate movement toward an RMS.
(3) Annual review of nutrient management systems being implemented
through the progressive planning process is highly encouraged to determine progress.
(c) When plans for nutrient management are developed and implemented in a way
that results in expected increases in soil phosphorus levels, the plans will include:
(1) Discussion about the potential for phosphorus accumulation in the soil and
how such accumulation increases the potential for transport, animal health, or crop production
problems.
(2) Discussion of the potential for soil phosphorus draw-down from the
production and harvesting of crops.
(d) In areas with specially protected water bodies, plans will be developed
incorporating any special requirements that are applicable within these areas.
(e) Land application of sewage sludge
402-10
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402.08(a)(8)
(1) When sewage sludge is applied to agricultural land, the accumulations of
potential pollutants from such sources (including: Arsenic, Cadmium, Copper, Lead, Mercury,
Selenium, and Zinc) in the soil is monitored in accordance with the U.S. Code Reference 40 CFR
Parts 403 and 503, applicable State laws, and/or local ordinances. States may determine if such
provisions should also be required for the land application of animal manure and other organic
by-products that contain any of these metals.
(2) Sewage sludge is analyzed prior to land application to determine its
nutrient value, heavy metals, and salt content.
(3) Acceptable application rates of sewage sludge are determined using
guidelines in this policy, and applicable Federal, State, or local regulations.
(f) Producers will be reminded that when producing "fresh, edible crops for the
produce market, such as vegetables, root, or tuber crops" and using sewage sludge, animal
manure, or other organic materials as a source of nutrients, applications should be
in accordance with provisions of all applicable Federal, State, or local laws or policies.
402.08 Record Keeping.
(a) It is the responsibility of producers, or the agents of producers, to maintain records
which document the implementation of plans for nutrient management. Records include:
(1) Soil test results and recommended nutrient application rates.
(2) Quantities and sources of nutrients applied; and heavy metals if applicable.
(3) Dates (month and year) on which nutrients were applied.
(4) Methods by which nutrients were applied (e.g. broadcast, incorporated
after broadcast, injected, or fertigation).
(5) Crops planted and dates of planting.
(6) Harvest dates and yields of crops.
(7) Where applicable, results of water quality tests (including irrigation
water), plant tissue, or other organic by-products tests.
(8) The results of reviews including the identification of the person
completing the review and any recommendations that resulted from the review.
402-11
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402.08(b)
(b) Records which document implementation of the plan should be retained for a
period of 5 years; or for a period longer than 5 years if specified by other Federal or State
agencies or local ordinances, or program or contract requirements.
(c) National Instruction No. 120-310, Amendment No. 4, dated June 17, 1998,
provides guidance for responding to requests for access to these records.
402-12
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APPENDIX C
COMPREHENSIVE NUTRIENT MANAGEMENT PLAN
FORMAT AND CONTENT
INTRODUCTION
A conservation plan is developed by the landowner/operator for his/her use to record decisions
for natural resource protection, conservation, and enhancement.
Decisions and resource information needed during implementation and maintenance of the plan
are recorded. The plan narrative and supporting documents provide guidance for implementation
and may serve as a basis for compliance with regulations and/or program funding through
federal, State, or local financial support initiatives.
A comprehensive nutrient management plan (CNMP) is to include all land units on which
manure and organic by-products will be generated, handled, or applied, and that the animal
feeding operation (AFO) owner/operator either owns or has decision-making authority over.
The following guidance helps to maintain quality and provide appropriate documentation of a
CNMP. The list shows the suggested items to be given to the AFO owner/operator. However,
the CNMP content should be tailored to the meet the AFO owner's/operator's needs.
Contents of a Comprehensive Nutrient Management Plan
1. Site information
• Names, phone numbers, and addresses of the AFO owner(s) and manager(s).
• Location of production site: legal description, driving instructions from nearest post
office, and the emergency 911 coordinates.
• Farmstead sketch.
• Plat map or local proximity map (Optional).
• Emergency action plan covering: fire, personal injury, manure storage and handling, and
land application operations.
• Operation procedures specific to the production site and practices.
• Existing documentation of present facility components that would aid in evaluating
existing conditions, capacities, etc. (i.e., as-built plans, year installed, number of animals
a component was originally designed for, etc.)
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2. Production information
• Animal types, phases of production, and length of confinement for each type at this site.
• Animal count and average weight for each phase of production on this site.
• Calculated manure and wastewater volumes for this site.
• Manure storage type, volume, and approximate length of storage.
3. Applicable permits or certifications
• Federal, Tribal, State or local permits and/or ordinances.
• Operator or manager certifications.
• Manure applicator certifications.
• Record of inspections or site assessments.
• Changes made to CNMP.
4. Land application site information
• Date plan prepared.
• Written manure application agreements. (Where Applicable)
• Aerial maps of land application area.
• Individuals field maps with marked setbacks, buffers, and waterways, and
environmentally sensitive areas, such as sinkholes, wells, gullies, tile inlets, etc.
• Landowner names, addresses, and phone numbers.
• Legal description of land sites, including watershed codes.
• Specific and unique field identification codes.
• Land use designation.
• Soil map, with appropriate interpretations
• Risk assessments for potential nitrogen or phosphorus transport from fields. (See NRCS
GM -190, Part 402, "Nutrient Management", Section 402.07)
• Land treatment practices planned and applied, and level of treatment they provide.
5. Manure application plans
• Crop types, realistic yield targets, and expected nutrient uptake amounts.
• Application equipment descriptions and methods of application.
• Expected application seasons and estimated days of application per season.
• Estimated application amounts per acre (volume in gallons or tons per acre, and pounds
of plant available nitrogen, phosphorous as P205, and potassium as K20 per acre)
• Estimated of acres needed to apply manure generated on this site respecting any
guidelines published for nitrogen or phosphorous soil loading limits.
6. Actual activity records
• Soil tests — not more than 5 years old.
• Manure test annually for each individual manure storage containment.
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• Planned and applied rates, methods of application, and timing (month and year) of
nutrients applied. (Include all sources of nutrients - manure, commercial fertilizers, etc.)
• Current and/or planned crop rotation.
• Weather conditions during nutrient application (Optional)
• General soil moisture condition at time of application (i.e., saturated, wet, moist, dry)
(Optional)
• Actual crop and yield harvest from manure application sites.
• Record of internal inspections for manure system components.
• Record of any spill events.
7. Mortality disposal
• Plan for morality disposal.
• Methods and equipment used to implement the disposal plan.
8. Operation and Maintenance
• Detailed operation and maintenance procedures for the conservation system, holding
facility, etc., contained in the CNMP. This would include procedures such as calibration
of land application equipment, storage facility emptying schedule, soil and manure
sampling techniques, etc.
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APPENDIX D
CONSERVATION PRACTICE STANDARDS
Natural Resources Conservation Service (NRCS) conservation practice standards provide
guidance for applying technology on the land, and set the minimum level for acceptable
application of the technology.
NRCS issues national conservation practice standards in its National Handbook of Conservation
Practices (NHCP). National standards for each practice are available at the NRCS website
http://www.ncg.nrcs.usda.gov/nhcp_2.html. Each State Conservationists determines which
national standards will be used in his/her state.
State Conservationists that choose to use national standards, without changes, adapt them for use
in their state and issue them as state conservation practice standards. State Conservationists add
the technical detail needed to effectively use the standards at the field office level. Also, State
Conservationists can make their conservation practice standards more restrictive, but not less
restrictive. State conservation practice standards are contained in Section IV of the Field Office
Technical Guide.
Copies of NRCS state conservation practice standards are not currently available from the NRCS
Homepage, but may be available later. Copies presently can be obtained by contacting the
appropriate NRCS State Office, (see Appendix G)
On the following pages are the three most commonly considered conservation practice standards
that may be used when developing a comprehensive nutrient management plan (CNMP):
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Code 590
NATURAL RESOURCES CONSERVATION SERVICE
CONSERVATION PRACTICE STANDARD
NUTRIENT MANAGEMENT
(Acre)
CODE 590
DEFINITION
Managing the amount, source, placement, form
and timing of the application of nutrients and
soil amendments.
PURPOSES
* To budget and supply nutrients for plant
production.
* To properly utilize manure or organic by-
products as a plant nutrient source.
* To minimize agricultural nonpoint source
pollution of surface and ground water
resources.
* To maintain or improve the physical,
chemical and biological condition of soil.
CONDITIONS WHERE PRACTICE APPLIES
This practice applies to all lands where plant
nutrients and soil amendments are applied.
CRITERIA
General Criteria Applicable to All Purposes
Plans for nutrient management shall comply
with all applicable Federal, state, and local laws
and regulations.
Plans for nutrient management shall be
developed in accordance with policy
requirements of the NRCS General Manual
Title 450, Part 401.03 (Technical Guides, Policy
and Responsibilities) and Title 190, Part 402
(Ecological Sciences, Nutrient Management,
Policy); technical requirements of the NRCS
Field Office Technical Guide (FOTG);
procedures contained in the National Planning
Procedures Handbook (NPPH), and the NRCS
National Agronomy Manual (NAM) Section 503.
Persons who review or approve plans for
nutrient management shall be certified through
any certification program acceptable to NRCS
within the state.
Plans for nutrient management that are
elements of a more comprehensive
conservation plan shall recognize other
requirements of the conservation plan and be
compatible with its other requirements.
A nutrient budget for nitrogen, phosphorus,
and potassium shall be developed that
considers all potential sources of nutrients
including, but not limited to animal manure and
organic by-products, waste water, commercial
fertilizer, crop residues, legume credits, and
irrigation water.
Realistic yield goals shall be established
based on soil productivity information,
historical yield data, climatic conditions, level
of management and/or local research on
similar soil, cropping systems, and soil and
manure/organic by-products tests. For new
crops or varieties, industry yield
recommendations may be used until
documented yield information is available.
Plans for nutrient management shall specify
the form, source, amount, timing and method
of application of nutrients on each field to
achieve realistic production goals, while
minimizing nitrogen and/or phosphorus
movement to surface and/or ground waters.
Erosion, runoff, and water management
controls shall be installed, as needed, on fields
that receive nutrients.
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Code 590
Soil Sampling and Laboratory Analysis
(Testing)
Nutrient planning shall be based on current soil
test results developed in accordance with Land
Grant University guidance or industry practice if
recognized by the Land Grant University.
Current soil tests are those that are no older
than five years.
Soil samples shall be collected and prepared
according to the Land Grant University
guidance or standard industry practice. Soil test
analyses shall be performed by laboratories that
are accepted in one or more of the following
programs:
* State Certified Programs,
* The North American Proficiency Testing
Program (Soil Science Society of America),
or
* Laboratories whose tests are accepted by
the Land Grant University in the state in
which the tests will be used.
Soil testing shall include analysis for any
nutrients for which specific information is
needed to develop the nutrient plan. Request
analyses pertinent to monitoring or amending
the annual nutrient budget, e.g. pH, electrical
conductivity (EC), soil organic matter, nitrogen,
phosphorus, and potassium.
Plant Tissue Testing
Tissue sampling and testing, where used, shall
be done in accordance with Land Grant
University standards or recommendations.
Nutrient Application Rates
Soil amendments shall be applied, as needed,
to adjust soil pH to the specific range of the
crop for optimum availability and utilization of
nutrients.
Recommended nutrient application rates shall
be based on Land Grant University
recommendations (and/or industry practice
when recognized by the university) that
consider current soil test results, realistic yield
goals and management capabilities. If the Land
Grant University does not provide specific
recommendations, application shall be based
on realistic yield goals and associated plant
nutrient uptake rates.
The planned rates of nutrient application, as
documented in the nutrient budget, shall be
determined based on the following guidance:
* Nitrogen Application - Planned nitrogen
application rates shall match the
recommended rates as closely as
possible, except when manure or other
organic by-products are a source of
nutrients. When manure or other organic
by-products are a source of nutrients, see
"Additional Criteria" below.
• Phosphorus Application - Planned
phosphorus application rates shall match
the recommended rates as closely as
possible, except when manure or other
organic by-products are a source of
nutrients. When manure or other organic
by-products are a source of nutrients, see
"Additional Criteria" below.
* Potassium Application - Excess
potassium shall not be applied in
situations in which it causes unacceptable
nutrient imbalances in crops or forages.
When forage quality is an issue
associated with excess potassium
application, state standards shall be used
to set forage quality guidelines.
* Other Plant Nutrients - The planned
rates of application of other nutrients shall
be consistent with Land Grant University
guidance or industry practice if recognized
by the Land Grant University in the state.
* Starter Fertilizers - Starter fertilizers
containing nitrogen, phosphorus and
potassium may be applied in accordance
with Land Grant University
recommendations, or industry practice if
recognized by the Land Grant University
within the state. When starter fertilizers
are used, they shall be included in the
nutrient budget.
Nutrient Application Timing
Timing and method of nutrient application shall
correspond as closely as possible with plant
nutrient uptake characteristics, while
considering cropping system limitations,
weather and climatic conditions, and field
accessibility.
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Code 590
Nutrient Application Methods
Nutrients shall not be applied to frozen, snow-
covered, or saturated soil if the potential risk for
runoff exists.
Nutrient applications associated with irrigation
systems shall be applied in accordance with the
requirements of Irrigation Water Management
(Code 449).
Additional Criteria Applicable to Manure or
Organic By-Products Applied as a Plant
Nutrient Source
Nutrient values of manure and organic by-
products (excluding sewage sludge) shall be
determined prior to land application based on
laboratory analysis, acceptable "book values"
recognized by the NRCS and/or the Land Grant
University, or historic records for the operation,
if they accurately estimate the nutrient content
of the material. Book values recognized by
NRCS may be found in the Agricultural Waste
Management Field Handbook, Chapter 4 -
Agricultural Waste Characteristics.
Nutrient Application Rates
The application rate (in/hr) for material applied
through irrigation shall not exceed the soil
intake/infiltration rate. The total application
shall not exceed the field capacity of the soil.
The planned rates of nitrogen and phosphorus
application recorded in the plan shall be
determined based on the following guidance:
* Nitrogen Application - When the plan is
being implemented on a phosphorus
standard, manure or other organic by-
products shall be applied at rates consistent
with the phosphorus standard. In such
situations, an additional nitrogen
application, from non-organic sources, may
be required to supply the recommended
amounts of nitrogen.
Manure or other organic by-products may
be applied on legumes at rates equal to the
estimated removal of nitrogen in harvested
plant biomass.
* Phosphorus Application - When manure
or other organic by-products are used, the
planned rates of phosphorus application
shall be consistent with any one of the
following options:
• Phosphorus Index (PI) Rating.
Nitrogen based manure application on
Low or Medium Risk Sites, phosphorus
based or no manure application on
High and Very High Risk Sites.**
• Soil Phosphorus Threshold Values.
Nitrogen based manure application on
sites on which the soil test
phosphorus levels are below the
threshold values. Phosphorus based
or no manure application on sites on
which soil phosphorus levels equal or
exceed threshold values.**
• Soil Test. Nitrogen based manure
application on sites on which there is a
soil test recommendation to apply
phosphorus. Phosphorus based or no
manure application on sites on which
there is no soil test recommendation
to apply phosphorus.**
** Acceptable phosphorus based
manure application rates shall be
determined as a function of soil test
recommendation or estimated
phosphorus removal in harvested
plant biomass. Guidance for
developing these acceptable rates is
found in the NRCS General Manual,
Title 190, Part 402 (Ecological
Sciences, Nutrient Management,
Policy), and the National Agronomy
Manual, Section 503.
A single application of phosphorus
applied as manure may be made at a rate
equal to the recommended phosphorus
application or estimated phosphorus
removal in harvested plant biomass for
the crop rotation or multiple years in the
crop sequence. When such
applications are made, the application
rate shall:
• not exceed the recommended
nitrogen application rate during the
year of application, or
• not exceed the estimated nitrogen
removal in harvested plant biomass
during the year of application when
there is no recommended nitrogen
application.
• not be made on sites considered
vulnerable to off-site phosphorus
transport unless appropriate
conservation practices, best
management practices, or
management activities are used to
reduce the vulnerability.
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Field Risk Assessment
When animal manures or other organic by-
products are applied, a field-specific
assessment of the potential for phosphorus
transport from the field shall be completed.
This assessment may be done using the
Phosphorus Index or other recognized
assessment tool. In such cases, plans shall
include:
* a record of the assessment rating for each
field or sub-field, and
* information about conservation practices
and management activities that can reduce
the potential for phosphorus movement
from the site.
When such assessments are done, the results
of the assessment and recommendations shall
be discussed with the producer during the
development of the plan.
Heavy Metals Monitoring
When sewage sludge is applied, the
accumulation of potential pollutants (including
arsenic, cadmium, copper, lead, mercury,
selenium, and zinc) in the soil shall be
monitored in accordance with the US Code,
Reference 40 CFR, Parts 403 and 503, and/or
any applicable state and local laws or
regulations.
Additional Criteria to Minimize Agricultural
Non-point Source Pollution of Surface and
Ground Water Resources
In areas with an identified or designated
nutrient-related water quality impairment, an
assessment shall be completed of the potential
for nitrogen and/or phosphorus transport from
the field. The Leaching Index (LI) and/or
Phosphorus Index (PI), or other recognized
assessment tools, may be used to make these
assessments. The results of these
assessments and recommendations shall be
discussed with the producer and included in the
plan.
Plans developed to minimize agricultural
nonpoint source pollution of surface or ground
water resources shall include practices and/or
management activities that can reduce the risk
of nitrogen or phosphorus movement from the
field.
Code 590
Additional Criteria to Improve the Physical.
Chemical, and Biological Condition of the
Soil.
Nutrients shall be applied in such a manner as
not to degrade the soil's structure, chemical
properties, or biological condition. Use of
nutrient sources with high salt content will be
minimized unless provisions are used to leach
salts below the crop root zone.
Nutrients shall not be applied to flooded or
saturated soils when the potential for soil
compaction and creation of ruts is high.
CONSIDERATIONS
Consider induced deficiencies of nutrients due
to excessive levels of other nutrients.
Consider additional practices such as
Conservation Cover (327), Grassed Waterway
(412), Contour Buffer Strips (332), Filter Strips
(393), Irrigation Water Management (449),
Riparian Forest Buffer (391A), Conservation
Crop Rotation (328), Cover and Green Manure
(340), and Residue Management (329A,
329B, or 329C, and 344) to improve soil
nutrient and water storage, infiltration,
aeration, tilth, diversity of soil organisms and
to protect or improve water quality.
Consider cover crops whenever possible to
utilize and recycle residual nitrogen.
Consider application methods and timing
that reduce the risk of nutrients being
transported to ground and surface waters,
or into the atmosphere. Suggestions
include:
* split applications of nitrogen to provide
nutrients at the times of maximum crop
utilization,
* avoiding winter nutrient application for
spring seeded crops,
* band applications of phosphorus near the
seed row,
* applying nutrient materials uniformly to
application areas or as prescribed by
precision agricultural techniques, and/or
* immediate incorporation of land applied
manures or organic by-products,
* delaying field application of animal
manures or other organic by-products if
precipitation capable of producing runoff
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NRCS, NHCP
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Code 590
and erosion is forecast within 24 hours of
the time of the planned application.
Consider minimum application setback
distances from environmentally sensitive areas,
such as sinkholes, wells, gullies, ditches,
surface inlets or rapidly permeable soil areas.
Consider the potential problems from odors
associated with the land application of animal
manures, especially when applied nearer
upwind of residences.
Consider nitrogen volatilization losses
associated with the land application of animal
manures. Volatilization losses can become
significant, if manure is not immediately
incorporated into the soil after application.
Consider the potential to affect National
Register listed or eligible cultural resources.
Consider using soil test information no older
than one year when developing new plans,
particularly if animal manures are to be a
nutrient source.
Consider annual reviews to determine if
changes in the nutrient budget are desirable (or
needed) for the next planned crop.
On sites on which there are special
environmental concerns, consider other
sampling techniques. (For example: Soil profile
sampling for nitrogen, Pre-Sidedress Nitrogen
Test (PSNT), Pre-Plant Soil Nitrate Test
(PPSN) or soil surface sampling for phosphorus
accumulation or pH changes.)
Consider ways to modify the chemistry of
animal manure, including modification of the
animal's diet to reduce the manure nutrient
content, to enhance the producer's ability to
manage manure effectively.
PLANS AND SPECIFICATIONS
Plans and specifications shall be in keeping
with this standard and shall describe the
requirements for applying the practice to
achieve its intended purpose(s), using nutrients
to achieve production goals and to prevent or
minimize water quality impairment.
The following components shall be included in
the nutrient management plan:
* aerial photograph or map and a soil map of
the site,
* current and/or planned plant production
sequence or crop rotation,
* results of soil, plant, water, manure or
organic by-product sample analyses,
* realistic yield goals for the crops in the
rotation,
* quantification of all nutrient sources,
* recommended nutrient rates, timing, form,
and method of application and
incorporation,
* location of designated sensitive areas or
resources and the associated, nutrient
management restriction,
* guidance for implementation, operation,
maintenance, recordkeeping, and
* complete nutrient budget for nitrogen,
phosphorus, and potassium for the
rotation or crop sequence.
If increases in soil phosphorus levels are
expected, plans shall document:
* the soil phosphorus levels at which it may
be desirable to convert to phosphorus
based implementation,
* the relationship between soil phosphorus
levels and potential for phosphorus
transport from the field, and
* the potential for soil phosphorus
drawdown from the production and
harvesting of crops.
When applicable, plans shall include other
practices or management activities as
determined by specific regulation, program
requirements, or producer goals.
In addition to the requirements described
above, plans for nutrient management shall
also include:
* discussion about the relationship between
nitrogen and phosphorus transport and
water quality impairment. The discussion
about nitrogen should include information
about nitrogen leaching into shallow
ground water and potential health impacts.
The discussion about phosphorus should
include information about phosphorus
accumulation in the soil, the increased
potential for phosphorus transport in
soluble form, and the types of water
quality impairment that could result from
phosphorus movement into surface water
bodies.
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Code 590
* discussion about how the plan is intended
to prevent the nutrients (nitrogen and
phosphorus) supplied for production
purposes from contributing to water quality
impairment.
* a statement that the plan was developed
based on the requirements of the current
standard and any applicable Federal, state,
or local regulations or policies; and that
changes in any of these requirements may
necessitate a revision of the plan.
OPERATION AND MAINTENANCE
The owner/client is responsible for safe
operation and maintenance of this practice
including all equipment. Operation and
maintenance addresses the following:
* periodic plan review to determine if
adjustments or modifications to the plan are
needed. As a minimum, plans will be
reviewed and revised with each soil test
cycle.
* protection of fertilizer and organic by-
product storage facilities from weather and
accidental leakage or spillage.
* calibration of application equipment to
ensure uniform distribution of material at
planned rates.
* documentation of the actual rate at which
nutrients were applied. When the actual
rates used differ from or exceed the
recommended and planned rates, records
will indicate the reasons for the differences.
* Maintaining records to document plan
implementation. As applicable, records
include:
• soil test results and recommendations for
nutrient application,
• quantities, analyses and sources of
nutrients applied,
• dates and method of nutrient applications,
• crops planted, planting and harvest dates,
yields, and crop residues removed,
• results of water, plant, and organic by-
product analyses, and
• dates of review and person performing the
review, and recommendations that
resulted from the review.
Records should be maintained for five years;
or for a period longer than five years if
required by other Federal, state, or local
ordinances, or program or contract
requirements.
Workers should be protected from and avoid
unnecessary contact with chemical fertilizers
and organic by-products. Protection should
include the use of protective clothing when
working with plant nutrients. Extra caution
must be taken when handling ammonia
sources of nutrients, or when dealing with
organic wastes stored in unventilated
enclosures.
The disposal of material generated by the
cleaning nutrient application equipment should
be accomplished properly. Excess material
should be collected and stored or field applied
in an appropriate manner. Excess material
should not be applied on areas of high
potential risk for runoff and leaching.
The disposal or recycling of nutrient containers
should be done according to state and local
guidelines or regulations.
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Code 313
NATURAL RESOURCES CONSERVATION SERVICE
CONSERVATION PRACTICE STANDARD
WASTE STORAGE FACILITY
(No.)
CODE 313
DEFINITION
A waste impoundment made by constructing an
embankment and/or excavating a pit or dugout,
or by fabricating a structure.
PURPOSE
To temporarily store wastes such as manure,
wastewater, and contaminated runoff as a
function of an agricultural waste management
system.
CONDITIONS WHERE PRACTICE APPLIES
The storage facility is a component of a planned
agricultural waste management system.
Temporary storage is needed for organic wastes
generated by agricultural production or
processing.
The storage facility can be constructed, operated
and maintained without polluting air or water
resources.
Soils, geology, and topography are suitable for
construction of the facility.
The practice applies to facilities utilizing
embankments with an effective height of 35 feet
or less where damage resulting from failure
would be limited to damage of farm buildings,
agricultural land, or township and country roads.
Fabricated structure facilities applies to tanks,
stacking facilities, and pond appurtenances.
CRITERIA
General Criteria
Storage period. The storage period is the
maximum length of time anticipated between
emptying events. The minimum storage period
shall be based on the timing required for
environmentally safe waste utilization
considering the climate, crops, soil, equipment,
and local, state, and Federal regulations.
Design storage volume. The design storage
volume shall consist of the total of the following
as appropriate:
a. M a n u re, wastewate r,andotherwastes
accumulated during the storage period.
b. Normal precipitation less evaporation on the
surface area of the facility during the storage
period.
c. Normal runoff from the facility's drainage
area during the storage period.
d. 25-year, 24-hour precipitation on the surface
of the facility.
e. 25-year, 24-hour runoff from the facility's
drainage area.
f. Residual solids after liquids have been
removed. A minimum of 6 inches shall be
provided for tanks.
g. Additional storage as may be required to
meet management goals or regulatory
requirements.
The design storage volume for a waste storage
facility is equal to its required volume.
Inlet. Inlets shall be of any permanent type
designed to resist corrosion, plugging, and
freeze damage incorporating erosion protection
as necessary. Inlets from enclosed buildings
shall be provided with a water-sealed trap and
vent or similar devices to control gas entry into
the buildings or other confined spaces.
Safety. Design shall include appropriate safety
features to minimize the hazards of the facility.
Protection. Embankments and disturbed areas
surrounding the facility shall be treated to control
erosion.
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Flexible membranes. Flexible membranes
shall meet or exceed the requirements of flexible
membrane linings specified in NRCS Practice
Standard Pond Sealing.
Pond Criteria
Location. Waste storage ponds, if located
within floodplains, shall be protected from
inundation or damage from a 25-year flood
event.
Soil and foundation. The pond shall be located
in soils with acceptable permeabilities, or the
pond shall be lined. Information and guidance
on controlling seepage from waste storage
ponds can be found in the Agricultural Waste
Management Field Handbook (AWMFH),
Chapter 7. The pond shall have a bottom
elevation that is a minimum of 2 feet above the
high water table.
Outlet. No outlet shall automatically release
storage from the required storage volume.
Manually operated outlets shall be of permanent
type designed to resist corrosion and plugging.
Embankments. The minimum elevation of the
top of the settled embankment shall be 1 foot
above the required storage volume. This height
shall be increased by the amount needed to
ensure that the top elevation will be maintained
after settlement. This increase shall be not less
than 5 percent. The minimum top width shall be
8 feet. The combined side slopes of the settled
embankment shall be not less than 5 horizontal
to 1 vertical, and neither slope shall be steeper
than 2 horizontal to 1 vertical.
Emptying facilities. Some type of facility shall
be provided for emptying the pond. It may be a
dock, a pumping platform, a retaining wall, or a
ramp. Ramps used to empty liquids shall have a
slope of 4 horizontal to 1 vertical or flatter.
Those used to empty slurry, semi-solid, or solid
waste shall have a slope of 10 horizontal to 1
vertical or flatter. Steeper slopes may be used if
special traction surfaces are provided.
Provision shall be made for periodic removal of
accumulated solids to preserve storage capacity.
The anticipated method for doing this must be
considered in planning, particularly in
determining the size and shape of the pond and
type of seal, if any.
Safety. The pond shall be fenced and warning
signs posted to prevent children and others from
using it for other than its intended purpose.
Fabricated Structure Criteria
Foundation. The foundations of waste storage
structures shall be proportioned to safely support
all superimposed loads without excessive
movement or settlement.
Where a non-uniform foundation cannot be
avoided or applied loads may create highly
variable foundation loads, settlement should be
calculated from site specific soil test data. Index
tests of site soil may allow correlation with similar
soils for which test data is available. If no test
data is available, presumptive bearing strength
values for assessing actual bearing pressures
may be obtained from Table 1 or another
nationally recognized building code. In using
presumptive bearing values, adequate detailing
and articulation shall be provided to avoid
distressing movements in the structure.
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Table 1 - Presumptive allowable bearing stress
values1
Foundation Description
Crystalline Bedrock
Sedimentary Rock
Sandy Gravel or Gravel
Sand, Silty Sand, Clayey Sand,
Silty Gravel, Clayey Gravel
Clay, Sandy Clay, Silty Clay,
Clayey Silt
Allowable Stress
12000psf
6000 psf
5000 psf
3000 psf
2000 psf
1 Basic Building Code, 12th Edition, 1993,
Building Officials and Code Administrators, Inc.
(BOCA)
Structural loadings. Waste storage structures
shall be designed to withstand all anticipated
loads including internal and external loads,
hydrostatic uplift pressure, concentrated surface
and impact loads, water pressure due to
seasonal high water table, and frost or ice
pressure and load combinations in compliance
with this standard and applicable local building
codes.
The lateral earth pressures should be calculated
from soil strength values determined from the
results of appropriate soil tests. Lateral earth
pressures can be calculated using the
procedures in TR-74. If soil strength tests are
not available, the presumptive lateral earth
pressure values indicated in Table 2 shall be
used.
Lateral earth pressures based upon equivalent
fluid assumptions shall be assigned according to
the structural stiffness or wall yielding as follows:
* Rigid frame or restrained wall. Use the
values shown in Table 2 under the column
"Frame Tanks," which gives pressures
comparable to the at-rest condition.
* Flexible or yielding wall. Use the values
shown in Table 2 under the column
"Freestanding Wall," which gives pressures
comparable to the active condition. Walls in
this category are designed on the basis of
gravity for stability or are designed as a
cantilever having a base wall thickness to
height of backfill ratio not more than 0.085.
Internal lateral pressure used for design shall be
65 Ibs/ft^ where the stored waste is not
protected from precipitation. A value of 60
Ibs/ft2 may be used where the stored waste is
protected from precipitation and will not become
saturated. Lesser values may be used if
supported by measurement of actual pressures
of the waste to be stored. If heavy equipment
will be operated near the wall, an additional two
feet of soil surcharge shall be considered in the
wall analysis.
Tank covers shall be designed to withstand both
dead and live loads. The live load values for
covers contained in ASAE EP378.3, Floor and
Suspended Loads on Agricultural Structure Due
to Use, and in ASAE EP393.2, Manure Storages,
shall be the minimum used. The actual axle
load for tank wagons having more than a 2,000
gallon capacity shall be used.
If the facility is to have a roof, snow and wind
loads shall be as specified in ASAE EP288.5,
Agricultural Building Snow and Wind Loads. If
the facility is to serve as part of a foundation or
support for a building, the total load shall be
considered in the structural design.
Structural design. The structural design shall
consider all items that will influence the
performance of the structure, including loading
assumptions, material properties and
construction quality. Design assumptions and
construction requirement shall be indicated on
the plans.
Tanks may be designed with or without covers.
Covers, beams, or braces that are integral to
structural performance must be indicated on the
construction drawings. The openings in covered
tanks shall be designed to accommodate
equipment for loading, agitating, and emptying.
These openings shall be equipped with grills or
secure covers for safety, and for odor and vector
control.
All structures shall be underlain by free draining
material or shall have footing located below the
anticipated frost depth.
Minimum requirements for fabricated structures
are as follows:
* Steel. "Manual of Steel Construction",
American Institute of Steel Construction.
* Timber. "National Design Specifications for
Wood Construction", American Forest and
Paper Association.
* Concrete. "Building Code Requirements for
Reinforced Concrete, ACI 318", American
Concrete Institute.
* Masonry. "Building Code Requirements for
Masonry Structures, ACI 530", American
Concrete Institute.
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Slabs on grade. Slab design shall consider
the required performance and the critical
applied loads along with both the subgrade
material and material resistance of the
concrete slab. Where applied point loads
are minimal and liquid-tightness is not
required, such as barnyard and feedlot slabs
subject only to precipitation, and the
subgrade is uniform and dense, the
minimum slab thickness shall be 4 inches
with a minimum joint spacing of 10 feet.
Joint spacing can be increased if steel
reinforcing is added based on subgrade drag
theory.
For applications where liquid-tightness is
required such as floor slabs of storage
tanks, the minimum thickness for uniform
foundations shall be 5 inches and shall
contain distributed reinforcing steel. The
required area of such reinforcing steel shall
be based on subgrade drag theory as
discussed in industry guidelines such as
American Concrete Institute, ACI 360,
"Design of Slabs-on-Grade".
* When heavy equipment loads are to be
resisted and/or where a non-uniform
foundation cannot be avoided, an
appropriate design procedure incorporating
a subgrade resistance parameter(s) such as
ACI 360 shall be used.
Safety provisions. Entrance ramps shall be no
steeper than 10 horizontal to 1 vertical. Warning
signs, ladders, ropes, bars, rails, and other
devices shall be provided, as appropriate, to
ensure the safety of humans and livestock.
Ventilation and warning signs must be provided
for covered waste holding structures, as
necessary, to prevent explosion, poisoning, or
asphyxiation. Pipelines from enclosed buildings
shall be provided with a water-sealed trap and
vent or similar devices to control gas entry into
the buildings.
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Table 2 - Lateral earth pressure values1
Soil
Equivalent fluid pressure (Ib/ft2/ft of
depth)
Description4
Unified Classification4
Above seaonsal
Below seasonal
high water table high water table
Free
standing
wall
Frame
tanks
Free
standing
wall
Fram
e
tanks
Clean gravel, sand or
sand-gravel mixtures
(maximum 5% fines)5
GP, GW, SP, SW
30
50
80
90
Gravel, sand, silt and
clay mixtures (less
than 50% fines)
Coarse sands with silt
and/or clay (less
than 50% fines)
All gravel/sand dual
symbol classifications
and GM, GC, SC,
SM, SC-SM
35
60
80
100
Low-plasticity silts and
clays with some sand
and/or gravel (50% or
more fines)
Fine sands with silt
and/or clay (less
than 50% fines)
CL, ML, CL-ML
SC, SM, SC-SM
45
75
90
105
Low to medium plasticity
silts and clays with
little sand and/or
gravel (50% or more
fines)
CL, ML, CL-ML
65
85
95
110
High plasticity silts and
clays (liquid limit more
than 50)6
CH, MH
For lightly compacted soils (85% to 90% maximum standard density.) Includes
compaction by use of typical farm equipment.
2 Also below seasonal high water table if adequate drainage is provided.
3 Includes hydrostatic pressure.
All definitions and procedures in accordance with ASTM D 2488 and D 653.
Generally, only washed materials are in this category
6 Not recommended. Requires special design if used.
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CONSIDERATIONS
Waste storage facilities should be located as
close to the source of waste and polluted runoff
as practicable. In addition, they should be
located considering prevailing winds and
landscape elements such as building
arrangement, landform, and vegetation to
minimize odors and visual resource problems.
An auxiliary (emergency) spillway and/or
additional embankment height should be
considered to protect the embankment.
Factors such as drainage area, pond size,
precipitation amounts, downstream hazards,
and receiving waters should be evaluated in
this consideration.
Non-polluted runoff should be excluded to the
fullest extent possible except where its storage
is advantageous to the operation of the
agricultural waste management system.
Freeboard for waste storage structures should
be considered.
Solid/liquid separation of runoff or wastewater
entering pond facilities should be considered to
minimize the frequency of accumulated solid
removal and to facilitate pumping and
application of the stored waste.
Due consideration should be given to
economics, the overall waste management
system plan, and safety and health factors.
PLANS AND SPECIFICATIONS
Plans and specifications shall be prepared in
accordance with the criteria of this standard
and shall describe the requirements for
applying the practice to achieve its intended
use.
OPERATION AND MAINTENANCE
An operation and maintenance plan shall be
developed that is consistent with the purposes
of the practice, its intended life, safety
requirements, and the criteria for its design.
The plan shall contain the operational
requirements for emptying the storage facility.
This shall include the requirement that waste
shall be removed from storage and utilized at
locations, times, rates, and volume in
accordance with the overall waste
management system plan. In addition, for
ponds, the plan shall include the requirement
that following storms, waste shall be removed
at the earliest environmentally safe period to
ensure that sufficient capacity is available to
accommodate subsequent storms.
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Code 633
NATURAL RESOURCES CONSERVATION SERVICE
CONSERVATION PRACTICE STANDARD
WASTE UTILIZATION
(Acre)
CODE 633
DEFINITION
Using agricultural wastes such as manure
and wastewater or other organic residues.
PURPOSES
Protect water quality
Provide fertility for crop, forage, fiber
production and forest products
Improve or maintain soil structure;
Provide feedstock for livestock
Provide a source of energy
CONDITIONS WHERE PRACTICE
APPLIES
This practice applies where agricultural
wastes including animal manure and
contaminated water from livestock and
poultry operations; solids and wastewater
from municipal treatment plants; and
agricultural processing residues are
generated, and/or utilized.
CRITERIA
General criteria applicable to all
purposes
All federal, state and local laws, rules and
regulations governing waste management,
pollution abatement, health and safety shall
be strictly adhered to. The owner or
operator shall be responsible for securing
any and all required permits or approvals
related to waste utilization, and for operating
and maintaining any components in
accordance with applicable laws and
regulations.
Use of agricultural wastes shall be based on
at least one analysis of the material during
the time it is to be used. In the case of daily
spreading, the waste shall be sampled and
analyzed at least once each year. As a
minimum the waste analysis should identify
nutrient and specific ion concentrations.
Where the metal content of municipal
wastewater, sludge, septage, and other
agricultural waste is of a concern, the
analysis shall also include determining the
concentration of metals in the material.
Where agricultural wastes are to be spread
on land not owned or controlled by the
producer, the waste management plan, as a
minimum, shall document the amount of
waste to be transferred and who will be
responsible for the environmentally
acceptable use of the waste.
Records of the use of wastes shall be kept a
minimum of five years as discussed in
OPERATION AND MAINTENANCE, below.
Additional criteria to protect water quality
All agricultural waste shall be utilized in a
manner that minimizes the opportunity for
contamination of surface and ground water
supplies.
Agricultural waste shall not be land-applied
on soils that are frequently flooded, as
defined by the National Cooperative Soil
Survey, during the period when flooding is
expected.
When liquid wastes are applied, the
application rate shall not exceed the
infiltration rate of the soil, and the amount of
waste applied shall not exceed the moisture
holding capacity of the soil profile at the time
of application. Wastes shall not be applied
to frozen or snow-covered ground.
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Additional criteria for providing fertility
for crop, forage, fiber production and
forest products
Where agricultural wastes are utilized to
provide fertility for crop, forage, fiber
production, and forest products, the practice
standard Nutrient Management (590) shall
be followed.
Where municipal wastewater and solids are
applied to agricultural lands as a nutrient
source, the single application or lifetime
limits of heavy metals shall not be exceeded.
The concentration of salts shall not exceed
the level that will impair seed germination or
plant growth.
Additional criteria for improving or
maintaining soil structure
Wastes shall be applied at rates not to
exceed the crop nutrient requirements or salt
concentrations as stated above, and shall be
applied at times the waste material can be
incorporated by appropriate means into the
soil within 72 hours of application.
Additional criteria for providing
feedstock for livestock
Agricultural wastes to be used for feedstock
shall be handled in a manner to minimize
contamination and preserve its feed value.
Chicken litter stored for this purpose shall be
covered. A qualified animal nutritionist shall
develop rations which utilize wastes.
Additional criteria for providing a source
of energy
Use of agricultural waste for energy
production shall be an integral part of the
overall waste management system.
All energy producing components of the
system shall be included in the waste
management plan and provisions for
utilization of residues of energy production
identified.
Where the residues of energy production are
to be land-applied for crop nutrient use or
soil conditioning, the criteria listed above
shall apply.
CONSIDERATIONS
The effect of Waste Utilization on the water
budget should be considered, particularly
where a shallow ground water table is
present or in areas prone to runoff. Limit
waste application to the volume of liquid that
can be stored in the root zone.
Minimize the impact of odors of land-applied
wastes by making application at times when
temperatures are cool and when wind
direction is away from neighbors.
Agricultural wastes contain pathogens and
other disease-causing organisms. Wastes
should be utilized in a manner that
minimizes their disease potential.
Priority areas for land application of wastes
should be on gentle slopes located as far as
possible from waterways. When wastes are
applied on more sloping land or land
adjacent to waterways, other conservation
practices should be installed to reduce the
potential for offsite transport of waste.
It is preferable to apply wastes on pastures
and hayland soon after cutting or grazing
before re-growth has occurred.
Reduce nitrogen volatilization losses
associated with the land application of some
waste by incorporation within 24 hours.
Minimize environmental impact of land-
applied waste by limiting the quantity of
waste applied to the rates determined using
the practice standard Nutrient Management
(590) for all waste utilization.
PLANS AND SPECIFICATIONS
Plans and specifications for Waste
Utilization shall be in keeping with this
standard and shall describe the
requirements for applying the practice to
achieve its intended purpose. The waste
management plan is to account for the
utilization or other disposal of all animal
wastes produced, and all waste application
areas shall be clearly indicated on a plan
map.
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OPERATION AND MAINTENANCE
Records shall be kept for a period of five
years or longer, and include when
appropriate:
• Quantity of manure and other
agricultural waste produced and their
nutrient content
• Soil test results
• Dates and amounts of waste
application where land applied, and the
dates and amounts of waste removed
from the system due to feeding, energy
production, or export from the
operation
• Waste application methods
• Crops grown and yields (both yield
goals and measured yield)
• Other tests, such as determining the
nutrient content of the harvested
product
• Calibration of application equipment.
The operation and maintenance plan shall
include the dates of periodic inspections and
maintenance of equipment and facilities
used in waste utilization. The plan should
include what is to be inspected or
maintained, and a general time frame for
making necessary repairs.
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APPENDIX E
NRCS FIELD OFFICE TECHNICAL GUIDE
The Natural Resources Conservation Service (NRCS) Field Office Technical Guide (FOTG)
is an essential tool for resource planning. The FOTG contains five Sections:
I. General Resource References - References, maps, cost lists, typical crop budgets,
and other information for use in understanding the field office working area, or in
making decisions about resource use and resource management.
II. Soil and Site Information - Soils are described and interpreted to help make
decisions about land use and management. In most cases, this will be an electronic
database.
III. Resource Management Systems - Guidance for developing resource management
systems. A description of the resource considerations and their acceptable levels of
quality or criteria are included in this section. This section contains the
Comprehensive Nutrient Management Planning Technical Guidance.
IV. Practice Standards and Specifications - Contains standards and specifications for
conservation practices used in the field office. Conservation practice standards
contain minimum quality criteria for designing and planning each practice;
specifications describe requirements necessary to install a practice.
V. Conservation Effects - Contains Conservation Practices Physical Effects matrices
that outline the impact of practices on various aspects of the five major resources -
soil, air, water, plants, and animals.
The FOTG is a document that is being updated continuously to reflect changes in technology,
resource information, and agency policy. The FOTG contains information that is unique to
states and local field offices within states. To obtain information contained within the
FOTG, contact a United States Department of Agriculture NRCS State Office (See Appendix
G for a listing).
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APPENDIX F
BACKGROUND INFORMATION AND CURRENT RESEARCH
ON RESOURCE CONCERNS
The information presented here was obtained from the USDA Agricultural Research
Service (ARS) Manure and Byproduct Utilization National Program Action Plan.
Additional Research is also being conducted under the ARS Air Quality National
Program. The action plans describe, in detail, the research goals in these areas over the
next five years. For the complete action plan and the most up-to-date information on
ARS National programs see: http://www.nps.ars.usda.gov/.
AIR QUALITY
Air quality changes resulting from livestock operations are poorly defined because of lack
of knowledge about the composition of emissions, emission rates, and dispersion of
emissions across the landscape. However, the issue of air quality is one of the critical
issues that must be addressed if animal feeding operations are to continue to exist in areas
with increasing urban-rural populations.
There are three types of emissions from livestock operations that affect air quality: gases,
particulates, and aerosols. Most gas emissions have not been examined or categorized.
Known gases of particular interest include: ammonia, odorous compounds, and gases
that adversely affect the atmosphere, such as methane, carbon dioxide and nitrous oxides.
Ammonia emissions appear to have the greatest potential for adverse environmental and
health impacts, while the generation and transport of malodorous compounds provokes
the largest public concern.
Ammonia production is a consequence of bacterial activity involving organic nitrogen
substrates. The primary source of ammonia production is the conversion of urea for
livestock and uric acid for poultry. The process is extremely rapid, requiring only hours
for substantial and days for complete conversion. A secondary source, which in this time
frame can account for up to 35 percent of ammonia production, is organic nitrogen
compounds in feces. In total, rapid processes convert about 35 percent of the total organic
nitrogen initially in manure to ammonia. Over longer time periods, principally during
storage, a total of 50 to 70 percent of the organic nitrogen can be converted to ammonia.
Odors are formed by the breakdown of manure via anaerobic digestion, and there are a
wide range of volatile compounds that may potentially contribute to detection of odors by
humans. Odorous compounds commonly associated with livestock facilities include:
ammonia, volatile organic compounds including amines and fatty acids, and organic and
inorganic sulfur containing compounds such as hydrogen sulfide and mercaptans.
The primary source of methane release in livestock production is ruminant animals.
Release is a consequence of microbiological activity within the gastrointestinal tract
necessary for breakdown of foodstuffs to compounds available for uptake by animals.
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Metabolic processes of methanogens can also result in significant methane release at all
stages of manure handling. Methane production from agriculture has been estimated to
be around 7.8 Tg/yr, with 70 percent of this amount produced by cattle that are grazed
and not in confinement feeding operations. Swine manure is estimated to produce
1.1 Tg/yr, while beef and dairy produce 0.9 Tg/yr. This difference is attributed to the
manure storage and handling process variations between swine and beef.
Carbon dioxide is the normal byproduct of animal and most bacterial metabolism.
Nitrogen dioxide and NOx release are normally the result of nitrification and
denitrification processes whereby ammonia is converted to inorganic forms of nitrogen
which, in turn, are converted to nitrogen gas. In addition, significant quantities of these
gases can be released as by-products of engineering processes designed to dispose of
manure or reduce odors.
Particulates are generally a consequence of interactions of animals with their
environment. In confined animal housing facilities, bedding, manure, litter, animal by-
products such as feathers, and feed mixing and distribution can contribute to the
generation of parti culates. Activity of animals during transport or other husbandry
activities can help particulates to become airborne. In external housing facilities, animal
movement on dry soil and manure can produce significant dust problems. Aerosols can
be generated anytime there is a water source and air movement. Numerous farm
management procedures generate aerosols, including misting or spraying to cool animals,
manure separation techniques, spray irrigation, and spraying to control dust. The current
development and implementation of the U.S. Environmental Protection Agency's PM-2.5
and PM-10 air particulate matter standards add additional urgency to addressing the
sources and amounts of parti culate emission.
The goals of ARS researchers working in the area of atmospheric emissions from
livestock operations are:
1. Develop certified methods to accurately measure emissions, e.g., ammonia,
particulates, odors, volatile organic compounds, and other greenhouse gases (CO2,
CH4, N2O, and NOx), related to livestock facilities. Develop robust methods that can
be used across a wide range of environments and animal production systems.
2. Understand ecology of aerobic and anaerobic microorganisms that are associated with
emissions. Identify mechanisms to change the ecology or metabolism of organisms to
reduce undesirable emissions. Develop methods to promote favorable changes in
ecology or metabolism of microorganisms.
3. Quantify the emission rates in relation to handling, storage, processing, and
application practices commonly used in U.S. livestock production systems. Correlate
emissions with management practices to allow identification of best management
practices for adoption by producers.
4. Determine environmental impacts on generation processes elucidated from Goal #2.
Determine the environmental impacts on transport and dispersion of gases and
particulates from livestock production and manure application sites. Quantify the
interactions of environment on generation, transport and dispersion processes.
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Quantify the interactions of emissions: gases, particulates, and aerosols, as factors
influencing atmospheric transport and dispersion.
5. Determine the direct on-site impact of emissions on environment and health.
Determine the local impact of emissions on environment and health. Determine the
relative contribution of emissions from livestock facilities compared to regional and
global emissions from other sources. Determine the net environmental cost of
emissions related to livestock facilities and manure application.
6. Determine whether application of current best management practices can reduce
emissions to acceptable on-site and off-site levels. Develop alternative management
practices that can reduce emissions and achieve most efficient use of nutrients by
animals. Determine the efficacy of various technologies and practices at a local,
regional, and national scale.
PATHOGENS
Utilization of contaminated irrigation water or manures containing pathogenic or parasitic
agents are considered to be important factors in the occurrence and epidemiology of
water- and food-borne diseases. Recycling of manure to the land without adequate
pathogen reduction directly increases the risks of human illness via water- or food-borne
contamination, as well as cycling pathogens back to animals on the farm. This is true for
pathogens associated with foods of animal origin as well as produce that may have been
contaminated during production. Techniques, such as composting or deep stacking, to
reduce pathogen levels in manure are often not used by producers because they require
extra time, attention, special equipment or structures, and impose additional costs.
Generally, soil that has not recently received raw manure (liquid, slurry, partially dried, or
improperly composted) or inadequately treated sewage has not been found to harbor
indigenous populations of enteric pathogens and parasites. Manure, however, is not the
only on-farm source of pathogens and parasites. Other farm sources include: dust,
aerosols, irrigation and runoff water, farm workers, plant residues, and the soil. For
example, Bacillus cereus, Clostridium spp, and Listeria monocytogenes, can be readily
found in many soils in association with plant material, vegetables, and decaying leaves
and other plant parts. In addition, coliforms such as Enterobacter spp. and Klebsiella spp.
are common inhabitants of soil and plant material, even in the absence of fecal material.
This limits the use of traditional fecal coliform methods as indicators of fecal
contamination, and reinforces the need for standard methods for the assessment of fecal
contamination of produce.
It is well established that pathogen spread in the environment results from improper
treatment and land application of sewage, slaughter offal, sludge, biosolids, slurry and
manure, as well as from wild and domesticated animals. This may lead, by way of
contamination of surface waters and colonization of birds, rodents and insects, to the
contamination of animal feeds or directly contribute to the re-colonization of farm
animals. Despite what is known about potential vectors of pathogen contamination, many
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critical questions remain to be answered. The lack of knowledge about pathogen survival
in manure and about the adequacy of various manure management techniques to reduce
the levels of these pathogens clearly points to the need for research on these issues. The
fate of pathogens in the environment (e.g., transport and survival) after manure and other
by-products have been land applied or otherwise disposed is not adequately known. In
addition, better estimates of human and animal exposure are required for risk assessment
to adequately assess the benefit of manure and byproduct treatment strategies.
Many of the pathogens that have emerged over the past 10 years cannot be easily detected
and quantified in complex environmental samples such as manure, compost, soil, and
foods. Application of current standard methods to the variety of matrices involved in
determining the exposure at the farm end of the farm-to-table continuum will require
adaptation and possibly development of new methods for detection and quantification of
viable microorganisms.
The specific goals of ARS researchers working in the area of pathogens from livestock
operations are:
1. To develop new techniques and adapt existing techniques for the detection of
pathogenic bacteria and protozoans in agricultural matrices such as manure and soil.
To standardize techniques for sampling and detection of each pathogen in all
environmental matrices encountered in agriculture (manure, soil, runoff water and
ground water) with respect to sample size, limit of detection, storage, etc., so that
studies can be compared. To develop sensors (biological, molecular, chemical) for
the rapid detection of pathogens in agricultural systems.
2. Determine the survival and transport of enteropathogenic bacteria in agricultural soils
managed under different agricultural practices. Determine the effect of soil structure,
pH, temperature, etc. on pathogen survival. Determine the influence of cover crops
on pathogen survival. Relate the survival of various pathogens under all these
conditions to the survival of more easily measured indicator organisms. Determine
the effect of manure composition on pathogen survival upon storage or on application
to soil. Determine the role of biofilm formation by saprophytes and pathogens on
plants, plant residues, and soil particles in the survival of pathogens derived from
fresh manure and treated manures.
3. Determine pathogen/parasite levels in feces and estimate pathogen loading rates for
different production systems. Develop functional relationships between vertical
versus surface pathogen transport and soil, topographic, vegetation, rainfall, and
organism parameters. Determine pathogen association with organic particulates
and/or sediments and the impact on transport potential/dissemination. Assess the
ability of vegetative buffer strips, riparian zones, and/or wetlands to reduce pathogen
runoff. Integrate laboratory, field plot, and watershed scale data to describe pathogen
transport in the context of hydrology. Assess the importance of wildlife/insect vectors
and aerial transport. Quantify the role of on-farm practices on inter- and intra-farm
pathogen dissemination (e.g., vehicular transport of incompletely disinfected
manures, birds, dust, etc.).
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4. Determine rates of pathogen destruction for major existing treatments, i.e., deep
stacks, compost (passive aerated, windrow, static piles, in-vessel), digestion, lagoon,
air drying, heat drying, and new treatments, and include pathogens and parasites
recently involved in the surge of food and waterborne illness outbreaks in the U.S.
Determine what protectants in manures, composts, or soils affect survival of
pathogens and parasites. Quantitatively relate rates of pathogen destruction to critical
environmental factors associated with each of the various treatment processes;
develop destruction functions for each of the major pathogens, manure types, and
treatments. Develop process quality criteria to guide operators so that pathogen
destruction is achieved to the extent possible for the treatment process selected.
Develop and validate appropriate quality control tests or measures for pathogen
destruction for each major treatment process. Determine which indicator or surrogate
organisms are appropriate for use in assessing reduction of particular pathogens in
manure from various animal species, and use them in on-farm tests. Improve
microbial growth, survival and thermal death models for manure and soil matrices,
including species and strain differences, and nonlinear declines. Develop concepts
and models of microbial exposure and risk analysis for treated manure products and
link to more general microbial risk assessment models. Incorporate pathogen
reduction data for major treatment methods into cost-benefit analysis models.
Compare actual and predicted destruction in various on-farm treatment processes.
Evaluate the use of industrial by-products to improve effectiveness of pathogen
reduction treatments. Develop new methods to reduce or eliminate contaminants
from establishing on plants before harvest. Develop new cost-effective disinfection
methods and equipment and systems modifications for processing manure that are
also consistent with air and water quality and nutrient management concerns.
5. Establish assessment endpoints. Evaluate manure management strategies in the
context of risk assessment.
NUTRIENT MANAGEMENT
Animal manures, applied in solid, semisolid and liquid forms contain essential nutrients
that can meet crop requirements if applied to land in the proper manner at the right time
and in suitable amounts. The manure generated annually in the U.S. contains about 8.3
million tons of nitrogen (N) and 2.5 million tons of phosphorus (P). However, manure in
general is underutilized as a nutrient source in high density animal production areas such
as dairy farms in southern California, beef feedlots in the Southern Plains, hog operations
in North Carolina and poultry houses in the Southeastern U.S. Manure can build soil
organic matter reserves, resulting in improved water-holding capacity, increased water
infiltration rates and improved structural stability. Manure can decrease the energy
needed for tillage, reduce impedance to seedling emergence and root penetration,
stimulate growth of beneficial soil microbial populations and increase beneficial
mesofauna such as earthworms.
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Animal feed and animal nutrition are important components of manure management.
Livestock and poultry diet directly influences the amount of manure produced; nutrient,
trace element and pathogen concentrations in manure; and formation of volatile
components. Research to increase feed use-efficiency emphasizes defining animal
nutritional requirements, diet formulation, genetically altered crops, use of enzymes and
alteration of intestinal microflora.
In the past, animal diets were oversupplied with nutrients to achieve maximum animal
performance with little regard for nutrients excreted. As environmental concerns
associated with excess manure nutrients have increased, research has turned toward more
efficient use of feed and matching feed nutrient concentrations to animal requirements.
This approach can reduce the volume of manure produced, reduce nutrients excreted and
lower production costs.
Ineffective utilization of P, especially by monogastric animals such as poultry and swine,
has resulted in excess levels of P in manure. Monogastric animals lack enzymes to
effectively break down the phytic acid form of P normally found in grain. Producers
routinely add inorganic P supplements to poultry and swine diets, resulting in even higher
levels of P in manure. Two basic approaches are being used to increase P utilization
efficiency: enzyme addition to animal feed and development of grain with P in forms
more readily available to the animal.
Nitrogen is especially susceptible to losses through ammonia volatilization,
denitrification, leaching, anaerobic decomposition in lagoons and during aerobic
composting. Treatment technologies are being developed to control ammonia
volatilization and to immobilize N and P. Management of liquid manure and wastewater
from animal operations is a major concern. Research is being conducted to allow more
effective use of manure resources from anaerobic and aerobic lagoons, to develop more
efficient separation of manure liquids and solids, and to find improved ways to
immobilize and capture manure nutrients. A combination of practices will be required to
effectively manage nutrients during manure handling and storage.
A greater understanding of nutrient transformations and reactions in manure and soil
treated with manure is required. Analytical methods are needed to give producers quick
reliable estimates of bioavailable nutrient concentrations in manure and soil. This will
allow manure application rates to be targeted to crop needs and will allow proper nutrient
credits for manure.
Effective management of N and P from manure and fertilizer is essential to protect
ground and surface water quality. In the past, animal manure application rates were based
on crop N requirements to minimize nitrate leaching to groundwater. The mean N:P ratio
(4:1) in manure is generally lower than the mean N:P ratio (8:1) taken up by major grain
and hay crops. Therefore, if manure application based on N has occurred for many years,
rapid build up of P levels in soils create the potential for P losses to surface waters
through runoff. Although protecting groundwater from nitrate leaching and limiting
ammonia volatilization are major concerns, the management emphasis has shifted to P in
many areas of the U.S.
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Irrigation, especially furrow irrigation, can significantly increase P losses by both surface
runoff and erosion in irrigation return flows. In addition, researchers have shown that soil
P moves through the soil profile to shallow subsurface water in heavily-manured areas of
the Delmarva Peninsula and through the soil profile to tile drains in the Midwest and
Southeast U.S. Several states have established threshold soil test P levels that are
perceived to protect surface waters from runoff that would cause eutrophication. These
threshold levels are based on soil tests originally designed to predict crop response to
nutrient additions. At soil test values above the threshold level, additional P cannot be
added to the soil or application rates are limited to crop removal rates.
However, there are a number of limitations to a regulatory approach based on soil
threshold P values. Also, it has been shown that 90 percent of the P runoff from an
agricultural watershed may come from only 10 percent of the land area during a few
relatively large storms. Therefore, the preferred approach to preventing P loss is to
define, target and remediate source areas of P that combine high soil P levels, high
surface runoff and erosion potentials, and proximity to P-sensitive bodies of water. This
approach addresses P management at multi-field or watershed scales. A P index has been
developed to rank the vulnerability of fields as sources of P losses in surface runoff. The
index accounts for and ranks transport and source factors controlling P losses in surface
runoff. The P index is being evaluated and refined in 14 states. When fully developed,
the P index will allow producers to identify areas in a watershed that are susceptible to P
losses and will suggest management options to correct the problem.
Alternative uses are needed for animal manure in areas where supply exceeds available
land and land application would cause significant environmental risk. Manure use for
energy production including burning, methane generation and conversion to other fuels is
being investigated. Methods to reduce the weight, volume or form of manure such as
composting or pelletizing will reduce transportation costs and create a more valuable
product. Manure is being mixed, blended or co-composted with industrial or municipal
byproducts to produce value-added material for specialized uses. Transportation subsidies
are needed to move manure from areas of over supply to areas with nutrient deficiencies.
Changes in farming practices may be needed to address manure problems. Systems that
balance nutrient inputs and outputs need to be developed at the whole-farm scale. These
systems would emphasize a reduction of purchased nutrient inputs and more effective use
and cycling of nutrients on the farm. Alternative production systems such as hoop houses
for swine need to be evaluated and used where appropriate to reduce environmental
threats from animal feeding operations. Benefits to be gained in terms of improved
environmental quality would partially offset any additional expenses associated with
these alternative manure uses and management practices.
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The specific goals of ARS researchers working in the area of nutrient management from
livestock manure are:
1. Determine the minimum nutrient requirements to support optimum production while
minimizing nutrient losses for modern domestic livestock species under different
production systems. Determine how nutrient requirements could be manipulated
through changes in animal physiological processes. Determine the effects of diet
formulation, environment, and feeding strategies on nutrient use and excretion by
livestock and poultry. Develop procedures for use of dietary enzymes, supplements,
and metabolic modifiers to improve nutrient utilization and decrease nutrient
excretion. Determine the impact of gut micro flora on nutrient excretion. Modify
feedstocks, livestock, and poultry for more efficient nutrient use by the animal and
reduced nutrient excretion. Develop simple, inexpensive, rapid and reliable tests to
reliably determine the bioavailability of nutrients in feeds. Determine the impact of
diet and feeding strategies on nonpoint source water pollution.
2. Increase understanding of manure chemistry and microbiology to reduce nutrient
losses during handling and storage and to improve treatment systems. Develop
improved systems for solids removal from liquid manures. Develop improved
manure handling, storage, and treatment methods to reduce ammonia volatilization.
Develop treatment systems that transform and/or capture nutrients, trace elements,
and pharmaceutically active chemicals from manure produced in confined animal
production systems. Improve composting and other manure stabilization techniques.
Develop treatment systems to remediate or replace anaerobic lagoons.
3. Develop techniques to identify and quantify the important compounds in animal
manure and byproducts that contribute plant-available nutrients. Develop quick,
accurate, and reliable methods for manure analysis. Develop techniques to assess the
dynamics of nutrient availability from manures and byproducts in specific soil-crop-
climate systems.
4. Develop best management practices for manure application rate, placement, and
timing to synchronize manure nutrient availability with crop nutrient demand.
Develop decision support tools and production practices that integrate manure and
byproduct use and balance nutrient inputs and outputs at the whole-farm scale.
5. Determine the relationship between phosphorus in soil and the movement of soluble
phosphorus to surface and shallow ground water. Develop predictive tools to identify
areas susceptible to phosphorus losses in a landscape. Develop comprehensive
water shed-scale nutrient management practices to protect water quality.
6. Determine the influence of agronomic practices such as tillage system, surface
residue, crop rotations, on movement of manure nutrients to surface and ground
water. Develop and evaluate methods such as vegetative buffer zones, grass filter
strips, riparian zones, and/or other vegetative filters to prevent manure nutrient
movement to surface waters.
7. Determine the long-term effects of manure and byproduct application on soil physical,
biological, and chemical properties. Determine the long-term effects of manure and
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byproduct application on crop, range, and livestock productivity. Determine the long-
term effects of manure and byproduct application on adjacent ecosystems.
8. Develop soil and crop management systems that increase utilization of manure
nutrients. Develop short-term remediation strategies (bio- and phyto-) to remove
excess nutrients in the soil. Develop long-term soil amendments and crop
management systems to remove excess nutrients from soil.
9. Develop effective methods to obtain energy from manure. Co-utilize animal manure
with other organic and inorganic waste resources to produce value-added products for
special uses.
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APPENDIX G
STATE OFFICES
United States Department of Agriculture
Natural Resources Conservation Service
Alabama
3381 Skyway Drive
P.O. Box 311
Auburn, AL 36830
Phone: 334/887-4500
Fax: 334/887-4552
Connecticut
344 Merrow Road
Tolland, CT 06084
Phone: 860/871-4011
Fax: 860/871-4054
Idaho
9173 West Barnes Drive
Suite C
Boise, ID 83709
Phone: 208/378-5700
Fax: 208/378-5735
Alaska
800 West Evergreen
Atrium Building, Suite 100
Palmer, AK 99645-6539
Phone: 907/761-7760
Fax: 907/761-7790
Delaware
1203 College Park Drive
Suite 101
Dover, DE 19904-8713
Phone: 302/678-4160
Fax: 302/678-0843
Illinois
1902 Fox Drive
Champaign, IL 61820-7335
Phone: 217/353-6600
Fax: 217/353-6676
Arizona
3003 North Central Avenue
Suite 800
Phoenix, AZ 85012-2945
Phone: 602/280-8801
Fax: 602/280-8849
Florida
2614 N.W. 43rd Street
Gainesville, FL 32606-6611 or
P.O Box 141510,
Gainesville, FL 32614
Phone: 352/338-9500
Fax: 352/338-9574
Indiana
6013 Lakeside Blvd.
Indianapolis, IN 46278-2933
Phone: 317/290-3200
Fax: 317/290-3225
Arkansas
Federal Building, Room 3416
700 West Capitol Avenue
Little Rock, AR 72201-3228
Phone: 501/301-3100
Fax: 501/301-3194
Georgia
Federal Building, Stop 200
355 East Hancock Avenue
Athens, GA 30601-2769
Phone: 706/546-2272
Fax: 706/546-2120
Iowa
693 Federal Building
210 Walnut Street, Suite 693
Des Momes, IA 50309-2180
Phone: 515/284-6655
Fax: 515/284-4394
California
430 G Street
Suite 4164
Davis, CA 95616-4164
Phone: 530/792-5600
Fax: 530/792-5790
Guam
Director, Pacific Basin Area
FHB Building, Suite 301
400 Route 8
Maite, GU 96927
Phone: 671/472-7490
Fax: 671/472-7288
Kansas
760 South Broadway
Salma,KS 67401-4642
Phone: 785/823-4565
Fax: 785/823-4540
Colorado
655 Parfet Street
Room E200C
Lakewood, CO 80215-5517
Phone: 303/236-2886 x202
Fax: 303/236-2896
Hawaii
300 Ala Moana Blvd.
Room 4-118
P.O. Box 50004
Honolulu, HI 96850-0002
Phone: 808/541-2600x100
Fax: 808/541-1335
Kentucky
771 Corporate Drive
Suite 110
Lexington, KY 40503-5479
Phone: 606/224-7350
Fax: 606/224-7399
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Louisiana
3737 Government Street
Alexandria, LA 71302
Phone: 318/473-7751
Fax: 318/473-7626
Mississippi
Suite 1321, Federal Building
100 West Capitol Street
Jackson, MS 39269-1399
Phone: 601/965-5205
Fax: 601/965-4940
New Jersey
13 70 Hamilton Street
Somerset, NJ 08873-3157
Phone: 732/246-1171 Ext. 120
Fax: 732/246-2358
Maine
967 Illinois Avenue
Suite #3
Bangor, ME 04401
Phone: 207/990-9100, Ext. 3
Fax: 207/990-9599
Missouri
Parkade Center, Suite 250
601 Business Loop 70 West
Columbia, MO 65203-2546
Phone: 573/876-0901
Fax: 573/876-0913
New Mexico
6200 Jefferson Street, N.E.
Suite 305
Albuquerque, NM 87109-3734
Phone: 505/761-4400
Fax: 505/761-4462
Maryland
John Hanson Business Center
339 Busch's Frontage Road
Suite 301
Annapolis, MD 21401-5534
Phone: 410/757-0861x314
Fax: 410/757-0687
Montana
Federal Building, Room 443
10 East Babcock Street
Bozeman, MT 59715-4704
Phone: 406/587-6811
Fax: 406/587-6761
New York
441 South Salina Street
Suite 354
Syracuse, NY 13202-2450
Phone: 315/477-6504
Fax: 315/477-6550
Massachusetts
451 West Street
Amherst,MA 01002-2995
Phone: 413/253-4351
Fax: 413/253-4375
Nebraska
Federal Building, Room 152
100 Centennial Mall, North
Lincoln, NE 68508-3866
Phone: 402/437-5300
Fax: 402/437-5327
North Carolina
4405 Bland Road, Suite 205
Raleigh, NC 27609-6293
Phone: 919/873-2102
Fax: 919/873-2156
Michigan
3001 Coolidge Road, Suite 250
East Lansing, MI 48823-6350
Phone: 517/324-5270
Fax: 517/324-5171
Nevada
5301 Longley Lane
Building F, Suite 201
Reno,NV 89511-1805
Phone: 775/784-5863
Fax: 775/784-5939
North Dakota
220 E. Rosser Avenue
Room 278
P.O. Box 1458
Bismarck, ND 58502-1458
Phone: 701/530-2000
Fax: 701/530-2110
Minnesota
375 Jackson Street
Suite 600
St. Paul, MN 55101-1854
Phone: 651/602-7856
Fax: 651/602-7914 or 7915
New Hampshire
Federal Building
2 Madbury Road
Durham, NH 03824-2043
Phone: 603/868-7581
Fax: 603/868-5301
Ohio
200 North High Street
Room 522
Columbus, OH 43215-2478
Phone: 614/255-2472
Fax: 614/255-2548
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Oklahoma
USDA Agri-Center Bldg.
100 USDA, Suite 203
Stillwater, OK 74074-2655
Phone: 405/742-1204
Fax: 405/742-1126
South Dakota
Federal Building, Room 203
200 Fourth Street, S.W.
Huron, SD 57350-2475
Phone: 605/352-1200
Fax: 605/352-1280
Washington
Rock Pointe Tower II
W. 316 Boone Avenue
Suite 450
Spokane, WA 99201-2348
Phone: 509/323-2900
Fax: 509/323-2909
Oregon
101 SW Main Street
Suite 1300
Portland, OR 97204-3221
Phone: 503/414-3201
Fax: 503/414-3277
Tennessee
675 U.S. Courthouse
801 Broadway
Nashville, TN 37203-3878
Phone: 615/227-2531
Fax: 615/277-2578
West Virginia
75 High Street, Room 301
Morgantown, WV 26505
Phone: 304/284-7540
Fax: 304/284-4839
Pennsylvania
1 Credit Union Place, Suite 340
Hamsburg, PA 17110-2993
Phone: 717/237-2212
Fax: 717/237-2238
Texas
W.R. Poage Building
101 South Main Street
Temple, TX 76501-7682
Phone: 254/742-9800
Fax: 254/742-9819
Wisconsin
6515 Watts Road, Suite 200
Madison, WI 53719-2726
Phone: 608/276-8732 x222
Fax: 608/276-5890
Puerto Rico
Director, Caribbean Area
IBM Building, Suite 604
654 Munoz Rivera Avenue
HatoRey,PR 00918-4123
Phone: 787/766-5206 Ext. 237
Fax: 787/766-5987
Utah
W.F. Bennett Federal Building
125 South State Street, Room
4402
Salt Lake City, UT 84138
P.O. Box 11350, SLC,UT
84147-0350
Phone: 801/524-4550
Fax: 801/524-4403
Wyoming
Federal Building, Room 3124
100 East B Street
Casper, WY 82601-1911
Phone: 307/261-6453
Fax: 307/261-6490
Rhode Island
60 Quaker Lane, Suite 46
Warwick, RI 02886-0111
Phone: 401/828-1300
Fax: 401/828-0433
Vermont
69 Union Street
Wmooski, VT 05404-1999
Phone: 802/951-6795
Fax: 802/951-6327
South Carolina
Strom Thurmond Federal Building
1835 Assembly Street, Room 950
Columbia, SC 29201-2489
Phone: 803/253-3935
Fax: 803/253-3670
Virginia
Culpeper Building, Suite 209
1606 Santa Rosa Road
Richmond, VA 23229-5014
Phone: 804/287-1691
Fax: 804/287-1737
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United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/625/R-92/013
Revised October 1999
http://www.epa.gov/ORD/NRMRL
&EPA Environmental
Regulations and
Technology
Control of Pathogens and
Vector Attraction in
Sewage Sludge
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EPA/625/R-92-013
Revised October 1999
Environmental Regulations and Technology
Control of Pathogens and Vector Attraction
in Sewage Sludge
(Including Domestic Septage)
Under 40 CFR Part 503
This guidance was prepared by
U.S. Environmental Protection Agency
Office of Research and Development
National Risk Management Research Laboratory
Center for Environmental Research Information
Cincinnati, OH 45268
Printed on Recycled Paper
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Notice
This report has been reviewed by the U.S. Environmental Protection Agency and approved
for publication. The process alternatives, trade names, or commercial products are only ex-
amples and are not endorsed or recommended by the U.S. Environmental Protection Agency.
Other alternatives may exist or may be developed.
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Foreword
This guidance document was produced by the U.S. Environmental Protection Agency's
(EPA) Pathogen Equivalency Committee (PEC) whose members include Robert Bastian, Bob
Brobst, John Cicmanec, G. Shay Fout, Hugh McKinnon, Mark Meckes, Frank Schaefer, Stephen
Schaub, and James E. (Jim) Smith, Jr. The contributions of Jim Smith, who was instrumental in
the administration, organization, and direction of this project; and of Bob Brobst, Mark Meckes,
and Robert Bastian along with Greg B. Kester of the State of Wisconsin, who provided signifi-
cant comments and guidance, are especially appreciated. Eliot Epstein and Nerissa Wu of E&A
Environmental Consultants, Inc., in Canton, Massachusetts prepared the document with infor-
mation and comments from the PEC and from EPA and State sludge coordinators and private
contributors including Joseph B. Farrell, a consultant, and Robert Reimers of Tulane University.
The assistance of reviewers including John Colletti, Madolyn Dominy, Lauren Fondahl, Alia
Roufaeal, and John Walker of EPA; Jeffrey G. Faust of Bio Gro; Jose Pearce of the State of
North Carolina; Bob Southworth, a consultant; and all other contributors, too numerous to name,
is very much appreciated.
The following individuals assisted by updating guidance for analytical procedures: Appen-
dix F: Sample Preparation for Fecal Coliform Tests and Salmonella sp. Analysis - Mark Meckes;
Appendix H: Method for the Recovery and Assay of Enteroviruses from Sewage Sludge - Shay
Fout; Appendix I: Analytical Method for Viable Helminth Ova - Frank Schaefer; Appendix J:
Composting: Basic Concepts Related to Pathogens and Vector Attraction - Eliot Epstein of E&A
Environmental Consultants and Bob Brobst of EPA's Region 8 Office in Denver, CO.
COVER PHOTOGRAPH: Application of sewage sludge compost to the White House lawn.
in
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Contents
Chapter 1 Introduction 1
1.1 What is Sewage Sludge? 1
1.2 U.S. Regulation of Treated Sewage Sludge (Biosolids) 4
1.3 Implementation Guidance 4
1.4 Definitions 5
1.5 Pathogen Equivalency Committee 6
1.6 What's in this Document? 6
Chapter 2 Sewage Sludge Pathogens 8
2.1 What are Pathogens 8
2.2 Pathogens in Sewage Sludge 8
2.3 General Information on Pathogens 10
2.4 Protecting Public Health-The Part 503 11
2.5 Frequently Asked Questions 16
Chapter 3 Overview of Part 503 Subpart D Requirements, Their Applicability, and Related Requirements 20
3.1 Introduction 20
3.2 Pathogen Reduction Requirements 20
3.3 Vector Attraction Reduction (VAR) Requirements [503.33] 21
3.4 Applicability of the Requirements [503.15 and 503.251 21
3.5 Frequency of Monitoring 22
3.6 Sampling Stockpiled or Remixed Biosolids 22
3.7 Record Keeping Requirements [503.17 and 503.27] 23
3.8 Reporting Requirements for Sewage Sludge [503.18 and 503.281 23
3.9 Permits and Direct Enforceability [503.3] 25
Chapter 4 Class A Pathogen Requirements
4.1 Introduction 26
4.2 Vector Attraction Reduction to Occur With or After Class A Pathogen Reduction [503.32(a)(2)] 28
4.3 Monitoring of Fecal Coliform or Salmonella sp. to Detect Growth of Bacterial Pathogens
[503.32(a)(3)-(8)] 27
4.4 Alternative 1: Thermally Treated Sewage Sludge [503.32(a)(3)] 28
4.5 Alternative 2: Sewage Sludge Treated in a High pH-High Temperature Process (Alkaline
Treatment) [503.32(a)(4)] 30
4.6 Alternative 3: Sewage Sludge Treated in Other Processes [503.32(a)(5)] 31
4 7 Alternative 4: Sewage Sludge Treated in Unknown Processes [503.32(a)(6) 32
4.8 Alternatives: Use of PFRP [503.32(a)(7)] 32
4.9 Alternative 6: Use of a Process Equivalent to PFRP [503.32(a)(8)] 33
4.10 Frequency of Testing 33
Chapter 5 Class B Pathogen Requirements and Requirements for Domestic Septage Applied to Agricultural
Land, a Forest, or a Reclamation Site 36
5.1 Introduction 36
5.2 Sewage Sludge Alternative 1: Monitoring of Fecal Coliform [503.32(b)(2)] 36
5.3 Sewage Sludge Alternative 2: Use of a Process to Significantly Reduce Pathogens [503.32(b)(3)]. 37
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Contents (continued)
5.4 Sewage Sludge Alternative 3: Use of Processes Equivalent to PSRP [503.32(b)(4)] 38
5.5 Site Restrictions for Land Application of Biosolids [503.32(b)(5)] 38
5.6 Domestic Septage [503.32(c)] 41
Chapter 6 Processes to Significantly Reduce Pathogens (PSRPs) 43
6.1 Introduction 43
6.2 Aerobic Digestion 43
6.3 Anaerobic Digestion 45
6.4 Air Drying 46
6.5 Composting 47
6.6 Lime Stabilization 48
6.7 Equivalent Processes
Chapter 7 Processes to Further Reduce Pathogens (PFRPs) 51
7.1 Introduction 51
7.2 Composting 51
7.3 Heat Drying 53
7.4 Heat Treatment 54
7.5 Thermophilic Aerobic Digestion 54
7.6 Beta Ray and Gamma Ray Radiation 55
7.7 Pasteurization 55
7.8 Equivalent Processes 56
Chapter 8 Requirements for Reducing Vector Attraction 58
8.1 Introduction 58
8.2 Option 1: Reduction in Volatile Solids Content [503.32(b)(l)] 58
8.3 Option 2: Additional Digestion of Anaerobically Digested Sewage Sludge [503.32(b)(2)] 60
8.4 Option 3: Additional Digestion of Aerobically Digested Sewage Sludge [503.32(b)(3)] 60
8.5 Option 4: Specific Oxygen Uptake Rate (SOUR) for Aerobically Digested Sewage
Sludge [503.32(b)(4)] 60
8.6 Option 5: Aerobic Processes at Greater than 40°C [503.32(b)(5)] 61
8.7 Option 6: Addition of Alkali [503.32(b)(6)] 61
8.8 Option 7: Moisture Reduction of Sewage Sludge Containing No Unstabilized Solids 62
8.9 Option 8: Moisture Reduction of Sewage Sludge Containing Unstabilized Solids [503.32(b)(8)] 62
8.10 Option 9: Injection [503.32(b)(9)] 62
8.11 Option 10: Incorporation of Sewage Sludge into the Soil [503.32(b)(10)] 63
8.12 Option 11: Covering Sewage Sludge [503.32(b)(11)] 63
8.13 Option 12: Raising the pH of Domestic Sludge [503.32(b)(12)] 63
8.14 Number of Samples and Timing 63
8.15 Vector Attraction Reduction Equivalency 63
Chapter 9 Sampling Procedures and Analytical Methods 65
9.1 Introduction 65
9.2 Laboratory Selection 65
9.3 Safety Precautions 65
9.4 Requirements for Sampling Equipment and Containers 66
9.5 Sampling Frequency and Number of Samples Collected 67
9.6 Sampling Free-Flowing Sewage Sludges 68
9.7 Sampling Thick Sewage Sludges 69
9.8 Sampling Dry Sewage Sludges 69
VI
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Contents (continued)
9.9 Control of Temperature, pH, and Oxygenation After Sample Collection Samples for Microbial
Tests 70
9.10 Sample Compositing and Size Reduction 77
9.11 Packaging and Shipment 72
9.12 Documentation 73
9.13 Analytical Methods 73
9.14 Quality Assurance 74
Chapter 10 Meeting the Quantitative Requirements of the Regulation 76
10.1 Introduction 76
10.2 Process Conditions 76
10.3 Schedule and Duration of Monitoring Events 77
10.4 Comparison of Feed Sludge and Sludge Product Samples 79
10.5 The Effect of Sludge Processing Additives on Monitoring 79
10.6 Collecting Representative Samples 80
10.7 Regulatory Objectives and Number of Samples that Should be Tested 81
Chapter 11 Role of EPA's Pathogen Equivalency Committee in Providing Guidance Under Part 503 90
11 .1 Introduction 90
11.2 Overview of the PEC's Equivalency Recommendation Process 92
11.3 Basis for PEC Equivalency Recommendations 92
11.4 Guidance on Demonstrating Equivalency for PEC Recommendations 97
11.5 Guidance on Application for Equivalency Recommendations 98
11.6 Pathogen Equivalency Committee Recommendations 100
11.7 Current Issues 100
Chapter 12 References and Additional Resources 103
Appendices
A EPA Regional and State Sludge Coordinators, Map of EPA Regions, and listing of EPA Pathogen
Equivalency Members 107
B Subpart D of the Part 503 Regulation.. 116
C Determination of Volatile Solids Reduction by Digestion 121
D Guidance on Three Vector Attraction Reduction Tests 143
E Determination of Residence Time for Anaerobic and Aerobic Digestion 149
F Sample Preparation for Fecal Coliform tests and Salmonella sp. Analysis 153
G Kenner and Clark (1974) Analytical Method for Salmonella sp. Bacteria 157
H Method for the Recovery and Assay of Enteroviruses from Sewage Sludge 158
I Analytical Method for Viable Helminth Ova 174
J The Biosolids Composting Process 181
VII
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Acknowledgements
This guidance document was produced by the U.S. Environmental Protection Agency (EPA's) Pathogen
Equivalency Committee (PEC) whose members include Robert Bastian, Bob Brobst, John Cicmanec, G.
Shay Fout, Hugh McKinnon, Mark Meckes, Frank Schaefer, Stephen Schaub, and James E.(Jim) Smith, Jr.
The contributions of Jim Smith, who was instrumental in the administration, organization, and direction of
this project; and of Bob Brobst, Mark Meckes, and Robert Bastian along with Greg B. Kester of the State of
Wisconsin, who provided significant comments and guidance, are especially appreciated. Eliot Epstein and
Nerissa Wu of E&A Environmental Consultants, Inc. in Canton, Massachusetts prepared the document with
information and comments from the PEC and from EPA and State sludge coordinators and private contribu-
tors including Joseph B. Farrell, a consultant, and Robert Reimers of Tulane University. The assistance of
reviewers including John Colletti, Madolyn Dominy, Lauren Fondahl, Alia Roufaeal, and John Walker of
EPA; Jeffrey G. Faust of Bio Gro; Joe Pearce of the State of North Carolina; Bob Southworth, a consultant;
and all other contributors, too numerous to name, is very much appreciated.
The following individuals assisted by updating guidance for analytical procedures: Appendix F: Sample
Preparation for Fecal Coliform Tests and Salmonella sp. Analysis - Mark Meckes; Appendix H: Method for
the Recovery and Assay of Enteroviruses from Sewage Sludge - Shay Fout; Appendix I: Analytical Method
for Viable Helminth Ova - Frank Schaefer; Appendix J: Composting: Basic Concepts Related to Pathogens
and Vector Attraction - Eliot Epstein of E&A Environmental Consultants and Bob Brobst of EPA's Region 8
Office in Denver, CO.
VIII
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Chapter 1
Introduction
1.1 What Is Sewage Sludge?
Sewage sludge -the residue generated during treatment
of domestic sewage (Figure l-l) - is often used as an or-
ganic soil conditioner and partial fertilizer in the United States
and many other countries. It is applied to agricultural land
(pastures and cropland), disturbed areas (mined lands, con-
struction sites, etc.), plant nurseries, forests, recreational
areas (parks, golf courses, etc.), cemeteries, highway and
airport runway medians, and home lawns and gardens (see
photographs, page 2-3). Certain treatment works (POTWs)
own or have access to land dedicated solely to disposal of
sewage sludge, a practice referred to as surface disposal.
The U.S. Environmental Protection Agency (EPA), the pri-
mary federal agency responsible for sewage sludge man-
agement, encourages the beneficial use of sewage sludge
through land application (Figure 1-2), after it has been ap-
propriately treated for its intended use. In 1995 it was found
that 54% of sewage sludge generated in the United States
was land applied (Bastian, 1997).
Sewage sludge has beneficial plant nutrients and soil
conditioning properties; however, it may also contain patho-
genic bacteria, viruses, protozoa, parasites, and other mi-
Domestic
Sewage
Generation
croorganisms that can cause disease. Land application and
surface disposal of untreated sewage sludge create a po-
tential for human exposure to these organisms through
direct and indirect contact. To protect public health from
these organisms and from the pollutants that some sew-
age sludge contains, many countries now regulate the use
and disposal of sewage sludge.
"Se wage Sludge " v. 'Biosolids "
Throughout the wastewater and sewage sludge indus-
try, the term "sewage sludge" has largely been replaced
by the term "biosolids." "Biosolids" specifically refers to
sewage sludge that has undergone treatment and meets
federal and state standards for beneficial use. The distinc-
tion between untreated sewage sludge and biosolids that
have undergone processing and analysis will be made
throughout this document.
What is Beneficial Use?
For the purposes of this document, land application is
considered to be beneficial use. The document specifically
deals with land application and the issues related to the
pathogen and vector attraction reduction requirements for
Sewage Sludge
Treatment
. Digestion
. Drying
. Composting
. Lime Stabilization
. Heat Treatment
. Etc.
Treated
Sewage I
Sludge f
.(Biosolids)1
Disposal
Industrial
Wastewater
Generation
Incineration
• Surface Disposal
Land Application
. Agricultural Land
. Strip-mined Land
. Forests
• Plant Nurseries
• Cemeteries
. Parks, Gardens
• Lawns and Home
Gardens
Figure l-l. Generation, treatment, use, and disposal of sewage sludge.
-------
Highway median strip in Illionis after land application of dried
sludges. (Photo courtesy of Metropolitan Water Reclamation District of
Greater Chicago)
Flower beds amended with sludge compost in Tulsa, Oklahoma.
(Photo courtesy of City of Tulsa, Oklahoma)
Injection of liquid sludge Into sod.
Oat field showing sludge-treated (right) and untreated (left) areas.
(Photo courtesy of City of Tulsa, Oklahoma)
-------
Reclaimed mine spoil land.
Corn grown on sludge-treated soil (right) and untreated soil (left).
Mine spoil land sludge treatment. Note lush vegetative cover on
reclaimed soil which will support grazing. (Photo courtesy of City of
Tulsa, Oklahoma)
Cross-section of Douglas fir tree showing how sludge application
increases tree growth. Note increased size of outer rings
indicating more rapid growth after sludge application. (Photo
courtesy of Metro Silvigrow)
-------
The U.S. Environmental Protection Agency (EPA)
will actively promote those municipal sludge man-
agement practices that provide for the beneficiai'use
of sewage sludge while maintaining or improving en-
vironmental quality and protecting human health. To
implement this policy, EPA will continue to issue regu-
lations that protect public health and other environ-
mental values.The Agency will require states to es-
tablish and maintain programs to ensure that local
governments utilize sewage sludge management
techniques that are consistent with federal and state
regulations and guidelines. Local communities will
, remain responsible for choosing" among alternative
prpgrams;forplanning,coristructing, and operating
facilities to meet their needs: and for ensuring the
continuing availability of adequate and acceptable
disposal or use capacity.
Figure 1-2. EPA policy on sewage sludge management. Source:
EPA, 1984.
land applied biosolids. For more information on the patho-
gen and vector attraction reduction requirements for the
surface disposal of biosolids, please refer to Section 503.25
of the regulation.
1.2 U.S. Regulation of Treated Sewage
Sludge (Biosolids)
In the United States, the use and disposal of treated
sewage sludge (biosolids), including domestic septage, are
regulated under 40 CFR Part 5031. This regulation, pro-
mulgated on February 19, 1993, was issued under the
authority of the Clean Water Act (CWA) as amended in
1977 and the 1976 Resource Conservation and Recovery
Act (RCRA). For most sewage sludge2, the new regulation
replaces 40 CFR 257, the original regulation governing
the use and disposal of sewage sludge, which has been in
effect since 1979.
The EPA policy shown below was developed in response
to specific language in the CWA and RCRA federal policy
statements in order to facilitate and encourage the benefi-
cial reuse of sewage sludge (U.S. EPA, 1984).
Protection of Public Health and the
Environment
Subpart D of the Part 503 regulation protects public
health and the environment through requirements designed
to reduce the potential for contact with the disease-bear-
ing microorganisms (pathogens) in sewage sludge applied
to the land or placed on a surface disposal site. These
requirements are divided into:
. Requirements designed to control and reduce patho-
gens in treated sewage sludge (biosolids)
. Requirements designed to reduce the ability of the
treated sewage sludge (biosolids) to attract vectors
(insects and other living organisms that can transport
biosolids pathogens away from the land application or
surface disposal site)
Subpart D includes both performance and technology
based requirements. It is designed to provide a more flex-
ible approach than the approach in the Part 257, which
required sewage sludge to be treated by specific listed or
approved treatment technologies. Under Part 503, treat-
ment works may continue to use the same processes they
used under Part 257, but they now also have the freedom
to modify conditions and combine processes with each
other, as long as the applicable Part 503 requirements are
met.
Environmental Effects of Pathogens in
Sewage Sludge
Because of concern over the effect of pathogens from
biosolids on animal health (certain human pathogens can
cross species lines and infect animals, particularly warm
blooded animals) the 503 regulations require that sewage
sludge undergo pathogen treatment prior to land applica-
tion. For sewage sludge subject to Class Be pathogen treat-
ment site restrictions are also required. While relatively
little research has been conducted on specific inter-spe-
cies crossover to wildlife, more information is available for
grazing animals which are more likely to have a greater
exposure to biosolids than wildlife. Available information
on the impact of biosolids pathogens on grazing animals
suggests that the Part 503 Subpart D requirements for
pathogen control (which include restrictions on grazing)
protect grazing animals (EPA, 1992). References regard-
ing the impact of biosolids application on both wild and
domestic animals are included at the end of this chapter.
1.3 Implementation Guidance
This document is not regulatory in nature. A complete
copy of Subpart D of the Part 503 Regulation appears in
Appendix B. This document is only intended to serves as
a guide to pathogen and vector attraction reduction for
anyone who is involved with the treatment of sewage sludge
for land application. This includes:
. Owners and operators of domestic sewage
works
treatment
'Because domestic septage is a form of sewage sludge, any use of the term "sew-
age sludge" in this document includes domestic septage.
2Sewage sludge generated at an industrial facility during the treatment of domestic
sewage commingled with industrial waslewater in an industrial wastewater treat-
ment facility is still covered under 40 CFR Part 257 if the sewage slude is applied to
the land.
. Developers or marketers of sewage sludge treatment
processes
. Groups that distribute and market biosolids products
. Individuals involved in applying biosolids to land
. Regional, state, and local government officials respon-
sible for implementing and enforcing the Part 503 Sub-
part D regulation
-------
. Consultants to these groups
. Anyone interested in understanding the federal require-
ments concerning pathogens in sewage sludge
This guide was previously released in 1993. The updates
and amendments to this document are a product of com-
ments and suggestions from the regulatory and sewage
sludge management community. This edition of the docu-
ment includes clarification of many of the sampling and
monitoring issues and reflects the increased understand-
ing of analytical issues. There are additional operational
guidelines and examples of how a variety of facilities have
complied with the Part 503 requirements. Some of the
notable additions to this edition include:
• Clarification of Class A processes
• More specific guidelines for the operation of
composting facilities
• More information on site restrictions including permit
conditions which may apply to specific crops
• Recommendation for the use of the Kenner and Clark
methodology for Salmonella sp . bacteria analysis
• Guidelines for retesting biosolids products that have
been stored or remixed
• More information on public health and pathogens
• More information on sampling and monitoring proto-
cols
• Updates on the Pathogen Equivalency Committee and
approved processes
Other publications related to pathogen or vector attrac-
tion issues include the "Technical Support Document for
Reduction of Pathogens and Vector Attraction in Sewage
Sludge" (U.S. EPA, 1992) and "Part 503 Implementation
Guidance" (U.S. EPA, 1995). Although the federal regula-
tion under 40 CFR Part 503 includes restrictions for pollut-
ant concentrations and application rates, this document is
intended to clarify pathogen and vector related require-
ments and does not discuss pollutant limits.
This document does not discuss the general require-
ments and management practices which must be followed
for land application of all biosolids except in the case of
"exceptional quality" biosolids which have met certain pol-
lutant limits and pathogen and vector attraction reduction
requirements. In addition to meeting the regulation set forth
in this document, bulk biosolids application must be con-
ducted in accordance with agronomic rates, and biosolids
appliers must ensure that applied biosolids are not applied
within 10 meters of any water body, do not enter surface
waters or wetlands without the approval of the appropriate
permitting authority, and do not adversely affect endan-
gered or threatened species or their habitats.
It should be noted that the Part 503 regulation and the
sampling and monitoring requirements outlined in the regu-
lation were developed as minimum requirements. EPA
supports the beneficial use of treated sewage sludge
(biosolids) and encourages facility operators and genera-
tors of biosolids products to develop sampling and moni-
toring plans that go beyond the minimum regulatory re-
quirements as needed to ensure consistent product qual-
ity.
For most states, the authority for implementing the Part
503 regulation currently remains with the Regional EPA
offices. A guide to EPA offices and relevant contacts can
be found in Appendix A.
1.4 Definitions
The sections of this document that discuss specific regu-
latory requirements utilize the same terminology used
throughout the Part 503 regulation in order to maintain
consistency between the regulation and this guidance
document. However, in some parts of this document, par-
ticularly in sections which discuss operational parameters
and other issues related to biosolids management, terms
which are not formally defined by the regulations are used.
The following glossary has been provided in order to pre-
vent confusion about the intent and jurisdiction of the Part
503 regulation.
Applier - The applier is the individual or party who land
applies treated sewage sludge (biosolids). This may in-
clude farmers, municipalities, and private enterprises that
land apply or their contractors.
Biosolids - Sewage sludge that has been treated and
meets state and federal standards for land application.
Control - Some of the regulatory requirements make a
distinction based on whether the biosolids preparer (see
below) has "control" over the material. A preparer loses
control over material when it is sold or given away. Until
that point, the material is still within the control of the
preparer even if the treatment process has ended and the
material is in storage on or off-site.
Detectable Limits - Minimum concentration at which
an analyte can be measured. The detectable limit for any
given analyte varies depending on the lab methodology
used and the volume of material analyzed. As such, de-
tectable limits may fluctuate. Throughout this document,
the term "detectable limit" refers to the limits as they are
defined in the allowable lab methodologies outlined in the
Appendices.
Exceptional Quality (EQ) Biosolids - The term "EQ" is
not used in the Part 503 regulation, but it has become a
useful description for regulators and biosolids preparers
when referring to biosolids that meet the pollutant concen-
tration limits of Table 3 of Section 503.13, Class A patho-
gen reduction, and one of the first eight treatment pro-
cesses for meeting vector attraction reduction standards.
Biosolids that fall into this category are not subject to the
Part 503 general requirements and management practices
for land application.
-------
Preparer - The person(s) who generate biosolids from
the treatment of domestic sewage in a treatment works or
change the quality of the sewage sludge received from
the generator. This includes facilities that derive a material
from sewage sludge prior to land application of the mate-
rial which could include wastewater treatment facilities,
composting or other sewage sludge processing operations,
and soil blenders who handle non-EQ biosolids materials.
A soil blender who takes EQ biosolids and mixes them
with other (non-sewage sludge) materials for land applica-
tion is not a preparer. However, a soil blender that takes
non-EQ biosolids and mixes it with other materials for land
application is a preparer.
Product - This may include materials such as
composted, heat-dried, lime stabilized, alkaline stabilized,
or otherwise processed biosolids which have met the re-
quirements of the Part 503. The term "product" is some-
times used in this document in discussions regarding ma-
terial distribution. The term "sludge derived material" is used
in the Part 503 to refer to these materials.
Sewage Sludge - The solid, semi-solid, or liquid resi-
due generated during the treatment of municipal sewage
in a treatment works. The term "biosolids" refers to sew-
age sludge which has undergone treatment and meets
state and federal requirements for land application. The
distinction between untreated sewage sludge and treated
biosolids is made throughout this document.
1.5 Pathogen Equivalency Committee
The Pathogen Equivalency Committee (PEC) is made
up of U.S. EPA experts who review pathogen and vector
attraction reduction issues and make recommendations
to the appropriate permitting authority. The primary role of
the PEC is to review proposals for Processes to Signifi-
cantly Reduce Pathogens (PSRP) and Processes to Fur-
ther Reduce Pathogens (PFRP) equivalency determina-
tions and to offer guidance on the issues associated with
pathogen and vector attraction reduction.
More information on the PEC and the process of apply-
ing for equivalency is presented in Chapter 11.
1.6 What's in this Document?
Chapter 2 of this document provides basic information
about pathogens and describes why pathogen control is
required to protect public health and the environment, and
Chapters 3 through 5 discuss the current federal require-
ments under Subpart D of Part 503. Chapters 6 and 7 re-
view the different PFRP and PSRP processes, and Chap-
ter 8 discusses vector attraction reduction issues. Chap-
ters 9 and 10 summarize sampling and analysis protocols
used to meet the quantitative requirements of Part 503.
Chapter 11 outlines the process for applying for equiva-
lency and discusses the kind of support EPA's Pathogen
Equivalency Committee can provide to permitting authori-
ties. Chapter 12 lists general references and additional
resources related to biosolids use; specific references re-
lated to particular topics are also included at the end of
each chapter.
The Appendices provide additional information on:
. Determination of volatile solids and residence time for
digestion
. Sample preparation and analytical methods for meet-
ing the Part 503 pathogen reduction requirements
. Tests for demonstrating vector attraction reduction
. Additional references on pathogen research and tech-
nical background to regulations
Appendix A lists EPA and state sewage sludge coordi-
nators, and Appendix B contains Subpart D of the Part
503 regulation.
References and Additional Resources
Alberici, T.M., W.E. Sopper, G.L. Storm, and R.H. Yahner.
1989. Trace metals in soil, vegetation, and voles from
mine land treated with sewage sludge. Journal of En-
vironmental Quality 18:115-1 20.
Anderson, T.J., and G.W. Barrett. 1982. Effects of dried
sewage sludge on meadow vole (Microtus
pennsylvanicus) populations in two grassland commu-
nities. Journal of Applied Ecology 19:759-772.
Bastian, R.K. 1997. The biosolids (sludge) treatment, ben-
eficial use, and disposal situation in the USA. Euro-
pean Water Pollution Control Journal, Vol 7, No. 2,
62-79.
Danron, B.L., H.R. Wilson, M.F. Hall, W.L. Johnson,
O.Osuna, R.L. Suber, and G.T. Edds. 1982. Effects of
feeding dried municipal sludge to broiler type chicks
and laying hens. Polut. Sci. 61 :1073-1 081.
Hegstrom, L.J. and S.D. West. Heavy metal accumulation
in small mammals following sewage sludge applica-
tion to forests. Journal of Environmental Quality 18:345.
Keinholz, E.W. 1980. Effects of toxic chemicals present in
sewage sludge on animal health. P 153-1 71 in Sludge
- Health risks of land application. Ann Arbor Science
Publishers.
Keinholz, E.W., G.M. Ward, D.E. Johnson, J. Baxter, G.
Braude, and G. Stern. 1979. Metropolitan Denver
sludge fed to feedlot steers. J. Anim. Sci. 48:735-741.
National Research Council. 1996. Use of reclaimed water
and sludge in food crop production. Washington, D.C.
U.S. EPA/USDA/FDA. 1981. Land Application of Munici-
pal Sewage Sludge for the Production of Fruits and
Vegetables; A Statement of Federal Policy and Guid-
ance. SW-905. U.S. EPA, Office of Solid Waste, Wash-
ington, D.C. 21 pp.
U.S. EPA. 1984. EPA policy on municipal sludge manage-
ment. Federal Register, 49(114):24358-24359. June
12, 1984.
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U.S. EPA. 1991. Interagency Policy on beneficial use of 136618. Springfield, VA: National Technical Infor-
municipal sewage sludge on federal land. Federal mation Service.
Register, 56(138):33186-33188. July 19, 1991.
U.S. EPA. 1995. Part 503 implementation guidance. EPA
U.S. EPA. 1992. Technical support document tor Part 833-R-95-001. Washington, D.C.
503 pathogen and vector attraction reduction re-
quirements in sewage sludge. NTIS No.: PB89- WEF/U.S. EPA. 1997. Biosolids: A short explanation and dis-
cussion. In Biosolids Fact Sheet Project.
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Chapter 2
Sewage Sludge Pathogens
2.1 What are Pathogens?
A pathogen is an organism or substance capable of caus-
ing disease. The Part 503 regulation only discusses patho-
genic organisms, and throughout this document, "patho-
gen" refers only to living organisms, except where speci-
fied. Pathogens infect humans through several different
pathways including ingestion, inhalation, and dermal con-
tact. The infective dose, or the number of a pathogenic
organism to which a human must be exposed to become
infected, varies depending on the organism and on the
health status of the exposed individual.
Pathogens that propagate in the enteric or urinary sys-
tems of humans and are discharged in feces or urine pose
the greatest risk to public health with regard to the use and
disposal of sewage sludge. Pathogens are also found in
the urinary and enteric systems of other animals and may
propagate in non-enteric settings. However, because this
document is concerned with the regulation of sewage
sludge, this chapter focuses on the pathogens most com-
monly found in the human enteric system.
2.2 Pathogens in Sewage Sludge
What pathogens can be found in sewage
sludge?
The four major types of human pathogenic (disease-
causing) organisms (bacteria, viruses, protozoa, and hel-
minths) all may be present in domestic sewage. The ac-
tual species and quantity of pathogens present in the do-
mestic sewage from a particular municipality (and the sew-
age sludge produced when treating the domestic sewage)
depend on the health status of the local community and
may vary substantially at different times. The level of patho-
gens present in treated sewage sludge (biosolids) also
depends on the reductions achieved by the wastewater
and sewage sludge treatment processes.
The pathogens in domestic sewage are primarily asso-
ciated with insoluble solids. Primary wastewater treatment
processes concentrate these solids into sewage sludge,
so untreated or raw primary sewage sludges have higher
quantities of pathogens than the incoming wastewater.
Biological wastewater treatment processes such as la-
goons, trickling filters, and activated sludge treatment may
substantially reduce the number of pathogens in the waste-
water (EPA, 1989). These processes may also reduce the
number of pathogens in sewage sludge by creating ad-
verse conditions for pathogen survival.
Nevertheless, the resulting biological sewage sludges
may still contain sufficient levels of pathogens to pose a
public health and environmental concern. Part 503 Regu-
lation thus requires sewage sludge to be treated by a Class
A pathogen treatment process or a Class B process with
site restrictions. These requirements prevent disease trans-
mission. Table 2-I lists some principal pathogens of con-
cern that may be present in wastewater and sewage
sludge. These organisms and other pathogens can cause
infection or disease if humans and animals are exposed to
sufficient levels of the organisms or pathogens. The lev-
els, called infectious doses, vary for each pathogen and
each host.
As mentioned in Chapter 1, one concern is the potential
effect of some human pathogens on animals. Enteric vi-
ruses can cross species lines, and animal life, particularly
warm blooded animals, can be affected if they are exposed
to some of the pathogens found in sewage sludge. Do-
mestic animals are protected by site restrictions which limit
grazing on sludge amended land.
How could exposure to these pathogens
occur?
If improperly treated sewage sludge was illegally applied
to land or placed on a surface disposal site, humans and
animals could be exposed to pathogens directly by com-
ing into contact with the sewage sludge, or indirectly by
consuming drinking water or food contaminated by sew-
age sludge pathogens. Insects, birds, rodents, and even
farm workers could contribute to these exposure routes by
transporting sewage sludge and sewage sludge pathogens
away from the site. Potential routes of exposure include:
Direct Contact
. Touching the sewage sludge.
. Walking through an area - such as a field, forest, or
reclamation area - shortly after sewage sludge appli-
cation.
. Handling soil from fields where sewage sludge has
been applied.
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Table 2-1. Principal Pathogens of Concern in domestic Sewage and
Sewage Sludge
Organism
Disease/Symptoms
Bacteria
Salmonella sp.
typhoid fever
Shigella sp.
Yersinia s p.
diarrhea, abdominal pain)
Vibrio cholerae
Campylobacter jejuni
Escherichia coli
(pathogenic strains)
Enteric Viruses
Hepatitis A virus
Norwalk and
Norwalk-like viruses
Rotaviruses
diarrhea
Enteroviruses
Polioviruses
Coxsackieviruses
Echoviruses
Heovirus
Astroviruses
Caliciviruses
Protozoa
Cryptosporidium
Entamoeba histolytica
Giardia lamblia
Balantidium co/i
Toxoplasma gondii
Helminth Worms
Ascaris lumbricoides
Ascaris suum
Trichuris trichiura
Toxocara canis
Taenia saginata
Taenia solium
Necator americanus
Hymenolepis nana
Salmonellosis (food poisoning),
Bacillary dysentery
Acute gastroenteritis (including
Cholera
Gastroenteritis
Gastroenteritis
Infectious hepatitis
Epidemic gastroenteritis with severe
diarrhea
Acute gastroenteritis with severe
Poliomyelitis
Meningitis, pneumonia, hepatitis,
fever, cold-like symptoms, etc.
Meningitis, paralysis, encephalitis,
fever, cold-like symptoms, diarrhea, etc.
Respiratory infections, gastroenteritis
Epidemic gastroenteritis
Epidemic gastroenteritis
Gastroenteritis
Acute enteritis
Giardiasis (including diarrhea, abdomi
nal cramps.weight loss)
Diarrhea and dysentery
Toxoplasmosis
Digestive and nutritional disturbances,
abdominal pain, vomiting, restlessness
May produce symptoms such as
coughing, chest pain, and fever
Abdominal pain, diarrhea, anemia,
weight loss
Fever, abdominal discomfort, muscle
aches, neurological symptoms
Nervousness, insommia, anorexia,
abdominal pain, digestive disturbances
Nervousness, insomnia, anorexia,
abdominal pain, digestive disturbances
Hookworm disease
Taeniasis
Source: Kowal (1985) and EPA (1989).
. Inhaling microbes that become airborne (via aerosols,
dust, etc.) during sewage sludge spreading or by strong
winds, plowing, or cultivating the soil after application.
Indirect Contact
. Consumption of pathogen-contaminated crops grown
on sewage sludge-amended soil or of other food prod-
ucts that have been contaminated by contact with these
crops or field workers, etc.
. Consumption of pathogen-contaminated milk or other
food products from animals contaminated by grazing
in pastures or fed crops grown on sewage sludge-
amended fields.
. Ingestion of drinking water or recreational waters con-
taminated by runoff from nearby land application sites
or by organisms from sewage sludge migrating into
ground-water aquifers.
. Consumption of inadequately cooked or uncooked
pathogen-contaminated fish from water contaminated
by runoff from a nearby sewage sludge application site.
. Contact with sewage sludge or pathogens transported
away from the land application or surface disposal site
by rodents, insects, or other vectors, including graz-
ing animals or pets.
The purpose of the Part 503 regulation is to place barri-
ers in the pathway of exposure either by reducing the num-
ber of pathogens in the treated sewage sludge (biosolids)
to below detectable limits, in the case.of Class A treat-
ment, or, in the case of Class B treatment, by preventing
direct or indirect contact with any pathogens possibly
present in the biosolids.
Each potential pathway has been studied to determine
how the potential for public health risk can be alleviated.
The references listed at the end of this chapter include
some of the technical writings which summarize the re-
search on which the Part 503 regulation is based.
For example, the potential for public health impacts via
inhalation of airborne pathogens was examined. Patho-
gens may become airborne via the spray of liquid biosolids
from a splash plate or high-pressure hose, or in fine par-
ticulate dissemination as dewatered biosolids are applied
or incorporated. While high-pressure spray applications
may result in some aerosolization of pathogens, this type
of equipment is generally used on large, remote sites such
as forests, where the impact on the public is minimal. Fine
particulates created by the application of dewatered
biosolids or the incorporation of biosolids into soil may
cause very localized fine particulate/dusty conditions, but
particles in dewatered biosolids are too large to travel far,
and the fine patticulates do not spread beyond the imme-
diate area. The activity of applying and incorporating
biosolids may create dusty conditions. However, the
biosolids are moist materials and do not add to the dusty
conditions, and by the time biosolids have dried sufficiently
to create fine particulates, the pathogens have been re-
duced (Yeager & Ward, 1981)
The study of each pathway and the potential for public
health risk resulted in site restrictions that are protective of
public health and the environment and that must be fol-
lowed when Class B biosolids are land applied. While the
site restrictions provided in the Part 503 rule are sufficient
to protect the public from health impacts, workers exposed
to Class B biosolids might benefit from several additional
precautions. For example, dust masks should be worn for
the spreading of dry materials, and workers should wash
-------
their hands carefully after working with sewage sludge or
biosolids. Other recommended practices for workers han-
dling biosolids or sewage sludge include:
. Wash hands before eating, drinking, smoking or using
the restroom.
. Use gloves when touching biosolids or sewage sludge
or surfaces exposed to biosolids or sewage sludge.
. Remove excess sewage sludge or biosolids from
shoes prior to entering an enclosed vehicle.
. Keep wounds covered with clean, dry bandages.
. If contact with biosolids or sewage sludge occurs, wash
contact area thoroughly with soap and water.
Table 2-2 shows the various pathways of exposure and
how the process requirements and site restrictions of the
Part 503 regulation protect public health for each path-
way.
2.3 General Information on Pathogens
The EPA has attempted, through this and other docu-
ments, to provide the public with a broad understanding of
the risk assessment and scientific basis of the Part 503
regulation. The regulation is based on the results of exten-
sive research and experience with land application of
treated sewage sludge (biosolids). However, as for all regu-
lations, proper interpretation and implementation of the
regulation are the most important aspects of protecting
public health and the environment.
Biosolids preparers should have a basic knowledge of
microbiology so that they can:
. Understand the goals of the Part 503 regulation and
what is expected to meet the requirements
. Address questions regarding pathogens and the pro-
tection of public health and the environment
. Design appropriate testing/sampling programs to meet
the Part 503 requirements
. Make informed decisions about laboratory and ana-
lytical methodology selection
This section outlines some of the generic issues of patho-
gen testing and quantification. References related to these
issues are listed at the end of this chapter as well as in
Chapter 12. Other chapters discuss sampling and sample
preservation as well as meeting the Part 503 requirements
in more detail.
Survivability of Pathogens
Wastewater generally contains significantly high concen-
trations of pathogens which may enter the wastewater sys-
tem from industries, hospitals, and infected individuals. The
wastewater treatment process tends to remove pathogens
from the treated wastewater, thereby concentrating the
Table 2-2. Pathways of Exposure and Applicable Site Restrictions
(Class B Biosolids Only)
Pathways
Part 503 Required Site Restriction
Handling soil from fields where
sewage sludge has been applied
Handling soil or food from home
gardens where sewage sludge
has been applied
Inhaling dust"
Walking through fields where
sewage sludge has been
applied"
Consumption of crops from fields
on which sewage sludge has
been applied
Consumption of milk or animal
products from animals grazed on
fields where sewage sludge has
been applied
Ingestion of water contaminated
by runoff from fields where
sewage sludge has been applied
from biosolids amended land from
affecting surface water.
Ingestion of inadequately cooked
fish from water contaminated by
runoff from fields where sewage
sludge has been applied
affecting surface water.
Contact with vectors which have
been in contact with sewage
sludge
No publis access* to application
sites until at least 1 year after
Class B biosolids application.
Class B biosolids may not be
applied on home gardens.
No public access to application
sites until at least 1 year after
Class B biosolids application.
No public access to fields until at
least 1 year after Class B biosolids
application.
Site restrictions which prevent the
harvesting of crops until environ-
mental attenuation has taken
place.
No animal grazing for 30 days after
Class B biosolids have been
applied.
Class B biosolids may not be
applied within 10 meters of any
waters in order to prevent runoff
Class B biosolids may not be
applied with 10 meters of any
waters in order to prevent runoff
from biosolids amended land from
All land applied biosolids must
meet one of the Vector Attraction
Reduction options (see Chapter 8).
'Public access restrictions do not apply to farm workers. If there is low
probability of public exposure to an application site, the public access
restrictions apply for only 30 days. However, application sites which
are likely to be accessed by the public, such as ballfields, are subject
to 1 year public access restric tions.
"Agricultural land is private property and not considered to have a
high potential for public access. Nonetheless, public access restrictions
still are applied.
pathogens in the sewage sludge. Like any other living or-
ganisms, pathogens thrive only under certain conditions.
Outside of these set conditions, survivability decreases.
Each pathogen species has different tolerance to different
conditions; pathogen reduction requirements are therefore
based on the need to reduce all pathogenic populations.
Some of the factors which influence the survival of patho-
gens include pH, temperature, competition from other mi-
croorganisms, sunlight, contact with host organisms, proper
nutrients, and moisture level.
The various Class A and Class B pathogen reduction
processes as well as the site restrictions for the land appli-
10
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cation of Class B biosolids are based on research regard-
ing the survivability of pathogens under specific treatment
conditions. Table 2-3 shows a comparison of the survival
of bacteria, viruses, and parasites in different sewage
sludge treatments. Table 2-4 shows the survival time of
various pathogens on soil or plant surfaces after land ap-
plication of biosolids.
Iden tification of Pathogens
Some of the pathogens of concern that appear in do-
mestic sewage and sewage sludge are shown in the pho-
tographs on pages 12 and 13. These include ascarids (/4s-
caris lumbricoides and Toxacara), whipworms (Trichuris
sp.), tapeworms (Hymenolepis sp. and Taenia sp.), amoeba
(Entamoeba coli), and giardia (Giardia lamblia). As shown
in these photographs, several color staining procedures
are needed to identify the organisms and the different struc-
tures within the organisms. The photograph of Giardia
lamblia depicts specimens stained with Lugol's iodine so-
lution, showing two nuclei, a median body, and axonemes
in each. In addition, scientists use a blue filter when pho-
tographing the pathogenic organisms through a micro-
scope. This filter is necessary to show the natural color of
the organisms.
What Units are Used to Measure
Pathogens?
Density of microorganisms in Part 503 is defined as num-
ber of microorganisms per unit mass of total so/ids (dry
Table 2-3. Summary of the Effects of Sewage Sludge Treatment on
Pathogens (Log Reductions Shown)
PSRP Treatment Bacteria Viruses Parasites (protozoa and
helminths)
Anaerobic Digestion
Aerobic Digestion
Composting (PSRP)
Air Drying
Lime Stabilization
0.5-4.0
054.0
2.0-4.0
0.5-4.0
0.5-4.0
0.5-2.0
0.5-2.0
2.0-4.0
0.5-4.0
4.0
0.5
0.5
2.0-4.0
0.5-4.0
0.5
'A l-log reduction (lo-fold) is equal to a 90% reduction. Class B
processes are based on a 2-log reduction.
Table 2-4. Survival Times of Pathogens in Soil and on Plant Surfaces3
Pathogen
Bacteria
Viruses
Protozoan cysts"
Helminth ova
Soil
Absolute
Maximum3
1 year
1 year*
10 days
7 years
Common
Maximum
2 months
3 months
2 days
2 years
Plants
Absolute Common
Maximum11 Maximum
6 months
2 months
5 days
5 months
1 month
1 month
2 days
1 month
"For survival rates, see Sorber and Moore (1986).
bAbsolute maximum survival times are possible under unusual
conditions such as consistently low temperatures or highly sheltered
conditions (e.g., helminth ova below the soil in fallow fields) (Kowal,
1985).
cLittle, if any, data are available on the survival times of Giardia cysts
and Cryptosporidium oocysts.
Source: Kowal, 1985.
weight). Ordinarily, microorganism densities are determined
as number per 100 milliliters of wastewater or sewage
sludge. While the use of units of volume is sensible for
wastewater, it is less sensible for sewage sludge. Many
microorganisms in sewage sludge are associated with the
solid phase. When sewage sludge is diluted, thickened, or
filtered, the number of microorganisms per unit volume
changes markedly, whereas the number per unit mass of
solids remains almost constant. This argues for reporting
their densities as the number present per unit mass of sol-
ids, which requires that sewage sludge solids content al-
ways be determined when measuring microorganism den-
sities.
A second reason for reporting densities per unit mass of
total solids is that biosolids application to the land is typi-
cally measured and controlled in units of mass of dry sol-
ids per unit area of land. If pathogen densities are mea-
sured as numbers per unit mass of total solids, the rate of
pathogen application to the land is directly proportional to
the mass of dry biosolids applied.
Different Methods for Counting
Microorganisms
The methods and units used to count microorganisms
vary depending on the type of microorganism. Viable hel-
minth ova are observed and counted as individuals (num-
bers) under a microscope. Viruses are usually counted in
plaque-forming units (PFU). Each PFU represents an in-
fection zone where a single infectious virus has invaded
and infected a layer of animal cells. For bacteria, the count
is in colony-forming units (CFU) or most probable number
(MPN). CFU is a count of colonies on an agar plate or filter
disk. Because a colony might have originated from a clump
of bacteria instead of an individual, the count is not neces-
sarily a count of separate individuals. MPN is a statistical
estimate of numbers in a sample. The sample is diluted at
least once into tubes containing nutrient medium. The tubes
are maintained under conditions favorable for bacterial
growth. The original bacterial density in the sample is esti-
mated based on the number of tubes that show growth
and the level of dilution in those tubes.
Part 503 Density limits
Under Part 503, the density limits for the pathogens are
expressed as numbers of PFUs, CFUs, or MPNs per 4
grams dry weight sewage sludge. This terminology came
about because most of the tests started with 100 ml of
sewage sludge which typically contained 4 grams of sew-
age sludge solids. Also, expressing the limits on a "per
gram" basis would have required the use of fractions (i.e.,
0.25/g or 0.75/g). Density limits for fecal coliforms, the in-
dicator organisms, however, are given on a "per gram" basis
because these organisms are much more numerous than
pathogens.
2.4 Protecting Public Health -The Part 503
The Part 503 regulation protects public health by limit-
ing the potential for public exposure to pathogens. This is
-------
Ascaris lumbricoldes (or var. suum) eggs, 66 pm, from anaerobically
digested sludge. Two-cell stage. (Photos on this page courtesy of Fox et
al., 1981)
Toxocara sp. egg, 90 urn, from raw sewage.
Ascaris lumbricoldes (or var. suum) eggs, 65 pm, from
anaerobically digested sludge.
Trichuris sp. egg, 60 urn, from anaerobically digested sludge.
12
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Taenia sp. ovum. (Photo courtesy of Fox et al., 1981)
Hymenolepis (tapeworm) ova. (Photo courtesy of Fox et al., 1981)
!' '",' "" • , -';"'"'>',-"•;'•'•' ^'.V'^V.Vi'^, * :,^"'-, ^ •' ' '
Giardla lamblla cysts. (Photo courtesy of Frank Schaefer, U.S. EPA,
National Risk Management Research Laboratory, Cincinnati, Ohio)
Preparing compost for pathogen analysis. (Photo courtesy of U.S.
Department of Agriculture, Beltsville, Maryland)
Entamoeba coll cysts, 15pm, from anaeroblcally digested sludge.
(Photo courtesy of Fox et al., 1981)
13
-------
accomplished through treatment of the sewage sludge or
through a combination of sewage sludge treatment and
restrictions on the land application site that prevent expo-
sure to the pathogens in the biosolids and allow time for
the environment to reduce the pathogens to below detect-
able levels. The Part 503 vector attraction reduction re-
quirements also help reduce the spread of pathogens by
birds, insects, and other disease carriers (i.e. vectors) by
requiring that all sewage sludge that is to be land applied
undergo vector attraction reduction.
The Part 503 regulation also establishes the analytical
protocol for pathogen analysis. More information on the
quantification of pathogens and how pathogen reduction
is measured is included in Chapter 10 and in the Appendi-
ces.
Reducing the Number of Pathogens
Pathogen reduction can be achieved by treating sew-
age sludge prior to use or disposal-and through environ-
mental attenuation. Many sewage sludge treatment pro-
cesses are available that use a variety of approaches to
reduce pathogens and alter the sewage sludge so that it
becomes a less effective medium for microbial growth and
vector attraction (Table 2-5). Processes vary significantly
in their effectiveness. For example, some processes (e.g.
lime stabilization) may effectively reduce bacteria and vi-
ruses but have little or no effect on helminth eggs. The
effectiveness of a particular process can also vary depend-
ing on the conditions under which it is operated. For ex-
ample, the length of time and the temperature to which
sewage sludge is heated is critical to the effectiveness of
heat-based treatment processes.
Part 503 lists sewage sludge treatment technologies that
are judged to produce biosolids with pathogens sufficiently
reduced to protect public health and the environment. The
regulation also allows the use of any other technologies
that produce biosolids with adequately reduced pathogens
as demonstrated through microbiological monitoring. The
Part 503 establishes two classifications of biosolids based
on the level of pathogen reduction the biosolids have un-
dergone. Class A biosolids are treated to the point at which
pathogens are no longer detectable. For Class B biosolids,
a combination of treatment and site restrictions are de-
signed to protect public health and environment.
Monitoring Indicator Species
Sewage sludge may contain numerous species of patho-
genic organisms, and analyzing for each species is not
practical. The microbiological requirements of the Part 503
are therefore based on the use of an indicator organism
for the possible presence of pathological bacteria and both
the representative and the hardiest of known species for
viruses and helminths to represent the larger set of patho-
genic organisms. The indicator and representative organ-
Table 2-5. General Approaches to Controlling Pathogens and Vector Attraction in Sewage Sludge
Approach Effectiveness
Process Example9
Applicatioin of high temperatures (temperatures
may be generated by chemical, biological, or
physical processes).
Application of radiation
Application of chemica disinfectants
Reduction of the sewage sludge's volatile
organic content (the microbial food source).
Removal of moisture from the sludge
Depends on time and temperature. Sufficient
temperatures maintained for sufficiently long
time periods can reduce bacteria, viruses,
protozoan cysts, and helminth ova to below
detectable levels. Helminth ova are the most
resistant to high temperatures.
Depends on dose. Sufficient doses can reduce
bacteria, viruses, protozoan cysts, and
helminth ova to below detectable levels.
Viruses are most resistant to radiation.
Substantially reduces bacteria and viruses
and vector attraction. Probably reduces
protozoan cysts. Does not effectively reduce
helminth ova unless combined with heat.
Reduces bacteria. Reduces vector attraction.
Reduces viruses and bacteria. Reduces
vector attraction as long as the sewage sludge
remains dry. Probably effective in destroying
protozoan cysts. Does not effectively reduce
helminth ova unless combined with other
processes such as high temperature.
Composting (using biological processes to
generate heat). Heat drying and heat treat-
ment (use physical processes to generate
heat, e.g., hot gasses, heat exchangers)
Pasteurization (physical heat, e.g., hot gases,
heat exchangers).
Aerobic digestion (biological heat)b
Anaerobic digestion (physical heat)b
Gamma and high-energy electron beam
radiation.
Lime stabilization
Aerobic digestion
Anaerobic digestion
Composting11
Air or heat drying
"See Chapters 6 and 7 for a description of these processes. Many processes use more than one approach to reduce pathogens.
"Effectiveness depends on design and operating conditions.
14
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isms are ones that have been found to respond to treat-
ment processes and environmental conditions in a man-
ner similar to other organisms. Monitoring the levels of
these organisms, therefore, provides information about the
survival of the larger group.
For example, for helminth ova, tests are employed to
determine their presence and viability. The only helminth
ova viability that can be determined is that of Ascaris sp.
Ascaris is the hardiest of known helminths; thus, if condi-
tions are such that it cannot survive, it is not possible for
other helminth species (Toxacara, Trichuris, and Hyme-
nolepis) to survive.
For viruses, a test is available that simultaneously moni-
tors for several enterovirus species (a subset of enteric
viruses - see Table 2-1), which are presumed to be good
representatives for other types of enteric viruses.
Salmonella sp. are bacteria of great concern as well as
good representatives of reduction of other bacterial patho-
gens because they are typically present in higher densi-
ties than are other bacterial pathogens and are at least as
hardy.
Fecal coliforms are enteric bacteria that are used as in-
dicators of the likelihood of the presence of bacterial patho-
gens. Although fecal coliforms themselves are usually not
harmful to humans, their presence indicates the presence
of fecal waste which may contain pathogens. These bac-
teria are commonly used as indicators of the potential pres-
ence of pathogens in sewage sludges. They are abundant
in human feces and therefore are always present in un-
treated sewage sludges. They are easily and inexpensively
measured, and their densities decline in about the same
proportion as enteric bacterial pathogens when exposed
to the adverse conditions of sludge processing (EPA, 1992).
In the case of Class B biosolids, the microbiological limit
for meeting Alternative 1 is 2 million MPN fecal coliforms
per gram dry weight. Because untreated sewage sludge
generally contains up to 100 million MPN fecal coliforms
per gram dry weight, this limit assumes an approximate 2-
log reduction in the fecal coliform population. Studies of
anaerobic or aerobic digestion of sludges have shown that
the corresponding reduction in the pathogen population
will be significant and sufficient so that environmental at-
tenuation can reduce pathogen levels to below detection
limit within the time period of site restrictions (Farrell et
al.1985; Martin et al. 1990).
For some processes, fecal coliforms may be an overly
conservative indicator. Because bacteria may proliferate
outside of a host, reintroduction of fecal coliforms into
treated biosolids may result in their growth. Concentra-
tions may exceed the Class A fecal coliform limit even
though pathogens are not present. In these cases, because
fecal coliforms themselves are not a concern, testing di-
rectly for Salmonella sp. as an indicator of pathogen sur-
vival is permissible. Another issue with fecal coliforms is
that the tests for these bacteria may overestimate the num-
ber of coliforms from human species. This is of particular
concern when additives such as wood chips or other bulk-
ing agents have been added to biosolids. (Meckes, 1995)
In this case also, it is advisable to test directly for Salmo-
nella sp.
It must however be noted that high counts of fecal
coliforms may also indicate that a process is not being
operated correctly. While a preparer may meet the regula-
tory requirements by testing for and meeting the regula-
tory limits for Salmonella sp., it is recommended that the
pathogen reduction process be reviewed to determine at
what point fecal coliforms are potentially not being reduced
or are being reintroduced into treated biosolids, and en-
sure that process requirements are being fulfilled.
Regrowth of Bacteria
One of the primary concerns for biosolids preparers is
regrowth of pathogenic bacteria. Some bacteria are unique
among sewage sludge pathogens in their ability to multi-
ply outside of a host. The processes outlined in the Part
503 regulation and in this document have been demon-
strated to reduce pathogens, but even very small popula-
tions of certain bacteria can rapidly proliferate under the
right conditions, for example, in sewage sludges in which
the competitive bacterial populations have been essen-
tially eliminated through treatment (see Section 4.3). Vi-
ruses, helminths, and protozoa cannot regrow outside their
specific host organism(s). Once reduced by treatment, their
populations do not increase. The Part 503 regulation con-
tains specific requirements designed to ensure that re-
growth of bacteria has not occurred prior to use or dis-
posal.
Preventing Exposure
Exposure to pathogens in Class B biosolids is limited by
restricting situations in which the public may inadvertently
come into contact with biosolids and by limiting access to
biosolids by vectors which may carry pathogens from the
sewage sludge.
S/te Restrictions
In the case of land application of Class B biosolids, site
restrictions are sometimes required in order to protect pub-
lic health and the environment. The potential pathways of
exposure to Class B biosolids or to pathogens which may
exist in Class B biosolids, are listed in Table 2.2 along with
a description of how site restrictions impose barriers to
exposure pathways. Site restrictions, discussed in detail
in Chapter 5, place limits on crop harvesting, animal graz-
ing, and public access on land where Class B biosolids
have been applied.
The goal of site restrictions is to limit site activities such
as harvesting and grazing until pathogens have been re-
duced by environmental conditions such as heat, sunlight,
desiccation, and competition from other microorganisms.
Table 2-3 summarizes the survival rates of four types of
pathogenic organisms on soil and on plants. As shown,
15
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helminths have the longest survival time; consequently,
the duration of some of the site restrictions are based on
helminth survival potential.
Vector Attraction Reduction
Insects, birds, rodents, and domestic animals may trans-
port sewage sludge and pathogens from sewage sludge
to humans. Vectors are attracted to sewage sludge as a
food source, and the reduction of the attraction of vectors
to sewage sludge to prevent the spread of pathogens is a
focus of the Part 503 regulation. Vector attraction reduc-
tion can be accomplished in two ways; by treating the sew-
age sludge to the point at which vectors will no longer be
attracted to the sewage sludge and by placing a barrier
between the sewage sludge and vectors. The technologi-
cal and management options for vector attraction reduc-
tion are discussed in Chapter 8.
2.5 Frequently Asked Questions
Because land application of biosolids has increased dra-
matically in the past several years, and because of some
well publicized incidents of pathogen contamination (not
necessarily related to biosolids), there have been many
questions about the level to which public health is pro-
tected. Although it is not possible for every issue to be
considered, the following section includes some of the
questions which are most frequently asked. In addition,
references are included at the end of this chapter and in
Chapter 12.
Can biosolids carry the pathogen that
causes mad cow disease?
It has been found that Bovine Spongiform Encephalopa-
thy (BSE), or Mad Cow disease, is caused by a prion pro-
tein, or the resistant beta form of protein. The pathway for
transmission is through the ingestion of tissue from infected
animals. There has been no evidence that the BSE prion
protein is shed in feces or urine. There have been no known
cases of BSE in the United States, and the Food and Drug
Administration (FDA) has taken various measures to pre-
vent spread of the disease to or within the United States.
For example, the primary route for infection, the use of
animal carcasses in animal feed, is banned in this country.
These measures have been effective, and BSE has not
become a public health concern in the U.S. with regard to
ingestion of beef or other exposure routes. Thus there
should be no risk of BSE exposure from biosolids. (Tan, et
al. 1999)
Is there any risk of HIV infection from
biosolids?
The HIV virus is contracted through contact with blood
or other body fluids of an infected individual. Feces and
urine do not carry the HIV virus, but contaminated fluids
may be discharged in minor amounts to the sewerage sys-
tem. The conditions in the wastewater system are not fa-
vorable for the virus's survival. Separation from the host
environment, dilution with water, chemicals from house-
hold and industrial sewer discharges, and the length of
time from discharge to treatment all impede the survival of
the virus (WEF/U.S. EPA Fact Sheet, 1997). HIV is sel-
dom detected in wastewater, and the additional treatment
that wastewater goes through, producing an effluent and
sewage sludge which undergoes treatment to become
Class A or B biosolids, makes it virtually impossible that
biosolids would contain the HIV virus. (Lue-Hing, et al.
1999)
Wastewater treatment workers may come into contact
with contaminated objects (bandages, condoms, etc.), but
common sense hygiene practices already in place at waste-
water treatment plants including the use of protective cloth-
ing and gloves greatly reduce the potential for exposure.
The U.S. Department of Health and Human Services stated
in 1990 that". . .these workers (wastewater treatment work-
ers) have no increased potential of becoming infected by
blood borne infectious agents. Therefore, medical waste
discarded to the sanitary sewer is not likely to present any
additional public health effects to the wastewater workers
or to the general public." (Johnson, et al. 1994)
What is a bioaerosol?
Bioaerosols are airborne water droplets containing mi-
croorganisms. These may include pathogenic microorgan-
isms. Bioaerosols are a potential public health concern with
regard to Class B biosolids because if pathogens are con-
tained in the biosolids, they may become airborne and in-
fect workers or the public through direct inhalation or
through contact after settling on clothing or tools. It has
been found that aerosolization of protozoa and helminths
is unlikely, but bacteria or bacterial components (endot-
oxin) and viruses may become airborne and disperse from
an application source depending on local meteorological
and topographical conditions. However, Class B biosolids
are rarely applied dry enough to become airborne; apply-
ing wet biosolids, particularly when the biosolids are incor-
porated or injected into the land, makes it highly unlikely
that bioaerosols will be dispersed from land application.
The public access restrictions for land-applied Class B
biosolids are based on the various pathways by which
pathogens may impact public health. Site restrictions are
adequate for the protection of public health, but site work-
ers who are present during the application of Class B
biosolids should follow standard hygiene precautions such
as washing their hands after contacting biosolids and wear-
ing dust masks if applying extremely dry material. More
information on aerosolization of pathogens from land ap-
plication can be found in the references following this chap-
ter.
What is Aspergillus fumigatus?
Aspergillus fumigatus is a pathogenic fungus which is
found in decaying organic matter such as sewage sludge,
leaves, or wood. Because the fungus is heat resistant, and
because sewage sludge composting facilities often use
wood chips as a bulking agent, A. fumigatus has been as-
sociated with composting. Inhalation of A. fumigatus spores
16
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may result in allergenic effects including irritation of the
mucous membranes and asthma. However, A. fumigatus
is a secondary, or opportunistic pathogen, and infection
from A. fumigafus ("Aspergillosis") is limited to debilitated
or immuno-compromised individuals. Studies of the health
status of compost facility workers, the population most likely
to be exposed to Aspergillus fumigafus, have not shown
any negative health impacts (Millner, et al. 1994).
A. fumigafus is a ubiquitous fungus and has been found
in homes, gardens, and offices at considerable levels.
Numerous studies have been conducted to determine the
level of the fungus in the areas surrounding active com-
post sites and compare this level to background concen-
trations of Aspergillus fumigafus. In general, it has been
found that concentrations of A. fumigafus drop to back-
ground levels within 500-1000 feet of site activity. A.
fumigafus is not covered in the Part 503.
There have been several incidents in which fruit has been
contaminated with pathogens. Was this due to the land
application of biosolids?
No. Pathogens such as Salmonella sp. and pathogenic
strains of E. coliare typically associated with animal prod-
ucts (meat and eggs), but outbreaks have been known to
occur as a result of vegetable or fruit contamination from
the use of animal manures. Some of the well-publicized
incidents include cases in which the consumption of fresh
apple juice and cider resulted in widespread illness and
the death of a child (Center for Disease Control, 1996).
One case was found to be due to contamination from £
coli found in bovine feces, and the other was due to
Crypfosporidium sp., also suspected to be from contact
with animal manure. Other cases have involved the con-
tamination of berries, melons, and alfalfa sprouts.
The Part 503 regulation applies only to the land applica-
tion of biosolids. Education of field workers, regulation of
working conditions, both domestically and abroad, and the
use of animal manure products are beyond the scope of
this document.
What is the fate of Giardia and
Cryp tosporidium during Se wage Sludge
Treatment?
Giardia lamblia and Crypfosporidium parvum are proto-
zoan parasites that can infect the digestive tract of hu-
mans and other warm blooded animals. Semi-aquatic
mammals can serve as hosts, transmitting the disease to
humans who consume contaminated water. Domestic
mammals (particularly ruminants) can serve as infective
hosts and contaminate a drinking water supply. It is cur-
rently believed that at least 7% of the diarrheal cases in
the United States are caused by Crypfosporidium sp.
West (1991) notes that human protozoan parasites such
as Crypfosporidium sp. and Giardia sp. possess several
traits which facilitate waterborne transmission. They can
(1) be excreted in feces in large numbers during illness;
(2) persist through conventional sewage treatment; (3)
survive in an environmentally robust form or demonstrate
resilience to inactivation while in aquatic environments; (4)
be resistant to commonly used disinfectants in the treat-
ment of drinking water; and (5) require low numbers to
elicit infection in susceptible hosts consuming or exposed
to contaminated water.
Stadterman et al. (1995) reported on an anaerobic di-
gestion study which spiked Crypfosporidium sp. oocysts
into the digester and then periodically removed samples
to determine the die-off. They found that conventional
anaerobic digestion produces about a 2-log removal or a
better log reduction on this protozoan than it does on bac-
teria and viruses, but it does not reduce densities to the
low values needed for Class A for this pathogen. The re-
ported survival of some protozoa after anaerobic diges-
tion at 35 °C is a cause for concern.
Jenkins et al. (1998) reported that ammonia inactivates
these oocysts, depending on the concentration. High pH
processes that increase the free ammonia concentration
can inactivate these oocysts (although pH by itself does
little).
A conservative conclusion from the limited research per-
formed is that Class B processes can only be expected to
reduce protozoan pathogens by about a factor of ten. The
restrictions written into the regulation (access control, grow-
ing only certain crops, restrictions on root crops, etc.) are
necessary to prevent exposure to these pathogens. The
Class A processes reduce protozoa to below detectable
limits.
References and Additional Resources
Ahmed, Anise U., and Darwin L. Sorensen. 1995. Kinetics
of pathogen destruction during storage of dewatered
biosolids. Water Environment Research, Vol. 67,
No.2:143-150.
Ault, Steven K., Michael Schott, 1993. Aspergillus, as-
pergillosis, and composting Operations in California,
Technical Bulletin No. 1. California Integrated Waste
Management Board.
Beuchat, Larry, and J.H. Ryu. 1997. Produce handling and
processing practices. Emerging Infectious Diseases,
Centers for Disease Control and Prevention. Vol3, No.
4.
Casson, L.W., et al. 1992. HIV survivability in water. Water
Environmental Research, Vol 64: 213-215.
Engineering News Record, August 13, 1987. No AIDS
threat in sewage. Issue 47.
Farzadegan, Homayoon. 1991. Proceedings of a Sympo-
sium: Survival of HIV in environmental waters. Balti-
more, MD. National Science Foundation and the Johns
Hopkins University.
17
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Farrell, J.B., G. Sternard, A.D. Venosa. 1985. Microbial de-
structions achieved by full-scale anaerobic digestion.
Paper presented at Municipal Wastewater Sludge Dis-
infection Workshop, Kansas City, Mo. Water Pollution
Control Federation October 1985.
Feldman, Kathleen, 1995. Sampling for airborne contami-
nants. BioCycle, August 1995 (84-86).
Cover, Nancy. 1993. "HIV in wastewater not a recognized
threat, other pathogens can be." National Small Flows
Clearinghouse Newsletter. July 1993.
Gupta, Phalguni. 1991. HIV survivability in wastewater. Pro-
ceedings of a Symposium: Survival of HIV in Environ-
mental Waters. Baltimore, MD. National Science Foun-
dation and the Johns Hopkins University.
Haines, John, 1995. Aspergillus in compost: Straw man or
fatal flaw? BioCycle, April 1995 (32-35).
Harding, H.J., R.E. Thomas, D.E. Johnson, and C.A. Sorber.
1981. Aerosols generated by liquid sludge application
to land. Report No. EPA-600/1-81 -028. Washington, DC:
U.S. EPA, Office of Research and Development.
Haug, Roger T. 1993. The practical handbook of compost
engineering. Lewis Publishers.
Hay, Johnathan C., 1996. Pathogen destruction and biosolids
composting. BioCycle, Vol. 37 No.6:67-76.
Jenkins, M.B., D.D. Bowman, and W.C. Ghiorse. 1998. In-
activation of Cryptosporidium parvum oocysts by am-
monia. Appl. Envir. Microbiol. 64, No.2, 784-788.
Johns Hopkins School of Hygiene and Public Health. 1991.
HIV transmission in the environment: What are the risks
to the public's health? Public Health News.
Johnson, R.W., Blatchley, E.R. Ill, and D.R. Mason. 1994.
HIV and the blood borne pathogen regulation: Implica-
tions for the wastewater industry. Water Environment
Research, Vol. 66: 684-691.
Kindzierski, W.B., R.E. Roberts, and N.J. Low. 1993. Health
effects associated with wastewater treatment, disposal,
and reuse. Water Environment Research, Vol. 65: 599-
606.
Kowal, N.E. 1985. Health effects of land application of mu-
nicipal sludge. Pub. No.: EPA/600/1 -85/015. Research
Triangle Park, NC: U.S. EPA Health Effects Research
Laboratory.
Kowal, N.E. 1994. Pathogen risk assessment: Status and
potential application in the development of Round II regu-
lations. Proceedings of the June 19-20,1994 Speciality
Conference. The Management of Water and Wastewa-
ter Solids for the 21st Century: A Global Perspective.
Water Environment Federation. Alexandria, VA.
Lue-Hing, Cecil, Leonard Casson, and Prakasam Tata. 1999.
HIV in wastewater: present survivability and risk to waste-
water treatment plant workers. Water Environment Fed-
eration monograph. Alexandria, VA.
Martin, J.H., Jr., H.F. Bastian, and G. Stern. 1990 Reduction
of enteric microorganisms during aerobic sludge diges-
tion. Wat. Res. 24(11):1377-l 385.
Meckes, Mark, E.W. Rice, C.H. Johnson, and S. Rock. 1995.
Assessment of the Bacteriological Quality of Compost
Science and Utilization. Vol. 3 No. 3:6-1 3.
Millner, P.O., S.A. Olenchock, E. Epstein, R. Rylander, J.
Haines, J. Walker, B.L. Ooi, E. Home, and M. Maritato.
1994. Bioaerosols associated with composting facilities.
Compost Science and Utilization. 2(4):6-57.
Moore, B.E. 1993. Survival of human immunodeficiency vi-
rus (HIV), HIV-infected lymphocytes, and poliovirus in
water. Applied and Environmental Microbiology. Vol. 59:
1437-1 443.
Morbidity and Mortality Weekly Report. 1996. Outbreak of
E.Coli O157:H7 infections associated with drinking un-
pasteurized commercial apple juice. Centers for Disease
Control and Prevention. Vol. 45, No. 44.
Obeng, L. 1985. Health aspects of water supply and sanita-
tion. In Information and Training for Low-Cost Water
Supply and Sanitation. Ed D. Trattles. World Bank. Wash-
ington, D.C.
Pell, Alice. 1997. Manure and microbes: Public and animal
health problem? Journal of Diary Science 80:2673-2681.
Ponugoti, PrabhakerR.,MohamedF. Dahab, Rao Surampalli.
1997. Effects of different biosolids treatment systems
on pathogen and pathogen indicator reduction. Water
Environment Research, Vol. 69: 1195-1 206
Scheuerman, P.R., S.R. Farrah, and G. Bitton. 1991. Labo-
ratory studies of virus survival during aerobic and anaero-
bic digestion of sewage sludge. Water Resources
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disinfection - Federal Perspectives. Presented at Water
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V.C. Rao and J.L. Melnick, eds. Human viruses in sedi-
ments, sludge, and soils. Boca Raton, FL: CRC Press
Sorber, C.A. ,B.E. Moore, D.E. Johnson, H.J. Harding, R.E.
Thomas. 1984. Microbiological aerosols from the ap-
18
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Project.
West, P. A., "Human pathogenic viruses and parasites:
Emerging pathogens in the water cycle," Journal of
Applied Bacteriology JABAA4, Vol.70, No. Supp, p
107S-1143,1991.
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wastewater sludge. Appl. Environ. Microbiol.
41 (5):1117-1 122.
19
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Chapter 3
Overview of Part 503 Subpart D Requirements,
Their Applicability, and Related Requirements
3.1 Introduction
The Subpart D (pathogen and vector attraction reduc-
tion) requirements of the 40 CFR Part 503 regulation ap-
ply to sewage sludge (both bulk sewage sludge and sew-
age sludge that is sold or given away in a bag or other
container for application to the land) and domestic septage
applied to the land or placed on a surface disposal site.
The regulated community includes persons who generate
or prepare sewage sludge for application to the land, as
well as those who apply it to the land. Included is anyone
who:
. Generates treated sewage sludge (biosolids) that is
land applied or placed on a surface disposal site
. Derives a material from treated sewage sludge
(biosolids)
. Applies biosolids to the land
. Owns or operates a surface disposal site
Sewage sludge cannot be applied to land or placed on a
surface disposal site unless it has met, among other things,
the two basic types of requirements in Subpart D:
. Requirements to ensure reduction of pathogens.
. Requirements to reduce the potential of the sewage
sludge to attract vectors (rodents, birds, insects, and
other organisms that can transport pathogens).
These two types of requirements are separated in Part
503 (they were combined in an earlier regulation, Part
257),which allows flexibility in how they are achieved. Com-
pliance with the two types of requirements must be dem-
onstrated separately. Therefore, demonstration that a re-
quirement for reduced vector attraction has been met does
not imply that a pathogen reduction requirement also has
been met, and vice versa.
This chapter provides an overview of the Subpart D re-
quirements, their applicability, and the requirements related
to frequency of monitoring and recordkeeping. Where rel-
evant, the titles of the sections in this chapter include the
number of the Subpart D requirement discussed in the
section. Chapters 4 through 8 provide detailed information
on the pathogen and vector attraction reduction require-
ments.
Some of the pathogen and vector attraction reduction
alternatives are suitable only for biosolids which have been
processed by particular methods, such as by aerobic or
anaerobic digestion or composting. Chapters 4 and 5 con-
tain examples of how some facilities have met Part 503
requirements using appropriate pathogen and vector at-
traction reduction protocols, and Chapter 8 discusses each
vector attraction option in detail.
3.2 Pathogen Reduction Requirements
Se wage Sludge [503.32(a) and(b)]
The pathogen reduction requirements for sewage sludge
are divided into two categories: Class A and Class B. These
requirements use a combination of technological and mi-
crobiological requirements to ensure reduction of patho-
gens.
The implicit goal of the Class A requirements is to re-
duce the pathogens in sewage sludge (including enteric
viruses, pathogenic bacteria, and viable helminth ova) to
below detectable levels, as defined in the 1992 regulation.
The implicit goal of the Class B requirements is to re-
duce pathogens in sewage sludge to levels that are un-
likely to pose a threat to public health and the environment
under the specific use conditions. For Class B biosolids
that are applied to land, site use restrictions are imposed
to minimize the potential for human or animal exposure to
Class B biosolids for a period of time following land appli-
cation and until environmental factors (e.g. sunlight, des-
iccation) have further reduced pathogens. Both Class A
treatment of the sewage sludge which reduces pathogens
to below detectable levels and the combination of Class B
sewage sludge treatment and use restrictions on the land
application site protect public health and the environment.
"Exceptional quality" (EQ) biosolids are biosolids which
have met the Part 503 pollutant concentration limits (Table
3 of Section 503.13) as well as Class A pathogen reduc-
tion requirements and one of the first eight vector attrac-
tion reduction options listed in 503.33(b)(l) through (b)(8).
EQ biosolids may be land applied without site restrictions.
20
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Application of Class B biosolids must be conducted in
compliance with site restrictions. Because it is not pos-
sible for regulators to follow the land application of biosolids
applied on lawns and home gardens, Class B biosolids
cannot be sold or given away in bags or other containers
or applied on lawns and home gardens.
The testing requirements outlined throughout this docu-
ment are minimum standards for compliance with the Part
503 rule. It should be pointed out that biosolids are prop-
erly distributed under the most recent test results. How-
ever, facilities which distribute biosolids between sampling
events may wish to enhance their sampling programs to
better ensure compliance with pathogen reduction require-
ments and to enhance public confidence in biosolids qual-
ity. More frequent testing should also enable the biosolids
generators and preparers to better detect any changes in
operations that might affect compliance and slow more
rapid correction in any adverse changes. It should be noted
that when additional determinations are made, even though
they are in excess of Part 503 regulatory requirements, all
these analytical results and records must be retained in
the generator's, preparer's or land applier's files or reported
to the regulatory authority depending on the classification
of the operation or the regulatory authority's wishes.
Domestic Septage [503.32(c)J
As stated in Chapter 1, domestic septage is a form of
sewage sludge. The requirements for domestic septage
vary depending on how it is used or disposed. Domestic
septage applied to a public contact site, lawn, or home
garden must meet the same requirements as treated sew-
age sludge (biosolids) applied to these types of land (Class
A requirements). Separate, less-complicated requirements
for pathogen reduction apply to domestic septage applied
to agricultural land, forests, or reclamation sites. These
requirements include site restrictions to reduce the poten-
tial for human exposure to domestic septage and to allow
for pH adjustment or environmental attenuation with site
restrictions only on harvesting crops. No pathogen require-
ments apply if domestic septage is placed on a surface
disposal site.
3.3 Vector Attraction Reduction (VAR)
Requirements [503.33]
Subpart D provides 12 options to demonstrate vector
attraction reduction. These are referred to in this docu-
ment as Options 1 through 12. Table 8-2 summarizes these
options, and Chapter 8 provides more detailed informa-
tion on the options.
Reduction through Treatment
Options 1 through 8 apply to sewage sludge that has
been treated in some way to reduce vector attraction (e.g.,
aerobic or anaerobic digestion, composting, alkali addi-
tion, drying). These options consist of either operating
conditions or tests to demonstrate that vector attraction
has been reduced in the treated sewage sludge. Option
12 is a requirement to demonstrate reduced vector attrac-
tion in domestic septage through elevated pH. This option
applies only to domestic septage.
Reduction through Barriers
Options 9 through 11 are "barrier" methods. These op-
tions require the use of soil as a physical barrier (i.e., by
injection, incorporation, or as cover) to prevent vectors from
coming in contact with the land applied biosolids. They
include injection of biosolids below the land surface, incor-
poration of biosolids into the soil, and placement of a cover
over the biosolids. Options 9 through 11 apply to both
biosolids and domestic septage. Option 11 may only be
used at surface disposal sites.
Timing of Pathogen and Vector Attraction
Reduction
In the case of Class A biosolids, pathogen reduction must
take place before or at the same time as vector attraction
reduction unless VAR Option 6, 7, or 8 is used. More in-
formation is provided in Section 4.2.
3.4 Applicability of the Requirements
[503.15 and 503.251
The applicability of the pathogen and vector attraction
reduction requirements is covered in 503.15 and 503.25.
Tables 3-I to 3-3 summarize the applicability of the Sub-
part D requirements to sewage sludge and domestic
septage.
Table 3-I. Subpart D Requirements for the Land Application of Bulk
Biosolids1
Applied to Agricultural
Land, a Forest, a Public
Contact Site2, or a
Reclamation Site3
Applied to a Lawn or
Home Garden
Pathogen
Requirements
Vector Attraction
Reduction
Requirements
Class A or Class B
with site restrictions
Options l-l 0s
Class A"
Options 1 -8s'6
1 Bulk biosolids are biosolids that are not sold or given away in a bag or
other container for application to the land.
2 Public contact site is land with a high potential for contact by the
public, e.g., public parks, ball fields, cemeteries, plant nurseries, turf
farms, and golf courses.
3 Reclamation site is drastically distrubed land (e.g., strip mine,
construction site) that is reclaimed using biosolids.
4 The regulation does not permit use of biosolids meeting Class B
requirements on lawns or home gardens, because it would not be
feasible under these circumstances to impose the site restrictions that
are an integral part of the Class B requirements.
5 See Chapter 8 for a description of these options.
6 The two vector attraction reduction requirements that cannot be met
when bulk biosolids are appliced to a lawn or a home garden are
injection of the bulk biosolids below the land surface and incorporation
of bulk biosolids into the soil. Implementation of these requiremtns for
bulk biosolids applied to a lawn or a home garden would be difficult, if
not impossible.
21
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Table 3-2. Subpart D Requirements for Biosolids Sold or Given Away
in a Bag or Other Container for Application to the Land
Land Application
Pathogen Requirements Class A1
Vector Attraction Reduction Options 1-82
Requirements
'Class B biosolids cannot be sold or given away for use on home
gardens or lawns because it is not feasible to impose the Class B site
restrictions for these uses.
2Only the treatment-related options for vector attraction reduction apply
to biosolids that are sold or given away in bags or other containers for
application to the land, because of the barrier options, which are
implemented at the site of application, would be impossible. See
Chapter 8 for a description of these options.
Table 3-3. Supart D Requirements for Domestic Septage Applied to
Agricultural Land, a Forest, or a Reclamation Site1 or
Placed on a surface Disposal Site
Application to Agricultural
Land, a Forest, or a
Reclamation Site2
Surface Disposal
Pathogen Reduction
Requirements
Vector Attraction
Reduction
Requirements
Class B site restrictions
only or a pH adjustment
(pH> 12 for 30 minutes)
plus restrictions concerning
crop harvesting
Options 9, 10,124
No pathogen
requirements3
Optionis 9-I 2"
1For application to all other types of land, domestic septage must meet
the same requirements as other forms of sewage sludge (see Tables 3-I
and 3-2).
'Reclamation site is drastically disturbed land (e.g., strip mine, construc-
tion site) that is reclaimed using biosolids.
"There is no pathogen requirement for domestic septage placed on a
surface disposal site because site restrictions for grazing of animals,
public access, and crop growing are already imosed by the Part 503,
Subpart C management practices to reduce exposure to pollutants in
domestic septage placed on a surface disposal site.
4See Chapter 8 for a description of these options.
Table 3-4. Frequency of Monitoring for Land Application and Surface
Disposal
Amount of Biosolids1 (metric tons
dry solids per 365-day period)
Minimum Frequency
Greater than zero but less than 2902
Equal to or greater than 290 but less
thanl.SOO2
Equal to or greater than 1,500 but
less than 1 5.0002
Equal to or greater than 15.0002
Once per year
Once per quarter (four times
per year)
Once per 60 days (six times
per year)
Once per month (12 times per
year)
'Either the amount of bulk biosolids applied to the land, or the amount
of sewage sludge received by a person who prepares biosolids that is
sold or given away in a bag or other container for application to the
land (dry weight basis), or the amount of biosolids (excluding domestic
septage) placed on a surface disposal site.
2290 metric tons = 320 tons (approximately 0.9 tons/day for a year)
1,500 metric tons = 1,653 tons (approximately 4.5 tons/day for a year)
15,000 metric tons = 16,534 tons (approximately 45 tons/day for a
year)
3.5 Frequency of Monitoring
Se wage Sludge [503.16(a) and 503.26(a)]
The Class A and Class B pathogen requirements and
the vector attraction reduction Options 1 through 8 (the
treatment related methods) all involve some form of moni-
toring. The minimum frequency of monitoring for these re-
quirements is given in Part 503.16(a) for land application
and Part 503.26(a) for surface disposal. The frequency
depends on the amount of biosolids used or disposed an-
nually (see Table 3-4). The larger the amount used or dis-
posed, the more frequently monitoring is required.
In addition to monitoring frequency, a sampling plan
should address the minimum number of samples per sam-
pling event that are necessary to adequately represent
biosolids quality. Both of these issues are addressed in
Chapter 9.
As stated throughout this document, the monitoring re-
quirements set forth in the Part 503 and this document are
the minimum requirements. Persons or facilities that gen-
erate and distribute biosolids are encouraged to go be-
yond the minimum required programs as necessary.
Domestic Septage [503.16(b) and 503.26(b)]
One of the requirements that can be used for demon-
strating both pathogen reduction and vector attraction re-
duction in domestic septage is to elevate pH to $12 for 30
minutes (see Sections 5.6 and 8.13). When this require-
ment is to be met, each container of domestic septage
(e.g., each tank truckload) applied to the land or placed on
a surface disposal site must be monitored for pH over 30
minutes.
3.6 Sampling Stockpiled or Remixed
Biosolids
In many cases there are several steps of preparation
before biosolids are actually used or distributed. For ex-
ample, some products such as composted biosolids may
be prepared and then mixed with other materials to create
a soil blend. Other biosolids products may be prepared
and then stored either on site or at a field until the material
can be applied. In some cases, resampling and/or re-es-
tablishment of the biosolids quality may be necessary.
Whether or not biosolids must undergo additional sam-
pling or processing depends on the classification of the
biosolids and on whether the biosolids remain in the con-
trol of the preparer or if they have been distributed or sold.
EQ Biosolids
If the biosolids are classified as exceptional quality (EQ)
(see Section 3.2), they may be distributed for land appli-
cation without site restriction. EQ is an industry term rather
than a regulatory term. Land application of EQ biosolids is
not regulated by the Part 503 once the biosolids leave the
control of the biosolids preparer. Therefore, soil blenders
or other (non-preparer) users who take EQ biosolids may
store the biosolids or mix the EQ biosolids with other (non-
sewage sludge) materials without resampling the product.
22
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Conversely, if EQ biosolids remain within the control of the
preparer, they are still considered biosolids and are still cov-
ered by the Part 503. Like all Class A products, they must
undergo microbiological testing at the last possible point
before being distributed. In addition, if the preparer mixes
the EQ biosolids or otherwise changes the quality of the
biosolids, the new biosolids product must again comply with
pathogen reduction, vector attraction reduction, and micro-
biological requirements.
Non-EQ Class A Biosolids
Class A biosolids are not necessarily classified as EQ
biosolids; if pollutant levels exceed the Table 3 limits or if
one of the first eight vector attraction options has not been
met, the Class A biosolids are not considered EQ. All Class
A biosolids must undergo microbiological testing just before
they are distributed, so testing for fecal coliforms or Salmo-
nella sp. must take place after storage. In addition, if the
preparer mixes the Class A biosolids with other materials or
otherwise changes the quality of the biosolids, the new
biosolids product must comply with pathogen reduction, vec-
tor attraction reduction, and microbiological requirements.
Non-EQ Class A biosolids must also be monitored after
they are distributed. For example, if a Class Acompost which
does not meet one of the EQ pollutant limits is sold to a
vendor who mixes the compost with soil, the soil blender
becomes a biosolids preparer, and must therefore comply
with all Part 503 regulations. The new biosolids product must
comply with pathogen reduction, vector attraction reduction,
and microbiological requirements.
Class B Biosolids
Class B biosolids can meet pathogen reduction require-
ments at any point; there is no requirement that Class B
biosolids be tested just before distribution. Therefore,
biosolids which have met the Class B pathogen reduction
requirements can be stored on site without retesting. How-
ever, if the Class B biosolids are mixed with other materials
or the quality of the biosolids are otherwise altered, the new
biosolids product must meet pathogen reduction and vector
attraction reduction requirements.
The same is true for Class B biosolids that are distributed
and no longer under the control of the preparer. Stored Class
B biosolids do not have to be retested for pathogen reduc-
tion, unless the quality of the biosolids is somehow altered
through mixing or further processing.
3.7 Record Keeping Requirements [503.17
and 503.27]
Record keeping requirements are covered in Part 503.17
for land application and Part 503.27 for surface disposal.
Records are required for both biosolids and domestic
septage that are used or disposed. All records must be
retained for 5 years except when the cumulative pollutant
loading rates (CPLRs) in Subpart B (Land Application) of
the Part 503 are used1. If CPLRs are used, records of pol-
lutant loading at each site must be kept indefinitely. All
records must be retained and made available to the regu-
latory authority upon request (see Section 3.8).
Land Application
Records must be kept to ensure that the biosolids meet
the applicable pollutant limits, management practices*, one
of the pathogen requirements, one of the vector attraction
reduction requirements and, where applicable, the site re-
strictions associated with land application of Class B
biosolids. When biosolids are applied to land, the person
preparing the biosolids for land application and the person
applying bulk biosolids must keep records3,4. The person
applying biosolids that were sold or given away does not
have to keep records.Table 3-5 summarizes the record
keeping requirements for land application.
Surface Disposal
When biosolids are placed on a surface disposal site,
the person preparing the biosolids and the owner/operator
of the surface disposal site must keep records. In the case
of domestic septage applied to agricultural land, forest, or
a reclamation site or placed on a surface disposal site, the
person applying the domestic septage and the owner/op-
erator of the surface disposal site may be subject to patho-
gen record keeping requirements, depending on which
vector attraction reduction option is met. Table 3-6 sum-
marizes the pathogen-related record keeping requirements
for surface disposal.
Certification Statement
In every case, record keeping involves signing a certifi-
cation statement that the requirement has been met. Parts
503.17 and 503.27 of the regulation contain the required
certification language.
3.8 Reporting Requirements for Sewage
Sludge [503.18 and 503.28]
Reporting requirements for sewage sludge are found in
Part 503.18 for land application and Part 503.28 for sur-
face disposal. These requirements apply to Class I sludge
management facilities5 and to publicly owned treatment
'Cumulative pollutant loading rates are not related to pathogen control and there-
fore are not covered in this document.
2Ppllutant limits and management practices are not related to the pathogen re-
quirements and therefore are not covered in this document.
3Person as defined under Part 503.9 may be an individual, association, partner-
ship, corporation, municipality, state or federal agency, or an agent or employee of
a state or federal agency.
4When biosolids are prepared by one person, and another person who places it in
a bag or other container for sale or give-away for application to the land changes
the quality of that biosolids, both persons must keep the records required of preparers
(see Table 3-5 and Section 3.6).
5A Class I sewage sludge management facility is any publicly owned treatment
works (POTW) required to have an approved pretreatment program under 40 CFR
403.8(a) [including any POTW located in a state that has assumed local program
responsibilities under 40 CFR 403.1 (e)] and any treatment works treating domestic
sewage classified as a Class I sludge management facility by EPA or the state
sludge management program because of the potential for its sewage sludge use or
disposal practices to adversely affect public health and the environment.
-------
Table 3-5. Summary of Pathogen and Vector Attraction Reduction Record Keeping Requirements for Land Application of Biosolids1
Description of
How Class A
Pathogen
Requirement
Was Met
Description of
How Class B
Pathogen
Requirement
Was Met
Description of
How the Class B
Site Restrictions
Were Met at Each
Site Where Sewage
Sludge Was Applied
Description of
How Pathogen
Requirement for
Domestic Septage
Applied to
Agricultural Land,
a Forest, or a
Reclamation Site
Was Met
Description of
How Vector
Attraction
Requirement
Was Met
Certification
Statement
that the
Requirement
Was Met
Biosolids - Pathogen
Requirements
Person preparing Class A
bulk biosolids
Person preparing Class A
biosolids for sale or give
away in a bag or other
container
Person preparing Class B
biosolids
Person applying Class B
biosolids
Biosolids - Vector-Attraction
Reduction Requirements
Person preparing biosolids
that meet one of the
treatment-related vector
attraction reduction
requirements (Options 1-8)
Person applying biosolids if a
barrier-related option
(Optioins 9-11) is used to
meet the vector attraction
reduction requirement
Domestic Septage
Person applying domestic
septage to agricultural
land, a forest, or a
reclamation site
V
V
V
V
'Other record keeping requirements, not covered in this document; apply to pollutant limits and management practices.
Table 3-6. Summary of Pathogen and Vector Attraction Reduction Record Keeping Requirements for Surface Disposal of Biosolids1
Required Records
Description of How Class A
or B Pathogen Requirement
was Met
Description of How Vector
Attraction Requirement
was Met
Certification Statement that
the Requirement was
Met
Biosolids - Pathogen Requirements
Person preparing the biosolids V
Sewage Slude - Vector Attraction Reduction Requirements
Person preparing biosolids that meet
one of the treatment-related vector
attraction reduction requirements
(Options I-8)
Owner/operator of the surface
disposal site if a barrier-related
option (Option 9-11) is used to meet
the vector attraction reduction
requirement
continued
24
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Table 3-6. (Continued)
Description of How Class A
or B Pathogen Requirement
was Met
Required Records
Description of How Vector
Attraction Requirement
was Met
Certification Statement that
the Requirement was
Met
Domestic Septage
Person who places domestic
septage on the surface
disposal site if the domestic
septage meets Option 12 for
vector attraction reduction
Owner/operator of the surface
disposal site if a barrier-related
option (Optioin 9-11) is used
to meet the vector attraction
reduction requirement
1Other record keeping requirements, not covered in this document, apply to pollutant limits and management practices.
works either with a design flow rate equal to or greater
than 1 million gallons per day or that serve 10,000 or more
people, or if specifically required by the permitting author-
ity. Reports must be submitted to the regulatory authority
(see Tables 3-5 and 3-6) and/or as the owner/operators of
surface disposal sites (see Table 3-6) on February 19 of
each year. There are no reporting requirements associ-
ated with the use or disposal of domestic septage, but
records must be kept and made available to the regulatory
authority upon request.
3.9 Permits and Direct Enforceability
[503.3]
Permits
Under Part 503.3(a), the requirements in Part 503 may
be implemented through (1) NPDES permits issued to treat-
ment works treating domestic sewage by EPA permits is-
sued by states with an EPA-approved sludge management
program, and (2) by permits issued under Subtitle C of the
Solid Waste Disposal Act; Part C of the Safe Drinking Water
Act; the Marine Protection, Research, and Sanctuaries Act
of 1972; or the Clean Air Act. Treatment works treating
domestic sewage should submit a permit application6 to
the approved state program, or, if there is no such pro-
gram, to the EPA Regional Sludge Coordinator (see Ap-
pendix A).
Direct Enforceability
Under Part 503.3(b), the requirements of Part 503 auto-
matically apply and are directly enforceable even when no
federal permit has been issued for the use or disposal of
biosolids.
«See 40 CFR Parts 122.123, and 501; 54 FR18716/May 2,1989; and 58FR9404/
February 19,1993, for regulations establishing permit requirements and proce-
dures, as well as requirements for states wishing to implement approved sewage
sludge management programs as either part of their NPDES programs or under
separate authority.
25
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Chapter 4
Class A Pathogen Requirements
4.1 Introduction
This chapter principally discusses the Class A pathogen
requirements in Subpart D of the 40 CFR Part 503 regula-
tion. Biosolids that are sold or given away in a bag or other
container for application to land must meet these require-
ments (see Section 3.4). Bulk biosolids applied to a lawn
or home garden also must meet these requirements. Bulk
biosolids applied to other types of land must meet these
requirements if site restrictions are not met (see Chapter 5
for guidance on Class B biosolids). Some discussion is,
however, presented of vector attraction reduction.
There are six alternative methods for demonstrating
Class A pathogen reduction. Two of these alternatives pro-
vide continuity with 40 CFR Part 257 by allowing use of
Processes to Further Reduce Pathogens (PFRPs) and
equivalent technologies (see Sections 4.8 and 4.9). Any
one of these six alternatives may be met for the sewage
sludge to be Class A with respect to pathogens. The im-
plicit objective of all these requirements is to reduce patho-
gen densities to below detectable limits which are:
Salmonella sp.
Enteric viruses1
Viable helminth ova
less than 3 MPN per 4 grams
total solids biosolids (dry weight
basis)
less than 1 PFU per 4 grams
total solids biosolids (dry weight
basis)
less than 1 viable helminth ova/
4 gram total solids biosolids (dry
weight basis)
One of the vector attraction reduction requirements (see
Chapter 8) also must be met when biosolids are applied to
the land or placed on a surface disposal site. To meet the
Part 503 regulatory requirements, pathogen reduction must
be met before vector attraction reduction or at the same
time vector attraction reduction is achieved.
For the following sections, the title of each section pro-
vides the number of the Subpart D requirement discussed
'Enteric viruses are monitored using a method that detects several enterpvirus
species-a subset of enteric viruses. This method is presumed to be a good indica-
tor of enteric viruses. Since the objective of the Part 503 regulation is to reduce al
enteric viruses to less than 1 PFU per 4 grams total solids sewage sludge, this
document refers to "enteric viruses" when discussing this requirement, although, in
reality, the detection method enumerates only enteroviruses.
in the section. The exact regulatory language can be found
in Appendix B, which is a reproduction of Subpart D. Chap-
ters 9 and 10 provide guidance on the sampling and analy-
sis needed to meet the Class A microbiological monitoring
requirements.
4.2 Vector Attraction Reduction to Occur
With or After Class A Pathogen
Reduction[503.32(a){2)]
Although vector attraction reduction and pathogen re-
duction are separate requirements, they are often related
steps of a process. Chapter 8 discusses the vector attrac-
tion reduction options in greater detail.
The order of Class A pathogen reduction in relation to
the reduction of vector attraction is important when certain
vector attraction reduction options are used. Part
503.32(a)(2) requires that Class A pathogen reduction be
accomplished before or at the same time as vector attrac-
tion reduction, except for vector attraction reduction by al-
kali addition [503.33(b)(6)] or drying [503.33(b)(7) and (8)]
(see Chapter 8).
This requirement is necessary to prevent the growth of
bacterial pathogens after sewage sludge is treated. Con-
tamination of biosolids with a bacterial pathogen after one
of the Class A pathogen reduction alternatives has been
conducted may allow extensive bacterial growth unless:
a) an inhibitory chemical is present, b) the biosolids are
too dry to allow bacterial growth, c) little food remains for
the microorganisms to consume, or d) an abundant popu-
lation of non-pathogenic bacteria is present. Vegetative
cells of non-pathogenic bacteria repress the growth of
pathogenic bacteria by "competitive inhibition" which is in
substantial part due to competition for nutrients. It should
be noted that vector attraction reduction by alkali addition
[503.3(b)(6)] or drying [503.3(b)(7)] and (8) is based on
the characteristic of the biosolids (pH or total solids) re-
maining elevated. Should the pH drop or the biosolids ab-
sorb moisture, the biosolids may be more hospitable to
microorganisms, and pathogenic bacteria, if introduced,
may grow. Therefore it is recommended that biosolids
treated with these methods be stored appropriately.
Biological treatment processes like anaerobic digestion,
aerobic digestion, and composting produce changes in the
26
-------
sewage sludge so that it satisfies one of the vector attrac-
tion reduction requirements [503.3(b)(l) through (5)]. They
repress bacterial growth by minimizing the food supply and
providing competition for the remaining food from non-
pathogenic organisms. The pathogen reduction alterna-
tive must precede the vector attraction reduction process:
otherwise, the large number of non-pathogenic bacterial
cells would be killed and growth of pathogenic bacteria
could occur. Certain pathogen reduction processes such
as composting accomplish vector attraction reduction by a
biological process simultaneously with thermal reduction
of pathogens. A non-pathogenic bacterial community sur-
vives which adequately suppresses growth of pathogenic
bacteria.
In the case of Class B biosolids, a population of non-
pathogenic bacteria is retained and inhibits the growth of
pathogenic bacteria through competition, and site restric-
tions are imposed with their land application to reduce the
risk of exposure to pathogens. Therefore, bacterial growth
is not a concern for Class B biosolids, and vector attrac-
tion reduction and pathogen reduction for compliance with
the Part 503 Rule requirements may be met in any order.
4.3 Monitoring of Fecal Coliform or
Salmonella sp. to Detect Growth of
Bacterial Pathogens [503.32(a)(3)-(8)]
The goal of Class A processes is to reduce the level of
pathogens to below detectable levels and below the level
at which they are infectious. The Class A processes have
been shown to sufficiently reduce pathogen levels in
biosolids, and studies to date have not found that the growth
of pathogenic bacteria may occur in materials after pro-
cesses take place or during storage. Favorable conditions
for the growth of pathogenic bacteria would be: adequate
moisture, absence of an inhibitory chemical, and inad-
equate reduction of nutritive value of the sewage sludges.
Because Class A biosolids may be used without site re-
strictions, all Class A material must be tested to show that
the microbiological requirements are met at the time when
it is ready to be used or disposed. In addition to meeting
process requirements, Class A biosolids must meet one of
the following requirements:
. Either the density of fecal coliforms in the sewage
sludge be less than 1,000 MPN2 per gram total solids
(dry weight basis),
. Or the density of Salmonella sp. bacteria in the sew-
age be less than 3 MPN per 4 grams of total solids
(dry weight basis).
Although the Part 503 regulation does not specify the
number of samples that should be taken to show compli-
ance with Class Adensity requirements, sampling programs
should provide adequate representation of the biosolids
generated. Chapter 9 provides guidance for calculating the
number of samples that should be taken per sampling
event. Unlike Class B biosolids, compliance with Class A
requirements is not based on an average value. Each
sample analyzed must comply with the numerical re-
quirements.
The microbiological requirement must be met either:
• At the time of use or disposal3, or
• At the time the biosolids are prepared for sale or give
away in a bag or other container for land application,
or
• At the time the biosolids or material derived from the
biosolids is prepared to meet the requirements in
503.1 0(b), 503.10(c), 503. 1 0(e), or 503. 1 0(f)4-
II a facility stores material before it is distributed for use
or disposal, microbiological testing should take place after
storage.
In each case, the timing represents the last practical
monitoring point before the biosolids are applied to the land
or placed on a surface disposal site. Biosolids that are sold
or given away cannot be monitored just prior to actual use
or disposal; instead monitoring is required as it is prepared
for sale or give away. Biosolids that meet the 503.1 0(b, c,
d, ore) requirements are considered "Exceptional Quality"
and are therefore not subject to further control (see Sec-
tion 1.4). For this reason, the microbiological requirements
must be met at the time the biosolids are prepared to meet
the 503.10 requirements, which in most cases is the last
time the biosolids are under the control of a biosolids
preparer.
As discussed in Chapter 9, the timing of pathogen sam-
pling is also a function of laboratory turnaround time. Ob-
taining results for fecal coliform and Salmonella sp. analy-
sis may take several days if tests are performed in-house,
but commercial labs may require more time to process and
report results. It is not unusual for laboratories to have a
turnaround time of 2 weeks, even for simple tests such as
fecal coliform. If this is the case, this time should be fac-
tored into the sampling program so that results can be
obtained before biosolids are distributed for use or dis-
posal.
Monitoring Fecal Coliforms or Salmonella
sp.
Fecal coliforms are used in the Part 503 as an indicator
organism, meaning that they were selected to be moni-
tored because reduction in fecal coliforms correlates to
reduction in Salmonella sp. and other organisms. The re-
2The membrane filter method is not allowed for Class A because, at the low fecal
coliform densities expected, the filter would have too high a loading of sewage
sludge solids to permit a reliable count of the number of fecal coliform colonies.
3Minus the time needed to test the biosolids and obtain the test results prior to use
or disposal (see Chapter 10).
4The 503.10(b)(c)(e) and (t) requirements are not discussed in this document.
27
-------
quirements were based on experimental work by Yanko
(1987) and correlations developed from Yanko's data by
Farrell (1993) which show that this level of fecal coliforms
correlate with a very low level of Salmonella sp. detection
in composted sewage sludge (EPA, 1992).
Anecdotal reports suggest that some composting facili-
ties may have diff iculty meeting this requirement even when
Salmonella sp. are not detected. This might be expected
under several circumstances. For example, very severe
thermal treatment of sewage sludge during composting can
totally eliminate Salmonella sp. yet leave residual fecal
coliforms. If the sewage sludge has been poorly composted
and thus is a good food source, fecal coliforms may grow
after the compost cools down from thermophilic tempera-
tures. Because the Salmonella sp. are absent, they can-
not grow. An even more probable circumstance could oc-
cur if the sewage sludge is treated with lime before
composting. Lime effectively destroys Salmonella sp. in
sewage sludge and leaves surviving fecal coliforms (Farrell
et al., 1974). Under conditions favorable for growth, the
fecal coliforms can regrow to levels higher than 1,000 MPN
per gram. Research has shown that detection of Salmo-
nella sp. is much rarer in composted sewage sludge that
has been lime treated and composted than detection of
fecal coliforms. Fecalcoliform densities maybe high there-
fore compared to pathogen densities in such cases and
maybe overly conservative. For this reason, all of the Part
503 Class A alternatives allow the direct measurement of
Salmonella sp. or fecal coliform analysis, but do not re-
quire both.
4.4 Alternative 1: Thermally Treated
Sewage Sludge [503.32(a)(3)]
This alternative may be used when the pathogen reduc-
tion process uses specific time-temperature regimes to
reduce pathogens. Under these circumstances, time-con-
suming and expensive tests for the presence of specific
pathogens can be avoided. It is only necessary to demon-
strate that:
. Either fecal coliform densities are below 1,000 MPN
per gram of total solids (dry weight basis), or Salmo-
nella sp. bacteria are below detection limits (3 MPN
per 4 grams total solids [dry weight basis]) at the time
the sewage sludge is used or disposed, at the time
the sewage sludge is prepared for sale or given away
in a bag or other container for land application, or at
the time the sewage sludge or material derived from
the sewage sludge is prepared to meet the require-
ments in 503.10(b), 503.10(c), 503.10(e), or 503.10(f).
. And the required time-temperature regimes are met.
Time- Temperature Requirement
Four different time-temperature regimes are given in
Alternative 1. Each regime is based on the percent solids
of the sewage sludge and on operating parameters of the
treatment process. Experimental evidence (EPA, 1992)
demonstrates that these four time-temperature regimes
reduce the pathogenic organisms to below detectable lev-
els.
The four time-temperature regimes are summarized in
Table 4-I. They involve two different time-temperature
equations. The equation used in Regimes A through C re-
sults in requirements that are more stringent than the re-
quirement obtained using the equation in Regime D. For
any given time, the temperature calculated for the Regime
D equation will be 3 Celsius degrees (5.4 Fahrenheit de-
grees) lower than the temperature calculated for the Re-
gimes A through C equation.
The time-temperature relationships described for Alter-
native 1 are based on extensive research conducted to
correlate the reduction of various pathogens in sewage
sludge to varying degrees of thermal treatment. The re-
sulting time-temperature relationship which is the basis for
Alternative 1 is shown in Figure 4-I. These requirements
are similar to the FDA requirements for treatment of egg-
nog, a food product with flow characteristics similar to those
of liquid sewage sludge. The Regimes A through D differ
depending on the characteristics of sewage sludge treated
and the type of process used because of the varying effi-
ciency of heat transfer under different conditions.
It is important to note that it is mandatory for all sew-
age sludge particles to meet the time-temperature re-
gime. Therefore, testing of temperatures throughout the
sewage sludge mass and agitating the material to ensure
uniformity would be appropriate. For processes such as
thermophilic digestion, it is important that the digester de-
sign not allow for short circuiting of untreated sewage
sludge. One approach that has been used to overcome
this problem has been to draw off treated sewage sludge
and charge feed intermittently with a sufficient time period
between draw-down and feeding to meet the time-tem-
perature requirement of Alternative 1. Another option would
be to carry out the process in two or more vessels in se-
ries so as to prevent bypassing.
These time-temperature regimes are not intended to be
used for composting (the time-temperature regime for
composting is covered in Alternative 5: Processes to Fur-
ther Reduce Pathogens).
A more conservative equation is required for sewage
sludges with 7% or more solids (i.e., those covered by
Regimes A and B) because these sewage sludges form
an internal structure that inhibits the mixing that contrib
utes to uniform distribution of temperature. The more strin-
gent equation is also used in Regime C (even though this
regime applies to sewage sludges with less than 7% sol-
ids) because insufficient information is available to apply
the less stringent equation for times less than 30 minutes.
The time-temperature requirements apply to every par-
ticle of sewage sludge processed. Time at the desired tem-
perature is readily determined for batch or plug flow op-
erations, or even laminar flow in pipes. Time of contact
also can be calculated for a number of completely mixed
28
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Table 4-1. The Four Time-Temperature Regimes for Alternative 1 (Thermally Treated Sewage Sludge) [503.32(a)(3)]
Regime
Part 503 Section
Applies to
Required Time-
Temperature'
A
B
503.32(a)(3)(ii)(A)
503.32(a)(3)(ii)(B)
503.32(a)(3)(ii)(C)
503.32(a)(3)(ii)(D)
Sewage sludge with at least
7% solids (except those covered
by Regime B)
Sewage sludge with at least
7% solids that are small particles
heated by contact with either warmed
gases or an immiscible liquid
Sewage sludge with less than
7% solids treated in processes with
less than 30 minutes contact time
Sewage sludge with less than
7% solids treated in processes with
at least 30 minutes contact time
D=i3i,7Qannniio0-14001
t>50°C(122°F)2
D> 0.0139 (i.e.,20 minutes)3
D=131>70HQDOJ10°-1'10CI
t>50°C(122°F)2
D>1.74X10'4(i.e., 15
seconds)5
D=131 70(IPH£WO°-1'I<""
1.74X io -"(i.e.,15
seconds) < D<0.021 (i.e. 30
minutes )6
D = 50,070,000/10°-14001
t>50'C(122°F)2
D > 0.021 (i.e. 30 minutes)'
1D = time in days; t = temperature ('C).
2The restriction to temperatures of at least 50°C (122°F) is imposed because information on the time-temperature relationship at lower temperatures
is uncertain.
3A minimum time at 20 minutes is required to ensure that the sewage sludge has been uniformly heated.
4Two examples of sewage sludge to which this requirement applies are:
. Sewage sludge cake that is mixed with previously dried solids to make the entire mass a mixture of separate particles, and is then dried by
contact with a hot gas stream in a rotary drier.
. Sewage sludge dried in a multiple-effect evaporator system in which the system sludge particles are suspended in a hot oil that is heated by
indirect heat transfer with condensing steam.
5Time-at-temperature of as little as 15 seconds is allowed because, for this type of sewage sludge, heat transfer between particles and the healing
fluid is excellent. Note that the temperature is the temperature achieved by the sewage sludge particles, not the temperature of the carrier medium.
6Time-at-temperature of as little as 15 seconds is allowed because heat transfer and uniformity of temperature is excellent in this type of sewage
sludge. The maximum time of 30 minutes is specified because a less stringent regime (D) applies when time-at-temperature is 30 minutes or more.
Time-at-temperature of at least 30 minutes is required because information on the effectiveness of this time-temperature regime for reducing
100
90
80
70
60
50
40
• Ascaris (Feachem)
+ Salmonellae (Feachem)
• EPA Thermal Process
X PHS - FDA, Eggnog
6
-1012345
Logarithm of Time (Log Sec)
Figure 4-I. EPA's time-temperature relationship for thermal disinfection compared with other time-temperature relationships.
29
-------
reactors in series (Schafer, et al, 1994). However, there
are concerns that flow-through systems may permit some
sludge to pass through without adequate treatment. It is
recommended that facilities wishing to use this alternative
for a flow-through system conduct tracer studies to dem-
onstrate that sewage sludge is treated at the required tem-
perature for sufficient time.
Vector Attraction Reduction
Thermally treated sewage sludge must be treated by an
additional vector attraction reduction process since ther-
mal treatment does not necessarily break down the vola-
tile solids in sewage sludge. Vector attraction reduction
can be met by further processing the sewage sludge with
pH adjustment or heat drying (Options 6 and 7), or by
meeting one of the other options (Options 8-11). Options
1 through 5 would not be applicable to thermally treated
sludge unless the sludge were subject to biological diges-
tion after or during thermal treatment.
Example of Meeting Class A Pathogen
and Vector Attraction Reduction
Requirements
Type of Facility
Class
Testing
Vector Attraction
Reduction
Use or Disposal
Thermophilic Anaerobic Digester
A
Digested sewage sludge is retained
for at least 5 days at 50* C (Regime
D). Sewage sludge is agitated regu-
larly to ensure thorough mixing, and
temperatures are monitored con-
tinually in a batch mode of opera-
tion.
Sewage sludge is sampled 6 times
each year for pollutants and fecal
conforms: Compliance wiih vector
attraction reduction is also moni-
tored.
VAR is met by reducing volatile sol-
ids by over 38 percent. Five
samples of input and output sew-
age sludge from each batch are
analyzed for volatile solids content
over a period of two weeks.
The Class A biosolids are land ap-
plied.
Microbiological Microbiological
Requirement
Microbiological monitoring for either fecal coliforms or
Salmonella sp. is required to ensure that growth of bacte-
rial pathogens has not occurred.
4.5 Alternative 2: Sewage Sludge Treated in
a High pH-High Temperature Process
(Alkaline Treatment) [503.32(a)(4)]
This alternative describes conditions of a high tempera-
ture-high pH process that has proven effective in reducing
pathogens to below detectable levels. The process condi-
tions required by the Part 503 regulation are:
. Elevating pH to greater than 12 and maintaining the
pH for more than 72 hours.
. Maintaining the temperature above 52°C (126°F)
throughout the sewage sludge for at .least 12 hours
during the period that the pH is greater than 12.
. Air drying to over 50% solids after the 72-hour period
of elevated pH.
The hostile conditions of high pH, high temperature, and
reduced moisture for prolonged time periods allow a vari-
ance to a less stringent time-temperature regime than for
the thermal requirements under Alternative 1. The pH of
the sewage sludge is measured at 25°C (77°F) or an ap-
propriate correction is applied (see Section 10.7).
Example of Meeting Class A Pathogen arid
Vector Attraction Reduction '-.--•'
Type of Process
Class
Pathogen Reduction
Testing
: Alkaline Treatment
Alkaline material is used to bring
sewage sludge pH to 12 for 72
hours during which time tempera-
tures are above 52°C for 72 hours.
Sewage sludge is agitated during
the heat pulse phase to maintain
even distribution, and tempera-
ture and pH are measured at
multiple points within the sewage
sludge. The sewage sludge is
then moved to piles and main-
tained until moisture is reduced to
50 percent.
Piles are tested quarterly for pol-
lutants and Salmonella sp.
Samples are taken from stock-
piled material, and material is not
distributed for use or disposal until
test results are received.
VAR Option 6, pH adjustment; pH
to remain elevated until
use/disposal
During winter months (Nov -
March), biosolids remain on site.
In the spring, biosolids are re-
tested for pathogens before be-
ing distributed.
Operational Issues
Because the elevated pH and temperature regimes must
be met by the entire sewage sludge mass, operational pro-
tocols which include monitoring pH and temperature at
various points in a batch and agitating the sewage sludge
during operations to ensure consistent temperature and
pH are appropriate.
Vector Attraction
Reductions
Use or Disposal
30
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Vector A ttraction Reduction
The pH requirement of vector attraction reduction Op-
tion 6 is met when Alternative 2 is met. Compliance with
Alternative 2 exceeds the pH requirements of Option 6.
Microbiological Requirements
As with all the Class Aalternatives, microbiological moni-
toring for fecal coliforms or Salmonella sp. is required (see
Section 4.3) to ensure that pathogens have been reduced
and growth of pathogenic bacteria has not occurred.
4.6 Alternative 3: Sewage Sludge Treated in
Other Processes [503.32(a)(5)]
This alternative applies to sewage sludge treated by pro-
cesses that do not meet the process conditions required
by Alternatives 1 and 2. This requirement relies on com-
prehensive monitoring of bacteria, enteric viruses and vi-
able helminth ova to demonstrate adequate reduction of
pathogens:
• Either the density of fecal coliforms in the sewage
sludge must be less than 1000 MPN per gram of total
solids (dry weight basis), or the Salmonella sp. bacte-
ria in sewage sludge must be less than 3 MPN per 4
grams of total solids (dry weight basis) at the time the
sewage is used or disposed, at the time the sewage
sludge is prepared for sale or given away in a bag or
other container for land application, or at the time the
sewage sludge or material derived from the sewage
sludge is prepared to meet the requirements in
503.10(b), 503.10(c), 503.10(6), or503.10(f).
. The density of enteric viruses in the sewage sludge
after pathogen treatment must be less than 1 PFU per
4 grams of total solids (dry weight basis).
. The density of viable helminth ova in the sewage
sludge after pathogen treatment must be less than 1
per 4 grams of total solids (dry weight basis).
Testing for enteric viruses and viable helminth ova can
be complicated by the fact that they are sometimes not
present in the untreated sewage sludge. In this case, an
absence of the organisms in the treated sewage sludge
does not demonstrate that the process can reduce them
to below detectable limits. For this reason, Alternative 3
requires that the feed sewage sludge be analyzed for en-
teric viruses and viable helminth ova. If these organisms
are not detected in the feed sewage sludge, the sewage
sludge is presumed to be acceptable as a Class A mate-
rial until the next monitoring episode. Monitoring is contin-
ued until enteric viruses and/or viable helminth ova are
detected in the feed sewage sludge (i.e., the density of
enteric viruses is greater than or equal to 1 PFU per 4
grams total solids (dry weight basis) and/or the density of
viable helminth ova is greater than or equal to 1 per 4grams
total solids (dry weight basis). At this point, the treated
sewage sludge is analyzed to see if these organisms sur-
vived treatment. If enteric viruses densities are below de-
tection limits, the sewage sludge meets Class A require-
ments for enteric viruses, and will continue to do so as
long as the treatment process is operated under the same
conditions that successfully reduced the enteric virus den-
sities. If the viable helminth ova densities are below detec-
tion limits, the process meets the Class A requirements for
enteric viruses and will continue to do so as long as the
treatment process is operated under the same conditions
that successfully reduced the viable helminth ova densi-
ties. Thus, it is essential to monitor and document operat-
ing conditions until adequate enteric virus and helminth
ova reduction have been successfully demonstrated.
Samples of untreated and treated sewage sludge must
correspond (see Section 7.4).
Enteric Virus and Viable Helminth Ova
Testing
Tests for enteric viruses and viable helminth ova take
substantial time: 4 weeks to determine whether helminth
ova are viable, and 2 weeks or longer for enteric viruses.
The treatment works operator does not know whether the
feed sewage sludge has enteric viruses or helminth ova
until at least 2 to 4 weeks after the first samples for testing
feed densities are taken. This works with rapid processes
but long-term process systems need to have temporally
related samples. In such cases, it may be feasible to ob-
tain results within the processing time constraints. For en-
teric viruses, the sewage sludge should be stored frozen,
unless the sample can be processed within 24 hours, in
which case the samples may be stored at 4°C (39°F). For
viable helminth ova, the sewage sludge should be stored
at 4°C (39°F) (see Section 9.6).
Finding a laboratory that performs viable helminth ova
and virus testing has been difficult for some sewage sludge
preparers. Chapter 9 has more information on how to se-
lect a laboratory. State and Regional EPA sludge coordi-
nators should also be contacted for information on quali-
fied labs in the region.
Since this option relies on testing, rather than process
and testing, to protect public health additional testings
should be completed. At a minimum, a detailed sampling
plan should be submitted to the permitting authority for
review.
Vector A ttractiun Reduction
For both Alternatives 3 and 4, meeting vector attraction
reduction depends on the process by which pathogen re-
duction is met. For example, sewage sludge subject to long
term storage may meet vector attraction reduction through
volatile solids reduction (Options 1 - 3). Sewage sludges
may also undergo additional processing or be applied fol-
lowing the requirements in Options 8-11.
Microbiological Requirements
As with all the Class A alternatives, microbiological moni-
toring for fecal coliforms or Salmonella sp. is required (see
Section 4.3) to ensure that pathogens have been reduced
and growth of pathogenic bacteria has not occurred.
31
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4.7 Alternative 4: Sewage Sludge Treated in
Unknown Processes [503.32(a)(6)]
The sewage sludge
time the biosolids (or
used or disposed , at
pared for sale or given
land application, or at
terial derived from the
the requirements in
503.1 0(f):
must meet the following limits at the
material derived from sludge) are
the time the sewage sludge is pre-
away in a bag or other container for
the time the sewage sludge or ma-
sewage sludge is prepared to meet
503.10(b),503.10(c),503.10(e),or
• The density of enteric viruses in the sewage sludge
must be less than 1 PFU per 4 grams of total solids
(dry weight basis).
. The density of viable helminth ova in the sewage
sludge must be less than 1 per 4 grams of total solids
(dry weight basis).
In addition, as for all Class A biosolids, the sewage sludge
must meet fecal coliform or Salmonella sp. limits. As with
Alternative 3, Alternative 4 depends on a successful sam-
pling program that provides accurate representation of the
sewage sludge's microbial quality (see Chapter 9).
Example Of Meeting Class A Pathogen And Vector
Attraction Reduction
Type of Facility Unknown Process
Class A
Pathogen Reduction Sewage Sludge is digested 'arid
retained in a lagoon for up to 2
years. Sewage sludge is then
mpvedctooa stockpilingjarea where
it may st^.v for up to 2 years.
Testing Before sewage sludge is'distrib-
uted, each pjle, representing ap-
fproximatetyl 1 yyeartoff sewage
sludge production, is tested 'for
Salmonella sp., viable helminth
ova, and enteric viruses. Since
quarterly testing, is mandated,
based on the amount of sewage
sludge which is used or disposed,
four samples per pife are submit-
ted.
Vector Attraction VAR is demonstrated by showing
Reduction a 38 percent reduction -in vqlatile
Solids. Records of 'incoming ma-
terial and volume, bulk density,
and percent volatile solids of out-
' going material are used to calcu-
late the reduction.
Distribution Biosolids are distributed for land
application oh agricultural land.
Examples of situations where Alternative 4 may be used:
. Sewage sludge treatment process is unknown.
. The sewage sludge was produced with the process
operating at conditions less stringent than the operat-
ing conditions at which the sewage sludge could qualify
as Class A under other alternatives.
Enteric Virus and Viable Helminth Ova
Testing
Tests for enteric viruses and viable helminth ova take
substantial time: 4 weeks to determine whether helminth
ova are viable, and 2 weeks or longer for enteric viruses.
The treatment works operator does not know whether the
feed sewage sludge has enteric viruses or helminth ova
until at least 2 to 4 weeks after the first samples for testing
feed densities are taken. This option works with rapid pro-
cesses but long-term process systems need to have tem-
porally related samples. In such cases, it may be feasible
to obtain results within the processing time constraints.
For enteric viruses, the sewage sludge should be stored
frozen, unless the sample can be processed within 24
hours, in which case the samples may be stored at 4°C
(39°F). For viable helminth ova, the sewage sludge should
be stored at 4°C (39°F) (see Section 9.6).
Finding a laboratory that performs viable helminth ova
and virus testing has been difficult for some sewage sludge
preparers. Chapter 9 has more information on how to se-
lect a laboratory. State and Regional EPA sludge coordi-
nators should also be contacted for information on quali-
fied labs in the region.
Since this option relies on testing, rather than process
and testing, to protect public health additional testings
should be completed. At a minimum, a detailed sampling
plan should be submitted to the permitting authority for
review.
Vector A ttraction Reduction
For both Alternatives 3 and 4, meeting vector attraction
reduction depends on the process by which pathogen re-
duction is met. For example, sewage sludge subject to long-
term storage may meet vector attraction reduction through
volatile solids reduction (Options I-3). Sewage sludges
may also undergo additional processing or be applied fol-
lowing the requirement in Options 8-11.
4.8 Alternative 5: Use of PFRP [503.32(a)(7)]
Alternative 5 provides continuity with the 40 CFR Part
257 regulation. This alternative states that sewage sludge
is considered to be Class A if:
. It has been treated in one of the Processes to Further
Reduce Pathogens (PFRPs) listed in Appendix B of
the regulation, and
. Either the density of fecal coliforms in the sewage
sludge is less than 1,000 MPN per gram total solids
(dry weight basis), or the density of Salmonella sp.
bacteria in the sewage sludge is less than 3 MPN per
4 grams total solids (dry weight basis) at the time the
sewage sludge is used or disposed, at the time the
sewage sludge is prepared for sale or give away in a
bag or other container for land application, or at the
32
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time the sewage sludge or material derived from the
sewage sludge is prepared to meet the requirements
in 503.10(b), 503.10(c), 503.10(e), or 503.10(f).
To meet this requirement, the sewage sludge treatment
processes must be operated according to the conditions
listed in Appendix B of the regulation.
The Appendix B list of PFRPs is reproduced in Table 4-
2. This list is very similar to the PFRP technologies listed
in 40 CFR Part 257, with two major differences:
. All requirements related to vector attraction reduction
have been removed.
• All the "add-on" processes listed in Part 257 are now
full-fledged PFRPs.
Under this Alternative, treatment processes classified as
PFRP under 40 CFR Part 257 can continue to be oper-
ated; however, microbiological monitoring must now be
performed to ensure that the pathogen density levels are
below detection limits and to ensure that growth of Salmo-
nella sp. bacteria does not occur between treatment and
use or disposal.
For all PFRP processes, the goal of temperature moni-
toring should be to represent all areas of a batch or pile
and to ensure that temperature profiles from multiple points
in the process all meet mandated temperatures. In some
instances it may be possible to monitor representative ar-
eas of a batch or pile or a reasonable worst case area to
insure compliance. Chapter 7 contains more guidelines
about the operation of PFRP processes.
4.9 Alternative 6: Use of a Process
Equivalent to PFRP [503.32(a)(8)]
The 40 CFR Part 257 regulation allowed any treatment
process to be determined equivalent to a PFRP. Under
Alternative 6, sewage sludge is considered to be a Class A
sewage sludge if:
• It is treated by any process equivalent to a PFRP, and
• Either the density of fecal coliforms in the sewage
sludge is less than 1,000 MPN per gram total solids
(dry weight basis), or the density of Salmonella sp.
bacteria in the sewage sludge is less than 3 MPN per
4 grams total solids (dry weight basis) at the time the
sewage sludge is used or disposed, at the time the
sewage sludge is prepared for sale or give away in a
bag or other container for land application, or at the
time the sewage sludge or material derived from the
sewage sludge is prepared to meet the requirements
in 503.1 0(b), 503.1 0(c), 503.10(e), or 503.1 0(f).
Facilities that meet Alternative 6 for pathogen reduction
must still meet vector attraction reduction requirements.
Processes Already Recommended as
Equivalent
Processes recommended to be equivalent to PFRP are
shown in Table 11.2. Products of all equivalent processes
must still meet the Class A fecal coliform or Salmonella sp.
requirements.
Who Determines Equivalency?
Part 503 gives the permitting authority responsibility for
determining equivalency under Alternative 6. The EPA's
Pathogen Equivalency Committee (PEC) is available as a
resource to provide guidance and recommendations on
equivalency determinations to both the permitting author-
ity and the regulated community (see Chapter 11).
4.10 Frequency of Testing
The Part 503 regulation sets forth minimum sampling
and monitoring requirements. Table 3-4 in Chapter 3 de-
Table 4-2. Processes to Further Reduce Pathogens (PFRPs) Listed in Appendix B of 40 CFR Part 503'
Composting
Heat Drying
Heat Treatment
Thermophilic Aerobic Digestion
Beta Ray Irradiation
Gamma Ray Irradiation
Pasteurization
Using either the within-vessel composting method or the static aerated pile composting method, the
temperature of sewage sludge is maintained at 55°C (131°F) or higher for 3 consecutive days.
Using the windrow composting method, the temperature of the sewage sludge is maintained at 55°C
(131°F) or higher for 15 consecutive days or longer. During the period when the compost is maintained at
55°C (131°F) or higher, there shall be a minimum of five turnings of the windrow.
Sewage sludge is dried by direct or indirect contact with hot gases to reduce the moisture content of the
sewage sludge to 10% or lower. Either the temperature of the sewage sludge particles exceeds 80°C
(176°F) or the wet bulb temperature of the gas in contact with the sewage sludge as the sewage sludge
leaves the dryer exceeds 80°C (176°F).
Liquid sewage sludge is heated to a temperature of 180°C (356°F) or higher for 30 minutes.
Liquid sewage sludge is agitated with air or oxygen to maintain aerobic conditions and the mean cell
residence time (i.e., the solids retention time) of the sewage sludge is 10 days at 55°C (131°F) to 60°C
(140°F).
Sewage sludge is irradiated with beta rays from an electron accelerator at dosages of at least 1.0 megarad
at room temperature (ca. 20°C [68°F]).
Sewage sludge is irradiated with gamma rays from certain isotopes, such as Cobalt 60 and Cesium 137, at
dosages of at least 1 .0 megarad at room temperature (ca. 20°C [68°F])-
The temperature of the sewage sludge is maintained at 70°C (158°F) or higher for 30 minutes or longer.
1 Chapter 7 provides a detailed description of these technologies.
33
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scribes the minimum frequency frequency at which the
sewage sludge must be sampled and analyzed for patho-
gens or vector attraction reduction in order to meet regula-
tory requirements. In addition to meeting these minimal
requirements, the EPA recommends that sewage sludge
generators and preparers also consider the potential pub-
lic health impact pathways and possible liability issues
when designing a sampling program. In some cases, it
may be appropriate to sample more frequently than the
required minimum.
Classification of biosolids as Class A or Class B is based
on the most recent test results available. For example, if a
facility produces a Class A compost, and sampling is per-
formed once each quarter, the compost produced after
each test result verifying Class A is returned is also as-
sumed to be Class A, assuming that the same process
continues to be followed. If a test result indicates that com-
post is not achieving Class A, all compost subsequently
generated would be classified as Class B (assuming it
meets Class B requirements). The Class B classification
would remain until a test result confirming Class A quality
is returned.
This raises several issues. Land application of Class B
biosolids without site restrictions is a violation of the 503
regulation. In addition, if material is mistakenly classified
as EQ biosolids and land applied without restriction to the
public, the biosolids preparer may be inadvertently creat-
ing a public health risk as well as opening the facility to
liability. The key issues to consider are:
At what point between the two sampling events does
the material change from C/ass A to C/ass B? This de-
pends on the particular situation. The Class B test result
may be an exception - the result of cross contamination
or faulty sampling or monitoring for one pile. On the other
hand, the test result could be indicative of an operation
which is not adequately reducing pathogens. The piles
which were actually sampled may have been used or dis-
tributed under the classification of the previous lab results
while lab results were pending (it generally takes 2 weeks
to get lab results back). Because distribution of this mate-
rial as Class A would constitute a violation of the Part 503
regulation, it is recommended that material generated dur-
ing and subsequent to a sampling event remain on site
until lab results are available.
What can you do if you suspect Class B biosolids
has been distributed as Class A biosolids? The first
question to answer is: has this material created a public
health risk. The material should be resampled to deter-
mine if it is indeed Class B and not Class A. The Part 503
requires that Class A biosolids meet either the fecal coliform
or the Salmonella sp. requirements (except for Alterna-
tives 3 and 4). If the material is out of compliance for fecal
coliforms, it should immediately be tested for Salmonella
sp. (and vice versa). In addition, the validity of the test
resujts should be checked by contacting the lab and re-
viewing the data.
Material distribution should then be tracked to determine
where material has been used. Businesses and individu-
als to whom material has been distributed should be noti-
fied and informed of the potential quality issue. If material
is stockpiled at distribution points such as at a soil blender
or landscaper, the material should be retested for patho-
gen levels, and distribution be curtailed until the process
is reviewed and acceptable results are achieved. The fa-
cility may even consider recalling the biosolids from the
users.
If material has already been distributed to public access
areas, including homes, gardens, parks, or other public
areas, the biosolids preparer may consider testing the soil.
If the testing indicates problems, corrective actions may
be necessary.
How can a situation like this be avoided? There are
several sampling practices that a facility should follow in
order to avoid a situation like this.
First, sampling should take place close enough to the
time of distribution so that results accurately reflect mate-
rial quality.
If possible, material sampled and subsequently produced
material should not be distributed until the results are avail-
able; there is usually a 2-week waiting period for lab re-
sults for fecal coliform or Salmonella sp. analysis.
More frequent sampling can help pinpoint when opera-
tional conditions change. This may allow more rapid cor-
rection of operations.
Stockpile biosolids in discrete batches and take multiple
samples per sampling event. This will allow better identifi-
cation of which piles may be out of compliance and will
allow for the distribution of material that is identified as
Class A.
References and Additional Resources
Barker, T.A. 1970. Pasteurization and sterilization of slud-
ges. Proc. Biochem, August, p 44-45.
Farrell, J.B., J.E. Smith, Jr., S.W. Hathaway, and R.B. Dean.
1974. Lime stabilization of primary sludges. J. WPCF
46(1): 113-122.
Farrell, J.B. 1993. Fecal pathogen control during composting.
p 282-300 in "Science & Engineering of Composting:
Design, Environmental, Microbiological, and Utilization
Aspects." edit. H.A. J. Hoitink and H.M. Keenerg.
Feachem, R-G., DJ. Bradley, H. Garelick, and D.D. Mara.
1983. "Sanitation and Disease: Health Aspects of Ex-
creta and Wastewater Management." Pub. for World
Bank by J. Wiley and Sons, NY.
Foess, Gerald W, and Ronald B. Sieger. 1993. Pathogen/
vector attraction reduction requirements of the sludge
rules. Water/Engineering & Management, June, p 25
IRGRD (International Research Group on Refuse Disposal)
1968. Information Bulletin No. 21-31. August 1964 -
December 1967. p 3230 - 3340. Reprinted by US Dept.
HEW, Bureau of Solid Waste Management (1969).
34
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Lee, K.M., C.A. Brunner, J.B.Farrell, and A.E. Eralp. 1989.
Destruction of enteric bacteria and viruses during two-
phase digestion. J. WPCF 61(8): 1422-1 429.
Martin, J.H., Jr., H.E. Bostian, and G. Stern. 1990. Reduc-
tion of enteric microorganisms during aerobic sludge
digestion. Wat. Res. 24(11):1377-l 385.
Schafer, P.L., J.B. Farrell, W.R. Uhte, and B. Rabinowitz.
1994. Pre-pasteurization, European and North Ameri-
can assessment and experience, p 10-39 to 10-50 in
"The Management of Water and Wastewater Solids
for the 21st Century: A Global Perspective." Confer-
ence Proceedings, June 19-22, 1992. Water Environ-
ment Federation.
U.S. Dept. of Health & Human Services. 1989. Grade A
Pasteurized Milk Ordinance, 1989 Revision, Public
Health Service/Food and Drug Administration Publi-
cation No. 229.
U.S. EPA. 1992. Technical support document for Part 503
pathogen and vector attraction reduction requirements
in sewage sludge. NTIS No: PB93-11069. Springfield,
VA: National Technical Information Service.
Yanko, W.A. 1987. Occurrence of pathogens in distribu-
tion and marketing municipal sludges. Report No.: EPA/
600/1-87/01 4. (NTIS: PB88-154273/AS.) Springfield,
VA: National Technical Information Service.
35
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Chapter 5
Class B Pathogen Requirements and Requirements for Domestic Septage
Applied to Agricultural Land, a Forest, or a Reclamation Site
5.1 Introduction
Class B pathogen requirements can be met in three dif-
ferent ways. The implicit objective of all three alternatives
is to ensure that pathogenic bacteria and enteric viruses
are reduced in density, as demonstrated by a fecal coliform
density in the treated sewage sludge (biosolids) of 2 mil-
lion MPN or CPU per gram total solids biosolids (dry weight
basis)'. Viable helminth ova are not necessarily reduced
in a Class B biosolids.
Unlike Class A biosolids, which are essentially patho-
gen free, Class B biosolids may contain some pathogens.
Site restrictions that restrict crop harvesting, animal graz-
ing, and public access for a certain period of time are re-
quired. This allows environmental factors to further reduce
pathogens. Where appropriate, these restrictions are de-
signed to ensure sufficient reduction in viable helminth ova,
one of the hardiest of pathogens, since these pathogens
may not have been reduced during sewage sludge treat-
ment.
The Class B requirements apply to bulk biosolids that
are land applied to such areas as agricultural land, for-
ests, public contact sites, or reclamation sites. Biosolids
that are placed on a surface disposal site also must meet
the Class B pathogen requirements, unless the active
biosolids unit on which the biosolids are placed is covered
at the end of each operating day (see Table 3-I). Because
the use of Class B biosolids must be closely monitored,
Class B biosolids cannot be given away or sold in bags or
other containers.
Domestic septage applied to agricultural land, forest, or
a reclamation site must meet all of the Class B site restric-
tions under 503.32(b)(5) unless the domestic septage has
met specific pH requirements (see Section 5.6).
'Farrell et al. (1985) have shown that if a processed sewage sludge is processed
by aerobic or anaerobic digestion it has a fecal coliform density of 2 million MPN or
CPU per gram, enteric viruses and bacteria are significantly reduced. A comparison
of suspended solids densities in entering wastewater to suspended solids densities
in treated sewaae sludpe shows that this density of fecal coliform in treated sew-
age sludge represents a 1 00-fold (Z-log) reduction in fecal coliform density, and is
expected to correlatewith an approximately 1.5 log (approximately 32-fold) reduc-
tion in Salmonella sp. density and an approximately 1.3 log (20-fold) reduction in
the density of enteric viruses.
Class B biosolids and domestic septage also must mee?
one of the vector attraction reduction requirements (see
Chapter 8). Note that the choice of vector attraction op-
tions may affect the duration of site restrictions in some
cases. Specifically, if Option 9 or 10 (injection or incorpo-
ration) is used to reduce vector attraction, the restriction
on harvesting for food crops grown below the soil surface
(potatoes, carrots, etc.) is increased from 20 months to 38
months.
Sections 5.2 to 5.4 discuss the three alternative Class B
pathogen requirements for sewage sludge. Section 5.5
discusses the site restrictions for land applied Class B
biosolids, and Section 5.6 presents the requirements for
domestic septage applied to agricultural land, forests, or
reclamation sites. The title of each section provides the
number of the Subpart D requirement discussed in the
section. A copy of Subpart D can be found in Appendix B.
Chapters 9 and 10 provide guidance on the sampling and
analysis necessary to meet the Class B microbiological
requirements.
5.2 Sewage Sludge Alternative 1:
Monitoring of Fecal Coliform
[503.32(b)(2)]
Alternative 1 requires that seven samples of treated sew-
age sludge (biosolids) be collected and that the geometric
mean fecal coliform density of these samples be less than
2 million CPU or MPN per gram of biosolids (dry weight
basis). This approach uses fecal coliform density as an
indicator of the average density of bacterial and viral patho-
gens. Over the long term, fecal coliform density is expected
to correlate with bacterial and viral pathogen density in
biosolids treated by biological treatment processes (EPA,
1992).
Use of at least seven samples is expected to reduce the
standard error to a reasonable value. The standard devia-
tion can be a useful predictive tool. A relatively high stan-
dard deviation for the fecal coliform density indicates a wide
range in the densities of the individual samples. This may
be due to sampling variability or variability in the labora-
tory analysis, or it may indicate that the treatment process
is not consistent in its reduction of pathogens. A high stan-
dard deviation can therefore alert the preparer that the
sampling, analysis, and treatment processes should be
reviewed.
36
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Each of the multiple samples taken for fecal coliform
analysis should be taken at the same point in the process
so that treatment of each sample has been equal. Samples
must be handled correctly and analyzed within 24 hours in
order to minimize the effect of the holding time of the sample
on the microbial population.
Laboratory sampling should follow Standard Methods
as outlined in the Appendix of this document. Standard
QA/QC practices, including duplicates to verify laboratory
Calculating the Geometric Mean for Class B Alternative 1
. Take seven samples over a 2-week period.
. Analyze samples for fecal coliform using the membrane
filter or MPN dilution method.
. Take the log (Base 10) of each result.
. Take the average (arithmetic) of the logs.
. Take the anti-log of the arithmetic average. This is ttie
geometric mean of the results.
Example: The results of analysis of seven samples of sew-
age sludge are shown below. The second column of the
table shows the log of each result.
(MPN/dry gram
sewage sludge)
Sample 1
Sample 2
Sample 3
Sample 4
Sample 5
Sample 6
Sample 7
Average (Arithmetic)
Antilog (geometric mean)
Log standard deviation
Fecal Coliform
Log
6.4 x106
4.8 x104
6.0 x105
5.7 x105
5.8X105
4.4 x106
6.2 x 10'
6.81
4.68
5.78
5.76
5.76
6 .64
7.80
6.18
1.5x106
1.00*
Note that this sewage sludge would meet Class B fecal
coliform requirements even though several of the analysis
results exceed the 2.0 x 1 06/dry gram limit.
. Duplicate analyses on the same sample would give a
much lower standard deviation. Variability is inflated by dif-
ferences in feed and product over a 2-week sampling pe-
riod.
protocols should be followed. Generally a log standard
deviation between duplicate samples under 0.3 is accept-
able for lab analyses.
Process parameters including retention time and tem-
perature should be examined in order to verify that the
process is running as specified. Monitoring equipment
should be calibrated regularly.
The seven samples should be taken over a 2-week pe-
riod in order to represent the performance of the facility
under a range of conditions. For small facilities that are
required to sample infrequently, sampling should be per-
formed under worst case conditions, for example, during
the winter when the climatic conditions are the most ad-
verse.
It has been found that for Class B compliance, the
MPN dilution method for fecal coliform analysis is more
appropriate than the membrane filtration test. This is
because colloidal and suspended solids may interfere with
media transport through the membrane filter. Furthermore,
concentration of toxic or inhibitory substances at the filter
surface may affect results. It is therefore recommended
that the membrane filter procedure be used only after dem-
onstrating comparability between the membrane filter test
and the MPN method for a given sewage sludge.
Example of Meeting Class B Pathogen and'
"Vector'Attraction" Reduction' Requirements
Type of Facility
Class
Pathogen Reduction
Testing
Vector Attraction
Reduction
Use' or Disposal
Extended Aeration
B
: Quarterly testing, for pollutants
: and for fecal coliform to determine
if Class B, Alternative 1 require-
ments are met. ,
The SOUR test is used to
demonstrate compliance with
VAR Option 4.
The Class B biosolids are
delivered to farmers along with
, information regarding analysis
and site restrictions.,
5.3 Sewage Sludge Alternative 2: Use of a
Process to Significantly Reduce
Pathogens (PSRP) [503.32(b)(3)]
The PSRP Class B alternative provides continuity with
the 40 CFR Part 257 regulation. Under this Alternative,
treated sewage sludge (biosolids) is considered to be Class
B if it is treated in one of the "Processes to Significantly
Reduce Pathogens" (PSRPs) listed in Appendix B of Part
503. The biological PSRP processes are sewage sludge
treatment processes that have been demonstrated to re-
sult in a 2-log reduction in fecal coliform density. See chap-
ter 7.
The PSRPs in the Part 503 are reproduced in Table 5-I
and described in detail in Chapter 6. They are similar to
the PSRPs listed in the Part 257 regulation, except that all
conditions related to reduction of vector attraction have
been removed. Under this alternative, sewage sludge
treated by processes that are PSRPs under 40 CFR Part
257 are Class B with respect to pathogens. Unlike the com-
parable Class A requirement (see Section 4.8), this Class
B alternative does not require microbiological monitoring.
37
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However, monitoring of process requirements such as time,
temperature, and pH is required.
Table 5-1. Processes to Significantly Reduce Pathogens (PSRPs)
Listed in Appendix B of 40 CFR Part 503
1. Aerobic Digestion Sewage sludge is agitated with air or
oxygen to maintain aerobic conditions for a
specific mean cell residence time (i.e.,
solids retention time) at a specific
temperature. Values for the mean cell
residence time and temperature shall be
between 40 days at 20°C (68°F) and 60
daysat15°C(59°F).
2. Air Drying Sewage sludge is dried on sand beds or
on paved or unpaved basins. The sewage
sludge dries for a minimum of 3 months.
During 2 of the 3 months, the ambient
average daily temperature is above 0°C
(32°F).
3. Anaerobic Digestion Sewage sludge is treated in the absence of
air for a specific mean cell residence time
(i.e., solids retention time) at a specific
temperature. Values for the mean cell
residence time and temperature shall be
between 15 days at 35°C to 55°C (131 °F)
and 60 days at 20°C (68°F).
4. Composting Using either the within-vessel, static
aerated pile, or windrow composting
methods, the temperature of the sewage
sludge is raised to 40°C (104°F) or higher
and remains at 40°C (104°F) or higher for
5 days. For 4 hours during the 5day
period, the temperature in the compost pile
exceeds 55°C(131°F).
5. Lime Stabilization Sufficient lime is added to the sewage
sludge to raise the pH of the sewage
sludge to 12 for $2 hours of contact.
5.4 Sewage Sludge Alternative 3: Use of
Processes Equivalent to PSRP
[503.32(b)(4)]
The Part 257 regulation allowed the sewage sludge to
be treated by a process determined to be equivalent to a
PSRP. Under Class B Alternative 3, sewage sludge treated
by any process determined to be equivalent to a PSRP is
considered to be Class B biosolids. A list of processes that
have been recommended as equivalent to PSRP are
shown in Table 11.1.
Part 503 gives the regulatory authority responsibility for
determining equivalency. The Pathogen Equivalency Com-
mittee is available as a resource to provide guidance and
recommendations on equivalency determinations to the
regulatory authorities (see Chapter 11).
5.5 Site Restrictions for Land Application of
Biosolids [503.32(b)(5)]
Potential exposure to pathogens in Class B biosolids
via food crops is a function of three factors: first there must
be pathogens in the biosolids; second, the application of
Class B biosolids to food crops must transfer the patho-
gens to the harvested crop, and third, the crop must be
ingested before it is processed to reduce the pathogens.
Elimination of one of these steps eliminates the pathway
by which public's health may be affected. The use of Class
A biosolids protects public health by reducing pathogens
in sewage sludge to below detectable levels. Biosolids that
meet the Class B requirements may contain reduced but
still significant densities of pathogenic bacteria, viruses,
protozoans, and viable helminth ova. Thus, site restrictions
are to allow time for further reduction in the pathogen popu-
lation. Harvest restrictions are imposed in order to reduce
the possibility that food will be harvested and ingested
before pathogens which may be present on the food have
died off. Harvest restrictions vary, depending on the type
of crop, because the amount of contact a crop will have
with biosolids or pathogens in biosolids varies.
The site restrictions are primarily based in the survival
rates of viable helminth ova, one of the hardiest of patho-
gens that may be present on sewage sludge. The survival
of pathogens, including the helminth ova, depends on ex-
posure to the environment. Some of the factors that affect
pathogen survival include pH, temperature, moisture, cat-
ions, sunlight, presence of soil microflora, and organic
material content. On the soil surface, helminth ova has
been found to die off within 4 months, but survival is longer
if pathogens are within the soil. Helminth ova have been
found to survive in soil for several years (Smith, 1997;
Kowal 1985). Site restrictions take this into account by
making a distinction between biosolids that are applied to
the land surface, biosolids that are incorporated into the
soil after at least 4 months on the soil surface, and biosolids
that are incorporated into the soil within 4 months of being
applied.
Site restrictions also take the potential pathways of ex-
posure into account. For example, crops that do not con-
tact the soil, such as oat or wheat, may be exposed to
biosolids, but pathogens on crop surfaces have been found
to be reduced very quickly (30 days) due to exposure to
sunlight, desiccation, and other environmental factors.
Crops that touch the soil, such as melons or cucumbers,
may also come into contact with biosolids particles, but
pathogens in this scenario are also subject to the harsh
effects of sunlight and rain and will die off quickly. Crops
grown in soil such as potatoes are surrounded by biosolids
amended soil, and pathogen die-off is much slower below
the soil surface.
These pathways should be considered when determin-
ing which site restriction is appropriate for a given situa-
tion. The actual farming and harvesting practices as well
as the intended use of the food crop should also be con-
sidered. For example, oranges are generally considered a
food crop that does not touch the ground. However, some
oranges grow very low to the ground and may come into
contact with soil. If the oranges that have fallen to the
ground or grew touching the ground are harvested for di-
rect consumption without processing, the 14-month har-
vest restriction for crops that touch the soil should be fol-
lowed. Orange crops which do not touch the ground at all
would not fall under the 14-month harvest restriction; har-
vest would be restricted for 30 days under 503.32(b)(5)(iv)
38
-------
which covers food crops that do not have harvested parts
in contact with the soil. For similar situations, the potential
for public health impacts must be considered. Harvest prac-
tices such as the use of fallen fruit or washing or process-
ing crops should be written into permits so that restrictions
and limits are completely clear. Figure 5-1 illustrates the
steps of exposure that should be considered when mak-
ing a decision about harvest and site restrictions. In addi-
tion, several examples of permit conditions are included.
The site restrictions for land applied Class B biosolids are
summarized below. The regulatory language is given in
italics. Note that the restrictions apply only to the harvest-
ing of food crops, but not to the planting or cultivation of
crops.
Food Crops with Harvested Parts That
Touch the Sewage Sludge/Soil Mixture
503.32(b)(5)(l): Food crops with harvested parts that
touch the sewage sludge/soil mixture and are total/y above
the land surface shall not be harvested for 14 months after
application of sewage sludge.
This time frame is sufficient to enable environmental
conditions such as sunlight, temperature, and desiccation
to further reduce pathogens on the land surface. Note that
the restriction applies only to harvesting. Food crops can
be planted at any time before or after biosolids applica-
tion, as long as they are not harvested within 14 months
Does sewage sludge comply with Class B
requirements?
No
Yes
Does sewage sludge comply with Class A
requirements?
No
Yes
Is the sewage sludge applied to a food crop?
Yes
No
Does the food crop touch the ground or will
fruit that falls on the ground be harvested?
Yes
No
Is it possible that harvested food will be
eaten raw or handled by the public?
Yes
No
Is the edible part of the crop grown below
the surface of the land?
Yes
No
Does the sewage sludge remain on the
surface of the land for more than 4 months
after application?
No
Yes
Harvest may not take place until 38 months
after application.
Must be diverted from land application.
Sludge can be land-applied without site
restrictions.
Site restrictions for sod farms, grazing
animals, or public access should be
followed.
Harvest may not take place until 30 days
after application.
Permitting authority may use discretion to
reduce waiting period from 14 months to 30
days, depending on the application.
Harvest may not take place until 14 months
ifter application.
Harvest may not take place until 20 months
after application.
Figure 5-1. Decision tree for harvesting and site restrictions.
39
-------
after sludge application. Examples of food crops grown on
or above the soil surface with harvested parts that typi-
cally touch the sewage sludge/soil mixture include lettuce,
cabbage, melons, strawberries, and herbs. Land applica-
tion should be scheduled so that crop harvests are not lost
due to harvest restrictions.
Food Crops with Harvested Parts Below the
Land Surface
503.32(b)(5)(ii): Food crops with harvested parts below
the surface of the land shall not be harvested for20 months
after application of sewage sludge when the sewage sludge
remains on the land surface for 4 months or longer prior to
incorporation into the soil.
Pathogens on the soil surface will be exposed to envi-
ronmental stresses which greatly reduce their populations.
Helminth ova have been found to die off after 4 months on
the soil surface (Kowal, 1994). Therefore, a distinction is
made between biosolids left on the soil surface for 4 months
and biosolids which are disced or plowed into soil more
quickly.
For a September 1999 harvest, biosolids could be ap-
plied to the soil surface up to the end of December 1997,
plowed or disced into the soil in April 1998, and the crop
planted in order to allow it to be harvested in September
1999. Examples of crops with harvested parts below the
Examples Of Site Restrictions for Questionable
Food Crop Situations
]
Tree Nut Crops - Nuts which are washed, hulled, and de-
hydrated before being distributed for'public consumption
must followthe 3Cklay restriction. Nuts which are harvested
from the ground and sold in their shell without processing
are subj ect to the 14-mohth restriction.
Sugar Beets - Sugar beets aren't expected to be. eaten
raw. If the beets are transported off site and considerable
biosolids amended soil is carried off with, them, the restric-
tions apply.: If biosblids are left on the 'soil surface for 4
months or longer before being incorporated, the 20-month
restriction 'applies.' If biosolids are incorporated within 4
months of application, the 38-month restriction applies.
Tomatoes (and peppers) - Fruit often comes in contact with
the ground. Tomatoes are sold both to processors and to
farm stands. Tomatoes may be eaten raw by the public
without further 'processing. The 14-month restriction ap-
plies.
land surface are potatoes, radishes, beets, onions and
carrots.
503.32(b)(5)(iii): Food crops with harvested parts below
the surface of the land shall not be harvested for38 months
after application of sewage sludge when the sewage sludge
remains on the land surface for less than 4 months prior to
incorporation info the soil.
Exposure of the surface of root crops such as potatoes
and carrots to viable helminth ova is a principal concern
under these circumstances. Four months is considered the
minimum time for environmental conditions to reduce vi-
able helminth ova in biosolids on the land surface. Class B
biosolids incorporated into the soil surface less than 4
months after application may contain significant numbers
of viable helminth ova. Once incorporated into the soil, die-
off of these organisms proceeds much more slowly; there-
fore, a substantially longer waiting period is required to
protect public health. Thirty-eight months after biosolids
application is usually sufficient to reduce helminth ova to
below detectable levels.
Food Crops, Feed Crops, and Fiber Crops
503.32(b)(5)(iv): Food crops, feed crops, and fiber crops
shall not be harvested for 30 days after application of sew-
age sludge,
This restriction covers food crops that are not covered
by 503.32(b)(l-iii) This would include crops with harvested
parts that do not typically touch the biosolids/soil mixture
and which are not collected from the ground after they have
fallen from trees or plants. The restriction also applies to
all feed and fiber crops. These crops may be exposed to
pathogens when biosolids are applied to the land. Har-
vesting of these crops could result in the transport of
biosolids pathogens from the growing site to the outside
environment. After 30 days, however, any pathogens in
biosolids that may have adhered to the crop during appli-
cation will likely have been reduced to non-detectable lev-
els. Hay, corn, soybeans, or cotton are examples of a crop
covered by this restriction.
Animal Grazing
503.32(b)(5)(v): Animals shall not be allowed to graze
on the land for 30 days after application of sewage sludge.
Biosolids can adhere to animals that walk on biosolids
amended land and thereby be brought into potential con-
tact with humans who come in contact with the animals
(for example, horses and milking cows allowed to graze
on a biosolids amended pasture). Thirty days is sufficient
to substantially reduce the pathogens in surface applied
biosolids, thereby significantly reducing the risk of human
and animal contamination.
Turf Harvesting
503.32(b)(5)(vi): Turf grown on land where sewage
sludge is applied shall not be harvested for 1 year after
application of the sewage sludge when the harvested turf
is placed on either land with a high potential for public ex-
posure or a lawn, unless otherwise specified by the per-
mitting authority.
The l-year waiting period is designed to significantly
reduce pathogens in the soil so that subsequent contact
40
-------
of the turf layer will not pose a risk to public health and
animals. A permitting authority may reduce this time pe-
riod in cases in which the turf is not used on areas with
high potential for public access.
Public Access
503.32(b)(5)(vii): Public access to land with a high po-
tential for public exposure shall be restricted for 1 year
after application of the sewage sludge.
As with the turf requirement above, a l-year waiting pe-
riod is necessary to protect public health and the environ-
ment in a potential high-exposure situation. A baseball dia-
mond, playground, public park, or a soccer field are ex-
amples of land with a high potential for public exposure.
The land gets heavy use and contact with the soil is sub-
stantial (children or ball players fall on it and dust is raised
which is inhaled and ingested).
503.32(b)(5)(viii): Public access to land with a low po-
tential for public exposure shall be restricted for 30 days
after application of the sewage sludge.
A farm field used to grow corn or soybeans is an ex-
ample of land with low potential for public exposure. Even
farm workers and family members walk about very little on
such fields. Public access restrictions do not apply to farm
workers, but workers should be aware of the public health
implications of land application and the land application
schedule, and should follow good hygiene practice during
the 30-day period. For example, workers should be in-
structed to wash their hands after handling soil or crops
that come into contact with soil. Protective clothing and
footwear are recommended for workers who work on fields
that have recently been applied with Class B biosolids.
More safety recommendations for workers handling
biosolids are included in Section 2.2.
5.6 Domestic Septage [503.32(c)]
Under Part 503.32(c), pathogen reduction in domestic
septage applied to agricultural land, forest, or reclamation
sites* may be reduced in one of two ways:
. Either all the Class B site restrictions under
503.32(b)(5) -see Section 5.5- must be met,
. Or the pH of the domestic septage must be raised to
12 or higher by alkali addition and maintained at pH
12 or higher for 30 minutes without adding more al-
kali, and the site restrictions on crop harvesting in
503.32(b)(5)(l-iv) must be met (see Section 5.5). The
Part 503 regulation uses the term alkali in the broad
sense to mean any substance that causes an increase
inpH.
Vector attraction reduction can be met with Options 9,
10, or 13. Domestic septage can be incorporated or in-
jected into the soil to prevent vector attraction, or the pH of
the domestic septage can be adjusted as outlined in Op-
tion 12 (see Section 8). pH adjustment can fulfill both patho-
gen and vector attraction reduction.
The pH requirement applies to every container of do-
mestic septage applied to the land, which means that the
pH of each container must be monitored. The first alterna-
tive reduces exposure to pathogens in land applied do-
mestic septage while environmental factors attenuate
pathogens. The second alternative relies on alkali treat-
ment to reduce pathogens and contains the added safe-
yuard of restricting crop harvesting, which prevents expo-
sure to crops grown on domestic septage amended soils.
References and Additional Resources
Farrell, J.B., G. Stern, and A.D. Venosa. 1985. Microbial
destructions achieved by full-scale anaerobic diges-
tion. Workshop on Control of Sludge Pathogens, Se-
ries IV. Alexandria, VA: Water Pollution Control Fed-
eration.
Farrell, J.B., B.V. Salotto, and A.D. Venosa. 1990. Reduc-
tion in bacterial densities of wastewater solids by three
secondary treatment processes. Res. Jour. WPCF
62(2): 177-1 84.
Gerba, C.P., C. Wallis, and J.L. Melmick. 1975. Fate of
wastewater bacteria and viruses in soil. J. Irrig. Drain
Div. Am. Soc. Civ. Engineers. 101 :157-1 74.
Kowal, N.E. 1985. Health effects of land application of
municipal sludge. Pub. No.: EPA/600/1-85/01 5. Re-
search Triangle Park, NC: U.S. EPA Health Effects
Research Laboratory.
Kowal, N.E. 1994. Pathogen risk assessment: Status and
potential application in the development of Round II
regulations. Proceedings of the June 19-20,1994 Spe-
ciality Conference. The Management of Water and
Wastewater Solids for the 21 st Century: A Global Per-
spective. Water Environment Federation. Alexandria,
VA.
Moore, B.E., D.E. Camann, G.A. Turk, and C.A. Sorber.
1988. Microbial characterization of municipal waste-
water at a spray irrigation site: The Lubbock infection
surveillance study. J. Water Pollut. Control Fed. 60(7):
1222-1 230.
Smith, J.E., Jr. 1988. Fate of pathogens during the sew-
age sludge treatment process and after land applica-
tion. In Proceedings of the January 21-22, 1998 Cali-
fornia Plant and Soil Conference: Agricultural chal-
lenges in an urbanizing state, Sacramento, CA.
Sobsey, M.D., and P.A. Shields. 1987. Survival and trans-
port of viruses in soils: Model studies. Pp. 155-1 77 in
V.C. Rao and J.L. Melnick, eds. Human viruses in sedi-
ments, sludges, and soils. Boca Raton, FL: CRC Press.
Sorber, C.A., and B.E. Moore. 1986. Survival and trans-
port of pathogens in sludge-amended soil, a critical
literature review. Report No.: EPA/600/2-87/028. Cin-
cinnati, OH: Office of Research and Development.
41
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Storey, G.W. ari
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Chapter 6
Processes to Significantly Reduce Pathogens (PSRPs)
6.1 Introduction
Processes to Significantly Reduce Pathogens (PSRPs)
are listed in Appendix B of Part 503. There are five PSRPs:
aerobic and anaerobic digestion, air drying, composting,
and lime stabilization. Under Part 503.32(b)(3), sewage
sludge meeting the requirements of these processes is
considered to be Class B with respect to pathogens (see
Section 5.3). When operated under the conditions speci-
fied in Appendix B, PSRPs reduce fecal coliform densities
to less than 2 million CPU or MPN per gram of total solids
(dry weight basis) and reduce Salmonella sp. and enteric
virus densities in sewage sludge by approximately a fac-
tor of 10 (Farrell, et al., 1985).
This level of pathogen reduction is required, as a mini-
mum, by the Part 503 regulation if the sewage sludge is
applied to agricultural land, a public contact site, a forest,
or a reclamation site or placed on a surface disposal site1.
Because Class B biosolids may contain some pathogens,
land application of Class B biosolids is allowed only if crop
harvesting, animal grazing, and public access are limited
for specific periods of time following application of Class B
biosolids so that pathogens can be further reduced by en-
vironmental factors (see Section 5.5).
The PSRPs listed in Part 503 are essentially identical to
the PSRPs that were listed under the 40 CFR Part 257
regulation, except that all requirements related solely to
reduction of vector attraction have been removed. Vector
attraction reduction is now covered under separate require-
ments (see Chapter 8) that include some of the require-
ments that were part of the PSRP requirements under Part
257, as well as some new options for demonstrating vec-
tor attraction reduction. These new options provide greater
flexibility to the regulated community in meeting the vector
attraction reduction requirements.
Although theoretically two or more PSRP processes,
each of which fails to meet its specified requirements, could
be combined and effectively reduce pathogens (i.e. partial
treatment in digestion followed by partial treatment by air
drying) it cannot be assumed that the pathogen reduction
contribution of each of the operations will result in the 2-
log reduction in fecal coliform necessary to define the com-
bination as a PSRP. Therefore, to comply with Class B
pathogen requirements, one of the PSRP processes must
be conducted as outlined in this chapter, or fecal coliform
testing must be conducted in compliance with Class B Al-
ternative 1. The biosolids preparer also has the option of
applying for PSRP equivalency for the combination of pro-
cesses. Achieving PSRP equivalency enables the preparer
to stop monitoring for fecal coliform density.
This chapter provides detailed descriptions of the PSRPs
listed in Appendix B. Since the conditions for the PSRPs,
particularly aerobic and anaerobic digestion, are designed
to meet pathogen reduction requirements, they are not
necessarily the same conditions as those traditionally rec-
ommended by environmental engineering texts and manu-
als.
6.2 Aerobic Digestion
In aerobic digestion, sewage sludge is biochemically
oxidized by bacteria in an open or enclosed vessel (see
photo). To supply these aerobic microorganisms with
enough oxygen, either the sewage sludge must be agi-
tated by a mixer, or air must be forcibly injected (Figure 6-
1). Under proper operating conditions, the volatile solids
in sewage sludge are converted to carbon dioxide, water,
and nitrate nitrogen.
Aerobic systems operate in either batch or continuous
mode. In batch mode, the tank is filled with untreated sew-
age sludge and aerated for 2 to 3 weeks or longer, de-
pending on the type of sewage sludge, ambient tempera-
ture, and average oxygen levels. Following aeration, the
stabilized solids are allowed to settle and are then sepa-
rated from the clarified supernatant. The process is begun
again by inoculating a new batch of untreated sewage
sludge with some of the solids from the previous batch to
supply the necessary biological decomposers. In continu-
ous mode, untreated sewage sludge is fed into the digester
once a day or more frequently; thickened, clarified solids
are removed at the same rate.
The PSRP description in Part 503 for aerobic digestion
is:
'Unless the active biosolids surface disposal unit is covered al the end of each
operating day, in which case no pathogen requirement applies.
. Sewage sludge is agitated with air or oxygen to main-
tain aerobic conditions for a specific mean cell resi-
43
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Digester in Vancouver, Washington.
Raw
Sludge
Aerodigester
Settling,
Tank
Oxidized
Overflow
to Treatment Works
Return Sludge
to Aerodigester
Stabilized
Sludge
to Disposal
Figure 6-1. Aerobic digestion.
44
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dence time at a specific temperature. Values for the
mean cell residence time and temperature shall be
between 40 days at 20°C (68°F) and 60 days at 15°C
(59°F).
For temperatures between 15°C (59°F) and 20°C (68°F)
use the relationship between time and temperature pro-
vided below to determine the required mean cell residence
time.
Time @T°C = 1.08 (20-T)
40 d
The regulation does not differentiate between batch, in-
termittently fed, and continuous operation, so any method
is acceptable, the mean cell residence time is considered
the residence time of the sewage sludge solids. The ap-
propriate method for calculating residence time depends
on the type of digester operation used (see Appendix E).
Continuous-Mode, No Supernatant Removal For con-
tinuous-mode digesters where no supernatant is removed,
nominal residence times may be calculated by dividing liq-
uid volume in the digester by the average daily flow rate in
or out of the digester.
Continuous-Mode, Supernatant Removal In systems
where the supernatant is removed from the digester and
recycled, the output volume of sewage sludge can be much
less than the input volume of sewage sludge. For these
systems, the flow rate of the sewage sludge out of the
digester is used to calculate residence times.
Continuous-Mode Feeding, Batch Removal of Sew-
age Sludge For some aerobic systems, the digester is
initially filled above the diffusers with treated effluent, and
sewage sludge is wasted daily into the digester. Periodi-
cally, aeration is stopped to allow solids to settle and su-
pernatant to be removed. As the supernatant is drawn off,
the solids content in the digester gradually increases. The
process is complete when either settling or supernatant
removal is inadequate to provide space for the daily sew-
age sludge wasting requirement, or sufficient time for di-
gestion has been provided. The batch of digested sewage
sludge is then removed and the process begun again. If
the daily mass of sewage sludge solids introduced has
been constant, nominal residence time is one-half the to-
tal time from initial charge to final withdrawal of the digested
sewage sludge.
Batch or Staged Reactor Mode A batch reactor or two
or more completely-mixed reactors in series are more ef-
fective in reducing pathogens than is a single well-mixed
reactor at the same overall residence time. The residence
time required for this type of system to meet pathogen re-
duction goals may be 30% lower than the residence time
required in the PSRP definition for aerobic digestion (see
Appendix E). However, since lower residence times would
not comply with PSRP conditions required for aerobic di-
gestion in the regulation, approval of the process as a PSRP
by the permitting authority would be required.
Other Digesters are frequently operated in unique ways
that do not fall into the categories above. Appendix E pro-
vides information that should be helpful in developing a
calculation procedure for these cases. Aerobic digestion
carried out according to the Part 503 requirements typi-
cally reduces bacterial organisms by 2-log and viral patho-
gens by l-log. Helminth ova are reduced to varying de-
grees, depending on the hardiness of the individual spe-
cies. Aerobic digestion typically reduces the volatile solids
content (the microbes' food source) of the sewage sludge
by 40% to 50%, depending on the conditions maintained
in the system.
Vector Attraction Reduction
Vector attraction reduction for aerobically digested sew-
age sludges is demonstrated either when the percent vola-
tile solids reduction during sewage sludge treatment equals
or exceeds 38%, or when the specific oxygen uptake rate
(SOUR) at 20°C (68°F) is less than or equal to 1.5 mg of
oxygen per hour per gram of total solids, or when addi-
tional volatile solids reduction during bench-scale aerobic
batch digestion for 30 additional days at 20°C (68°F) is
less than 15% (see Chapter 8).
Thermophilic aerobic systems (operating at higher tem-
peratures) capable of producing Class A biosolids are de-
scribed in Section 7.5.
6.3 Anaerobic Digestion
Anaerobic digestion is a biological process that uses
bacteria that function in an oxygen-free environment to
convert volatile solids into carbon dioxide, methane, and
ammonia. These reactions take place in an enclosed tank
(see Figure 6-2) that may or may not be heated. Because
the biological activity consumes most of the volatile solids
needed for further bacterial growth, microbial activity in
the treated sewage sludge is limited. Currently, anaerobic
digestion is one of the most widely used treatments for
sewage sludge treatment, especially in treatment works
with average wastewater flow rates greater than 19,000
cubic meters/day (5 million gallons per day).
Most anaerobic digestion systems are classified as ei-
ther standard-rate or high-rate systems. Standard-rate
systems take place in a simple storage tank with sewage
sludge added intermittently. The only agitation that occurs
comes from the natural mixing caused by sewage sludge
gases rising to the surface. Standard-rate operation can
be carried out at ambient temperature, though heat is some-
times added to speed the biological activity.
High-rate systems use a combination of active mixing
and carefully controlled, elevated temperature to increase
the rate of volatile solids destruction. These systems some-
times use pre-thickened sewage sludge introduced at a
uniform rate to maintain constant conditions in the reactor.
Operating conditions in high-rate systems foster more effi-
cient sewage sludge digestion.
The PSRP description in Part 503 for anaerobic diges-
tion is:
45
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Raw
Sludge
First Stage
(completely mixed)
Figure 6-2. Two-stage anaerobic digestion (high rate).
. Sewage sludge is treated in the absence of air for a
specific mean cell residence time at a specified tem-
perature. Values for the mean cell residence time and
temperature shall be between 15 days at 35°C to 55°C
(95°Fto 131 °F) and 60 days at20°C(68°F).
Straight-line interpolation to cakuiatfe mean cell resi-
dence time is allowable when the temperature falls be-
tween 35°C and 2Q°C.
Section 6.2 provides information on calculating residence
times. Anaerobic digestion that meets the required resi-
dence times and temperatures typically reduces bacterial
and viral pathogens by 90% or more. Viable helminth ova
are not substantially reduced under mesophilic conditions
(32°C to 38°C [90°F to 1 00°F]) and may not be completely
reduced at temperatures between 38°C (100°F) and 50°C
(122°F).
Anaerobic systems reduce volatile solids by 35% to 60%,
depending on the nature of the sewage sludge and the
system's operating conditions. Sewage sludges produced
by systems that meet the operating conditions specified
under Part 503 will typically have volatile solids reduced
by at least 38%, which satisfies vector attraction reduction
requirements. Alternatively, vector attraction reduction can
be demonstrated by Option 2 of the vector attraction re-
duction requirements, which requires that additional vola-
tile solids loss during bench-scale anaerobic batch diges-
tion of the sewage sludge for 40 additional days at 30°C to
37°C (86°F to 99°F) be less than 17% (see Section 8.3).
The SOUR test is an aerobic test and cannot be used for
anaerobically digested sewage sludge.
6.4 Air Drying
Air drying allows partially digested sewage sludge to dry
naturally in the open air (see photo). Wet sewage sludge
Second Stage
(stratified)
is usually applied to a depth of approximately 23 cm (9
inches) onto sand drying beds, or even deeper on paved
or unpaved basins. The sewage sludge is left to drain and
dry by evaporation. Sand beds have an underlying drain-
age system; some type of mechanical mixing or turning is
frequently added to paved or unpaved basins. The effec-
tiveness of the air drying process depends very much on
the local climate: drying occurs faster and more completely
in warm, dry weather, and slower and less completely in
cold, wet weather. During the drying/storage period in the
bed, the sewage sludge is undergoing physical, chemical,
and biological changes. These include biological decom-
position of organic material, ammonia production, and des-
iccation.
Sludge drying operation. (Photo credit: East Bay Municipal Utility
District)
46
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The PSRP description in Part 503 for air drying is:
. Sewage sludge is dried on sand beds or on paved or
unpaved basins. The sewage sludge dries for a mini-
mum of 3 months. During 2 of the 3 months, the ambi-
ent average daily temperature is above 0°C (32°F).
Although not required by the Part 503, it is advisable to
ensure that the sewage sludge drying beds are exposed
to the atmosphere (i.e., not covered with snow) during the
2 months that the daily temperature is above 0°C (32°F).
Also, the sewage sludge should be at least partially di-
gested before air drying. Under these conditions, air dry-
ing will reduce the density of pathogenic viruses by l-log
and bacteria by approximately 2-log. Viable helminth ova
also are reduced, except for some hardy species that re-
main substantially unaffected.
Vector Attraction Reduction
Frequently sand-bed drying follows an aerobic or anaero-
bic digestion process that does not meet the specified pro-
cess requirements and does not produce 38% volatile sol-
ids destruction. However, it may be that the volatile solids
reduction produced by the sequential steps of digestion
and drying will meet the vector attraction reduction require-
ment of 38% volatile solids reduction. If this is the case,
vector attraction reduction requirements are satisfied.
Example,of Meeting F^§RP and "'•'
Vector Attraction Reduction Requirements
Type of Facility
Class ,
Pathogen Reduction
Air Drying < „ -
BJ • - - N
^ ^ v
Partially digested sewage
, sludge is thickened and
: Spread in drying beds. Filling
; of beds starts in June, and the
-:'- beds' accommodate sewage
''": .sludge generated over 1 full
. ;^year; Beds am'fhen emptied
. tl% fplldwlijg {September so
, that ail sewage sludge is re-
tained over an entire summer
(> 0°O ambient tempera-
tures). '-• ,
Sewage sludge is tested for
pollutants 2 weeks before
material is removed and dis-
~ >ibuted/',
Vector Attraction Reduction Biosoiids are land applied
- , and plowed immediately into
- , thesoiL , " . '
Use or Disposal Biosoiids are delivered to lo-
cal farmers. Farmers are
given Information on site re-
strictions, and must follow
harvest, grazing, and public
access restrictions.
Testing
Vector Attraction Reduction
Air-dried sewage sludge typically is treated by aerobic
or anaerobic digestion before it is placed on drying beds.
Usually, the easiest vector attraction reduction requirement
to meet is a demonstration of 38% reduction in volatile
solids (Option 1, See Section 8.2), including the reduction
that occurs during its residence on the drying beds.
In dry climates, vector attraction reduction can be
achieved by moisture reduction (see Option 7 in Section
8.8, and Option 8 in Section 8.9).
6.5 Composting
Composting involves the aerobic decomposition of or-
ganic material using controlled temperature, moisture, and
oxygen levels. Several different composting methods are
currently in use in the United States. The three most com-
mon are windrow, aerated static pile, and within-vessel
composing, are described below.
Composting can yield either Class A or Class B biosolids,
depending on the time and temperature variables involved
in the operation.
All composting methods rely on the same basic pro-
cesses. Bulking agents such as wood chips, bark, saw-
dust, straw, rice hulls, or even-finished compost are added
to the sewage sludge to absorb moisture, increase poros-
ity, and add a source of carbon. This mixture is stored (in
windrows, static piles, or enclosed tanks) for a period of
intensive decomposition, during which temperatures can
rise well above 55°C (131 °F). Depending on ambient tem-
peratures and the process chosen, the time required to
reduce pathogens and produce Class B biosolids can range
from 3 to 4 weeks. Aeration and/or frequent mixing or turn-
ing are needed to supply oxygen and remove excess heat.
Following this active stage, bulking agents may or may
not be screened from the completed compost for recycling
(see photo), and the composted biosolids are "cured" for
an additional period.
Windrow composting involves stacking the sewage
sludge/bulking agent mixture into long piles, or windrows,
generally 1.5 to 2.7 meters high (5 to 9 feet) and 2.7 to 6.1
meters wide (9 to 20 feet). These rows are regularly turned
or mixed with a turning machine or front-end loader to fluff
up the material and increase porosity which allows better
convective oxygen flow into the material. Turning also
breaks up compacted material and reduces the moisture
content of the composting media (see photo, next page).
Active windrows are typically placed in the open air, ex-
cept in areas with heavy rainfall. In colder climates, winter
weather can significantly increase the amount of time
needed to attain temperatures needed for pathogen re-
duction.
Aerated static pile composting uses forced-air rather than
mechanical mixing (see Figure 6-3) to both supply suffi-
cient oxygen for decomposition and carry off moisture. The
sewage sludge/bulking agent mixture is placed on top of
47
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Composted sludge is screened to remove the bulking agent prior
to land application.
Compost mixing equipment turns over a windrow of compost for
solar drying prior to screening. [Photo credit: East Bay Municipal
Utility District)
either (1) a fixed underlying forced aeration system, or (2)
a system of perforated piping laid on the composting pad
surface and topped with a bed of bulking agent. The entire
pile is covered with a layer of cured compost for insulation
and odor control. Pumps are used to blow air into the com-
post pile or suck air through it. The latter provides greater
odor control because the compost air can be easily col-
lected and then filtered or scrubbed.
Within-vessel composting systems vary greatly in de-
sign, but they share two basic techniques: the process
takes place in a reactor vessel where the operating condi-
tions can be carefully controlled (see photo page 49), and
active aeration meets the system's high oxygen demand.
Agitated bed systems (one type of within-vessel
composting) depend on continuous or periodic mixing
within the vessel, followed by a curing period
Pathogen reduction during composting depends on time
and temperature variables (see photo page 49). Part 503
provides the following definition of PSRP requirement for
pathogen reduction during composting:
. Using either the within-vessel, static aerated pile, or
windrow composting methods, the temperature of the
sewage sludge is raised to 40°C (104°F) or higher and
remains at 40°C (104°F) or higher for 5 days. For 4
hours during the 5-day period, the temperature in the
compost pile exceeds 55°C (131 °F).
These conditions, achieved using either within-vessel,
aerated static pile, or windrow methods, reduce bacterial
pathogens by 2-log and viral pathogens by l-log.
A process time of only 5 days is not long enough to fully
break down the volatile solids in sewage sludge, so the
composted sewage sludge produced under these condi-
tions will not be able to meet any of the requirements for
reduced vector attraction. In addition, sewage sludge that
has been composted for only 5 days may still be odorous.
Breakdown of volatile solids may require 14 to 21 days for
within-vessel; 21 or more days for aerated static pile; and
30 or more days for windrow composting. Many treatment
works allow the finished sewage sludge compost to fur-
ther mature or cure for at least several weeks following
active composting during which time pile turning or active
aeration may continue.
Composting is most often used to meet Class A require-
ments. More guidance for composting operations and how
to meet Class A time and temperature requirements is pro-
vided in Chapter 7.
Vector Attraction Reduction
Vector attraction reduction must be conducted in accor-
dance with Option 5, or compost must be incorporated into
soil when land applied. This option requires aerobic treat-
ment (i.e., composting) of the sewage sludge for at least
14 days at over 40°C (104°F) with an average tempera-
ture of over45°C(113°F).
6.6 Lime Stabilization
The lime stabilization process is relatively straightforward:
lime — either hydrated lime, Ca(OH)2; quicklime, CaO; or
lime containing kiln dust or fly ash — is added to sewage
sludge in sufficient quantities to raise the pH above 12 for
2 hours or more after contact, as specified in the Part 503
PSRP description for lime stabilization:
. Sufficient lime is added to the sewage sludge to raise
the pH of the sewage sludge to 12 after 2 hours of
contact.
For the Class B lime stabilization process, the alkaline
material must be a form of lime. Use of other alkaline ma-
48
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Taulman Weiss in-vessel composting facility in Portland, Oregon.
Compost operator measures compost pile temperature as part of
process monitoring. (Photo credit: East Bay Municipal Utioity District,
Oakland, California)
Air
Air
Composted
Sludge
Bulking Agent/
Sludge Mixture
Porous Base:
Wood Chips or
Compost
Figure 6-3. Static aerated pile composting.
terials must first be demonstrated to be equivalent to a
PSRP. Elevation of pH to 12 for 2 hours is expected to
reduce bacterial and viral density effectively.
Lime may be introduced to liquid sewage sludge in a
mixing tank or combined with dewatered sewage sludge,
providing the mixing is complete and the sewage sludge
cake is moist enough to allow aqueous contact between
the sewage sludge and lime.
Mixing must be sufficient to ensure that the entire mass
of sewage sludge comes into contact with the lime and
Filter Pile of
Composted Sludge
undergoes the increase in pH and to ensure that samples
are representative of the overall mixture (see Chapter 9).
pH should be measured at several locations to ensure that
the pH is raised throughout the sewage sludge.
A variety of lime stabilization processes are currently in
use. The effectiveness of any lime stabilization process
for controlling pathogens depends on maintaining the pH
at levels that reduce microorganisms in the sewage sludge.
Field experience has shown that the application of lime
stablized material after the pH has dropped below 10.5
may, in some cases, create odor problems. Therefore it is
49
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recommended that biosolids application take place while
the pH remains elevated. If this is not possible, and odor
problems develop, alternate management practices in the
field include injection or incorporation or top dressing the
applied biosolids with additional lime. Alternate manage-
ment practices if the biosolids have not yet left the waste-
water treatment plant may include adding additional lime
to maintain the elevated pH or additional treatment through
drying or composting. Lime stabilization can reduce bac-
terial and viral pathogens by 99% or more. Such alkaline
conditions have little effect on hardy species of helminth
ova, however.
Vector Attraction Reduction
For lime-treated sewage sludge, vector attraction reduc-
tion is best demonstrated by Option 6 of the vector attrac-
tion reduction requirements. This option requires that the
sewage sludge pH remain at 12 or higher for at least 2
hours, and then at 11.5 or more for an additional 22 hours
(see Section 8.7).
Lime stabilization does not reduce volatile solids. Field
experience has shown that the application of lime stabi-
lized material after the pH has dropped below 10.5 may
create odor problems. Therefore it is recommended that
land application of biosolids take place as soon as pos-
sible after vector attraction reduction is completed and while
pH remains elevated.
6.7 Equivalent Processes
Table 11 .1 in Chapter 11 lists some of the processes
that the EPA's Pathogen Equivalency Committee has rec-
ommended as being equivalent to PSRP under Part 257.
Information on the PEC and how to apply for equivalency
are discussed in Chapter 11.
References and Other Resources
Berg G. and D. Berman. 1980. Destruction by anaero-
bic mesophilic and thermophilic digestion of vi-
ruses and indicator bacteria indigenous to do-
mestic sludges. Appl. Envir. Microbiol. 39 (2):361-
368.
Farrell, J.B., G. Stern, and A.D. Venosa. 1990. Mi-
crobial destructions achieved by full-scale
anaerobic digestion. Paper presented at Munici-
pal Wastewater Sludge Disinfection Workshop.
Kansas City, MO. Water Pollution Control Fed-
eration, October 1995.
U.S. EPA. 1992. Technical support document for re-
duction of pathogens and vector attraction in sew-
age sludge. EPA 822/R-93-004.
50
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Chapter 7
Processes to Further Reduce Pathogens (PFRPs)
7.1 Introduction
Processes to Further Reduce Pathogens (PFRPs) are
listed in Appendix B of the Part 503. There are seven
PFRPs: composting, heat drying, heat treatment, thermo-
philic aerobic digestion, beta ray irradiation, gamma ray
irradiation, and pasteurization. When these processes are
operated under the conditions specified in Appendix B,
pathogenic bacteria, enteric viruses, and viable helminth
ova are reduced to below detectable levels. The PFRPs
listed in Part 503 are essentially identical to the PFRPs
listed under the 40 CFR Part 257 regulation, except that
all requirements related solely to reduction of vector at-
traction have been removed.
This chapter provides detailed descriptions of the seven
PFRPs listed in Part 503. Because the purpose of these
processes is to produce Class A biosolids, the pathogen
reduction process must be conducted concurrent to or prior
to the vector attraction reduction process (see Section 4.2).
Under Part 503.32(a)(7), sewage sludge treated in these
processes is considered to be Class A with respect to hel-
minth ova, enteric viruses, and pathogenic bacteria. In
addition, Class A biosolids must be monitored for fecal
coliform or Salmonella sp. bacteria at the time of use or
disposal, at the time the biosolids are prepared for sale or
give away in a bag or other container for land application,
or at the time the biosolids are prepared to meet the re-
quirements for "exceptional quality" sludge (see Chapter
2) in 503.10(b), 503.10(c), 503.10(e), or 503.10(0 to en-
sure that growth of bacteria has not occurred (see Section
4.3). Guidelines regarding the frequency of pathogen sam-
pling and sampling protocols are included in Chapter 9.
7.2 Composting
Composting is the controlled, aerobic decomposition of
organic matter which produces a humus-like material. Sew-
age sludge which is to be composted is generally mixed
with a bulking agent such as wood chips which increases
porosity in the sewage sludge, allowing air to more easily
pass through the composting material and maintain aero-
bic conditions. There are three commonly used methods
of composting: windrow, static aerated pile, and within-
vessel.
To be considered a PFRP under Part 503, the composting
operation must meet certain operating conditions:
. Using either the within-vessel composting method or
the static aerated pile composting method, the tem-
perature of the sewage sludge is maintained at 55°C
(131 °F) or higher for 3 consecutive days.
. Using the windrow composting method, the tempera-
ture of the sewage sludge is maintained at 55°C (131°F)
or higher for 15 consecutive days or longer. During
the period when the compost is maintained at 55°C
(131°F) or higher, there shall be a minimum of five turn-
ings of the windrow.
For aerated static pile and in-vessel composting pro-
cesses, temperatures should be taken at multiple points
at a range of depths throughout the composting medium.
Points which are likely to be slightly cooler than the center
of the pile, such as the toes of piles, also should be moni-
tored. Because the entire mass of sewage sludge must
attain the required temperatures for the required duration,
the temperature profiles from every monitoring point, not
just the average of the points, should reflect PFRP condi-
tions.
It has been found that points within 0.3 m (1 foot) of the
surface of aerated static piles may be unable to reach PFRP
temperatures, and for this reason, it is recommended that
a 0.3 m (1 foot) or greater layer of insulating material be
placed over all surfaces of the pile. Finished compost is
often used for insulation. It must be noted that because
the insulation will most likely be mixed into the composted
material during post-processing or curing, compost used
as an insulation material must be a Class A material so as
not to reintroduce pathogens into the composting sewage
sludge.
For windrow composting, the operational requirements
are based on the same time-temperature relationship as
aerated static pile and in-vessel composting. The material
in the core of the windrow attains at least 55°C and must
remain at that temperature for 3 consecutive days. Wind-
row turning moves new material from the surface of the
windrow into the core so that this material may also un-
dergo pathogen reduction. After five turnings, all material
in the windrow must have spent 3 days at the core of the
pile. The time-temperature regime takes place over a pe-
riod of at least 15 consecutive days during which time the
temperature in the core of the windrow is at least 55*o* C.
See Appendix J for additional guidance.
51
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Pathogen reduction is a function of three parameters:
. Ensuring that all sewage sludge is mixed into the core
of the pile at some point during active composting
. Ensuring that all sewage sludge particles spend 3 con-
secutive days in the core during which time the tem-
peratures are at 55°C
. Preventing growth of pathogenic bacteria in composted
material
The first issue, ensuring that all material is mixed into
the core of the pile, depends on the configuration of the
windrows and the turning methodology. Pile size and shape
as well as material characteristics determine how much of
the pile is in the "hot zone" at any given time. Additional
turning and maintenance of temperatures after the man-
dated 15 days are recommended, depending on the wind-
row configuration. For example, the Los Angeles County
Sanitation District found that as many as 12-15 turnings
were necessary to reduce pathogens in windrow
composted sewage sludge (Personal Communication,
Ross Caballero, Los Angeles County Sanitation District,
1998).
Second, it is important that once that material is in the
pile core it be subject to the full time-temperature regime
necessary to reduce pathogens. Therefore, the turning
schedule and the recovery of the core zone to 55°C are
important factors. If pile turning is not evenly distributed
throughout the 15-day period, some material may not spend
adequate time in the core of the pile. Additionally, pile tem-
peratures generally drop off immediately after turning; if
temperatures in the pile core do not quickly recover to 55°C
(within 24 hours), the necessary pathogen reduction pe-
riod of 3 days will not be achieved.
Because of the operational variability, pathogen reduc-
tion in windrow composting has been found to be less pre-
dictable than pathogen reduction in aerated static pile or
in-vessel composting. In order to improve pathogen re-
duction, the following operational guidelines are recom-
mended.
• Windrow turning should take place after the pile core
has met pathogen reduction temperatures for 3 con-
secutive days. Windrow turnings should be evenly
spaced within the 15 days so that all material remains
in the core zone for 3 consecutive days; allowing addi-
tional time as needed for the core temperature to come
up to 55°C.
. Pathogen reduction temperatures (55°C) must be met
for 15 consecutive days at the pile core;
• Temperatures should be taken at approximately the
same time each day in order to demonstrate that 55°C
has been reached in the pile core within 24 hours after
pile turning;
. Testing frequency should be increased; a large sew-
age sludge windrow composting operation recom-
mends testing each windrow for Salmonella sp. be-
fore piles are distributed (Personal Communication,
Ross Caballero, Los Angeles County Sanitation Dis-
trict, 1998). Samples are taken after turning is com-
pleted, and piles which do not comply with Class A
requirements are retained on site for further
composting.
Vector Attraction Reduction (VAR)
The options for demonstrating vector attraction reduc-
tion for both PFRP and PSRP composting are the same.
Option 5 is the most appropriate for composting opera-
tions. This option requires aerobic treatment (e.g.
composting) of the sewage sludge for at least 14 consecu-
tive days at over 40°C (104°F) with an average tempera-
ture of over 45°C (113°F). This is usually easily attained
by sewage sludge composting.
The PFRP and VAR requirements can be met concur-
rently in composting. For within-vessel or aerated static
pile composting, the temperature profile should show PFRP
temperatures at each of the temperature monitoring points
for 3 consecutive days, followed by a minimum of 11 more
days during which time the average temperature of the
pile complies with VAR requirements. For windrow piles,
the compliance with PFRP temperatures will also fulfill VAR
requirements.
PFRP temperatures should be met before or at the same
time that VAR requirements are fulfilled in order to reduce
the potential for pathogen regrowth. However, continued
curing of the composting material will most likely further
prevent the growth of pathogenic bacteria from taking place.
Like all microbiological processes, composting can only
take place with sufficient moisture (45-60%). Excessive
aeration of composting piles or arid ambient condition may
dry composting piles to the point at which microbial activ-
ity slows or stops. The cessation of microbial activity re-
sults in lowered pile temperatures which can easily be mis-
taken for the end-point of composting. Although composting
may appear to have ended, and compost may even meet
vector attraction reduction via Option 7, overly dried com-
post can cause both odor problems and vector attraction if
moisture is reintroduced into the material and microbial
activity resumes. It is therefore recommended that the
composting process be maintained at moisture levels be-
tween 45-60% (40-55% total solids) (Epstein, 1997).
Microbiological Requiremen fs
If the conditions specified by the Part 503 regulation are
met, all pathogenic viruses, bacteria, and parasites will be
reduced to below detectable levels However, it may be
difficult to meet the Class A microbiological requirement
for fecal coliforms even when Salmonella sp. bacteria are
not present. Biological sewage sludge treatment processes
involving high temperatures, such as composting, can re-
duce Salmonella sp. to below detectable levels while leav-
ing some surviving fecal coliforms. If sufficient nutrients
remain in the sewage sludge, bacteria can later grow to
52
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significant numbers. It may be preferable, therefore, to test
composted sewage sludge directly for Salmonella sp.,
rather than using fecal coliforms as an indicator of patho-
gen control.
Although not mandated by the Part 503 regulation, com-
post is usually maintained on site for longer than the re-
quired PFRP and VAR duration. In order to produce a high-
quality, marketable product, it has been found that a cur-
ing period, or the period during which the volatile solids in
the sewage sludge continue to decompose, odor potential
decreases, and temperatures decrease into the mesophilic
(40-45°C) range, is necessary. Depending on the feed-
stock and the particular process, the curing period may
last an additional 30 - 50 days after regulatory require-
ments are met.
In general, compost is not considered marketable until
the piles are no longer self-heating. It is important to note
that compost piles that are cooled by excessive aeration
or that do not self-heat because the material is too dry to
support microbial activity may not actually be fully decom-
posed.
It has been found that further reduction of organic mate-
rial takes place during the curing phase of composting
(Epstein, 1997). Therefore microbiological testing should
take place at the end of the curing process when compost
is prepared for sale or distribution. Compost which is stored
on site for extended periods of time until it can be sold or
distributed must be tested for compliance with microbio-
logical limits when it is to be used or disposed.
7.3 Heat Drying
Heat drying is used to reduce both pathogens and the
water content of sewage sludge. The Part 503 PFRP de-
scription of heat drying is:
. Sewage sludge is dried by direct or indirect contact
with hot gases to reduce the moisture content to 10%
or lower. Either the temperature of the sewage sludge
particles exceeds 80°C (176°F) or the wet bulb tem-
perature of the gas in contact with the sewage sludge
as it leaves the dryer exceeds 80°C (176°F).
Properly conducted heat drying will reduce pathogenic
viruses, bacteria, and helminth ova to below detectable
levels. Four processes are commonly used for heat drying
sewage sludge: flash dryers, spray dryers, rotary dryers,
and steam dryers. Flash dryers used to be the most com-
mon heat drying process installed at treatment works, but
current practice favors rotary dryers. These processes are
briefly described below. More detailed descriptions are
provided in EPA's Process Design Manual (EPA, 1979).
Flash Dryers
Flash dryers pulverize sewage sludge in the presence
of hot gases. The process is based on exposing fine sew-
age sludge particles to turbulent hot gases long enough to
attain at least 90% solids content.
Spray Dryers
A spray dryer typically uses centrifugal force to atomize
liquid sewage sludge into a spray that is directed into a
drying chamber. The drying chamber contains hot gases
that rapidly dry the sewage sludge mist. Some spray dry-
ing systems use a nozzle to atomize sewage sludge.
Rotary Dryers
Rotary dryers function as horizontal cylindrical kilns. The
drum rotates and may have plows or louvers that mechani-
cally mix the sewage sludge as the drum turns. There are
many different rotary kiln designs, utilizing either direct
heating or indirect heating systems. Direct heating designs
maintain contact between the sewage sludge and the hot
gases. Indirect heating separates the two with steel shells.
Steam Dryers
Indirect steam dryers utilize steam to heat the surface of
the dryers which will come into contact with the sewage
sludge. The heat transfer surface may consist of discs or
paddles, which rotate to increase their contact with the
sewage sludge.
Vector Attraction Reduction
No further processing is required because the PFRP
requirements for heat drying also meet the requirements
of Option 8 for vector attraction reduction (the percent sol-
ids must be at least 90% before mixing the sewage sludge
with other materials). This fulfills the requirement of Op-
tion 7 if the sewage sludge being dried contains no
unstabilized solids.
Drying of sewage sludge to 90% solids deters the at-
traction of vectors, however, unstabilized dried biosolids
which are rewet may become odorous and attract vectors.
Therefore, it is recommended that materials be used or
disposed while the level of solids remains high and that
dried material be stored and maintained under dry condi-
tions.
Some operators have found that maintaining stored
material at solids levels above 95% helps to deter reheat-
ing because microbiological activity is halted. However,
storage of materials approaching 90% total solids can lead
to spontaneous combustion with subsequent fires and risk
of explosion. While there is little likelihood of an explosion
occurring with storage of materials like pellets, precaution-
ary measures such as maintaining proper oxygen levels
and minimizing dust levels in storage silos and monitoring
temperatures in material can reduce the risk of fires.
Microbiological Requirements
Heat dried biosolids must be tested for fecal coliform or
Salmonella sp. at the last point before being used or dis-
posed. For example, biosolids should be tested immedi-
ately before they are bagged or before they leave the site
for bulk distribution. If material is stored for a long period
of time, it should be re-tested, even if previous testing has
53
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shown the biosolids to have met the Part 503 regulation.
This is particularly important if material has been rewetted.
7.4 Heat Treatment
Heat treatment processes are used to disinfect sewage
sludge and reduce pathogens to below detectable levels.
The processes involve heating sewage sludge under pres-
sure for a short period of time. The sewage sludge be-
comes sterilized and bacterial slime layers are solubilized,
making it easier to dewater the remaining sewage sludge
solids. The Part 503 PFRP description for heat treatment
is:
. Liquid sewage sludge is heated to a temperature of
180°C (356°F) or higher for 30 minutes.
Two processes have principally been used for heat treat-
ing sludge in preparation for dewatering: the Porteous and
the Zimpro process. In the Porteous process the sewage
sludge is preheated and then injected into a reactor ves-
sel. Steam is also injected into the vessel under pressure.
The sewage sludge is retained in the vessel for approxi-
mately 30 minutes after which it is discharged to a decant
tank. The resulting sewage sludge can generally be con-
centrated and dewatered to high solids concentrations.
Further dewatering may be desirable to facilitate sewage
sludge handling.
The Zimpro process is similar to the Porteous process.
However, air is injected into the sewage sludge before it
enters the reactor and the vessel is then heated by steam
to reach the required temperature. Temperatures and pres-
sures are approximately the same for the two processes.
Vector Attraction Reduction
Heat treatment in most cases must be followed by vec-
tor attraction reduction. Vector attraction reduction Options
6 to 11 (pH adjustment, heat drying, or injection, incorpo-
ration, or daily cover) may be used (see Chapter 8). Op-
tions 1 through 5 would not typically be applicable to heat
treated sludge unless the sludge was digested or other-
wise stabilized during or after heat treatment (e.g. through
the use of wet air oxidation during heat treatment).
Microbiological Requirements
When operated according to the Pan 503 requirements,
the process effectively reduces pathogenic viruses, bac-
teria, and viable helminth ova to below detectable levels.
Sewage sludge must be properly stored after processing
because organic matter has not been reduced, and there-
fore, growth of bacteria can occur.
Heat treated sewage sludge must be tested for fecal
coliform or Salmonella sp. at the time of use or disposal or
as it is prepared for sale or distribution. If heat treated
biosolids are subsequently composted or otherwise treated,
pathogen testing should take place after that processing
is complete.
7.5 Thermophilic Aerobic Digestion
Thermophilic aerobic digestion is a refinement of the
conventional aerobic digestion processes discussed in
Section 6.2. In this process, feed sewage sludge is gener-
ally pre-thickened and an efficient aerator is used. In some
modifications, oxygen is used instead of air. Because there
is less sewage sludge volume and less air to carry away
heat, the heat released from biological oxidation warms
the sewage sludge in the digester to as high as 60°C
(140°F).
Because of the increased temperatures, this process
achieves higher rates of organic solids reduction than are
achieved by conventional aerobic digestion which oper-
ates at ambient air temperature. The biodegradable vola-
tile solids content of the sewage sludge can be reduced
by up to 70% in a relatively short time. The digested sew-
age sludge is effectively pasteurized due to the high tem-
peratures. Pathogenic viruses, bacteria, viable helminth
ova and other parasites are reduced to below detectable
limits if the process is carried out at temperatures exceed-
ing 55°C (131T).
This process can either be accomplished using auxiliary
heating of the digestion tanks or through special designs
that allow the energy naturally released by the microbial
digestion process to heat the sewage sludge. The Part
503 PFRP description of thermophilic aerobic digestion is:
. Liquid sewage sludge is agitated with air or oxygen to
maintain aerobic conditions and the mean cell resi-
dence time of the sewage sludge is 10 consecutive
days at 55°C to 60°C (131 °F to 140°F).
The thermophilic process requires significantly lower
residence times (i.e., solids retention time) than conven-
tional aerobic processes designed to qualify as a PSRP,
which must operate 40 to 60 days at 20°C to 15°C (68°F
to 59°F), respectively. Residence time is normally deter-
mined by dividing the volume of sewage sludge in the ves-
sel by the volumetric flow rate. Facility operation should
minimize the potential for bypassing by withdrawing treated
sewage sludge before feeding, and feeding no more than
once a day.
In the years following the publication of the Part 503 regu-
lation, advances in thermophilic digestion have been made.
It should be noted, however, that complete-mix reactors
with continuous feeding may not be adequate to meet Class
A pathogen reduction because of the potential for bypass-
ing or short-circuiting of untreated sewage sludge.
Vector Attraction Reduction
Vector attraction reduction must be demonstrated. Al-
though all options, except Options 2, 4, and 12 are pos-
sible, Options 1 and 3 which involve the demonstration of
volatile solids loss are the most suitable. (Option 2 is ap-
propriate only for anaerobically digested sludge, and Op-
tion 4 is not possible because it is not yet known how to
translate SOUR measurements obtained at high tempera-
tures to 20°C [68°F].)
Thermophilically aerobically digested biosolids must be
tested for fecal coliform or Salmonella sp. at the time of
54
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use or disposal or as it is prepared for sale or distribution.
If digested biosolids are subsequently composted or oth-
erwise treated, pathogen testing for either fecal coliform
or Salmonella sp. should take place after processing is
complete.
7.6 Beta Ray and Gamma Ray Radiation
Radiation can be used to disinfect sewage sludge. Ra-
diation destroys certain organisms by altering the colloidal
nature of the cell contents (protoplasm). Gamma rays and
beta rays are the two potential energy sources for use in
sewage sludge disinfection. Gamma rays are high-energy
photons produced by certain radioactive elements. Beta
rays are electrons accelerated in velocity by electrical po-
tentials in the vicinity of 1 millions volts. Both types of ra-
diation destroy pathogens that they penetrate if the doses
are adequate. The Part 503 PFRP descriptions for irradia-
tion systems are:
Beta Ray Irradiation
. Sewage sludge is irradiated with beta rays from an
accelerator at dosages of at least 1 .0 megarad at room
temperature (ca. 20°C [68°F]).
Gamma Ray Irradiation
• Sewage sludge is irradiated with gamma rays from
certain isotopes, such as Cobalt 60 and Cesium 137
[at dosages of at least 1 .0 megarad] at room tempera-
ture (ca. 20°C[68°F]).
The effectiveness of beta radiation in reducing patho-
gens depends on the radiation dose, which is measured in
rads. A dose of 1 megarad or more will reduce pathogenic
viruses, bacteria, and helminths to below detectable lev-
els. Lower doses may successfully reduce bacteria and
helminth ova but not viruses. Since organic matter has not
been destroyed with process, sewage sludge must be prop-
erly stored after processing to prevent contamination.
Although the two types of radiation function similarly to
inactivate pathogens, there are important differences.
Gamma rays can penetrate substantial thicknesses of sew-
age sludge and can therefore be introduced to sewage
sludge by either piping liquid sewage sludge into a vessel
that surrounds the radiation source (Figure 7-I) or by car-
rying composted or dried sewage sludge by hopper con-
veyor to the radiation source. Beta rays have limited pen-
etration ability and therefore are introduced by passing a
thin layer of sewage sludge under the radiation source
(Figure 7-2).
Vector Attraction Reduction
Radiation treatment must be followed by vector attrac-
tion reduction. The appropriate options for demonstrating
vector attraction reduction are the same as for heat treat-
ment (see Section 7.4), namely Options 6 to 11. Options
I-5 are not applicable unless the sewage sludge is subse-
quently digested.
Microbiological Requirements
Irradiated sewage sludge must be tested for fecal coliform
or Salmonella sp. at the time of use or disposal or as it is
prepared for sale or distribution.
7.7 Pasteurization
Pasteurization involves heating sewage sludge to above
a predetermined temperature for a minimum time period.
For pasteurization, the Part 503 PFRP description is:
. The temperature of the sewage sludge is maintained
at 70°C (158°F) or higher for 30 minutes or longer.
Sludge
Inlet
Vent
Sludge
Outlet
Figure 7-1. Schematic representation of cobalt-60 (gamma ray)
irradiation facility at Geiselbullach, Germany. Source:
EPA. 1979.
Input
(untreated or
Digested Sludge)
Electron
Beam
Electron Beam
Scanner
High Energy
JDisinfection
Zone
Sludge
leceiving
Tank
Output
(Disinfected
Sludge)
Figure 7-2. Beta ray scanner and sludge spreader. Source: EPA,
1979.
Constant
Head Tank
Underflow
Weir
Inclined
Feed Ramp
55
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Pasteurization reduces bacteria, enteric viruses, and vi-
able helminth ova to below detectable values. Sewage
sludge can be heated by heat exchangers or by steam
injection. Although sewage sludge pasteurization is uncom-
mon in the United States, it is widely used in Europe. The
steam injection method is preferred because it is more ef-
fective at maintaining even temperatures throughout the
sewage sludge batch being processed. Sewage sludge is
pasteurized in batches to prevent recontamination that
might occur in a continuous process. Sewage sludge must
be properly stored after processing because the organic
matter has not been stabilized and therefore odors and
growth of pathogenic bacteria can occur if sewage sludge
is re-inoculated.
In theory, quicklime can be used to meet the require-
ments for pasteurization of sewage sludge. The water in
the sludge slakes the lime, forming calcium hydroxide, and
generates heat. However, it is difficult to ensure that the
entire mass of sewage sludge comes into contact with the
lime and achieves the required 70°C for 30 minutes. This
is particularly true for dewatered sewage sludges. Pro-
cesses must be designed to 1) maximize contact between
the lime and the sewage sludge, 2) ensure that adequate
moisture is present, 3) ensure that heat loss is minimal,
and 4) if necessary, provide an auxiliary heat source. Pas-
teurization cannot be accomplished in open piles.
In addition, in order for pasteurization to be conducted
properly, facility operators must be trained with regard to
1) the proper steps to be taken to ensure complete hydra-
tion of the alkaline reagent used, 2) the evaluation of the
slaking rate of the lime based alkaline material required
for their particular process, specifying the reactivity rate
required, 3) the proper measurement of pH, 4) an aware-
ness of the effect of ammonia gassing off and how this
affects the lime dose, and 5) the necessity for maintaining
sufficient moisture in the sewage sludge/alkaline mixture
during the mixing process to ensure the complete hydra-
tion of the quicklime and migration of hydroxyl ions through-
out the sewage sludge mass. This is to ensure that the
entire sewage sludge mass is disinfected.
EPA -sponsored studies showed that pasteurization of
liquid sewage sludge at 70°C (158°F) for 30 minutes inac-
tivates parasite ova and cysts and reduces the population
of measurable viruses and pathogenic bacteria to below
detectable levels (U.S. EPA, 1979). This process is based
on the pasteurization of milk which must be heated to at
least 63°C (145°F) for at least 30 minutes.
Vector Attraction Reduction
Pasteurization must be followed by a vector attraction
reduction process unless the vector attraction reduction
conditions of Option 6 (pH adjustment) have been met.
The options appropriate for demonstrating vector attrac-
tion reduction are the same as those for heat treatment
(see Section 10.4), namely Options 6 to 11. Options 1 to 5
are not applicable unless the sludge is subsequently di-
gested.
Microbiological Requirements
Pasteurized sludge must be tested for fecal coliform or
Salmonella sp. at the time of use or disposal or as it is
prepared for sale or distribution. In Europe, serious prob-
lems with regrowth of Salmonella sp. have occurred, so
pasteurization is rarely used now as a terminal treatment
process. Pre-pasteurization followed by mesophilic diges-
tion has replaced the use of pasteurization after digestion
in many European communities.
7.8 Equivalent Processes
Under Class A Alternative 6, sewage sludge treated in
processes that are determined to be equivalent to PFRP
are considered to be Class A with respect to pathogens
(assuming the treated sewage sludges also meet the Class
A microbiological requirement). Table 11-2 in Chapter 11
lists some of the processes that were found, based on the
recommendation of EPA's Pathogen Equivalency Commit-
tee, to be equivalent to PFRP under Part 257. Chapter 11
discusses how the PEC makes a recommendation of
equivalency.
References and Additional Resources
Caballero, Ross. 1984. Experience at a windrow
composting facility: LA County site technology trans-
fer. US EPA, Municipal Environmental Research. Cin-
cinnati, Ohio.
Composting Council. 1994. Compost facility operating
guide: A reference guide for composting facility and
process management. Alexandria, Virginia.
Epstein, Eliot. 1997. The science of composting. Technomic
Publishing Company.
Farrell, J.B. 1992. Fecal pathogen control during
composting, presented at International Composting
Research Symposium, Columbus, Ohio.
Haug, Roger T. 1993. The practical handbook of compost
engineering. Lewis Publishers.
lacaboni, M.D., J.R. Livingston, and T.J. LeBrun. 1984.
Windrow and static pile composting of municipal sew-
age sludges. Report No.: EPA/600/2-84-122 (NTIS
PB84-215748).
U.S. EPA. 1979. Process design manual for sludge treat-
ment and disposal. Repot-f No.: EPA/625/1-79/001.
Cincinnati, OH: Water Engineering Research Labora-
tory and Center for Environmental Research Informa-
tion.
USDA/U.S. EPA. 1980. Manual for composting sewage
sludge by the Beltsville aerated-pile method. Report
No.: EPA/600/8-80-022.
WEF/ASCE. 1998. WEF Manual of Practice No. 8, Design
of Municipal Wastewater Treatment Plants. Pub. WEF
(Alexandria, VA) and ASCE (New York, NY).
56
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Yanko, W.A. 1987. Occurrence of pathogens in distribu-
tion and marketing municipal sludges. Report No.: EPA/
600/1 -87/014. (NTIS PB88-154273/AS.) Springfield,
VA: National Technical Information Service.
57
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Chapter 8
Requirements for Reducing Vector Attraction
8.1 Introduction
The pathogens in sewage sludge pose a disease risk
only if there are routes by which the pathogens are brought
into contact with humans or animals. A principal route for
transport of pathogens is vector transmission. Vectors are
any living organisms capable of transmitting a pathogen
from one organism to another either mechanically (by sim-
ply transporting the pathogen) or biologically by playing a
specific role in the life cycle of the pathogen. Vectors for
sewage sludge pathogens would most likely include in-
sects, rodents, and birds.
Suitable methods for measuring vector attraction directly
are not available. Vector attraction reduction is accom-
plished by employing one of the following:
. Biological processes which breakdown volatile solids,
reducing the available food nutrients for microbial ac-
tivities and odor producing potential
• Chemical or physical conditions which stop microbial
activity
• Physical barriers between vectors and volatile solids
in the sewage sludge
At the present time there is no vector attraction equiva-
lency committee that evaluates other options for vector
attraction reduction. The creation of one is being consid-
ered. The specific options outlined in the Part 503 regula-
tion are currently the only available means for demonstrat-
ing vector attraction reduction.
The term "stability" is often used to describe sewage
sludge. Although it is associated with vector attraction re-
duction, stability is not regulated by the Part 503 Rule. With
regard to sewage sludge, stability is generally defined as
the point at which food for rapid microbial activity is no
longer available. Sewage sludge which is stable will gen-
erally meet vector attraction reduction (VAR) requirements.
The converse is not necessarily true; meeting VAR require-
ments does not ensure sewage sludge stability. Because
stability is also related to odor generation and the contin-
ued degradation of sewage sludge, it is often considered
an important parameter when producing biosolids for sale
or distribution. Table 8-I lists some of the common meth-
ods for measuring stability.
Table 8-I. Stability Assessment
Process
Monitoring Methods
Composting
Heat Drying
Alkaline Stabilization
Aerobic Digestion
Anaerobic Digestion
CO, respiration, 0, uptake
Moisture content
pH; pH change with storage; moisture;
ammonia evolution; temperature
SOUR; volatile solids reduction, additional
volatile solids reduction
Gas production; volatile solids reduction,
additional volatile solids reduction
More information on stability can be found in the WERF
publication, "Defining Biosolids Stability: A Basis for Public
and Regulatory Acceptance" (1997).
The Part 503 regulation contains 12 options, described
below and summarized in Table 8-2, for demonstrating a
reduction in vector attraction of sewage sludge. These re-
quirements are designed to either reduce the attractive-
ness of sewage sludge to vectors (Options 1 through 8
and Option 12) or prevent the vectors from coming in con-
tact with the sewage sludge (Options 9 through 11).
Guidance on when and where to sample sewage sludge
to meet these requirements is provided in Chapter 10.
As mentioned in Chapter 3, meeting the vector attrac-
tion reduction requirements must be demonstrated sepa-
rately from meeting the pathogen reduction requirements.
Therefore, demonstration of vector attraction reduction
(e.g., through reduction of volatile solids by 38% as de-
scribed below) does not demonstrate achievement of
pathogen reduction. It should be noted that for Class A
biosolids, vector attraction reduction must be met after or
concurrent with pathogen reduction to prevent growth of
pathogenic bacteria.
8.2 Option 1: Reduction in Volatile Solids
Content [503.33(b)(l)]
This option is intended for use with biological treatment
systems only. Under Option 1, reduction of vector attrac-
tion is achieved if the mass of volatile solids in the sewage
sludge is reduced by at least 38%. This is the percentage
58
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Table 8-2. Vector Attraction Reduction Options
Requirement What is Required?
Most Appropriate For:
Option 1
503.33(b)(1;
At least 38% reduction in volatile solids during
sewage sludge treatment
Sewage sludge processed by:
Anaerobic biological treatment
Aerobic biological treatment
Option 2
503.33(b)(2)
Less than 17% additional volatile solids loss during
bench-scale anaerobic batch digestion of the sewage
sludge for 40 additional days at 30°C to 37°C
(86°F to 99°F)
Only for anaerobically digested sewage sludge that
cannot meet the requirements of Option 1
Option 3
503.33(b)(3)
Option 4
503.33(b)(4)
Less than 15% additional volatile solids reduction during
bench-scale aerobic batch digestion for 30 additional days
at 20°C (68°F)
SOUR at 20°C (68°F) is #1.5 mg oxygen/hr/g total
sewage sludge solids
Only for aerobically digested liquid sewage sludge with
2% or less solids that cannot meet the requirements of
Option 1 — e.g., sewage sludges treated in extended
aeration plants. Sludges with , 2% solids must be
diluted.
Liquid sewage sludges from aerobic processes run at
temperatures between 10 to 30° C. (should not be used
for composted sewage sludges).
Option 5
503.33(b)(5)
Option 6
503.33(b)(6)
Option 7
503.33(b)(7)
Option 8
503.33(b)(8)
Option 9
503.33(b)(9)
Aerobic treatment of the sewage sludge for at least 14
days at over 40°C (104°F) with an average temperature
ofover45°C(113°F)
Addition of sufficient alkali to raise the pH to at least 12
at 25°C (77°F) and maintain a pH $12 for 2 hours and a
pH $11.5 for 22 more hours
Percent solids $75% prior to mixing with other materials
Percent solids $90% prior to mixing with other materials
Sewage sludge is injected into soil so that no significant
amount of sewage sludge is present on the land surface
1 hour after injection, except Class A sewage sludge
which must be injected within 8 hours after the pathogen
reduction process.
Compcsted sewage sludge (Options 3 and 4 are likely
to be easier to meet for sewage sludges from other
aerobic processes)
Alkali-treated sewage sludge (alkaline materials include
lime, fly ash, kiln dust, and wood ash)
Sewage sludges treated by an aerobic or anaerobic
process (i.e., sewage sludges that do not contain
unstabilized solids generated in primary wastewater
treatment)
Sewage sludges that contain unstabilized solids
generated in primary wastewater treatment (e.g., heat-
dried sewage sludges)
Sewage sludge applied to the land or placed on a
surface disposal site. Domestic septage applied to
agricultural land, a forest, or a reclamation site, or
placed on a surface disposal site
Option 10 Sewage sludge is incorporated into the soil within 6 hours
503.33(b)(10) after application to land or placement on a surface disposal
site, except Class A sewage sludge which must be applied
to or placed on the land surface within 8 hours after the
pathogen reduction process.
Option 11 Sewage sludge placed on a surface disposal site must be
503.33(b)(11) covered with soil or other material at the end of each
operating day.
Option 12 pH of domestic septage must be raised to $12 at 25°C
503.33{b)(12) (77°F) by alkali addition and maintained at $12 for 30
minutes without adding more alkali.
Sewage sludge applied to the land or placed on a
surface disposal site. Domestic septage applied to
agricultural land, forest, or a reclamation site, or placed
on a surface disposal site
Sewage sludge or domestic septage placed on a
surface disposal site
Domestic septage applied to agricultural land, a forest,
or a reclamation site or placed on a surface disposal
site
of volatile solids reduction that can generally be attained
by the "good practice" recommended conditions for
anaerobic digestion of 15 days residence time at 35°C
[95°F] in a completely mixed high-rate digester. The per-
cent volatile solids reduction can include any additional
volatile solids reduction that occurs before the biosolids
leave the treatment works, such as might occur when the
sewage sludge is processed on drying beds or in lagoons.
The starting point for measuring volatile solids in sew-
age sludge is at the point at which sewage sludge enters a
sewage sludge treatment process. This can be problem-
59
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atic for facilities in which wastewater is treated in systems
like oxidation ditches or by extended aeration. Sewage
sludges generated in these processes are already sub-
stantially reduced in volatile solids content by their long
exposure to oxidizing conditions in the process. If sewage
sludge removed from these processes is further treated
by anaerobic or aerobic digestion to meet VAR require-
ments, it is unlikely that the 38% reduction required to meet
Option 1 can be met. In these cases, use of Options 2,3,
or 4 is more appropriate.
The end point where volatile solids are measured to cal-
culate volatile solids losses can be at any point in the pro-
cess. Because volatile solids continue to degrade through-
out sewage sludge treatment, it is recommended that
samples be taken at the end point of treatment.
Volatile solids reduction is calculated by a volatile solids
balance around the digester or by the Van Kleeck formula
(Fisher, 1984). Guidance on methods of calculation is pro-
vided in Appendix C.
Volatile solids reduction is typically achieved by anaero-
bic or aerobic digestion. These processes degrade most
of the biodegradable material to lower activity forms. Any
biodegradable material that remains characteristically de-
grades so slowly that vectors are not drawn to it.
8.3 Option 2: Additional Digestion of
Anaerobically Digested Sewage Sludge
[503.33(b)(2)]
Under this option, an anaerobically digested sewage
sludge is considered to have achieved satisfactory vector
attraction reduction if it loses less than 17% additional vola-
tile solids when it is anaerobically batch-digested in the
laboratory in a bench-scale unit at 30°C to 37°C (86°F to
99°F) for an additional 40 days. Procedures for this test
are presented in Appendix D. As noted in Appendix D, the
material balance method for calculating additional volatile
solids reduction will likely show greater reductions than
the Van Kleeck method.
Frequently, return activated sludges have been recycled
through the biological wastewater treatment section of a
treatment works or have resided for long periods of time in
the wastewater collection system. During this time they
undergo substantial biological degradation. If they are sub-
sequently treated by anaerobic digestion for a period of
time, they are adequately reduced in vector attraction, but
because they entered the digester with volatile solids al-
ready partially reduced, the volatile solids reduction after
treatment is frequently less than 38%. The additional di-
gestion test is used to demonstrate that these sewage slud-
ges are indeed satisfactorily reduced in vector attraction.
It is not necessary to demonstrate that Option 1 cannot
be met before using Option 2 or 3 to comply with VAR
requirements.
This additional anaerobic digestion test may have utility
beyond use for sewage sludge from the classical anaero-
bic digestion process. The regulation states that the test
can be used for a previously anaerobically digested sew-
age sludge. One possible application is for sewage sludge
that is to be removed from a wastewater lagoon. Such
sewage sludge may have been stored in such a lagoon for
many years, during which time it has undergone anaero-
bic digestion and lost most of its volatile solids. It is only
recognized by the regulations as a sewage sludge when it
is removed from the lagoon. If it were to be further pro-
cessed by anaerobic digestion, the likelihood of achieving
38% volatile solids reduction is very low. The additional
anaerobic digestion test which requires a long period of
batch digestion at temperatures between 30 and 37°C
would seem to be an appropriate test to determine whether
such a sewage sludge has the potential to attract vectors.
8.4 Option 3: Additional Digestion of
Aerobically Digested Sewage Sludge
[503.33(b)(3)]
Under this option, an aerobically digested sewage sludge
with 2% or less solids is considered to have achieved sat-
isfactory vector attraction reduction if it loses less than 15%
additional volatile solids when it is aerobically batch-di-
gested in the laboratory in a bench-scale unit at 20°C (68°F)
for an additional 30 days. Procedures for this test and the
method for calculating additional volatile solids destruc-
tion are presented in Appendix D. The test can be run on
sewage sludges up to 2% solids and does not require a
temperature correction for sewage sludges not initially di-
gested at 20°C (68°F). Liquid sludges with greater than
2% solids can be diluted to 2% solids with unchlorinated
effluent, and the test can then be run on the diluted sludge.
This option should not be used for non-liquid sewage sludge
such as dewatered cake or compost.
This option is appropriate for aerobically digested sew-
age sludges that cannot meet the 38% volatile solids re-
duction required by Option 1. These include sewage slud-
ges from extended aeration and oxidation ditch processes,
where the nominal residence time of sewage sludge leav-
ing the wastewater treatment processes section generally
exceeds 20 days. In these cases, the sewage sludge may
already have been substantially reduced in biological
degradability prior to aerobic digestion.
As was suggested for the additional anaerobic digestion
test, the additional aerobic digestion test may have appli-
cation to sewage sludges that have been aerobically treated
by other means than classical aerobic digestion.
8.5 Option 4: Specific Oxygen Uptake Rate
(SOUR) for Aerobically Digested
Sewage Sludge [503.33(b)(4)]
For an aerobically digested sewage sludge with a total
solids content equal to or less than 2% which has been
processed at a temperature between 10-30° C, reduc-
tion in vector attraction can also be demonstrated using
the SOUR test. The SOUR of the sewage sludge to be
used or disposed must be less than or equal to 1.5 mg of
60
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oxygen per hour per gram of total sewage sludge solids
(dry weight basis) at 20°C (68°F).1 This test is based on
the fact that if the aerobically treated sewage sludge con-
sumes very little oxygen, its value as a food source for
vectors is very low and therefore vectors are unlikely to be
attracted to it. Frequently aerobically digested sewage slud-
ges are circulated through the aerobic biological waste-
water treatment process for as long as 30 days. In these
cases, the sewage sludge entering the aerobic digester is
already partially digested, which makes it difficult to dem-
onstrate the 38% reduction required by Option 1.
The oxygen uptake rate depends on the conditions of
the test and, to some degree, on the nature of the original
sewage sludge before aerobic treatment. The SOUR test
should not be used on sewage sludge products such as
heat or air dried sludge or compost. Because of the reduc-
tion of microbial populations that occur in these processes,
the SOUR results are not accurate and should not be used.
SOUR testing on sewage sludges with a total solids con-
tent below 0.5% may give inaccurately high results. Farrell,
et al. (1996) cite the work of several investigators indicat-
ing such an effect. Farrell, et al. (1996) also note that stor-
age for up to two hours did not cause a significant change
in the SOUR measurement. It is therefore suggested that
a dilute sewage sludge could be thickened to a solids con-
tent less than 2% solids and then tested, provided that the
thickening period is not in excess of two hours.
The SOUR test requires a poorly defined temperature
correction at temperatures differing substantially from 20°C
(68°F). SOUR cannot be applied to sewage sludges di-
gested outside the 10-30° C range (50-86°F). The actual
temperature of the sewage sludge tested cannot be ad-
justed because temperature changes can cause short-term
instability in the oxygen uptake rate (Benedict, et al. (1973);
Farrell, et al. [1996]), and this would invalidate the results
of the test. Guidance on performing the SOUR test and on
sewage sludgedependent factors are provided in Appen-
dix D.
It should be noted that the limit on the use of the SOUR
test for sewage sludges at different solids and tempera-
ture levels is due to the lack of research and data on differ-
ent sewage sludges. EPA encourages the collection of
SOUR data for different sewage sludges so that at some
point, Option 4 may be expanded to include more sewage
sludge materials.
'SOUR is defined in Part 503 as the mass of oxygen consumed per unit time per
unit mass of total solids (dry weight basis) in the sewage sludge. SOUR is usually
based on total suspended volatile solids rather than total solids because it is as-
sumed that it is the volatile matter in the sewage sludge that is being oxidized. The
SOUR definition in Part 503 is based on the total solids primarily to reduce the
number of different determinations needed and for consistency with application
rates, which are measured in total solids per unit area. Generally, the range in the
ratio of volatile solids to total solids in aerobically digested sewage sludges is not
large. The SOUR based on total solids will merely be slightly lower than if it had
been based on volatile suspended solids to indicate the same endpoint.
8.6 Option 5: Aerobic Processes at Greater
Than 40°C [503.33(b)(5)]
The sewage sludge must be aerobically treated for 14
days or longer during which time the temperature must be
over 40°C (104°F) and the average temperature higher than
45°C (113°F). This option applies primarily, but not exclu-
sively, to composted sewage sludge. These processed
sewage sludges generally contain substantial amounts of
partially decomposed organic bulking agents, in addition
to sewage sludge. This option must be used for composted
sewage sludge; other options are either not appropriate or
have not adequately been investigated for use with com-
post.
The Part 503 regulation does not specifically mention or
limit this option to composting. This option can be applied
to sewage sludge from other aerobic processes such as
aerobic digestion as long as temperature requirements can
be met and the sewage sludge is maintained in an aerobic
state for the treatment period, but other methods such as
Options 3 and 4 are likely to be easier to meet for these
sewage sludges.
If composting is used to comply with Class A pathogen
requirements, the VAR time-temperature regime must be
met along with or after compliance with the pathogen re-
duction time-temperature regime.
8.7 Option 6: Addition of Alkali
[503.33(b)(6)]
Sewage sludge is considered to have undergone ad-
equate vector attraction reduction if sufficient alkali is added
to:
. Raise the pH to at least 12
. Maintain a pH of at least 12 without addition of more
alkali for 2 hours
. Maintain a pH of at least 11.5 without addition of more
alkali for an additional 22 hours
pH should be measured in a slurry at 25°C. For more
information on making a slurry, see Section 10.7. Either
sewage sludge samples may be taken and heated or
cooled to 25°C, or results can be adjusted based on the
ambient temperature where pH is measured and the fol-
lowing calculation:
Correction Factor = 0.03 oH units XfT-2 5" C
1.0TC'
Actual pH = Measured pH +/- the Correction Factor
T= Temperature measured
Example of Using the prt Correction Factor
If the measured pH Is 12.304 at 30° C, the actual pH can
be calculated as follows:
Correction Factor« 0.03 X (30-25) =+0.15
Actual pH - 12.304+ 0.15 - 12.454
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It should be noted that temperature compensation de-
vices on pH meters correct only for variations in the con-
ductance of pH probes, and not for the variability in solu-
tion concentration. Therefore, the temperature correction
noted above should be applied to pH measurements, even
if a pH meter with temperature settings is used.
As noted in Section 5.6, the term "alkali" means a sub-
stance that causes an increase in pH. Raising sewage
sludge pH through alkali addition reduces vector attrac-
tion by reducing or stopping biological activity. However,
this reduction in biological activity is not permanent. If the
pH drops, surviving bacteria become biologically active and
the sewage sludge will again putrefy and potentially at-
tract vectors. The more soluble the alkali, the less likely it
is that there will be an excess present when a pH of 12 is
reached. Consequently, the subsequent drop in pH with
time will be more rapid than if a less soluble alkali is used.
The conditions required under this option are designed
to ensure that the sewage sludge can be stored for at least
several days at the treatment works, transported, and ap-
plied to soil without the pH falling to the point where bio-
logical activity results in vector attraction. The requirement
of raising the pH to 12 increases the probability that the
material will be used before pH drops to a level at which
putrefaction can occur. The requirements for pH adjust-
ment of domestic septage are less stringent because it is
unlikely that septage haulers will hold domestic septage
for long periods of time.
Raising the pH to 12 and maintaining this pH for two
hours and a pH of 11.5 for an additional 22 hours ensures
that the pH will stay at adequately high levels to prevent
putrefaction before disposal in all but unusual cases. In
any event, it is prudent in a timely manner to apply sludge
in a thin layer or incorporate it into the soil for the preven-
tion of odors and vector attraction.
More information on alkali addition and measurement of
pH are included in Chapter 10.
8.8 Option 7: Moisture Reduction of
Sewage Sludge Containing No
Unstabilized Solids [503.33(b)(7)]
Under this option, vector attraction is considered to be
reduced if the sewage sludge does not contain unstabilized
solids generated during primary wastewater treatment and
if the solids content of the sewage sludge is at least 75%
before the sewage sludge is mixed with other materials.
Thus, the reduction must be achieved by removing water,
not by adding inert materials.
It is important that the sewage sludge not contain
unstabilized solids because the partially degraded food
scraps likely to be present in such a sewage sludge could
attract birds, some mammals, and possibly insects, even
if the solids content of the sewage sludge exceeds 75%.
The way dried sewage sludge is handled or stored be-
fore use or disposal can create or prevent vector attrac-
tion. If dried sewage sludge is exposed to high humidity,
the outer surface of the sewage sludge could equilibrate
to a lower solids content and attract vectors. Proper man-
agement should be conducted to prevent this from hap-
pening.
8.9 Option 8: Moisture Reduction of
Sewage Sludge Containing Unstabilized
Solids [503.33(b)(8)]
Vector attraction of any sewage sludge is considered to
be reduced if the solids content of the sewage sludge is
increased to 90% or greater. This extreme desiccation
deters vectors in all but the most unusual situations. As
noted for Option 7, the solids increase should be achieved
by removal of water and not by dilution with inert solids.
Drying to this extent severely limits biological activity and
strips off or decomposes the volatile compounds that at-
tract vectors.
Because sewage sludge meeting vector attraction re-
duction with this option may contain unstabilized solids,
material that absorbs moisture or is rewet may putrefy and
attract vectors. Proper storage and use of this material
should be considered in order to prevent potential patho-
gen growth and vector attraction.
8.10 Option 9: Injection [503.33(b)(9)]
Vector attraction reduction can be achieved by injecting
the sewage sludge below the ground. Under this option,
no significant amount of the sewage sludge can be present
on the land surface within 1 hour after injection, and, if the
sewage sludge is Class A with respect to pathogens, it
must be injected within 8 hours after discharge from the
pathogen-reduction process.
Injection of sewage sludge beneath the soil places a
barrier of earth between the sewage sludge and vectors.
The soil quickly removes water from the sewage sludge,
which reduces the mobility and odor of the sewage sludge.
Odor is usually present at the site during the injection pro-
cess, but it quickly dissipates when injection is complete.
The special restriction requiring injection within 8 hours
for Class A sewage sludge is needed because these sew-
age sludges are likely devoid of actively growing bacteria
and are thus an ideal medium for growth of pathogenic
bacteria (see Section 4.3). If pathogenic bacteria are
present (survivors or introduced by contamination), their
numbers increase slowly for the first 8 hours after treat-
ment, but after this period, their numbers can rapidly in-
crease. This kind of explosive growth is not likely to hap-
pen with Class B sludge because high densities of non-
pathogenic bacteria are present which suppresses the
growth of pathogenic bacteria. In addition, the use of Class
B biosolids requires site restrictions which reduce the risk
of public exposure to pathogens. Consequently, this spe-
cial requirement is not needed for Class B biosolids
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8.11 Option 10: Incorporation of Sewage
Sludge into the Soil [503.33(b)(10)]
Under this option, sewage sludge applied to the land
surface or placed on a surface disposal site must be incor-
porated into the soil within 6 hours after application to or
placement on the land. If the sewage sludge is Class A
with respect to pathogens, the time between processing
and incorporation after application or placement must not
exceed 8 hours -the same as for injection under Option
9.
When applied at agronomic rates, the loading of sew-
age sludge solids typically is about I/I 00th or less of the
mass of soil in the plow layer (approximately the top six
inches of soil). If mixing is reasonably good, the dilution of
sewage sludge in the soil surface is equivalent to that
achieved with soil injection. Odor will be present and vec-
tors will be attracted temporarily, as the sewage sludge
dewaters on the soil surface. This attraction diminishes
and is virtually eliminated when the sewage sludge is mixed
with the soil. The mixing method applies to liquid sewage
sludges, dewatered sewage sludge cake, and even to dry
sewage sludges that have not already met the vector at-
traction reduction requirements of the regulation by one of
the other options.
The 6 hours allowed to complete the mixing of sewage
sludge into the soil should be adequate to allow for proper
incorporation. As a practical matter, it may be wise to com-
plete the incorporation in a much shorter time. Clay soils
tend to become unmanageably slippery and muddy if the
liquid sewage sludge is allowed to soak into the first inch
or two of topsoil.
8.12 Option 11: Covering Sewage Sludge
[503.33(b)(11)]
Under this option, sewage sludge placed on a surface
disposal site must be covered with soil or other material at
the end of each operating day. Daily covering reduces vec-
tor attraction by creating a physical barrier between the
sewage sludge and vectors, while environmental factors
work to reduce pathogens.
8.13 Option 12: Raising the pH of
Domestic Septage [503.33(b)(12)]
This option applies only to domestic septage applied to
agricultural land, forest, a reclamation site, or surface dis-
posal site. Vector attraction is reduced if the pH is raised
to at least 12 through alkali addition and maintained at 12
or higher for 30 minutes without adding more alkali. (These
conditions also accomplish pathogen reduction for domes-
tic septage-see Section 5.6.) When this option is used,
every container (truckload) must be monitored to demon-
strate that it meets the requirement. As noted in Section
5.6, "alkali" refers to a substance that causes an increase
inpH.
This vector attraction reduction requirement is slightly
less stringent than the alkali addition requirement for sew-
age sludge. The method is geared to the practicalities of
the use or disposal of domestic septage, which is typically
treated by lime addition in the domestic septage hauling
truck. The treated septage is typically applied to the land
shortly after lime addition. During the very short time inter-
val, the pH is unlikely to fall to a level at which vector at-
traction could occur.
If domestic septage is not applied soon after pH adjust-
ment, it is recommended that pH be retested, and addi-
tional alkali be added to the domestic septage to raise the
pH to 12 if necessary. Alternatively, if pH has dropped and
the domestic septage begins to putrefy, it is advisable to
cover or incorporate the domestic septage in order to pre-
vent vector attraction.
8.14 Number of Samples and Timing
Unlike pathogenic bacteria, volatile solids cannot regen-
erate once they are destroyed, so samples can be taken
at any point along the process. However, since volatile
solids are destroyed throughout treatment, it is recom-
mended that samples be taken at the end of processing.
Facilities which use Option 2 or 3 to demonstrate vector
attraction reduction must schedule sampling to leave ample
time to complete the laboratory tests before sewage sludge
is used or disposed. A suggested procedure would be to
take several samples at evenly spaced time intervals dur-
ing the period between the required monitoring dates and
calculate running averages comprised of at least four vola-
tile solids results. This has the advantage of not basing
the judgement that the process is performing adequately
(or inadequately) on one or two measurements that could
be erroneous because of experimental error or a poorly
chosen sample inadvertently taken during a brief process
upset. It also provides an important quality control mea-
sure for process operations. Since the Part 503 regulation
do not specify a sampling program, it is recommended that
sewage sludge preparers consult with the regulatory au-
thority with regard to sampling schedules.
8.15 Vector Attraction Reduction
Equivalency
Many of the vector attraction reduction tests are time
consuming and inconvenient, particularly for small treat-
ment plants that do not have a laboratory. Efforts to define
new, simpler methods for measuring vector attraction are
on-going.
Since it is infeasible to measure the actual attraction of
vectors, given the large number of variables, methodology
development must continue to focus on the cause of vec-
tor attraction, namely the availability of a food source (vola-
tile solids) or odor. The tests to measure the attractants
may vary depending on the technology by which the sew-
age sludge is processed.
Some of the parameters which might be used to mea-
sure vector attraction may include gas production or mea-
sures of microbial activity. For example, several methods
63
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which measure carbon dioxide evolution or reheating po-
tential are currently in use to measure compost stability,
but these methods must be examined more closely to de-
termine if they can be applied to other forms of sewage
sludge and if results can be adequately correlated to vec-
tor attraction.
The responsibility to eventually develop additional vec-
tor attraction reduction test protocols lies with the scien-
tific community and the sewage sludge industry. Since there
is currently no standard procedure for considering VAR
equivalency, new methods must be submitted to the EPA
for consideration and potential inclusion in the next rule-
making effort.
References and Additional Resources
Benedict, A.M., and D.A. Carlson. 1973. Temperature ac-
climation in aerobic bio-oxidation systems. Jour.
WPCF: 45(1), 10-24. January.
Farrell, Joseph B., Vinayak Bhide, James E. Smith, Jr.
1996. Development of EPA's new methods to quantify
vector attraction of wastewater sludges. Water Envi-
ronment Research, Volume 68, Number 3.
Fisher, W.J. 1984. Calculation of volatile solids destruc-
tion during sludge digestion. Pp 514-528 in Bruce, A.,
ed Sewage sludge stabilization and disinfection. Pub-
lished for Water Research Center. Chichester, England:
E.Harwood, Ltd.
Smith, J. E.,Jr.,and J. B. Farrell, Vector attraction reduc-
tion issues associated with the Part 503 Regulations
and Supplemental Guidance, Proceedings of the Wa-
ter Environment Federation's Conference, "Interna-
tional Management of Water and Wastewater Solids
for the 21 st Century': A Global perspective, June 19-
22, 1994, Washington, DC, pp 131 1-1330.
Switzenbaurm, Michael S., L.H. Moss, E.Epstein, A. B.
Pincince, J.F. Donovan. 1997. Defining biosolids sta-
bility: a basis for public and regulatory acceptance.
Water Environment Research Foundation.
WEF/ASCE. 1998. WEF Manual of Practice No. 8, Design
of Municipal Wastewater Treatment Plants. Pub. WEF
(Alexandria, VA) and ASCE (New York, NY).
WERF. 1997. Defining biosolids stability: A basis for public
and regulatory acceptance. Pub. WERF. Alexandria,
VA.
U.S. EPA 1992. Technical support document for reduction
of pathogens and vector attraction in sewage sludge.
EPA 822/R-93-004. EPA, Washington, D.C.
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Chapter 9
Sampling Procedures and Analytical Methods
9.1 Introduction
Many of the Part 503 Subpart D pathogen and vector
attraction reduction requirements call for monitoring and
analysis of the sewage sludge to ensure that microbiologi-
cal quality and vector attraction reduction meet specified
requirements (see Chapters 4 to 6 for a description of the
requirements).The purpose of this chapter is to describe
procedures for obtaining representative samples and in-
suring their quality and integrity. It also summarizes the
analytical methods required under Part 503, and directs
the reader to other sections of this document that describe
some of those methods.
Sampling personnel will also benefit from reading ex-
panded presentations on the subject. "Standard Methods"
(APHA, 1992), "Principles of Environmental Sampling"
(Keith, 1988), "Samplers and Sampling Procedures for
Hazardous Waste Streams" (EPA, 1980), 'Sludge Sam-
pling and Analysis Guidance Document" (EPA, 1993), and
ASTM Standard E 300-86, "Standard Practice for Sam-
pling Industrial Chemicals" (ASTM, 1992a) are highly rec-
ommended. The latter publication provides an in-depth
description of available sampling devices and procedures.
When referring to other publications, it is important to
note that most guidance on specific sampling techniques
is directed toward chemical analysis. Procedures described
may be inappropriate for microbiological sampling because
they expose the samples to possible contamination, or may
be appropriate only after some modification to reduce the
risk of microbial contamination during sampling.
9.2 Laboratory Selection
A very important, but often overlooked component of
pathogen and vector attraction monitoring is selecting an
appropriate analytical laboratory. The analysis of sewage
sludge or biosolids for indicator and pathogenic organisms
is more complex than water analysis. Solid samples such
as biosolids are prepared differently than water samples
and also typically contain a much higher background mi-
crobial population than water contains. Biosolids products
such as compost can be very heterogeneous, requiring
special sample preparation procedures. It is therefore im-
portant to use a laboratory that has developed an exper-
tise through the routine analysis of biosolids products.
Regional and state sludge coordinators should be con-
tacted for assistance in selecting a qualified laboratory.
To ensure that a laboratory has adequate experience
with biosolids analyses, the following information should
be obtained and reviewed.
• For how long has the laboratory been analyzing
biosolids for the specified parameters?
. Approximately how many biosolids samples does the
laboratory analyze per week or month?
. For how many wastewater treatment facilities is the
laboratory conducting the specified analyses?
. A list of references.
. Does the laboratory have a separate and distinct mi-
crobiology lab?
. Does the laboratory have microbiologists on staff?
Request and review their resumes
• Who will actually perform the analyses?
. Is the laboratory familiar with the analytical procedures
including sample preparation, holding times, and QA/
QC protocols?
A laboratory tour and reference check is also recom-
mended. A good laboratory should be responsive, provid-
ing requested technical information in a timely manner. It
is the biosolids generator's responsibility to provide accu-
rate analytical results. Consequently, the selection of an
appropriate laboratory is an important component of de-
veloping a biosolids monitoring plan.
9.3 Safety Precautions
Sewage sludges that are being sampled should be pre-
sumed to contain pathogenic organisms, and should be
handled appropriately. Both the sampler and the person
carrying out the microbiological analysis must take appro-
priate precautions. Safety precautions that should be taken
when sampling and when analyzing the samples are dis-
cussed in Standard Methods (APHA, 1992) in Sections
1060Aand1090C.
Individuals performing sampling (usually employees of
wastewater treatment works) should receive training in the
microbiological hazards of sewage sludge and in safety
65
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precautions to take when sampling. Laboratory personnel
should be aware that the outside of every sample con-
tainer is probably contaminated with microorganisms, some
of which may be pathogens. Personal hygiene and labo-
ratory cleanliness are also extremely important. Several
safety practices that should be standard procedures dur-
ing sample collection and analysis are:
. Gloves should be worn when handling or sampling
untreated sewage sludge or treated biosolids.
. Personnel taking the samples should clean sample
containers, gloves, and hands before delivering the
samples to others.
. Hands should be washed frequently and always be-
fore eating, smoking, and other activities that involve
hand-to-mouth contact.
• Photocell-activated or foot-activated hand washing
stations are desirable to reduced spreading of con-
tamination to others.
• Employees should train themselves to avoid touching
their lips or eyes.
. Mouth pipetting should be forbidden.
. Smoking should not be allowed inside the lab.
Employees involved in sample collection (or any other
activity where they are exposed to wastewater or sewage
sludges) should review their immunization history. At a
minimum, employees should be immunized against teta-
nus. However, employees should consider immunization
for other diseases, particularly hepatitis A and B. Employ-
ees should also consider having a blood sample analyzed
to determine if they still have active antibodies for the vari-
ous immunizations they received as children.
Personnel analyzing sewage sludge or biosolids samples
should receive training in awareness and safety concern-
ing biohazards. Because microbiological laboratories have
safety programs, this subject is not covered in depth here.
A facility's sampling plan should include a section on mi-
crobiological hazards and appropriate safety practices or,
alternatively, refer the reader to another document where
this information is presented.
9.4 Requirements for Sampling Equipment
and Containers
Containers
Sampling containers may be of glass or plastic that does
not contain a plasticizer (Teflon, polypropylene, and poly-
ethylene are acceptable). Plastic bags are especially use-
ful for thick sewage sludges and free-flowing solids. Pre-
sterilized bags are available. Stainless steel containers are
acceptable, but steel or zinc coated steel vessels are not
appropriate. In addition to providing guidance on appropri-
ate containers for specific analyses, private analytical labo-
ratories will typically provide sample containers at no cost.
Sampling containers used for microbiological analyses
should be sterile. Sampling tools that come in contact with
the actual sample should be constructed of stainless steel,
which is easily cleaned, and sterilized. Tools made of wood,
which is difficult to sterilize because of porosity, should not
be used.
Equipment
The sampling equipment used is primarily dependent
on the type of material being sampled. For relatively high
solids content biosolids, a hand trowel or scoop may be
adequate, whereas, collecting stratified samples from a
lagoon requires more sophisticated and specialized equip-
ment. Automated sampling equipment, as commonly used
for wastewater, should not be used. Such equipment can
cause solids separation during sampling and is difficult to
clean, resulting in cross contamination. Sampling equip-
ment should be constructed of a non-corrosive materials,
such as stainless steel, Teflon, or glass, that can be thor-
oughly cleaned. Sampling equipment should be dedicated
for this task and should not be used for other applications.
Equipment should be cleaned well with detergent and a
nylon scrub brush after each use and stored inside in a
dedicated location. The types of sampling equipment and
their applications are presented in Table 9-1. The use of
this equipment is discussed in greater detail in Sections
9.6 and 9.7.
Sterilization
The containers and tools used for sampling must be ster-
ilized if the biosolids product is to be analyzed for Class A
microbiological parameters. Alternatively, pre-sterilized,
disposable scoops, and other sampling devices can be
purchased, alleviating the need to sterilize sampling equip-
ment. Conservative microbiological practice also requires
sterilization of containers and sampling tools used for col-
lecting samples to be tested for meeting the Class B re-
quirements. Sample containers and equipment should be
scrupulously cleaned prior to actual sample collection. Af-
ter the samples are collected, the sampling equipment
should be cleaned well with soap and water and put away
until the next sampling event. Equipment should be dedi-
cated to sampling and not used for other activities. Only
equipment that touches the actual sample must be steril-
ized. Equipment such as shovels or heavy equipment used
to access a sludge pile interior does not need to be steril-
ized, but should be clean, as long as another sterile sample
collection device (such as a hand trowel) is used to ac-
cess and collect the actual sample. Sterilization is not re-
quired when collecting samples of sewage sludge to be
used in vector attraction reduction tests, but all equipment
must be clean.
Either steam or a sterilizing solution such as sodium
hypochlorite (household bleach) should be used for steril-
izing equipment. If bleach is used, equipment must be
rinsed thoroughly in order to prevent residual bleach from
having an effect on the microbial population in the sample.
Equipment should be thoroughly washed with water, soap,
and a brush prior to sterilization. If an autoclave or large
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Table 9-i. Equipment used for Collecting Sewage Sludge Samples
Equipment Application
Composite Liquid Waste
Sampler (Coliwasa)
Weighted Bottle
Dipper
Sampling Thief
Trier
Auger
Scoops and Shovels
The Coliwasa is a device employed to sample free-flowing sewage sludges contained in drums, shallow tanks, pits,
and similar containers. It is especially useful for sampling wastes that consist of several immiscible liquid phases.
The Coliwasa consists of a glass, plastic, or metal tube equipped with an end closure that can be opened and closed
while the tube is submerged in the material to be sampled.
This sampling device consists of a glass or plastic bottle, sinker, stopper, and a line that is used to lower, raise, and
open the bottle. The weighted bottle is used for sampling free flowing sewage sludges and is particularly useful for
obtaining samples at different depths in a lagoon. A weighted bottle with line is built to the specifications in ASTM
Method D270 and E300.
The dipper consists of a glass or plastic beaker clamped to the end of a two- or three-piece telescoping aluminum or
fiberglass pole that serves as the handle. A dipper is used for obtaining samples of free flowing sewage sludges that
are difficult to access. Dippers are not available commercially and must be fabricated.
A thief consists of two slotted concentric tubes, usually made of stainless steel or brass. The outer tube has a conical
pointed tip that permits the sampler to penetrate the material being sampled. The inner tube is rotated to open and
close the sampler. A thief is used to sample high solids content materials such as composted and heat dried biosolids
for which particle diameter is less than one-third the width of the slots. Thief samplers are available from laboratory
supply companies.
A trier consists of a tube cut in half lengthwise with a sharpened tip that allows the sampler to cut into sticky materials
such as dewatered cake and lime stabilized biosolids. A trier samples moist or sticky solids with a particle diameter
less than one-half the diameter of the trier. Triers 61 to 100 cm long and 1.27 to 2.54 cm in diameter are available
from laboratory supply companies
An auger consists of sharpened spiral blades attached to a hard metal central shaft. An auger can be used to obtain
samples through a cross section of a biosolids stockpile. Augers are available at hardware and laboratory supply
stores.
Scoops are used to collect samples from sewage sludge or biosolids stockpiles, shallow containers, and conveyor
belts. Stainless steel or disposable plastic scoops are available at laboratory supply houses. Due to the difficulty of
sterilizing shovels and other large sampling equipment, this type of equipment should only be used for accessing the
center of stockpiles and should not be used for collecting the actual sample.
pressure cooker is available, enclose the sampling tool in
a kraft paper bag and place the bag in the autoclave. A
minimum period of 30 minutes at a temperature of 121°C
is required for sterilization. The kraft paper bag keeps the
sampling device from becoming contaminated in the field.
A steam cleaner can also be used to sterilize sampling
equipment. Place the equipment in a heat resistant plastic
bucket and direct steam onto the equipment for a mini-
mum of 10 minutes. When done, place the sterilized equip-
ment in a kraft paper bag.
Many facilities do not have an autoclave or steam clean-
ing equipment and will need to use a sterilizing solution to
sterilize equipment. A 10% household bleach solution (1
part bleach, 9 parts water) is readily available and works
well. However, bleach is corrosive and may also affect the
microbial population of a sample and does need to be ad-
equately removed from the equipment prior to sample col-
lection. Make up the 10% solution in a clean plastic bucket.
Immerse each piece of clean equipment in the solution for
a minimum contact time of a minute. Rinse the equipment
in another bucket containing sterile or boiled water. Let
the equipment air dry for a few minutes or dry with sterile
paper or cloth towels. After drying, place the equipment in
a paper bag. Sterile plastic bags obtained from a scientific
equipment supplier can also be used for short-term sterile
equipment storage.
9.5 Sampling Frequency and Number of
Samples Collected
The primary objective of biosolids monitoring is to as-
sure that all of the biosolids produced meets the regula-
tory requirements related to land application. It is obviously
not feasible to sample and analyze every load of biosolids
leaving a facility, nor is it necessary. However, a sampling
plan does need to adequately account for the variability of
the biosolids. This entails collecting samples at an adequate
frequency and analyzing a sufficient number of samples.
The minimum sampling frequency and number of samples
to be analyzed are shown in 40 CFR Part 503. As shown
in Table 3-4, the sample collection frequency is determined
by the amount of biosolids used or disposed.
The number of samples which must be analyzed for com-
pliance with Class A microbiological parameters is not
specified, however, it is strongly recommended that mul-
tiple samples per sampling event be analyzed for biosolids.
The number of samples taken must be sufficient to ad-
equately represent biosolids quality. It must be noted that
for Class A biosolids, analytical results are not averaged:
every sample analyzed must meet the Class A require-
ments.: "Either the density of fecal coliform in the sewage
sludge must be less than 1,000 MPN per gram of total
solids (dry weight basis), or the density of Salmonella sp.
67
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bacteria in sewage sludge must be less than 3 MPN per 4
grams of total solids (dry weight basis).".
To meet Class B Alternative 1 requirements, seven
samples must be taken and the geometric mean of results
must meet the 2.0 x 106 MPN fecal coliform per dry gram
limit (see Chapter 5). It is recommended that the samples
be taken over a two-week period in order to adequately
represent variability in the sewage sludge.
The actual sampling and analysis protocol is typically
developed by the facility and reported to the regulatory
authority, which can require a more stringent sampling and
analysis protocol than that stipulated in the Part 503 regu-
lation. In some cases, the regulatory authority may initially
require a more stringent monitoring schedule which may
be relaxed once product consistency is established. The
biosolids preparer should carefully consider the treatment
process, analytical variability, end-use, and other factors
when determining the frequency and number of samples
to be analyzed. Collecting samples more frequently or
analyzing more samples will help to ensure the product
meets the regulatory criteria and that pathogen and vector
attraction reduction goals have been met. More informa-
tion on this subject is available in Chapter 10.
It is recommended that additional sampling be conducted
for heterogeneous biosolids products. A single grab sample
may adequately represent the sewage sludge in a digester
that is being mixed, but might not adequately represent
several hundred yards of compost product stored in sev-
eral stockpiles. Likewise, a facility that conducts a single
annual analysis should consider more frequent monitor-
ing, particularly if the analytical results from the annual
analysis are near the regulatory limit. It is a facility's re-
sponsibility and in the facility's best interest to develop a
monitoring plan that assures product quality.
9.6 Sampling Free-Flowing Sewage
Sludges
Sewage sludges below about 7% solids behave, at worst,
like moderately viscous liquids such as an SAE 20 lubri-
cating oil. They flow freely under small pressure gradients,
and flow readily into a sample bottle. They are heteroge-
neous, and concentration gradients develop upon stand-
ing. Generally settling is slow and is overcome by good
mixing.
Liquid sewage sludges may be flowing in pipes, under-
going processing, or stored in concrete or metal tanks, in
tank cars or tank trucks, or in lagoons. This section de-
scribes procedures for sampling from these various situa-
tions, except for lagoons, which are discussed in Section
9.7.
Filling Containers
Liquid sewage sludge samples are usually transferred
into wide mouth bottles or flexible plastic containers. Sew-
age sludges can generate gases, and pressure may build
up in the container. Consequently, the bottle or container
is generally not filled. If the sewage sludge is to be used
for the oxygen uptake test, the sample bottle should not
be more than half full, to provide some oxygen for respira-
tion of the microorganisms in the sewage sludge. Con-
versely, if the sewage sludge is to be used for the addi-
tional anaerobic digestion test for vector attraction reduc-
tion, it is important that it not be exposed to oxygen more
than momentarily. Consequently, sample bottles must be
completely filled to the top. Bottles should have closures
that can pop off, or else be made of flexible plastic that
can both stretch and assume a spherical shape to relieve
any internal pressure that develops.
The containers used to collect the samples can be
widemouth bottles that can be capped, or pails. If a pail is
used and only part of its contents will be taken as a sample,
the sample should be transferred to a bottle at the sam-
pling location. Preferably, the transfer should be made by
use of a ladle rather than by pouring, since some settling
can occur in the pail, particularly with primary or mixed
sewage sludges of solids contents below about 3%.
Collecting Liquid Sewage Sludge Samples
If liquid sewage sludges are to be sampled, it is most
desirable to sample them as they are being transferred
from one vessel to another. Preferably this is done down-
stream of a pump that serves to mix the sewage sludge
thoroughly. Ideally, the sample is taken through a probe
facing upstream in the center of the discharge pipe and is
withdrawn at the velocity of the liquid at the center-line of
the pipe. This approach generally is not possible with sew-
age sludge, because fibrous deposits can build up on the
probe and plug up the pipeline.
Sampling through a side tap off the main discharge pipe
is adequate only if the flow is turbulent and the sample
point is over ten pipe diameters downstream from the pipe
inlet (e.g., for a 3-inch [7.6-cm] pipe, 30 inches [76 cm]
downstream) or the tap is downstream from a pump. For
any kind of a slurry, the fluid at the wall contains fewer
particles than the bulk of the fluid in the pipe. The sample
should be withdrawn fast enough so that it minimizes the
amount of thinned-out fluid from the outside pipe wall that
enters the sample.
If the sewage sludge discharges into the open as it is
transferred from one vessel to another, it can be sampled
by passing a sample container through the discharge. The
container should be large enough to catch the whole dis-
charge during the sampling interval, rather than, for ex-
ample, just sampling the center or the edge of the dis-
charge. The sample container could be a pail or a beaker
at the end of an extension arm. Sample volume should be
about three times what is needed for the analyses planned.
The collection of a representative sample often requires
the use of time compositing procedures. For example, if a
digester is being sampled during a withdrawal that takes
about 15 minutes, a sample can be taken during the first,
second, and third 5-minute period. The three separate
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samples should be brought back to the laboratory and
composited into a single sample. If the sample is being
analyzed for bacteria, viruses, or vector attraction reduc-
tion, the composite should be prepared within an hour of
collecting the first individual grab sample. A longer time
period might allow microbiological changes to occur in the
first sample taken. Composite sampling over 24 hours is
possible for viable helminth ova analysis, provided that the
ova in the sample are not exposed to chemical or thermal
stress such as temperatures above 40°C (104°F) or cer-
tain chemicals such as ammonia, hydroxides, and oxidants.
Sampling Sewage Sludge in Tanks
The purpose of the sampling is to determine the proper-
ties of the entire mass of the sewage sludge, rather than,
for example, to find out if there is a gradient in the property
at various points in the tank. This requires that the tank be
well-mixed, otherwise many subsamples must be taken
throughout the tank and composited. Large tanks, even if
they are well-mixed, have the potential for developing gra-
dients in composition. An enclosed tank such as an anaero-
bic digester must be sampled through pipelines entering
the digester. A minimum of three taps on a side wall of the
enclosed tank is recommended. The sample tap pipe
should project several feet into the tank. Precautions must
be taken to minimize contamination from sample collec-
tion lines. When a sample is taken, enough material must
be withdrawn to thoroughly flush the line before the sample
is collected. This helps flush any contaminants in the
sample line and assure that a representative sample is
collected from the tank. The sample line should be back-
flushed with water after the sample is withdrawn to clean
out residual sewage sludge and prevent microbial growth.
Sampling should be conducted when the tank is being
agitated. An open tank such as an aerobic digester can be
sampled by drawing a vacuum on a vacuum-filtering flask
connected to a rigid tube lowered to the desired level in
the tank. A weighted sampling bottle may also be used to
sample the liquid at the desired depth in the tank (see ASTM
E30086, Par. 21, in ASTM [1992a]).
9.7 Sampling Thick Sewage Sludges
If sewage sludges are above 7% solids, they take on
"plastic" flow properties; that is, they require a finite shear
stress to cause flow. This effect increases as the solids
content increases. Solids may thicken in lagoons to 15%
solids. At these concentrations, they will not flow easily
and require a substantial hydrostatic head before they will
flow into a sample bottle.
Sampling of sewage sludge stored in lagoons may be
very difficult, depending on the objectives of sampling and
the nature of the sewage sludge in the lagoon. The thick-
ened sewage sludge solids are generally nonuniformly dis-
tributed in all three dimensions. It is desirable first to map
the distribution of depth with length and width to deter-
mine where the sampling should be concentrated. Alength-
width grid should be established that takes the
nonuniformity of the solids deposit into account. ASTM
E300-86, Figure 19 (ASTM, 1992a), shows a grid for sam-
pling a uniform deposit in a railroad car.
The layer of water over the sewage sludge complicates
the use of many types of tube samplers because the over-
lying water should not be included in the sample. A thief
sampler (ASTM, 1992a) that samples only the sewage
sludge layer may be useful. Weighted bottle samplers
(ASTM, 1992a) that can be opened at a given depth can
be used to collect samples at a desired depth. Samples at
three depths can be taken and composited. Most likely the
sewage sludge will be as much as twice as high in solids
content at the bottom of the sewage sludge layer as at the
top. Compositing of equal volumes of samples from top,
middle, and bottom produces an excellent mass-average
sample and adjusts for this difference in solids content.
Generally there is no point in determining the gradient with
depth for microbiological and VAR parameters, because
there is no practical way of separately removing layers of
sewage sludge from a lagoon. Determining whether there
are gradients with length and width makes more sense
because, if desired, sewage sludge could be removed se-
lectively from part of a lagoon, leaving behind the unac-
ceptable material.
Sewage sludges from dewatering equipment such as
belt filter presses and centrifuges can have a solids con-
tent up to 35% and even higher following some condition-
ing methods. High solids content sewage sludges are easy
to sample if they are on moving conveyors, as described
in Section 9.5. However, if the sewage sludge is stored in
piles, obtaining a representative sample requires more
planning and a greater overall effort. As a result of the dif-
ferent environment between the pile surface and interior a
gradient will develop over time in the sewage sludge stor-
age pile. The sampling methodology used needs to ad-
dress this potential gradient between the pile surface and
interior. Sampling devices such as augers (a deeply
threaded screw) are used on high solids cakes (ASTM,
1992a) to collect a cross sectional sample. The auger is
'turned into the pile and then pulled straight out. The sample
is removed from the auger with a spatula or other suitable
device." Alternatively, a shovel can be used to collect
subsamples for compositing from the pile interior. The pile
should be sampled in proportion to its mass; more samples
are taken where the pile is deeper.
9.8 Sampling Dry Sewage Sludges
For purposes of this discussion, "dry" sewage sludges
contain as much as 60% water. They include heat dried
and composted sewage sludges, and sewage sludges from
dewatering processes, such as pressure filtration, that pro-
duce a cake which is usually handled by breaking it up into
pieces. Some centrifuge cakes are dry enough that they
are comprised of small pieces that remain discrete when
piled.
Dry sewage sludges are best sampled when they are
being transferred, usually on conveyors. Preferably mate-
rial across the entire width of the conveyor is collected for
69
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a short period of time. Several of these across-width
samples are collected and combined into a time-compos-
ite sample, if the entire width of the conveyor cannot be
sampled, the sample is collected from various points across
the breadth of the conveyor, and a space and time-
cornposited sample is collected.
Collecting a representative sample from a stockpile con-
taining a dried sewage sludge product poses a greater
challenge than collecting the sample from a conveyor. The
settling and classification of the material and the different
environments between the pile edge and interior must be
considered. When a material comprised of discrete par-
ticles is formed into a pile, classification occurs. If the par-
ticles are homogeneous in size and composition, a repre-
sentative sample can be easily obtained (assuming the
sample is collected within 24 hours of pile construction).
However if the particles are of a different size or composi-
tion, an unequal distribution of the particles may result
during settling. For example, a composted sewage sludge
may be heterogeneous, with respect to particle composi-
tion, even when oversized bulking agents have been re-
moved. It is important that the edges and interior of such
piles are properly weighted as part of the sample collec-
tion procedure. A sampling grid that prevents bias, such
as that presented in ASTM E300-86, Item 31.4 (ASTM,
1992a), should be used.
The heterogeneous nature and presence of large par-
ticles in some composted sewage sludges causes another
problem in sampling. For example, most augers and sam-
pling thiefs will be ineffective in getting a representative
sample from the interior of a pile containing large wood
chips and fine composted sewage sludge. There may be
no substitute for digging with a shovel to get to the desired
location.
Stockpile sampling is also made more difficult by the
constant evolution of the characteristics of stored mate-
rial. Immediately after a sewage sludge stockpile is con-
structed, physical, chemical, and biological changes be-
gin to occur within and on the surface of the stockpile.
Within a period as short as 24 hours, the characteristics of
the surface and outer part of the pile can differ substan-
tially from that of the pile interior. The outer part of a pile
tends to remain at or near ambient temperature, loses
moisture through evaporation, and volatilizes some com-
pounds such as ammonia. In contrast, pile interiors retain
heat (achieving temperatures that can be 40°C greater than
the pile surface), but lose little moisture or chemical com-
pounds through evaporation and volatilization. As a result,
the level of microbial growth and activity within the pile
and on the pile surface will also differ. The potential for
growth of fecal coliform bacteria in mesophilic regions of
the pile is of particular concern. If a sewage sludge stock-
pile is more than one day old, the sample should be col-
lected from a pile cross section. This is especially impor-
tant when there is a large temperature gradient between
the pile surface and interior.
9.9 Control of Temperature, pH, and
Oxygenation After Sample Collection
Samples for Microbial Tests
Table 9-2 summarizes the maximum holding times and
temperatures for sewage sludge samples taken for micro-
bial analyses. All samples should be cooled to appropriate
temperatures immediately after they are collected to mini-
mize changes in indicator organism and pathogen popula-
tions. For example, enteric viral and bacterial densities are
noticeably reduced by even 1 hour of exposure to tem-
peratures of 35°C (95°F) or greater. The requirement for
cooling limits the practical size of the sample collection
container. Agallon sample bottle takes much longer to cool
than a quart bottle. Use of bottles no larger than a quart is
recommended for most samples, particularly if the sew-
age sludge being sampled is from a process operated at
above ambient temperature. Granular solids and thick sew-
age sludges take a long time to cool, so use of containers
smaller than one quart is advised. For rapid cooling, place
the sample container in a slurry of water and ice. Placing
the sample container in a cooler containing bagged ice or
"blue ice" is effective in maintaining low temperatures but
several hours can elapse before this kind of cooling re-
duces sample temperature to below 10°C (50°F) (Kent and
Payne, 1988). The same is true if warm samples are placed
in a refrigerator. The presence or absence of oxygen is not
a serious concern for the microbiological tests if the
samples are promptly cooled.
Table Q-2. Analytical Methods Required Under Part 503
Analysis
Enteric Viruses
Fecal Coliform
Salmonella sp.
Bacteria
Viable Helminth
Ova
Specific Oxygen
Uptake Rate
(SOUR)
Total, Fixed, and
Volatile Solids
Percent Volatile
Solids Reduction
Methodology
American Society for
Testing and Materials
Method D 4994-89
(ASTM,1992b)1
Standard Methods
Part 9221 E or Part
9222 D (APH A, 1 992)2
Standard Methods
Part9260D
(APHA,1992)2or
Kenner and Clark
(1974) (see
Appendix G of this
document)
Yanko (1987) (see
Appendix I of this
document)
Standard Methods
Part 27108
(APHA.1992)
Standard Methods
Part 2540G
IAPHA..1992),
Appendix C of this
document
Maximum Holding
Time3/Temperature
-18°C(0°F);upto2
weeks
4°C (39.2°F) (do not
freeze); 24 hours
4°C (39.2°F) (do not
freeze); 24 hours
4°C (39.2°F) (do not
freeze); 1 month
20°C (sewage sludge
must be digested in the
10-30°C range); 2 hours
NA
NA
'Appendix H of this document presents a detailed discussion of this
method.
2Method SM-9221 E, the MPN procedure, is required for analysis of
Class A biosolids and recommended for Class B biosolids. Method SM-
9221 D, the membrane filtration procedure is also allowable for Class B
biosolids. See Appendix F of this document for recommended sample
preparation procedures and a discussion of the reporting of results.
3Time between sampling and actual analysis, including shipping time.
70
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Standard Methods (APHA, 1992) states that if analysis
for bacterial species (fecal coliform and Salmonella sp.)
will commence within 1 hour after sample collection, no
temperature adjustment is required. If analysis will com-
mence between 1 and to 6 hours after following collection,
the sample should be immediately cooled to at least 10°C.
If analysis will commence between 6 and 24 hours after
collection the sample should be immediately cooled to 4°C.
The sample should never be frozen and analysis must
commence within 24 hours of collection.
Proper planning and coordination with the courier ser-
vice and analytical laboratory are essential if bacterial
analyses are to be conducted within 24 hours of sample
collection. The laboratory needs to be notified several days
in advance so they can be prepared to initiate the analysis
within several hours of receiving the sample. If they are
not notified, the laboratory may not be adequately prepared
and another day may lapse before the samples are ana-
lyzed. Actual sample collection should be conducted in the
afternoon, within a few hours of the sample courier's ar-
rival. If the samples are collected in the morning, a greater
than 24-hour period may pass before the laboratory actu-
ally begins the analysis.
Follow-up with the laboratory is important to determine
the actual sample holding time and temperature of the
sample when it was received. This information can be used
to improve the overall sample collection and transfer pro-
cedure. Feedback received from the lab regarding sample
condition and holding times may also provide an explana-
tion for erroneous or unexpected test results.
The requirement for prompt chilling of samples is appro-
priate for viruses as well as bacteria. There are far fewer
laboratories capable of carrying out virus tests than can
conduct bacterial analyses, so time between sample col-
lection and analysis can routinely exceed 24 hours. Fortu-
nately, viruses are not harmed by freezing. Typically, virol-
ogy laboratories store samples at -70°C (-94°F) before
analysis. Samples can be frozen in a -18°C (0°F) freezer
and stored for up to 2 weeks without harm. Samples should
be frozen, packed in dry ice, and shipped overnight to the
analytical laboratory.
Viable helminth ova are only slightly affected by tem-
peratures below 35°C (95°F), provided chemicals such as
lime, chlorine, or ammonia are not utilized in the treatment
process. Nevertheless, chilling to 4°C (39.2°F) is advised.
If the samples are held at this temperature, a period of a
month can elapse between sampling and analysis. Freez-
ing should be avoided because the effect of freezing on
helminth ova is not well understood.
Vector Attraction Reduction Tests
For the vector attraction reduction tests that measure
oxygen uptake, or additional anaerobic or aerobic diges-
tion (see Appendix D), the samples must be kept at the
temperature at which they were collected. This sometimes
can be done just by collecting a large sample in a large
container. Covering the sample with an insulating blanket
or placing it in an insulated box provides adequate protec-
tion against temperature change in most cases. Desired
temperature can be maintained in the box by adding a "hot
water bottle" or a bag of blue ice.
Depending on the whether the sewage sludge is from
an aerobic process or anaerobic digestion, the presence
or lack of oxygen will determine which vector attraction
reduction test is appropriate and therefore how the sample
should be handled. For aerobic sewage sludges, a lack of
oxygen will interfere with the metabolic rate of the aerobic
microorganisms in the sample. Similarly, presence of oxy-
gen will seriously affect or even kill the anaerobic organ-
isms that convert organic matter to gases in anaerobic di-
gestion. With samples taken for SOUR analysis, it has been
the experience of some investigators that if the test is not
run almost immediately after collection (within about 15
minutes), that erroneous results are obtained. The addi-
tional aerobic digestion test is more "forgiving" (because it
is a long-term test and shocked bacteria can revive); up to
4 hours of shortage of oxygen can be tolerated. For the
additional anaerobic digestion test, the sample containers
should be filled to exclude air. In any subsequent opera-
tions where there is a freeboard in the sample or testing
vessel, that space should be filled with an inert gas such
as nitrogen.
No pH adjustment is to be made for any of the vector
attraction reduction tests. For those vector attraction pro-
cesses that utilize lime, the only requirement is to mea-
sure pH after the time periods indicated in the vector at-
traction reduction option (see Section 8.7).
9.10 Sample Compositing and Size
Reduction
The amount of sample collected in the field generally far
exceeds the amount needed for analysis. The field sample
must therefore be reduced to a manageable size for the
analyst to handle. As for all sample handling, sample size
reduction is more difficult for microbial samples than for
samples taken for vector attraction reduction tests because
of the potential for microbial contamination. The labora-
tory may be better equipped to perform subsampling than
samplers in the field.
Microbial Tests
Freely flowing liquids samples can be adequately mixed
in the sample bottles by shaking the bottles. There must
be room in the bottle for adequate mixing. Compositing of
smaller samples is accomplished by pouring them into a
larger bottle with adequate freeboard and mixing it by shak-
ing or stirring it thoroughly with a sterile paddle. Pouring
off a portion of the contents of a large container into a
smaller bottle is not an acceptable procedure because the
top layer of any slurry always contains fewer solids than
do lower layers. Sampling with a pipette with a wide bore
is an acceptable alternative, provided the bore of the pi-
pette does not restrict the entry of solid particles. The
71
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sample should be drawn into the pipette slowly and the tip
moved through the sample to minimize selective collec-
tion of liquid over solid particles.
Sample size reduction for thick sewage sludges is diffi-
cult, because they cannot be mixed by shaking. Stirring
with a mechanical mixer or a paddle is often inadequate
(recall how long it takes to mix a can of paint). A satisfac-
tory approach is to hand mix a composite of subsamples,
and then take a large number of small grabs from the
composited sample to form the smaller sample for the ana-
lyst.
Dry solids samples can generally be mixed adequately
by shaking if there is sufficient head space in the sample
container, but the individual particles are frequently large
and must be reduced in size to get a representative sample.
If the particles are large and a number of subsamples must
be combined into a large composite, it may be necessary
to reduce the particle size before they are composited. This
can be done in a sterile covered chopper, blender, or
grinder. The individual subsamples are then combined and
mixed by shaking, rotating, and tumbling. A smaller com-
posite is then prepared by combining a number of grabs
from all parts of the combined sample. Many facilities do
not have adequate equipment needed to perform this size
reduction procedure. However, most analytical laborato-
ries have this capability and will typically perform this pro-
cedure at a nominal cost. Coordination with the analytical
laboratory regarding subsampling is an important part of
the sampling and analysis procedure that should not be
ignored. Some other sample size reduction methods, such
as "coning and quartering" (ASTM, 1992a) may be use
only if aseptic handling practices are observed. It should
be noted that particle size reduction is not appropriate if
the large pieces in the sample are not sewage sludge but
are other materials which have been added to the sewage
sludge for processing purposes. For the purpose of micro-
bial or volatile solids reduction testing, additives such as
wood chips should be removed from the sample before
size reduction or sample preparation (see Section 10.5). It
is recommended in these cases that a one-quarter inch
mesh sieve be used for this purpose.
Vector Attraction Reduction Tests
The lack of a need to prevent microbial contamination
makes compositing and size reduction easier for vector
attraction reduction tests than for the microbial tests. How-
ever, there is a need to keep the aerobic samples aerobic
and to prevent the anaerobic samples from coming into
contact with air. Subsamples for the anaerobic tests can
be collected into individual bottles at the sampling loca-
tion. As noted above, these sample bottles should be filled
completely and capped. A brief exposure to air will not
cause a problem, but any prolonged exposure, such as
might occur when several subsamples are being blended
together and reduced in size for a representative compos-
ite sample, must be avoided. One acceptable sample size
reduction procedure is to flush a large sterile bottle with
nitrogen, then pour in the subsamples and blend them to-
gether with nitrogen still bleeding into the vessel. Alterna-
tively, the nitrogen-filled vessel could be flushed with more
nitrogen after the admission of the subsamples, capped,
and then shaken thoroughly to accomplish the blending.
Analytical laboratories generally can perform this size re-
duction procedure.
9.11 Packaging and Shipment
Proper packaging and shipment are important to ensure
that the samples arrive in good condition (proper tempera-
ture, no spillage) within the specified time frame.
Sealing and Labeling Sample Containers
Sample containers should be securely taped to avoid
contamination, and sealed (e.g., with gummed paper) so it
is impossible to open the container without breaking the
seal. Sealing ensures that sample integrity is preserved
until the sample is opened in the laboratory. A permanent
label should be affixed to each sample container. At a mini-
mum the following information should be provided on each
sample container:
• Type of analysis to be performed (e.g., Salmonella sp.,
fecal coliform bacteria, enteric virus, or viable helm-
inth ova)
• Sample identification code (if used) or a brief descrip-
tion of the sample (that distinguishes it from other
samples) if no sample code system is used
• Sample number (if more than one sample was col-
lected at the same point on the same day)
Other information may include:
. Facility name, address and telephone number
. Date and time the sample was taken
. Facility contact person
This information should also be included on an enclosed
chain of custody form.
Shipment Container
A soundly constructed and insulated shipment box is
essential to provide the proper environment for the pre-
serving sample at the required temperature and to ensure
the sample arrives intact. Small plastic cased coolers are
ideal for sample shipping. It is recommended that the out-
side of the shipment container be labeled with the follow-
ing information:
. The complete address of the receiving laboratory (in-
cluding the name of the person responsible for receiv-
ing the samples and the telephone number)
. Appropriate shipping label that conforms to the
courier's standards
. Number of samples included (i.e. "This cooler contains
10 samples")
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. The words "Fragile" and "This End Up"
To maintain a low temperature in the shipment box, a
blue-ice type of coolant in a sealed bag should be included
in the box. If the blue ice has been stored in a 0°F (-18°C)
freezer (e.g., a typical household freezer), the coolant
should be "tempered" to warm it up to the melting point of
ice (0°C [32°F]) before it is placed around the sample. Ad-
ditional packing material (bubble wrap, Styrofoam peanuts,
balled-up newspaper) should be placed in the shipping
container to fill in empty space to prevent sample contain-
ers from moving and potentially breaking or spilling during
shipping. It is also recommended that the courier be con-
tacted in order to determine if there are any special re-
quirements for the shipping of this type of sample.
Adherence to Holding and Shipment Times
Adherence to sample preservation and holding time lim-
its described in Section 9.6 is critical. Samples that are not
processed within the specified time and under the proper
conditions can yield erroneous results, especially with the
less stable microorganisms (i.e., bacteria). Make sure the
analytical laboratory reports the date and time when the
samples arrived, and total holding time (period from when
the sample was collected to the initiation of analysis). This
information will be valuable for improving future sample
events and maintaining quality control.
9.12 Documentation
Sampling Plan
It is recommended that all procedures used in sample
collection, preparation, and shipment be described in a
sampling plan. At a minimum, a sampling plan should pro-
vide the following information:
. Sample collection locations
. Volume of sample to be collected
. Sample compositing procedures
• Days and times of collection
. Required equipment
. Instructions for labeling samples and ensuring chain
of custody
. A list of contact persons and telephone numbers in
case unexpected difficulties arise during sampling
If a formal sampling plan is not available, a field log that
includes instructions and a sample collection form may be
used (EPA, 1980).
Sampling Log
All information pertinent to a sampling event should be
recorded in a bound log book, preferably with consecu-
tively numbered pages. At a minimum, the following infor-
mation should be recorded in the log book.
. Purpose of sampling event
. Date and time of sample collection
. Location where samples were collected
. Grab or composite sample (for composite samples,
the location, number, and volume of subsamples
should be included)
. Name of the person collecting the sample(s)
. Type of sewage sludge
. Number and volume of the sample taken
. Description of sampling point
. Date and time samples were shipped
Chain of Custody
To establish the documentation necessary to trace
sample possession from the time of collection, it is recom-
mended that a chain-of-custody record be filled out and
accompany every sample. This record is particularly im-
portant if the sample is to be introduced as evidence in
litigation. Suggested information for the chain-of-custody
record includes, at a minimum:
. Collector's name
. Signature of collector
. Date and time of collection
. Place and address of collection
. Requested preprocessing (subsampling, compositing,
particle size reduction)
. Requested analyses
. Sample code number for each sample (if used)
. Signatures of the persons involved in the chain of pos-
session
A good rule of thumb is to record sufficient information
so that the sampling situation can be reconstructed with-
out reliance on the collector's memory. Chain of custody
forms can be obtained from the laboratory and should be
used even if the laboratory is on-site and part of the treat-
ment facility.
9.13 Analytical Methods
Part 503.8(b) of the Par-t 503 regulation specifies meth-
ods that must be used when analyzing for enteric viruses;
fecal coliform; Salmonella sp.; viable helminth ova; spe-
cific oxygen uptake rate; and total, fixed, and volatile sol-
ids. Table 9-2 lists the required methods. Complete refer-
ences for these methods can be found in Chapter 12, and
recommended sample preparation and analytical methods
can be found in the appendix as listed below.
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Calculating volatile solids reduction Appendix C
Conducting additional digestion and Appendix D
specific oxygen uptake rate (SOUR)
tests
Determination of residence time in Appendix E
digesters
Sample preparation — fecal Appendix F
coliform and Salmonella sp. analysis
Analytical method — Salmonella sp. Appendix G
Analytical method — enterovi ruses Appendix H
in sewage sludge
Analytical method — viable Appendix I
helminth ova
As of the time of publication of this document, the allow-
able analytical methodologies are as listed above. How-
ever, in the case of fecal coliform analysis for Class B-
Alternative 1, it is recommended that the MPN method be
used instead of the membrane filter test (the MPN method
is required for Class A fecal coliform analysis), and that
the Kenner and Clark methodology be used for Salmo-
nella sp. analysis.
9.14 Quality Assurance
Quality assurance involves establishing a sampling plan
and implementing quality control measures and procedures
for ensuring that the results of analytical and test mea-
surements are correct. A complete presentation of this
subject is beyond the scope of this manual. Aconcise treat-
ment of quality assurance is found in Standard Methods
(APHA, 1992) and is strongly recommended. Parts 1000
to 1090 of Standard Methods are relevant to the entire
sampling and analysis effort. Part 1020 discusses quality
assurance, quality control, and quality assessment. Stan-
dard Methods (Part 10208) states that "a good quality con-
trol program consists of at least seven elements: certifica-
tion of operator competence, recovery of known additions,
analysis of externally supplied standards, analysis of re-
agent blanks, calibration with standards, analysis of dupli-
cates, and maintenance of control charts." For most of the
tests to be carried out to meet the pathogen and vector
attraction reduction requirements of the Part 503 regula-
tion, these elements cannot be met completely, but they
should be kept in mind as a goal.
Microbial Tests
For the microbiological tests, quality assurance is needed
to verify precision and accuracy. Quality assurance for
microbiological methods is discussed in Part 9020 of Stan-
dard Methods. The quality control approach suggested is
recommended for the microbiological tests required by the
Part 503 regulation. In Part 9020B-4, Analytical Quality
Control Procedures, it is suggested that precision be ini-
tially established by running a number of duplicates, and
that thereafter duplicates (5% of total samples) be run to
determine whether precision is being maintained.
Spiking and recovery tests are an important part of quality
assurance. Yanko (1987) has found that spiking is useful
for the viable helminth ova test, but that testing recovery
effectiveness on unspiked sewage sludge is more useful
for quality assurance for bacterial or viral tests. With either
method, the density of the measured pathogens should
be at levels that are relevant to the Part 503 regulation.
For example, for viable helminth ova, samples should be
spiked to density levels of approximately 100 per gram.
Recovery of bacteria and viruses should be conducted on
primary sewage sludges that typically contain viruses at
low but consistent levels (such as primary sewage slud-
ges from large cities).
For both commercial and in-house laboratories, quality
assurance procedures should be incorporated into the
analytical method and assessed routinely. Communication
with the analytical personnel is an important part of devel-
oping a good sampling and analysis protocol. The sewage
sludge preparer should review quality assurance data along
with analysis results to ensure that laboratory performance
is acceptable.
Vector Attraction Reduction Tests
It is not possible to test for accuracy for any of the vector
attraction reduction tests, because standard sewage slud-
ges with consistent qualities do not exist. Standard Meth-
ods gives guidance on precision and bias. However, for
some of the vector attraction reduction options, this infor-
mation was not available or was approximate. Section 10.7
provides guidance on the number of samples to take. The
procedures for three of the vector attraction options devel-
oped for the Part 503 regulation (additional anaerobic and
aerobic digestion and the specific oxygen uptake rate test),
which are presented in Appendix D, have internal quality
control procedures that include replication. Since the tests
are newly proposed, the data are insufficient to judge
whether agreement between replicates is adequate. This
kind of information will be communicated as experience
with these options accumulates.
References and Additional Resources
APHA. 1992. Standard methods for the examination of
water and wastewater. 18th ed. Washington DC: Ameri-
can Public Health Association.
ASTM. 1992a. Annual book of ASTM standards. Philadel-
phia, PA: American Society for Testing and Materials.
ASTM. 1992b. Standard practice for sampling industrial
chemicals. Philadelphia, PA: American Society for Test-
ing and Materials.
Kent, R.T., and K.E. Payne. 1988. Sampling groundwater
monitoring wells: Special quality assurance and qual-
ity control considerations, p 231-246 in Keith, L.H. Prin-
ciples of Environmental Sampling. American Chemi-
cal Society.
Kieth, L.H., ed. 1988. Principles of environmental sampling.
American Chemical Society.
U.S. EPA. 1980. Samplers and sampling procedures for
hazardous waste streams. Report No.: EPA/600/2-80/
74
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018. Cincinnati, OH: Municipal Environmental Re- U.S, EPA. 1999. Biosolids Management Handbook. U.S.
search Laboratory. EPA Region VIII, P-W-P, 999 18th street Denver CO
80202-2466.
U.S. EPA. 1993. POTW sludge sampling and analysis
guidance document. EPA 833-B-89-100. Office of Yanko, W.A. 1987. Occurrence of pathogens in distribu-
Water tion and marketing municipal sludges. Report No.: EPA!
600/1-87/01 4. (NTIS PB88-154273/AS.) Springfield,
U.S. EPA. 1993. Sewage sludge sampling techniques VA: National Technical Information Service.
(video).
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Chapter 10
Meeting the Quantitative Requirements of the Regulation
10.1 Introduction
The Part 503 regulation contains operational standards
for pathogen and vector attraction reduction. It provides
only minimal guidance on the amount of information that
must be obtained during a monitoring event to prove that
a standard has been met or to demonstrate that process
conditions have been maintained. This document provides
more detailed information for regulators and facilities on
how to adequately satisfy the regulatory requirements.
Some frequently asked questions and answers are also
included at the end of this chapter.
In general, it has been found that the daily, weekly, and
seasonal fluctuations that occur in wastewater treatment
works and sludge quality make it difficult to adequately
represent sludge quality with minimum sampling. It is there-
fore recommended that multiple samples be taken for any
sampling event and that samples be taken over a mini-
mum 2-week period in order to best represent the perfor-
mance of a sludge treatment process. Although extensive-
sampling is time consuming and facility operators are of-
ten under pressure to reduce costs, it is strongly recom-
mended that multiple samples be included in a sampling
plan so that the variable quality of sludge can fully be un-
derstood.
There are many types of wastewater treatment plants
and sludge management practices. This document ad-
dresses some of the many operational variables and pro-
vides some examples of how to demonstrate compliance
with the regulations, The final decision about what to moni-
tor and how frequently to monitor it lies with the permitting
authority who may impose permit conditions based on spe-
cific parameters including the type of sludge produced, its
intended usage, and/or the history of the facility.
10.2 Process Conditions
Sufficient information must be collected about sludge
processing conditions and made available to the permit-
ting authority and any other interested parties to enable a
qualified reviewer to determine if the Part 503 requirements
have been met. How this information is collected and how
much information is needed depend on the process. The
following example illustrates the type of information and
the level of detail that may be included in a permit applica-
tion. Consider the case of a treatment works that meets
the pathogen reduction requirement for a Class B sludge
by using anaerobic digestion conducted at the PSRP con-
ditions of 35°C (95°F) with a 15-day residence time. To
meet the pathogen reduction requirement, the monitoring
results must demonstrate that the 35°C (95°F) tempera-
ture and 15-day residence time are maintained whenever
the process is being used. The example below illustrates
some of the factors to be considered in assuring compli-
ance with the regulation. In addition, a contingency plan in
case the conditions are not met, and product usage should
be specified.
Example
Facility Clarksdale Wastewater Treatment
Facility Anaerobic Digestion
Size: 300 dry metric tons per year
Class: B
Sewage sludge is treated in two digesters, operated in
parallel, fed by constant displacement progressive cavity
pumps. The facility complies with PSRP requirements by
maintaining sludge at a temperature at or above 35° C for
a minimum of 15 consecutive days.
. Temperature — During the first six months of opera-
tion under this permit, the permittee shall perform tem-
perature scans throughout the volume of the digester
to establish the location of the zone at which tempera-
ture is at a minimum. Scans will be conducted under
the expected range of operating conditions. Once the
location of the zone is established, the permit-tee will
continuously measure digester temperature in the zone
of minimum temperature. Temperatures will be re-
corded continuously or at intervals of eight hours. The
temperature measuring device will be calibrated on a
monthly basis.
. Retention Time — The permittee shall calculate the
working volume of the digester to determine residence
time. The permittee shall provide evidence that the
digester has been cleaned within the last two years,
or alternatively, determine the levels of grit and scum
accumulation. Residence time must be at least 15
days. Flow rate and residence time will be measured
and calculated each year.
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. Vector Attraction Reduction -The facility will comply
with vector attraction reduction via management prac-
tices. After digestion, the sludge will be dewatered and
transported to farm land where it will be land applied
and disked immediately (within six hours) into the soil
(see below). Sludge will not be stored at application
sites.
. Reporting — The data collected throughout the year
will be summarized and submitted to the permitting
authority annually. Reports will include temperature and
residence time records as well as records of all appli-
cation sites and sludge application rates.
. Contingency Plan — If the facility fails to meet the 35°
C/l 5 day requirement, it has several options. The fa-
cility can try to meet the Class B time/temperature re-
quirement with lower temperatures and longer resi-
dence times as determined by a linear interpolation
between 35°C (95°F) and 15 days and 20°C (68°F)
and 60 days. If the facility does not have the flexibility
to maintain sludge in the digester for longer than 15
days, it can meet Class B requirements by sampling
the sludge for fecal coliform and demonstrating that
the sludge contains less than 2 million CPU or MPN
per gram of sludge on a dry weight basis. Alternatively,
the facility can dispose of the sludge by means other
than land application. In the case that the facility can-
not meet the time/temperature requirements, the per-
mitting authority must be contacted so that a sampling
plan which adequately represents sludge quality and
demonstrates Class B pathogen reduction can be de-
signed. If the facility decides to divert the sludge from
land application, it must notify the regulatory agency
of its plans.
. Product Use — The sludge will be land applied in ac-
cordance with all Part 503 restrictions. The facility will
distribute the Class B sludge to local fruit farmers. The
facility will notify applicators of sludge quality and rel-
evant site restrictions. Crop harvesting will be restricted
in accordance with Part 503 site restrictions. In the
case of application to fruit trees, the farmer will wait a
minimum of 30 days after application to harvest the
fruit. If fruit that has fallen off the trees or otherwise
touched the ground will also be harvested, the farmer
will wait 14 months after sludge application to harvest
the* *fruit. If there is any question about the waiting
period or if the facility wishes to distribute sludge to
farmers of crops which touch the ground, the facility
should notify the regulator. Site restrictions for crops
which touch the soil or which grow below the soil sur-
face are subject to longer waiting periods.
The number and the level of detail of a permit's condi-
tions vary depending on the type of process. Facilities that
handle sludge or septage from more than one source
should be subject to more frequent testing until they can
demonstrate that the product consistently meets quality
standards. The permitting authority must determine at what
point the facility has adequately demonstrated consistency
and can reduce the level of sampling.
For example, consider a treatment facility that collects
liquid sewage sludge and septage from several different
sources. Although all of the sludge collected undergoes
standard treatment for Class B pathogen reduction, the
quality of the sludge generated may vary depending on
the particular feedstock received. Initially, the permitting
authority may require this facility to monitor every batch of
sludge in order to demonstrate that it consistently produces
sludge in compliance with regulatory and permit require-
ments. Eventually, if enough data is available showing that
the treated sewage sludge is rarely off specification, and
the sampling frequency could be reduced.
For other processes, such as static pile composting, a
sampling plan might specify that one of several piles con-
structed in a day could be monitored, probably with sev-
eral thermocouples at different elevations and locations in
the pile, to demonstrate conformance for the whole day's
production.
At times, processes do not conform to process condi-
tions. In such cases, the operator should keep records
showing that the treated sludge produced was either re-
cycled to be processed again or diverted in some manner
for use or disposal consistent with its quality (e.g., disposal
in a landfill with daily cover or, if the sludge meets the Class
B requirements, application as a Class B [rather than as a
Class A] biosoiids).
10.3 Schedule and Duration of Monitoring
Events
For purposes of this discussion:
. A sampling event is defined as the period during which
samples are collected. Samples may include several
independently analyzed subsamples taken during the
sampling event.
. A monitoring event includes the sampling period and
the period to analyze the samples and provide the re-
sults needed to determine compliance.
Monitoring events are intended to reflect the typical usual
performance of the treatment works. Conditions should be
as stable as possible before the monitoring event. Day-to-
day variations in feed rate and quality are inevitable in sew-
age sludge treatment, and the processes are designed to
perform satisfactorily despite these variations. However,
major process changes should be avoided before moni-
toring events, because long periods of time-as much as 3
months if anaerobic digestion is part of the process train-
are required before steady state operation is reestablished.
Monitoring for Microbiological Quality
To meet the Part 503 pathogen reduction requirements,
sewage sludges may have to be monitored to determine
densities of fecal coliforms, Salmonella sp., enteric viruses,
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and/ or viable helminth ova. Monitoring for these microor-
ganisms presents special problems, primarily caused by
the length of time it takes to obtain microbiological test
results. This is a function of the time it takes to deliver the
samples to a laboratory, have the tests conducted, and
obtain the results. Microbiological analyses require a sub-
stantially longer period than conventional physical and
chemical analyses. The approximate time to complete spe-
cific microbiological analyses is summarized as follows.
Fecal coliform (MPN), 4 days
Salmonella sp. (MPN) 5 to 7 days
Enteric viruses, 14 days
Viable helminth ova, 28 days
Variations in the microbiological quality of the treated
sludge and intrinsic variation in the analytical methods are
generally large enough that a single measurement of a
microbiological parameter is inadequate to determine
whether a process meets or fails to meet a requirement.
The Pathogen Equivalency Committee recommends that
the monitoring event include at least seven samples taken
over a period of approximately 2 weeks (see Section 10.7).
Based on the reliability of the treatment process and his-
toric test results, there may be times when a reduction in
this monitoring recommendation is justified.
Thus, the time required for a monitoring event could
range from 3 to 7 weeks. During this time, the quality of
the treated sewage sludge generated is unknown. As dis-
cussed in Section 4.10, classification of sludge as Class A
or B is based on the most recent test results available.
Therefore, material can continue to be distributed under
its classification as Class A or B until more recent analyti-
cal results are available. However, it is recommended that
material generated during the monitoring event be retained
on site until results from the monitoring event are avail-
able. This will prevent misclassified sludge from being er-
roneously distributed.
For example, consider a facility producing a Class A
sludge that is sampled for Salmonella sp. analysis every
quarter. All historic data has shown the facility to be in com-
pliance with Class A standards including the most recent
set of lab analyses from the January monitoring event.
Under these results, materials are distributed as-Class A
products even throughout April when a subsequent moni-
toring event takes place. This is acceptable because ma-
terial is still classified under the most recent available lab
result. However, suppose the April results show non-com-
pliance with Class A standards. Despite the fact that the
preparer complied with regulations, it is possible that some
Class B material was inadvertently distributed for Class A
use.
In order to avoid this situation, it is recommended that
the sludge processed during the monitoring event either
be stored until it is demonstrated that the processed sludge
meets the quality requirements for use as a Class A or B
sludge, or - if the sludge is being monitored for Class A
requirements - used or disposed as a Class B sludge (pro-
vided it meets the Class B requirements). This may take
up to 3 weeks in the case of fecal coliform or Salmonella
sp. analysis and much longer if sludge is being analyzed
for helminth ova or viruses. Contingencies for this type of
situation should be discussed with the regulatory authority
and included in permit conditions and operational plans.(For
more discussion on the timing of sampling and distribu-
tion, see Section 4.10)
Monitoring for Vector Attraction Reduction
Not all the vector attraction reduction options listed in
the regulation (see Chapter 8) require lab testing. Four of
the methods (treatment of sewage sludge in an aerobic
process for 14 days or longer, injection below the surface
of the land, incorporation of sludge into the land, and place-
ment of sludge on a surface disposal site and covering it
at the end of each day) are technology descriptions. These
technologies have to be maintained throughout the year in
the manner described in the regulation. Examples of the
kind of information needed to demonstrate adequate per-
formance are provided in Section 10.2.
The remaining vector attraction reduction options are
based on laboratory testing for volatile solids reduction,
moisture content, or oxygen uptake reduction. Some of
the options can only be used with certain sludge processes.
For example, the oxygen uptake rate test is only appropri-
ate for a sludge from any aerobic digestion or wastewater
treatment process. Other options, such as the 38 percent
reduction in volatile solids, can be applied to a variety of
biological sludge treatment processes. In any case, the
technology aspect of the option, or the process by which
vector attraction reduction is being attained, must be docu-
mented in the manner described in Section 10.2. Monitor-
ing for vector attraction reduction should be performed at
a minimum according to the required monitoring sched-
ule.
Some tests for vector attraction reduction can be con-
ducted within a few hours while others can take more than
a month. For the tests that can be conducted within a few
hours, the sampling event must be more than a few hours
to account for the variability in the material tested and the
performance of the vector attraction reduction process as
affected by the changes in feedstock.
It is suggested in Section 8.14 that facilities maintain a
sampling program that involves sampling at evenly spaced
time intervals throughout an established monitoring period.
The on-going samples can be used to calculate running
averages of volatile solids reduction which are more rep-
resentative than single samples or an attempt to correlate
feed sludge and sludge product. As is the case for the mi-
crobiological tests, these vector attraction reduction tests
should be conducted over approximately 2 weeks to mini-
mize the expected effect of these variations. The 2-week
period can be the same 2-week period during which the
microbiological parameters are being determined.
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The longer VAR tests present a similar problem as moni-
toring for microbiological quality. Some of the tests - such
as the additional digestion tests -take more than a month
to complete. Unless the treatment works has several sets
of duplicate testing equipment, it will be impossible to run
these tests on enough samples during a 2-week sampling
period to assess the variability in the performance of the
treatment process. Storing samples taken during this pe-
riod until the equipment becomes available is not an op-
tion, because samples cannot be stored for more than a
limited time period (see Section 9.6). In such circum-
stances, the preparer may wish to run the vector attraction
reduction tests more frequently than required in order to
demonstrate on-going compliance with the requirements.
More frequent testing will indicate if the facility is perform-
ing consistently and will reduce the need for multiple
samples during the sampling period.
The preparer may wish to conduct composite sampling
which combines samples taken within a 24 hour period to
better represent sludge quality. (See Section 10.6). Since
some of the bench scale tests may be affected by long-
term storage of samples, compositing should be limited to
a 24 hour period. If composting is done, the composite
should be held at # 5°C during compositing, and the assay
must begin immediately upon completion of the compos-
ite.
Preparers should discuss specific facility parameters with
the permitting authority to design a sampling program that
is appropriate.
10.4 Comparison of Feed Sludge and
Sludge Product Samples
The enteric virus and viable helminth ova analytical re-
quirements to demonstrate that an existing or new sludge
treatment process is equivalent to a PFRP one and some
of the vector attraction reduction methods (e.g., percent
volatile solids reduction) involve taking input and output
samples that correspond (i.e., they are "before process-
ing" and "after processing" samples of the same batch of
sludge). The comparison of input and output samples al-
lows for the determination of whether enteric viruses and
helminth ova levels are being reduced to adequate levels
and/or percent volatile solids reduction.
Obtaining samples that correspond can be difficult for
sewage sludge treatment processes, such as anaerobic
digestion, that characteristically treat sludge in fully mixed
reactors with long residence times. For example, as men-
tioned in Section 10.3, it can take up to 3 months for an
anaerobic digester to achieve steady state operation after
some substantive change in feed sludge or process con-
dition is made. Samples taken only after the process has
reached steady state operation are considered as corre-
sponding.
Many of the treatment processes that might be consid-
ered for demonstrating equivalency to PFRP are either
batch or plug flow processes. In theory it is relatively simple
to obtain corresponding samples - it is only necessary to
calculate the time for the input material to pass through
the system and sample the downstream sludge at that time.
Achieving accurate correspondence in practice, however,
is seldom easy. Consider, for example, the difficulty of ob-
taining good correspondence of feed and treated sludge
for a composting operation in which the feed sewage sludge
is to be compared to composted sludge that has been
stored for 3 months.
Taking multiple samples and appropriately compositing
the samples of feed and treated sludge averages out the
composition of these sewage sludges and reduces the
correspondence problem. It is the regulatory authority's
task to determine how many samples should be taken and
how much data is necessary to demonstrate reduction of
microorganisms in corresponding samples. As indicated
in Section 10.6, limitations on the periods of time over which
microbiological samples can be collected limit the utility of
compositing.
10.5 The Effect of Sludge Processing
Additives on Monitoring
Many sewage sludge dewatering and stabilization pro-
cesses introduce other substances into the sludge. With
the exception of large bulky additives such as wood chips,
there is no need to modify sampling and analytical proce-
dures. As discussed below, additives such as wood chips
can complicate sample preparation and analysis and are
best removed prior to analysis.
Polymers, lime, ferric chloride, paper pulp, and recycled
sludge ash are frequently used to aid in dewatering. Disin-
fection by alkaline treatment requires the addition of lime
or other alkaline materials to increase the temperature of
the sewage sludge cake to disinfecting temperature. These
materials also reduce the microbial densities by dilution
and increased solids content. However, the change in mi-
crobial density caused by dilution may not be substantial.
For example, an increase in mass of 20% would result in a
reduction in the log density of a microbiological parameter
of only 0.079.
The exposure risk to human health is directly related to
the mass of treated sludge. So the achievement of patho-
gen reduction requirements and safe end-use is dictated
by the population of pathogenic organisms in the final prod-
uct. This is the approach taken by the Part 503 regulation,
which requires that the treated sludge, regardless of the
mass of other materials added, meet the standards for
Class A or Class B sludge.
For some sludges, particularly those treated by
composting (these usually will be Class A biosolids), the
amount of additive can be considerable. Nevertheless, the
regulation requires that the biosolids meet the standard,
which means that no correction need be made for dilution.
The issues of sampling and analytical procedures for
employment are different when considering wood chips or
other materials which are often added to sludge as a bulk-
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ing agent for composting. Compost product may be given
away or sold as a screened or unscreened product, and
although regulations require that the treated sludge, as it
is applied, meets 503 standards, in the case of wood chips
and other large particle size bulking materials, it is appro-
priate to remove large pieces before analysis takes place.
Large additives are removed in order to improve the
accuracy of the microbial measurements. The wood chips
are so big (typically 4 cm x 4 cm x 1 cm) that a very large
sample would have to be taken and blended to get a rep-
resentative subsample. Sample reliability is reduced when
the sample consists of a mix of sludge solids and fibrous
wood-chip residue from blending. Another reason for re-
moving the wood chips prior to microbial analysis is that
the exposure of users to the compost is related to the fine
particle content and not to large, physically distinct wood
chips. For example, a user who handles the compost gets
his or her hands covered with compost particles. Similarly,
the user might breathe in a dust of compost particles. In
both cases, it is the "fines" of the compost, not the wood
chips that the user is exposed to.
In order to ensure that wood chips are not included in
the lab's subsample, the facility should remove wood chips
after sampling, being careful not to contaminate, with a
sterilized sieve. The size of the sieve needed depends on
the dimensions of the wood chips, but the same sieve size
should be used for each sampling event. Alternatively, the
laboratory should be asked to remove wood chips from
samples before subsampling or analyses are conducted.
Again, the sieve size should be established so that a stan-
dard size is used.
10.6 Collecting Representative Samples
Sludge quality varies depending on the inputs to the
wastewater system. In addition, the process is subject to
ambient conditions which vary daily as well as seasonally.
The goal of a sampling program is to adequately repre-
sent the quality of sludge; Therefore, both the frequency
of sampling and the number of samples taken in any one
sampling event must be considered carefully. This section
discusses the issue of variability and how sampling fre-
quency and composite sampling can improve the quality
of data collected. A sampling plan is recommended for all
sampling events to assure representative samples.
Random Variability
Virtually all sewage sludge treatment processes will ex-
perience a certain amount of short-term random or cyclic
variation in the feed sludge and in process performance.
Evaluation of average performance over a 2-week time
period is suggested as a reasonable approach to account
for these variations. Cyclic variation can be minimized by
sampling on randomly selected days and time-of-day in a
given week. In the case of Class B fecal coliform analysis
ONLY variability is minimized by taking the geometric mean
of analytical results. In the case of Class A, all samples
must meet the fecal coliform or Salmonella sp. numerical
limit.
Seasonal Variability
For some sewage sludge treatment processes, perfor-
mance is poorer during certain parts of the year due to
seasonal variations in such factors as temperature, sun-
shine, and precipitation. For example, aerobic digestion
and some composting operations can be adversely affected
by low ambient temperature. In such cases, it is critical
that process performance be evaluated during the time of
year when poorest performance is expected. If a treatment
works is evaluated four or more times a year at intervals of
2 or 3 months, there is no problem, because all seasons of
the year will be covered. For small treatment works that
are evaluated only once or twice a year, it is important to
monitor in the time of year where performance is expected
to be poorest, to avoid approving a process that is not per-
forming adequately for much of the year. It may also be
beneficial to initially conduct sampling more frequently than
the required minimum, perhaps on a quarterly basis, in
order to determine the range of sludge quality. Process
criteria of PSRPs and PFRPs should be discussed by the
facility with the regulatory authority, and specific require-
ments should be included in permit conditions.
Composite Sampling
Composite sampling, or the combination of several grab
samples to better represent a large quantity of sludge, is
frequently practiced in wastewater treatment. Composites
may consist of grab samples taken over time (typically for
continuous flow processes) or from random locations in a
vessel or pile (typically for batch processes). Since the
purpose of composite sampling is to provide representa-
tion of a large quantity of sludge, the number and distribu-
tion of grab samples, the locations from where they are
taken, and the process of combining grab samples to cre-
ate a composite sample are important to consider.
The following is an example of a sampling procedure for
compositing a continuous flow process. A small stream of
wastewater or sludge is drawn off at rate proportional to
the flow of the main stream being sampled and collected
as a single sample. Typically, times of collection are for
one shift (8 hours) or one day (24 hours). In this case, the
accumulated sample represents a volume-average sample
over the period of time the sample is drawn. The sample is
chilled during the period it is being collected to prevent
chemical/microbiological change until it can be brought
back to the laboratory for analysis.
Composite sampling from stockpiled solid material in-
volves taking multiple grab samples from a range of loca-
tions in the stockpile. Samples should be taken from dif-
ferent interior sections of the pile which may represent
material produced in different time periods. Grab samples
should all be of the same size so that the composite is an
equal representation of all of the grab samples. The grab
samples should be mixed thoroughly and a subsample
pulled from the mixture.
Composite sampling is useful for any type of sampling,
but the protocol must be modified when microbial analy-
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ses are intended. Samples must be taken over a shorter
period of time so that microbial populations do not undergo
significant changes during the sampling event. For ex-
ample, a composite time-average sample can be obtained
by combining a series of small samples taken once every
5 minutes for a period of an hour. A composite sample for
bacterial and viral testing could be taken over an hour or
less under most circumstances without compromising the
results. Composite sampling over 24 hours, or even longer
if special precautions are taken, is possible for viable hel-
minth ova provided the ova in the sample are not exposed
to thermal or chemical stress (e.g., temperatures above
40°C [1 04°F] or the addition of certain chemicals such as
ammonia, hydroxides, and oxidants). In addition to limit-
ing the sampling period, sterile equipment must be used
when taking grab samples or compositing the samples for
microbiological analysis in order to prevent introducing
pathogenic bacteria.
Composite sampling may be possible for samples to be
used in some of the procedures to determine whether vec-
tor attraction reduction is adequate. It may not be appro-
priate for those procedures that depend on bacterial respi-
ration (i.e., aerobic or anaerobic digestion). This subject is
discussed in Appendix D which presents procedures for
three methods to demonstrate reduced vector attraction.
10.7 Regulatory Objectives and Number of
Samples that Should be Tested
Overall, it is recommended that numerous samples be
taken over a period of 2 weeks in order to represent the
average characteristics of a sludge stream. Unfortunately,
sampling for microbial and vector attraction reduction pa-
rameters is more complicated than sampling for heavy
metals because of the time limits and contamination is-
sues involved. In addition, the results of microbial testing
must be handled differently. The following is a review of
the primary sampling and monitoring issues that relate to
particular pathogen and vector attraction reduction param-
eters.
Class B: Monitoring for Fecal Conform
Densities
Part 503 requires that seven samples be taken to dem-
onstrate compliance with the fecal coliform levels required
of Class B biosolids. Under the Class B requirements seven
samples also means seven analyses. Seven samples were
judged adequate to account for the short-term fluctuations
in treated sludge quality and allow determination of aver-
age performance. Variance of fecal coliform determinations
is known to be high, but analysis (presented below) showed
that if seven samples are averaged, the error band about
the mean value is sufficiently compressed that treatment
works with adequately treated sludge would not have diffi-
culty meeting the standard. If the mean value does not
meet the standard, the material is not a Class B biosolids
and must be disposed of otherwise until the standard is
met.
The regulation requires that the geometric mean fecal
coliform density of the seven samples be less than 2 mil-
lion CPU or MPN per gram of total solids sewage sludge
(dry weight basis). If a treatment works were producing a
treated sewage sludge with a true mean density of exactly
2 million fecal coliform per gram, measured values of the
fecal coliform density would cluster around 2 million per
gram, but half would be below and half would be above it.
Half the time, the treatment works would appear not to be
meeting the requirement. The true mean density must be
below 2 million per gram to be confident that the experi-
mentally determined average will be below 2 million per
gram. Just how much below depends on the standard er-
ror of the average.
Use of at least seven samples is expected to reduce the
standard error to a reasonable value. In tests on extended
aeration sludges, Farrell et al. (1990) obtained a standard
deviation of the logarithm of the fecal coliform density (s)
of 0.3 using the membrane filter method. This included the
variability in the analysis as well as variability over time
(approximately a year). Standard error for the average of
seven measurements (S.E.= s/(n1'2)) is 0.11. Using the
normal probability distribution, the true mean must be be-
low 1.30 million if the geometric mean of seven measure-
ments is to be below 2 million 95% of the time (see Table
1 O-l for details of this calculation). If the standard devia-
tion were higher, the true mean would have to be even
lower to be reasonably confident that the geometric mean
would be below 2 million per gram. Thus, efforts should be
made to reduce variability. Steps that can be taken are:
. Reduce the standard error by increasing the number
of measurements used to determine the geometric
mean.
. Reduce process variability.
. Improve sampling and analytical techniques.
What action to take to reduce the geometric mean de-
pends on the process. For anaerobic or aerobic digestion,
some suggested steps are to increase temperature, in-
crease residence time, use a draw-and-fill feeding proce-
dure rather than fill-and-draw or continuous feeding, and
increase the time between withdrawal and feeding. After
an attempt at improvement, the evaluation should be re-
peated. If the process continues to fail, more substantial
changes to the process may be appropriate.
Class A: Monitoring for Fecal Coliform or
Salmonella sp. Densities
Part 503 requires that, to qualify as a Class A sludge,
sewage sludge must be monitored for fecal coliform or
Salmonella sp. and have a density of less than 1,000 MPN
fecal coliform per gram of total solids sewage sludge (dry
weight basis) or Salmonella sp. densities below detection
limits (3 MPN/4 g). The regulation does not specify the
number of samples that have to be taken during a moni-
toring event. One sample is not enough to properly repre-
sent the sewage sludge. It is recommended that multiple
81
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Table 10-1. True Geometric Mean Needed If Standard Fecal Coliform Density of 2 Million CPU Per Gram is to be Rarely Exceeded
Assumptions
. The fecal coliform densities of the sewage sludge are log normally distributed. (The arithmetic mean of the logarithms of the fecal coliform
densities is the mean of the distribution. The geometric mean is the antilog of the arithmetic mean of the log values.)
. The goal is to ensure that the measured mean value does not exceed the density requirement more than once in 20 monitoring events.
. The standard deviation of the log density is 0.30.
Calculation
To predict the expected frequency of a measurement using the normal probability distribution, the variable x is converted to the standard measure
(u - see below) and its probability of occurrence is obtained from tabulated values of the probability distribution. In this case, the reverse is carried
out. A certain probability of occurrence is desired and the value of the standard measure is read from the tables. From the normal distribution table
(single-sided), u is 1.645 when P = 0.05 (one in 20),
Where:
and:
Where:
P =
u =
u=
n =
s=
the proportion of the area under the curve to the right of u relative to the whole area under the curve.
the standard measure
(Equation 1)
true log mean
log mean of the measurements
Sj = s/n1/2
number of measurements that are averaged
standard deviation of a single measurement of log mean density
The logarithm of the fecal coliform density requirement (2 million CFU/g) is x (\ = 6.301). This is the number that should not be exceeded more
than once in 20 monitoring episodes. Substituting into Equation 1 and calculating n,
1.645 = (6.301 -n)/(0.3/7ic)
fi = 6.114
Antilog 6.114 = 1.3 million CFU/g.
samples (>7) be taken over a period of two weeks in order
to adequately represent sludge quality. Based on the reli-
ability of the treatment process and historic test results,
there may be time when a reduction in this monitoring
recommendation is justified. In the case of Class A, ana-
lytical results from multiple samples are not averaged to-
gether; instead, all results must demonstrate be in compli-
ance with Class A limits.
The measured fecal coliform density provides an esti-
mate of the likelihood of Salmonella sp. detection and, if
detected, the expected density. Yanko (1987) obtained a
good correlation between fecal coliform density and Sal-
monella sp. detections in his extensive investigation of
composts derived from sewage sludge. The fraction de-
tected is less than 10% when fecal coliform density is less
than 1,000 MPN/g. Yanko also obtained a good correla-
tion between fecal coliform density and Salmonella sp.
density for those samples for which Salmonella sp. were
detected. That correlation predicts that, for fecal coliform
densities less than 1,000 MPN/g,Salmonella sp. densities
will be less than 1 .0 MPN/g. Thus, at fecal coliform densi-
ties 4,000 MPN/g, Salmonella sp. detections will be in-
frequent and, if detected, densities are expected to be
below 1 MPN/g.
The Part 503 allows the monitoring of either fecal coliform
or Salmonella sp. in order to demonstrate compliance with
Class A microbiological requirements. The Salmonella sp.
determination is somewhat similar to the fecal coliform test,
but it is much more expensive and requires a high experi-
ence level. In all likelihood, the Salmonella sp. tests would
have to be carried out by a contract laboratory.
The standard deviation for Class Asludges will most likely
be lower than for Class B. This is due to the fact that we
have many more organisms present in Class B sludges
which are not equally distributed within the biosolids. There-
fore you have greater variability and hence a higher S.D.
What action to take to further reduce pathogens in case
the fecal coliform requirement is not met depends on the
process. In general, verification of retention times and tem-
peratures as well as elimination of cross-contamination
between feed and treated sludge or opportunities for re-
introduction of pathogens into treated sludge are recom-
mended. For aerated deep-pile composting, thicker insu-
lating layers on the pile and longer maturing times are sug-
gested.
Class A: Monitoring for and Demonstration
of Enteric Virus and Viable Helminth Ova
Reduction
The accuracy of monitoring results demonstrating the
absence of enteric viruses and helminth ova is influenced
by the variability in the influent to the treatment works and
the inherent error in the experimental method. Information
82
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on method error for both enteric viruses and helminth ova
is available only on standard deviations calculated from
duplicate samples. Goyal et al. (1984) report that, in their
comparison of methods for determining enteroviruses, the
log standard deviation for the virus determination in sew-
age sludge was 0.26 (47 degrees of freedom). A review of
the work of Reimers et al. (1989) indicates that, in the range
of 5 to 100 viable Ascaris ova per 10 grams sewage sludge
solids, standard deviation was about half the number of
viable ova. This is equivalent to a log density of 0.3, which
is about the same as for fecal coliform. Thus, there is no
unusually high variability in the basic test methods that
would require an increased number of samples to mini-
mize this effect.
Deciding how many samples to take for enteric viruses
and viable helminth ova is more difficult than for fecal
coliform and Salmonella sp. because enteric viruses and
viable helminth ova oftenmay not be present in untreated
sludge. For this reason, the interpretation of the density
determinations for these organisms in treated sludge de-
pends on the quality of the feed sludge. If no enteric vi-
ruses or viable helminth ova are detected in the feed sludge,
then the absence of these organisms in corresponding
samples of treated sludge does not indicate in any way
whether the process is or is not capable of reducing these
organisms to below detectable limits. The ability of a pro-
cess to reduce these organisms to below detectable limits
is indicated when analysis shows that these organisms
were present in the feed sludge and were not present in
corresponding samples of treated sludge. One important
questions is: What fraction of the total pairs of correspond-
ing samples must show positive in the feed sludge and
negative in the treated sludge to provide convincing evi-
dence that the process consistently reduces enteric viruses
and viable helminth ova to below detectable levels? This
is a difficult question to answer.
Because viable helminth ova are relatively stable micro-
organisms, compositing is suggested as a way to obtain
meaningful representative samples and analytical results.
If precautions are taken, such as cooling the sample
promptly to close to 0°C (32°F) and destroying or neutral-
izing any added chemicals such as strong bases that were
added as part of the pathogen-reducing process, compos-
ites can be collected over a 2-week period. Correspond-
ing composites of feed and treated sludge can be com-
pared, with a much lower likelihood of not finding viable
helminth ova in the feed sewage sludge. Because the ana-
lytical method itself has a high variance (see above), a
minimum of four duplicates of the composite should be
tested.
For enteric viruses, the same approach may be used as
suggested above for viable helminth ova. Precautions are
taken to cool the sample and destroy or neutralize any
chemicals added in the pathogen-reducing process.
Samples are collected on separate days and are promptly
frozen at 0°F (-18°C), or -94°F (-70°C) if samples will be
stored for more than 2 weeks. When the samples are to
be analyzed, the individual samples are thawed and
composited, and viral densities determined.
The density of both viable helminth ova and enteric vi-
ruses in processed sludge must be-based on the results of
several measurements. Most of these measurements are
expected to show below detectable densities. If any one
sample is above 1 PFU (for viruses) or 1 viable helminth
ovum (for helminths) per 4 grams, the process does not
meet the Part 503 operational standard.
Vector Attraction Reduction Tests
Reduction in Volatile Solids
One way to demonstrate reduction in volatile solids re-
quires measurement of volatile solids of the sewage sludge
before and after sludge treatment. The sampling point for
the "after treatment" measurement can be immediately
leaving the processing unit or at the point of use or dis-
posal, provided there has been no significant dilution down-
stream with inert solids.
Farrell et al. (1996) have determined the standard de-
viation of the percent volatile solids (%VS) determination
for separate samples withdrawn from pilot-scale digesters
to be 0.65% (total solids content ranged from 2% to 5%).
Conventional statistical procedures (see Davies and Gold-
smith, 1972) were used to calculate the standard error of
the percent volatile solids reduction (%VSR), which is cal-
culated from the %VS of the untreated and treated sludge.
The standard error of the %VSR when calculated by the
Van Kleeck equation (see Appendix D) is 2.0% in the range
of interest (38% VSR). The 95% confidence limits of the
%VSR are ±4%, which is excessive. If the %VSR is the
average of seven determinations, the confidence interval
is reduced to ±1.5%, which is a more acceptable value.
The most difficult problem with the %VSR determina-
tion, as discussed above in Section 10.4, is getting corre-
spondence of the influent sludge with the effluent sludge.
If there has been a significant change in an inlet concen-
tration or flow rate, achieving correspondence can require
several months of monitoring inlet and outlet volatile sol-
ids concentrations. If conditions have been steady and feed
compositions have been fluctuating about an average value
for a long period, data taken over a 2-week period would
be adequate to establish steady state performance.' This
implies that data have been collected beforehand that dem-
onstrate that sewage sludge composition has reached
steady state for a long period before the 2-week sampling
period. It appears that regular collection of data for some
months before the sampling period is unavoidable to dem-
onstrate steady state performance before the testing pe-
riod. Fortunately, the total and volatile solids determina-
tions are not costly, and they provide valuable operating
information as well.
Total and volatile solids content of a sample do not
change significantly over the course of a day, particularly if
'Note that, unlike the plug flow case, there should be no displacement in time be-
tween comparisons of input and output for fully mixed reactors. Only when there
has been a significant change is it necessary to wait a long time before the com-
parisons can be made.
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the sludge is cooled. Time composites collected over a
course of a day can be used for these determinations.
Seven or more determinations are recommended to re-
duce the error band around the mean to minimize the
chance that a process that actually has a greater volatile
solids reduction than 38% might show an average that is
below this value.
Additional Digestion Tests
The essential measurement in the additional digestion
tests for aerobic and anaerobic sludges (see Sections 8.3
and 8.4) is the percent volatile solids content (%VS) from
which the percent volatile solids reduction is calculated
(%VSR). Using the standard deviation of 0.65% determined
by Farrell et al. (see above), the standard error of the %VSR
when calculated by the Van Kleeck equation (see Appen-
dix D) is 2.5% in the range of interest (15% VSR). The
95% confidence limits of the %VSR are ± 5%. The tests
(see Appendix D) require substantial internal replication
which shrinks these confidence limits. Samples should also
be taken to account for the variability in the process. The
2-week sampling period suggested for the Class A disin-
fection microbiological tests may be excessively restric-
tive if several samples are to be evaluated. The equip-
ment needed for the test is not expensive but the units
take up substantial bench space. It is unlikely that a treat-
ment works will want to have more than two sets of test
equipment. Since the tests take 30 to 40 days, it is not
possible to run more than one set of tests (two in a set)
within a monitoring event. It is suggested that these tests
be routinely carried out during the year and the results be
considered applicable to the monitoring period. It is esti-
mated on a best judgment basis that five tests are needed
to account for variability in the feed sludge and in the treat-
ment process itself.
Specific Oxygen Uptake Rate Test
The Oxygen uptake measuring part of the specific oxy-
gen uptake rate test (SOUR, see Appendix D) can be com-
pleted in the laboratory or field in a few minutes, so there
is no difficulty in completing the test during a monitoring
event. The test requires the SOUR determination to be
made on two subsamples of a given sample. Farrell et al.
(1996) found that, in the target SOUR value of 1.5 mg O/
hr/g, sludge solids replicates agreed within about ± 0.1 mg
O2/hr/g. Since the test is easy to run, it is suggested that
seven tests within the 2-week sampling event will ad-
equately define the SOUR. Labs performing this test should
demonstrate that they too can achieve this level of preci-
sion for replicates (± 0.1 mg O^hr/g). Arithmetic average
of the tests should be computed and compared against
the Part 503 SOUR value.
Raising the pH to 12
There are two options in the regulation that reduce vec-
tor attraction by pH adjustment. In the first, sludge is raised
in pH by alkali addition so that pH is 212 for 2 hours after
alkali addition and, without further alkali addition, remains
at pH 211.5 for an additional 22 hours (see Section 8.7).
The second method is for domestic septage. The pH is
raised to pH 212 by alkali addition and, without further ad-
dition of alkali, remains at 112 for 30 minutes (see Section
8.13). As noted in Section 5.6, the term alkali is used in the
broad sense to mean any substance that increases pH.
The pH requirement in the regulation was established
using data obtained at room temperature (Counts and
Shuckrow, 1975; Ronner and Cliver, 1987), which is pre-
sumed to have been 25°C (77°F). Consequently, pH should
be measured at 25°C (77°F) or measured at the existing
temperature and converted to 25°C (77°F) by use of a tem-
perature-versus-pH conversion table determined experi-
mentally for a treated sludge that meets the pH require-
ments. The correction is not trivial for alkaline solutions; it
is about -0.03 pH units/°C (-0.017 pH unit/°F) for aqueous
calcium hydroxide with a pH of about 12, and should not
be ignored. Note that temperature-compensated pH meters
only adjust instrument parameters and do not compen-
sate for the effect of temperature on the pH of the solution.
pH Adjustment and Septage
Each container of domestic septage being treated with
alkali addition must be monitored. The pH is monitored
just after alkali addition and a half hour or more after alkali
addition. Bonner and Cliver (1987) suggest that alkali (they
used slaked lime) be added to the septic tank or to the
septic tank truck while domestic septage is being pumped
from a septic tank into the tank truck. If slaked lime is used,
a dose of 0.35 Ib per 10 gallons (4.2 g per liter) is sufficient
to raise the pH to 12 for a typical domestic septage of about
1% solids content. The agitation from the high velocity in-
coming stream of septage distributes the lime and mixes it
with the domestic septage. The pH is measured when the
truck loading is complete. The truck then moves to the use
or disposal site. Agitation generated by the motion of the
truck may helps in mixing and distributing the lime how-
ever, supplemental mixing in the tank may be needed. The
pH is again measured at the use or disposal site. The sec-
ond pH measurement should be at least a half hour after
the addition of lime. The sample may be obtained through
the top entry of the tank truck, using, for example, a stain-
less steel cup welded to a long handle to collect the sample.
The pH is most conveniently measured with alkaline pH
paper in the pH range of 11 to 13. The pH paper can age
and become contaminated. It is best to use strips from two
separate containers. If they do not agree, compare with a
third batch and reject the one that disagrees with the oth-
ers. Accuracy of these measurements is within ± 0.1 pH
unit. If the pH is below 12, either initially or after 30 min-
utes, more lime should be added and mixed in. After an
additional waiting period of at least 30 minutes, the pH
must again be measured to ensure that it is greater than
12.
pH Adjustment and Sewage Sludges
For addition of alkali to sewage sludges, the pH require-
ment is part of both the PSRP process description (see
Section 5.3) and the requirement of a vector attraction
option (see Section 8.7). Monitoring is required from 1 to
12 times a year (see Table 3-4 in Chapter 3), and the pro-
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cess must meet the prescribed operating conditions
throughout the year.
Alkali is sometimes added to liquid sludge and some-
times to dewatered sludge. The pH requirements as stated
in the regulation apply in the same way for both liquid and
dewatered sludge. For the first measurement of pH in liq-
uid sludge 2 hours after addition of alkali, it is assumed
that the alkali and the sludge have been mixed together
for a sufficient time to reach equilibrium (not considering
the gradual changes that occur over substantial periods of
time). Consequently, the pH measurement can be made
directly in the liquid sludge. The pH measurement is made
preferably with a pH meter equipped with a temperature
compensation adjustment and a low-sodium glass elec-
trode for use at pH values over 10. The pH electrode is
inserted directly in the sludge for the reading. The second
measurement is made 24 hours after addition of alkali. If
the sludge is still in the liquid state, the pH measurement
is made in the same fashion. However, if the process in-
cludes a dewatering step immediately following the alkali
addition and the sludge is now a dewatered cake, the cake
must be made into a slurry for the pH measurement. Ac-
ceptable procedures for preparing the sample and mea-
suring pH are given by EPA (1986). The procedure requires
adding 20 ml_ of distilled water (containing 0.01 M CaCI2)
to 10 g of sludge cake, mixing occasionally for half an hour,
waiting for the sample to clarify if necessary, and then
measuring pH. The important step is the mixing step that
allows the alkali-treated dewatered sludge to come into
equilibrium with the added water.
Number of Samples
The accuracy of pH meters and of pH paper is within ±
0.1 pH unit. More than one sample is necessary if the do-
mestic septage or sludge is not well mixed. If the lime has
been added gradually over the period in which septage is
being pumped into a tank trug is considered adequate and
a single measurement taken at the top of the tank truck is
sufficient. If alkali has been added to liquid sludge in a
tank at a treatment plant, tests are easily run to establish
how much mixing is required to produce a uniform pH in
the sludge. If this adequate mixing time is used, a single
sample withdrawn from the tank for pH measurement is
sufficient.
If alkali is added to sludge cake, more sampling is sug-
gested. Typically, alkali (usually lime) is added to sludge
cake in a continuous process. The sludge from the dewa-
tering process discharges continuously to a mixer, from
which it discharges to a pile or to a storage bin. Lime is
metered into the mixer in proportion to the sludge flow rate.
The flow rate and compositions of the sewage sludge can
vary with time. To demonstrate compliance on a given day,
several time-composite samples each covering about 5
minutes should be collected, and the pH measured. This
procedure should be repeated several times during the
course of a 2-week sampling event.
For sludge cake, the composites collected for pH mea-
surement must be reduced in size for the pH
measurement.The alkaline-treated sludge may be dis-
charged from the mixing devices in the form of irregular
balls that can be up to 5 to 7.6 cm (2 or 3 inches) in diam-
eter. It is important that the biosolids to which the environ-
ment will be exposed have been treated to reduce patho-
gens and vector attraction to the desired level. If the dis-
charged biosolids are ball shaped and the alkali has not
penetrated the entire ball, one or both of these goals is not
met for the material inside the ball. The entire ball should
be at the proper pH. It is suggested that the composite be
thoroughly mixed and that a subsample be taken for analy-
sis from the mixed composite. An even more conservative
approach is to sample only the interior of the balls.
Percent Solids Greater Than or Equal to
75% and 90%
The monitoring requirement for these vector attraction
options (see Sections 8.8 and 8.9) is simply measurement
of total solids. This measurement is described in Standard
Methods (APHA [1992], Standard Method 2540 G). Stan-
dard Methods
states that duplicates should agree within ± 0.5% of their
average. For 75% solids, this would be ± 3.8%,. For a con-
tinuous process, a time-composite sample can be taken
over the course of a day, and duplicate analyses carried
out on this composite. This is possible because biological
activity essentially ceases at high solids content, and de-
composition will not occur. Approximately seven such com-
posites over the course of a 2-week sampling period would
provide adequate sampling.
Some drying processes such as drying sludge on sand
drying beds are batch processes. In such cases, it may be
desirable to ascertain that the sludge meets the vector at-
traction reduction requirements before removing the sludge
from the drying area. This can be done by taking two sepa-
rate space-composites from the dried sludge, analyzing
each of them in duplicate, and removing the sludge only if
it meets the required solids content.
Frequently Asked Questions
How many samples should be submitted for each
monitoring event for Class A pathogen tests? How
many grab samples should be taken for each com-
posite?
The 503 regulations do not specify a minimum number
of samples per sampling event for Class A sludge, but it is
strongly recommended that enough samples be taken to
adequately represent the mass of material which is to be
distributed. A minimum of seven samples, as required for
Class B fecal coliform testing is recommended, but the
number of samples, and the number of grab samples which
each composite should represent, depends on the size of
the facility and the volume of sludge product that is distrib-
uted. A sampling plan should be developed and submitted
to the permitting authority for review.
Are you out of compliance for Class A if you take more
than one sample, and one result is over the limit?
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Yes, In order to meet Class Astandards, all material must
meet pathogen standards. Although Class B pathogen stan-
dards are based on a geometric mean of analytical re-
suits, geometric (or arithmetic) means are not acceptable
for compliance with Class A standards. Therefore, if sev-
eral samples are submitted for analysis during one moni-
toring event, and one sample is found to be out of compli-
ance with Class A pathogen standards, the entire batch
must be considered Class B (assuming it meets Class B
standards).
For batch processes, one way to prevent one 'out of
compliance' sample from affecting the classification of a
large volume of finished product is to maintain smaller sepa-
rate storage piles and to sample from segregated areas.
For example, finished compost could be separated into
piles based on when composting was completed. If one
result shows non-compliance with the Class A standards,
but other samples are within the Class A limits, it would be
relatively simple to separate out the non-compliance ma-
terial and reprocess it or distribute it as Class B material.
Continuous flow operations can reduce the probability
that one outlying result will cause their process to fail by
taking multiple samples over a 24-hour period and
compositing the samples. The composite sample can then
be analyzed in duplicate to provide more data.
Averaging lab results is allowable as a means to elimi-
nate laboratory variability however all data must be reported
to the permitting authority for review. For example, if a lab
runs duplicate fecal coliform analyses on one sample, the
results from these analyses can be averaged together for
one result. This is not intended to allow facilities to rerun
analyses on out of compliance samples in the hope of low-
ering average results.
Pathogen testing on our Class A sludge product has
shown that we consistently reduce Salmonella sp. to
below detectable limits, but fecal coliform levels are
sometimes over 1000 MPN per gram. Should we be
concerned about this? Should we be concerned If the
fecal coliform level In our Class A material Is occa-
sionally as high as 990 MPN/gram?
According to the regulations, neither situation is a prob-
lem. You are required to comply with either the Salmonella
sp. or the fecal coliform standards, not both. However, the
level of fecal coliform in the product may indicate that there
is incomplete pathogen destruction or some regrowth in
your product, in which case you should examine your patho-
gen and vector attraction reduction processes to ensure
that you are complying fully with the requirements and are
not contaminating the product. The high fecal coliform
counts may also be due to the presence of other, non-
fecal coliforms in the sludge. These coliforms, which share
some characteristics with fecal coliforms, may be detected
in fecal coliform testing. They are particularly likely to ap-
pear in compost samples since they tend to be found in
woody materials.
In addition, certain processes have been found to leave
a residual population of fecal coliform which can repopu-
late the sludge. It is possible that testing would find fecal
coliform over the Class A limits even when the pathogenic
bacteria for which fecal coliform are intended to serve as
indicators have been reduced below detectable levels.
Composting and lime treatment are two of these processes.
It is therefore recommended that if properly operated Class
A facilities yield high populations of fecal coliform in fin-
ished solids that Salmonella sp. be used as the indicator
organism for these types of facilities.
Can we distribute finished material before getting
pathogen test results back? If yes, what do you do if
results later show that material was not Class A?
This issue is covered extensively in Section 4.10. Sludge
classification is based on the most recent available lab data,
and therefore, material generated during a sampling pe-
riod can be distributed before results from that sampling
period are available (based on the results of the previous
sampling event). However, it is recommended that materi-
als generated during the sampling period be held on site
until results are available in order to prevent a situation in
which material is erroneously classified and distributed as
Class A.
If composting piles are monitored for temperatures
at three different points, do all three points have to
meet PFRP at the same time?
All particles of sludge must undergo the PFRP time and
temperature regime. For aerated static pile and in-vessel
composting, the entire pile must meet the temperature re-
quirements concurrently. If one point is found to be below
the 55°C level during the temperature monitoring period,
the entire pile is considered to be out of compliance, and
the three consecutive day PFRP period must start over
again. However, if temperatures are taken in distinct piles
or cells of an in-vessel system, each section can meet the
PFRP requirements separately.
Our facility often stockpiles composted sewage
sludge over the winter. In the spring, we may have as
much as four months' production of compost on site.
How should sampling be conducted?
After material is stored on site, it must be resampled in
order to determine if regrowth of pathogens has taken
place. The number of samples should correspond to the
time period that the stockpile represents and the mandated
frequency of sampling based on the facility's size. For ex-
ample, if a facility is required to sample sludge every month,
and there are four months' worth of compost on site, a
minimum of four samples (therefore, 4 times 7 or 28 analy-
sis) from appropriate sections of the stockpile must be
submitted. Ideally, material will be stored in segregated
piles so that each month's production of compost can be
sampled separately.
This applies to other long-term sludge storage such as
lagoons. The number of samples taken from lagoons
should be based on the time period that the lagoon(s) repre-
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sent and the frequency of sampling that a facility is obli-
gated to follow because of the rate of sludge generation.
What should we do if our process changes or ex-
pands?
Permits are granted based on particular operational pa-
rameters. Therefore, any projected changes in the opera-
tion or expanded flow should be discussed with the per-
mitting authority before changes are made, even if you do
not have a permit.
Can we be permitted for operation only during cer-
tain months?
If your operation will only meet pathogen or vector at-
traction reduction standards during part of the year, your
permit can contain conditions which allow distribution only
during these times. Permits can also be written to take
ambient conditions into account; for example, some "low-
impact" composting facilities are required to retain mate-
rial over two summers. It may also be practical to limit stor-
age and utilization of particular types of sludges to some
seasons.
Can we combine two PSRP processes that individually
do not meet the specified process requirements to pro-
duce a Class B product? Can time in extended aeration be
added to digester time?
The only way to evaluate the effectiveness of pathogen
reduction through a combination of two or more PSRP pro-
cesses is by testing the sludge for fecal coliform density. If
sufficient pathogen reduction can be demonstrated con-
sistently, the preparer also may consider applying for a
PSRP equivalency for the combined processes in order to
eliminate the need for fecal coliform testing.
In general, extended aeration cannot be considered a
PSRP or part of a PSRP because raw sewage is continu-
ally being added to the aerator and blending with the mixed
liquor. Specific cases in which extended aeration is not
subject to short-circuiting and is thought to contribute sig-
nificantly to the pathogen reduction process should be
evaluated by testing the resulting sludge for fecal coliform
density and by the SOUR test or extended aerobic diges-
tion one for addressing VAR requirements.
If I produce an "exceptional quality" (EQ) product
and mix the product with topsoil before distribution,
does the mix have to be tested for 503 compliance?
Regulations regarding "exceptional quality" material, or
material which complies with the highest levels of patho-
gen and vector attraction reduction as well as heavy met-
als limits, are based on when the sludge preparer loses
control of the material. If the EQ material is still within your
control (i.e. on-site or owned by the preparer) when it is
mixed, the new product must undergo pathogen and vec-
tor attraction reduction processes and be analyzed for Part
503 parameters including pathogens, vector attraction re-
duction, and heavy metals. This may be problematic for
some facilities since a mix of stable compost and soil, for
example, is unlikely to meet/undergo PFRP time and tem-
perature requirements. You may have to test the mix for
helminth ova and enteric viruses in order to demonstrate
compliance with Class A pathogen reduction. If, however,
the EQ material has left your control (i.e. is sold to a soil
blender), the material falls out of the jurisdiction of the Part
503, and any subsequent blending of the material with other
products is not covered by these regulations. Non-EQ
materials are always subject to the Pan' 503, and storage
or mixing of non-EQ materials with soil, yard waste, or other
additives must be followed with re-testing and re-classifi-
cation. The party responsible for the sludge mixing is con-
sidered a sludge preparer and is therefore subject to all
Part 503 requirements.
Our sludge product meets vector attraction reduc-
tion requirements because the level of total solids In
the material is greater than 75 percent. If stored mate-
rial becomes wet because of rainfall, is the material
still in compliance with the requirements?
The vector attraction reduction requirement stipulates
that the material be processed to greater than 75 percent
(or 90 percent when unstabilized solids are present) total
solids. If dried sewage sludge (biosolids) is stored at your
facility and becomes wet, It still meets the vector attraction
reduction criteria as long as the facility has testing docu-
mentation that the biosolids were processed to >75 or 90
percent solids prior to the time the material became wet. It
is a good management practice however to prevent dried
biosolids from getting wet while it is being stored at the
facility.
In the case of vector attraction reduction Option 6, it is
required that the pH of the sludge be raised to >12 for 2
hours and 211.5 for 22 hours. It is not required that the
sludge be maintained at the elevated pH once the mate-
rial has fulfilled the vector attraction reduction requirement.
However, it is important to note that the sludge which ap-
pears to be stable under the elevated conditions may be-
come odorous and attract vectors if the pH declines. It is
recommended that sludge be utilized before the pH drops
below 10.5 in order to prevent odors or vector attraction
which may result in a public nuisance.
Can Alternative 1 be used to demonstrate pathogen
reduction for composting if the compost piles do not
attain 55° C for 3 consecutive days?
Alternative 1 is based on similar time/temperature rela-
tionships as the composting process. Regime A
(D=131,700,000/1001400t in which t>50° C and D10.0139
days) can apply to composting. The table below shows
some points on the time/temperature curve that would com-
ply with the regime.
Time (Days)
Temperature ("C)
0.02 (30 min)
0.04 (1 hour)
0.08 (2 hours)
1
2
3
70
68
66
58
56
55
87
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As shown, it is theoretically possible that a compost pile
could comply with Alternative 1 by reaching very high tem-
peratures for a short period of time. Alternative 1 is based
on the assumption that all particles of sludge are at-
taining these temperatures uniformly. This may be diffi-
cult in a compost pile unless the compost pile is completely
enclosed and well insulted. In addition, excessive tempera-
tures in a composting process may result in anaerobic
conditions and subsequent odors.
Our facility is planning to expand next year, and we
would like to implement a new process for pathogen
reduction. We will submit our request for equivalency
to the PEC this year, but, given the current turn around
time for applications, do not expect to have equiva-
lency granted for 2 more years. What should we do in
the Interim?
Depending on the class of sludge you are hoping to pro-
duce, you have two options. If you are producing a Class
B sludge, you should continue to do fecal coliform testing
in order to demonstrate compliance with the Class B limit
of 2 million CPU or MPN per dry gram of sludge. If you are
producing a Class A sludge, you could follow Alternative 4
and test the sludge product for helminth ova and enteric
viruses as well as either fecal coliform or Salmonella sp..
In either case, an application for equivalency will require
data demonstrating pathogen reduction, so this data will
be useful in that respect.
You may also wish, in the case of Class A sludge, to test
the feed sludge for enteric virus and helminth ova. Adequate
demonstration that the process reduces these pathogens
on a consistent basis may qualify the process as a PFRP
equivalent one (Class A, Alternative 6). You should con-
sult with the permitting authority to determine an accept-
able sampling protocol. Demonstration of helminth ova and
virus reduction is difficult, particularly if the density of these
pathogens in the influent is low or sporadic. The sampling
program must demonstrate that actual reduction is taking
place, not just that the pathogen density in the treated
sludge is low. Once pathogen reduction has been suffi-
ciently demonstrated, testing for enteric viruses and helm-
inth ova are no longer necessary as long as the process is
conducted in compliance with specified conditions for PFRP
equivalency.
Our facility distributes Class B lime stabilized sludge
to farmers who use the sludge on a variety of crops. Is
It our responsibility to keep track of how this sludge is
used?
You are required to provide the farmers with all sludge
quality data as well as regulatory information which will
allow them to comply with the appropriate site restrictions.
The applicator, the farmer, is then responsible for follow-
ing the correct site and harvest restrictions. However, given
that any problems with land application will most likely af-
fect the public perception of sludge reuse and this may in
turn affect your facility, it is recommended that you work
closely with farmers to ensure that the regulations are be-
ing followed. In addition, the permitting authority may
choose to include conditions related to site and harvest
restrictions in your permit.
Is there any limit of how long Class B sludge can be
stored before it is used?
Part 503 Rule defines storage as "the placement of sew-
age sludge: on land on which the sewage sludge remains
for two years or less." It does not include placement of
sewage sludge on the land for treatment. After two years
the storage site is considered a final disposal one. The
permitting authority may include storage conditions in your
permit which mandates usage of the material while it still
retains certain characteristics (moisture content) or within
a certain time period. It is recommended that storage of
Class B material be limited to 30 days and be conducted
under similar site restrictions as usage of Class B mate-
rial. For example, public contact and access to the stor-
age site should be restricted.
If the vector attraction reduction requirements have
been fulfilled under Option 6, is there any need for the
sludge to remain at an elevated pH?
In the case of vector attraction reduction Option 6, it is
required that the pH of the sludge be raised to 212 for 2
hours and >11.5 for 22 hours. It is not required that the
sludge be maintained at the elevated pH once the mate-
rial has fulfilled the vector attraction reduction requirement.
However, it is important to note that sludge that appears to
be stable under the elevated conditions may become odor-
ous and attract vectors if the pH declines. It is recom-
mended that sludge be utilized before the pH drops below
10.5 in order to prevent odors or vector attraction that may
result in a public nuisance.
References and Additional Resources
Counts, C.A. and A.J. Shuckrow. 1975. Lime stabilized
sludge: its stability and effect on agricultural land. Rept.
EPA670/2-75-012, pub. U.S. EPA.
Davies, 01. and P.L. Goldsmith, ad. 1972. Statistical meth-
ods in research and production. Essex, England:
Longman Group Ltd.
Farrell, J.B., B.V. Salotto, and A.D. Venosa. 1990. Reduc-
tion in bacterial densities of wastewater solids by three
secondary treatment processes. Res. J. WPCF 62(2):
177-184. .
Farrell, J.B., V. Bhide, and J.E. Smith. 1996. Development
of EPA's new methods to quantify vector attraction re-
duction of wastewater sludges. Water Environment Re-
search, Vol. 68, No. 3.
Goyal, S.M., S.A. Schaub, FM. Wellings, D. Berman, J.S.
Glass, C.J. Hurst, D.A. Brashear, C.A. Sorber, B.E.
Moore, G. Bitton, P.M. Gibbs, and S.R. Farrah. 1984.
Round robin investigation of methods for recovering
human enteric viruses from sludge. Applied & Environ.
Microbiology 48:531-538.
88
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Kowal, N.E. 1994. Pathogen risk assessment: Status and
potential application in the development of Round II regu-
lations. Proceedings of the June 19-20,1994 Speciality
Conference. The Management of Water and Waste-
water Solids for the 21st Century: A Global Perspec-
tive. Water Environment Federation. Alexandria, VA.
Reimers, R.S., M.D. Little, T.G. Akers, W.D. Henriques,
R.C. Badeaux, D.B. McDonnell, and K.K. Mbela. 1989.
Persistence of pathogens in lagoon-stored sludge.
Kept. No. EPA/600/2-89/015 (NTIS No. PB89-190359/
AS). Cincinnati, OH: U.S. EPA Risk Reduction Engi-
neering Laboratory.
Ronner, A.B. and D.O. Cliver. 1987. Disinfection of viruses
in septic tank and holding tank waste by calcium hy-
droxide (Lime). Unpublished report, Small Scale Waste
Management Project. Madison, Wl: University of Wis-
consin.
U.S. EPA. 1986. Test methods for evaluating solid waste:
method 9045A, soil and waste pH, Revision 1, Nov.
1990. Washington, D.C.: Office of Solid Waste and
Emergency Response, U.S. EPA. (avail. U.S. Supt. of
Documents).
Weaver, R.W.; J.S. Angle; and P.S. Bottomley 1994. Meth-
ods of Soil Analysis. Part 2. Microbiological and Bio-
chemical properties. Madison, Wl Soil Science Soci-
ety of America.
Yanko, W.A. 1987. Occurrence of pathogens in distribu-
tion and marketing municipal sludges. Report No.: EPA/
600/1 87/014. (NTIS PB88-154273/AS.) Springfield,
VA: National Technical Information Service.
89
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Chapter 11
Role of EPA's Pathogen Equivalency Committee in
Providing Guidance Under Part 503
11 .1 Introduction
One way to meet the pathogen reduction requirements
of the Part 503 is to treat sewage sludge in a process
"equivalent to" the PFRP or PSRP processes listed in Ap-
pendix B of the Part 503 regulation (see Tables 4-2 and 5-
1 for a list of these processes):
. Under Class A Alternative 6, sewage sludge that is
treated in a process equivalent to PFRP and meets
the Class A microbiological requirement (see Section
4.3) is considered to be a Class A biosolids with re-
spect to pathogens (see Section 4.9).
. Under Class B Alternative 3, sewage sludge treated
by a process equivalent to PSRP is considered to be
a Class B biosolids with respect to pathogens (see
Section 5.4).
These alternatives provide continuity with the Part 257
regulation, which required that sewage sludge be treated
by a PSRP, PFRP, or equivalent process prior to use or
disposal. There is one major difference between Part 257
and Part 503 with respect to equivalency. Under Part 257,
a process had to be found equivalent in terms of both patho-
gen reduction and vector attraction reduction. Under Part
503, equivalency pertains only to pathogen reduction.
However, like all Class A and B biosolids, sewage sludges
treated by equivalent processes must also meet a sepa-
rate vector attraction reduction requirement (see Chapter
8).
What Constitutes Equivalency?
To be equivalent, a treatment process must be able to
consistently reduce pathogens to levels comparable to the
reduction achieved by the listed PSRPs or PFRPs. (These
levels, described in Section 11.3, are the same levels re-
quired of all Class A and B biosolids.) The process contin-
ues to be equivalent as long as it is operated under the
same conditions (e.g., time, temperature, pH) that produced
the required reductions. Equivalency may be site-specific;
equivalency applies only to that particular operation run at
that location under the specified conditions, and cannot
be assumed for the same process performed at a different
location, or for any modification of the process. Processes
that are able to consistently produce the required patho-
gen reductions under the variety of conditions that may be
encountered at different locations across the country may
qualify for a recommendation of national equivalency (a
recommendation that the process will be equivalent wher-
ever it is operated in the United States).
Who Determines Equivalency?
The permitting authority is responsible for determining
equivalency under Part 503. The permitting authority and
facilities are encouraged to seek guidance from EPA's
Pathogen Equivalency Committee (PEC) in making equiva-
lency determinations. The PEC makes both site-specific
and national equivalency recommendations.
What Are the Benefits of Equivalency?
A determination of equivalency can be beneficial to a
facility, because it reduces the microbiological monitoring
burden in exchange for greater monitoring of process pa-
rameters. For example a facility meeting Class A require-
ments by sampling for enteric viruses and viable helminth
ova in compliance with Alternative 4 may be able to elimi-
nate this monitoring burden if they are able to demonstrate
that their treatment process adequately reduces these
pathogens on a consistent basis'. Similarly, a facility meet-
ing Class B Alternative 1 requirements by analyzing sew-
age sludge for fecal coliform may be able to eliminate the
need for testing if the process is shown to reduce patho-
gens to the same extent as all PSRP processes. Equiva-
lency is also beneficial to facilities which may have low
cost, low technology systems capable of reducing patho-
gen populations. Options such as long term storage, air
drying, or low technology composting have been consid-
ered by the PEC.
Because equivalency status allows a facility to eliminate
or reduce microbiological sampling, it is imperative that
the treatment processes deemed equivalent undergo rig-
orous review to ensure that the Part 503 requirements are
met. Obtaining a recommendation of equivalency neces-
sitates a thorough examination of the process and an ex-
'A determination of PFRP equivalency will not reduce the monitoring required for
Salmonella sp. or fecal coliform because all Class A biosolids, even biosolids pro-
duced by equivalent processes, must be monitored for Salmonella sp. or fecal
coliform (see Section 4.3)
90
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tensive sampling and monitoring program. The time needed
to review an application is contingent on the completeness
of the initial application. Sewage sludge preparers wishing
to apply for equivalency should review this chapter care-
fully and discuss the issue with the regulatory authority in
order to determine if equivalency is appropriate for their
situation.
Figure 11-1 indicates when application for equivalency
may be appropriate.
Recommendation of National Equivalency
The PEC can also recommend that a process be con-
sidered equivalent on a national level if the PEC finds that
the process consistently produces the required pathogen
reductions under the variety of conditions that may be en-
countered at different locations across the country. A rec-
ommendation of national equivalency can be useful for
treatment processes that will be marketed, sold, or used
at different locations in the United States. Such a recom-
No
Is your process capable of
consistently reducing enteric viruses
and viable helminth ova to below
detectatfe levels?
Is your process capable of consistently
reducing the density of fecal coliforms
to below 2 million CPU or MPN per
gram total sewage sludge solids?
No
Your process is
unlikely to be
equivalent to
PSRP
Yes
Site-specific
PSRP
equivalency may
be useful
Are you a developer of a sewage
sludge treatment process that has
been or will be marketed and sold in
different areas of the United States?
Yes
Is the effectiveness of your process
independent of the variety of climatic
and other conditions that may be
encountered in different locations in
the United States?
Yes
A recommendation of national PSRP
equivalency may be useful
No
recommendation
of national
equivalency is
unnecessary
Your process is
unlikely to be
recommended
as equivalent on
a national level
Yes
Is your process covered under Class A
Alternative 1,2, or 5?
No u
Yes
Site-specific
PFRP
equivalency may
be useful (see
Section 11.3)
Equivalency is
unnecessary
Are you a developer of a sewage
sludge treatment process that has
been or will be marketed and sold in
different areas of the United States?
^ Yes
Is the effectiveness of your process
independent of the variety of climatic
and other conditions that may be
encountered in different locations in
the United States?
T
Yes
A recommendation of national PFRP
equivalency may be useful
J
Figure 11-1. When is application for PFRP or PSRP equivalency appropriate?
91
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mendation may be useful in getting PFRP or PSRP equiva-
lency determinations from different permitting authorities
across the country.
Role of the Pathogen Equivalency
Committee
The U.S. Environmental Protection Agency created the
Pathogen Equivalency Committee (PEC) in 1985 to make
recommendations to EPA management on applications for
PSRP and PFRP equivalency under Part 257 (Whittington
and Johnson, 1985). The PEC consists of approximately
ten members with expertise in bacteriology, virology, para-
sitology, environmental engineering, medical and veteri-
nary sciences, statistics, and sewage sludge regulations.
It includes representatives from EPA's Research and De-
velopment Office, the Office of Water, and the regional of-
fices. The 1993 memorandum included at the end of this
chapter describes the role of the PEC.
Guidance and Technical Assistance on
Equivalency Determinations
The PEC continues to review and make recommenda-
tions to EPA management on applications for equivalency
under Part 503. Its members also provide guidance to ap-
plicants on the data necessary to determine equivalency,
and to permitting authorities and members of the regu-
lated community on issues (e.g., sampling and analysis)
related to meeting the Subpart D (pathogen and vector
attraction reduction) requirements of Part 503. It is not
necessary to consult the PEC with regard to sampling and
monitoring programs if a protocol is already approved un-
der one of the Class A alternatives. Figure 11-2 elaborates
on the role of the PEC under Part 503.
What's in This Chapter?
This chapter explains how the PEC makes equivalency
recommendations and describes how to apply for PEC
guidance. The guidance in this chapter may also prove
useful for permitting authorities in establishing the infor-
mation they will need to make equivalency determinations.
11.2 Overview of the PEC's Equivalency
Recommendation Process
The first point of contact for any equivalency determina-
tion, recommendation, or other guidance is usually the
permitting authority. This is the regional EPA office or the
State in cases in which responsibility for the Part 503 pro-
gram has been delegated to the state. Appendix A pro-
vides a list of EPA Regional and state Contacts. If PEC
involvement is appropriate, the permitting authority will
coordinate contact with the PEC.
The PEC considers each equivalency application on a
case by-case basis. Applicants submit information on sew-
age sludge characteristics, process characteristics, climate,
and other factors that may affect pathogen reduction or
process efficiency as described in Section 11.5. The com-
mittee evaluates this information in light of current knowl-
edge concerning sewage sludge treatment and pathogen
reduction, and recommends one of five decisions about
the process or process sequence:
. It is equivalent to PFRP.
. It is not equivalent to PFRP.
. It is equivalent to PSRP.
. It is not equivalent to PSRP.
. Additional data or other information are needed.
Site-specific equivalency is relevant for many applica-
tions; to receive a recommendation for national equiva-
lency, the applicant must demonstrate that the process will
produce the desired reductions in pathogens under the
variety of conditions that may be encountered at different
locations across the country. Processes affected by local
climatic conditions or that use materials that may vary sig-
nificantly from one part of the country to another are un-
likely to be recommended as equivalent on a national ba-
sis unless specific material specifications and process pro-
cedure requirements can be identified.
If the PEC recommends that a process is equivalent to a
PSRP or PFRP, the operating parameters and any other
conditions critical to adequate pathogen reduction are
specified in the recommendation. The equivalency recom-
mendation applies only when the process is operated un-
der the specified conditions.
If the PEC finds that it cannot recommend equivalency,
the committee provides an explanation for this finding. If
additional data are needed, the committee describes what
those data are and works with the permitting authority and
the applicant, if necessary, to ensure that the appropriate
data are gathered in an acceptable manner. The commit-
tee then reviews the revised application when the addi-
tional data are submitted.
11.3 Basis for PEC Equivalency
Recommendations
As mentioned in Section 11.1, to be determined equiva-
lent, a treatment process must consistently and reliably
reduce pathogens in sewage sludge to the same levels
achievable by the listed PSRPs or PFRPs. The applicant
must identify the process operating parameters (e.g., time,
temperature, pH) that result in these reductions.
PFRP Equivalency
To be equivalent to a PFRP, a treatment process must
be able to consistently reduce sewage sludge pathogens
to below detectable limits. For purposes of equivalency,
the PEC is concerned only with the ability of a process to
demonstrate that enteric viruses and viable helminth ova
have been reduced to below detectable limits. This is be-
cause Part 503 requires ongoing monitoring of all Class A
biosolids for fecal coliform or Salmonella sp. (see Section
92
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C 20460
JUN 15 1993
OFFICE! f
W A J [ »
MEMORANDUM
SUBJECT:
FROM:
The Role of the Pathogen Kquivalency Committee Under
the Part 503 Standards for the Use or Disposal of
Sewage Sludge
TO:
PURPOSE
Michael B. Cook, Direct
Office of Wastewater Enforc
James A. Hanlon, Acting Directo:
Office of Science & Technology
Water Division Directors
Regions I - X
This memorandum explains the role of the Pathogen
Equivalency Committee (PEC)in providing technical assistance and
recommendations regarding pathogen reduction equivalency in
implementing the Part 503 Standards for the Use or Disposal of
Sewage. The PEC is an Agency resource available to assist your
permit writers and regulated authorities. This information
should be sent to your Regi9nal Sludge Coordinators, Municipal
Construction Managers, Permits and Enforcement Coordinators, and
Solid Waste Offices, State Sludge Management Agencies and others
concerned with sewage sludge management.
BACKGROUND
The PEC Under Part 257
The Criteria for Classification of Solid Waste Facilities
and Practices (44 IB 53438, September 13, 1979), in 40 CFR Part
257 required that sewage sludge disposed on the land be treated
by either'a Process to Significantly Reduce Pathogens (PSRP) or a
Process to Further Reduce Pathogens (PFRP). A list of PSRPs and
PFRPs were included in Appendix II to Part 257.
In 1985, the PEC was formed to provide technical assistance
and recommendations on whether sewage sludge treatment processes
not included in Appendix II to Part 257 were equivalent to PSRP
or PFRP. Under Part 257, the PEC provided technical assistance
to both the permitting authority and to members of the regulated
Figure 11-2. Role of the PEC under Part 503.
93
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A series of options are provided in the Part 503 regulation
for meeting the specific requirements for the two classes of
pathogen reduction. One of the Class A alternatives is to treat
the sewage sludge by a process equivalent to a PFRP and one of
the Class B alternatives is to treat the sewage sludge by a
process equivalent to a PSRP. The permitting authority must
decide whether a process is equivalent to a PFRP or a. PSRP, which
is the same approach used under Part 257.
THE PEC UNDER 503
Part 503 provides specific criteria and procedures for
evaluating bacterial indicators (Fecal coliforms and Salmonella
sp.), enteric virus and viable helminth ova as well as vector
attraction reduction. The PEC will continue to support the
permitting authority and members of the regulated community under
the new Part 503 regulation in evaluating equivalency situations
and providing technical assistance in matters such as sampling
and analysis. Specifically the PEC:
will continue to provide technical assistance to the
permitting authority and regulated community, including
recommendations to the permitting authority about
process equivalency. The PEC also will make both site-
specific and national (i.e., a process that is
equivalent anywhere in the United States where it is
installed and operated) recommendations on process
equivalency .
will submit recommendations on process equivalency to
the Director, Xealth and Ecological Criteria Division,
Office of Science and Technology, who will review those
recommendations and then notify the applicant and
appropriate permitting authorities of our
recommendation.
For site-specific recommendations, requests for PEC review
or assistance should be made through the appropriate Federal
permitting authority (e.g., the State sludge regulatory authority
for delegated programs or the EPA Regional Sludge Coordinator for
non-delegated programs). For national recommendations, requests
for PEC review or assistance can also be made through the
Director, Health and Ecological Criteria Division (WH-586),
Office of Science & Technology, U.S. EPA, 401 M St. , SW,
Washington, D.C. 20460 or directly to the PEC Chairman. The
current PEC Chairman is: Dr. James E. Smith, Jr., U.S. EPA,
CERI, (Center for Environmental Research Information) 26 W Martin
Luther King Dr., Cincinnati, OH 45268 (Tele: 513/569-7355).
Additional information and guidance to supplement the
pathogen reduction requirements of Part 503 and the procedures to
use to reach the PEC and the assistance provided by the PEC is
provided in "Control of Pathogens and Vector Attraction in Sewage
Figure 11-2. Role of the PEC under Part 503 (continued).
94
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community. The PEC membership has included representatives from
the Office of Research * Development (ORD), office of Wastewater
Enforcement i Compliance (OWEC), and the Office of Science £
Technology (OST) with extensive experience in microbiology,
sludge process engineering, statistics and regulatory issues.
The PEC recommendations regarding the equivalency of processes
were forwarded to the Office of Science and Technology, which
notified applicants about the PBC's recommendations. Final
decisions on equivalency were made by the permitting authority.
The Part 503 Sewage Sludge Standards
The 40 CFR Part 503 Standards for the Use or Disposal of
Sevags Sludge were published in the Federal Register on
February 19, 1993 (58 FR 9248) under the authority of section 405
of the Clean Water Act, as amended. Part 503 establishes
requirements for sewage sludge applied to the land, placed on a
surface disposal site, or fired in a sewage sludge incinerator.
Along with the 40 CFR Part 258 Municipal Solid Waste (MSW)
Landfill Regulation (56 FR 50978, October 9, 1991), which
established requirements for materials placed in MSW landfills,
the Part 503 requirements for land application of sewage sludge
and placement of sewage sludge on a surface disposal site,
replaces the requirements for those practices, including the
requirement to treat the sewage sludge in either a PSRP or a
PFRP, in Part 257.
The Part 503 regulation addresses disease-causing organisms
(i.e., pathogens) in sewage sludge by establishing requirements
for sewage sludge to be classified either as Class A or Class B
with respect to pathogens as an operational standard. Class A
requirements are met by treating the sewage sludge to reduce
pathogens to below detectable limits, while the Class B
requirements rely on a combination of treatment and sits
restrictions to reduce pathogens. The site restrictions prevent
exposure to the pathogens and rely on Natural Environmental
processes to reduce the pathogens in the sewage sludge to below
detectable levels. In addition to pathogen reduction, a vector
attraction reduction requirement has to be met when sewage sludge
is applied to the land or placed on a surface disposal site.
Vector attraction reduction requirements are imposed under
Part 503 to reduce the potential for spreading of infectious
disease agents by vectors (i.e., flies, rodents, and birds). A
series of alternative methods for meeting the vector attraction
reduction requirement are provided in the rule.
All sewage sludges that are to be sold or given away in a
bag or other container for land application, or applied to lawns
or home gardens must meet Class A pathogen control and vector
attraction reduction requirements. All sewage sludge intended
for land application must meet at least the Class B pathogen
control and vector attraction reduction requirements. Surf ace
disposal of sewage sludge requires that Class A or Class B
requirements, along with one of the vector attraction reduction
practices, be met unless the sewage sludge is covered with soil
or other material daily.
Figure 11-2. Role of the PEC under Part 503 (continued).
95
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Sludge" (EPA 625/R-92/013), which will-be updated from time to
time by the PEC. This document is an update of the 1989 document
"Control of Pathogens in Municipal Wastewatsr Sludge"
(EPA/625/10-89/006), and is available from CERI.
If there are any questions about this memorandum,please
contact Bob Bastiaa from OWEC at 202/260-7378 or Dr. Smith at
CERI.
Figure 11-2. Rote of the PEC under Part 503 (continued).
96
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4.3) to ensure that Salmonella sp. are reduced to below
detectable limits (i.e., to less than 3 MPN per 4 grams total
solids sewage sludge [dry weight basis]) and that growth
of pathogenic bacteria has not occurred. Thus, to demon-
strate PFRP equivalency, the treatment process must be
able to consistently show that enteric viruses and viable
helminth ova are below the detectable limits, shown be-
low:
There are two ways these reductions can be demon-
strated:
. Direct monitoring of treated and untreated sewage
sludge for enteric viruses and viable helminth ova
. Comparison of the operating conditions of the process
with the operating conditions of one of the listed
PFRPs.
The process comparison approach to demonstrating
equivalency is discussed in
Section 11.4.
PSRP Equivalency
To be equivalent to PSRPs, a process must consistently
reduce the density of pathogenicviruses and bacteria (num-
ber per gram of biosolids (dry weight basis)) in mixed sludge
from a conventional plant by equal to or greater than 1 log
(base 10). Data indicate that, for conventional biological
and chemical treatment processes (e.g. digestion and lime
treatment) a reduction of 1 log (base 10) in pathogenic
virus and bacteria density correlates with a reduction of 1
to 2 logs (base 10) in the density of indicator organisms
(Farrell et al, 1985, Farrah et al, 1986). On this basis a 2-
log (base 10) reduction in fecal indicator density is accepted
as satisfying the requirement to reduce pathogen density
by 1 log (base 10) for these types of processes (EPA,
1989c). Specifically, the applicant must demonstrate a 2-
log (base 10) reduction (number per gram of biosolids (dry
weight basis)) in fecal coliforms.
There is substantial data to indicate that sludge produced
by conventional wastewater treatment and anaerobic di-
gestion at 35EC for more than 15 days contains fecal
coliforms at average log (base 10) densities (number per
gram of biosolids (dry weight basis)) of less than 6.0
(Farrell, 1988). Thus, for processes or combinations of
processes that do not depart radically from conventional
treatment (gravity thickening, anaerobic or aerobic biologi-
cal treatment, dewatering, air drying and storage of liquid
or sludge cake), or for any process where there is a dem-
onstrated correlation between pathogenic bacteria and vi-
rus reduction and indicator organisms reduction, the PEC
accepts an average log (base 10) density (no./g. TSS) of
fecal coliforms and fecal streptococci of less than 6.0 in
the treated sludge as indicating adequate viral and bacte-
rial pathogen reduction. (The average log density is the
log of the geometric mean of the samples taken. Calcula-
tions of average log density should be based on data from
approximately nine sludge samples to account for the natu-
ral variability and the variability of the microbiological tests.)
The data submitted must be scientifically sound in order
to ensure that the process can reliably produce the re-
quired reductions under all the different types of condi-
tions that the process may operate. For example, for pro-
cesses that may be affected by daily and seasonal varia-
tions in the weather, four or more sets of samples taken at
different times of the year and during different precipita-
tion conditions (including worst-case conditions) will be
needed to make this demonstration.
For national equivalency recommendations, the demon-
stration must show that the process can reliably produce
the desired reductions under the variety of climatic and
other conditions that may be encountered at different lo-
cations in the United States.
11.4 Guidance on Demonstrating
Equivalency for PEC
Recommendations
Many of the applicants seeking equivalency do not re-
ceive a recommendation from the PEC. The most com-
mon reason for this is incomplete applications or insuffi-
cient microbiological data. The review process can be both
lengthy and expensive, but it can be expedited and simpli-
fied if the applicant is aware of the type of data that will be
required for the review and submits a complete plan for
demonstrating equivalency in a timely fashion.
As described below, equivalency can be demonstrated
in one of two ways:
. By comparing operating conditions to existing PFRPs
or PSRPs.
. By providing performance and microbiological data.
Comparison to Operating Conditions for
Existing PSRPs or PFRPs
If a process is similar to a PSRP or PFRP described in
the Part 503 regulation (see Tables 4-2 and 5-1), it may be
possible to demonstrate equivalency by providing perfor-
mance data showing that the process consistently meets
or exceeds the conditions specified in the regulation. For
example, a process that consistently produces a pH of 12
after 2 hours of contact (the PSRP condition required in
Part 503 for lime stabilization) but uses a substance other
than lime to raise pH could possibly qualify as a PSRP
equivalent. In such cases, microbiological data may not
be necessary to demonstrate equivalency.
Process-Specific Performance Data and
Microbiologic Data
In all other cases, both performance data and microbio-
logical data (listed below) are needed to demonstrate pro-
cess equivalency:
. A description of the various parameters (e.g., sewage
sludge characteristics, process operating parameters,
climatic factors) that influence the microbiological char-
97
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acteristics of the treated sewage sludge (see Section
11.5 for more detail on relevant parameters).
. Sampling and analytical data to demonstrate that the
process has reduced microbes to the required levels
(see Section 11.3 for a description of levels).
. A discussion of the ability of the treatment process to
consistently operate within the parameters necessary
to achieve the appropriate reductions.
Sampling and Analytical Methods
Sewage sludge should be sampled using accepted,
state-of-the-art techniques for sampling and analyzed us-
ing the methods required by Part 503 (see Chapter 9).
The sampling program should demonstrate the quality of
the sewage sludge that will be produced under a range of
conditions. Therefore, sampling events should include a
sufficient number of samples to adequately represent prod-
uct quality, and sampling events should be designed to
reflect how the operation might be affected by changes in
conditions including climatic and sewage sludge quality
variability.
Data Quality
The quality of the data provided is an important factor in
EPA's equivalency recommendation. The following steps
can help ensure data quality:
. Use of accepted, state-of-the-art sampling techniques
(see Chapter 9)
. Obtaining samples that are representative of the ex-
pected variation in sewage sludge quality.
. Developing and following quality assurance procedures
for sampling.
. Using an independent, experienced laboratory to per-
form the analysis.
Since processes differ widely in their nature, effects, and
processing sequences, the experimental plan to demon-
strate that the process meets the requirements for PSRP
or PFRP equivalency should be tailored to the process.
The permitting authority will evaluate the study design, the
accuracy of the data, and the adequacy of the results for
supporting the conclusions of the study.
Can Pilot-Scale Data Be Submitted?
Operation of the process at a full scale facility is desir-
able. However, if a pilot-scale operation truly simulates full-
scale operation, testing on this reduced scale is possible.
The permitting authority and the PEC should be contacted
to discuss this possibility before testing is initiated. In such
cases, it is important to indicate that the data were ob-
tained from a pilot-scale operation, and to discuss why and
to what extent this simulates full-scale operation. Any data
available from existing full-scale operations would be use-
ful.
The conditions of the pilot-scale operation should be at
least as severe as those of a full-scale operation. The ar-
rangement of process steps, degree of mixing, nature of
the flow, vessel sizing, proportion of chemicals used, etc.
are all part of the requirement. Any substantial degree of
departure in the process parameters of the full-scale op-
eration that might reduce the severity of the procedure will
invalidate any PEC equivalency recommendations and
permitting authority equivalency determinations and will
require a retest under the new condition.
11.5 Guidance on Application for
Equivalency Recommendations
The following outline and instructions are provided as
guidance for preparing applications for equivalency rec-
ommendations by EPA's Pathogen Equivalency Commit-
tee.
Summary Fact Sheet
The application should include a brief fact sheet that
summarizes key information about the process. Any im-
portant additional facts should also be included.
Introduction
The full name of the treatment works and the treatment
process should be provided. The application should indi-
cate whether it is for recommendation of:
. PSRP or PFRP equivalency.
. Site-specific or national equivalency.
Process Description
The type of sewage sludge used in the process should
be described, as well as other materials used in the pro-
cess. Specifications for these materials should be provided
as appropriate. Any terms used should be defined.
The process should be broken down into key steps and
graphically displayed in a quantified flow diagram of the
wastewater and sewage sludge treatment processes. De-
tails of the wastewater treatment process should be pro-
vided and the application should precisely define which
steps constitute the beginning and end of sewage sludge
treatment.*' The earliest point at which sewage sludge
treatment can be defined as beginning is the point at which
the sewage sludge is collected from the wastewater treat-
ment process. Sufficient information should be provided
for a mass balance calculation (i.e., actual or relative volu-
metric flows and solids concentration in and out of all
streams, additive rates for bulking agents or other addi-
tives). A description of process parameters should be pro-
vided for each step of the process, giving typical ranges
and mean values where appropriate. The specific process
parameters that should be discussed will depend on the
type of process and should include any of the following
that affect pathogen reduction or process reliability:
Sewage Sludge Characteristics
. Total and volatile solids content of sewage sludge be-
fore and after treatment
98
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. Proportion and type of additives (diluents) in sewage
sludge
. Chemical characteristics (as they affect pathogen sur-
vival/destruction, e.g., pH)
. Type(s) of sewage sludge (unstabilized vs. stabilized,
primary vs. secondary, etc.)
. Wastewater treatment process performance data (as
they affect sewage sludge type, sewage sludge age,
etc.)
. Quantity of treated sewage sludge
. Sewage sludge age
. Sewage sludge detention time
Process Characteristics
. Scale of the system (e.g., reactor size, flow rate)
. Sewage sludge feed process (e.g., batch vs. continu-
ous)
. Organic loading rate (e.g., kg volatile solids/cubic
meter/day)
. Operating temperature(s) (including maximum, mini-
mum, and mean temperatures)
. Operating pressure(s) if greater than ambient
• Type of chemical additives and their loading rate
• Mixing
. Aerobic vs. anaerobic
. Duration/frequency of aeration
. Dissolved oxygen level maintained
. Residence/detention time
. Depth of sewage sludge
. Mixing procedures
. Duration and type of storage (e.g., aerated vs.
nonaerated)
Climate
. Ambient seasonal temperature range
. Precipitation
. Humidity
The application should include a description of how the
process parameters are monitored including information
on monitoring equipment. Process uniformity and reliabil-
ity should also be addressed. Actual monitoring data should
be provided whenever appropriate.
Description of Treated Sewage Sludge
The type of treated sewage sludge (biosolids) should be
described, as well as the sewage sludge monitoring pro-
gram for pathogens (if there is one). How and when are
samples taken? For what parameters are the samples
analyzed? What protocols are used for analysis? What are
the results? How long has this program been in opera-
tion?
Sampling Technique(s)
The PEC will evaluate the representativeness of the
samples and the adequacy of the sampling techniques.
For a recommendation of national PFRP equivalency,
samples of untreated and treated sewage sludge are usu-
ally needed (see Sections 11.3, 4.6, and 10.4). The sam-
pling points should correspond to the beginning and end
of the treatment process as defined previously under Pro-
cess Description above. Chapters 9 and 10 provide guid-
ance on sampling. Samples should be representative of
the sewage sludge in terms of location of collection within
the sewage sludge pile or batch. The samples taken should
include samples from treatment under the least favorable
operating conditions that are likely to occur (e.g., winter-
time). Information should be provided on:
. Where the samples were collected from within the sew-
age sludge mass. (If samples were taken from a pile,
include a schematic of the pile and indicate where the
subsamples were taken.)
. Date and time the samples were collected. Discuss
how this timing relates to important process param-
eters (e.g., turning over, beginning of drying).
. Sampling method used.
. How any composite samples were compiled.
. Total solids of each sample.
. Ambient temperature at time of sampling.
. Temperature of sample at time of sampling.
• Sample handling, preservation, packaging, and trans-
portation procedures.
. The amount of time that elapsed between sampling
and analysis.
Analytical Methods
Identify the analytical techniques used and the
laboratory(s) performing the analysis.
Analytical Results
The analytical results should be summarized, preferably
in tabular form. A discussion of the results and a summary
of major conclusions should be provided. Where appropri-
ate, the results should be graphically displayed. Copies of
original data should be provided in an appendix.
99
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Quality Assurance
The application should describe how the quality of the
analytical data has been ensured. Subjects appropriate to
address are: why the samples are representative; the qual-
ity assurance program; the qualifications of the in-house
or contract laboratory used; and the rationale for selecting
the sampling technique.
Rationale for Why Process Should Be
Determined Equivalent
Finally, the application should describe why, in the
applicant's opinion, the process qualifies for PSRP or PFRP
equivalency. For example, it may be appropriate to de-
scribe or review particular aspects of the process that con-
tribute to pathogen reduction, and why the process is ex-
pected to operate consistently. Complete references should
be provided for any data cited. Applications for a recom-
mendation of national equivalency should discuss why the
process effectiveness is expected to be independent of
the location of operation.
Appendices
A copy of the complete laboratory report(s) for any sam-
pling and analytical data should be attached as an appen-
dix. Any important supporting literature references should
also be included as appendices.
11.6 Pathogen Equivalency Committee
Recommendations
Tables 11 .1 and 11.2 list processes that the PEC has
recommended for use nationally as equivalent to PSRP or
PFRP respectively. Space in the tables limits the detail
given for each of the processes. As such individuals hav-
ing an interest in any of the processes are encouraged to
contact either the PEC or the applicant for greater detail
on how the process must be operated to be PSRP or PFRP
respectively.
Table 11-1. Processes Recommended as Equivalent to PSRP
Applicant Process Process Description
N-Viro Engery
Systems Ltd.,
Toledo, Ohio
Synox Corp.,
Jacksonville, FL
Alkaline Addition
to achieve Lime
Stabilization
OxyOzonation
Use of cement kiln dust and
lime kiln dust (instead of lime)
to treat sludge by raising the
pH. Sufficient lime or kiln dust
is added to sludge to produce
apHof 12foratleast 12
hours of contact
Batch process where sludge
is acidified to pH 3.0 by
sulfuric acid; exposed to 1 Ib.
Ozone/i 000 gallons of treated
sludgte under 60 psig
pressure for 60 minutes;
depressurized; mixed with
100 mg/l of sodium nitrite and
held for > 2 hours; and stored
at < pH 3.5. Limitations
imposed were for total solids
to be < 4%; temperature must
be > 20°C; and total solids
must be < 6.2% before nitrite
addition.
11.7 Current Issues
The PEC is continuing to develop methodologies and
protocols for the monitoring of pathogen and vector attrac-
tion reduction. Current issues include:
. Establishment of a vector attraction reduction equiva-
lency process
. Conducting round robin laboratory testing for patho-
gens in sewage sludge and biosolids
In addition, the PEC continues to recommend interpre-
tations of the Part 503 with regard to the sampling and
monitoring requirements set forth in this document.
100
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Table 11-2. Processes Recommended as Equivalent to PFRP
Applicant Process
Process Description
CBI Walker, Inc.,
Aurora, Illinois
ATP™ Two Stage Sludge
Stabilization Process
Fuchs Gas und
Wassertechnik, Gmbh,
Mayen, Germany
Autothermal Thermophilic
Aerobic Digestion
International Process
Systems, Inc.,
Glastonbury,
Connecticut
K-F Environmental
Technologies, Inc.,
Pompton Plains, NJ
Type of Composting
Process
Sludge Drying
Sludge is introduced intermittently into a vessel, amounting to 5 to 20% of
its volume, where it is heated by both external heat exchange and by the
bio-oxidation which results from vigorously mixing air with the sludge
(pasteurized) and has a nominal residence time of 18 to 24 hours. Time
between feedings of unprocessed sludge can range from 1.2 (@ - 65°C) to
4.5 (@ > 60°C) hours. Exiting sludge is heat exchanged with incoming
unprocessed sludge. Thus the sludge is cooled before it enters a
mesophilic digester. Time and temperature in the first vessel are
critical and controlled by the equation below for sludges of < 7%
solids, times > 30 minutes, and temperatures > 50°C. Operations
of the reaction vessel during the time-temperature period must be
either plug flow or batch mode.
D = 50,070,000 no0-14001 where D «time required in days; t =
temperature in °C
ATAD is a two-stage, autothermal aerobic digestion process. The stages
are of equal volume. Treated sludge amounting to 1/3 the volume of a
stage is removed every 24 hours from the second stage as product. An
equal amount then is taken from the firststage and fed to the second stage.
Similary, an equal amount of untreated sludge is then fed to the first stage.
In the 24 hour period between feedings, the sludge in both stages is
vigorously agitated and contacted with air. Bio-oxidation takes place and
the heat produced increases the temperature. Sludge temperature in
the reactors averages between 56 and 57°C for > a 16 hour period, while
the overall hydraulic residence time is 6 days.
40 CFR 503.32(a)(7) states that when the within-vessel composting
method is employed, the sludge is to be maintained at operating condition
of 55C or greater for 3 days, for the product to be PFRP. IPS Process'
operation is to further be controlled so that the composting mass passes
through a zone in the reactor in which the temperature of the compost is at
least 55°C throughout the entire zone, and the time of contact in this zone is
at least three days.
Sludge is heated to a minimum temperature of 100°C and indirectly dried
to below 10% moisture using oil as a heat transfer medium. The final
discharge product has exceeded a temperature of 80°C and is granular dry
pellet that can be land applied, incinerated or landfilled. In addition the
following conditions must be met: Dewatered sludge cake is dried by direct
or indirect contact with hot gases, and moisture content is reduced to 10%
or lower. Sludge particles reach temperatures well in excessof 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 of80"C.
Lyonnaise des Eaux,
Le Pecz-Sur-Seine, -France
Two-Phase Thermo-Meso
Feed Sequencing Anaerobic
Digestion*
ATW, Inc.
Santa Barbara,
CA
Alkaline Stabilization
Sewage sludge is treated in the absence of air in an acidogenic thermophilic
reactor and a mesophilic methanogenic reactor connected in series. The
mean cell residence time shall be at least 2.1 days (± 0.05 d) in the
acidogenic thermophilic reactor followed by 10.5 days (± 0.3 d) in the
mesophilic methanogenic reactor. Feeding of each digester shall be
intermittent and occurring 4 time per day every 6 hours. The mesophilic
methanogenic reactor shall be fed in priority from the acidogenic
thermophilic reactor. Between two consecutive feedings temperature inside
the acidogenic thermophilic reactor should be between 49°C and 55°C with
55°C maintained during at least 3 hours. Temperature inside the mesophilic
methanogenic reactor shall be constant and at least 37°C.
Manchak process uses quicklime to simultaneously stabilize and pasteurize
biosolids. Quicklime, or a combination of quicklime and flyash, is mixed with
dewatered biosolids at a predetermined rate in a confined space. An instant
exothermic reaction is created in the product wherein the pH is raised in
excess of 12 after two hours of contact, in addition, the temperature is
raised in excess of 70°C for > 30 minutes.
(continued)
101
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Table 11-2. Continued.
Applicant
Process
Process Description
N-Viro Energy Systems, Ltd.,
Toledo, OH
Advanced Alkaline stabilization
with subsequent accelerated
drying
Synox Corp.,
Jacksonville, FL
OxyOzonation
Ultraclear,
Marlboro, NJ
Microbiological Conditioning
and Drying Process (MVCD)
Alternative 1: Fine alkaline materials (cement kiln dust, lime kiln dust,
quicklime fines, pulcerized lime, or hydrated lime) are uniformly mixed by
mechanical or aeration mixing into liquid or dewatered sludge to raise the
pH to >12 for 7 days. If the resulting sludge is liquid, it is dewatered. The
stabilized sludge cake is then air dried (while pH remains >12 for > 7 days)
for > 30 days and until the cake is > 65% solids. A solids concentration of >
60% is achieved before the pH drops below 12. The mean temperature of
the air surrounding the pile is > 5°C (41 °F) for the first 7 days.
Alternative 2: Fine alkaline materials (cement kiln dust, lime kiln dust,
quicklime fines, pulverized lime, or hydrated lime) are uniformly mixed by
mechanical or aeration! mixing into liquid or dewater sludge to raise the pH
to > 12 for > 72 hours. If the resulting sludge is liquid, it is dewatered. The
sludge cake is then heated, while the pH > 12, using exothermic reactionis
or other thermal processes to achieve temperatures of > 52°C (126°F)
throughout the sludge for > 12 hours. The stabilized sludge is then air dried
(while pH > 12 for > 3 days) to > 50% solids.
Operation occurs in a batch mode and under the following conditions:
sludge temperature of > 20°C; sludge solids of c 6% TSS; pH during
ozonation of 2.5 - 3.1 and during nitrite contact of 2.6 - 3.5; sludge ORP
after ozonation of > 100 mV; nitrite dose of > 670 mg (NO2)/1 sludge or 16
g (NO2)/kg sludge solids, whichever is greater is to be mixed into the
ozonated sludge. Ozonation takes place in a pressure vessel operating at
60 psig.
In this process, sludge cake passes through several aerobic-biological type
stages (Composting is an example) where different temperatures are
maintained for varying times. Stage 1 occurs at 35°C for 7-9 hours; stage 2
occurs at 35-45°C for 8-10 hours; stage 3 occurs at 45-65°C for 7-I 0 hours;
and the last stage is pasteurization at 70-80°C for 7-10 hours. In addition
one of two conditions described below must be met:
Condition 1: Dewatered sludge cake is dried by direct or indirect contact
with hot gases, and moisture content is reduced to 10% or lower. Sludge
particles reach temperatures we//in excess of80°C, or the wef 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. OR
Condition 2: A) Using the within-vessel, static aerated pile, or windrow
composting methods, the sludge is maintained at minimum operating
conditions of40°C for 5 days. For 4 hours during the period the temperature
exceeds 55°C; {Note: another PSRP-type process should be substituted for
that of composting); and B) Sludge is maintained for at least 30 minutes at a
minimum temperature of 70°C.
'Currently a site specific recommendation. Undergoing further study for national equivalency
References and Additional Resources
Farrah, S.R., G. Bitton and S.G. Zan. 1986. Inactiva-
tion of enteric pathogens during aerobic digestion
of wastewater sludge. EPA Pub. No. EPA/600/2-86/
047. Water Engineering Research Laboratory, Cin-
cinnati, OH. NTIS Publication No. PB86-183084/A5.
National Technical Information Service. Springfield.
Virginia.
Farrell, J.B., G. Stern, and A.D. Venosa. 1985. Micro-
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Series IV. Water Pollution Control Federation. Alex-
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Smith, James E. Jr. and J.B. Farrell. 1996. Current and future
disinfection - Federal perspectives. Presented at Water
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Whittington, W.A., and E. Johnson. 1985. Application of 40 CFR
Part 257 regulations to pathogen reduction preceding land
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Memorandum to EPA Water Division Directors. U.S. EPA
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102
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Chapter 12
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APHA.1992. Standard methods for the examination of wa-
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ASTM. 1992a. Annual book of ASTM standards. Philadel-
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Berg G. and D. Berman.1980. Destruction by anaerobic
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Bonner, A.B. and D.O. Cliver. 1987. Disinfection of viruses in
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Counts, C.A. and A.J. Shuckrow. 1975. Lime stabilized
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Davies, 01. and P.L. Goldsmith. 1972. Statistical methods
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Engineering News Record, August 13,1987. No AIDS Threat
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Epstein, E.. 1997.The science of composting. Technomic
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Farrell, J.B., J.E. Smith, Jr., S.W. Hathaway, and R.B. Dean.
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Farrell, J.B., B.V. Salotto, and A.D. Venosa. 1990. Reduc-
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Farrell, J.B. 1993. Fecal pathogen control during composting.
pp. 282-300 In: H.A. J. Hoitink and H.M. Keener (eds).
Science & Engineering of Composting: Design, Envi-
ronmental, Microbiological, and Utilization Aspects. Re-
naissance, Pub., Worthington, OH.
Farrell, J. B, V. Bhide, and J. E. Smith Jr. 1996. Develop-
ment of EPA's new methods to quantify vector attraction
of wastewater sludges. Water Environ. Res. 68 (3): 286-
294.
Farzadegan, H. 1991. Proceedings of a Symposium: Sur-
vival of HIV in Environmental Waters. Baltimore, MD.
National Science Foundation and the Johns Hopkins
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106
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Appendix A
EPA Regional and State Sludge Coordinators, Map of EPA Regions, and
Listing of EPA Pathogen Equivalency Committee Members
Regional Sludge Coordinators
Thelma Murphy
U.S. EPA Region I
JFK Federal Building - CMU
Boston, MA 02203
(617) 918-1 615 (phone)
(617) 918-1 505 (fax)
MURPHY.THELMA@EPAMAIL.EPA.GOV
Alia Roufaeal
U.S. EPA Region II
Div. of Enforcement and Compliance Assist.
290 Broadway - 20th Floor
New York, New York 10007-1 866
(212) 637-3864
(212) 637-3953
ROUFAEAL.ALIA@EPAMAIL.EPA.GOV
Ann Carkhuff
U.S. EPA Region III
Water Protection Div.
841 Chestnut Street
Philadelphia, PA 19107
(215) 566 5735 (phone)
(215) 566 2301 (fax)
CARKHUFF.ANN@EPAMAIL.EPA.GOV
Madolyn Dominy
U.S. EPA Region IV
100 Alabama Street
Atlanta, GA 30303
(404) 562-9305 (phone)
(404) 562-8692 (fax)
MILLER.VINCE@EPAMAILEPA.GOV
John Colletti
U.S. EPA Region V (WN-16J)
Water Division
77 West Jackson Blvd.
Chicago, IL 60604-3590
(312) 886-6106 (phone)
(312) 886-7804 (fax)
COLLETTI.JOHN@EPAMAIL.EPA.GOV
Stephanie Kordzi (6WQ-PO)
U.S. EPA Region VI
Water Quality Management Division
1445 Ross Avenue #1200
Dallas, TX 75202-2733
(214) 665-7520 (phone)
(214) 665-2191 (phone)
KORDZI.STEPHANIE@EPA.GOV
John Dunn
U.S. EPA Region VII
Waste Management Division
726 Minnesota Ave.
Kansas City, KS 66101
(913) 551-7594 (phone)
(913) 551-7765 (fax)
DUNN.JOHN@EPAMAIL.EPA.GOV
Bob Brobst
Biosolids Program manager (P2-W-P)
U.S. EPA Region VIII
999 18th Street, Suite 500
Denver, CO 80202-2466
(303) 312-6129 (phone)
(303) 312-7084 (fax)
BROBST.BOB@EPA.GOV
Lauren Fondahl
U.S. EPA Region IX (WTR-7)
Biosolids Coordinator
Office of Clean Water Act Compliance
75 Hawthorne Street
San Francisco, CA 94105-3901
(415) 744-I 909 (phone)
(415) 744-1 235 (fax)
FONDAHL.LAUREN@EPAMAIL.EPA.GOV
Dick Hetherington
U.S. EPA Region X
NPDES Permits Unit (OW-130)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-I 941 (phone)
(206) 553-I 280 (fax)
HETHERINGTON.DICK@EPAMAILEPA.GOV
107
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Region I
State Sludge Coordinators
Region 2
Connecticut
Bob Norwood/Warren Herzig
CT DEP
Water Compliance Unit
79 Elm Street
Hartford, CT 06106-1 632
(860) 424-3748 (phone)
(860) 424-4067 (fax)
ROBERT.NORWOOD@PO.STATE.CT.US
Maine
David Wright
Maine DEP
Sludge Residuals Unit
State House, Station 17
Augusta, ME 04333
(207) 287-2651 (phone)
(207) 287-7826 (fax)
DAVID.W.WRIGHT@STATE.ME.US
Massachusetts
Larry Polese
MA DEP
50 Route 20
Millbury, MA 01527
(508) 752-8648 (phone)
(508) 755-9253 (fax)
LARRY.POLESE@STATE.MA.US
New Hampshire
Michael Rainey
Sludge & Septage Management
NH DES
6 Hazen Drive
Concord, NH 03301
(603) 271-2818 (phone)
(603) 271-7894 (fax)
M_RA!NEY@DES.STATE.NH.US
Rhode island
Warren Towne, P.E.
Supervising Sanitary Engineer
Rl DEM, Office of Water Resources
235 Promenade St.
Providence, Rl 02908
(401) 222-6820 (phone)
(401) 222-6177 (fax)
Vermont
Cathy Jamieson
VT Dept. of Environmental Conservation
103 S. Main St., Sewing Bldg.
Waterbury, VT 05676
(802) 241-3831 (phone)
(802) 241-2596 (fax)
CATHYJ@DEC.ANR.STATE.VT.US
New Jersey
Mary Jo M. Aiello, Chief
Bureau of Pretreatment and Residuals
Watershed Permitting Element, DWQ
NJ DEP
P.O. Box 029
Trenton, NJ 08625-0029
(609) 633-3823 (phone)
(609) 984-7938 (fax)
MAIELLO@DEP.STATE.NJ.US
New York
Sally J. Rowland, Ph.D., PE
NY Dept. of Environmental Conservation
Division of Solid and Hazardous Materials
50 Wolf Road, Room 212
Albany, New York 12233-7253
(518) 457-3966 (phone)
(518) 457-I 283 (fax)
SJROWLAN@GW.DEC.STATE.NY.US
Puerto Rico
Robert Allada
Water Quality Area
Environmental Quality Board
PO Box 11488
Santurce, Puerto Rico 00916
(787) 767-8073 (phone)
Virgin Islands
Leonard G. Reed, Jr.
Environmental Protection Division
Deparmtnet of Planning & Natural Resources
396-I Foster Plaza
St. Thomas, VI 00802
(340) 777-4577 (phone)
Region 3
Delaware
Steve Rohm
DE DNREC
P.O. Box 1401
89 Kings Highway
Dover, DE 19903
(302) 739-5731 (phone)
(302) 739-3491 (fax)
SROHM@DNREC.STATE.DE.US
District of Columbia
Jeruselem Bekele
Water Quality Control Branch
Department of Health
2100 MLK Jr. Avenue SE #203
Washington, D.C. 20020
(202) 645-6617
108
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Maryland
Region 4
Hussain Alhija, Chief
Design & Certification Division
Maryland Department of the Environment
2500 Broening Highway
Baltimore, MA 21224
(410) 631-3375
(410) 631-3842
Martha Hynson
MD Dept. of the Environment
2500 Broening Hwy
Baltimore, MD 21224
(410) 631-3375 (phone)
(410) 631-3321 (fax)
Pennsylvania
Cuong Vu
Bureau of Water Quality Protection
P.O. Box 8774
RCSUB 11th Floor
Harrisburg, PA 17105-8774
(717) 787 7381 (phone)
(717) 772-5156 (fax)
VU.CUONG@A1 .DEP.STATE.PA.US
Virginia
Cal M. (C.M.) Sawyer
VA Dept. of Health
Division of Wastewater Engineering
Box 2448
Richmond, Virginia 23218
(804) 786-I 755 (phone)
(804) 371-2891 (fax)
CSAWYER@VDH.STATE.VA.US
Lily Choi
VA DEQ
P.O. Box 11143
Richmond, VA 23230-I 143
(804) 698-4054 (phone)
(804) 698-4032 (fax)
YCHOI@DEQ.STATE.VA.US
West Vifginia
Clifford Browning
WVDEP
Office of Water Resources
1201 Greenbrier Street
Charleston, WV 25311
(304) 558-4086 (phone)
(304) 558-5903 (fax)
Alabama
L. Cliff Evans
Municipal Branch, Water Division
AL Dept. of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1 463
(334) 271-7816 (phone)
(334) 279-3051 (fax)
LCE@ADEM.STATE.ALUS
Florida
Maurice Barker
Domestic Wastewater, Section MS #3540
Florida Department of Environmental Protection
Twin Towers Office Bldg, 2600 Blair Stone Road
Tallahassee, Florida 32399-2400
(850) 922-4295 (phone)
(850) 921-6385 (fax)
BARKER-M@DEP.STATE.FLUS
Georgia
Sam Shepard/Nancy Prock
Municipal Permitting Program - Environmental Protection
Division
GA DNR
4244 International Pkwy, Suite 110
Atlanta, GA 30354
(404) 656-4708 (phone)
(404) 362-2680 (phone)
(404) 362-2691 (fax)
NANCY-PROCK@MAIL.DNR.STATE.GA.US
Kentucky
Mark Crim/Bob Bickner
Solid Waste Branch, Division of Waste Management
KY Department of Natural Resources and Environmental
Protection
Frankfort Office Park
14 Reilly Road
Frankfort, KY 40601
(502) 564-6716 (phone)
(502) 564-4049 (fax)
CRIM@NRDEP.NR.STATE.KY.US
BICKNER@NRDEP.NR.STATE.KY.US
Art Curtis
Facilities Construction Branch, Division of Water
Kentucky Department of Natural Resources and Environ-
mental Protection Cabinet
Frankfort Office Park, 14 Reilly Road
Frankfort, KY 40601
(502) 564-4310 (phone)
(502) 564-4245 (fax)
CURTIS@NRDEP.NR.STATE.KY.US
109
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Mississippi
Glenn Odom, P.E.
MS DEQ
Office of Pollution Control
P.O. Box 10385
Jackson, MS 39289-0385
(601) 961-5159 (phone)
(601) 961-5376 (fax)
GLENN-ODEM@DEQ.STATE.MS.US
North Carolina
Dennis Ramsey
Division of Water Quality
NC Department of Environment and Natural Resources
P.O. Box 29535
512 N. Salisbury Street
Raleigh, NC 27626-0535
(919) 733-5083 ext. 528 (phone)
(919) 733-0719 (fax)
DENNIS_RAMSEY@H2O.ENR.STATE.NC.US
Kim H. Colson
Division of Water Quality
NC Department of Environment and Natural Resources
P.O. Box 29535
512 N. Salisbury Street
Raleigh, NC 27626-0535
(919) 733-5083 (phone)
(919) 733-0719 (fax)
KIM_COLSON@H2O.ENR.STATE.NC.US
Kevin H. Barnett
Division of Water Quality
Non-Discharge Compliance/Enforcement Unit
1617 Mail Service Center
Raleigh, NC 27699-I 617
(919) 733-5083 ext. 529 (phone)
KEVIN.BARNETT@NCMAIL.NET
South Carolina
Michael Montebello
Domestic Wastewater Division
SC Dept. of Health & Environment
2600 Bull Street
Columbia, SC 29201
(803) 734-5226 (phone)
(803) 734-5216 (fax)
MONTEBMJ@COLUMB32.DHEC.STATE.SC.US
Tennessee
John McClurkan/Roger Lemaster
Div. of Water Pollution Control
TN DEC
401 Church Street, Sixth Floor Annex
Nashville, TN 37243-I 534
(615) 532-0625 (phone)
(615) 532-0603 (fax)
JMCCLURKAN@MAIL.STATE.TN.US
Region 5
Illinois
S. Alan Keller
ILEPA
DWPC, Permits Section
P.O. Box 19276
1021 N. Grand Avenue, East
Springfield, IL 62794-9276
(217) 782-0610 (phone)
(217) 782-9891 (fax)
EPA1185@EPA.STATE.ILUS
Indiana
Dennis Lasiter, Chief
Land Use Section
IN DEM
P.O. Box 6015
100 N. Senate Avenue
Indianapolis, IN 46206-6015
(317) 232-8732 (phone)
(317) 232-3403 (fax)
DLAS!TER@DEM.STATE.IN.US
Michigan
Bob Babcock
Chief, Pretreatment and Biosolids Unit
Ml DEQ
Surface WQ Div, Permits Section
Knapp's Off ice Center, Second Floor
300 S. Washington Square
P.O. Box 30273
Lansing, Ml 48909-7773
(517) 373 8566 (phone)
(517) 373 2040 (fax)
BABCOCKR@STATE.MI.US
Grace Scott
(517) 335-4107 (phone)
SCOTTG@STATE.MI.US
Minnesota
Jorja DuFresne
WQ Div., Point Source Section
MN Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-4194
(612) 296-9292 (phone)
(612) 297-8683 (fax)
JORJA.DUFRESNE@PCA.STATE.MN.US
Ohio
Brad Gallant
Division of Surface Water
Ohio EPA
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43216-0149
(614) 644-2001 (ohone)
(614) 644-2329 (fax)
BRAD@GALLANT@EPA.STATE.OHIO.US
110
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Annette De Havilland
Division of Solid & Infectious Waste Mgmt.
Ohio EPA
P.O. Box 1049
Columbus, Ohio 43216-1 049
(614) 644-2621 (phone)
(614) 728-5315 (fax)
ANNETTE.DEHAVILLAND@EPA.STATE.OH.US
Wisconsin
Greg Kester (WTO)
Wl DNR
Bureau of Watershed Mgmt., Point Source Section
101 South Webster Street
Madison, Wl 53707
(608) 267 7611 (phone)
(608) 267 7664 (fax)
KESTEG@DNR.STATE.WI.US
Region 6
Arkansas
Keith Brown, P.E.
Manager, State Permits Branch
Water Division
AR Department of Pollution Control and Ecology
P.O. Box 8913
Little Rock, AR 72219
(501) 682-0648 (phone)
(501) 682-0910 (fax)
BROWNK@ADEQ.STATE.AR.US
Jamal Solaimanian, Ph.D
AR Department of Pollution Control and Ecology
P.O. Box 8913
Little Rock, AR 72219-8913
(501) 682-0648 (phone)
(501) 682-0910 (fax)
JAMAL@ADEQ.STATE.AR.US
Louisiana
J. Kilren Vidrine
Water Pollution Control Division
Louisiana Department of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-2215
(504) 765-0534 (phone)
(504) 765-0635 (fax)
KILRENV@DEQ.STATE.I_A.US
Hoa Van Nguyen
Solid Waste Division
Louisiana Department of Environmental Quality
P.O. Box 82178
Baton Rouge, LA 70884-2178
(504) 765-0249 (phone)
(504) 765-0299 (fax)
HOAVAN_N@DEQ.STATE.LA.US
Yolunda Righteous
Solid Waste Division
LADEQ
P.O. Box 82178
Baton Rouge, LA 70884-2178
(504) 765-0249 (phone)
YOLUNDAR@DEQ.STATE.LA.US
New Mexico
Jim Davis
NMED Surface Water Qualitv Bureau
NM Environment Department
P.O. Box26110
Santa Fe, NM 87502
Oklahoma
Danny Hodges
Water Quality Division
OK Dept. of Environmental Quality
1000 NE Tenth Street
Oklahoma City, OK 73117-1 299
(405) 271-5205 (phone)
(405) 271-7339 (fax)
DANNY.HODGES@DEQMAIL.OK.STATE.US
Texas
Paul Curtis
TX Natural Resource Conservation Commission
P.O. Box 13087
Austin, TX 7871 I-3087
(512) 239-4580 (phone)
(512) 239-4750 (fax)
PCURTIS@TNRCD.STATE.TX.
Region 7
Iowa
Billy Chen
IA Dept. of Water, Air &Waste Mgmt.
Henry A. Wallace Building
900 East Grand
Des Moines, IA 50319
(515) 281-4305 (phone)
(515) 281-8895 (fax)
Kansas
Mark Gerard
Kansas Dept. of Health & Environment
Forbes Field Building 283
Topeka, KS 66620-0001
(785) 296-5520 (phone)
(785) 296-5509 (fax)
Missouri
Ken Arnold
MO DNR
P.O. Box 176
205 Jefferson Street
Jefferson City, MO 65102
(573) 751-6825 (phone)
(573) 526-5797 (fax)
111
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Nebraska
Rudy Fiedler
Permits and Compliance
NE DEQ
Suite 400 The Atrium
1200 N. Street, P.O. Box 98922
Lincoln, NE 68509-8922
(402) 471-4239
(402) 471-2909
DEQ118@MAILDEQ.STATE.NE.US
Region 8
Colorado
Lori Tucker
Water Quality Control Division
CO Dept. of Public Health & Environment
4300 Cherry Creek Drive South
Denver, CO 80246-I 530
(303) 692-3613 (phone)
(303) 782-0390 (fax)
LORI.TUCKER@STATE.CO.US
Montana
Paul LeVigne
MT Dept of Environmental Quality
Technical & Financial Assistance Bureau
Metcalf Building
Helena, MT 59620
(406) 444-6697 (phone)
(406) 444 6836 (fax)
PLAVIGNE@MT.GOV
North Dakota
Gary Bracht
Environmental Health Section
Division of Water Quality
ND Dept. of Health
1200 Missouri Ave.
P.O. Box 5520
Bismark, ND 58505-5520
(701) 221-5210 (phone)
(701) 328-5200 (fax)
CCMAIL.GBRACHT@RANCH.STATE.ND.US
South Dakota
Eric Meintsma
SD Dept. of Environment and Natural Resources
Joe Foss Building
523 East Capital
Pierre, SD 57501-3181
(605) 773-3351 (phone)
(605) 773 5286 (fax)
ERICM@DENR.STATE.SD.US
Utah
MarkSchmitz
UTDEQ
Division of Water Quality
28814 1460 Street West
Salt Lake City, UT 84114-4870
(801) 538-6097 (phone)
(801) 538-6016 (fax)
MSCHMITZ@DEQ.STATE.UT.US
Wyoming
Larry Robinson
WYDEQ
Herschler Bldg., 4th Floor West
122 W. 25th Street
Cheyenne, WY 82002
1307) 777-7075 (phone)
(307) 777-5973 (fax)
LROBIN@MISSC.STATE.WY.US
Region 9
Arizona
Nicole Heffington
AZDEQ
3033 N. Central
Phoenix, AZ 85012
(602) 207-4158 (phone)
(602) 207-2383 (fax)
HEFFINGTON.NICOLE@EV.STATE.AZ.US
Jill Galaway
AZDEQ
3033 N. Central
Phoenix, AZ 85012
(602) 207-4125 (phone)
(602) 207-2383 (fax)
GALAWAY.JILL@EV.STATE.AZ.US
California
Todd Thompson, P.E.
Division of Water Quality
State Water Resources Control Board
PO Box 944213
Sacramento, CA 94244-2130
(916) 657-0577 (phone)
(916) 657-2388 (fax)
THOMT@DWQ.SWRCB.CA.GOV
Michael Wochnick
CA Integrated Waste Mgmt. Board
Remediation, Closure, and Technical Services Branch
8800 Cal Centre Drive
Sacramento, CA 95826
(916) 255-I 302 (phone)
MWOCHNIC@CIWMB.CA.GOV
Bill Orr
CA Integrated Waste Mgmt. Board
8800 Cal Centre Drive
Sacramento, CA 95826
BORR@MRT.CIWMB.CA.GOV
Hawaii
Dennis Tulang/Gayle Takasaki, Engineer
Wastewater Branch
HI Dept. of Health
P.O. Box 3378
Honolulu, HI 96813
(808) 586-4294 (phone)
(808) 586-4370 (fax)
GTAKASAKI@EHA.HEALTH.STATE.HI.US
112
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Nevada
Bill Coughlin
NVDEP
333 West Nye Lane
Carson City, NV 89706-0866
(702) 687-4670 ext. 3153 (phone)
(702) 6875856 (fax)
Region 10
Alaska
Kris McCum by
Solid Waste Program
AK Dept. of Environmental Conservation
610 University Avenue
Fairbanks, AK 99709-3643
(907) 451-2134 (phone)
(907) 451-2187 (fax)
KMCCUMBY@ENVIRCON.STATE.AK.US
Idaho
Rick Huddleston
DEQ Construction & Permits Bureau
IDDHW
1410 North Hilton
Boise, ID 83706-1253
(208) 373-0501 or (208) 373-0502 (phone)
(208) 373-0576 (fax)
RHUDDLES@DEQ..STATE.ID.US
Oregon
Douglas Peters, Biosolids Coordinator
OR DEQ
Water Quality Policy and Program Development Section
811 SW 6th Avenue
Portland, OR 97204
(503) 229-6442 (phone)
(503) 229-5408 (fax)
PETERS.DOUGLAS@DEQ.STATE.OR.US
Washington
Kyle Dorsey
Biosolids Coordinator
Washington State Department of Ecology
PO Box 47600
Olympia, WA 98504-7600
(360) 407-6107 (phone)
(360) 407-7157 or -6102 (fax)
KDOR461 @ECY.WA.GOV
113
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USEPA Pathogen Equivalency Committee Membership -1999
Robert Bastian (4204)
Senior Scientist - Biologist
USEPA-OWM
401 M Street, SW
Washington, DC 20460
202-260-7378
Robert B. Brobst, PE
Environmental Engineer
Biosolids Program Manager
USEPA-Region 8 (P2-W-P)
999 18th Street, Suite 500
Denver, CO 80202-2466
303-312-6129
Dr. John Cicmanec (MS-G75)
Veterinarian
USEPA-NRMRL-TTSD
26 W Martin Luther King Drive
Cincinati, OH 45268
513-569-7481
Dr. G. Shay Fout (MS-320)
Senior Research Virologist
USEPA-NERL
26 W Martin Luther King Drive
Cincinati, OH 45268
513-569-7387
Dr. Hugh McKinnon (MS-235)
Medical Officer / Doctor
Associate Laboratory Director for Health
USEPA-NRMRL
26 W Martin Luther King Drive
Cincinati, OH 45268
513-569-7689
Mark Meckes (MS-489)
Research Microbiologist
USEPA-NRMRL-WS&WRD
26 W Martin Luther King Drive
Cincinati, OH 45268
513-569-7348
Dr. Frank W. Schaefer, III
Senior Research Parasitologist
USEPA-NERL (MS-320)
26 W Martin Luther King Drive
Cincinati, OH 45268
513-569-7222
Dr. Stephen A. Schaub (4304)
Virologist
USEPA-OST-HECD-HRAB
401 M Street, SW
Washington, DC 20460
202-260-7591
Dr. Jim Smith (MS-G77)
Senior Environmental Engineer & PEC Chair
USEPA-NRMRL-TTSD (CERI)
26 W Martin Luther King Drive
Cincinnati, OH 45268
513-569-7355
114
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Appendix B
Subpart D of the Part 503 Regulation
[Code of Federal Regulations]
[Title 40, Volume 21, Parts 425 to 699]
[Revised as of July 1,1998]
From the U.S. Government Printing Office via GPO Access
[CITE: 40CFR503.30]
TITLE 40—PROTECTION OF
ENVIRONMENT
CHAPTER (-ENVIRONMENTAL
PROTECTION AGENCY (Continued)
PART 503—STANDARDS FOR THE USE OR
DISPOSAL OF SEWAGE SLUDGE-Table of
Contents
Subpart D-Pathogens and Vector
Attraction Reduction
Sec. 503.30 Scope.
(a) This subpart contains the requirements for a sewage
sludge to be classified either Class A or Class B with re-
spect to pathogens.
(b) This subpart contains the site restrictions for land on
which a Class B sewage sludge is applied.
(c) This subpart contains the pathogen requirements for
domestic septage applied to agricultural land, forest, or a
reclamation site.
(d) This subpart contains alternative vector attraction
reduction requirements for sewage sludge that is applied
to the land or placed on a surface disposal site.
Sec. 503.31 Special definitions.
(a) Aerobic digestion is the biochemical decomposition
of organic matter in sewage sludge into carbon dioxide
and water by microorganisms in the presence of air.
(b) Anaerobic digestion is the biochemical decomposi-
tion of organic matter in sewage sludge into methane gas
and carbon dioxide by microorganisms in the absence of
air.
(c) Density of microorganisms is the number of microor-
ganisms per unit mass of total solids (dry weight) in the
sewage sludge.
(d) Land with a high potential for public exposure is land
that the public uses frequently. This includes, but is not
limited to, a public contact site and a reclamation site lo-
cated in a populated area (e.g, a construction site located
in a city).
(e) Land with a low potential for public exposure is land
that the public uses infrequently. This includes, but is not
limited to, agricultural land, forest, and a reclamation site
located in an unpopulated area (e.g., a strip mine located
in a rural area).
(f) Pathogenic organisms are disease-causing organ-
isms. These include, but are not limited to, certain bacte-
ria, protozoa, viruses, and viable helminth ova.
(g) pH means the logarithm of the reciprocal of the hy-
drogen ion concentration.
(h) Specific oxygen uptake rate (SOUR) is the mass of
oxygen consumed per unit time per unit mass of total sol-
ids (dry weight basis) in the sewage sludge.
(i) Total solids are the materials in sewage sludge that
remain as residue when the sewage sludge is dried at 103
to 105 degrees Celsius.
(j) Unstabilized solids are organic materials in sewage
sludge that have not been treated in either an aerobic or
anaerobic treatment process.
(k) Vector attraction is the characteristic of sewage sludge
that attracts rodents, flies, mosquitos, or other organisms
capable of transporting infectious agents.
(I) Volatile solids is the amount of the total solids in sew-
age sludge lost when the sewage sludge is combusted at
550 degrees Celsius in the presence of excess air.
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Sec. 503.32 Pathogens.
(a) Sewage sludge-Class A. (1) The requirement in Sec.
503.32(a)(2) and the requirements in either Sec.
503.32(a)(3), (a)(4), (a)(5), (a)(6), (a)(7), or (a)(8) shall be
met for a sewage sludge to be classified Class A with re-
spect to pathogens.
(2) The Class A pathogen requirements in Sec. 503.32
(a)(3) through (a)(8) shall be met either prior to meeting or
at the same time the vector attraction reduction require-
ments in Sec. 503.33, except the vector attraction reduc-
tion requirements in Sec. 503.33 (b)(6) through (b)(8), are
met.
(3) Class A-Alternative 1. (i) Either the density of fecal
coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight ba-
sis), or the density of Salmonella sp. bacteria in the sew-
age sludge shall be less than three Most Probable Num-
ber per four grams of total solids (dry weight basis) at the
time the sewage sludge is used or disposed; at the time
the sewage sludge is prepared for sale or give away in a
bag or other container for application to the land; or at the
time the sewage sludge or material derived from sewage
sludge is prepared to meet the requirements in Sec. 503.10
(b), (c), (e), or (f).
(ii) The temperature of the sewage sludge that is used
or disposed shall be maintained at a specific value for a
period of time.
(A) When the percent solids of the sewage sludge is
seven percent or higher, the temperature of the sewage
sludge shall be 50 degrees Celsius or higher; the time
period shall be 20 minutes or longer; and the temperature
and time period shall be determined using equation (2),
except when small particles of sewage sludge are heated
by either warmed gases or an immiscible liquid.
sludge is 50 degrees Celsius or higher; and the time pe-
riod is 30 minutes or longer, the temperature and time pe-
riod shall be determined using equation (3).
D =
131,700,000
10'
0.14001
Eq.(2)
Where,
D=time in days.
t=temperature in degrees Celsius.
(B) When the percent solids of the sewage sludge is
seven percent or higher and small particles of sewage
sludge are heated by either warmed gases or an immis-
cible liquid, the temperature of the sewage sludge shall be
50 degrees Celsius or higher; the time period shall be 15
seconds or longer; and the temperature and time period
shall be determined using equation (2).
(C) When the percent solids of the sewage sludge is
less than seven percent and the time period is at least 15
seconds, but less than 30 minutes, the temperature and
time period shall be determined using equation (2).
(D) When the percent solids of the sewage sludge is
less than seven percent; the temperature of the sewage
50,070,000
10'
0.14001
Eq.(3)
Where,
D=time in days.
t=temperature in degrees Celsius.
(4) Class A-Alternative 2. (i) Either the density of fecal
coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight ba-
sis), or the density of Salmonella sp. bacteria in the sew-
age sludge shall be less than three Most Probable Num-
ber per four grams of total solids (dry weight basis) at the
time the sewage sludge is used or disposed; at the time
the sewage sludge is prepared for sale or give away in a
bag or other container for application to the land; or at the
time the sewage sludge or material derived from sewage
sludge is prepared to meet the requirements in Sec. 503.10
(b), (c), (e), or (f).
(ii)(A) The pH of the sewage sludge that is used or dis-
posed shall be raised to above 12 and shall remain above
12 for 72 hours.
(B) The temperature of the sewage sludge shall be above
52 degrees Celsius for 12 hours or longer during the pe-
riod that the pH of the sewage sludge is above 12.
(C)At the end of the 72 hour period during which the pH
of the sewage sludge is above 12, the sewage sludge shall
be air dried to achieve a percent solids in the sewage sludge
greater than 50 percent.
(5) Class A-Alternative 3. (i) Either the density of fecal
coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight ba-
sis), or the density of Salmonella sp. bacteria in sewage
sludge shall be less than three Most Probable Number per
four grams of total solids (dry weight basis) at the time the
sewage sludge is used or disposed; at the time the sew-
age sludge is prepared for sale or give away in a bag or
other container for application to the land; or at the time
the sewage sludge or material derived from sewage sludge
is prepared to meet the requirements in Sec. 503.10 (b),
(c), (e), or (f).
(ii)(A) The sewage sludge shall be analyzed prior to
pathogen treatment to determine whether the sewage
sludge contains enteric viruses.
(B) When the density of enteric viruses in the sewage
sludge prior to pathogen treatment is less than one Plaque-
forming Unit per four grams of total solids (dry weight ba-
sis), the sewage sludge is Class A with respect to enteric
viruses until the next monitoring episode for the sewage
sludge.
(C) When the density of enteric viruses in the sewage
sludge prior to pathogen treatment is equal to or greater
116
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than one Plaque-forming Unit per four grams of total sol-
ids (dry weight basis), the sewage sludge is Class A with
respect to enteric viruses when the density of enteric vi-
ruses in the sewage sludge after pathogen treatment is
less than one Plaque-forming Unit per four grams of total
solids (dry weight basis) and when the values or ranges of
values for the operating parameters for the pathogen treat-
ment process that produces the sewage sludge that meets
the enteric virus density requirement are documented.
(D) After the enteric virus reduction in paragraph
(a)(5)(ii)(C) of this section is demonstrated for the patho-
gen treatment process, the sewage sludge continues to
be Class A with respect to enteric viruses when the values
for the pathogen treatment process operating parameters
are consistent with the values or ranges of values docu-
mented in paragraph (a)(5)(ii)(C) of this section.
(iii)(A) The sewage sludge shall be analyzed prior to
pathogen treatment to determine whether the sewage
sludge contains viable helminth ova.
(B) When the density of viable helminth ova in the sew-
age sludge prior to pathogen treatment is less than one
per four grams of total solids (dry weight basis), the sew-
age sludge is Class A with respect to viable helminth ova
until the next monitoring episode for the sewage sludge.
(C) When the density of viable helminth ova in the sew-
age sludge prior to pathogen treatment is equal to or greater
than one per four grams of total solids (dry weight basis),
the sewage sludge is Class A with respect to viable helm-
inth ova when the density of viable helminth ova in the
sewage sludge after pathogen treatment is less than one
per four grams of total solids (dry weight basis) and when
the values or ranges of values for the operating param-
eters for the pathogen treatment process that produces
the sewage sludge that meets the viable helminth ova den-
sity requirement are documented.
(D) After the viable helminth ova reduction in paragraph
(a)(5)(iii)(C) of this section is demonstrated for the patho-
gen treatment process, the sewage sludge continues to
be Class A with respect to viable helminth ova when the
values for the pathogen treatment process operating pa-
rameters are consistent with the values or ranges of val-
ues documented in paragraph (a)(5)(iii)(C) of this section.
(6) Class A-Alternative 4. (i) Either the density of fecal
coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight ba-
sis), or the density of Salmonella sp. bacteria in the sew-
age sludge shall be less than three Most Probable Num-
ber per four grams of total solids (dry weight basis) at the
time the sewage sludge is used or disposed; at the time
the sewage sludge isprepared for sale or give away in a
bag or other container for application to the land; or at the
time the sewage sludge or material derived from sewage
sludge is prepared to meet the requirements in Sec. 503.10
(b), (c), (e), or (f).
(ii) The density of enteric viruses in the sewage sludge
shall be less than one Plaque-forming Unit per four grams
of total solids (dry weight basis) at the time the sewage
sludge is used or disposed; at the time the sewage sludge
is prepared for sale or give away in a bag or other con-
tainer for application to the land; or at the time the sewage
sludge or material derived from sewage sludge is prepared
to meet the requirements in Sec. 503.10 (b), (c), (e), or (f),
unless otherwise specified by the permitting authority.
(iii) The density of viable helminth ova in the sewage
sludge shall be less than one per four grams of total solids
(dry weight basis) at the time the sewage sludge is used
or disposed; at the time the sewage sludge is prepared for
sale or give away in a bag or other container for applica-
tion to the land; or at the time the sewage sludge or mate-
rial derived from sewage sludge is prepared to meet the
requirements in Sec. 503.10 (b), (c), (e), or (f), unless oth-
erwise specified by the permitting authority.
(7) Class A-Alternative 5. (i) Either the density of fecal
coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight ba-
sis), or the density of Salmonella, sp. bacteria in the sew-
age sludge shall be less than three Most Probable Num-
ber per four grams of total solids (dry weight basis) at the
time the sewage sludge is used or disposed; at the time
the sewage sludge is prepared for sale or given away in a
bag or other container for application to the land; or at the
time the sewage sludge or material derived from sewage
sludge is prepared to meet the requirements in Sec.
503.10(b), (c), (e), or®.
(ii) Sewage sludge that is used or disposed shall be
treated in one of the Processes to Further Reduce Patho-
gens described in appendix B of this part.
(8) Class A-Alternative 6. (i) Either the density of fecal
coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight ba-
sis), or the density of Salmonella, sp. bacteria in the sew-
age sludge shall be less than three Most Probable Num-
ber per four grams of total solids (dry weight basis) at the
time the sewage sludge is used or disposed; at the time
the sewage sludge is prepared for sale or given away in a
bag or other container for application to the land; or at the
time the sewage sludge or material derived from sewage
sludge is prepared to meet the requirements in Sec.
503.10(b), (c), (e), or (f).
(ii) Sewage sludge that is used or disposed shall be
treated in a process that is equivalent to a Process to Fur-
ther Reduce Pathogens, as determined by the permitting
authority.
(b) Sewage sludge-Class B. (l)(i) The requirements in
either Sec. 503.32(b)(2), (b)(3), or (b)(4) shall be met for a
sewage sludge to be classified Class B with respect to
pathogens.
(ii) The site restrictions in Sec. 503.32(b)(5) shall be met
when sewage sludge that meets the Class B pathogen
requirements in Sec. 503.32(b)(2), (b)(3), or (b)(4) is ap-
plied to the land.
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(2) Class B-Alternative 1. (i) Seven samples of the sew-
age sludge shall be collected at the time the sewage sludge
is used or disposed.
(ii) The geometric mean of the density of fecal coliform
in the samples collected in paragraph (b)(2)(i) of this sec-
tion shall be less than either 2,000,000 Most Probable
Number per gram of total solids (dry weight basis) or
2,000,000 Colony Forming Units per gram of total solids
(dry weight basis).
(3) Class B-Alternative 2. Sewage sludge that is used
or disposed shall be treated in one of the Processes to
Significantly Reduce Pathogens described in appendix B
of this part.
(4) Class B-Alternative 3. Sewage sludge that is used
or disposed shall be treated in a process that is equivalent
to a Process to Significantly Reduce Pathogens, as deter-
mined by the permitting authority.
(5) Site restrictions, (i) Food crops with harvested parts
that touch the sewage sludge/soil mixture and are totally
above the land surface shall not be harvested for 14 months
after application of sewage sludge.
(ii) Food crops with harvested parts below the surface of
the land shall not be harvested for 20 months after appli-
cation of sewage sludge when the sewage sludge remains
on the land surface for four months or longer prior to incor-
poration into the soil.
(iii) Food crops with harvested parts below the surface
of the land shall not be harvested for 38 months after ap-
plication of sewage sludge when the sewage sludge re-
mains on the land surface for less than four months prior
to incorporation into the soil.
(iv) Food crops, feed crops, and fiber crops shall not be
harvested for 30 days after application of sewage sludge.
(v) Animals shall not be allowed to graze on the land for
30 days after application of sewage sludge.
(vi) Turf grown on land where sewage sludge is applied
shall not be harvested for one year after application of the
sewage sludge when the harvested turf is placed on either
land with a high potential for public exposure or a lawn,
unless otherwise specified by the permitting authority.
(vii) Public access to land with a high potential for public
exposure shall be restricted for one year after application
of sewage sludge.
(viii) Public access to land with a low potential for public
exposure shall be restricted for 30 days after application
of sewage sludge.
(c) Domestic septage. (1) The site restrictions in Sec.
503.32(b)(5) shall be met when domestic septage is ap-
plied to agricultural land, forest, or a reclamation site; or
(2) The pH of domestic septage applied to agricultural land,
forest, or a reclamation site shall be raised to 12 or higher
by alkali addition and, without the addition of more alkali,
shall remain at 12 or higher for 30 minutes and the site
restrictions in Sec. 503.32 (b)(5)(i) through (b)(5)(iv) shall
be met.
Sec. 503.33 Vector attraction reduction.
(a)(l) One of the vector attraction reduction requirements
in Sec. 503.33 (b)(l) through (b)(IO) shall be met when
bulk sewage sludge is applied to agricultural land, forest,
a public contact site, or a reclamation site.
(2) One of the vector attraction reduction requirements
in Sec. 503.33 (b)(l) through (b)(8) shall be met when bulk
sewage sludge is applied to a lawn or a home garden.
(3) One of the vector attraction reduction requirements
in Sec. 503.33 (b)(l) through (b)(8) shall be met when sew-
age sludge is sold or given away in a bag or other con-
tainer for application to the land.
(4) One of the vector attraction reduction requirements
in Sec. 503.33 (b)(l) through (b)(ll) shall be met when
sewage sludge (other than domestic septage) is placed
on an active sewage sludge unit.
(5) One of the vector attraction reduction requirements
in Sec. 503.33 (b)(9), (b)(IO), or (b)(12) shall be met when
domestic septage is applied to agricultural land, forest, or
a reclamation site and one of the vector attraction reduc-
tion requirements in Sec. 503.33 (b)(9) through (b)(12) shall
be met when domestic septage is placed on an active sew-
age sludge unit.
(b)(l) The mass of volatile solids in the sewage sludge
shall be reduced by a minimum of 38 percent (see calcu-
lation procedures in "Environmental Regulations and Tech-
nology-Control of Pathogens and Vector Attraction in
Sewage Sludge", EPA-625/R-92/01 3,1992, U.S. Environ-
mental Protection Agency, Cincinnati, Ohio 45268).
(2) When the 38 percent volatile solids reduction require-
ment in Sec. 503.33(b)(l) cannot be met for an anaerobi-
cally digested sewage sludge, vector attraction reduction
can be demonstrated by digesting a portion of the previ-
ously digested sewage sludge anaerobically in the labora-
tory in a bench-scale unit for 40 additional days at a tem-
perature between 30 and 37 degrees Celsius. When at
the end of the 40 days, the volatile solids in the sewage
sludge at the beginning of that period is reduced by less
than 17 percent, vector attraction reduction is achieved.
(3) When the 38 percent volatile solids reduction require-
ment in Sec. 503.33(b)(l) cannot be met for an aerobi-
cally digested sewage sludge, vector attraction reduction
can be demonstrated by digesting a portion of the previ-
ously digested sewage sludge that has a percent solids of
two percent or less aerobically in the laboratory in a bench-
scale unit for 30 additional days at 20 degrees Celsius.
When at the end of the 30 days, the volatile solids in the
sewage sludge at the beginning of that period is reduced
118
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by less than 15 percent, vector attraction reduction is
achieved.
(4) The specific oxygen uptake rate (SOUR) for sewage
sludge treated in an aerobic process shall be equal to or
less than 1.5 milligrams of oxygen per hour per gram of
total solids (dry weight basis) at a temperature of 20 de-
grees Celsius.
(5) Sewage sludge shall be treated in an aerobic pro-
cess for 14 days or longer. During that time, the tempera-
ture of the sewage sludge shall be higher than 40 degrees
Celsius and the average temperature of the sewage sludge
shall be higher than 45 degrees Celsius.
(6) The pH of sewage sludge shall be raised to 12 or
higher by alkali addition and, without the addition of more
alkali, shall remain at 12 or higher for two hours and then
at 11.5 or higher for an additional 22 hours.
(7) The percent solids of sewage sludge that does not
contain unstabilized solids generated in a primary waste-
water treatment process shall be equal to or greater than
75 percent based on the moisture content and total solids
prior to mixing with other materials.
(8) The percent solids of sewage sludge that contains
unstabilized solids generated in a primary wastewater treat-
ment process shall be equal to or greater than 90 percent
based on the moisture content and total solids prior to mix-
ing with other materials.
(9)(i) Sewage sludge shall be injected below the surface
of the land.
(ii) No significant amount of the sewage sludge shall be
present on the land surface within one hour after the sew-
age sludge is injected.
(iii) When the sewage sludge that is injected below the
surface of the land is Class A with respect to pathogens,
the sewage sludge shall be injected below the land sur-
face within eight hours after being discharged from the
pathogen treatment process.
(10)(i) Sewage sludge applied to the land surface or
placed on a surface disposal site shall be incorporated into
the soil within six hours after application to or placement
on the land.
(ii) When sewage sludge that is incorporated into the
soil is Class A with respect to pathogens, the sewage sludge
shall be applied to or placed on the land within eight hours
after being discharged from the pathogen treatment pro-
cess.
(11) Sewage sludge placed on an active sewage sludge
unit shall be covered with soil or other material at the end
of each operating day.
(12) The pH of domestic septage shall be raised to 12 or
higher by alkali addition and, without the addition of more
alkali, shall remain at 12 or higher for 30 minutes.
119
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Appendix C
Determination of Volatile Solids Reduction by Digestion
Introduction
Under 40 CFR Part 503, the ability of sewage sludge to
attract vectors must be reduced when sewage sludge is
applied to the land or placed on a surface disposal site.
One way to reduce vector attraction is to reduce the vola-
tile solids in the sewage sludge by 38% or more (see Sec-
tion 8.2 of this document). Typically, volatile solids reduc-
tion is accomplished by anaerobic or aerobic digestion.
Volatile solids reduction also occurs under other circum-
stances, such as when sewage sludge is stored in an
anaerobic lagoon or is dried on sand beds. To give credit
for this extra loss in volatile solids, the regulation allows
the untreated sewage sludge to be compared with the
treated sewage sludge that leaves the treatment works,
which should account for all of the volatile solids reduction
that could possibly occur. For most processing sequences,
the processing steps downstream from the digester, such
as short-term storage or dewatering, have no influence on
volatile solids content. Consequently, the appropriate com-
parison is between the sewage sludge entering the digester
and the sewage sludge leaving the digester. The remain-
der of the discussion is limited to this circumstance, ex-
cept for the final section of this appendix, which compares
incoming sewage sludge with the sewage sludge leaving
the treatment works.
The Part 503 regulation does not specify a method for
calculating volatile solids reduction. Fischer (1984) ob-
served that the United Kingdom has a similar requirement
for volatile solids reduction for digestion (40%), but also
failed to prescribe a method for calculating volatile solids
reduction. Fischer has provided a comprehensive discus-
sion of the ways that volatile solids reduction may be cal-
culated and their limitations. He presents the following
equations for determining volatile solids reduction:
. Full mass balance equation
. Approximate mass balance equation
. "Constant ash" equation
. Van Kleeck equation
The full mass balance equation is the least restricted
approach but requires more information than is currently
collected at a wastewater treatment plant. The approxi-
mate mass balance equation assumes steady state con-
ditions. The "constant ash" equation requires the assump-
tion of steady state conditions as well as the assumption
that the ash input rate equals the ash output rate. The Van
Kleeck equation, which is the equation generally suggested
in publications originating in the United States (WPCF,
1968), is equivalent to the constant ash equation. Fischer
calculates volatile solids reduction using a number of ex-
amples of considerable complexity and illustrates that dif-
ferent methods frequently yield different results.
Fischer's paper is extremely thorough and is highly rec-
ommended for someone trying to develop a deep under-
standing of potential complexities in calculating volatile
solids reduction. However, it was not written as a guid-
ance document for field staff faced with the need to calcu-
late volatile solids reduction. The nomenclature is precise
but so detailed that it makes comprehension difficult. In
addition, two important troublesome situations that com-
plicate the calculation of volatile solids reduction - grit depo-
sition in digesters and decantate removal - are not explic-
itly discussed. Consequently, this presentation has been
prepared to present guidance that describes the major pit-
falls likely to be encountered in calculating percent volatile
solids reduction.
It is important to note that the calculation of volatile sol-
ids reduction is only as accurate as the measurement of
volatile solids content in the sewage sludge. The principal
cause of error is poor sampling. Samples should be repre-
sentative, covering the entire charging and withdrawal
periods. Averages should cover extended periods of time
during which changes in process conditions are minimal.
For some treatment, it is expected that periodic checks of
volatile solids reduction will produce results so erratic that
no confidence can be placed in them. In this case, ad-
equacy of stabilization can be verified by the method de-
scribed under Options 2 and 3 in Chapter 8 -periodically
batch digest anaerobically digested sewage sludge for 40
additional days at 30EC (86EF) to 37EC (99EF), or aero-
bically digested sewage sludge for 30 additional days at
20EC (68EF). If the additional VS reduction is less than
17% for the anaerobically digested sewage sludge or less
than 15% for the aerobically digested sewage sludge, the
sewage sludge is sufficiently stable (see Sections 8.3 and
8.4).
120
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Equations for FVSR
The equations for fractional volatile solids reduction
(FVSR) that will be discussed below are the same as those
developed by Fischer (1984), except for omission of his
constant ash equation. This equation gives identical re-
sults to the Van Kleeck equation so it is not shown. Fischer's
nomenclature has been avoided or replaced with simpler
terms. The material balance approaches are called meth-
ods rather than equations. The material balances are drawn
to fit the circumstances. There is no need to formalize the
method with a rigid set of equations.
In the derivations and calculations that follow, both VS
(total volatile solids content of the sewage sludge or
decantate on a dry solids basis) and FVSR are expressed
throughout as fractions to avoid the frequent confusion that
occurs when these terms are expressed as percentages.
"Decantate" is used in place of the more commonly used
"supernatant" to avoid the use of "s" in subscripts. Simi-
larly, "bottoms" is used in place of "sludge" to avoid use of
"s" in subscripts.
Method Full Mass Balance
The full mass balance method must be used when steady
conditions do not prevail over the time period chosen for
the calculation. The chosen time period must be substan-
tial, at least twice the nominal residence time in the di-
gester (nominal residence time equals average volume of
sludge in the digester divided by the average volumetric
flow rate. Note: when there is decantate withdrawal, vol-
ume of sewage sludge withdrawn should be used to cal-
culate the average volumetric flow rate). The reason for
the long time period is to reduce the influence of short-
term fluctuations in sewage sludge flow rates or composi-
tions. If input compositions have been relatively constant
for a long period of time, then the time period can be short-
ened.
An example where the full mass balance method would
be needed is where an aerobic digester is operated as
follows:
. Started with the digester 1/4 full (time zero)
. Raw sewage sludge is fed to the digester daily until
the digester is full
. Supernatant is periodically decanted and raw sewage
sludge is charged into the digester until settling will
not occur to accommodate daily feeding (hopefully after
enough days have passed for adequate digestion)
. Draw down the digester to about 1/4 full (final time),
discharging the sewage sludge to sand beds
The full mass balance is written as follows:
Sum of total volatile solids inputs in feed streams during
the entire digestion period = sum of volatile solids outputs
in withdrawals of decantate and bottoms + loss of volatile
solids + accumulation of volatile solids in the digester. (1)
Loss of volatile solids is calculated from Equation 1.
FVSR is calculated by Equation 2:
FVSR = loss in volatile solids
sum of volatile solids inputs
(2)
The accumulation of volatile solids in the digester is the
final volume in the digester after the drawdown times final
volatile solids concentration less the initial volume at time
zero times the initial volatile solids concentration.
To properly determine FVSR by the full mass balance
method requires determination of all feed and withdrawal
volumes, initial and final volumes in the digester, and vola-
tile solids concentrations in all streams. In some cases,
which will be presented later, simplifications are possible.
Approximate Mass Balance Method
If volumetric inputs and outputs are relatively constant
on a daily basis, and there is no substantial accumulation
of volatile solids in the digester over the time period of the
test, an approximate mass balance (AMB) may be used.
The basic relationship is stated simply:
volatile solids input rate = volatile solids output rate + rate
of loss of volatile solids. (3)
The FVSR is given by Equation 2.
No Decantate, No Grit Accumulation (Problem 1)
Calculation of FVSR is illustrated for Problem 1 in Table
C-l, which represents a simple situation with no decantate
removal and no grit accumulation. An approximate mass
balance is applied to the digester operated under constant
flow conditions. Because no decantate is removed, the
volumetric flow rate of sewage sludge leaving the digester
equals the flow rate of sewage sludge entering the digester.
Applying Equations 3 and 2,
FY, = BY, + loss
Loss = 1 00(5030) = 2000
FVSR = Loss
py,
FVSR = 2000 = 0.40
(100) (50)
(4)
(5)
(6)
(7)
Nomenclature is given in Table C-l. Note that the calcu-
lation did not require use of the fixed solids concentra-
tions.
The calculation is so simple that one wonders why it is
so seldom used. One possible reason is that the input and
output volatile solids concentrations (Y, and. Y ) .typically
will show greater coefficients of variation (standard devia-
tion divided by arithmetic average) than the fractional vola-
tile solids (VS is the fraction of the sewage sludge solids
121
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Table Cl. Quantitative Information for Example Problems1'2'3
Problem Statement Number
Parameter
Nominal Residence Time
Time period for averages
Feed Sludge
Volumetric flow rate
Volatile solids concentration
Fixed solids concentration
Fractional volatile solids
Mass flow rate of solids
Digested Sludge (Bottoms)
Volumetric flow rate
Volatile solids concentration
Fixed solids concentration
Fractional volatile solids
Mass flow rate of solids
Decantate
Volumetric flow rate
Volatile solids concentration
Fixed solids concentration
Fractional volatile solids
Mass flow rate of solids
Symbol
e
—
F
Y,
x,
vs,
MI
B
\
x*
A,
MO
D
Y,
Xi
A
Ma
Units
d
d
m3/d
kg/m3
kg/m3
kg/kg
kg/d
m3/d
kg/m3
kg/m3
kg/kg
kg/d
m3/d
kg/m3
kg/m3
kg/kg
kg/d
1
20
60
100
50
17
0.746
6700
100
30
17
0.638
4700
0
—
—
—
—
2
20
60
100
50
17
0.746
6700
100
41.42
15
0.667
4500
0
—
—
—
—
3
20
60
100
50
17
0.746
6700
41.42
23.50
0.638
12.76
7.24
0.638
4
20
60
100
50
17
0.746
6700
49.57
41.42
23.50
0.638
50.43
12.76
7.24
0.638
Conditions are steady state; all daily flows are constant. Volatile solids are not accumulating in the digester, although grit may be settling out in the
digester.
'Numerical values are given at 3 or 4 significant figures. This is unrealistic considering the expected accuracy in measuring solids concentrations
nd sludge volumes. The purpose of extra significant figures is to allow more understandable comparisons to be made of the different calculation
methods.
3AII volatile solids concentrations are based on total solids, not merely on suspended solids.
that is volatile-note the difference between VS and Y). If
this is the case, the volatile solids reduction calculated by
the approximate mass balance method from several sets
of Yr-Y data will show larger deviations than if it were cal-
culated by the Van Kleeck equation using VS,-VSb data.
Grit deposition can be a serious problem in both aerobic
and anaerobic digestion. The biological processes that
occur in digestion dissolve or destroy the substances sus-
pending the grit, and it tends to settle. If agitation is inad-
equate to keep the grit particles in suspension, they will
accumulate in the digester. The approximate mass bal-
ance can be used to estimate accumulation of fixed sol-
ids.
For Problem 1, the balance yields the following:
Fx, = BX, + fixed solids loss (8)
(100)(17) = (100)(17)+ Fixed Solids Loss
Fixed Solids Loss = 0
(9)
(10)
The material balance compares fixed solids in output
with input. If some fixed solids are missing, this loss term
will be a positive number. Because digestion does not con-
sume fixed solids, it is assumed that the fixed solids are
accumulating in the digester. As Equation 10 shows, the
fixed solids loss equals zero. Note that for this case, where
input and output sewage sludge flow rates are equal, the
fixed solids concentrations are equal when there is no grit
accumulation.
Grit Deposition (Problem 2)
The calculation of fixed solids is repeated for Problem 2.
Conditions in Problem 2 have been selected to show grit
accumulation. Parameters are the same as in Problem 1
except for the fixed solids concentration (X,) and param-
eters related to it. Fixed solids concentration in the sew-
age sludge is lower than in Problem 1. Consequently, VS
is higher and the mass flow rate of solids leaving is lower
than in Problem 1. A mass balance on fixed solids (input
rate = output rate + rate of loss of fixed solids) is presented
in Equations 11-13.
FX, = BX,, + Fixed Solids Loss
Fixed Solids Loss = FX,- BX,
(11)
(12)
Fixed Solids Loss = (100)(7)-(100)(15) = 200 kg/d (13)
The material balance, which only looks at inputs and
outputs, informs us that 200 kg/d of fixed solids have not
appeared in the outputs as expected. Because fixed sol-
ids are not destroyed, it can be concluded that they are
accumulating in the bottom of the digester. The calcula-
tion of FVSR for Problem 2 is exactly the same as for Prob-
lem 1 (see Equations 4 through 7) and yields the same
result. The approximate mass balance method gives the
122
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correct answer for the FVSR despite the accumulation of
solids in the digester. As will be seen later, this is not the
case when the Van Kleeck equation is used.
Decantate Withdrawal, No Grit Accumulation (Problem 3)
In Problem 3, decantate is withdrawn daily. Volatile and
fixed solids concentrations are known for all streams but
the volumetric flow rates are not known for decantate and
bottoms. It is impossible to calculate FVSR without know-
ing the relative volumes of these streams. However, they
are determined easily by taking a total volume balance
and a fixed solids balance, provided it can be assumed
that loss of fixed solids (i.e., accumulation in the digester)
is zero.
Selecting a basis for F of 100 m3/d,
Volume balance: 100 = B + D
Fixed solids balance: 100 X, + BX, + DX,
(14)
(15)
Because the three Xs are known, B and D can be found.
Substituting 100-D for B and the values for the Xs from
Problem 3 and solving for D and B,
(100)(17) = (100 - D)(23.50) + (D)(7.24)
D = 40.0m3/d, B = 60.0 m3/d
(16)
(17)
The FVSR can now be calculated by drawing a volatile
solids balance:
FY, + BY, + DY, + loss (18)
FVSR = loss = IFY - BY - Dy
FY, FY; (19)
FVSR = (1001 (501 -(60VY41.42U40V.r-L2.76V = 0 40
(100) (50) (20)
Unless information is available on actual volumes of
decantate and sewage sludge (bottoms), it is not possible
to determine whether grit is accumulating in the digester.
If it is accumulating, the calculated FVSR will be in error.
When the calculations shown in Equations 18 through
20 are made, it is assumed that the volatile solids that are
missing from the output streams are consumed by biologi-
cal reactions that convert them to carbon dioxide and meth-
ane. Accumulation is assumed to be negligible. Volatile
solids are less likely to accumulate than fixed solids, but it
can happen. In poorly mixed digesters, the scum layer that
collects at the surface is an accumulation of volatile sol-
ids. FVSR calculated by Equations 18 through 20 will be
overestimated if the volatile solids accumulation rate is
substantial.
Decantate Withdrawal and Grit Accumulation (Problem 4)
In Problem 4, there is suspected grit accumulation. The
quantity of B and D can no longer be calculated by Equa-
tions 14 and 15 because Equation 15 is no longer correct.
The values of B and D must be measured. All parameters
in Problem 4 are the same as in Problem 3 except that
measured values for B and D are introduced into Problem
4. Values of B and D calculated assuming no grit accumu-
lation (Problem 3-see previous discussion), and measured
quantities are compared below:
D
Calculated
60
40
Measured
49.57
50.43
The differences in the values of B and D are not large
but they make a substantial change in the numerical value
of FVSR. The FVSR for Problem 4 is calculated below:
FVSR = (100U5Q1 - (49.57U41.42^-J50.43U12.76)
(100)(50)
= 0.461 (21)
If it had been assumed that there was no grit accumula-
tion, FVSR would equal 0.40 (see Problem 3). It is pos-
sible to determine the amount of grit accumulation that has
caused this change. A material balance on fixed solids is
drawn:
FX, = BX,, + DX, + Fixed Solids Loss
(22)
The fractional fixed solids loss due to grit accumulation
is found by rearranging this equation:
Fixed Solids Loss = FX - BX - Dx
FX,
FX,
(23)
Substituting in the parameter values for Problem 4,
Fixed Solids I nss = nntWITl - «9.57U23.50liY50.43U7.24V
FX, (100)
= 0.100
(24)
If this fixed solids loss of 10 percent had not been ac-
counted for, the calculated FVSR would have been 13%
lower than the correct value of 0.461. Note that if grit accu-
mulation occurs and it is ignored, calculated FVSR will be
lower than the actual value.
The Van Kleeck Equation
Van Kleeck first presented his equation without deriva-
tion in a footnote for a review paper on sewage sludge
treatment processing in 1945 (Van Kleeck, 1945). The
equation is easily derived from total solids and volatile sol-
ids mass balances around the digestion system. Consider
a digester operated under steady state conditions with
decantate and bottom sewage sludge removal. A total sol-
ids mass balance and a volatile solids mass balance are:
M, = M + M + (loss of total solids)
(25)
123
-------
M, • VSf=M* VS,+Md.VSd +(loss of volatile solids) (26)
where
M,, M,, and Md are the mass of solids in the feed, bot-
toms, and decantate streams.
The masses must be mass of solids rather than total
mass of liquid and solid because VS is an unusual type of
concentration unit-it is "mass of volatile solids per unit mass
of total solids."
It is now assumed that fixed solids are not destroyed
and there is no grit deposition in the digester. The losses
in Equations 25 and 26 then comprise only volatile solids
so the losses are equal. It is also assumed that the VS of
the decantate and of the bottoms are the same. This means
that the bottoms may have a much higher solids content
than the decantate but the proportion of volatile solids to
fixed solids is the same for both streams. Assuming then
that VS, equals VS,, and making this substitution in the
defining equation for FVSR (Equation 2),
FVSR = Loss of vol. solids = KM +MJVS
M, x Vs, TvlrxVS( (27)
From Equation 25, recalling that we have assumed that
loss of total solids equals loss of volatile solids,
Mb + Md + M, - loss of vol. solids
Substituting for Mb + Md into Equation 27,
FVSR = 1 - M-loss of vol. solids^. VSb
M, .VS,
Simplifying further,
1-(1/VS,-FVSR).VS,
Solving for FVSR,
FVSR = VS - V S > BC
„-- (vs(. vsj
(28)
(29)
(30)
(31)
This is the form of the Van Kleek equation found in WPCF
Manual of Practice No. 16 (WPCF, 1968). Van Kleeck
(1945) presented the equation in the following equivalent
form:
(32)
FVSR = 1 - VS: X M -\
vs,x(1-Vs'b)
The Van Kleeck equation is applied below to Problems I
through 4 in Table C- 1 and compared to the approximate
mass balance equation results:
Approximate Mass
Balance (AMB)
Van Kleeck (VK)
1
0.40
0.40
0.40
0.318
Problem 1: No decantate and no grit accumulation. Both
methods give correct answer.
Problem 2: No decantate but grit accumulation. VK is
invalid and incorrect.
Problem 3: Decantate but no grit accumulation. AMB
method is valid. VK method is valid only if VS, equals VS,.
Problem 4: Decantate and grit accumulation. AMB
method valid only if B and D are measured. VK method is
invalid.
The Van Kleeck equation is seen to have serious short-
comings when applied to certain practical problems. The
AMB method can be completely reliable, whereas the Van
Kleeck method is useless under some circumstances.
Average Values
The concentrations and VS values used in the equa-
tions will all be averages. For the material balance meth-
ods, the averages should be weighted averages accord-
ing to the mass of solids in the stream in question. The
example below shows how to average the volatile solids
concentration for four consecutive sewage sludge addi-
tions.
Addition
2
3
Volume
12m3
13rm3
10m3
Total Solids VS
Concentration
72 kg/m3
JO 60 kg/m3
55 kg/m3
0.75
0.77
(33)
Weigh ted by Mass
12x72x0.75 + 8x50x0.82
VS av = +13x60x0.80+ 10x55x0.77
12 x 72 + 8 x 50 + 13 x 60 + 10 x 55
= 0.795
Weigh ted by Volume
VS av = 12 x 0.75 + 8 x 0.82 + 13 x 0.80 + 10 x 0.77
12 + 8 + 13 + 10
= 0.783
Arithmetic A verage
VS av = 075 + 0.82 +0.80 + 0.77 = 0.785
4
(34)
(35)
(36)
0.40
0.40
0.461
0.40
In this example the arithmetic average was nearly as
close as the volume-weighted average to the mass-
weighted average, which is the correct value.
Which Equation to Use?
Full Mass Balance Method
The full mass balance method allows calculation of vola-
tile solids reduction for all approaches to digestion, even
124
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processes in which the final volume in the digester does
not equal the initial volume and where daily flows are not
steady. A serious drawback to this method is the need for
volatile solids concentration and the volumes of all streams
added to or withdrawn from the digester, as well as initial
and final volumes and concentrations in the digester. This
can be a daunting task, particularly for the small treatment
works that is most likely to run digesters in other than steady
flow modes. For treatment works of this kind, an "equiva-
lent" method that shows that the sewage sludge has un-
dergone the proper volatile solids reduction is likely to be
a better approach than trying to demonstrate 38% volatile
solids reduction. An aerobic sewage sludge has received
treatment equivalent to a 38% volatile solids reduction if
the specific oxygen uptake rate is below a specified maxi-
mum. Anaerobically digested sewage sludge has received
treatment equivalent to a 38% volatile solids reduction if
volatile solids reduction after batch digestion of the sew-
age sludge for 40 days is less than a specified maximum
(EPA, 1992).
Approximate Mass Balance Method
The approximate mass balance method assumes that
daily flows are steady and reasonably uniform in composi-
tion, and that digester volume and composition do not vary
substantially from day to day. Results of calculations and
an appreciation of underlying assumptions show that the
method is accurate for all cases, including withdrawal of
decantate and deposition of grit, provided that in addition
to composition of all streams the quantities of decantate
and bottoms (the digested sewage sludge) are known. If
the quantities of decantate and bottoms are not known,
the accumulation of grit cannot be determined. If accumu-
lation of grit is substantial and FVSR is calculated assum-
ing it to be negligible, FVSR will be lower than the true
value. The result is conservative and could be used to show
that minimum volatile solids reductions are being achieved.
Van Kleeck Method
The Van Kleeck equation has underlying assumptions
that should be made clear wherever the equation is pre-
sented. The equation is never valid when there is grit ac-
cumulation because it assumes the fixed solids input equals
fixed solids output. Fortunately, it produces a conservative
result in this case. Unlike the AMB method it does not pro-
vide a convenient way to check for accumulation of grit. It
can be used when decantate is withdrawn, provided VS,
equals VS,. Just how significant the difference between
these VS values can be before an appreciable error in
FVSR occurs is unknown, although it could be determined
by making up a series of problems with increasing differ-
ences between the VS values, calculating FVSR using the
AMB method and a Van Kleeck equation, and comparing
the results.
The shortcomings of the Van Kleeck equation are sub-
stantial, but the equation has one strong point: The VS of
the various sewage sludge and decantate streams are likely
to show much lower coefficients of variation (standard de-
viation divided by arithmetic average) than volatile solids
and fixed solids concentration. Reviews of data are needed
to determine how seriously the variation in concentrations
affect the confidence interval of FVSR calculated by both
methods. A hybrid approach may turn out to be advanta-
geous. The AMB method could be used first to determine
if grit accumulation is occurring. If grit is not accumulating,
the Van Kleeck equation could be used. If decantate is
withdrawn, the Van Kleeck equation is appropriate, par-
ticularly if the decantate is low in total solids. If not, and if
VS, differs substantially from VS,, it could yield an incor-
rect answer.
Volatile Solids Loss Across All Sewage
Sludge Treatment Processes
For cases when appreciable volatile solids reduction can
occur downstream from the digester (for example, as would
occur in air drying or lagoon storage), it is appropriate to
calculate the volatile solids loss from the point at which
the sewage sludge enters the digester to the point at which
the sewage sludge leaves the treatment works. Under
these circumstances, it is virtually never possible to use
the approximate mass balance approach, because flow
rates are not uniform. The full mass balance could be used
in principle, but practical difficulties such as measuring the
mass of the output sewage sludge (total mass, not just
mass of solids) that relates to a given mass of entering
sewage sludge make this also a practical impossibility.
Generally then, the only option is to use the Van Kleeck
equation, because only the percent volatile solids content
of the entering and exiting sewage sludge is needed to
make this calculation. As noted earlier, this equation will
be inappropriate if there has been a selective loss of high
volatility solids (e.g., bacteria) or low volatility solids (e.g.,
grit) in any of the sludge processing steps.
To make a good comparison, there should be good cor-
respondence between the incoming sewage sludge and
the treated sewage sludge to which it is being compared
(see Section 10.4). For example, when sewage sludge is
digested for 20 days, then dried on a sand bed for 3 months,
and then removed, the treated sludge should be compared
with the sludge fed to the digester in the preceding 3 or 4
months. If no selective loss of volatile or nonvolatile solids
has occurred, the Van Kleeck equation (see Equation 31)
can be used to calculate volatile solids reduction.
References
EPA. 1992. Technical Support Document for Part 503
Pathogen and Vector Attraction Reduction Require-
ments in Sewage Sludge. Office of Water, U.S. EPA,
Washington, DC. NTIS No PB93-11069. Natl. Techni-
cal Information Service, Springfield, VA.
Fischer, W.J. 1984. Calculation of volatile solids during
sludge digestion. In: Bruce, A., ed. Sewage Sludge
Stabilization and Disinfection, pp. 499-529. Water
Research Centre, E. Norwood Ltd., Chichester, En-
gland.
125
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Van Kleeck, L.W. 1945. Sewage Works J., Operation of Water Pollution Control Federation. 1968. Manual of Prac-
Sludge Drying and Gas Utilization Units. 17(6): 1240- tice No. 16, Anaerobic Sludge Digestion. Washington,
1255. DC.
126
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Appendix D
Guidance on Three Vector Attraction Reduction Tests
This appendix provides guidance for the vector attrac-
tion reduction Options 2,3, and 4 to demonstrate reduced
vector attraction (see Chapter 8 for a description of these
requirements).
1. Additional Digestion Test for
Anaerobically Digested Sewage Sludge
Background
The additional digestion test for anaerobically digested
sewage sludge is based on research by Jeris et al. (1985).
Farrell and Bhide (1993) explain in more detail the origin
of the time and volatile solids reduction requirements of
the test.
Jeris et al. (1985) measured changes in many param-
eters including volatile solids content while carrying out
additional digestion of anaerobically digested sludge from
several treatment works for long periods. Samples were
removed from the digesters weekly for analysis. Because
substantial amount of sample was needed for all of these
tests, they used continuously mixed digesters of 18 liters
capacity. The equipment and procedures of Jeris et al.,
although not complex, appear to be more elaborate than
needed for a control test. EPAstaff (Farrell and Bhide, 1993)
have experimented with simplified tests and the procedure
recommended is based on their work.
Recommended Procedure
The essentials of the test are as follows:
. Remove, from the plant-scale digester, a representa-
tive sample of the sewage sludge to be evaluated to
determine additional volatile solids destruction. Keep
the sample protected from oxygen and maintain it at
the temperature of the digester. Commence the test
within 6 hours after taking the sample.
. Flush fifteen 100-mL volumetric flasks with nitrogen,
and add approximately 50 mL of the sludge to be tested
into each flask. Frequently mix the test sludge during
this operation to assure that its composition remains
uniform. Select five flasks at random, and determine
total solids content and volatile solids content, using
the entire 50 ml for the determination. Seal each of
the remaining flasks with a stopper with a single glass
tube through it to allow generated gases to escape.
• Connect the glass tubing from each flask through a
flexible connection to a manifold. To allow generated
gases to escape and prevent entry of air, connect the
manifold to a watersealed bubbler by means of a ver-
tical glass tube. The tube should be at least 30-cm
long with enough water in the bubbler so that an in-
crease in atmospheric pressure will not cause backflow
of air or water into the manifold. Maintain the flasks
containing the sludge at constant temperature either
by inserting them in a water bath (the sludge level in
the flasks must be below the water level in the bath) or
by placing the entire apparatus in a constant tempera-
ture room or box. The temperature of the additional
digestion test should be the average temperature of
the plant digester, which should be in the range of 30°C
to 40°C (86°F to 104°F). Temperature should be con-
trolled within + 0.15°C (0.27°F).
. Each flask should be swirled every day to assure ad-
equate mixing, using care not to displace sludge up
into the neck of the flask. Observe the water seal for
the first few days of operation. There should be evi-
dence that gas is being produced and passing through
the bubbler.
. After 20 days, withdraw five flasks at random. Deter-
mine total and volatile solids content using the entire
sample for the determination. Swirl the flask vigorously
before pouring out its contents to minimize the hold up
of thickened sludge on the walls and to assure that
any material left adhering to the flask walls will have
the same average composition as the material with-
drawn. Use a consistent procedure. If holdup on walls
appears excessive, a minimal amount of distilled wa-
ter may be used to wash solids off the walls. Total re-
moval is not necessary, but any solids left on the walls
should be approximately of the same composition as
the material removed.
. After 40 days, remove the remaining five flasks. De-
termine total and volatile solids content using the en-
tire sample from each flask for the determination. Use
the same precautions as in the preceding step to re-
move virtually all of the sludge, leaving only material
with the same approximate composition as the mate-
rial removed.
127
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Total and volatile solids content are determined using
the procedures of Method 2540 G of Standard Methods
(APHA, 1992).
Mean values and standard deviations of the total solids
content, the volatile solids content, and the percent vola-
tile solids are calculated. Volatile solids reductions that
result from the additional digestion periods of 20 and 40
days are calculated from the mean values by the Van
Kleeck equation and by a material balance (refer to Ap-
pendix C for a general description of these calculations).
The results obtained at 20 days give an early indication
that the test is proceeding satisfactorily and will help sub-
stantiate the 40-day result.
Alternative approaches are possible. The treatment
works may already have versatile bench-scale digesters
available. This equipment could be used for the test, pro-
vided accuracy and reproducibility can be demonstrated.
The approach described above was developed because
Farrell and Bhide (1993) in their preliminary work experi-
enced much difficulty in withdrawing representative
samples from large digesters even when care was taken
to stir the digesters thoroughly before sampling. If an al-
ternative experimental setup is used, it is still advisable to
carry out multiple tests for the volatile solids content in
order to reduce the standard error of this measurement,
because error in the volatile solids content measurement
is inflated by the nature of the equation used to calculate
the volatile solids reduction.
Variability in flow rates and nature of the sludge will re-
sult in variability in performance of the plant-scale digest-
ers. It is advisable to run the additional digestion test rou-
tinely so that sufficient data are available to indicate aver-
age performance. The arithmetic mean of successive tests
(a minimum of three is suggested) should show an addi-
tional volatile solids reduction of < 17%.
Calculation Details
Appendix C, Determination of Volatile Solids Reduction
by Digestion, describes calculation methods to use for di-
gesters that are continuously fed or are fed at least once a
day. Although the additional anaerobic digestion test is a
batch digestion, the material balance calculations approach
is the same. Masses of starting streams (input streams)
are set equal to masses of ending streams (output
streams).
The test requires that the fixed volatile solids reduction
(FVSR) be calculated both by the Van Kleeck equation
and the material balance method. The Van Kleeck equa-
tion calculations can be made in the manner described in
Appendix C.
The calculation of the volatile solids reduction (and the
fixed fractional solids reduction [FFSR]) by the mass bal-
ance method shown below has been refined by subtract-
ing out the mass of gas lost from the mass of sludge at the
end of the digestion step. For continuous digestion, this
loss of mass usually is ignored, because the amount is
small in relation to the total digesting mass, and mass be-
fore and after digestion are assumed to be the same. Con-
sidering the inherent difficulty in matching mass and com-
position entering to mass and composition leaving for a
continuous process, this is a reasonable procedure. For
batch digestion, the excellent correspondence between
starting material and final digested sludge provides much
greater accuracy in the mass balance calculation, so in-
clusion of this lost mass is worthwhile.
In the equations presented below, concentrations of fixed
and volatile solids are mass fractions-mass of solids per
unit mass of sludge (mass of sludge includes both the sol-
ids and the water in the sludge)- and are indicated by, the
symbols lowercase y and x. This is different from the us-
age in Appendix C where concentrations are given in mass
per unit volume, and are indicated by the symbols upper-
case y and x. This change has been made because masses
can be determined more accurately than volumes in small-
scale tests.
In the material balance calculation, it is assumed that as
the sludge digests, volatile solids and fixed solids are con-
verted to gases that escape or to volatile compounds that
distill off when the sludge is dried. Any production or con-
sumption of water by the biochemical reactions in diges-
tion is assumed to be negligible. The data collected (vola-
tile solids and fixed solids concentrations of feed and di-
gested sludge) allow mass balances to be drawn on vola-
tile solids, fixed solids, and water. As noted, it is assumed
that there is no change in water mass- all water in the feed
is present in the digested sludge. Fractional reductions in
volatile solids and fixed solids can be calculated from these
mass balances for the period of digestion. Details of the
calculation of these relationships are given by Farrell and
Bhide (1993). The final form of the equations for fractional
volatile solids reduction (mass balance [m b.] method) and
fractional fixed solids reduction (m.b. method) are given
below:
FVSR(m.b.) = Y (I XL1 - Y fl-X,l
FFSR(m.b.) = x'l-y 1 -
^
f i-vy
where:
y = mass fraction of volatile solids in the liquid sludge
x = mass fraction of fixed solids in the liquid sludge
f = indicates feed sludge at start of the test
b = indicates "bottoms" sludge at end of the test
If the fixed solids loss is zero, these two equations are
reduced to Equation 2 below:
FVSR(m.b.) = (y, - Y,) / Y, (I-Y,)
(2)
If the fixed solids loss is not zero but is substantially
smaller than the volatile solids reduction, Equation 2 gives
surprisingly accurate results. For five sludges batch-di-
gested by Farrell and Bhide (1993), the fixed solids reduc-
128
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tions were about one-third of the volatile solids reductions.
When the FVSR(m.b.) calculated by Equation 1 a averaged
15%, the FVSR(m b.) calculated by Equation 2 averaged
14.93%, which is a trivial difference.
The disappearance of fixed solids unfortunately has a
relatively large effect on the calculation of FVSR by the
Van Kleeck equation. The result is lower than it should be.
For five sludges that were batch-digested by Farrell and
Bhide (1993), the FVSR calculated by the Van Kleeck
method averaged 15%, whereas the FVSR (m.b.) calcu-
lated by Equation 1 a or 2 averaged about 20%. When the
desired endpoint is an FVSR below 17%, this is a sub-
stantial discrepancy.
The additional digestion test was developed for use with
the Van Kleeck equation, and the 17% requirement is based
on results calculated with this equation. In the future, use
of the more accurate mass balance equation may be re-
quired, with the requirement adjusted upward by an ap-
propriate amount. This cannot be done until more data with
different sludge become available.
2. Specific Oxygen Uptake Rate
Background
The specific oxygen uptake rate of a sewage sludge is
an accepted method for indicating the biological activity of
an activated sewage sludge mixed liquor or an aerobically
digesting sludge. The procedure required by the Part 503
regulation for this test is presented in Standard Methods
(APHA, 1992) as Method 2710 B, Oxygen-Consumption
Rate.
The use of the specific oxygen uptake rate (SOUR) has
been recommend by Eikum and Paulsrud (1977) as a reli-
able method for indicating sludge stability provided tem-
perature effects are taken into consideration. For primary
sewage sludges aerobically digested at 18°C (64°F), sludge
was adequately stabilized (i.e., it did not putrefy and cause
offensive odors) when the SOUR was less than 1.2 mg
O2/hr/g VSS (volatile suspended solids). The authors in-
vestigated several alternative methods for indicating sta-
bility of aerobically digested sludges and recommended
the SOUR test as the one with the most advantages and
the least disadvantages.
Ahlberg and Boyko (1972) also recommend the SOUR
as an index of stability. They found that, for aerobic digest-
ers operated at temperatures above 10°C (50°F), SOUR
fell to about 2.0 mg O2/hr/g VSS after a total sludge age of
60 days and to 1 .0 mg 0,/hr/g VSS after about 120 days
sludge age. These authors state that a SOUR of less than
1.0 mg Cyhr/g VSS at temperatures above 10°C (50°F)
indicates a stable sludge.
The results obtained by these authors indicate that long
digestion times-more than double the residence time for
most aerobic digesters in use today-are needed to elimi-
nate odor generation from aerobically digested sludges.
Since the industry is not being deluged with complaints
about odor from aerobic digesters, it appears that a higher
SOUR standard can be chosen than they suggest without
causing problems from odor (and vector attraction).
The results of long-term batch aerobic digestion tests
by Jeris et al. (1985) provide information that is helpful in
setting a SOUR requirement that is reasonably attainable
and still protective. Farrell and Bhide (1993) reviewed the
data these authors obtained with four sewage sludges from
aerobic treatment processes and concluded that a stan-
dard of 1.5 mg O2/hr/g TS at 20°C (68°F) would discrimi-
nate between adequately stabilized and poorly stabilized
sludges. The "adequately digested" sludges were not to-
tally trouble-free, i.e., it was possible under adverse con-
ditions to develop odorous conditions. In all cases where
the sludge was deemed to be adequate, minor adjustment
in plant operating conditions created an acceptable sludge.
The SOUR requirement is based on total solids rather
than volatile suspended solids. This usage is preferred for
consistency with the rest of the Part 503 regulation where
all loadings are expressed on a total solids basis. The use
of total solids concentration in the SOUR calculation is ra-
tional since the entire sludge solids and not just the vola-
tile solids degrade and may exert some oxygen demand.
Making an adjustment for the difference caused by basing
the requirement on TS instead of VSS, the standard is
about 1.8 times higher than Eikum and Paulsrud's recom-
mended value and 2.1 times higher than Ahlberg and
Boykos' recommendation.
Unlike anaerobic digestion, which is typically conducted
at 35°C (95°F), aerobic digestion is carried out without any
deliberate temperature control. The temperature of the di-
gesting sludge will be close to ambient temperature, which
can range from 5°C to 30°C (41°F to 86°F). In this tem-
perature range, SOUR increases with increasing tempera-
ture. Consequently, if a requirement for SOUR is selected,
there must be some way to convert SOUR test results to a
standard temperature. Conceivably, the problem could be
avoided if the sludge were simply heated or cooled to the
standard temperature before running the SOUR test. Un-
fortunately, this is not possible, because temperature
changes in digested sludge cause short-term instabilities
in oxygen uptake rate (Benedict and Carlson [1973], Farrell
and Bhide [1993]).
Eikum and Paulsrud (1977) recommend that the follow-
ing equation be used to adjust the SOUR determined at
one temperature to the SOUR for another temperature:
(SOUR)T1/(SOUR)T2 =
(3)
where:
(SOUR),, = specific oxygen uptake rate at T,
(SOUR),, = specific oxygen uptake rate at T2
0 = the Streeter-Phelps temperature sensitivity
coeffficient
129
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These authors calculated the temperature sensitivity
coefficient using their data on the effect of temperature on
the rate of reduction in volatile suspended solids with time
during aerobic digestion. This is an approximate approach,
because there is no certainty that there is a one-to-one
relationship between oxygen uptake rate and rate of vola-
tile solids disappearance. Another problem is that the
coefficient depends on the makeup of each individual
sludge. For example, Koers and Mavinic (1977) found the
value of 6 to be less than 1.072 at temperatures above
15°C (59°F) for aerobic digestion of waste activated slud-
ges, whereas Eikum and Paulsrud (1977) determined 6 to
equal 1.112 for primary sludges. Grady and Lim (1980)
reviewed the data of several investigators and recom-
mended that 9 = 1.05 be used for digestion of waste-acti-
vated sludges when more specific information is not avail-
able. Based on a review of the available information and
their own work, Farrell and Bhide(1993) recommend that
Eikum and Paulsruds' temperature correction procedure
be utilized, using a temperature sensitivity coefficient in
the range of 1.05 to 1.07.
Recommended Procedure for Temperature
Correction
A SOUR of 1.5 mg Q Jhr/g total solids at 20°C (68°F)
was selected to indicate that an aerobically digested sludge
has been adequately reduced in vector attraction.
The SOUR of the sludge is to be measured at the tem-
perature at which the aerobic digestion is occurring in the
treatment works and corrected to 20°C (68°F) by the fol-
lowing equation:
SOUR,, = SOUR, xe<2t^-T> (4)
where
0= 1.05 above 20°C(68°F)
1.07 below 20°C (68°F)
This correction may be applied only if the temperature
of the sludge is between 10°C and 30°C (50°F and 86°F).
The restriction to the indicated temperature range is re-
quired to limit the possible error in the SOUR caused by
selecting an improper temperature coefficient.. Farrell and
Bhide's (1993) results indicate that the suggested values
for 9 will give a conservative value for SOUR when trans-
lated from the actual temperature to 20°C (68°F).
The experimental equipment and procedures for the
SOUR test are those described in Part 2710 B, Oxygen
Consumption Rate, of Standard Methods (APHA, 1992).
The method allows the use of a probe with an oxygen-
sensitive electrode or a respirometer. The method advises
that manufacturer's directions be followed if a respirom-
eter is used. No further reference to respirometric meth-
ods will be made here. A timing device is needed as well
as a 300-mL biological oxygen demand (BOD) bottle. A
magnetic mixer with stirring bar is also required.
The procedure of Standard Method 2710 B should be
followed with one exception. The total solids concentra-
tion instead of the volatile suspended solids concentration
is used in the calculation of the SOUR. Total solids con-
centration is determined by Standard Method 2540 G.
Method 2710 B cautions that if the suspended solids con-
tent of the sludge is greater than 0.5%, additional stirring
besides that provided by the stirring bar be considered.
Experiments by Farrell and Bhide (1993) were carried out
with sludges up to 2% in solids content without difficulty if
the SOUR was lower than about 3.0 mg O/g/h. It is pos-
sible to verify that mixing is adequate by running repeat
measurements at several stirrer bar speeds. If stirring is
adequate, oxygen uptake will be independent of stirrer
speed.
The inert mineral solids in the wastewater in which the
sludge particles are suspended do not exert an oxygen
demand and properly should not be part of the total solids
in the SOUR determination. Ordinarily, they are such a
small part of the total solids that they can be ignored. If the
ratio of inert dissolved mineral solids in the treated waste-
water to the total solids in the sludge being tested is greater
than 0.15, a correction should be made to the total solids
concentration. Inert dissolved mineral solids in the treated
wastewater effluent is determined by the method of Part
2540 B of Standard Methods (APHA, 1992). This quantity
is subtracted from the total solids of the sludge to deter-
mine the total solids to be used in the SOUR calculation.
The collection of the sample and the time between
sample collection and measurement of the SOUR are im-
portant. The sample should be a composite of grab samples
taken within a period of a few minutes duration. The sample
should be transported to the laboratory expeditiously and
kept under aeration if the SOUR test cannot be run imme-
diately. The sludge should be kept at the temperature of
the digester from which it was drawn and aerated thor-
oughly before it is poured into the BOD bottle for the test.
If the temperature differs from 20°C (68°F) by more than
±10°C (±18°F), the temperature correction may be inap-
propriate and the result should not be used to prove that
the sewage sludge meets the SOUR requirement.
Variability in flow rates and nature of the sludge will re-
sult in variability in performance of the plant-scale digest-
ers. It is advisable to run the SOUR test routinely so that
sufficient data are available to indicate average perfor-
mance. The arithmetic mean of successive tests-a mini-
mum of seven over 2 or 3 weeks is suggested-should give
a SOUR of < 1.5 mg O^hr/g total solids.
3. Additional Digestion Test for
Aerobically Digested Se wage Sludge
Background
Part 503 lists several options that can be used to dem-
onstrate reduction of vector attraction in sewage sludge.
These options include reduction of volatile solids by 38%
and demonstration of the SOUR value discussed above
(see also Chapter 8). These options are feasible for many,
but not all, digested sludges. For example, sludges from
extended aeration treatment works that are aerobically di-
130
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gested usually cannot meet this requirement because they
already are partially reduced in volatile solids content by
their exposure to long aeration times in the wastewater
treatment process.
The specific oxygen uptake test can be utilized to evalu-
ate aerobic sludges that do not meet the 38% volatile sol-
ids reduction requirement. Unfortunately, this test has a
number of limitations. It cannot be applied if the sludges
have been digested at temperatures lower than 10°C (50°F)
or higher than 30°C (86°F). It has not been evaluated un-
der all possible conditions of use, such as for sludges of
more than 2% solids.
A straightforward approach for aerobically treated slud-
ges that cannot meet either of the above criteria is to de-
termine to what extent they can be digested further. If they
show very little capacity for further digestion, they will have
a low potential for additional biodegradation and odor gen-
eration that attracts vectors.Such a test necessarily takes
many days to complete, because time must be provided
to get measurable biodegradation. Under most circum-
stances, this is not a serious drawback. If a digester must
be evaluated every 4 months to see if the sewage sludge
meets vector attraction reduction requirements, it will be
necessary to start a regular assessment program. A record
can be produced showing compliance. The sludge currently
being produced cannot be evaluated quickly but it will be
possible to show compliance over a period of time.
The additional digestion test for aerobically digested slud-
ges in Part 503 is based on research by Jeris et al. (1985),
and has been discussed by Farrell et al. (EPA, 1992). Farrell
and Bhide (1993) explain in more detail the origin of the
time and volatile solids reduction requirements of the test.
Jeris et al. (1985) demonstrated that several parameters-
volatile solids reduction, COD, BOD, and SOUR-declined
smoothly and approached asymptotic values with time as
sludge was aerobically digested. Any one of these param-
eters potentially could be used as an index of vector at-
traction reduction for aerobic sludges. SOUR has been
adopted (see above) for this purpose. Farrell and Bhide
(1993) have shown that the additional volatile solids re-
duction that occurs when sludge is batch digested aerobi-
cally for 30 days correlates equally as well as SOUR with
the degree of vector attraction reduction of the sludge. They
recommend that a sewage sludge be accepted as suitably
reduced in vector attraction when it shows less than 15%
additional volatile solids reduction after 30 days additional
batch digestion at 20°C (68°F). For three out of four slud-
ges investigated by Jeris et al. (1985), the relationship
between SOUR and additional volatile solids reduction
showed that the SOUR was approximately equal to 1.5
mg O2/hr/g (the Part 503 requirement for SOUR) when
additional volatile solids reduction was 15%. The two re-
quirements thus agree well with one another.
Recommended Procedure
There is considerable flexibility in selecting the size of
the digesters used for the additional aerobic digestion test.
Farrell and Bhide (1993) used a 20-liter fish tank. A tank of
rectangular cross-section is suggested because sidewalls
are easily accessible and are easily scraped clean of ad-
hering solids. The tank should have a loose-fitting cover
that allows air to escape. It is preferable to vent exhaust
gas to a hood to avoid exposure to aerosols. Oil and par-
ticle-free air is supplied to the bottom of the digester through
porous stones at a rate sufficient to thoroughly mix the
sewage sludge. This will supply adequate oxygen to the
sludge, but the oxygen level in the digesting sludge should
be checked with a dissolved oxygen meter to be sure that
the supply of oxygen is adequate. Oxygen level should be
at least 2 mg/L Mechanical mixers also were used to keep
down foam and improve mixing.
If the total solids content of the sewage sludge is greater
than 2%, the sludge must be diluted to 2% solids with sec-
ondary effluent at the start of the test. The requirement
stems from the results of Reynolds (1973) and Malina
(1966) which demonstrate that rate of volatile solids re-
duction decreases as the feed solitis concentration in-
creases. Thus, for example, a sludge with a 2% solids con-
tent that showed more than 15% volatile solids reduction
when digested for 30 days might show a lower volatile
solids reduction and would pass the test if it were at 4%.
This dilution may cause a temporary change in rate of vola-
tile solids reduction. However, the long duration of the test
should provide adequate time for recovery and demon-
stration of the appropriate reduction in volatile solids con-
tent.
When sampling the sludge, care should be taken to keep
the sludge aerobic and avoid unnecessary temperature
shocks. The sludge is digested at 20°C (68°F) even if the
digester was at some other temperature. It is expected
that the bacterial population will suffer a temporary shock
if there is a substantial temperature change, but the test is
of sufficient duration to overcome this effect and show a
normal volatile solids reduction. Even if the bacteria are
shocked and do not recover completely, the test simulates
what would happen to the sludge in the environment. If it
passes the test, it is highly unlikely that the sludge will at-
tract vectors when used or disposed to the environment.
For example, if a sludge digested at 35°C (95°F) has not
been adequately reduced in volatile solids and is shocked
into biological inactivity for 30 days when its temperature
is lowered to 20°C (68°F), it will be shocked in the same
way if it is applied to the soil at ambient temperature. Con-
sequently, it is unlikely to attract vectors.
The digester is charged with about 12 liters of the sew-
age sludge to be additionally digested, and aeration is com-
menced. The constant flow of air to the aerobic digestion
test unit will cause a
substantial loss of water from the digester. Water loss
should be made up every day with distilled water. Solids
that adhere to the walls above and below the water line
should be scraped off and dispersed back into the sludge
daily. The temperature of the digesting sludge should be
approximately 20°C (68°F). If the temperature of the labora-
131
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tory is maintained at about 22°C (72°F), evaporation of
water from the digester will cool the sludge to about 20°C
(68°F).
Sewage sludge is sampled every week for five succes-
sive weeks. Before sampling, makeup water is added (this
will generally require that air is temporarily shut off to allow
the water level to be established), and sludge is scraped
off the walls and redistributed into the digester. The sludge
in the digester is thoroughly mixed with a paddle before
sampling, making sure to mix the bottom sludge with the
top. The sample is comprised of several grab samples
collected with a ladle while the digester is being mixed.
The entire sampling procedure is duplicated to collect a
second sample.
Total and volatile solids content of both samples are
determined preferably by Standard Method 2540 G (APHA,
1992). Percent volatile solids is calculated from total and
volatile solids content. Standard Methods (APHA, 1992)
states that duplicates should agree within 5% of their av-
erage. If agreement is substantially poorer than this, the
sampling and analysis should be repeated.
Calculation Details
Fraction volatile solids reduction is calculated by the Van
Kleeck formula (see Appendix C) and by a mass balance
method. The mass balance (m.b.) equations become very
simple, because final mass of sludge is made very nearly
equal to initial mass of sludge by adjusting the volume by
adding water. These equations for fractional volatile solids
reduction (FVSR) and fractional fixed solids reduction
(FFSR) are:
FVSR(m.b.) = (y, - y,) / y,
FFSR(m.b.) = (x, -xb) / x,
where:
(5a)
(5b)
y and x = mass fraction of volatile and fixed solids, re-
spectively (see previous section
on"Calculation details" for explanation of
"mass fraction")
f and b = subscripts indicating initial and final sludges
This calculation assumes that initial and final sludge
densities are the same. Very little error is introduced by
this assumption.
The calculation of the fractional fixed solids reduction is
not a requirement of the test, but it will provide useful infor-
mation.
The test was developed from information based on the
reduction in volatile solids content calculated by the Van
Kleeck equation. As noted in the section on the additional
anaerobic digestion test, for batch processes the material
balance procedure for calculating volatile solids reduction
is superior to the Van Kleeck approach. It is expected that
the volatile solids reduction by the mass balance method
will show a higher volatile solids reduction than the calcu-
lation made by using the Van Kleeck equation.
4. References
Ahlberg, N.R. and B.I. Boyko. 1972. Evaluation and de-
sign of aerobic digesters. Jour. WPCF 44(4):634-643.
Benedict, A.M., and D.A. Carlson. 1973. Temperature ac-
climation in aerobic big-oxidation systems. Jour. WPCF
45(1): 10-24.
Eikum, A., and B. Paulsrud. 1977. Methods for measuring
the degree of stability of aerobically stabilized slud-
ges. Wat. Res. 11: 763-770
EPA. 1992. Technical support document for Part 503 patho-
gen and vector attraction reduction requirements in
sewage sludge. NTIS No.: PB93-11069. Springfield,
VA: National Technical Information Service.
Farrell, J.B. and V. Bhide. 1993. Development of methods
for quantifying vector attraction reduction. (Manuscript
in preparation.)
APHA (American Public Health Association). 1992. Stan-
dard methods for the examination of water and waste-
water. Greenberg, A.E., L.S. Clesceri, and A.D. Eaton
(eds.). APHA, AWWA, and WEF, Washington, DC.
Grady, C.P.L., Jr., and H.C. Lim. 1980. Biological waste-
water treatment: theory and applications. Marcel
Dekker, New York.
Jeris, J.S., D. Ciarcia, E. Chen, and M. Mena. 1985. De-
termining the stability of treated municipal sludge. EPA
Rept. No. 600/2-85-001 (NTIS No. PB 851-1 471891
AS). U.S. Environmental Protection Agency, Cincin-
nati, Ohio.
Koers, D.A., and D.V. Mavinic. 1977. Aerobic digestion of
waste-activated sludge at low temperatures. Jour.
WPCF 49(3): 460-468.
Malina, Jr., J.F. 1966. Discussion, pp. 157-1 60, in paper
by D. Kehr, "Aerobic sludge stabilization in sewage
treatment plants." Advances in Water Pollution Re-
search, Vol. 2, pp 143-1 63. Water Pollution Control
Federation, Washington, DC.
Reynolds, T.D. 1973. Aerobic digestion of thickened waste-
Proc. 28th
Industr. Waste Conf., Purdue University.
132
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Appendix E
Determination of Residence Time for Anaerobic and Aerobic Digestion
Introduction
The PSRP and PFRP specifications in 40 CFR 257 for
anaerobic and aerobic digestion not only specify tempera-
tures but also require minimum mean cell residence times
of the sludge in the digesters. The mean cell residence
time is the time that the sludge particles are retained in the
digestion vessel under the conditions of the digestion. The
calculation of residence time is ordinarily simple but it can
become complicated under certain circumstances. This
appendix describes how to make this calculation for most
of the commonly encountered modes for operating digest-
ers.
Approach
The discussion has to be divided into two parts: resi-
dence time for batch operation and for plug flow, and resi-
dence time for fully mixed digesters. For batch operation,
residence time is obvious-it is the duration of the reaction.
For plug flow, the liquid-solid mixture that is sludge passes
through the reactor with no backward or forward mixing.
The time it takes the sludge to pass through the reactor is
the residence time. It is normally calculated by the follow-
ing equation:
6 = V/q (1)
where
6 = plug flow solids residence time
V = volume of the liquid in the reactor
q = volume of the liquid leaving the reactor
Normally the volume of liquid leaving the reactor will
equal the volume entering. Conceivably, volume leaving
could be smaller (e.g., because of evaporation losses) and
residence time would be longer than expected if 1 were
based on inlet flow. Ordinarily, either inlet or outlet flow
rate can be used.
For a fully mixed reactor, the individual particles of the
sludge are retained for different time periods-some par-
ticles escape very soon after entry whereas others circu-
late in the reactor for long periods before escaping. The
average time in the reactor is given by the relationship:
where
8s = an increment of sludge solids that leaves the reactor
0 = time period this increment has been in the reactor
0n = nominal average solids residence time
When the flow rates of sludge into and out of the com-
pletely mixed vessel are constant, it can be demonstrated
that this equation reduces to:
(3)
where
V = reactor volume
q = flow rate leaving
Cv = concentration of solids in the reactor
Cq = concentration of solids in exiting sewage sludge
It is important to appreciate that q is the flow rate leaving
the reactor. Some operators periodically shut down reac-
tor agitation, allow a supernatant layer to form, decant the
supernatant, and resume operation. Under these condi-
tions, the flow rate entering the reactor is higher than the
flow rate of sludge leaving.
Note that in Equation 3, VCv is the mass of solids in the
system and pC is the mass of solids leaving. Ordinarily Cv
equals CqancLmese terms could be canceled. They are
left in the equation because they show the essential form
of the residence time equation:
0n = mass of solids in the diaester
mass flow rate of solids leaving
(4)
9 = ZCSs x 61
E(8s)
(2)
Using this form, residence time for the important operat-
ing mode in which sludge leaving the digester is thickened
and returned to the digester can be calculated.
In many aerobic digestion installations, digested sludge
is thickened with part of the total volume returned to in-
crease residence time and part removed as product. The
calculation follows Equation 4 and is identical with the SRT
(solids retention time) calculation used in activated sludge
process calculations. The focus here is on the solids in the
digester and the solids that ultimately leave the system.
Applying Equation 4 fcr residence time then leads to Equa-
tion 5:
133
-------
(5)
where
p = flow rate of processed sludge leaving the system
Cp = solids concentration in the processed sludge
The subscript p indicates the final product leaving the
system, not the underflow from the thickener. This approach
ignores any additional residence time in the thickener since
this time is relatively short and not at proper digestion con-
ditions.
Sample Calculations
In the following paragraphs, the equations and principles
presented above are used to demonstrate the calculation
of residence time for several commonly used digester op-
erating modes:
Casel
. Complete-mix reactor
. Constant feed and withdrawal at least once a day
. No substantial increase or decrease in volume in the
reactor (V)
. One or more feed streams and a single product stream
(q)
The residence time desired is the nominal residence time.
Use Equation 3 as shown below:
qCq q
The concentration terms in Equation 4 cancel out be-
cause Cv equals Cq.
Case 2a
. Complete-mix reactor
. Sludge is introduced in daily batches of volume (Vi)
and solids concentration (C}
. Vessel contains a "heel" of liquid sludge (V,) at the
beginning of the digestion step
• When final volume (V,) is reached, sludge is discharged
until Vh remains and the process starts again
Some aerobic digesters are run in this fashion. This prob-
lem is a special case involving a batch reaction. Exactly
how long each day's feeding remains in the reactor is
known, but an average residence time must be calculated
as shown in Equation 2:
9 = Sv.Q x time that batch i remains in the reactor
~~~
Let v = 30 m3 (volume of "heel")
vd = 130 m3 (total digester volume)
V; = each day 10 m3 is fed to the reactor at the begin-
ning of the day
Q = 12 kg/m3
V,' Is reached in 10 days. Sludge is discharged at the
end of Day 10.
Then 9 = (10-12-10+10-12-9 +... +10-12-11
(10.12 +10.12 + . . .10-12)
9 = 10-12-55 = 5.5 days
10-12-10
Notice that the volume of the digester or of the "heel" did
not enter the calculation.
Case 2b
Same as Case 2a except:
. The solids content of the feed varies substantially from
day to day
. Decantate is periodically removed so more sludge can
be added to the digester
The following problem illustrates the calculation:
Let Vh = 30 m3, and Vd = 130m3
Day vi (m3) Solids Content (kg/m3) Decantate (m3)
1
2
3
4
5
6
7
8
9
10
11
12
10
10
10
10
10
10
10
10
10
10
10
10
10
15
20
15
15
10
20
25
15
10
15
20
0
0
0
0
0
0
0
0
10
0
10
0
The following problem illustrates the calculation:
9 = (10-10-12+10-15-11+10-20-10+...
. ..+1 Q-1Q-3+1Q-15-2+1Q-2Q-1)
(10-10+10-15+10-20+....
+10-10+10-15+10-20
9n = 11,950/1 ,900 + 6.29d
The volume of "heel" and sludge feedings equaled 150
m3, exceeding the volume of the digester. This was made
possible by decanting 20 m3.
Case 3
Same as Case 2 except that after the digester is filled it
is run in batch mode with no feed or withdrawals for sev-
eral days.
A conservative 9n can be calculated by simply adding
the number of extra days of operation to the On calculated
134
-------
for Case 2. The same applies to any other cases followed
by batch mode operation.
Case 4
. Complete-mix reactor
. Constant feed and withdrawal at least once a day
. No substantial increase or decrease of volume in the
reactor
. One or more feed streams, one decantate stream re-
turned to the treatment works, one product stream;
the decantate is removed from the digester so the
sludge in the digester is higher in solids than the feed
This mode of operation is frequently used in both anaero-
bic and aerobic digestion in small treatment works.
Equation 3 is used to calculate the residence time:
Let V = 100m3
q, = 10 m3/d (feed stream)
C, = 40 kg solids/m3
q = 5 m3/d (existing sludge stream)
Cv = 60 kg solids/m3
6 = 100x60 = 20 d
5x60
Case 5
. Complete-mix reactor
. Constant feed and withdrawal at least once a day
• Volume in digester reasonably constant
• One or more feed streams, one product stream that is
thickened, some sludge is recycled, and some is drawn
off as product
This mode of operation is sometimes used in aerobic
digesters. Equation 5 is used to calculate residence time.
Let V = 100 m3
Feed flow rate = 10 m3/d
Feed solids content = 10 kg/m3
Flow rate from the digester = 12 m3/d
Solids content of sludge from the digester = 13.3 kg/m3
Flow rate of sludge from the thickener = 4 m3/d
Solids content of sludge from the thickener = 40 kg/m3
Flow rate of sludge returned to the digester = 2 m3/d
Flow rate of product sludge = 2 m3/d
9 =100X13.3 = 16.6 d
2x40
The denominator is the product of the flow rate leaving
the system (2 m3/d) and the concentration of sludge leav-
ing the thickener (40 kg/m3). Notice that flow rate of sludge
leaving the digester did not enter into the calculation.
Comments on Batch and Staged Operation
Sludge can be aerobically digested using a variety of
process configurations (including continuously fed single-
or multiple-stage completely mixed reactors), or it can be
digested in a batch mode (batch operation may produce
less volatile solids reduction for a primary sludge than the
other options because there are lower numbers of aerobic
microorganisms in it). Single-stage completely mixed re-
actors with continuous feed and withdrawal are the least
effective of these options for bacterial and viral destruc-
tion, because organisms that have been exposed to the
adverse condition of the digester for only a short time can
leak through to the product sludge.
Probably the most practical alternative to use of a single
completely mixed reactor for aerobic digestion is staged
operation, such as use of two or more completely mixed
digesters in series. The amount of slightly processed sludge
passing from inlet to outlet would be greatly reduced com-
pared to singlestage operation. If the kinetics of the reduc-
tion in pathogen densities are known, it is possible to esti-
mate how much improvement can be made by staged op-
eration.
Farrah et al. (1986) have shown that the declines in den-
sities of enteric bacteria and viruses follow first-order ki-
netics. If first-order kinetics are assumed to be correct, it
can be shown that a one-log reduction of organisms is
achieved in half as much time in a two-stage reactor (equal
volume in each stage) as in a one-stage reactor. Direct
experimental verification of this prediction has not been
carried out, but Lee et al. (1989) have qualitatively verified
the effect.
It is reasonable to give credit for an improved operating
mode. Since not all factors involved in the decay of micro-
organisms densities are known, some factor of safety
should be introduced. It is recommended then that for
staged operation using two stages of approximately equal
volume, the time required be reduced to 70% of the time
required for single-stage aerobic digestion in a continu-
ously mixed reactor. This allows a 30% reduction in time
instead of the 50% estimated from theoretical consider-
ations. The same reduction is recommended for batch
operation or for more than two stages in series. Thus, the
time required would be reduced from 40 days at 20°C (68°F)
to 28 days at 20°C (68°F), and from 60 days at 15°C (59°F)
to 42 days at 15°C (59°F). These reduced times are also
more than sufficient to achieve adequate vector attraction
reduction.
If the plant operators desire, they may dispense with the
PSRP time-temperature requirements of aerobic digestion
but instead demonstrate experimentally that microbial lev-
els in the product from their sludge digester are satisfacto-
rily reduced. Under the current regulations, fecal coliform
densities must be less than or equal to 2,000,000 CFU or
MPN per gram total solids. Once this performance is dem-
onstrated, the process would have to be operated between
monitoring episodes at time-temperature conditions at least
as severe as those used during their tests.
135
-------
References NTIS Publication No. PB86-183084/A5. National Tech-
nical Information Service, Springfield, Virginia.
Farrah.. S.R., G. Bitton. and S.G. Zan. 1986. Inactivation
of enteric pathogens during aerobic digestion of waste- Lee, K.M., C.A. Brunner, J.B. Farrell, and A.E. Eralp. 1989.
water sludge. EPA Pub. No. EPA/600/2-86/047. Wa- Destruction of enteric bacteria and viruses during two-
ter Engineering Research Laboratory, Cincinnati, OH. phase digestion. Journal WPCF 61(6):1421-l 429.
136
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Appendix F
Sample Preparation for Fecal Coliform Tests and Salmonella sp. Analysis
1. Sample Preparation for Fecal Coliform
Tests
1.1 Class B Alternative I
To demonstrate that a given domestic sludge sample
meets Class B Pathogen requirements under alternative
1, the density of fecal coliform from at least seven samples
of treated sewage sludge must be determined and the
geometric mean of the fecal coliform density must not ex-
ceed 2 million Colony Forming Units (CPU) or Most Prob-
able Number (MPN) per gram of total solids (dry weight
basis). The solids content of treated domestic sludge can
be highly variable. Therefore, an aliquot of each sample
must be dried and the solids content determined in accor-
dance with procedure 2540 G. of the 18th edition of Stan-
dard Methods for the Examination of Water and Wastewa-
ter (SM).
Sludge samples to be analyzed in accordance with SM
9221 E. Fecal Coliform MPN Procedure and 9222 D. Fe-
cal Coliform Membrane Filter Procedure may require dilu-
tion prior to analysis. An ideal sample volume will yield
results which accurately estimate the fecal coliform den-
sity of the sludge. Detection of fecal coliform in undiluted
samples could easily exceed the detection limits of these
procedures. Therefore, it is recommended that the follow-
ing procedures be used (experienced analysts may sub-
stitute other dilution schemes as appropriate).
For Liquid Samples:
1. Use a sterile graduated cylinder to transfer 30.0 mL
of well mixed sample to a sterile blender jar. Use
270 ml of sterile buffered dilution water (see Sec-
tion 9050C) to rinse any remaining sample from the
cylinder into the blender. Cover and blend for two
minutes on low speed. 1 .0 ml of this mixture is 0.1
ml of the original sample or 1.0X1 O'1.
2. Use a sterile pipette to transfer 11 .O ml_ of the
blended sample mixture to 99 mL of sterile buffered
dilution in a sterile screw cap bottle and mix by vig-
orously shaking the bottle a minimum of 25 times.
This is dilution "A". 1 .0 ml of this mixture is 0.010
mL of the original sample or 1.0X1 O'2.
3. Use a sterile pipette to transfer 1.0 mL of dilution
"A" to a second screw cap bottle containing 99 mL
of sterile buffered dilution water, and mix as before.
This is dilution "B". 1 .0 mL of this mixture is 0.00010
mL of the original sample or 1.0X1 0~4.
4. Use a sterile pipette to transfer 1.0 mL of dilution
"B" to a sterile screw cap bottle containing 99 mL of
sterile buffered dilution water, and mix as before.
This is dilution "C". Go to step 5. for MPN analysis
(preferred) or 7. for MF analysis.
5. For MPN analysis, follow procedure 9221 E. in SM.
Four series of 5 tubes will be used for the analysis.
Inoculate the first series of 5 tubes each with 10.0
mLof dilution "B". This is a 0.0010 mL of the original
sample. The second series of tubes should be in-
oculated with 1 .0 mL of dilution "B"(0.00010). The
third series of tubes should receive 10.0 mL of
"C"(0.000010). Inoculate a fourth series of 5 tubes
each with 1 .0 mL of dilution "C"(0.0000010). Con-
tinue the procedure as described in SM.
6. Refer to Table 9221 .IV.in SM to estimate the MPN
index/100 mL. Only three of the four series of five
tubes will be used for estimating the MPN. Choose
the highest dilution that gives positive results in all
five tubes, and the next two higher dilutions for your
estimate. Compute the MPN/g according to the fol-
lowing equation:
MPN Fecal Co!iform/g = 10 X MPN Index/100mL
largest volume X % dry solids
Examples:
In the examples given below, the dilutions used to de-
termine the MPN are underlined. The number in the nu-
merator represents positive tubes; that in the denomina-
tor, the total number of tubes planted; the combination of
positives simply represents the total number of positive
tubes per dilution.
0.0010 0.00010 0.000010 0.0000010 Combination
Example ml ml mL ml of positives
a
b
c
515
5/5
0/5
5/5
3/5
1/5
3/5
1&
fl/5
0/5
0/5
015
5-3-0
5-3-I
0-1-0
137
-------
For each example we will assume that the total solids
content is 4.0%.
For example a:
The MPN index/I 00 ml from Table 9221.4 is 80. There-
fore:
MPN/g = 10x80
0.00010x4.0 = 2.0 x106
For example b:
The MPN index/I 00 mLfrom Table 9221.4 is 110. There-
fore:
MPN/g = 10 x11Q
0.0010 x 4.0 = 2.8 x105
For example c:
The MPN index/I 00 mL from Table 9221.4 is 2. There-
fore:
MPN/g = 10x2
0.0010x4.0 = 5.0 x103
5. Alternately the membrane filter procedure may be
used to determine fecal coliform density. This
method should only be used if comparability with
the MPN procedure has been established for the
specific sample medium. Three individual filtrations
should be conducted in accordance with SM 9222
D. using 10.0 ml of dilution "C", and 1.0 mL and
10.0 mL of dilution "B". These represent 0.000010,
0.00010, and 0.0010 mL of the original sample. In-
cubate samples, and count colonies as directed.
Experienced analysts are encouraged to modify this
dilution scheme(e.g. half log dilutions) in order to
obtain filters which yield between 20 and 60 CFU.
6. Compute the density of CFU from membrane filters
which yield counts within the desired range of 20 to
60 fecal coliform colonies:
coliform colonies/g = coliform colonies counted X 1 OQ
mL sample X % dry solids
For Solid Samples:
1. In a sterile dish weigh out 30.0 grams of well mixed
sample. Whenever possible, the sample tested
should contain all materials which will be included
in the sludge. For example, if wood chips are part of
a sludge compost, some mixing or grinding means
may be needed to achieve homogeneity before test-
ing. One exception would be large pieces of wood
which are not easily ground and may be discarded
before blending. Transfer the sample to a sterile
blender. Use 270 mL of sterile buffered dilution wa-
ter to rinse any remaining sample into the blender.
Cover and blend on low speed for two minutes. One
milliliter of this sample contains 0.10 g of the origi-
nal sample.
2. Use a sterile pipette to transfer 11 .O mL of the
blender contents to a screw cap bottle containing
99 mL of sterile buffered dilution water and shake
vigorously a minimum of 25 times. One milliliter of
this sample contains 0.010 g of the original sample.
This is dilution "A".
3. Follow the procedures for "Liquid Samples" starting
at Step 3.
Examples:
Seven samples of a treated sludge were obtained prior
to land spreading. The solids concentration of each sample
was determined according to SM. These were found to
be:
Sample No.
1
2
3
4
5
6
7
Solids Concentration (%)
3.8
4.3
4.0
4.2
4.1
3.7
3.9
The samples were liquid with some solids. Therefore the
procedure for liquid sample preparation was used. Fur-
thermore, the membrane filter technique was used to de-
termine if the fecal coliform concentration of the sludge
would meet the criteria for Class B alternative 1. Samples
were prepared in accordance with the procedure outlined
above. This yielded 21 individual membrane filters (MF)
plus controls. The results from these tests are shown in
table 1
Table 1. Number of Fecal Coliform Colonies on MF Plates
Sample No.
1
2
3
4
5
6
7
0.000010
mL Filtration
0
2
0
0
0
0
0
0.00010
mL Filtration
1
18
8
5
1
1
1
0.0010
mL Filtration
23
TNTC
85
58
17
39
20
The coliform density is calculated using only those MF
plates which have between 20 and 60 blue colonies when-
ever possible. However, there may be occasions when the
total number of colonies on a plate will be above or below
the ideal range. If the colonies are not discrete and appear
to be growing together results should be reported as "to
numerous to count" (TNTC). If no filter has a coliform count
falling in the ideal range (20 -60), total the coliform counts
on all countable filters and report as coliform colonies/g.
For sample number 2 the fecal coliform density is:
138
-------
coliform colonies/g =
(2 + 18) x 100
(0.000010 +0.00010) x 4.3 = 4.2x1 O6
Sample number 3 has two filters which have colony
counts outside the ideal range also. In this case both count-
able plates should be used to calculate the coliform den-
sity/g. For sample number 3, the fecal coliform density is:
coliform colonies/g = (8 + 65) x 100
(0.00010 + 0.0010)x 4.0= 1.6x1 O6
Except for sample number 5, all of the remaining samples
have at least one membrane filter within the ideal range.
For these samples, use the number of colonies formed on
that filter to calculate the coliform density. For sample num-
ber 1, the fecal coliform density is:
coliform colonies/g =
23x100
0.0010 x 3.8 = 6.0 x105
Coliform densities of all the samples were calculated and
converted to log 0 values to compute a geometric mean.
These calculated values are presented in Table 2.
Table 2. Coliform Density of Sludge Samples
Sample No. Coliform Density
log.
6.0 X105
4.2 X106
1.6X106
9.0 x105
4.0 x105
1.0x106
5.1 x105
5.78
6.62
6.20
5.95
5.60
6.00
5.71
The geometric mean for the seven samples is determined
by averaging the log 0 values of the coliform density and
taking the antilog of that value.
(5.78 + 6.62 + 6.20 + 5.95 + 5.60 + 6.00 + 5.71) II = 5.98
The antilog of 5.98 = 9.5 x 105
Therefore, the geometric mean fecal coliform density is
below 2 million and the sludge meets Class B Pathogen
requirements under alternative 1.
1.2 Class A Alternative I
Part 503 requires that, to qualify as a Class A sludge,
treated sewage sludge must be monitored for fecal coliform
(or Salmonella sp. and have a density of less than 1,000
MPN fecal coliform per gram of total solids (dry weight
basis). The regulation does not specify total number of
samples. However, it is suggested that a sampling event
extend over two weeks and that at least seven samples
be collected and analyzed. The membrane filter procedure
may not be used for this determination. This is because
the high concentration of solids in such sludges may plug
the filter or, render the filter uncountable. The total solids
content for each sample must be determined in accordance
with procedure 2540 G. of SM.
For Liquid Samples:
1. Follow procedure 9221 E. in SM. Inoculate at least
four series of five tubes using ten fold serial dilu-
tions. Prepare the sample as described for "Class
B Alternative 1 .Liquid Samples," except inoculate
each of the first series of tubes with 10.0 mL of the
blender contents (the concentration of the enrich-
ment broth must be adjusted to compensate for the
volume of added sample). This is equivalent to add-
ing 1 .0 mL of sludge to the first series of tubes. In-
oculate the remaining tubes and complete the analy-
sis in accordance with SM.
2. Calculate the MPN as directed in Step 4 above.
For Solid Samples:
1. Follow procedure 9221 E. in SM. Inoculate at least
four series of five tubes using ten fold serial dilu-
tions. Prepare the sample as described for "Class
B alternative 1, Solid Samples," except inoculate
each of the first series of tubes with 10.0 mL of the
blender contents (the concentration of the enrich-
ment broth must be adjusted to compensate for the
volume of added sample). This is equivalent to add-
ing 1 .0 g of sludge (wet wieght) to the first series of
tubes. Inoculate the remaining tubes and complete
the analysis in accordance with SM.
2. Calculate the MPN as directed in step 4 above.
2. Sample Preparation for Salmonella sp.
Analysis
Salmonella sp. quantification may be used to demon-
strate that a sludge meets Class A criteria, instead of ana-
lyzing for fecal coliforms. Sludges with Salmonella sp. den-
sities below 3 MPN/4 g total solids (dry wieght basis) meet
Class A criteria. The analytical method described in Ap-
pendix F of this document, describes the procedure used
to identify Salmonella sp. in a water sample. Similarly, the
procedures for analysis of Salmonella sp. in SM (Section
9260 D) do not address procedures for sludges, the sample
preparation step described here should be used, and the
total solids content of each sample must be determined
according to method 2540 G in SM.
For Liquid Samples:
1. Follow the same procedure used for liquid sample
preparation for fecal coliform analysis described un-
der "Class A Alternative 1". However, the enrichment
medium used for this analysis should be dulcitol se-
lenite broth (DSE) as described in Appendix G of
this document or dulcitol selenite or tetrathionate
broth as described in SM. Only three series of five
tubes should be used for this MPN procedure. Use
a sterile open tip pipette to transfer 10.0 mL of well
mixed sample to each tube in the first series. These
tubes should contain 10.0 mL of double strength
enrichment broth. Each tube in the second series
should contain 10.0 mL of double strength enrich-
ment broth. These tubes should each receive 10.0
139
-------
ml of the blended mixture. The final series of tubes
should contain 10.0 ml of single strength enrich-
ment broth. These tubes should each receive 1.0
ml of the blended mixture. Complete the MPN pro-
cedure as described in Appendix G or SM as ap-
propriate.
2. Refer to Table 9221 .IV.in SM to estimate the MPN
index/I 00 ml_. Calculate the MPN/4 g according to
the following equation:
Salmonella sp. MPN/4 g = MPN Index/I QQmL x 4
% dry solids
For example:
If one tube in the first series was identified as being posi-
tive for Salmonella sp. and no other tubes were found to
be positive, from Table 9221 .IV one finds that a I-O-O com-
bination of positives has an MPN index/I 00 mL of 2. If the
percent of dry solids for the sample was 4.0, then:
Salmonella sp. MPN/4 g = 2x4
4.0 = 2
For Solid Samples:
1. Follow the procedure for solid sample preparation
for fecal coliform analysis described under Class A
Alternative 1 above. However, the enrichment me-
dium used for this analysis should be dulcitol selen-
2.
ite broth (DSE) as described in Appendix G or dulci-
tol selenite or tetrathionate broth as described in
SM, and only three series of five tubes should be
used for this MPN procedure. Use aseptic technique
to weigh out and transfer 10.0 g of well mixed sample
to each screw cap tube in the first series, shake
vigorously to mix. These tubes should contain 10.0
mL of double strength enrichment broth. Likewise,
each tube in the second series should contain 10.0
mLof double strength enrichment broth. These tubes
should receive 10.0 mL of the blended mixture. The
final series of tubes should contain 10.0 mL of single
strength enrichment broth. These tubes should re-
ceive 1 .0 mL of the blended mixture. Alternately,
because the calculated detection limit is dependant
upon the total solids content of the sample, samples
with total solids contents >28% can be blended as
described above and the blender contents can be
used for inoculating the initial series of tubes. When
this option is chosen, the final series of tubes will
contain 0.1 mL of the blender contents. Complete
the MPN procedure as described in Appendix G or
SM as appropriate.
Refer to Table 9221 .IV.in SM to estimate the MPN
index/I 00 mL Calculate the MPN/4 g according to
the following equation:
Salmonella sp. MPN/4 g = MPN Index/I QOmL x 4
% dry solids
140
-------
Appendix G
IKenner and Clark (1974) Analytical Method for Salmonella sp. Bacteria*
Detection and enumeration of Salmonella
and Pseudomonas aerwginosa
BERNARD A. KENNEH AND HAROLD P. CLARK
THE FEDERAL WATER POLLUTION CON-
TROL AMENDMENTS of 1972 1-4 may
well require the quantification and enu-
meration of pathogens such as Salmonella
species in all classes of waters. The re-
quirements are described by Shedroff .D
One of the continuing programs of the
Environmental Protection Agency (EPA)
is a research project concerned with the
development of practical laboratory meth-
ods for the isolation, quantification, and
enumeration of pathogens from polluted
waters. This paper reports a monitoring
method developed for the simultaneous
isolation and enumeration of Salmonella
species and Pseudomonas aeruginosa from
potable waters, reuse waters, treatment
plant effluents, receiving waters, and
sludges.
The method described herein, and de-
veloped by Kenner," is practical because
readily available bacteriological media,
chemicals, and equipment are all that are
required to obtain the desired results.
These results are the establishment of the
absence or presence of Salmonella species
( pathogenic hazardous bacteria ) and/or
Pseudomonas aeruginosa (potential patho-
gens) that affect persons who are in a
debilitated condition and are very com-
mon as infectious agents in hospitals be-
cause of their resistance to antibiotic
therapy.'-" Potable waters have also been
shown to contain Ps. aeruginosa.*- 10 The
sources of these potential pathogens are
human and animal feces and waste-
waters.11' l5
When the monitoring method was used,
it was found that 100 percent of municipal
wastewaters and treatment plant sludges
contained both of these potential patho-
gens. Ps. aeruginosa has been found in
potable water supplies of large and small
municipalities where insufficient residual
chlorine is evident. Also important is the
fact that these organisms may be found in
the absence of fecal coliforms, whereas
negative indicator tests may give a false
sense of security. It is believed by the
authors that these organisms may be better
indicators than fecal coliforms of pollu-
tion in potable, direct reuse, bathing, and
recreational waters.
MATERIALS AND METHODS
The monitoring method uses a multiple
tube ( MPN) procedure in which dulcitol
selenite broth ( DSE) 13 is used for primary
enrichment medium, and is modified by
the use of sodium acid selenite ( BBL).
The formula is proteose peptone (Bacto),
0.4 percent; yeast extract (Bacto), 0.15
percent; dulcitol, 0.4 percent; BBL, 0.5
percent; Na2HPO4, 0.125 percent; and
KH2PO4, 0.125 percent in distilled water.
The constituents are dissolved in a sterile
flask, covered with foil, and heated to
88°C in a water bath to obtain a clear
sterile medium that does not require ad-
justment of pH. Productivity for Salmo-
n& species is enhanced by the addition
of an 18-hr, 37°C culture of Salmonella
paratyphi A (10 percent by volume) in
single-strength DSE broth, killed by heating
to 88°C.
Concentration of bacteria from large
volumes of water is necessary* when pota-
ble, direct reuse, receiving waters, and
treatment effluents are being monitored.
-Vol. 46, No. 9, September 1974 3163
141
-------
KENNED AND CI.ARK
TABLE I.-Retentive Characteristics of Several Glass Fiber Filter Papers'
Compared with Membrane Filters
Filter
Total Bacteriat
Filtered
Milliporc (MF) HAWG 047 HA 0.45 it, white,
grid, 47 mm, Millipore Filter Corp.
984H Ultra Glass Fiber Filter, 47 mm,
Reeve Angel Corp.
GF/F Glass Paper Whatman, t 47 mm,
Reeve Angel Corp.
GF/D Glass Paper Whatman.t 47 mm,
Reeve Angel Corp.
934AH Glass Fiber Filter, 47 mm,
Reeve Angel Corp.
GF/A Glass Paper Whatman, 47 mm,
Reeve Angel Corp.
1,376
1,229
2,698
2,622
1,049
1,066
Number Passing i Percentage
Fil'.cr I Retention
o
25
6
2,166
198
100
98
99.8
17.4
81
36
* The 984H Ultra Glass Fiber Filter is flexible when wet, readily allows filtration of large volumes of water,
can readily be bent double with forceps, and, when placed into primary enrichment broth, disintegrates when
tube is shaken and releases entrapped bacteria.
t Enteric bacteria. E. coli, 0.5 X 1-3 it.
t A new paper filter GF/F has better retentive properties than the 984H, and has same properties (tested
Oct. 1973).
Concentration is attained by filtration tube in the first row of the setup into 10
through glass fiber filters ° in a membrane ml of double-strength DSE is made, 1 ml
filter apparatus. After the desired volume of sample in 9 ml of single-strength DSE
of water is filtered through the ultra filter, in the second row, and so on. The MPN
the flexible filter is folded double with table in "Standard Methods" " is used to
sterile forceps and inserted into a suitable read directly the results per volume of
sample.
Incubation temperature of 40" ± 0.2°C
for 1 and 2 days is critical to obtain opti-
tube should then be shaken to cause the mum recovery of Salmonella sp. and
filter to disintegrate (Table I and Figure Pseudomonas aemginosa when DSE broth
1 ). To obtain MPN results per one 1 or is used for primary enrichment. After
per 10 I, 100 ml or 1,000 ml of sample, primary incubation at 40°C, surface loop-
respectively, are filtered for each tube of fuls (scum) (7 mm platinum or nichrome
volume of single-strength DSE medium
contained in a test tube located in the
first row of the multiple tube setup. The
DSE medium in the first row of the five-
tube MPN setup. Additional dilutions are
made by transferring material from tubes
in the first row to tubes farther back in
the setup.
Obtaining results on a per I-gal (3.8-1)
basis requires filtration of 380 ml, and on
a per 10-gal (38-1) basis requires filtration
of 3,600 ml for each tube in the first row.
Where concentration of bacteria is not
usually required, as in municipal waste-
wire loop) are removed from each multi-
ple-tube culture and streaked on each of
two sections of a divided plate of Xylose
lysine desoxycholate agar ( XLD) ir' in order
to isolate colonial growth. The numbered
plates are inverted and incubated at 37°C
for a period not to exceed 24 hr.
Commercial dehydrated XLD agars ( BBL
and Difco) are satisfactory if they are re-
constituted in distilled water in sterile
foil-covered flasks and heated to 88" or
waters, sludges, or primary effluents, the 92°C, respectively. The agar is then
regular transfer of 10 ml of sample to each
• Reeve Angel 984H ultra glass fiber filter, 47
mm, Reeve Angel &. Co., inc., Clifton, N. J.
Mention of trade names does not constitute en-
dorsement or recommendation by EPA.
cooled to 55" to 60°C and distributed in
sterile petri dishes. This laboratory pre-
fers 10-mI portions in each section of a
divided sterile disposable plastic dish
( Figure 1).
2164 Journal WPCF-
142
-------
PATHOGEN DETECTION
i
Sterile
polypropylene
container
3
Filter funnel
for 47-mm 984 H
filtei pad
2 Gallon
sample
of waler
vacuum
flask
Alter filtration filter-pad IS
folded double with forceps
4
5 1000ml pad inserted into 20ml
IxDSE broth lor each of 5-tubes
_in 1st row
2ml to
| 8ml IxDSE in
2nd row
1 ml from
2nd row to
'9ml IxDSE /'
rd row etc /
v Completed MPN Incubated at 40C tor '
I- and 2- days-Secondary medium streaked for
Isolated colonies Irom surface MPN tubes with
7 mm Nichrome 22 gauge loop
6
XLD Agar plate invert plates incubate 37C 20-24 hrs
Loosen cap
Loosen caps
Pick Black centered flf
x colonies to KIA • ,
slants 1000 A. JRed or
—.- < no-change
i Aslant
'H2S
Black
Yellow
Acid
Sti
Pink colonies
rarely
Salmonella sp
reak and Slab butt
Bull
Blue Green
Ps. aerugmosa
Incubate Slants at 35-
Pick flat erose edge 37C 18-20 hr.
grayish alkaline colonies
lo Tech Agar slreak & stab
typical slant
^r Salmonella sp
Slide Serology Purify on XLD Plate
Salmonella "O poly A-l f Urease __ Urease -^tor Isolated pure strains
or Salmonella "H' poly a-z\ Negative Tesl
FIGURE I.~Procedure for isolation of pathogens,
Positive incubated XLD plate cultures
contain typical clear, pink-edged, black-
centered Salmonella colonies, and flat,
mucoid, grayish alkaline, pink erose-edged
Ps. aeruginosa. The Salmonella colonies
are picked to Kligler iron agar ( KIA) or
Triple sugar iron agar slants for typical
appearance, purification, and identity tests.
Ps. aeruginosa colonies are picked to King
A agar slants (Tech agar BBL) for obtain-
ing the bluegreen pyocyanin confirmation
at 40°C (Figure 1).
Typically, Salmonella sp. slant cultures
(streaked and stabbed), incubated over-
-Vol. 46, No. 9, September 1974 2165
143
-------
KENNER AND CLARK
TABLE H.
-Advantage of Ultra-filter 984H Use in Monitoring Suspected
Waters for Salmonella Species
Tvpe of Sample
Stormwater runoff
Stormwater runoff
Activated sludge effluent
M unicipal wastewater
Municipal wastewater
Activated sludge effluent
Mississippi River water,
mile 403.1
Municipal wastewater
Salmonella
(no/ 100 ml)
4.5
<3.0
<3.0
6.2
<3.0
<3.0
43
3.0
Serotypes Found
(no./lOO ml)
S. bareUly1
none
none
Arizona'
none
none
5. ohiow
S. cholerasuis
var. kunzendorf1
Salmonella
(no./gal)
210
7.3
3.6
1,500
110
28
> 11,000
21
Serotypes Found
(no./gal)
S. kottbus"
S. bareilly11
S. jaia4
S. muencheti*
S. group G1
Arizona'
S. anatum1
S. newpori1
S. san diego'1
S. worthington1
S, anatum*
S. derby1
S. newport1
S. blockleyi
S. newport1
S. ohio"
S. derby'
S. meleagridis*
S. cholerasuis
var. kunzendorf
S. newporl*
night at 37 °C, give an unchanged or alka-
line red-appearing slant; the butt is black-
ened by H2S, is acid-yellow, and has gas
bubbles, except for rare species. Typical-
appearing slant cultures are purified by
transferring them to XLD agar plates for
the development of isolated colonies. The
flat or umbonated-appearing colonies with
large black centers and clear pink edges
then are picked to KIA slants (streaked and
stabbed), incubated at 37°C, and urease
tested before the identification procedure
(Figure 1). Urease-negative tubes are re-
tained for presumptive serological tests
and serotype identification.
Typical Tech agar slant cultures for Ps.
aeruginoca that are incubated at 40°C
overnight turn a bluegreen color from
pyocyanin, a pigment produced only by
this species. A reddish-blue color is caused
by the additional presence of pyorubin.
The blue pigment is extractable in chloro-
form and is light blue in color after a few
hours at room temperature. No further
tests are necessary. The count is read di-
rectly from the MPN table.
21GG Journal WPCF
JUSTIFICATION FOR
PROCEDURES
Choice of primary enrichment medium
and secondary isolation agar. Most of the
enrichment media described in contem-
porary literature were designed for the
isolation of pathogens from clinical speci-
mens from ill persons or from samples of
suspected foods, and they work quite well
for those types of samples. When they
are used, however, for the isolation of
pathogens from polluted waters and other
types of environmental samples, such as
soils, they do not prove adequate. En-
richment media that were tested and found
wanting in regard to detection and selec-
tivity were tetrathionate broth (IT), with
and without brilliant green at 41.5°C;
selenite cystine broth at 37°C; selenite
F broth at 37°C; selenite brilliant green,
with and without sulfa, at 37" and 41.5°C;
and Cram-negative broth (CN) at 40" and
41.5°C.
None of the media named worked well
at 37°C for the isolation of Salmonella sp.,
and isolation from wastewaters only oc-
144
-------
PATHOGEN DETECTION
TABLE III.-Percentage of Colony Picks from DSE-XLD Combination Positive
for Salmonella species
Liquid Samples
Municipal wastewater
Stockyard wastewater
Rivers
Mississippi
Ohio
Stormwater runoffs
Activated sludge biological
effluent
Trickling filter effluent
Package plant effluent
Package plant sludge
Chlorinated primary outfall
Creek 1 mile (1.6 km) below
package plant outfall
Dupontfitrfrhs
Feed
Reject
Product- negative
Raw primary sludge
Primary activated sludge
Anaerobic digester sludge
Anaerobic digester sludge
(28 days)
Activated secondary sludge
Total
NO.
15
1
8
2
20
7
6
2
2
2
2
1
1
4
1
3
1
6
84
Total Picks
from XLD
315
36
110
18
386
183
41
SO.
Positive
250
36
a4
14
306
78
55
37
17
37
17
20
16
80
15
78
9
189
1,570
13
16
10
14
8
66
13
65
3
155
1,223
so.
Negative
65
0
26
4
80
25
2!
I
4
21
Percentage
Positive
7Y
100
76
78
79
Range of
Salmonella
coums/100 ml
3.0-1,500
2,100
1.5->300
0.2-1.5
0.1-1.100
76 0.35-140
66
91)
76
43
7 sy
6
8
1-1
2
13
6
34
347
70
50
83
87
83
33
82
average 78
1.8-620
43-240
• 3-43
4.5-12
0.26-1.1
4.3
0.91
13-700
23
79-170
2
11->1 1,000
curred by chance and was purely qualita-
tive. Of the above-named media used in
preliminary tests, selenite brilliant green
sulfa broth (SBGS) at 41.5°C gave the
best isolation of Salmonella sp. from waste-
waters (with and without the addition of
S. typhimurium in known numbers). Of
thirteen wastewater samples tested in SBGS
at 41.5°C, six contained Salmonella or 46
percent were positive. With DSE broth at
40°C, 28 of 28, or 100 percent of waste-
water samples, gave positive results,
Studies were not continued on SBGS me-
dium when it was noted that some lots of
commercially available SBGS seemed to be
selective for Salmonella sp. while others
were not. The medium was then pre-
pared according to the original formula I6
with six different lots of brilliant green
(certified), only one of which was selec-
tive. The use of brilliant green agar as
a selective medium is subject to the same
variability, according to Read and Reyes.17
The main reasons for rejection of TT,
with and without brilliant green, and for
selenite broth's using brilliant green agar
and XLD agar as secondary media are not
only fewer isolations of Salmonella sp., but
also the poor selectivity of these combina-
tions when they are used for monitoring
polluted waters. These combinations' poor
selectivity at 41.5°C is apparent in the
results of Dutka and Bell,16 where the TT
broth-XLD combination yielded 26 percent
confirmation of colonial picks, and selenite
broth-BGA and selenite broth-XLD gave 55
and 56 percent confirmations, respectively.
The authors had similar results. The GN-
XLD combination was poorest for water
samples at 40" and 41.5°C, yielding less
than 10 percent isolations from waste-
waters.
Effect of incubation temperature on iso-
lation of Salmonella sp. In a study of
26 wastewater samples that was conducted
with the DSE multiple tube setups at three
-Vol. 46, No. 9, September 1974 2167
145
-------
KENNER AND CLARK
TABLE IV.-Serotypes of Salmonella Found in
Polluted Waters
v- ! No. of
oerotyue c
otraiu*
1 typhiinurium* 375
2 derby 287
3 cubana 223
4 Chester 20.1
5 title for! 1 188
6 kaltbus | 158
7 bloctlry : 157
8 infautis 141
10 aiiafHiii 127
11 heidtlbrrg 111)
12 Manhattan 97
13 par at y pin B 91
14 iKiiiot J 77
15 thntnpson 63
16iitinjifo»e : 52
17 woMtm'iiVa i 47
IB tnitoichfn ' 45
19 oru»lt'»bt?r£ 44
20 jdft difno i 44
21 kanVIIy i 42
22 tshiotigwr I 41
23 arion ' 41
24 stnflltibtri 39
25 scliworstitgrund t 37
26itiintlnn 33
27 choltrasuis 30
28 iiuni ; 29
29 chnleranti-. var.
kunzcmlorf 29
Other fcrotyiws:
30 albauy 20
31 bcnfiea • 10
32 braendfritp -, 13
33 branctistcr 1
34 brrdcnry 8
35 California 2
36 Jry/iooi ! 14
37 fricilenau 4
38 f ire 25
39 grumpCHiii ' 10
40 /iui/d i 2
41 karlfiwt • 2
42 hatanit . 16
43 iitJiitna > 10
44>,mi 15
45 j«jrm>m 13
46h/c/i/it'M i 17
47 lawita 26
48 meti-aiiritlis 18
49 mi5ji.ni - 14
50 iitwiiiKtnii '
51 iievlaii.ls ; H
52 Itnru'iclt ' 14
53 ii/iui 19
54 pro dm 2
55 retitlinti 26
56 fiitr;(cJK' 15
57 J.iu;/ /will 21
5fl vyA/ •ifdii'iiii 1 ?
00 ic/f(i t $$>u tin \ L
59 jtJir>*6ur^ U
60 taksuny 1ft
61 fruiffsjrr U
62 typhi'Hiiis var.
6-1 K'Si'u^fio 2B
64 wit 3
65 wjrthiuKloii \ 10
Sul) total ; 3.4! 7
Incomplete -erolo^y , 232
Total 3.800
Rank in Rank in
Water ' Human
Illation* • Occurrence*
1 ' 1 and 6t
2 12
3 20
4 19
! 5 1 4
i 6 ; -t
7 1 11
8 ' 9
9 5
10 13
1 1 6
12 14
13 17
14 -t
IS 3
Ib -t
17 16
18 18
19 . 15
19 i 18
20 ! 23
2 1 i —
! 21 ' — t
22 25
i 23 — t
1 24 — t
25 — t
. 26 24
26 -t
1 31 ' — t
40 —1
38 — I
— i
' 23
— I
37 — i
'29 22
40 -t
— t
35 '' -}
40 — J
36 7
38 : 8
34 2 1
i«j t
28 — I
33 •. 25
" : =1
37 j -t
32 ' -t
28 ' -{
'(I I 10
—t
35 — t
39 20
27 -J
40 24
* Hank in human occurrence Table 1. Martin and ICwin^-1'
t Separation of .V. typtiimurinm
done alter initial identification.*.
and var. Copenhagen not
t.Serotypes occurring in human-. 1965-1971. ("enter (or
Disea.-e Control. Salmonella Surveillance. Annual Summarv
1971. Table IX. U. S. DllliW. PUS UllliW PuW. No. vHSM)
73-8184 (Oct. 1972).
°16S Journal WPCF
." A WU JUUlllCil V V A V^'A ^^^
different temperatures, it was found that
100 percent of the samples contained Sal-
monella sp. and Ps. aeruginosa at 40°C.
At 41.5°C, however, only 50 percent or 13
of the samples yielded Salmonella sp., and
at 37°C only 8 percent or 2 of the samples
yielded Salmonella sp.
Effect of enhancement of DSE broth with
a killed culture of S. paratyphi A. In a
study of 84 samples of activated sludge
effluents, trickling filter effluents, package
plant effluents, and stream waters, DSE
broth enhanced with a killed culture of
S. paratyphi A in DSE broth (10 percent
by volume ) yielded isolations in 64 sam-
ples or 74 percent isolated Salmonella sp.,
compared with 48 samples or 57 percent
isolations when the DSE broth was used
without enhancement. An improved iso-
lation of 17 percent was achieved with
enhanced DSE broth.
Ultra-filter. The advantages of ultra-
filter use in testing water samples are illus-
trated in Table II.
RESULTS AND DISCUSSION
Of importance to those who must use
bacteriological tests to obtain Salmonella
sp. and Ps. aeruginosa counts from waters
is the amount of work that must be done
to secure accurate results. Table III pre-
sents the percentage of colony picks made
with the described method that proved to
be Salmonella sp. If there are black-
centered colonies on the XLD plates, more
than 75 percent of the picks will prove to
be Salmonella sp.: thus, the method leads
to less unproductive work. When other
methods were used, the authors have at
times had to pick 50 black-centered col-
onies to obtain only 5 Salmonella sp.
strains. This type of unproductive work
has given the search for pathogens in the
environment an undeserved bad reputation,
and it has caused some to give up.
In Table II it may readily be seen that
in many cases the fault with many tests
has been the testing of an insufficient vol-
ume of sample. Many people think that
it involves too much work, and that only
espensive fluorescent antibody techniques
will work. The problem is, however, to
146
-------
PATHOGEN DETECTION
TABLE V.-Percentage of Various Types of Water Samples Positive for Salmonella species
Type of Sample
Municipal wastcwaters
Municipal primary effluents
(chlorinated)
Activated sludge effluents (clarified)
Activated sludge effluents
Before chlorination
Afrcsidnal,ri5iaiii!»,c6ritaH) mg/1
Trickling filter effluents
Package plant effluents
Creek 1 mile (1.6 km) below package-
plant
Ohio River above Cincinnati public
landing
\Vabasli River
M ississippi Kivcr
Streams collective
Stormwalcr runoff alter heavy rain
Farm wells
Home cisterns suburban
Septic tank sludges
Totals
1 Number of
Samples
28
9
: 4°
5
i 8
I 26
15
I 3
20
4
I 4
31
i 6
4
3
6
! 183
Number
Positive
28
5
29
A
0
15
7
Number
Negative
0
4
11
1
8
'i
3 0
9
3
3
18
3t
0
2
11
i
i*
13
3t
4
3
— i 1
114 69
PcrcentaKC
Positives
100.0
56.0
72.5
80.0
0.0
57.7
46.7
100.0
45.0
75.0
75.0
58.0
50.0
0.0
40.0
5U.O
• Municipal intake.
f Positive by per-gallon technique.
% Negative by per-100 ml technique.
concentrate the bacteria in a 10-gal (38-1)
sample or a 100-gal (380-1 ) sample of
potable or reuse water to obtain results,
and still not require even more expensive
filtration or centrifugation equipment. It
also seems unrealistic to test only extremely
small samples of the water being examined,
because they may not be representative.
Table IV contains a list of Salmonella
serotypes isolated from polluted waters and
ranked according to the frequency of sero-
type isolations. It will be noted that all
of the serotypes except S. typhi were iso-
lated from environmental samples by the
monitoring method, and that only 6 of the
65 serotypes reported were not reported
as occurring in humans in the U. S. over
the period from 1965 to 1971.
Table V summarizes the percentage of
various types of water samples positive
for Salmonella sp. Of interest is the fact
that 100 percent of the municipal waste-
waters tested contain Salmonella sp., that
56 percent of chlorinated primary effluents
tested contain the pathogens, and that 100
percent of chlorinated secondary effluents
are negative for pathogens. There are
more studies scheduled for testing of sec-
ondary and tertiary effluents to obtain
minimal chlorine residuals. Calabro et
al.™ reported that more than 50 attempts
at isolating Salmonella Sp. from septic tank
samples using SBGS-BGSA combinations were
unsuccessful.
Table VI summarizes the isolation of
Ps. aeruginosa from potable water supply,
that is, wells, cisterns, and small municipal
water supply. It should be noted that
fecal coliforms were not detected in most
of these samples. Fecal streptococci counts
were higher than fecal coliform counts
where both tests were used. Ps. aeruginosa
were present in all but three of the tests,
and Salmonella sp. were isolated from
two different cistern samples.
It is of importance to the user of patho-
gen tests that the test be quantitative. In
initial studies on the DSE-XLD combination,
it was important to know if the enrichment
broth would support the growth of a wide
-Vol. 46, No. 9, September 1974 2169
147
-------
KENNER AND CLARK
TABLE Vl.-Isolation of Pseudomonas aeruginosa from Potable Water Supply
Type of Sample
Well 8/16/7 1
Well 8/25/7 I
Well 3/27/72
Well 3/27/72
(chlorinated)
Well 8/23/72
Well 10/ 4/72
Suburban cisterns
8/ 4/72
10/ 9/72*
ll/ 6/72*
ll/ 6/72
11/26/72
Municipal applies
Population served 54,700
3/17/71
6/21/71
7/19/71
6/19/72
10/ 9/72
5/ 8/72
Population served 14,000
5/ 8/72
10/24/72
Population served < 10,000
11/27/72
Ps. acruginosa
Isolation
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
+
, 0
0
+
0
Indicators/LOO ml
Total
Conforms
4
22
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Fecal
Conforms
—
—
<1
<1
0.25
<2
180
IS
<2
<2
3
<1
<1
<1
0.26
<1
<1
<1
<1
<1
Fecal
Streptococci
—
—
—
—
62
46
—
156
22
0
L
28
—
—
—
—
<1
—
—
18
<1
* Salmonella sp. also present in samples.
range of Salmonella serotypes. Laboratory
cultures of S. paratyphi A, S. typhimurium,
S. bredeney, S. oranienberg, S. pullorum, S.
anatum, S. give, and S. worthington were
tested in three enrichment broths. The
time required to isolate each of the above
cultures from an estimated 10 to 20 orga-
nisms/100 ml in buffer water was 48 to 72
hr for S. paratyphi A in TT broth, 24 hr for
DSE broth, and 36 to 48 hr for SBCS broth.
The rest of the cultures were isolated in es-
timated numbers in 14 to 24 hr in TT and
DSE broths. In SBCS broth, S. typhimurium,
S. bredeney, S. anatum, S. give, and S.
worthington required 36 to 48 hr incuba-
tion, and S. pullorum and S. oranienberg
required 48 to 72 hr incubation.
It is impossible to know if 100 percent
of Salmonella sp. in a polluted water
sample are isolated. In tests where lab-
2170 Journal WPCF
oratory cultures have been added in low
numbers to wastewater and treatment
effluent samples, all of the numbers added
were detected, as well as the Salmonella
sp. that were naturally occurring. The
higher the quality of the water (for ex-
ample, secondary or tertiary treatment
effluent, or even potable waters), the better
the possibility of isolation of all the Salmo-
nella serotypes present, as well as Ps.
aeruginosa, a potential pathogen.
SUMMARY
A practical laboratory method is pre-
sented for the simultaneous isolation and
enumeration of Salmonella sp. and Pseudo-
monas aeruginosa from all classes of waters,
including potable water supplies, with a
minimum of interfering false positive iso-
lations. The method allows for the testing
148
-------
PATHOGEN DETECTION
of large volumes of high quality waters,
wherein the absence of indicator bacteria
(that is, total coliforms, fecal coliforms,
and fecal streptococci ), may give a false
sense of security because of the low
volumes of water usually tested. Justifica-
tion for each step of the procedural method
is presented.
ACKNOWLEDGMENTS
Credits. The technical assistance of
Pauline C. Haley in performing the neces-
sary serology for identifying many of the
Salmonella serotypes reported is gratefully
acknowledged.
Authors. Bernard A. Kenner is super-
visory research microbiologist, and Harold
P. Clark is biological technician, Waste
Identification and Analysis Activity of the
Advanced Waste Treatment Research Lab-
oratory, Natonal Environmental Research
Center, U. S. Environmental Protection
Agency, Cincinnati, Ohio.
REFERENCES
1. Federal Water Pollution Control Amendments,
PL 92-500, 86 Stat. 816, 33 U. S. Code
Sec. 1151 et seq. (1972).
2. FWPCA, Section 504 as amended (1972).
3. FWPCA, Section 307 (a) (1972).
4. FWPCA, Section 311 (1972).
5. Quality Assurance Division, Office of Research
and Monitoring, U. S. EPA, "Proc. 1st
Microbiology Seminar on Standardization
of Methods." EPA-R4-73-022 ( Mar. 1973).
6. Kenner, B. A., et al, "Simultaneous Quantita-
tion of Salmonella species and Pseudomonas
oeruginosa. I. Polluted Waters. II. Persist-
ence of Pathogens in Sludge Treated Soils.
III. Analysis of Waste Treatment Sludges
for Salmonella species as a Surveillance
Tool." U. S. EPA, National Environ-
mental Research Center, Cincinnati, Ohio
(Sept. 1971).
7. Moody, M. R., et al., "Pacudonwnax acruginosa
in a Center for Cancer Research. I. Dis-
tribution of Intraspecies Types from
Human and Environmental Sources." Jour.
Inf. Di-seases, 125. 95 (1972).
8. Edmonds, P., et al., "Epidemiology of Pxcudo-
monas aeruginosa in a Burns Hospital. Sur-
veillance by a Combined Typing System."
Appl. Microbiol, 24, 219 (1972).
9. "New Hospital Controls Urged to Stem
Pseudomonas Rise." Clin. Lab. Forum
(Eli Lilly), 2, 1 (May-June 1970).
10. Reitler, R., and Seligmann, R., "Pseudo-
monas aeritpinosa i n Drinking Water."
Jour. Appl. Bacterial., 20, 145 ( 1957).
11. Ringen, L. M., and Drake, C. H., "A Study
of the Incidence of Pseudomonas acruginosa
from Various Natural Sources." Jour.
Bacterial., 64, 841 (1952).
12. Drake, C. H., "Evaluation of Culture Media
for the Isolation and Enumeration of
Pseudomonas aeruginoso." Health Lab.
Sci., 3, 10 (1966).
13. Raj, H., "Enrichment Medium for Selection
of Salmonella from Fish Homogenate."
Appl. Microbiol., 14, 12 (1966).
14. "Standard Methods for the Examination of
Water and Wastewater." 13th Ed., Amer.
Pub. Health Assn., New York, K7. Y. (1971).
15. Taylor, W. L, "Isolation of Shigellae. I.
Xylose Lysine Agars; New hledia for Iso-
lation of Enteric Pathogens." Tech. Bull.
Reg. Med. Technol, 35, 161 (1965).
16. Osborne, W. W., and Stokes, I L., "A Modi-
fied Selenite Brilliant-Green Medium for
the Isolation of Salmonella from Egg Prod-
ucts." Appl. Microbiol, 3, 295 (1955).
17. Read, R. B., Jr., and Reyes, A. L., "Variation
in Plating Efficiency of Salmonellae on
Eight Lots of Brilliant Green Agar." Appl.
Microbiol, 16, 746 ( 1968).
18. Dutka, B. J., and Bell, J. B., "Isolation of
Salmonellae from Moderately Polluted
Waters." Jour. Water Poll. Control fed.,
45, 316 (1973).
19. Martin, W. J., and Ewing, W. H., "Prevalence
of Serotypes of Salmonella." Appl. Micro-
biol, 17, 111 (1969).
20. Calabro, J. F., et al." Recovery of Gram Nega-
tive Bacteria with Hektoen Agar." Jour.
Water Poll. Control Fed., 44, 491 (1972).
-Vol. 46, No. 9, September 1974 2171
149
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Appendix H
Method for the Recovery and Assay of Total Cultivable Viruses from Sludge
1 Introduction
1.f. Scope
This chapter describes the method that must be followed
to produce Class A sludge when virus monitoring under 40
CFR Part 503 is required. The method is designed to dem-
onstrate that sludges meet the requirement that human
enteric viruses (i.e., viruses that are transmitted via the
fecal-oral route) are less than one plaque-forming unit
(PFU) per 4 g of total dry solids.
1.2. Significance
More than 100 different species of pathogenic human
enteric viruses may be present in raw sludge. The pres-
ence of these viruses can cause hepatitis, gastroenteritis
and numerous other diseases. Hepatitis A virus and
caliciviruses are the primary human viral pathogens of
concern, but standard methods for their isolation and de-
tection have not been developed. The method' detailed in
this chapter detects total culturable viruses, which prima-
rily include the enteroviruses (e.g., polioviruses,
coxsackieviruses, echoviruses) and reoviruses.
1.3. Safefy
The sludges to be monitored may contain pathogenic
human enteric viruses. Laboratories performing virus analy-
ses are responsible for establishing an adequate safety
plan and must decontaminate and dispose of wastes ac-
cording to their safety plan and all applicable regulations.
Aseptic techniques and sterile materials and apparatus
must be used throughout the method.
2. Sample Collection
For each batch of sludge that must be tested for viruses,
prepare a composite sample by collecting ten representa-
tive samples of 100 ml each (1,000 mL total) from differ-
ent locations of a sludge pile or at different times from batch
or continuous flow processes. Combine and mix thoroughly
all representative samples for a composite. Batch samples
that cannot be assayed within 8 hours of collection must
be frozen; otherwise, they should be held at 4°C until pro-
cessed. If representative samples must be frozen before
they can be combined, then thaw, combine and mix them
thoroughly just prior to assay. Then remove a 50 ml por-
tion from each composite sample for solids determination
as described in section 3. The remaining portion is held at
4°C while the solids determination is being performed or
frozen for later processing if the assay cannot be initiated
within 8 hours.
3. Determination of Total Dry Solids2
3.1. Weigh a dry weighing pan that has been held in a
desiccator and is at a constant weight. Place the 50 mL
sludge portion for solids determination into the pan and
weigh again.
3.2. Place the pan and its contents into an oven main-
tained at 103-1 05°C for at least one hour.
3.3. Cool the sample to room temperature in a desic-
cator and weigh again.
3.4. Repeat the drying (1 h each), cooling and weigh-
ing steps until the loss in weight is no more than 4% of the
previous weight.
3.5. Calculate the fraction of total dry solids (T) using
the formula:
R = — xm
400
where A is the weight of the sample and dish after drying,
B is the weight of the sample and dish before drying, and
C is the weight of the dish. Record the fraction of dry sol-
ids (T) as a decimal (e.g., 0.04).
4. Total Culturable Virus Recovery from
Sludge
4.1. In froducfion
Total culturable viruses in sludge will primarily be asso-
ciated with solids. Although the fraction of virus associ-
ated with the liquid portion will usually be small, this frac-
'Method D4994-89, ASTM (1992)
•Modified from EPA/600/4-84/013(R7), September 1989 Revision (section 3). This
and other cited EPA publications may be requested from the Biohazard Assess-
ment Research Branch, National Exposure Research Laboratory, U.S. Environ-
mental Protection Agency, Cincinnati, Ohio, USA 45268.
150
-------
tion may vary considerably with different sludge types. To
correct for this variation, samples will first be treated to
bind free virus to solids. Virus is then eluted from the sol-
ids and concentrated prior to assay.
4.2. Conditioning of Suspended Solids
Conditioning of sludge binds unadsorbed total culturable
viruses present in the liquid matrix to the sludge so/ids.
Each analyzed composite sample (from the portion re-
maining after so/ids determination) must have an initial total
dry solids content of at least 16 g. This amount is needed
for positive controls and for storage of a portion of the
sample at -70°C as a backup in case of procedural mis-
takes or sample cytotoxicity.
4.2.1. Preparation
(a) Apparatus and Materials
(a.1) Refrigerated centrifuge capable of attaining 10,000
(g and screw-capped centrifuge bottles with 100 to 1000
m L capacity.
Each bottle must be rated for the relevant centrifugal
force.
(a.2) A pH meter with an accuracy of at least 0.1 pH
unit, equipped with a combination-type electrode.
(a.3) Magnetic stirrer and stir bars.
(b) Media and Reagents
Analytical Reagent or ACS grade chemicals (unless
specified otherwise) and deionized, distilled water (dH2O)
should be used to prepare all reagents. All water used must
have a resistance of greater than 0.5 megohms-cm, but
water with a resistance of 18 megohms-cm is preferred.
(b.1) Hydrochloric acid (HCI) — 1 and 5 M.
Mix 10 or 50 ml of concentrated HCI with 90 or 50 m L of
dH2O, respective/y.
(b.2) Aluminum chloride (AICI3. 6H2O) — 0.05 M.
Dissolve 12.07 g of aluminum chloride in a final volume
of 7000 mL ofdH2O. Autoclave at 121°C for 15 minutes.
(b.3) Sodium hydroxide (NaOH) — 1 and 5 M.
Dissolve 4 or 20 g of sodium hydroxide in a final volume
of 100 mL ofdH2O, respectively.
(b.4) Beef extract (Difco Product No. 0115-i 7-3 or
equivalent).
Prepare buffered 10% beef extract by dissolving 10 g
beef extract, 1.34 g Na2HPO4! 7H 0 and 0.12 g citric acid
in 100 mL ofdH2O. The pH should be about 7.0. Dissolve
by stirring on a magnetic stirrer. Autoclave for 15 minutes
at 121°C.
Do not use paste beef extract (Difco Laboratories Prod-
uct No. 0126) for virus elution. This beef extract tends to
elute cytotoxic materials from sludges.
(b.5) HOCI —0.1%
Add 19 mL of household b/each (Clorox, The Clorox Co.,
or equivalent) to 981 mL ofdH2O and adjust the pH of the
solution to 6-7 with 1 M HCI.
(b.6) Thiosulfate — 2% and 0.02%
Prepare a stock solution of 2% thiosulfate by dissolving
20 g of thiosulfate in a total of 1 liter of dH,0. Sterilize the
solution by autoclaving at 121°C for 75 minutes. Prepare
a working solution of 0.02% thiosulfate just prior to use by
mixing 1 mL of 2% thiosulfate with 99 mL of sterile dH2O.
4.2.2. Conditioning Procedure — Figure 1
gives a flow diagram for the procedure to condition
suspended solids.
(a) Calculate the amount of sample to condition.
Use a graduated cylinder to measure the volume. If the
volumes needed are not multiples of 100 mL (100, 200,
300 mL, etc.), add sterile water to bring the volume to the
next multiple of 100 mL. Each sample should then be
aliquoted into 100 mL portions before proceeding. Samples
must be mixed vigorously just before aliquoting because
solids begin to settle out as soon as the mixing stops. Each
aliquot should be placed into a 250 mL beaker containing
a stir bar.
CAUT/ON: A/ways avoid the formation of aerosols by
slowly pouring samples down the sides of vessels.
(a.1) Calculate the amount needed to measure the en-
dogenous total culturable virus in a composite sludge
sample using the formula:
12
Xts = —
T
where Xts equals the milliliters of sample required to ob-
tain 12 g of total solids and T equals the fraction of total
dry solids (from section 3).3
(a.2) Calculate the amount needed for a recovery con-
trol for each sludge composite from the formula:
Xpc = —
v T
where Xpc equals the milliliters of sample required to ob-
tain 4 g of total solids.
Add exact/y 400 plaque forming units (PFU) of poliovi-
rus to the recovery control sample.
'This formula is based upon the assumption that the density ol the liquid in sludge
is 1 g/mL If the fraction of total dry solids is too low (e.g., less than 0.02), then the
volume of sludge collected must be increased.
151
-------
USPENDED SOLIDS (PER 100 mL)
Mix suspension on magnetic stirrer.
Add 1 mL of 0.05 M Al Cl 3.
ALTED SOLIDS SUSPENSION
I
Continue mixing suspension.
Adjust pH of salted suspension to 3.5
±0.1 with5MHC1.
Mix vigorously for 30 minutes.
H-ADJUSTED SOLIDS SUSPENSION
Centrifuge salted, pH-adjusted suspension
at 2,500 xg for 15 minutes at6 4°C.
Discard supernatant.
Retain solids.
OLIDS
Figure 1.
Flow diagram of method for conditioning suspended
solids.
(a.3) Place 30 mL of 10% buffered beef extract and 70
Lofc
a negative process control.
mL of dH2O into a 250 mL beaker with stir bar to serve as
(a.4) Freeze any remaining composite sample for
backup purposes.
(b) Perform the following steps on each 100 mL ali-
quot from steps 4.2.2a.1 to 4.2.2a.3.
(b.1) Place the beaker on a magnetic stirrer, cover
loosely with aluminum foil, and stir at a speed sufficient to
develop vortex. Add 1 mL of 0.05 M AICI3 to the mixing
aliquot.
The final concentration of AICI3 in each aliquot is ap-
proximately 0.0005 M.
(b.2) Place a combination-type pH electrode into the
mixing aliquot. Adjust the pH of the aliquot to 3.5 ± 0.1 with
5 M HCI. Continue mixing for 30 minutes.
The pH meter must be standardized at pH 7 and 4. When
solids adhere to an electrode, clean it by moving up and
down gent/y in the mixing aliquot.
After adjusting the pH of each sample, rinse the elec-
trode with dH2O and sterilize it with 0.7% HOCI for five
minutes. Neutralize the HOC/ by submerging the electrode
in sterile 0.02% thiosulfate for one to five minutes.
The pH of the aliquot should be checked at frequent in-
tervals. If the pH drifts up, readjust it to 3.5 A 0.1 with 5 M
HCI. If the pH drifts down, readjust it with 5 M NaOH. Use
1 M acid or base for small adjustments. Do not allow the
pH to drop below 3.4.
(b.3) Pour the conditioned aliquot into a centrifuge bottle
and centrifuge at 2,500 xg for 15 minutes at 4°C.
To prevent the transfer of the stir bar into the centrifuge
bottle when decanting the aliquot, ho/d another stir bar or
magnet against the bottom of the beaker. So/ids that ad-
here to the stir bar in the beaker may be removed by ma-
nipulation with a pipette. It may be necessary to pour the
aliquot back and forth several times from the centrifuge
bottle to the beaker to obtain a// the so/ids in the bottle. If a
large enough centrifuge bottle is available, the test sample
aliquots may be combined into a sing/e bottle at this step.
If there is more than one recovery control aliquot, they may
also be combined into another centrifuge bottle.
(b.4) Decant the supernatant into a beaker and discard.
Replace the cap onto the centrifuge bottle. Elute the sol-
ids by following the procedure described in section 4.3.
4.3. Elution of Viruses from Solids
4.3.1. Apparatus and Materials
In this and following sections only apparatus and mate-
rials which have not been described in previous sections
are listed.
(a) Membrane filter apparatus for sterilization — 47
mm diameter Swinnex filter holder and 60 mL slip-tip sy-
ringe (Millipore Corp. Product No. SXOO 047 00 and Becton
Dickinson Product No. 1627 or equivalent).
(b) Disc filters, 47 mm diameter — 3.0, 0.45, and 0.2
m pore size filters (Mentec America, Filterite Div., Duo-
Fine series, Product No. 8025-030, 8025-034 and 8025-
037 or equivalent). Filters may be cut to the proper diam-
eter from sheet filters.
Disassemble a Swinnex filter holder. Place the filter with
a 0.25 m pore size on the support screen of the filter holder
and stack the remaining filters on top in order of increas-
ing pore size. Reassemble and tighten filter holder. Wrap
filter stack in foil and sterilize by autoclaving at 121 °C for
15 min.
Filters stacked in tandem as described tend to clog more
slowly when turbid material is filtered through them. Pre-
pare several filter stacks.
4.3.2. Elution Procedure
A flow diagram of the virus elution procedure is given in
Figure 2.
(a) Place a stir bar and 100 mL of buffered 10% beef
extract into the centrifuge bottle containing the solids (from
section 4.2.2b.4).
If the tept and control samples are divided into more than
one centrifuge bottles, the solids should be combined at
this step.
(b) Place the centrifuge bottle on a magnetic stirrer,
and stir at a speed sufficient to develop a vortex for 30 min
at room temperature.
To minimize foaming (which may inactivate viruses), do
not mix faster than necessary to develop vortex.
152
-------
JOLIDS
Add 100 ml_ of buffered 10% beef extract,
to pH 7.0 ± 0.1 if necessary.
Mix resuspended solids on magnetic stirrer for
30 minuts to elute viruses.
^SUSPENDED SOLIDS
Centrifuge resuspended solids for 30 minutes
at 4°C using a centrifugal force of 10,000 x g
Discard solids
Retain eluate (supernatant).
ILUATE
Filter eluate through 47 mm Filterite filter
stack of 3.0, 0.45, and 0.25 urn pore sizes
with the 025 fim pore size on support screen of
filter and remaining filters on top in order of increa;
ing pore size.
ALTERED ELUATE
Figure 2. Flow diagram of method for elution of virus from solids.
(c) Remove the stir bar from each bottle with a long
sterile forceps or a magnet retriever and centrifuge the
solids-eluate mixture at 10,000 (g for 30 minutes at 4°C.
Decant supernatant fluid (eluate) into a beaker and dis-
card the solids.
Determine if the centrifuge bottle is appropriate for the
centrifugal force that will be applied.
Cen trifuga tion at 10,000 (g is normally required to clarify
the sludge samples sufficiently to force the resulting su-
pernatant through the filter stacks.
(d) Place a filter holders that contains filter stacks (from
section 4.3.1 b) onto a 250 mL Erlenmeyer receiving flask.
Load 50 mL syringes with the supernatants from step
4.3.2c. Place the tip of the syringe into the filter holder and
force the supernatant through the filter stacks into 250 mL
receiving flasks.
Prior to use, pass 15 mL of 3% beef extract through each
filter holder to minimize non-specific adsorption of viruses.
Prepare 3% beef extract by mixing 4.5 mL of 10% beef
extract and 10.5 mL of dH2O. Take care not to break off
the tip of the syringe and to minimize pressure on the re-
ceiving flask because such pressure may crack or topple
the flask. If the filter stack begins to clog badly, empty the
loaded syringe into the beaker containing unfiltered elu-
ate, fill the syringe with air, and inject air into filter stack to
force residual eluate from the filters. Continue the filtration
procedure with another filter holder and filter stack. Dis-
card contaminated filter holders and filter stacks. This pro-
cedure may be repeated as often as necessary to filter the
entire volume of supernatant. Disassemble each filter
holder and examine the bottom 0.25 m filters to be certain
they have not ruptured. If a bottom filter has ruptured, re-
peat the step with new filter holders and filter stacks.
Proceed immediately to section 4.4.
4.4 Organic Flocculation
This organic flocculation concentration procedure
(Katzenelson et al., 1976) is used to reduce the number of
cell cultures needed for assays by concentrating total
culturable viruses in the eluate. The step significantly re-
duces costs associated with labor and materials.
Floe formation capacity of the beef extract reagent must
be pretested, Because some beef extract lots may not pro-
duce sufficient floe, each new lot must be pretested to de-
termine virus recovery. This may be performed by spiking
100 mL ofdH2O with a known amount of poliovirus in the
presence of a 47 mm nitrocellulose filter. This sample
should be conditioned using section 4.2 above to bind vi-
rus to the filter. Virus should then be eluted from the filter
using the procedure in section 4.3, and concentrated and
assayed using the following procedures. Any lot of beef
extract not giving a overall recovery of at least 50% should
not be used.
4.4.1 Media and Reagents
In this and following sections only media and reagents
which have not been described in previous sections are
listed.
(a) Sodium phosphate, dibasic (Na.HPO, • 7H.O) —
0.15 M.
Dissolve 40.2 g of sodium phosphate in a final volume
of 1000 mL Autoclave at 121 °C for 75 minutes.
4.4.2 Virus Concentration Procedure
A flow diagram for the virus concentration procedure is
given in Figure 3.
(a) Pour the filtered eluates from the test sample, re-
covery control and negative process control from section
4.3.24 into graduated cylinders, and record their volumes.
Transfer the samples into separate 600 mL beakers and
cover them loosely with aluminum foil.
(b) For every 3 mL of beef extract eluate, add 7 mL of
dH2O to the 600 mL beakers. Add stir bars to each beaker.
The concentration of beef extract is now 3%. This dilu-
tion is necessary because 10% beef extract often does
not process well by the organic flocculation concentration
procedure.
(c) Record the total volume of the diluted eluates.
Place the beakers onto a magnetic stirrer, cover loosely
with aluminum foil, and stir at a speed sufficient to develop
vortex.
153
-------
ILTERED ELUATE
Add sufficient volume of dH2O TO Filtered
eluate to reduce concentration of beef
extract from 10% to 3%. Record total volume
of the diluted beef extract.
ULUTED, FILTERED ELUATE
Mix diluted eluate on a magnetic stirrer.
Adjust the pH of the eluate to 3.5 ± 0.1 with
1 M HC1. A precipitate (floe) will form.
Continue mixing for 30 minutes.
LOCCULATED ELUATE
Centrifuge flocculated eluate at 2,500 xg for 15
minutes at 4°C.
Discard supernatant.
Retain floe.
'LOG FROM ELUATE
Add 0.15 M Na-jHPO, to floe, using 1/20th of
the recorded volume of the diluted 3% beef
extract.
Mix suspended floe on magnetic stirrer until
floe dissolves.
Adjust to a pH of 7.0 to 7.5.
IISSOLVED FLOC
See section 5 for virus assay procedure.
DISSOLVED FLOC FOR VIRUSES
Figure 3. Flow diagram of method for concentration of viruses from
beef extract.
To minimize foaming (which may inactivate viruses), do
not mix faster than necessary to develop vortex.
(d) For each diluted, filtered beef extract, insert a ster-
ile combination-type pH electrode and then add 1 M HCI
slowly until the pH of the extract reaches 3.5 ± 0.1. Con-
tinue to stir for 30 minutes at room temperature.
The pH meter must be standardized at pH 4 and 7. Ster-
ilize the electrode by treating it with 0.1% HOC/for five
minutes. Neutralize the HOC/ by treating the electrode with
0.02% sterile thiosulfate for one to five minutes.
A precipitate will form. If the pH is accidentally reduced
below 3.4, add 1 M NaOH until it reaches 3.5± 0.7. Avoid
reducing the pH below 3.4 because some inactivation of
virus may occur.
(e) Pour the contents of each beaker into 1,000 mL
centrifuge bottles. Centrifuge the precipitated beef extract
suspensions at 2,500 (g for 15 minutes at 4°C. Pour off
and discard the supernatants.
To prevent the transfer of the stir bar into a centrifuge
bottle, ho/d another stir bar or magnet against bottom of
the beaker when decanting contents.
(f) Place stir bars into the centrifuge bottles that con-
tains the precipitates. To each, add a volume of 0.15 M
Na2HPO4. 7H2O equal to exactly 1120 of the volume re-
corded in step 4.4.2c. Place the bottles onto a magnetic
stirrer, and stir slowly until the precipitates have dissolved
completely.
Support the bottles as necessary to prevent toppling.
Avoid foaming which may inactivate or aerosolize viruses.
The precipitates may be partially dissipated with sterile
spatulas before or during the stirring procedure.
(g) Measure the pH of the dissolved precipitates.
If the pH is above or below 7.0-7.5, adjust to that range
with either 1 M HCI or 1 M NaOH.
(h) Freeze exactly one half of the dissolved precipi-
tate test sample (but not the positive and negative con-
trols) at -70°C. This sample will be held as a backup to use
should the sample prove to be cytotoxic. Record the re-
maining test sample volume (this volume represents 6 g
of total dry solids). Refrigerate the remaining samples im-
mediately at 4°C until assayed in accordance with the in-
structions given in section 5 below.
If the virus assay cannot be undertaken within eight
hours, store the remaining samples at -70°C.
5. Assay for Plaque-forming Viruses4
5.1 Introduction
This section outlines procedures for the detection of vi-
ruses in sludge by use of the plaque assay system. The
system uses an agar medium to localize virus growth fol-
lowing attachment of infectious virus particles to a cell
monolayer. Localized lesions of dead cells (plaques) de-
veloping some days after viral infection are visualized with
the vital stain, neutral red, which stains only live cells. The
number of circular unstained plaques are counted and re-
ported as plaque forming units, whose number is propor-
tional to the amount of infectious virus particles inoculated.
The detection methodology presented in this section is
geared towards laboratories with a small-scale virus as-
say requirement. Where the quantities of cell cultures,
media and reagents set forth in the section are not suffi-
cient for processing the test sample concentrates, the pre-
scribed measures may be increased proportionally to meet
the demands of more expansive test regimes.
'ModifiedforEPA/600/4-84/013(RH), March 1988 Revision
154
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5.2 Plaque Assay Procedure
5.2.1 Apparatus and materials.
(a) Waterbath set at 50 ± 1 °C.
Used for maintaining the agar temperature (see section
5.2.2J).
5.2.2 Media and Reagents.
(a) ELAH — 0.65% lactalbumin hydrolysate in Earle's
base.
Dissolve 6.5 g of tissue culture, highly soluble grade lac-
talbumin hydrolysate (Gibco BRL Product No. 11800 or
equivalent) in 1 L of Earle's base (Gibco BRL Product No.
14015 or equivalent) prewarmed to 50-60%C. Sterilize
ELAH through a 0.22 m filter stack and store for up to two
months at 4°C.
(b) Wash medium — Add 1 ml of penicillin-strepto-
mycin stock (see section 6.4.2e.1 for preparation of antibi-
otic stocks), 0.5 mL of tetracycline stock and 0.2 mL of
fungizone stock per liter to ELAH immediately before wash-
ing of cells.
(c) HEPES — 1 M (Sigma Chemical Product No. H-
3375 or equivalent).
Prepare 50 m L of a 1 M solution by dissolving 11,92 g of
HEPES in a final volume of 50m L dH2O. Sterilize by auto-
claving at 121 °C for 15 min.
(d) Sodium bicarbonate (NaHCO3) — 7.5% solution.
Prepare 50 m L of a 7,5% solution by dissolving 3,75 g of
sodium bicarbonate in a final volume of 50 mL dH2O. Ster-
ilize by filtration through a 0.22 m filter.
(e)
tion.
Magnesium chloride (MgCI2! 6H20) — 1 .0% solu-
Prepare 50 mLofal .0% solution by dissolving 0.5 g of
magnesium chloride in a final volume of 50 mL dH2O. Ster-
ilize by autoclaving at 121 °C for 15 min.
(f) Neutral red solution — 0.333%, 100 mL volume
(GIBCO BRL Product No. 630-5330 or equivalent).
Procure one 100 m L bottle.
Some neutral red solutions are cytotoxic. All new solu-
tions should be tested prior to their use for assaying sludge
samples, Testing may be performed by assaying a stock
of poliovirus with known titer using this plaque assay pro-
cedure.
(g) Bacto skim milk (Difco Laboratories Product No.
0032-01 or equivalent).
Prepare 100 mL of 10% skim milk in accordance with
directions given by manufacturer.
(h) Preparation of Medium 199.
The procedure described is forpreparation of 500 mL of
Medium 199 (GIBCO BRL Product No. 400- 11 00 or equiva-
lent) at a 2X concentration. This procedure will prepare
sufficient medium for at least fifty 6 oz glass bottles or eighty
25 en? plastic flasks.
(h.1) Place a three inch stir bar into a one liter flask.
Add the contents of a 1 liter packet of Medium 199 into the
flask. Add 355 mLof dH2O. Rinse medium packet with three
washes of 20 mL each of dH O and add the washes to the
flask.
Note that the amount ofdH2O is 5% less than desired
final volume of medium.
(h.2) Mix on a magnetic stirrer until the medium is com-
pletely dissolved. Filter the reagent under pressure through
a filter stack (see section 6.2.6).
7esf each lot of medium to confirm sterility before the lot
is used (see section 6.5). Each batch may be stored for
two months at 4°C.
(i) Preparation of overlay medium for plaque assay.
The procedure described is for preparation of 100 mL of
overlay medium and will prepare sufficient media for at
/east ten 6 oz glass bottles or twenty 25 oz plastic f/asks
when mixed with the agar prepared in section 5.2.2J.
(i.1) Add 79 mL of Medium 199 (2X concentration) and
4 mL of serum to a 250 mL flask.
(i.2) Add the following to the flask in the order listed,
with swirling after each addition: 6 mL of 7.5% NaHCO3, 2
mL of 1% MqfJ amL of 0.333% neutral red solution, 4
mL of 1 M HEPES, 0.2 mL of penicillin-streptomycin stock
(see section 6.4.2e for a description of antibiotic stocks),
0.1 mL of tetracycline stock, and 0.04 mL of fungizone
stock.
(i.3) Place flask with overlay medium in waterbath set
at36±1°C.
(j) Preparation of overlay agar for plaque assay.
(j.l) Add 3 g of agar (Sigma Chemical Product No. A-
991 5 or equivalent) and 100 m LofdH2Oto a 250 mL flask.
Melt by sterilizing the agar solution in an autoclave at 121 °C
for 15 min.
(j.2) Cool the agar to 50°C in waterbath set at 50 ±
(k) Preparation of agar overlay medium.
(k.1) Add 2 mL of 10% skim milk to overlay medium
prepared in section 5.2.2L
(k.2) Mix equal portions of overlay medium and agar by
adding the medium to the agar flask.
To prevent solidification of the liquified agar, limit the
portion of agar overlay medium mixed to that volume which
can be dispensed in 10 min.
155
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5.2.3 Procedure for Inoculating Test Samples.
Section 6.6 provides the procedures for the preparation
of cell cultures used for the virus assay in this section.
Cell cultures used for virus assay are generally found to
be at their most sensitive level between the third and sixth
days after initiation. Those older than seven days should
not be used.
(a) Decant and discard the growth medium from pre-
viously prepared cell culture test vessels.
To prevent splatter, a gauze-covered beaker may be used
to collect spent medium.
The medium is changed from one to four hours before
cultures are to be inoculated and carefully decanted so as
not to disturb the cell monolayer.
(b) Replace discarded medium with an equal volume
of wash medium (from section 5.2.2b) on the day the cul-
tures are to be inoculated.
To reduce shock to cells, prewarm the maintenance
medium to 36.5 ± 1 °C before placing it onto the cell mono-
layer.
To prevent disturbing cells with the force of the liquid
against the cell monolayer, add the maintenance medium
to the side of cell culture test vessel opposite the cell mono-
layer.
(c) Identify cell culture test vessels by coding them
with an indelible marker. Return the cell culture test ves-
sels to a 36.5 ± 1 °C incubator and hold at that temperature
until the cell monolayers are to be inoculated.
(d) Decant and discard the wash medium from cell
culture test vessels.
Do not disturb the cell monolayer.
(e) Inoculate BGM cultures with the test sample and
positive and negative process control samples from sec-
tion 4.4.2h. Divide each sample onto a sufficient number
of BGM cultures to ensure that the inoculum volume is no
greater than 1 ml for each 40 cm2 of surface area. Use
Table 1 as a guide for inoculation size.
Avoid touching either the cannula or the pipetting de-
vice to the inside rim of the cell culture test vessels to avert
the possibility of transporting contaminants to the remain-
ing culture vessels.
If the samples are frozen, thaw them rapidly by placing
them in warm wafer. Samples should be shaken during
the thawing process and removed from the warm wafer as
soon as the last ice crystals have dissolved.
(e.1) Inoculate BGM cultures with the entire negative
process control sample using an inoculum volume per ves-
sel that is appropriate for the vessel size used.
Table 1. Guide for Virus Inoculation, Suspended Cell Concentration
and Overlay Volume of Agar Medium
Vessel Type
1 oz glass
bottle'
25 cm2 plastic
flask
6 oz glass
bottle
75 cm2 plastic
flask
Volume of
Virus
Inoculum
(ml)
V=0.8'P'C
0.1
0.1-0.5
0.5-I .0
1 B-2.0
Volume of
Agar Overlay
Medium (mL)
5
10
20
30
Total Number
of Cells
1 x107
2x 107
4x 107
6x10'
'Size is given in oz only when it is commercially designated in that unit.
(e.2) Inoculate two BGM cultures with an appropriate
volume of 0.15 M NaJHPO, • 7HQ.preadjust.ed to pH 7.0-
7.5 and spiked with 20-40 PFUof poliovirus. These cul-
tures will serve as a culture sensitivity control.
(e.3) Remove a volume of the test sample concentrate
exactly equal to 1/6th (i.e., 1 g of total dry solids) of the
volume recorded in section 4.4.2h. Spike this subsample
with 20-40 PFU of poliovirus. Inoculate the subsample onto
one or more BGM cultures using a inoculum volume per
vessel that is appropriate for the vessel size used. These
cultures will serve as controls for cytotoxicity (see section
5.2.5b).
(e.4) Inoculate BGM cultures with the entire recovery
control sample using an inoculum volume per vessel that
is appropriate for the vessel size used.
(e.5) Record the volume of the remaining 5/6th portion
of the test sample. This remaining portion represents a
total dry solids content of 5 g. Inoculate the entire remain-
ing portion (even if diluted to reduce cytotoxicity) onto BGM
cultures using an inoculum volume per vessel that is ap-
propriate for the vessel size used. Inoculation of the entire
volume is necessary to demonstrate a virus density level
of less than 1 PFU per 4 g total dry solids.
(f) Rock the inoculated cell culture test vessels gen-
tly to achieve uniform distribution of inoculum over the sur-
face of the cell monolayers. Place the cell culture test ves-
sels on a level stationary surface at room temperature (22-
25%) so that the inoculum will remain distributed evenly
over the cell monolayer.
(g) Incubate the inoculated cell cultures at room tem-
perature for 80 min to permit viruses to adsorb onto and
infect cells and then proceed immediately to section 5.2.4.
It may be necessary to rock the vessels every 15-20 min
during the 80 min incubation to prevent cell death in the
middle of the vessels from dehydration.
5.2.4 Procedure for Overlaying Inoculated
Cultures with Agar
If there is a likelihood that a test sample will be toxic to
cell cultures, the cell monolayer should be treated in ac-
cordance with the method described in section 5.2.5b.
156
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(a) To each cell culture test vessel, add the volume of
warm (42-46°C) agar overlay medium appropriate for the
cell surface area of the vessels used (see Table 1).
The preparation of the overlay agar and the agar over-
lay medium must be made far enough in advance so that
they will be at the right temperature for mixing at the end
of the 80 min inoculation period.
To prevent disturbing cells with the force of the liquid
against the cell monolayer, add the agar overlay medium
to the side of the cell culture test vessel opposite the cell
monolayer,
(b) Place cell culture test vessels, monolayer side
down, on a level stationary surface at room temperature
(22-25°C) so that the agar will remain evenly distributed
as it solidifies. Cover the vessels with a sheet of aluminum
foil, a tightly woven cloth, or some other suitable cover to
reduce the light intensity during solidification and incuba-
tion. Neutral red can damage or kill tissue culture cells by
light-induced crosslinking of nucleic acids.
Care must be taken to ensure that all caps on bottles
and f/asks are tight; otherwise, the gas sea/will not be
complete and an erroneous virus assay will result.
Agar will fully solidify within 30 min.
(c) After 30 min, invert the cell culture test vessels
and incubate them covered in the dark at 36.5 ± 1°C.
5.2.5. Plaque Counting Technique
(a) Count, mark and record plaques in cell culture test
vessels on days one, two, three, four after adding the agar
overlay medium. Plaques should be counted quickly using
a lightbox (Baxter Product No. 85080-I or equivalent) in a
darkened room. Most plaques should appear within 1 week.
Depending on the virus density and virus types present
in the inoculated sample, rescheduling of virus counts at
plus or minus one day may be necessary. Virus titers are
calculated from the total plaque count. Note that not all
plaques will be caused by viruses.
(b) Determine if samples are cytotoxic by macroscopic
examination of the appearance of the cell culture mono-
layer (compare negative, positive and recovery controls
from section 5.2.3e with spiked and unspiked test samples)
after one to four days of incubation at 36.5 ± 1 °C. Samples
show cytotoxicity if cell death is observed on test and re-
covery control samples prior to its development on posi-
tive controls. Cytotoxicity should be suspected when the
agar color is more subdued, generally yellow to yellow-
brown. This change in color results in a mottled or blotchy
appearance instead of the evenly diffused "reddish" color
observed in "healthy" cell monolayers. Cytotoxicity may
also cause viral plaques to be reduced in number or to be
difficult to distinguish from the surrounding monolayer. To
determine if this type of cytotoxicity is occurring, compare
the two types of positive controls (section 5.2.3e). If
samples are cytotoxic, do not proceed to the next steps.
Re-assay a small amount of the remaining sample using
1:2,1:4 and 1:8 dilutions. Then re-assay the remaining
sample as specified in section 5.2.3 using the dilution which
removes cytotoxicity and the specified number of flasks
times the reciprocal of the dilution.
A small amount of sample may be tested for cytotoxicity
prior to a full assay.
(c) Examine cell culture test vessels as in step 5.2.5a
on days six, eight, twelve and sixteen.
If no new plaques appear at 1 6 days, proceed with step
5.2.6; otherwise continue to count, mark and record plaques
every two days until no new plaques appear between
counts and then proceed with step 5.2.6.
Inoculated cultures should always be compared to
uninoculated control cultures so that the deterioration of
the cell monolayers is not recorded as plaques.
If negative process controls develop plaques or if posi-
tive controls fail to develop plaques, stop a// assays until
the source of the problem is corrected.
Samples giving plaque counts that are greater than 2
plaques per cm2 should be diluted and replated.
5.2.6. Virus Plaque Confirmation Procedure
The presence of virus in plaques must be confirmed for
all plaques obtained from sludge samples. Where more
than ten plaques are observed, it is allowable to confirm at
least ten well-separated plaques per sample or 10% of the
plaques in a sample, whichever is greater. Flasks may be
discarded after samples are taken for plaque confirma-
tion.
(a) Apparatus, Materials and Reagents
(a.1) Pasteur pipettes, disposable, cotton plugged —
229 mm (9 inches) tube length and rubber bulb — 1 ml_
capacity.
Flame each pipette gently about 2 cm from end of the tip
until the tip bends to an approximate angle of 45%. Place
the pipettes into a 4 liter beaker covered with aluminum
foil and sterilize by autoclaving or by dry heat.
(a.2) 16 x 150 mm Cell Culture Tubes Containing BGM
Cells.
See section 6.6 for the preparation of cell culture tubes.
(a.3). Tissue culture roller apparatus — 1/5 rpm speed
(New Brunswick Scientific Product No. TC-1 or equivalent)
with culture tube drum for use with roller apparatus (New
Brunswick Scientific Product No. ATC-TT16 or equivalent).
(a.4) Freezer vial, screw-capped (with rubber insert) or
cryogenic vial — 0.5-I dram capacity.
157
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(b) Procedure for obtaining viruses from plaque.
In addition to plaques from sludge samples, perform the
procedure on at least three negative regions of negative
process control f/asks and at /east three plaques from posi-
tive control f/asks.
(b.1) Place a rubber bulb onto the upper end of a cot-
ton-plugged Pasteur pipette and then remove the screw-
cap or stopper from a plaque bottle.
(b.2) Squeeze the rubber bulb on the Pasteur pipette to
expel the air and penetrate the agar directly over the edge
of a plaque with the tip of the pipette. Gently force the tip
of the pipette through the agar to the surface of the vessel,
and scrape some of the cells from the edge of the plaque.
Repeatedly scratch the surface and use gent/e suction
to insure that virus-cell-agar plug enters the pipette.
(b.3) Remove the pipette from the plaque bottle and
tightly replace the cap or stopper.
(c) Procedure for inoculating cell cultures with agar
plugs from negative control samples and from plaques.
(c.1) Prepare plaque conformation maintenance me-
dium by adding 5 ml of serum and 5 ml_ of dH2O per 90
mL of wash medium (section 5.2.2b) on day samples are
to be tested.
(c.2) Pour the spent medium from cell culture tubes and
discard the medium. Replace the discarded medium with
2 mL of the plaque conformation maintenance medium.
Label the tubes with sample and plaque isolation identifi-
cation information.
To prevent splatter, a gauze-covered beaker may be used
to collect spent medium.
To reduce shock to cells, warm the maintenance me-
dium to 36.5 ± 1 °C before p/acing on cell monolayer.
To prevent disturbing cells with the force of the liquid
against the cell monolayer, add the maintenance medium
to the side of cell culture test tube opposite the cell mono-
layer. Note that cells will be on/y on the bottom inner sur-
face of the culture tube relative to their position during in-
cubation.
(c.3) Remove the cap from a cell culture tube and place
the tip of a Pasteur pipette containing the agar plug from
section 5.2.6b.3 into the maintenance medium in the cell
culture tube. Force the agar plug from the Pasteur pipette
by gently squeezing the rubber bulb. Withdraw and dis-
card the pipette, and replace and tighten down the screw-
cap on the culture tube.
Tilt cell culture tube as necessary to facilitate the proce-
dure and to avoid scratching the cell sheet with the pi-
pette.
Squeeze bulb repeated/y to wash contents ofpipetfe info
the maintenance medium.
(c.4) Place the cell culture tubes in the drum used with
the tissue culture roller apparatus. Incubate the cell cul-
tures at 36.5 ± 1°C while rotating at a speed of 1/5 rpm.
Examine the cells daily microscopically for 1 week for evi-
dence of cytopathic effects (CPE).
CPE may be identified as cell disintegration or as
changes in cell morphology. Rounding-up of infected cells
is a typical effect seen with enteric virus infections. How-
ever, uninfected cells round up during mitosis and a sample
should not be considered positive unless there are signifi-
cant clusters of rounded-up cells over and beyond what is
observed in the uninfected controls. If there is any doubt
about the presence of CPE or if CPE appears late (i.e., on
day 6 or 7), the conformation process should be repeated
by transferring 0.2 mL of the medium in the culture tube to
a freshly prepared tube.
Incubation of BGM cells in roller apparatus for periods
greater than 1 week is not recommended as cells under
these conditions fend to die-off if he/d longer.
If tubes receiving agar plugs from negative controls de-
velop CPE or tubes receiving agar plugs from positive con-
trols fail to develop CPE, stop all assays until the source of
the failure is identified and corrected.
Tubes developing CPE may be stored in a -70°C freezer
for additional optional tests (e.g., the Lim Benyesh-Melnick
identification procedure.5
(c.5) Determine the fraction of confirmed plaques (C)
for each sludge sample tested. Calculate "C" by dividing
the number of tubes inoculated with agar plugs from
plaques that developed CPE by the total number of tubes
inoculated (i.e., if CPE was obtained from 17 of 20 plaques,
C = 0.85).
5.2.7 Calculation of virus titer.
If more than one composite sample was assayed, aver-
age the titer of all composite samples and report the aver-
age titer and the standard deviation for each lot of sludge
tested.
(a) If the entire remaining portion of a test sample was
inoculated onto BGM cultures as described in section
5.2.3e.5, calculate the virus titer (V) in PFU per 4 g of total
dry solids according to the formula:
V=0.8xPxC
where P is the total number of plaques in all test vessels
tor that sample and C equals the fraction of confirmed
plaques.
(b) If the sample was diluted due to high virus levels
(e.g., when the virus density of the input to a process is
5For more information see EPA/600/4-84/013(R12), May 1986 Revision
158
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being determined; see section 5.2.5c), calculate the virus
titer (V) in PFU per 4 g total dry solids with the formula:
V = 0.8* — xDXC
where P is the total number of plaques in all test vessels
for dilution series, I is the volume (in mL) of the dilution
inoculated, D is reciprocal of the dilution made on the in-
oculum before plating, S is the volume of the remaining
portion of the test sample (as recorded in section 5.2.3e.5)
and C is the fraction of confirmed plaques.
5.2.8 Calculate the percent of virus recovery (R)
using the formula:
tf = — jclOO
400
where P is the total number of plaques on all test vessels
inoculated with the recovery control.
6. Cell Culture Preparation and
Maintenance6
6.1. Introduction
This section outlines procedures and media for cultur-
ing the Buffalo green monkey (BGM) cell line and is in-
tended for the individual who is experienced in cell culture
preparation. BGM cells are a continuous cell line derived
from African Green monkey kidney cells. The characteris-
tics of this line were described by Barren et a/. (1970). Use
of BGM cells for recovering viruses from environmental
samples was described by Dahling et a/. (1974). The me-
dia and methods recommended are the results of the BGM
cell line optimization studies by Dahling and Wright (1986).
The BGM cell line can be obtained by qualified laborato-
ries from the Biohazard Assessment Research Branch,
National Exposure Research Laboratory, U. S. Environ-
mental Protection Agency, Cincinnati, Ohio, USA 45268.
Although BGM cells will not detect all enteric viruses that
may be present in sludges, the use of this cell line alone is
sufficient to meet the requirements of 40 CFR Part 503.
6.2. Apparatus and Materials
6.2.1. Glassware, Pyrex (Corning Product No.
1395 or equivalent).
Storage vessels must be equipped with airtight closures.
6.2.2. Autoclavable inner-braided tubing with metal
quick- connect connectors or with screw
clamps for connecting tubing to equipment
to be used under pressure.
Quick-connect connectors can be used only after equip-
ment has been properly adapted.
6.2.3. Positive pressure air, nitrogen or 5% CO, source
equipped with pressure gauge.
Pressure sources from laboratory air lines and pumps
must be equipped with an oil filter. The source musf not
deliver more pressure to the pressure vessel than is rec-
ommended by manufacturer.
6.2.4. Dispensing pressure vessel — 5 or 20 liter ca-
pacity (Millipore Corp. Product No. XX67 OOP
05 and XX67 OOP 20 or equivalent).
6.2.5. Disc filter holders — 142 mm or 293 mm diam-
eter (Millipore Corp. Product No. YY30 142 36
and YY30 293 16 or equivalent).
Use only pressure type filter holders.
6.2.6. Sterilizing filter stacks — 0.22 m pore size
(Millipore Corp. Product No. GSWP 142 50 and
GSWP 293 25 or equivalent). Fiberglass
prefilters (Millipore Corp. Product No. AP15 142
50 or AP15 293 25 and AP20 142 50 or AP20
293 25 or equivalent).
StackAP20 and AP15 prefilters and 0.22 jim membrane
filter into a disc filter holder with AP20 prefilter on top and
0.22 m membrane filter on bottom.
Always disassemble the filter stack after use to check
the integrity of the 0.22 m filter. Refilter any media filtered
with a damaged stack.
6.2.7. Positively-charged cartridge filter — 10 inch
(Zeta plus TSM, Cuno Product No. 45134-01-
600P or equivalent). Holder for cartridge filter
with adaptor for 10 inch cartridge (Millipore Corp.
Product No. YY16 012 00 or equivalent).
6.2.8. Culture capsule filter (Gelman Sciences Prod-
uct No. 12140 or equivalent).
6.2.9. Cell culture vessels — Pyrex, soda or flint glass
or plastic bottles and flasks or roller bottles (e.g.,
Brockway Product No. 1076-09A, 1925-02,
Corning Product No. 25100-25, 2511 O-75,
25120-1 50, 25150-1 750 or equivalent).
Vessels must be made from clear glass or plastic to al-
low observation of the cultures and be equipped with air-
tight closures. Plastic vessels must be treated by the manu-
facturer to allow cells to adhere properly.
6.2.10. Screw caps, black with rubber liners (Brockway
Product No. 24-414 for 6 oz bottles7 or equiva-
lent).
'Modified from EPA/600/4-84/Oi3(R9), January 1987 Revision
'Size is given in oz only when it is commercially designated in that unit.
159
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Caps for larger culture bottles usually supplied with
bottles.
6.2.11. Roller apparatus Bellco Product No. 7730 or
equivalent).
6.2.12. Incubator capable of maintaining the tempera-
ture of cell cultures at 36.5 ± 1 °C.
6.2.13. Waterbath, equipped with circulating device to
assure even heating at 36.5 ± 1 °C.
6.2.14. Light microscope, with conventional light source,
equipped with lenses to provide 40X, 100X, and
400X total magnification.
6.2.15. Inverted light microscope equipped with lenses
to provide 40X, 100X, and 400X total magnifi-
cation.
6.2.16. Cornwall syringe pipettors, 2,5 and 10 ml sizes
(Cut-tin Matheson Scientific Product No. 221-
861,221-879, and 221-887 or equivalent).
6.2.17. Brewer-type pipetting machine (Curtin Matheson
Scientific Product No. 138-1 07 or equivalent).
6.2.18. Phase contrast counting chamber (hemocytom-
eter) (Cur-tin Matheson Scientific Product No.
158-501 or equivalent).
6.2.19. Conical centrifuge tubes, sizes 50 ml_ and 250
ml.
6.2.20. Rack for tissue culture tubes (Bellco Product No.
2028 or equivalent).
6.2.21. Bottles, aspirator-type with tubing outlet, size
2,000 mL
Bottles for use with pipetting machine.
6.2.22. Storage vials, size 2 mL
Via/s must withstand temperatures to -70°C.
6.3. Media and Reagents
6.3.1. Sterile fetal calf, gammagobulin-free newborn
calf or iron-supplemented calf serum, certified
free of viruses, bacteriophage and mycoplasma
(GIBCO BRL or equivalent).
Test each lot of serum for cell growth and toxicity before pur-
chasing. Serum should be stored at -20°C for long-term stor-
age. Upon thawing, each bottle should be heat-inactivated at
56°C for 30 min and stored at 4°C for short term use.
6.3.2. Trypsin, 1:250 powder (Difco Laboratories Prod-
uct No. 0152-1 5-9 or equivalent) or trypsin, 1:300
powder (BBL Microbiology Systems Product No.
12098 or equivalent).
6.3.3. Sodium (tetra) ethylenediamine tetraacetate
powder (EDTA), technical grade, (Fisher Scien-
tific Product No. S657-500 or equivalent).
6.3.4. Thioglycollate medium (Difco Laboratories Prod-
uct No. 0257-01-g or equivalent).
6.3.5. Fungizone (amphotericin B, Sigma Chemical
Product No. A-9528 or equivalent), Penicillin G
(Sigma Chemical Product No. P- 3032 or equiva-
lent), dihydrostreptomycin sulfate (ICN
Biomedicals Product No. 100556 or equivalent),
and tetracycline (ICN Biomedicals Product No.
103011 or equivalent).
Use antibiotics of at /east tissue culture grade.
6.3.6. Eagle's minimum essential medium (MEM) with
Hanks' salts and L-glutamine, without sodium
bicarbonate (GIBCO BRL Product No. 41 O-l 200
or equivalent).
6.3.7. Leibovitz's L-l 5 medium with L-glutamine
(GIBCO BRL Product No. 430-1300 or equiva-
lent).
6.3.8. Trypan blue (Sigma Chemical Product No. T-
6146 or equivalent).
Note: This chemical is on the EPA list of proven or sus-
pected carcinogens.
6.3.9. Dimethyl sulfoxide (DMSO; Sigma Chemical
Product No. D-2650 or equivalent).
6.3.10. Mycoplasma testing kit (Irvine Scientific Prod-
uct No. T500-000 or equivalent).
6.4 Preparation of Cell Culture Media
6.4.1. General Principles
(a) Equipment care — Carefully wash and sterilize
equipment used for preparing media before each use.
(b) Disinfection of work area — Thoroughly disinfect
surfaces on which the medium preparation equipment is
to be placed. Many commercial disinfectants do not ad-
equately kill total culturable viruses. To ensure thorough
disinfection, disinfect all surfaces and spills with either a
solution of 0.5% (5 g per liter) I, in 70% ethanol or 0.1%
HOCI.
(c) Aseptic technique — Use aseptic technique when
preparing and handling media or medium components.
(d) Dispensing filter-sterilized media-To avoid post-
filtration contamination, dispense filter-sterilized media into
storage containers through clear glass filling bells in a mi-
crobiological laminar flow hood. If a hood is unavailable,
use an area restricted solely to cell culture manipulations.
(e) Coding media -Assign a lot number to and keep
a record of each batch of medium or medium components
160
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prepared. Place the lot number, the date of preparation,
the expiration date, and the initials of the person preparing
the medium on each bottle.
(f) Sterility test — Test each lot of medium and me-
dium components to confirm sterility as described in sec-
tion 6.5 before the lot is used for cell culture.
(g) Storage of media and medium components —
Store media and medium components in clear airtight con-
tainers at 4°C or -20°C as appropriate.
(h) Sterilization of NaHCO3-containing solutions —
Sterilize media and other solutions that contain NaHCO3
by positive pressure filtration.
Negative pressure filtration of such solutions increases
the pH and reduces the buffering capacity
6.4.2. Media Preparation Recipes
(a) Sources of cell culture media.
Commercially prepared liquid cell culture media and
medium components are available from several sources.
Cell culture media can also be purchased in powder form
that requires only dissolution in dH2O and sterilization.
Media from commercial sources are quality controlled. The
conditions specified by the supplier for storage and expi-
ration dates should be strictly observed. However, media
can also be prepared in the laboratory directly from chemi-
cals. Such preparations are labor intensive, but allow quality
control of the process at the level of the preparing labora-
tory.
(b) Procedure for the preparation of EDTA-trypsin.
The procedure described is for the preparation of 10 li-
ters of EDTA-trypsin reagent. It is used to dislodge cells
attached to the surface of culture bottles and f/asks. This
reagent, when stored at 4°C, retains its working strength
for at least four months. The amount of reagent prepared
should be based on projected usage over a four month
period.
(b.1) Add 30 g of trypsin (1:250) or 25 g of trypsin (1:300)
and two liters of dH2O to a six liter flask containing a three
inch stir bar. Place the flask onto a magnetic stirrer and
mix the trypsin solution rapidly for a minimum of one hour.
Trypsin remains cloudy.
(b.2) Add four liters of
-------
(d.2) Sterilize the solution by autoclaving at 121°C for
15 minutes and store in a screw-capped container at room
temperature.
(e) Procedure for preparation of stock antibiotic solu-
tions.
If not purchased in sterile form, stockantibiotic solutions
must be filter-sterilized by the use of 0.22 urn membrane
filters. It is important that the recommended antibiotic lev-
els not be exceeded when planting cells as the cultures
are particular/y sensitive to excessive concentrations at
this stage.
Antibiotic stock solutions should be placed in screw-
capped containers and stored at -20°C until needed. Once
thawed, they may be refrozen; however, repeated freez-
ing and thawing of these stock solutions should be avoided
by distributing them in quantities that are sufficient to sup-
port a week's cell culture work.
(e.1) Preparation of penicillin-streptomycin stock solu-
tion.
The procedure described is for preparation of ten 10 mL
aliquots ofpenicillin-streptomycin stock solution at concen-
trations of 1,000,000 units of penicillin and 1,000,000 g of
streptomycin per 10 mL unit. The antibiotic concentrations
listed in step 6.4.2e. 1.7 may not correspond to the con-
centrations obtained from other lots or from a different
source.
(e.1.1.) Add appropriate amounts of penicillin G and dihy-
drostreptomycin sulfate to a 250 mL flask containing 100 ml of
dH O. Mix the contents of the flasks on magnetic stirrer until the
antibiotics are dissolved.
For penicillin suppled at 1435 units per mg, add 7 g of the
antibiotic,
For streptomycin supplied at 740 mg per g, add 14 g of the
antibiotic.
(e.l.2) Sterilize the antibiotics by filtration through 0.22 m
membrane filters and dispense in 10 mL volumes into screw-
capped containers.
(e.2) Preparation of tetracycline stock solution. Add 1.25
g of tetracycline hydrochloride powder and 3.75 g of ascor-
bic acid to a 125 mL flask containing 50 mL of dH2O. Mix
the contents of the flask on a magnetic stirrer until the an-
tibiotic is dissolved. Sterilize the antibiotic by filtration
through a 0.22 jun membrane filter and dispense in 5 mL
volumes into screw-capped containers.
(e.3) Preparation of amphotericin B (fungizone) stock
solution. Add 0.125 g of amphotericin B to a 50 mL flask
containing 25 mL of d. dH Cl.Mix the contents of the flask
on a magnetic stirrer untilthe antibiotic is dissolved. Ster-
ilize the antibiotic by filtration through 0.22 pm membrane
filter and dispense 2.5 mL volumes into screw-capped con-
tainers.
6.5 Procedure for Verifying Sterility of
Liquids
There are many techniques available for verifying the
sterility of liquids such as cell culture media and medium
components. The two techniques described below are stan-
dard in many laboratories. The capabilities of these tech-
niques are limited to the detection of microorganisms that
grow unaided on the test medium utilized. Viruses, myco-
plasma, and microorganisms that possess fastidious
growth requirements or that require living host systems
will not be detected. Nonetheless, with the exception of a
few special contamination problems, the test procedures
and microbiological media listed below should prove ad-
equate. Do not add antibiotics to media or medium com-
ponents until after sterility of the antibiotics, media and
medium components has been demonstrated. The BGM
cell line used should be checked every six months for
mycoplasma contamination according to test kit instruc-
tions. Cells that are contaminated should be discarded.
6.5.1. Procedure for Verifying Sterility of Small Volumes
of Liquids. Inoculate 5 mL of the material to be
tested for sterility into 5 mL of thioglycollate broth.
Shake the mixture and incubate at 36.5 ± 1°C.
Examine the inoculated broth daily for seven
days to determine whether growth of contami-
nating organisms has occurred.
Vessels that contain thioglycollate medium must be tightly
sealed before and after medium is inoculated.
6.52. Visual Evaluation of Media for Microbial Con-
taminants. Incubate media at 36.5 ± 1 °C for at
least one week prior to use. Visually examine
and discard any media that lose clarity.
A clouded condition that develops in the media indicates
the occurrence of contaminating organisms.
6.5.3. Procedures for Preparation and
Passage of BGM Cell Cultures
A laminar flow biological safety cabinet should be used
to process cell cultures. If a biological safety cabinet is not
available, cell cultures should be prepared in controlled
facilities used for no other purposes. Viruses or other mi-
croorganisms must not be transported, handled, or stored
in cell culture transfer facilities.
6.6.1. Vessels and Media for Cell Growth
(a) The BGM cell line grows readily on the inside sur-
faces of glass or specially treated, tissue culture grade plas-
tic vessels. 16 to 32 oz (or equivalent growth area) flat-
sided, glass bottles, 75 or 150 cm2 plastic cell culture flasks,
and 690 cm2 glass or 850 cm2 plastic roller bottles are usu-
ally used for the maintenance of stock cultures. Flat-sided
bottles and flasks that contain cells in a stationary position
are incubated with the flat side (cell monolayer side) down.
If available, roller bottles and roller apparatus units are
preferable to flat-sided bottles and flasks because roller
162
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cultures require less medium than flat-sided bottles per
unit of cell monolayer surface. Roller apparatus rotation
speed should be adjusted to one-half revolution per minute
to ensure that cells are constantly bathed in growth me-
dium.
(b) Growth and maintenance media should be pre-
pared on the day they will be needed. Prepare growth
medium by supplementing MEM/L-15 medium with 10%
serum and antibiotics (100 ml of serum, 1 ml of penicillin-
streptomycin stock, 0.5 mL of tetracycline stock and 0.2
mL of fungizone stock per 900 mL of MEM/L-15). Prepare
maintenance medium by supplementing MEM/L-15 with
antibiotics and 2% or 5% serum (20 or 50 mL of serum,
antibiotics as above for growth medium and 70 or 50 mL
of dH2O, respectively).
6.6.2. General Procedure for Cell Passage
Pass stock BGM cell cultures at approximately seven
day intervals using growth medium.
(a) Pour spent medium from cell culture vessels, and
discard the medium.
To prevent splatter, a gauze-covered beaker may be used
to collect spent medium.
Before discarding, autoclave all media that have been
in contact with cells or that contain serum.
(b) Add to the cell cultures a volume of warm EDTA-
trypsin reagent equal to 40% of the volume of medium
replaced.
See Table 2 for the amount of reagents required for com-
monly used vessel types.
To reduce shock to cells, warm the EDTA-trypsin reagent
to 36.5 ± 1 °C before placing if on cell monolayers. Dis-
Table 2. Guide for Preparation of BGM Stock Cultures
EDTA-
Trypsin
Vessel Type Volume (ml)1
1 6 oz glass flat
bottlesy
32 oz glass flat
bottles
75 cm2 plastic flat
flask
1 50 cm2 plastic flat
flask
690 cm2 glass roller
bottle
850 cm2 plastic roller
bottle
10
20
12
24
40
50
Media
Volume (mL)2
25
50
30
60
100
120
Total No.
Cells to Plate
per Vessel
2.5
5.0
3.0
6.0
7.0
8.0
x106
x106
x106
x106
x107
x107
The volume required to remove cells from vessels.
2Serum requirements: growth medium contains 10% serum; mainte-
nance medium contains 2-5% serum. Antibiotic requirements:
penicillin-streptomycin stock solution, 1 .O mL/ liter; tetracycline stock
solution, 0.5 ml/liter; fungizone stock solution, 0.2 ml/liter.
3Size is given in oz only when it is commercially designated in that unit.
pense the EDTA-trypsin reagent directly onto the cell mono-
layer.
(c) Allow the EDTA-trypsin reagent to remain in con-
tact with the cells at either room temperature or at 36.5 ±
1°C until cell monolayer can be shaken loose from inner
surface of cell culture vessel (about five min).
If necessary, a sterile rubber policeman (or scraper) may
be used to physically remove the cell sheet from the bottle.
However, this procedure should be used only as a last
resort because of the risk of cell culture contamination in-
herent in such manipulations. The EDTA-trypsin reagent
should remain in contact with the cells no longer than nec-
essary as prolonged contact can alter or damage the cells.
(d)
bottles.
Pour the suspended cells into centrifuge tubes or
To facilitate collection and resuspension of cell pellets,
use tubes or bottles with conical bottoms. Centrifuge tubes
and bottles used for this purpose must be able to with-
stand the g-force applied.
(e) Centrifuge cell suspension at 1,000 (g for 10 min
to pellet cells. Pour off and discard the supernatant.
Do not exceed this speed as cells may be damaged or
destroyed.
(f) Suspend the pelleted cells in growth medium (see
section 6.6.1 b) and perform a viable count on the cell sus-
pension according to procedures in section 6.7.
Rest/spend pelleted cells in sufficient volumes of me-
dium to allow thorough mixing of the cells (to reduce sam-
pling error) and to minimize the significance of the loss of
the 0.5 mL of cell suspension required for the cell counting
procedure. The quantity of medium used for resuspending
pelleted cells varies from 50 to several hundred mL, de-
pending upon the volume of the individual laboratory's need
for cell cultures.
(g) Dilute the cell suspension to the appropriate cell
concentration with growth medium and dispense into cell
culture vessels with either a Cornwall-type syringe or
Brewer-type pipetting machine dispenser.
Calculate the dilution factor requirement using the cell
count established in section 6.7 and the cell and volume
parameters given in Tab/e 2 for stock cultures and in Table
3 for virus assay cultures.
As a general rule, the BGM cell line can be split at a 1:3
ratio. However, a more suitable inoculum is obtained if low
passages of the line (passages 100-150) are split at a 1:2
ratio and higher passages (generally above passage 250)
are split at a 1:4 ratio. To plant two hundred 25 cm2 cell
culture f/asks week/y from a low-level passage of the line
would require the preparation of six roller bottles (surface
area 690 cm2 each): two to prepare the six roller bottles
and four to prepare the 25 cm2 flasks.
163
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Table 3. Guide for Preparation of Virus Assay Cell Cultures
Do not under or over fill the chambers.
Vessel Type
1 oz glass bottle2
25 cm2 plastic flask
6 oz glass bottle
75 cm2 plastic flask
16mm( 150mmtubes
Volume of Medium
(mL)'
4
10
15
30
2
Final Cell Count
per Bottle
9.0 x 10=
3.5 x106
5.6 x106
1.0x107
4.0x104
'Serum requirements: growth medium contains 10% serum; mainte-
nance medium contains 2-5% serum. Antibiotic requirements:
penicillin-streptomycin stock solution, 1 .O ml/liter; tetracycline stock
solution, 0.5 ml/liter; fungizone stock solution, 0.2 ml/liter.
2Size is given in oz only when it is commercially designated in that unit.
(h) Except during handling operations, maintain BGM
cells at 36.5 ± 1 °C in airtight cell culture vessels.
6.6.3. Procedure for Changing Medium on
Cultured Ceils
Cell monolayers normally become 95 to 100% confluent
three to four days after seeding with an appropriate num-
ber of cells, and growth medium becomes acidic. Growth
medium on confluent stock cultures should then be re-
placed with maintenance medium containing 2% serum.
Maintenance medium with 5% serum should be used when
monolayers are not yet 95% to 100% confluent but the
medium in which they are immersed has become acidic.
The volume of maintenance medium should equal the vol-
ume of discarded growth medium.
6.7. Procedure for Performing Viable
Cell Counts
With experience a fair/y accurate cell concentration can
be made based on the volume of packed cells. However,
viable cell counts should be performed periodically as a
quality control measure.
6.7.1. Add 0.5 ml of cell suspension (or diluted cell
suspension) to 0.5 mL of 0.5% trypan blue solu-
tion in a test tube.
To obtain an accurate cell count, the optimal total num-
ber of cells per hemocytometer section should be between
20 and 50. This range is equivalent to between 6.0 (105
and 1.5 (10s cells permL of cell suspension. Thus, a dilu-
tion of 1:10 (0.5 mL of cells in 4.5 mL of growth medium) is
usually required for an accurate count of a cell suspen-
sion.
6.7.2. Disperse cells by repeated pipetting.
Avoid introducing air bubbles into the suspension, be-
cause air bubbles may interfere with subsequent filling of
the hemocytometer chambers.
6.7.3. With a capillary pipette, carefully fill a hemocy-
tometer chamber on one side of a slip-covered
hemocytometer slide. Rest the slide on a flat
surface for about one min to allow the trypan
blue to penetrate the cell membranes of nonvi-
able ceils.
6.7.4. Under 100X total magnification, count the cells
in the four large corner sections and the center
section of the hemocytometer chamber.
Include in the count cells lying on the lines marking the
top and left margins of the sections, and ignore cells on
the lines marking the bottom and right margins. Trypan
blue is excluded by living cells. Therefore, to quantify vi-
able cells, count only cells that are clear in color. Do not
count cells that are blue.
6.7.5. Calculate the average number of viable cells in
each mL of cell suspension by totaling the num-
ber of viable cells counted in the five sections,
multiplying this sum by 4000, and where neces-
sary, multiplying the resulting product by the re-
ciprocal of the dilution.
6.8. Procedure for Preservation of BGM
Cell Line
An adequate supply of BGM cells must be available to
replace working cultures that are used only periodically or
become contaminated or lose virus sensitivity Cells have
been held at -70°C for more than 15years with a minimum
loss in cell viability
6.6.1. Preparation of Cells for Storage
The procedure described is for the preparation of 100
cell culture via/s. Cell concentration per mL must be at /east
1 X106.
Base the actual number of vials to be prepared on us-
age of the line and the anticipated time interval require-
ment between cell culture start-up and full culture produc-
tion.
(a) Prepare cell storage medium by adding 10 mL of
DMSO to 90 mL of growth medium (see section 6.6.1 b).
Sterilize cell storage medium by passage through an 0.22
m sterilizing filter.
Collect sterilized medium in 250 mL flask containing a
stir bar.
(b) Harvest BGM cells from cell culture vessels as
directed in section 6.6.2. Count the cells according to the
procedure in section 6.7 and resuspend them in the cell
storage medium at a concentration of 1 (106 cells per mL.
(c) Place the flask containing suspended cells on a
magnetic stirrer and slowly mix for 30 min. Dispense 1 mL
volumes of cell suspension into 2 mL vials.
6.8.2. Procedure for Freezing Cells
The freezing procedure requires slow cooling of the cells
with the optimum rate of -1 °C per min. A slow cooling rate
can be achieved using the following method or by using
the recently available freezing containers (e.g., Nalge Com-
164
-------
pany Product No. 5100-0001 or equivalent) as recom-
mended by the manufacturers.
(a) Place the vials in a rack and place the rack in re-
frigerator at 4°C for 30 min, in a -20°C freezer for 30 min,
and then in a -70°C freezer overnight. The transfers should
be made as rapidly as possible.
To allow for more uniform cooling, wells adjoining each
vial should remain empty
(b) Rapidly transfer vials into boxes or other contain-
ers for long-term storage.
To prevent substantial loss of cells during storage, tem-
perature of cells should be kept constant after -70°C has
been achieved.
6.8.3. Procedure for Thawing Cells
Ce//s must be thawed rapidly to decrease loss in cell
viability,
(a) Place vials containing frozen cells into a 36°C
water bath and agitate vigorously by hand until all ice has
melted. Sterilize the outside surface of the vials with 0.5%
I, in 70% ethanol.
(b) Add BGM cells to either 6 oz tissue culture bottles
or 25 cm2 tissue culture flasks containing an appropriate
volume of growth medium (see Table 3). Use two vials of
cells for 6 oz bottles and one vial for 25 cm2 flasks.
(c) Incubate BGM cells at 36.5 ± 1 °C. After 18 to 24 h
replace the growth medium with fresh growth medium and
then continue the incubation for an additional five days.
Pass and maintain the new cultures as directed in section
6.6.
7. Bibliography and Suggested Reading
ASTM. 1998. Standard Methods for the Examination of
Water and Wastewater (L.S. Clesceri, A.E. Greenberg
and A.D. Eaton, ed), 20th Edition. United Book Press,
Baltimore, MD.
Barron, A.L., C. Olshevsky, and M.M. Cohen. 1970. Char-
acteristics of the BGM line of cells from African green
monkey kidney. Archiv. Gesam. Virusforsch. 32:389-
392.
Berg, G., D. Berman, and R.S. Safferman. 1982. A Method
for concentrating viruses recovered from sewage slud-
ges. Can. J. Microbiol. 2&55S-556.
Berg, G., R.S. Safferman, D.R. Dahling, D. Berman, and
C.J. Hurst. 1984. USEPA Manual of Methods for Virol-
ogy. U.S. Environmental Protection Agency Publica-
tion No. EPA/600/4-84-013, Cincinnati, OH.
Berman, D., G. Berg, and R.S. Safferman. 1981. A method
for recovering viruses from sludges. J. Virol. Methods.
3:283-291.
Brashear, D.A., and R.L. Ward. 1982. Comparison of meth-
ods for recovering indigenous viruses from raw waste-
water sludge. Appl. Environ. Microbiol. 43:1413-1 418.
Dahling, D.R., and B.A. Wright. 1986. Optimization of the
BGM cell line culture and viral assay procedures for
monitoring viruses in the environment. Appl. Environ.
Microbiol. 57:790-812.
Dahling, D.R., G. Berg, and D. Berman. 1974. BGM, a
continuous cell line more sensitive than primary rhesus
and African green kidney cells for the recovery of vi-
ruses from water. Health Lab. Sci. 77:275-282.
Dahling, D. R., G. Sullivan, R. W. Freyberg and R. S.
Safferman. 1989. Factors affecting virus plaque con-
firmation procedures. J. Virol. Meth. 24:111-122.
Dahling, D. R., R. S. Safferman, and B. A. Wright. 1984.
Results of a survey of BGM cell culture practices.
Environ. Internat. 70:309-313.
Dulbecco, R. 1952. Production of plaques in monolayer
tissue cultures by single particles of an animal virus.
Proc. Natl. Acad. Sci. U.S.A. 38:747-752.
Eagle, H. 1959.Amino acid metabolism in mammalian cell
cultures. Science. 730432-437.
Hay, R. J. 1985. ATCC Quality Control Methods for Cell
Lines. American Type Culture Collection, Rockvilie,
MD.
Hurst, C. J. 1987. Recovering viruses from sewage slud-
ges and from solids in water, pp. 25-51. In G. Berg
(ed), Methods for Recovering Viruses from the Envi-
ronment. CRC Press, Boca Raton, FL.
Katzenelson, E., B. Fattal, and T. Hostovesky. 1976. Or-
ganic flocculation: an efficient second-step concentra-
tion method for the detection of viruses in tap water.
Appl. Environ. Microbiol. 32:638-639.
Lennette, E. H. and N. J. Schmidt (ed.). 1979. Diagnostic
Procedures for Viral, Rickettsial and Chlamydial Infec-
tions, 5th ed. American Public Health Association, Inc.,
Washington, D.C.
Safferman, R. S., M. E. RohrandT. Goyke. 1988. Assess-
ment of recovery efficiency of beef extract reagents
for concentrating viruses from municipal wastewater
sludge solids by the organic flocculation procedure.
Appl. Environ. Microbiol. 54:309-316.
Stetler, R. E., M. E. Morris and R. S. Safferman. 1992.
Processing procedures for recovering enteric viruses
from wastewater sludges. J. Virol. Meth. 4067-76.
Ward, R. L, and C. S. Ashley. 1976. Inactivation of poliovi-
rus in digested sludge. Appl. Environ. Microbiol.
37:921-930.
165
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Appendix I
Test Method for Detecting, Enumerating, and Determining the
Viability of Ascaris Ova in Sludge.
1. Scope
1.1 This test method describes the detection, enu-
meration, and determination of viability of Ascaris ova in
water, wastewater, sludge, and compost. These pathogenic
intestinal helminths occur in domestic animals and humans.
The environment may become contaminated through di-
rect deposit of human or animal feces or through sewage
and wastewater discharges to receiving waters. Ingestion
of water containing infective Ascaris ova may cause dis-
ease1.
1.2 This test method is for wastewater, sludge, and
compost. It is the user's responsibility to ensure the valid-
ity of this test method for untested matrices.
1.3 This standard does not purport to address all of
the safety problems, if any, associated with it use. It is the
responsibility of the user of this standard to establish ap-
propriate safety and health practices and determine the
applicability of regulatory limitations prior to use. For spe-
cific hazard statements, see section 9.
2.0 Referenced Documents
2.1 ASTM Standards: (Use words "Specification for,"
"Practice for," "Test Method for," etc.)
(Include standards listed below and others that are re-
ferred to in the test method.)
D 1129 Terminology Relating to Water2
D 1193 Specification for Reagent Water3
D 2777 Practice for Determination of Precision and Bias
of Applicable Methods of committee D-l 9 on Water
2.2 Other Documents: (Include any standards or codes
from other organizations that are required to conduct test;
if all from same organizations, use that as the title.)
3.0 Terminology
(Definitions and Descriptions of Terms must be approved
by the Definitions Advisor.)
3.1 Definitions - For definitions of terms used in this
test method, refer to Terminology D 1129.
3.2 Descriptions of Terms Specific to This Standard:
3.2.1 The normal nematode life cycle consists of the egg,
4 larval stages and an adult. The larvae are similar in ap-
pearance to the adults; that is, they are typically worm-like
in appearance.
3.2.2 Molting (ecdysis) of the outer layer (cuticle) takes
place after each larval stage. Molting consists of 2 distinct
processes, the deposition ofthe new cuticle and the shed-
ding of the old one or exsheathment. The cuticle appears
to be produced continuously, even throughout adult life.
3.2.3 A molted cuticle that still encapsulates a larva is
called a sheath,
3.2.4 Ascarid egg shells are commonly comprised of lay-
ers. The outer tanned, bumpy layer is referred to as the
mammillated layer and is useful in identifying Ascaris eggs.
The mammillated layer is sometimes absent. Eggs that do
not possess the mammillated layer are referred to as deco-
rticated eggs.
3.2.5 A potentially infective Ascaris egg contains a third
stage larva4 encased in a the sheath of the first larval stage.
4. Summary of Test Method
4.1 This method is used to concentrate pathogenic As-
caris ova from wastewater, sludge, and compost. Samples
are processed by blending with buffered water containing
a surfactant. The blend is screened to remove large par-
ticulates. The solids in the screened portion are allowed to
settle out and the supernatant is decanted. The sediment
is subjected to density gradient centrifugation using mag-
nesium sulfate (specific gravity 1.20). This flotation proce-
The boldface numbers in parentheses refer to the list of references at the end of
this test method.
'Annual Book of ASTM Standards, Vol 11.01.
3Annual Book of ASTM Standards, Vol 11.01.
'P.L. Geenen. J. Bresciani, Jeap Boes, A. Pedersen. Lis Eriksen, H.P. Fagerholm,
and P. Nansen (1999) The Morphogenesis of A scan's suum to the infective third-
stage larvae within the egg, J. Parasitology, 85(4):616-622
166
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dure yields a layer likely to contain Ascaris and some other
parasitic ova if present in the sample. Small particulates
are removed by a second screening on a small mesh size
screen.5 Proteinaceous material is removed using an acid-
alcohol/ethyl acetate extraction step. The resulting con-
centrate is incubated at 26EC until control Ascaris eggs
are fully embryonated. The concentrate is then microscopi-
cally examined for the categories of Ascaris ova on a
Sedgwick-Rafter counting chamber.6
5. Significance and Use
5.1 This test method is useful for providing a quantita-
tive indication of the level of Ascaris ova contamination of
wastewater, sludge, and compost.
5.2 This test method will not identify the species of
Ascaris detected nor the host of origin.
5.3 This method may be useful in evaluating the ef-
fectiveness of treatment.
6. interferences
6.1 Freezing of samples will interfere with the buoy-
ant density of Ascaris ova and decrease the recovery of
ova.
7. Apparatus
7.1 A good light microscope equipped with brightfield,
and preferably with phase contrast and/or differential con-
trast optics including objectives ranging in power from 1 OX
to 45x.
7.2 Sedgwick-Rafter cell.
7.3 Pyrex beakers, 2 L. Coat with organosilane.
7.4 Erlenmeyer flask, 500 mL Coat with organosilane.
7.4 A centrifuge that can sustain forces of at least 660
X G with the rotors listed below.
7.4.1 A swinging bucket rotor to hold 100 or 250 ml cen-
trifuge glass or plastic conical bottles.
7.4.2 A swinging bucket rotor to hold 15 ml conical glass
or plastic centrifuge tubes.
7.5 Tyler sieves.
7.5.1 20 or 50 mesh.
7.5.2 400 mesh, stainless steel, 5 inch in diameter.
7.5.3 A large plastic funnel to support the sieve. Coat
with organosilane.
7.6 Teflon spatula.
7.7 Incubator set at 26EC.
7.8 Large test tube rack to accommodate 100 or 250
ml centrifuge tubes.
7.9 Small test tube rack to accommodate 15 mL coni-
cal centrifuge tubes.
7.10 Centrifuge tubes, 100 or 250 mL. Coat with
organosilane.
7.11 Conical centrifuge tubes, 15 mL. Coat with
organosilane.
7.12 Number "0" stoppers.
7.13 Wooden applicator sticks.
7.14 Pasteur pipettes. Coat with organosilane.
7.15 Vacuum aspiration apparatus.
7.15.1 Vacuum source.
7.15.2 Vacuum flask, 2 L or larger.
7.15.3 Stopper to fit vacuum flask, fitted with a glass or
metal tubing as a connector for 1/4 inch tygon tubing.
7.16 Wash bottles (500 mL), label "Water".
7.17 Spray bottles (16 fl oz.) (2).
7.17.1 Label one "Water".
7.17.2 Label one "1% 7X".
8. Reagents and Materials
(This section must be approved by Reagents Advisor.)
8.1 Purity of Reagents — Reagent grade chemicals
shall be used in all tests. Unless otherwise indicated, it is
intended that all reagents shall conform to the specifica-
tions of the Committee on Analytical Reagents of the Ameri-
can Chemical Society7. Other grades may be used, pro-
vided it is first ascertained that the reagent is of sufficiently
high purity to permit its use without lessening the accu-
racy of the determination.
8.2 Purity of Water — Unless otherwise indicated, ref-
erences to water shall be understood to mean reagent
water conforming to Specification D 1193, Type I.
6The preceeding portion of the procedure is adapted from: Reimers, R.S., M.D.
Little, T.G. Akers, W.D. Henriques, R.C. Badeaux, D.B. McDonnel, and K.K. Mbela.
1989. Persistence of pathogens in lagoon-stored sludge. Cooperative Agreement
N. 810289. U.S. Environmental Protection Agency. EPA/600/2-89/015.
6This portion of the procedure was adapted from: Task Method for Detecting, Enu-
merating, and Determining the Viability of Ascaris Ova in Wastewater and Sludge.
Draft No. 01.
Reagent CherrSnaciAmerican Chaminal Societv
lications. American Chemi-
cal Society, Washington, DC. For suggestions on the testing of Reagents not listed
by the American Chemical Society, see Analar Standards tnr Laboratory nhami-
cals.BDH Ltd., Poole, Dorset, U.K., and the United States Pharmacopeia and Na-
tional Formulary. US. Pharmaceutical Convention, Inc. (USPC),
167
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8.3 Preparation of Reagents — Prepare reagents in
accordance with Practice E200. (List other reagents in al-
phabetical order by the critical word, from highest to low-
est concentration, with concentrations in parentheses.
Example: Copper Solution, Standard (1 mL = 1 mg Cu).)
8.3.1 Phosphatebuffered water (1 L = 34.0 g KH2PO4, pH
adjusted to 7.2 ± 0.5 with 1 N NaOH).
8.3.2 1% (v/v) 7X("Limbro" laboratory detergent) (1 L = 999
ml phosphate-buffered water, 1 ml 7X "Limbro", Adjust pH to
7.2 ±0.1 with 1 NNaOH).
8.3.3 Magnesium sulfate, sp. gr. 1.20. (1 L= 215.2 g MgSO4,
check specific gravity with a hydrometer; adjust as necessary to
reach 1.20).
83.4 Acid alcohol. 0.1. N.H SO, made in 35% ethyl alcohol.
(100 ml = 35 mL EtOH, 0.98CF g H^Oj
8.3.5 Ethyl Acetate, reagent grade.
8.4 Organosilane. For coating glassware. Coat all glass-
ware according to manufacturer's instructions.
8.5 Fresh Ascaris ova for positive control, either dissected
from Ascaris suum gravid adult female worms or purified from
Ascaris infected pig fecal material.
9. Precautions
(To be reviewed by the Reagents Advisor)
9.1 When harvesting Ascaris ova from gravid female
worms, the analyst must wear latex gloves, a surgical mask and
protective goggles or full face mask, and laboratory coat before
dissecting the worms. Moreover, it is recommended that the
Ascaris ova harvest be carried out either in a biological safety
cabinet or minimally a chemical hood. These precautions are
designed to prevent the development of an allergy to Ascaris
pseudocoelomic fluid. If infective Ascarisova are ingested they
may cause disease.
10. Sampling
10.1 Collect 1 liter of compost, wastewater, or sludge
in accordance with Practice D 1066, Specification D 1192,
and Practices D 3370, as applicable.
10.2 Place the sample container(s) on wet ice or around
chemical ice and ship back to the laboratory for analysis
within 24 hours of collection.
10.3 Store the samples in the laboratory refrigerated at
2 to 5°C. Do not freeze the samples during transport or
storage.
11. Preparation of Apparatus
(Give instructions in imperative mood.)
12. Calibration and Standardization
(To be reviewed by the Reagents Advisor) (Give instruc-
tions in imperative mood.)
13. Procedure
(To be reviewed by the Reagents Advisor) (Give instruc-
tions in imperative mood.)
13.1 The percentage moisture of the sample is deter-
mined by analyzing a separate portion of the sample, so
the final calculation of ova per gram dry weight can be
determined. The concentration of ova in liquid sludge
samples may be expressed as ova per unit volume.
13.2 Initial preparation:
13.1.1 Dry or thick samples: Weigh about 300 g (esti-
mated dry weight) and place in about 500 ml water in a
beaker and let soak overnight at 4 - 10EC. Transfer to
blender and blend at high for one minute. Divide sample
into four beakers.
13.1.2 Liquid samples: Measure 1,000 ml or more (esti-
mated to contain at least 50 g dry solids) of liquid sample.
Place one half of sample in blender. Add about 200 mL
water. Blend at high speed for one minute transfer to a
beaker. Repeat for other half of sample.
13.3 Pour the homogenized sample into a 1000 mL tall
form beaker and using a wash bottle, thoroughly rinse
blender container into beaker. Add 1% 7X to reach 900 ml
final volume.
13.4 Allow sample to settle four hours or overnight at 4
- 10EC. Stir occasionally with a wooden applicator, as
needed to ensure that material floating on the surface
settles. Additional 1% 7X may be added, and the mixture
stirred if necessary.
13.5 After settling, vacuum aspirate supernatant to just
above the layer of solids. Transfer sediment to blender and
add water to 500 ml, blend again for one minute at high
speed.
13.6 Transfer to beaker, rinsing blender and add 1%
7X to reach 900 ml. Allow to settle for two hours at 4 -
1 OEC, vacuum aspirate supernatant to just above the layer
of solids.
13.7 Add 300 ml 1% 7X and stir for five minutes on a
magnetic stirrer.
13.8 Strain homogenized sample through a 20 or 50
mesh sieve placed in a funnel over a tall beaker. Wash
sample through sieve with a spray of 1% 7X from a spray
bottle.
13.9 Add 1% 7X to 900 mL final volume and allow to
settle for two hours at 4 -1 OEC.
13.10 Vacuum aspirate supernatant to just above layer
of solids. Mix sediment and distribute equally to 50 mL
graduated conical centrifuge tubes. Thoroughly wash any
sediment from beaker into tubes using water from a wash
bottle. Bring volume in tubes up to 50 ml with water.
168
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13.11 Centrifuge for 10 minutes at 1000 X G. Vacuum
aspirate supernatant from each tube down to just above
the level of sediment. (The packed sediment in each tube
should not exceed 5 mL If it exceeds this volume, add
water and distribute the sediment evenly among additional
tubes, repeat centrifugation, and vacuum aspirate super-
natant.)
13.12 Add 10 to 15 mL of MgSO4 solution (specific grav-
ity 1.20) to each tube and mix for 15 to 20 seconds on a
vortex mixer. (Use capped tubes to avoid splashing of mix-
ture from the tube.)
13.13 Add additional MgSO4 solution (specific gravity
1.20) to each tube to bring volume to 50 mL Centrifuge for
five to ten minutes at 800 to 1000 X g. DO NOT USE
BRAKE.
13.14 Allow the centrifuge to coast to a stop without the
brake. Pour the top 25 to 35 ml of supernatant from each
tube through a 400 mesh sieve supported in a funnel over
a tall beaker.
13.15 Using a water spray bottle, wash excessive flota-
tion fluid and fine particles through sieve.
13.16 Rinse sediment collected on the sieve into a 100
mL beaker by directing the stream of water from the wash
bottle onto the upper surface of the sieve.
13.17 After thoroughly washing the sediment from the
sieve, transfer the suspension to the required number of
15 mL centrifuge tubes, taking care to rinse the beaker
into the tubes. Usually one beaker makes one tube.
13.18 Centrifuge the tubes for three minutes at 800 X
G, then discard the supernatant.
13.19 If more than one tube has been used for the
sample, transfer the sediment to a single tube, fill with water,
and repeat centrifugation.
13.20 Resuspend the pellet in
tion and add 3 mL ethyl acetate.
7 mL acid alcohol solu-
13.21 Cap the tube with a rubber stopper and invert sev-
eral times, venting after each inversion.
13.22 Centrifuge the tube at 660 x G for 3 minutes.
13.23 Aspirate the supernatant above the solids.
13.24 Resuspend the solids in 4 mL 0.1 N H2SO4 and
pour into a 220-mL polyethylene scintillation vial or equiva-
lent with loose caps.
13.25 Before incubating the vials, mark the liquid level
in each vail with a felt tip pen. Incubate the vials, along
with control vials containing Ascaris ova mixed with 4 mL
0.1 N H2SO4, at 26°C for three to four weeks. Every day or
so, check the liquid level in each vial. Add reagent grade
water up to the initial liquid level line as needed to com-
pensate for evaporation. After 18 days, suspend, by inver-
sion and sample small aliquots of the control cultures once
every 2-3 days. When the majority of the control Ascaris
ova are fully embryonated, samples are ready to be ex-
amined.
13.26 Examine the concentrates microscopically using
a Sedgwick-Rafter cell to enumerate the detected ova.
Classify the ova as either unembryonated, embryonated
to the first, second or third larval stage. In some embryo-
nated Ascaris ova the larva may be observed to move.
See Figure 1 for examples of various Ascaris egg catego-
ries.
14. Calculation
(To be reviewed by the Results Advisor.) (Provide direc-
tions in the imperative mood and include equations using
appropriate quantity symbols and key.)
14.1
suit:
Calculate % total solids using the % moisture re-
% Total solids = 100% - % moisture
14.2 Calculate catagories of ova/g dry weight in the fol-
lowing manner:
Ova/g dry wt = (NO) x (CV) x (FV)
(SP) x (TS)
Where:
NO = no. ova
CV = chamber volume(= 1 mL)
FV = final volume in mL
SP = sample processed in mL or g
TS = % total solids
15. Report
(To be reviewed by the Results Advisor.) (State detailed
information required in reporting results, as particular pro-
cedure used; can include report forms or worksheets as
Figures.)
15.1 Report the results as the total number of Ascaris
ova, number of unembryonated Ascaris ova, number of
1 st, 2nd or 3rd stage larva; reported as number of Ascaris
ova and number of various larval Ascaris ova per g dry
weight. Representative reporting forms are shown in Fig-
ure 2.
16. Precision and Bias
(Approval of the Results Advisor is required for the pro-
posed program both before testing is initiated and for the
calculations and final precision statement that appears in
the test method. See Practice D 2777-86 for precision and
bias requirements and formats.)
169
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Figure 1. Ascaris ovum: potentially non-fertile, note bumpy
mammilated outer layer.
Figure 2. Ascaris ovum: fertile, note the bumpy outer mammilated
layer.
Figure 3. /4scar/s ovum: decorticated, unembryonated. Note the outer Figure 4. Ascaris ovum: decorticated and embryonated.
mammilated layer is gone.
170
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'3*1
Figure 5. Ascaris ovum: decorticated, embryonated.
Figure 6. Ascaris ovum with second stage or potentially third stage
larva; note the first stage larval sheath at the anterior end
of the worm.
171
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16.1 This test method was tested by laboratories, with
each operator analyzing each sample on different days.
These collaborative test data were obtained on reagent
water and waters. For other matrices, these data may not
apply.
16.1.1 Precision -The precision of this test method within
its designated range may be expressed as follows: (This
data may be included as a figure.)
16.1.2 Bias - Recoveries of known amounts of in a se-
ries of prepared standards were as follows: (This data may
be included as a table.)
16.2 (The deficiency boilerplate should be added as
applicable. It reads:)
, .independent laboratories (and a total of operators) par-
ticipated in t'he round robin study. Precision and bias for
this test method conforms to Practice D 2777-77, which
was in place at the time of collaborative testing. Under the
allowances made in 1.5 of Practice D 2777-86, these pre-
cision and bias data do meet existing requirements for
interlaboratory studies of Committee D-l 9 test methods.
17. Keywords
17.1 Ascaris, ova, embryonation, viability assay, helm-
inth.
Notice
The PEC was consulted in a recent (1998-1999) pilot
study by Lyonnaise des Eaux concerning the use of a mi-
croscope in making helminth ova counts for different types
of sludge. Solids and debris present in the sludge being
viewed with the microscope were found to impair ones
ability to count. Dilution of raw sludge and digested sludge,
however, with phosphate-buffered water prior to analyzing
them significantly improved the number of ova that could
be counted. Raw sludges were diluted by a factor of 20
and digested sludges by a factor of 5. QA/QC procedures
were followed to validate this procedure. The PEC should
be consulted for more details.
172
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Appendix J
The Biosolids Composting Process
Introduction
Composting is the biological decomposition of organic
matter under controlled aerobic conditions. The objectives
of composting are to reduce pathogens to below detect-
able levels, degrade volatile solids, and produce a usable
product. Pathogen reduction is a function of time and tem-
perature. Composted biosolids is one way to meet 40 CFR
Part 503 pathogen (and vector attraction) reduction require-
ments. Composted biosolids can meet either a "Process
to Significantly Reduce Pathogens" (PSRP/Class B) or a
"Process to Further Reduce Pathogens" (PFRP/Class A)
standard, depending upon the operating conditions main-
tained at the facility. Process and operational consider-
ations must be taken into account when a facility desires
to meet the pathogen and vector attraction requirements
of 40 CFR 503. The 40 CFR Part 503 regulations require
composted biosolids applied to the land to meet specific
pollutant limits, site restrictions, management practices,
and pathogen and vector attraction reduction processes,
depending upon whether they: 1) are applied to agricul-
tural land, forest, a public contact site, or a reclamation
site; 2) are sold or given away in a bag or other container;
or 3) are applied to a lawn or home garden. Discussions
provided here are presented in summary form, it is recom-
mended that the facility seek additional details in develop-
ing a compost operation.
Composting Process Discription
The addition of a bulking agent to sewage sludge pro-
vides optimum conditions for the composting process,
which usually lasts 3 to 4 weeks. A bulking agent acts as a
source of carbon for the biological process, increases po-
rosity, and reduces the moisture level. The composting
process has several phases, including the active phase,
the curing phase, and the drying phase.
Active phase.Dur'mg the active or stabilization phase,
the sewage sludge/bulking agent mix is aerated and the
sewage sludge is decomposed due to accelerated biologi-
cal activity. The biological process involved in composting
can raise the temperature up to 60°C or more. At these
high temperatures, all of the disease-causing pathogens
are destroyed. Windrow systems must meet this condition
by achieving 55°C for a minimum of 15 consecutive days
during which time the windrow is turned five times. The
critical requirement is that the material in the core of the
compost pile be maintained at the required temperatures
(55°C) for the required time (3 days). Therefore, the first
phase typically lasts 21 days. Aeration is accomplished in
one of two ways: 1) by mechanically turning the mixture
so that the sewage sludge is exposed to oxygen in the air;
or 2) by using blowers to either force or pull air through the
mixture.
Curing phase. After the active phase, the resulting ma-
terial is cured for an additional 30 days to 180 days. At this
time, additional decomposition, stabilization, pathogen
destruction, and degassing takes place. Composting is
considered complete when the temperature of the com-
post returns to ambient levels. Depending upon the extent
of biodegradation during the active phase and the ultimate
application of the finished product, the curing phase may
not be carried out as a separate process.
Drying Phase. After curing, some operations add another
step called the drying phase which can vary from days to
months. This stage is necessary if the material is to be
screened to either recover the unused bulking agent for
recycling or for an additional finished product. If the prod-
uct is to be marketable, the final compost should be 50%
to 60% solids.
There are two main process configurations for the
composting process:
Unconfined composting. This process is conducted in
long piles (windrows)' or in static piles. Operations using
unconfined composting methods may provide oxygen to
the compost by turning the piles by hand or machine or by
using air blowers which may be operated in either a posi-
tive (blowing) or negative (suction) mode. For windrows
without blower aeration, it is typical to turn the windrow
two or three times a week, using a front-end loader. Prop-
erly operating aerated static piles do not require turning.
Confined (in-vessel) composting. This process is car-
ried out within an enclosed container, which minimizes
odors and process time by providing better control over
the process variables. Although in-vessel composting has
been effective for small operations, typically these opera-
tions are proprietary and therefore will not be described
any further in this fact sheet.
173
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Operational Considerations
The key process variables for successful composting are
the moisture content and carbon to nitrogen (C:N) ratio of
the biosolids/bulking agent mixture, and temperature and
aeration of the compost pile. Other process parameters
such as volatile solids content, pH, mixing and the materi-
als used in the compost also affect the process.
Biosolids/Bulking Agent Mixture Moisture Content. Mois-
ture control is an important factor for effective composting.
Water content must be controlled for effective stabiliza-
tion, pathogen inactivation, odor control and finished com-
post quality (Benedict, 1988). The optimum moisture con-
tent of the mix is between 40% and 60%. At less than 40%
water, the material is too fluid, has reduced porosity and
has the potential for producing septic conditions and odors;
above 60% solids, the lack of moisture may slow down the
rate of decomposition. Since typical dewatered sewage
sludge or biosolids are often in the range of 15% to 20%
solids for vacuum filtered sewage sludge or biosolids and
20% to 35% solids for belt press or filter pressed sewage
sludge or biosolids, the addition of drier materials (bulking
agents) is usually essential.
Biosolids/Bulking Agent Mixture Carbon to Nitrogen Ra-
tio. Microorganisms need carbon for growth and nitrogen
for protein synthesis. For efficient composting, the carbon
to nitrogen (C:N) ratio of the biosolids/bulking agent mix-
ture should be in the range of 25:1 to 35:1
Oxygen levels. For optimum aerobic biological activity,
air within the pile should have oxygen levels of between
5% and 15%. Lower levels of oxygen will create odors and
reduce the efficiency of the composting. Excessive aera-
tion will cool the pile, slow the composting process, and
will not provide the desired pathogen and vector attraction
reduction.
Conventional windrows obtain necessary oxygen through
the natural draft and ventilation induced from the hot, moist
air produced during active composting and from the peri-
odic windrow turning. Where blowers are used for aera-
tion, it is typical to provide at least one blower per pile.
Biosolids/Bulking Agent Mixture Volatile Solids Con tent.
The volatile solids content of the biosolids/bulking agent
mix should be greater than 50% for successful composting
(EPA, 1985). This parameter is an indicator of the energy
available for biological activity and therefore compostability.
Biosolids/Bulking Agent Mixture pH. The pH of the
biosolids/bulking agent mix should be in the range of 6 to
9 for efficient composting (EPA, 1985). Higher pH mixtures
may result if lime stabilized biosolids are used. They can
be composted; however, it may take longer for the
composting process to achieve the temperatures needed
to reduce pathogens.
Biosolids and Bulking Agent Mixing. Uniform mixing is
necessary in order to assure that moisture concentration
is constant through the pile and that air can flow
throughout Type of Biosolids. The type of biosolids used
may have an effect on the composting process.
Composting can be accomplished with unstabilized
biosolids, as well as anaerobically and aerobically digested
biosolids. Raw sludge has a greater potential to cause
odors because they have more energy available and will,
therefore, degrade more readily. This may cause the com-
post pile to achieve higher temperatures faster unless suf-
ficient oxygen is provided and may also cause odors (EPA,
1985).
Material for Bulking Agents. Materials such as wood
chips, sawdust and recycled compost are usually added
as "bulking agents" or "amendments" to the compost mix-
ture to provide an additional source of carbon and to con-
trol the moisture content of the mixture. Other common
bulking agents used by facilities around the country include
wood waste, leaves, brush, manure, grass, straw, and
paper (Goldstein, 1994). Because of their cost, wood chips
are often screened out from the matured compost, for re-
use. Although sawdust is frequently used for in-vessel
composting, coarser materials such as wood chips, wood
shavings, and ground-up wood are often preferred because
they permit better air penetration and are easier to remove.
Recycled compost is often used as a bulking agent in wind-
rows, especially if bulking agents must be purchased. How-
ever, its use is limited because the porosity decreases as
the recycle ages (EPA, 1989). The amount of biosolids
and bulking agent which must be combined to make a suc-
cessful compost is based on a mass balance process con-
sidering the moisture contents, C:N ratio, and volatile sol-
ids content.
Compost Pile Size. In general, assuming adequate aera-
tion, the larger the pile the better. A larger pile has less
surface area per cubic yard of contents and therefore re-
tains more of the heat that is generated and is less influ-
enced by ambient conditions. In addition, less cover and
base material (recycled compost, wood chips, etc.) is
needed as well as the overall land requirements for the
compost operation. Larger piles tend to retain moisture
longer. The surface area to volume ratio has an effect on
the temperature of the pile. Assuming other factors are
constant (e.g., moisture, composition, aeration), larger piles
(with their lower surface area to volume ratio), retain more
heat than smaller piles. Ambient temperatures have a sig-
nificant impact on composting operations (Benedict, 1988).
A typical aerated static pile for a large operation would
be triangularly shaped in cross section about 3 meters(m)
high by 4.5 to 7.5 m wide (15 to 25 feet) at the base by 12
to 15 m long (39 to 50 feet) (Haug, 1980). One survey
study indicates that extended aerated static pile (where
piles are formed on the side of older piles) heights were
typically 12 to 13 feet high. Minimum depths of base and
cover materials (recycled compost, wood chips etc.) were
12 and 18 inches, respectively (Benedict, 1988).
In windrow composting, the compost mix is stacked in
long parallel rows. In cross section, windrows may range
from rectangular to trapezoidal to triangular, depending
174
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upon the material and the turning equipment. Atypical trap-
ezoidal windrow might be 1.2 m (4 feet) high by 4.0 m (13
feet) at its base and 1 .0 m (3 feet) across the top (Haug,
1980).
Monitoring and Sampling of the Compost
Pile
Unless the entire composting mass is subject to the
pathogen reduction temperatures, organisms may survive
and repopulate the mass once the piles or windrows are
cooled. Therefore it is crucial that temperatures be attained
throughout the entire pile. For aerated static piles or in-
vessel systems using static procedures such as tunnels or
silos, temperature monitoring should represent points
throughout the pile, including areas which typically are the
coolest. In aerated static piles this is usually the toes of
the pile (Figure 1). Temperatures should be taken at many
locations and at various depths to be assured that the core
of the pile maintains the require temperature. Records of
the temperature, date, and time should be maintained and
reviewed on an ongoing basis. Microbial analysis should
at a minimum be taken in a matter to represent the entire
compost pile. Operational parameters such as moisture,
oxygen as well as the others should be monitored at a
frequency necessary to assure that the compost opera-
tion is operating within acceptable ranges.
For composting, vector attraction reduction (VAR) is
achieved through the degradation of volatile solids. The
extent to which the volatile solids are degraded is often
referred to as compost stability. Stabilization requires suf-
ficient time for the putrescible organic compounds and for
other potential food sources for vectors to decompose.
Under this vector attraction reduction option, the Part 503
requires that biosolids be maintained under aerobic condi-
tions for at least 14 days, during which time temperatures
are over 40°C (104°F), and the average temperature is
over 45°C (113°F) (503.33(b)(5). These criteria are based
on studies which have shown that most of the highly pu-
trescible compounds are decomposed during the first 14
days of composting and that significant stability is achieved
at mesophilic (<45 ° C ) temperatures.
Recommendations for Specific
Technologies
Aerated static pile - Aerated static piles should be cov-
ered with an insulation layer of sufficient thickness to en-
sure that temperatures throughout the pile, including the
pile surface, reach 55° C. It is recommended that the insu-
lation layer be at least 1 foot thick. Screened compost is a
more effective insulation than unscreened compost or wood
chips. Screened compost also provides more odor control
than the other two materials.
Air flow rate and the configuration of an aeration system
are other factors which affects temperature. Air flow must
be sufficient to supply oxygen to the pile, but excessive
aeration removes heat and moisture from the composting
material. The configuration of an aeration system is also
important. Aeration piping too close to pile edges may re-
sult in uneven temperatures in the pile and excessive cool-
ing at the pile toes. If holes in the perforated piping are too
large or not distributed properly, portions of the pile may
receive too much air and be too cool as a result.
Windrows - Compliance with the pathogen reduction
requirements for windrows depends on proper windrow size
and configuration. If windrows are too small, the high sur-
face area to volume ratio will result in excessive heat loss
from the pile sides. Turning must ensure that all material
A 1 foot thick insulation layer is recommended to ensure that the
entire pile reaches pathogen reduction temperatures.
Blower
Pile toes are usually the coolest part of an aerated static pile.
Figure la. Aerated static pile.
175
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Pile Core
\
7 \
Material turned into the pile core reaches pathogen reduction temperatures.
Operations must ensure that all material is turned into the core at some point
during composting and that core temperatures rise to 55 degrees after turning.
Figure 1 b. Windrow.
in a windrow be introduced into the pile core and raised to
pathogen reduction temperatures. This is most easily
achieved with a windrow turning machine.
In-Vessel systems- It is difficult to provide guidance for
these systems as there are numerous types with varying
configurations. Two key factors that apply to all in-vessel
systems are aeration and available carbon. As with aer-
ated static piles, the air flow configuration and rate can
affect the distribution of aeration to different parts of a
composting mass and the temperature profile of a pile.
Many in-vessel systems use sawdust as an amendment.
This may not provide sufficient energy if the volatile solids
in the biosolids are low.
Requirements for Class A/Class B Compost
For class A biosolids, aerated static pile, conventional
windrow and in-vessel composting methods must meet the
PFRP requirements, including the following temperature/
time requirements:
. Aerated static piles and in-vessel systems must be
maintained at a minimum operating temperature of
55°C (131°F) for at least 3 days; and
. Windrow piles must be maintained at a minimum op-
erating temperature of 55°C (131°F) for 15 days or
longer. The piles must be turned five times during this
period.
For class B biosolids, aerated static pile, conventional
windrow and in-vessel composting methods must meet the
PSRP requirements, including the following temperature/
time requirements:
. The compost pile must be maintained at a minimum of
40°C for at least five days; and
. During the five-day period, the temperature must rise
above 55°C for at least four hours to ensure pathogen
destruction. This is usually done near the end of the
active composting phase in order to prevent inactivat-
ing the organic destroying bacteria.
To meet 40 CFR Part 503 vector attraction reduction
requirements using the "aerobic process" alternative,
composting operations must ensure that the process lasts
for 14 days or longer at a temperature greater than 40°C.
In addition, the average temperature must be higher than
45°C,
Additional References
Benedict, Arthur et al., Composting Municipal Sludge: A
Technology Evaluation, Pollution Technology Review
No. 152, Noyes Data Corporation, Park Ridge, New
Jersey, 1988.
BioCycle, Managing Sludge by Composting, JG Press Inc.,
Emmaus, PA, 1984.
Goldstein, N. et al., "1994 Biocycle Biosolids Survey."
Biocycle: Journal of Composting and Recycling, De-
cember 1994.
Haug, Roger T., Compost Engineering, Principles and Prac-
tice, Ann Arbor Science Publishers, Ann Arbor, Michi-
gan, 1980.
Information Transfer Inc., 1977 National Conference on
Composting of Municipal Residues and Sludges, Au-
gust 23-25,1977, Information Transfer, Inc., Rockville,
Maryland, 1978.
Jensen, Ric, Research Encourages Biosolids Re-use, En-
vironmental Protection, December 1993.
The BioCycle Guide to In-Vessel Composting, JG Press
Inc., Emmaus, PA 1986.
U.S. EPA, A Plain English Guide to the EPA Part 503
Biosolids Rule. Office of Wastewater Management.
EPA/832/R-93/003. September 1994.
U.S. EPA Guidance for NPDES Compliance Inspectors,
Evaluation of Sludge Treatment Processes. Office of
Wastewater Enforcement and Compliance, Office of
Water. November 1991.
176
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U.S. EPA, Summary Report, In-Vessel Composting of Mu- mation, Office of Research and Development. EPA 625/4-
nicipal Wastewater Sludge. EPA/625/8-89/016. Sep- 85-014. August, 1985.
tember 1989.
U.S. EPA, Environmental Regulations and Technology, Use
U.S. EPA, Seminar Publication: Composting of Municipal Waste- and Disposal of Municipal Wastewater Sludge. EPA
water Sludges. Center for Environmental Research Infor- 625/1 0-84/003.1984.
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The National Response Team's Integrated Contingency Plan Guidance (One Plan) file:///G|/one-plan.html
The National Response Team's Integrated
Contingency Plan Guidance (One Plan)
AGENCY: Environmental Protection Agency (EPA), U.S. Coast Guard (USCG), Minerals Management
Service (MMS), Research and Special Programs Administration (RSPA), Occupational Safety and Health
Administration (OSHA)
ACTION: Notice
SUMMARY: The U.S. Environmental Protection Agency, as the chair of the National Response Team
(NRT), is announcing the availability of the NRT's Integrated Contingency Plan Guidance ("one plan").
This guidance is intended to be used by facilities to prepare emergency response plans. The intent of the
NRT is to provide a mechanism for consolidating multiple plans that facilities may have prepared to
comply with various regulations into one functional emergency response plan or integrated contingency
plan (ICP). This notice contains the suggested TCP outline as well as guidance on how to develop an ICP
and demonstrate compliance with various regulatory requirements. The policies set out in this notice are
intended solely as guidance.
ADDRESSES: Additional copies of this one-plan guidance can be obtained by writing to the following
address: William Finan, U.S. Environmental Protection Agency, Mail Code 5101, 401 M Street SW,
Washington, DC 20460. Copies of the ICP Guidance are also available by calling the
EPCRA/RCRA/Superfund Hotline at (800) 424-9346 (in the Washington, DC, metropolitan area, (703)
412-9810). In addition, this guidance is available electronically at the home page of EPA's Chemical
Emergency Preparedness and Prevention Office (http://www.epa.gov/swercepp/).
FOR FURTHER INFORMATION CONTACT: William Finan, U.S. Environmental Protection
Agency, Mail Code 5101, 401 M Street, SW, Washington, DC 20460, at (202) 260-0030 (E-Mail
homepage.ceppo@epamail.epa.gov — please include "one plan" in the subject line). In addition, the
EPCRA/RCRA/Superfund Hotline can answer general questions about the guidance.
For further information and guidance on complying with specific regulations, contact: for EPA's Oil
Pollution Prevention Regulation: Bobbie Lively-Diebold, U.S. Environmental Protection Agency, Mail
Code 5203G, 401 M Street, SW, Washington, DC 20460, at (703) 356-8774 (E-Mail
Lively.Barbara@epamail.epa.gov), or the SPCC Information Line at (202) 260-2342); for the U.S. Coast
Guard's Facility Response Plan Regulation: LCDR Mark Hamilton, U.S. Coast Guard, Commandant
(G-MOR), 2100 2nd Street, SW, Washington, DC 20593, at 202-267-1983 (E-Mail
M.Hamilton/G-M03@CGSMTP.uscg.mil); for DOT/RSPA's Pipeline Response Plan Regulation: Jim
Taylor, U.S. Department of Transportation, Room 2335, 400 7th Street, SW, Washington, DC 20590 at
(202) 366-8860 (E-Mail OPATEAM@RSPA.DOT.GOV); for pertinent OSHA regulations, contact
either your Regional or Area OSHA office; for DOI/MMS' Facility Response Plan Regulation: Larry Ake,
U.S. Department of the Interior - Minerals Management Service, MS 4700, 381 Elden Street, Herndon,
VA 22070-4817 at (703) 787-1567 (E-Mail Larry_Ake@SMTP.MMS.GOV); for EPA's Risk
Management Program Regulation: William Finan (see above); and for RCRA's Contingency Planning
Requirements, contact the EPCRA/RCRA/Superfund Hotline (see above).
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The NRT welcomes comments on specific implementation issues related to this guidance. Please provide
us with information about the successful use of this guidance, about problems with using this guidance, as
well as suggestions for improving the guidance. Send comments to William Finan (see above) or to any of
the other people listed in the previous paragraph.
SUPPLEMENTARY INFORMATION:
Presidential Review Findings
Section 112(r)(10) of the Clean Air Act required the President to conduct a review of federal release
prevention, mitigation, and response authorities. The Presidential Review was delegated to EPA, in
coordination with agencies and departments that are members of the National Response Team (NRT).
The Presidential Review concluded that, while achieving its statutory goals to protect public safety and
the environment, the current system is complex, confusing, and costly. It identified several key problem
areas and recommended a second phase to address these issues. One of the issues identified by the
Presidential Review is the multiple and overlapping federal requirements for facility emergency response
plans.
NRT Policy Statement
This one-plan guidance is intended to be used by facilities to prepare emergency response plans for
responding to releases of oil and non-radiological hazardous substances. The intent of the NRT is to
provide a mechanism for consolidating multiple plans that facilities may have prepared to comply with
various regulations into one functional emergency response plan or integrated contingency plan (ICP). A
number of statutes and regulations, administered by several federal agencies, include requirements for
emergency response planning. A particular facility may be subject to one or more of the following federal
regulations:
EPA's Oil Pollution Prevention Regulation (SPCC and Facility Response Plan Requirements) - 40 CFR
part 112.7(d) and 112.20-.21;
MMS's Facility Response Plan Regulation - 30 CFR part 254;
RSPAs Pipeline Response Plan Regulation - 49 CFR part 194;
USCG's Facility Response Plan Regulation - 33 CFR part 154, Subpart F;
EPA's Risk Management Programs Regulation - 40 CFR part 68;
OSHAs Emergency Action Plan Regulation - 29 CFR 1910.38(a);
OSHAs Process Safety Standard - 29 CFR 1910.119;
OSHAs HAZWOPER Regulation - 29 CFR 1910.120; and
EPA's Resource Conservation and Recovery Act Contingency Planning Requirements - 40 CFR part 264,
Subpart D, 40 CFR part 265, Subpart D, and 40 CFR 279.52.
In addition, facilities may also be subject to state emergency response planning requirements that this
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guidance does not specifically address. Facilities are encouraged to coordinate development of their ICP
with relevant state and local agencies to ensure compliance with any additional regulatory requirements.
Individual agencies' planning requirements and plan review procedures are not changed by the advent of
the ICP format option. This one-plan guidance has been developed to assist facilities in demonstrating
compliance with the existing federal emergency response planning requirements referenced above.
Although it does not relieve facilities from their current obligations, it has been designed specifically to
help meet those obligations. Adherence to this guidance is not required in order to comply with federal
regulatory requirements. Facilities are free to continue maintaining multiple plans to demonstrate federal
regulatory compliance; however, the NRT believes that an integrated plan prepared in accordance with
this guidance is a preferable alternative.
The NRT realizes that many existing regulations pertaining to contingency planning require review by a
specific agency to determine compliance with applicable requirements. It is not the intent of the NRT to
modify existing agency review procedures or to supersede the requirements of a regulation.
This one-plan guidance was developed through a cooperative effort among numerous NRT agencies,
state and local officials, and industry and community representatives. The NRT and the agencies
responsible for reviewing and approving federal response plans to which the ICP option applies agree that
integrated response plans prepared in the format provided in this guidance will be acceptable and be the
federally preferred method of response planning. The NRT realizes that alternate formats for integrating
multiple plans already exist and that others likely will be developed. Certain facilities may find those
formats more desirable than the one proposed here. The NRT believes that a single functional plan is
preferable to multiple plans regardless of the specific format chosen. While they are acceptable, other
formats may not allow the same ease of coordination with external plans. In any case, whatever format a
facility chooses, no individual NRT agency will require an integrated response planning format differing
from the ICP format described here. The NRT anticipates that future development of all federal
regulations addressing emergency response planning will incorporate use of the ICP guidance. Also,
developers of state and local requirements will be encouraged to be consistent with this document.
The ICP guidance does not change existing regulatory requirements; rather, it provides a format for
organizing and presenting material currently required by the regulations. Individual regulations are often
more detailed than the ICP guidance. To ensure full compliance, facilities should continue to read and
comply with all of the federal regulations that apply to them. Furthermore, facilities submitting an ICP (in
whatever format) for agency or department review will need to provide a cross-reference to existing
regulatory requirements so that plan reviewers can verify compliance with these requirements. The
guidance contains a series of matrices designed to assist owners and operators in consolidating various
plans and documenting compliance with federal regulatory requirements. (See Attachments 2 and 3.) The
matrices can be used as the basis for developing a cross-reference to various regulatory requirements.
This guidance also provides a useful contingency planning template for owners and operators of facilities
not subject to the federal regulations cited previously.
Integrated Contingency Plan Philosophy
The ICP will minimize duplication in the preparation and use of emergency response plans at the same
facility and will improve economic efficiency for both the regulated and regulating communities. Facility
expenditures for the preparation, maintenance, submission, and update of a single plan should be much
lower than for multiple plans.
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The use of a single emergency response plan per facility will eliminate confusion for facility first
responders who often must decide which of their plans is applicable to a particular emergency. The
guidance is designed to yield a highly functional document for use in varied emergency situations while
providing a mechanism for complying with multiple agency requirements. Use of a single integrated plan
should also improve coordination between facility response personnel and local, state, and federal
emergency response personnel.
The adoption of a standard plan format should facilitate integration of plans within a facility, in the event
that large facilities may need to prepare separate plans for distinct operating units. The TCP concept
should also allow coordination of facility plans with plans that are maintained by local emergency
planning committees (LEPCs),7 Area Committees,2 co-operatives, and mutual aid organizations. In some
cases, there are specific regulatory requirements to ensure that facility plans are consistent with external
planning efforts. Industry use of this guidance along with active participation on local and Area
Committees will improve the level of emergency preparedness and is therefore highly encouraged.
(7 LEPC plans are developed by LEPCs in coordination with facility emergency response coordinators
under section 303 of the Emergency Planning and Community Right-to-Know Act.)
(2 Area Contingency Plans are developed by Area Committees pursuant to section 4202(a)(6) of the Oil
Pollution Act of 1990 (OPA).)
In some areas, it may be possible to go beyond simple coordination of plans and actually integrate certain
information from facility plans with corresponding areas of external plans. The adoption of a single,
common ICP outline such as the one proposed in this guidance would facilitate a move toward
integration of facility plans with local, state, and federal plans.
The projected results described above will ultimately serve the mutual goal of the response community to
more efficiently and effectively protect public health, worker safety, the environment, and property.
Scope
This one-plan guidance is provided for any facility subject to federal contingency planning regulations and
is also recommended for use by other facilities to improve emergency preparedness through planning. In
this context, the term "facility" is meant to have a wide connotation and may include, but is not limited to,
any mobile or fixed onshore or offshore building, structure, installation, equipment, pipe, or pipeline.
Facility hazards need to be addressed in a comprehensive and coordinated manner. Accordingly, this
guidance is broadly constructed to allow for facilities to address a wide range of risks in a manner tailored
to the specific needs of the facility. This includes both physical and chemical hazards associated with
events such as chemical releases, oil spills, fires, explosions, and natural disasters.
Organizational Concepts
The ICP format provided in this one-plan guidance (See Attachment 1) is organized into three main
sections: an introductory section, a core plan, and a series of supporting annexes. It is important to note
that the elements contained in these sections are not new concepts, but accepted emergency response
activities that are currently addressed in various forms in existing contingency planning regulations. The
goal of the NRT is not to create new planning requirements, but to provide a mechanism to consolidate
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existing concepts into a single functional plan structure. This approach would provide a consistent basis
for addressing emergency response concerns as it gains widespread use among facilities.
The introduction section of the plan format is designed to provide facility response personnel, outside
responders, and regulatory officials with basic information about the plan and the entity it covers. It calls
for a statement of purpose and scope, a table of contents, information on the current revision date of the
plan, general facility information, and the key contact(s) for plan development and maintenance. This
section should present the information in a brief factual manner.
The structure of the sample core plan and annexes in this guidance is based on the structure of the
National Interagency Incident Management System (NIIMS) Incident Command System (ICS). NIEVIS
ICS is a nationally recognized system currently in use by numerous federal, state, and local organizations
(e.g., some Area Committees under OP A). NIIMS ICS is a type of response management system that has
been used successfully in a variety of emergency situations, including releases of oil or hazardous
substances. NIEVIS ICS provides a commonly understood framework that allows for effective interaction
among response personnel. Organizing the ICP along the lines of the NIEVIS ICS will allow the plan to
dovetail with established response management practices, thus facilitating its ease of use during an
emergency.
The core plan is intended to contain essential response guidance and procedures. Annexes would contain
more detailed supporting information on specific response management functions. The core plan should
contain frequent references to the response critical annexes to direct response personnel to parts of the
ICP that contain more detailed information on the appropriate course of action for responders to take
during various stages of a response. Facility planners need to find the right balance between the amount
of information contained in the core plan versus the response critical annexes (Annexes 1 through 3).
Information required to support response actions at facilities with multiple hazards will likely be
contained in the annexes. Planners at facilities with fewer hazards may choose to include most if not all
information in the core plan. Other annexes (e.g., Annexes 4 through 8) are dedicated to providing
information that is non-critical at the time of a response (e.g., cross-references to demonstrate regulatory
compliance and background planning information). Consistent with the goal of keeping the size of the
ICP as manageable as practicable, it is not necessary for a plan holder to provide its field responders with
all the compliance documentation (e.g., Annexes 4 through 8) that it submits to regulatory agencies.
Similarly, it may not be necessary for a plan holder to submit all annexes to every regulatory agency for
review.
Basic headings are consistent across the core plan and annexes to facilitate ease of use during an
emergency. These headings provide a comprehensive list of elements to be addressed in the core plan and
response annexes and may not be relevant to all facilities. Planners should address those regulatory
elements that are applicable to their particular facilities. Planners at facilities with multiple hazards will
need to address most, if not all, elements included in this guidance. Planners at facilities with fewer
hazards may not need to address certain elements. If planners choose to strictly adopt the ICP outline
contained in this guidance but are not required by regulation to address all elements of the outline, they
may simply indicate "not applicable" for those items where no information is provided. A more detailed
discussion of the core plan and supporting annexes follows.
Core Plan
The core plan is intended to reflect the essential steps necessary to initiate, conduct, and terminate an
emergency response action: recognition, notification, and initial response, including assessment,
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mobilization, and implementation. This section of the plan should be concise and easy to follow. A rule of
thumb is that the core plan should fit in the glovebox of a response vehicle. The core plan need not detail
all procedures necessary under these phases of a response but should provide information that is time
critical in the earliest stages of a response and a framework to guide responders through key steps
necessary to mount an effective response. The response action section should be convenient to use and
understandable at the appropriate skill level.
The NRT recommends the use of checklists or flowcharts wherever possible to capture these steps in a
concise easy-to-understand manner. The core plan should be constructed to contain references to
appropriate sections of the supporting annexes for more detailed guidance on specific procedures. The
NRT anticipates that for a large, complex facility with multiple hazards the annexes will contain a
significant amount of information on specific procedures to follow. For a small facility with a limited
number of hazard scenarios, the core plan may contain most if not all of the information necessary to
carry out the response thus obviating the need for more detailed annexes. The checklists, depending on
their size and complexity, can be in either the core or the support section.
The core plan should reflect a hierarchy of emergency response levels. A system of response levels is
commonly used in emergency planning for classifying emergencies according to seriousness and assigning
an appropriate standard response or series of response actions to each level. Both complex and simple
industrial facilities use a system of response levels for rapidly assessing the seriousness of an emergency
and developing an appropriate response. This process allows response personnel to match the emergency
and its potential impacts with appropriate resources and personnel. The concept of response levels should
be considered in developing checklists or flowcharts designed to serve as the basis for the core plan. Note
that for those facilities subject to planning requirements under OP A, response levels in the core plan may
not necessarily correspond to discharge planning amounts (e.g., average most probable discharge,
maximum most probable discharge, and worst case discharge).
Facility owners and operators should determine appropriate response levels based on 1) the need to
initiate time-urgent response actions to minimize or prevent unacceptable consequences to the health and
safety of workers, the public, or the environment; and 2) the need to communicate critical information
concerning the emergency to offsite authorities. The consideration and development of response levels
should, to the extent practicable, be consistent with similar efforts that may have been taken by the
LEPC, local Area Committee, or mutual aid organization. Response levels, which are used in
communications with offsite authorities, should be fully coordinated and use consistent terminology.
Annexes
The annexes are designed to provide key supporting information for conducting an emergency response
under the core plan as well as document compliance with regulatory requirements not addressed
elsewhere in the TCP. Annexes are not meant to duplicate information that is already contained in the core
plan, but to augment core plan information. The annexes should relate to the basic headings of the core
plan. To accomplish this, the annexes should contain sections on facility information, notification, and a
detailed description of response procedures under the response management system (i.e, command,
operations, planning, logistics, and finance). The annexes should also address issues related to post
accident investigation, incident history, written follow-up reports, training and exercises, plan critique and
modification process, prevention, and regulatory compliance, as appropriate.
The TCP format contained in this guidance is based on the NTEVIS ICS. If facility owners or operators
choose to follow fundamental principles of the NIEVIS ICS, then they may adopt NIEVIS ICS by reference
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rather than having to describe the system in detail in the plan. The owner or operator should identify
where NIIMS ICS documentation is kept at the facility and how it will be accessed if needed by the
facility or requested by the reviewing agency.
Regardless of the response management system used, the plan should include an organization chart,
specific job descriptions,^ a description of information flow ensuring liaison with the on-scene
coordinator (OSC), and a description of how the selected response management system integrates with a
Unified Command.^ If a system other than NIIMS ICS is used, the plan should also identify how it differs
from NIIMS or provide a detailed description of the system used.
(3 OP A 90 planning requirements for marine transfer facilities (33 CFR 154.1035) require job
descriptions for each spill management team member regardless of the response management system
employed by the facility.)
(4 Under NIEVIS ICS, the command module has traditionally been represented by a single incident
commander (supported by a command staff) who directs efforts of and receives input from the four
supporting functional areas (planning, logistics, operations, and finance).
More recently, a Unified Command System as described in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) found at 40 CFR part 300 has been used for larger spill responses
where the command module is comprised of representatives from the federal government (i.e., federal
on-scene coordinator), state government (state on-scene coordinator), and the responsible party working
in a cooperative manner. Unified Command allows all parties who have jurisdictional or functional
responsibility for the incident to jointly develop a common set of incident objectives and strategies. Such
coordination should be guided by procedures found in the NCP (see figure la at 40 CFR 300.105(e)(l))
and the applicable Area Contingency Plan.)
The NRT anticipates that the use of linkages (i.e., references to other plans) when developing annexes
will serve several purposes. Linkages will facilitate integration with other emergency plans within a
facility (until such plans can be fully incorporated into the ICP) and with external plans, such as LEPC
plans and Area Contingency Plans (ACPs). Linkages will also help ensure that the annexes do not become
too cumbersome. The use of references to information contained in external plans does not relieve
facilities from regulatory requirements to address certain elements in a facility-specific manner and to
have information readily accessible to responders. When determining what information may be linked by
reference and what needs to be contained in the ICP, response planners should carefully consider the time
critical nature of the information. If instructions or procedures will be needed immediately during an
incident response, they should be presented for ready access in the ICP. The following information would
not normally be well-suited for reference to documents external to the ICP: core plan elements, facility
and locality information (to allow for quick reference by responders on the layout of the facility and the
surrounding environment and mitigating actions for the specific hazard(s) present), notification
procedures, details of response management personnel's duties, and procedures for establishing the
response management system. Although linkages provide the opportunity to utilize information
developed by other organizations, facilities should note that many LEPC plans and ACPs may not
currently possess sufficient detail to be of use in facility plans or the ICP. This information may need to be
developed by the facility until detailed applicable information from broader plans is available.
In all cases, referenced materials must be readily available to anticipated plan users. Copies of documents
that have been incorporated by reference need not be submitted unless it is required by regulation. The
appropriate sections of referenced documents that are unique to the facility, those that are not nationally
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recognized, those that are required by regulation, and those that could not reasonably be expected to be
in the possession of the reviewing agency, should be provided when the plan is submitted for review
and/or approval. Discretion should be used when submitting documents containing proprietary data. It is,
however, necessary to identify in the TCP the specific section of the document being incorporated by
reference, where the document is kept, and how it will be accessed if needed by the facility or requested
by the reviewing agency. In addition, facility owners or operators are reminded to take note of submission
requirements of specific regulations when determining what materials to provide an agency for review as
it may not be necessary to submit all parts of an ICP to a particular agency.
As discussed previously, this guidance contains a series of matrices designed to assist owners and
operators in the plan consolidation process and in the process of ensuring and documenting compliance
with regulatory requirements. The matrix in Attachment 2 to this guidance displays areas of current
regulations that align with the suggested elements contained in this guidance document. When addressing
each element of the ICP outline, plan drafters can refer to this matrix to identify specific regulatory
requirements related to that element. The matrices in Attachment 3 to this guidance display regulatory
requirements as contained in each of the regulations listed in the NRT policy statement above (which are
applicable to many facilities) along with an indication of where in the suggested ICP outline these
requirements should be addressed. If a facility chooses to follow the ICP outline, these matrices can be
included as Annex 8 to a facility's ICP to provide the necessary cross-reference for plan reviewers to
document compliance with various regulatory requirements. To the extent that a plan deviates from the
suggested ICP outline, plan drafters will have to alter the matrices to ensure that the location of
regulatory requirements within the ICP is clearly identified for plan reviewers.
Integrated Contingency Plan Elements
Presented below is a list of elements to be addressed in the ICP and a brief explanation, displayed in
italicized text, of the nature of the information to be contained in that section of the ICP. Attachment 1
presents the complete outline of the ICP without the explanatory text. As discussed previously, the
elements are organized into three main sections: plan introduction, core plan, and response annexes.
Section I - Plan Introduction Elements
1. Purpose and Scope of Plan Coverage
This section should provide a brief overview of facility operations and describe in general the physical
area, and nature of hazards or events to which the plan is applicable. This brief description will help
plan users quickly assess the relevancy of the plan to a particular type of emergency in a given location.
This section should also include a list of which regulation's) are being addressed in the ICP.
2. Table of Contents
This section should clearly identify the structure of the plan and include a list of annexes. This will
facilitate rapid use of the plan during an emergency.
3. Current Revision Date
This section should indicate the date that the plan was last revised to provide plan users with
information on the currency of the plan. More detailed information on plan update history (i.e.. a
record of amendments) may be maintained in Annex 6 (Response Critique and Plan Review and
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Modification Process).
4. General Facility Identification Information
a. Facility name
b. Owner/operator/agent (include physical and mailing address and phone number)
c. Physical address of the facility (include county/parish/borough, latitude/longitude, and directions)
d. Mailing address of the facility (correspondence contact)
e. Other identifying information (e.g., ID numbers, SIC Code, oil storage start-up date)
f Key contact(s) for plan development and maintenance
g. Phone number(s) for key contact(s)
h. Facility phone number
i. Facility fax number
This section should contain a brief profile of the facility and its key personnel to facilitate rapid
identification of key administrative information.
Section II - Core Plan Elements
1. Discovery
This section should address the initial action the person(s) discovering an incident will take to assess the
problem at hand and access the response system. Recognition, basic assessment, source control (as
appropriate), and initial notification of proper personnel should be addressed in a manner that can be
easily understood by everybody in the facility. The use of checklists or flowcharts is highly
recommended.
2. Initial Response
a. Procedures for internal and external notifications (i.e., contact, organization name, and phone number
of facility emergency response coordinator, facility response team personnel, federal, state, and local
officials)
b. Establishment of a response management system
c. Procedures for preliminary assessment of the situation, including an identification of incident type,
hazards involved, magnitude of the problem, and resources threatened
d. Procedures for establishment of objectives and priorities for response to the specific incident,
including:
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(1) Immediate goals/tactical planning (e.g., protection of workers and public as priorities)
(2) Mitigating actions (e.g., discharge/release control, containment, and recovery, as appropriate)
(3) Identification of resources required for response
e. Procedures for implementation of tactical plan
f Procedures for mobilization of resources
This section should provide for activation of the response system following discovery of the incident. It
should include an established 24-hour contact point (i.e.. that person and alternate who is called to set
the response in motion) and instructions for that per son on who to call and what critical information to
pass. Plan drafters should also consider the need for bilingual notification. It is important to note that
different incident types require that different parties be notified. Appropriate federal, state, and local
notification requirements should be reflected in this section of the ICP. Detailed notification lists may
be included here or in Annex 2. depending upon the variety of notification schemes that a facility may
need to implement. For example, the release of an extremely hazardous substance will require more
extensive notifications (i.e.. to State Emergency Response Commissions (SERCs) andLEPCs) than a
discharge of oil. Even though no impacts or awareness are anticipated outside the site, immediate
external notifications are required for releases ofCERCLA andEPCRA substances. Again, the use of
forms, such as flowcharts, checklists, call-down lists, is recommended.
This section should instruct personnel in the implementation of a response management system for
coordinating the response effort. More detailed information on specific components and functions of the
response management system (e.g.. detailed hazard assessment, resource protection strategies) may be
provided in annexes to the ICP.
This part of the plan should then provide information on problem assessment, establishment of
objectives and priorities, implementation of a tactical plan, and mobilization of resources. In
establishing objectives and priorities for response, facilities should perform a hazard assessment using
resources such as Material Safety Data Sheets (MSDSs) or the Chemical Hazard Response Information
System (CHRIS) manual. Hazardous Materials Emergency Planning Guide (NRT-1). developed by the
NRTto assist community personnel with emergency response planning, provides guidance on
developing hazard analyses. If a facility elects to provide detailed hazard analysis information in a
response annex, then a reference to that annex should be provided in this part of the core plan.
Mitigating actions must be tailored to the type of hazard present. For example, containment might be
applicable to an oil spill (i.e.. use of booming strategies) but would not be relevant to a gas release. The
plan holder is encouraged to develop checklists, flowcharts, and brief descriptions of actions to be taken
to control different types of incidents. Relevant questions to ask in developing such materials include:
What type of emergency is occurring?
What areas/resources have been or will be affected?
Do we need an exclusion zone?
Is the source under control?
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What type of response resources are needed?
3. Sustained Actions
This section should address the transition of a response from the initial emergency stage to the
sustained action stage where more prolonged mitigation and recovery actions progress under a
response management structure. The NRT recognizes that most incidents are able to be handled by a
few individuals without implementing an extensive response management system. This section of the
core plan should be brief and rely heavily on references to specific annexes to the ICP.
4. Termination and Follow-Up Actions
This section should briefly address the development of a mechanism to ensure that the person in charge
of mitigating the incident can, in coordination with the federal or state OSC as necessary, terminate the
response. In the case of spills, certain regulations may become effective once the "emergency" is
declared over. The section should describe how the orderly demobilization of response resources will
occur. In addition, follow-up actions associated with termination of a response (e.g.. accident
investigation, response critique, plan review, written follow-up reports) should also be outlined in this
section. Plan drafters may reference appropriate annexes to the ICP in this section of the core plan.
Section III - Annexes
Annex 1. Facility and Locality Information
a. Facility maps
b. Facility drawings
c. Facility description/layout, including identification of facility hazards and vulnerable resources and
populations on and off the facility which may be impacted by an incident
This annex should provide detailed information to responders on the layout of the facility and the
surrounding environment. The use of maps and drawings to allow for quick reference is preferable to
detailed written descriptions. These should contain information critical to the response such as the
location of discharge sources, emergency shut-off valves and response equipment, and nearby
environmentally and economically sensitive resources and human populations (e.g.. nursing homes.
hospitals, schools). The ACP and LEPC plan may provide specific information on sensitive
environments and populations in the area. EPA Regional Offices. Coast Guard Marine Safety Offices.
andLEPCs can provide information on the status of efforts to identify such resources. Plan holders may
need to provide additional detail on sensitive areas near the facility. In addition, this annex should
contain other facility information that is critical to response and should complement but not duplicate
information contained in part 4 of the plan introduction section containing administrative information
on the facility.
Annex 2. Notification
a. Internal notifications
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b. Community notifications
c. Federal and state agency notifications
This annex should detail the process of making people aware of an incident (i.e.. who to call, when the
call must be made, and what information/data to provide on the incident). The incident commander is
responsible for ensuring that notifications are carried out in a timely manner but is not necessarily
responsible for making the notifications. ACPs. Regional Contingency Plans (RCPs). and LEPC plans
should be consulted and referenced as a source of information on the roles and responsibilities of
external parties that are to be contacted. This information is important to help company responders
understand how external response officials fit into the picture. Call-down lists must be readily accessible
to ensure rapid response. Notification lists provided in the core plan need not be duplicated here but
need to be referenced.
Annex 3. Response Management System
This annex should contain a general description of the facility's response management system as well as
contain specific information necessary to guide or support the actions of each response management
function (i.e.. command, operations, planning, logistics, and finance) during a response.
a. General
If facility owners or operators choose to follow the fundamental principles of NIIMS ICS (see discussion
of annexes above), then they may adopt NIIMSICS by reference rather than having to describe the
response management system in detail in the plan. In this section of Annex 3. planners should briefly
address either 1) basic areas where their response management system is at variance with NIIMS ICS or
2) how the facility's organization fits into the NIIMS ICS structure. This may be accomplished through a
simple organizational diagram.
If facility owners or operators choose not to adopt the fundamental principles of NIIMS ICS. this section
should describe in detail the structure of the facility response management system.
Regardless of the response management system used, this section of the annex should include the
following information:
Organizational chart:
Specific job description for each position: 5
A detailed description of information flow: and
Description of the formation of a unified command within the response management system.
(5 OP A 90 planning requirements for marine transfer facilities (33 CFR 154.1035) require job
descriptions for each spill management team member regardless of the response management system
employed by the facility.)
b. Command
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(1) List facility Incident Commander and Qualified Individual (if applicable) by name and/or title and
provide information on their authorities and duties
This section of Annex 3 should describe the command aspects of the response management system that
will be used (i.e.. reference NIIMSICS or detail the facility's response management system). The
location (s) ofpredesignated command posts should also be identified.
(2) Information (i.e., internal and external communications)
This section of Annex 3 should address how the facility will disseminate information internally (i.e.. to
facility/response employees) and externally (i.e.. to the public). For example, this section might address
how the facility would interact with local officials to assist with public evacuation and other needs.
Items to consider in developing this section include press release statement forms, plans for
coordination with the news media, community relations plan, needs of special populations, and plans for
families of employees.
(3) Safety
This section of Annex 3 should include a process for ensuring the safety ofresponders. Facilities should
reference responsibilities of the safety officer, federal/state requirements (e.g.. HAZWOPER). and safety
provisions of the ACP. Procedures for protecting facility personnel should be addressed (i.e..
evacuation signals and routes, sheltering in place).
(4) Liaison - Staff Mobilization
This section of Annex 3 should address the process by which the internal and external emergency
response teams will interact. Given that parallel mobilization may be occurring by various response
groups, the process of integration (i.e.. unified command) should be addressed. This includes a process
for communicating with local emergency management especially where safety of the general public is
concerned.
c. Operations
(1) Operational response objectives
(2) Discharge or release control
(3) Assessment/monitoring
(4) Containment
(5) Recovery
(6) Decontamination
(7) Non-responder medical needs, including information on ambulances and hospitals
(8) Salvage plans
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This section of Annex 3 should contain a discussion of specific operational procedures to respond to an
incident. It is important to note that response operations are driven by the type of incident. That is. a
response to an oil spill will differ markedly from a response to a release of a toxic gas to the air. Plan
drafters should tailor response procedures to the particular hazards in place at the facility. A facility
with limited hazards may have relatively few procedures. A larger more complex facility with numerous
hazards is likely to have a series of procedures designed to address the nuances associated with each
type of incident.
d. Planning
(1) Hazard assessment, including facility hazards identification, vulnerability analysis, prioritization of
potential risks
This section of Annex 3 should present a detailed assessment of all potential hazards present at the
facility, an analysis of vulnerable receptors (e.g.. human populations, both workers and the general
public, environmentally sensitive areas, and other facility-specific concerns) and a discussion of which
risks deserve primary consideration during an incident. NRT-1 contains guidance on conducting a
hazard analysis. Also. ACPs and LEPC plans may provide information on environmentally sensitive and
economically important areas, human populations, and protection priorities. Plan drafters should
address the full range of risks present at the facility. By covering actions necessary to respond to a
range of incident types, plan holders can be prepared for small, operational discharges and large
catastrophic releases. One approach that is required by certain regulations, such as the Clean Air Act
(CAA) and OP A is to develop planning scenarios for certain types and sizes of releases (i.e.. worst case
discharge). Facilities may address such planning scenarios and associated calculations in this section of
Annex 3 or as part of a separate annex depending on the size and complexity of the facility.
(2) Protection
This section of Annex 3 should present a discussion of strategies for protecting the vulnerable receptors
identified through the hazard analysis. Primary consideration should be given to minimizing those risks
identified as a high priority. Activities to be considered in developing this section include: population
protection: protective booming: dispersant use, in-situ burning, bioremediation: water intake
protection: wildlife recovery/rehabilitation: natural remediation: vapor suppression: and monitoring.
sampling, and modeling. ACPs and LEPC plans may contain much of this information.
(3) Coordination with natural resource trustees
This section should address coordination with government natural resource trustees. In their role as
managers of and experts in natural resources, trustees assist the federal OSC in developing or selecting
removal actions to protect these resources. In this role, they serve as part of the response organization
working for the federal OSC. A key area to address is interaction with facility response personnel in
protection of natural resources.
Natural resource trustees are also responsible to act on behalf of the public to present a claim for and
recover damages to natural resources injured by an oil spill or hazardous substance release. The
process followed by the natural resource trustees, natural resource damage assessment (NRDA).
generally involves some data collection during emergency response. NRDA regulations provide that the
process may be carried out in cooperation with the responsible party. Thus, the facility may wish to plan
for how that cooperation will occur, including designation of personnel to work with trustees in NRDA.
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(4) Waste management
This section should address procedures for the disposal of contaminated materials in accordance with
federal, state, and local requirements.
e. Logistics
(1) Medical needs of responders
(2) Site security
(3) Communications (internal and external resources)
(4) Transportation (air, land, water)
(5) Personnel support (e.g., meals, housing, equipment)
(6) Equipment maintenance and support
This section of the Annex 3 should address how the facility will provide for the operational needs of
response operations in each of the areas listed above. For example, the discussion of personnel support
should address issues such as: volunteer training: management: overnight accommodations: meals:
operational/administrative spaces: and emergency procedures. The NRT recognizes that certain
logistical considerations may not be applicable to small facilities with limited hazards.
f. Finance/procurement/administration
(1) Resource list
(2) Personnel management
(3) Response equipment
(4) Support equipment
(5) Contracting
(6) Claims procedures
(7) Cost documentation
This section of Annex 3 should address the acquisition of resources (i.e.. personnel and equipment) for
the response and monitoring of incident-related costs. Lists of available equipment in the local and
regional area and how to procure such equipment as necessary should be included. Information on
previously established agreements (e.g.. contracts) with organizations supplying personnel and
equipment (e.g.. oil spill removal organizations) also should be included. This section should also
address methods to account for resources expended and to process claims resultins from the incident.
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Annex 4. Incident Documentation
a. Post accident investigation
b. Incident history
This annex should describe the company's procedures for conducting a follow-up investigation of the
cause of the accident, including coordination with federal, state, and local officials. This annex should
also contain an accounting of incidents that have occurred at the facility, including information on
cause, amount released, resources impacted, injuries, response actions, etc. This annex should also
include information that may be required to prove that the facility met its legal notification
requirements with respect to a given incident, such as a signed record of initial notifications and
certified copies of written follow-up reports submitted after a response.
Annex 5. Training and Exercises/Drills
This annex should contain a description of the training and exercise program conducted at the facility
as well as evidence (i.e.. logs) that required training and exercises have been conducted on a regular
basis. Facilities may follow appropriate training or exercise guidelines (e.g.. National Preparedness for
Response Exercise Program Guidelines) as allowed under the various regulatory requirements.
Annex 6. Response Critique and Plan Review and Modification Process
This annex should describe procedures for modifying the plan based on periodic plan review or lessons
learned through an exercise or a response to an actual incident. Procedures to critique an actual or
simulated response should be apart of this discussion. A list of plan amendments (i.e.. history of
updates) should also be contained in this annex. Plan modification should be viewed as apart of a
facility's continuous improvement process.
Annex 7. Prevention
Some federal regulations that primarily address prevention of accidents include elements that relate to
contingency planning (e.g.. EPA's RMP and SPCC regulations and OSHA 's Process Safety Standard).
This annex is designed to allow facilities to include prevention-based requirements (e.g.. maintenance.
testing, in-house inspections, release detection, site security, containment, fail safe engineering) that are
required in contingency planning regulations or that have the potential to impact response activities
covered in a contingency plan. The modular nature of the suggested plan outline provides planners with
necessary flexibility to include prevention requirements in the ICP. This annex may not need to be
submitted to regulatory agencies for review.
Annex 8. Regulatory Compliance and Cross-Reference Matrices
This annex should include information necessary for plan reviewers to determine compliance with
specific regulatory requirements. To the extent that plan drafters did not include regulatory required
elements in the balance of the ICP. they should be addressed in this annex. This annex should also
include signatory pages to convey management approval and certifications required by the regulations.
such as certification of adequate response resources and/or statements of regulatory applicability as
required by regulations under OP A authority. Finally, this annex should contain cross-references that
indicate where specific regulatory requirements are addressed in the ICP for each regulation covered
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under the plan. As discussed previously. Attachment 3 contains a series of matrices designed to fulfill
this need in those instances where plan drafters adhere to the outline contained in this guidance.
ATTACHMENT 1 - ICP OUTLINE
Section I - Plan Introduction Elements
1. Purpose and Scope of Plan Coverage
2. Table of Contents
3. Current Revision Date
4. General Facility Identification Information
a. Facility name
b. Owner/operator/agent (include physical and mailing address and phone number)
c. Physical address of the facility (include county/parish/borough, latitude/longitude, and directions)
d. Mailing address of the facility (correspondence contact)
e. Other identifying information (e.g., ID numbers, SIC Code, oil storage start-up date)
f Key contact(s) for plan development and maintenance
g. Phone number for key contact(s)
h. Facility phone number
i. Facility fax number
Section II - Core Plan Elements
1. Discovery
2. Initial Response
a. Procedures for internal and external notifications (i.e., contact, organization name, and phone number
of facility emergency response coordinator, facility response team personnel, federal, state, and local
officials)
b. Establishment of a response management system
c. Procedures for preliminary assessment of the situation, including an identification of incident type,
hazards involved, magnitude of the problem, and resources threatened
d. Procedures for establishment of objectives and priorities for response to the specific incident,
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including:
(1) Immediate goals/tactical planning (e.g., protection of workers and public as priorities)
(2) Mitigating actions (e.g., discharge/release control, containment, and recovery, as appropriate)
(3) Identification of resources required for response
e. Procedures for implementation of tactical plan
f Procedure for mobilization of resources
3. Sustained Actions
4. Termination and Follow-Up Actions
Section III - Annexes
Annex 1. Facility and Locality Information
a. Facility maps
b. Facility drawings
c. Facility description/layout, including identification of facility hazards and vulnerable resources and
populations on and off the facility which may be impacted by an incident
Annex 2. Notification
a. Internal notifications
b. Community notifications
c. Federal and state agency notifications
Annex 3. Response Management System
a. General
b. Command
(1) List facility Incident Commander and Qualified Individual (if applicable) by name and/or title and
provide information on their authorities and duties
(2) Information (i.e., internal and external communications)
(3) Safety
(4) Liaison - Staff mobilization
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c. Operations
(1) Operational response objectives
(2) Discharge or release control
(3) Assessment/monitoring
(4) Containment
(5) Recovery
(6) Decontamination
(7) Non-responder medical needs including information on ambulances and hospitals
(8) Salvage plans
d. Planning
(1) Hazard assessment, including facility hazards identification, vulnerability analysis, prioritization of
potential risks
(2) Protection
(3) Coordination with natural resource trustees
(4) Waste management
e. Logistics
(1) Medical needs of responders
(2) Site security
(3) Communications (internal and external resources)
(4) Transportation (air, land, water)
(5) Personnel support (e.g., meals, housing, equipment)
(6) Equipment maintenance and support
f Finance/procurement/administration
(1) Resource list
(2) Personnel management
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(3) Response equipment
(4) Support equipment
(5) Contracting
(6) Claims procedures
(7) Cost documentation
Annex 4. Incident Documentation
a. Post accident investigation
b. Incident history
Annex 5. Training and Exercises/Drills
Annex 6. Response Critique and Plan Review and Modification Process
Annex 7. Prevention
Annex 8. Regulatory Compliance and Cross-Reference Matrices
Attachment 3: Regulatory Cross-Comparison Matrices
-i
RCRA (40 CFR part 264 Subpart Dl, 40 CFR | ICP
part 265 Subpart D2, 40 CFR part 279.52(b)3) | Citation(s)
+
264.52 Content of contingency plan I
+
(a) Emergency response actions4 I
+
(b) Amendments to SPCC plan I
+
(c) Coordination with State and local |II.2.b
response partiesS I III.3.a
+
(d) Emergency coordinator(s) I II.2.a
| III .2
1
(e) Detailed description of emergency |II.2.d.(3)
equipment on-site |II.2.e
| II.2. f
|III.3.f.(1)
|III.3.f.(3)
|Ill.S.f.(4)
1
(f) Evacuation plan if applicable I III.3.b. (3)
1
264.53 Copies of contingency plan I
1
264.54 Amendment of contingency plan I III.6
1
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264.55 Emergency coordinator I II. 2. a
| Ill.S.b. (1)
1
264.56 Emergency procedures I
1
(a) Notification |II.2.a
| III .2
|Ill.S.b. (2)
+
(b) Emergency |II.2.c
identification/characterization I III.3.c. (3)
+
(c) Health/environmental assessment |II.2.c
| III.S.c. (3)
+
(d) Reporting I II. 2.a
| III.2
|III.S.c.(3)
+
(e) Containment |III.3.c.(2)
|III.S.c. (4)
+
(f) Monitoring |III.3.b.(3)
|III.S.c.(3)
+
(g) Treatment, storage, or disposal |III.3.d.(4)
of wastes I
+
(h) Cleanup procedures I
+
(1) Disposal |III.3.d.(4)
+
(2) Decontamination |III.3.c.(6)
-I 1-
(i) Follow-up procedures I II. 4
1
(j) Follow-up report I III.4.a
1
265.52 Content of contingency plan I
1
(a) Emergency response actions6 I
1
(b) Amendments to SPCC plan I
1
(c) Coordination with State and local |II.2.b
response parties? I III.3.a
1
(d) Emergency coordinator(s) I II.2.a
| III .2
1
(e) Detailed description of emergency |II.2.d.(3)
equipment on-site |II.2.e
| II.2. f
|III.3.f.(1)
IHI.S.f.(3)
|Ill.S.f.(4)
+
(f) Evacuation plan if applicable I Ill.S.b. (3)
+
265.53 Copies of contingency plan I
+
265.54 Amendment of contingency plan I III. 6
+
265.55 Emergency coordinator I II. 2. a
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| Ill.S.b. (1)
1
265.56 Emergency procedures I
1
(a) Notification |II.2.a
| III .2
|Ill.S.b. (2)
1
(b) Emergency |II.2.c
identification/characterization I III.3.c. (3)
+
(c) Health/environmental assessment |II.2.c
| III.S.c. (3)
+
(d) Reporting I II. 2.a
| III.2
|III.S.c.(3)
+
(e) Containment |III.3.c.(2)
|III.S.c. (4)
+
(f) Monitoring |III.3.b.(3)
|III.S.c.(3)
+
(g) Treatment, storage, or disposal |III.3.d.(4)
of wastes I
+
(h) Cleanup procedures I
-I 1-
(1) Disposal |III.3.d.(4)
+
(2) Decontamination |III.3.c.(6)
1
(i) Follow-up procedures I II. 4
1
(j) Follow-up report I III.4.a
1
279.52(b)(2) Content of contingency plan I
1
(i) Emergency response actionsS |
1
(ii) Amendments to SPCC plan |
1
(iii) Coordination with State |II.2.b
and local response parties9 I III.3.a
1
(iv) Emergency coordinator (s) |II.2.a
| III .2
1
(v) Detailed description of |II.2.d.(3)
emergency equipment on-site |II.2.e
| II.2. f
|III.3.f.(1)
IHI.S.f.(3)
| Ill.S.f. (4)
1
(vi) Evacuation plan if |III.3.b.(3)
applicable I
+
(3) Copies of contingency plan I
+
(4) Amendment of contingency plan I III.6
+
(5) Emergency coordinator I II. 2. a
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| Ill.S.b. (1)
1
(6) Emergency procedures I
1
(i) Notification |II.2.a
| III .2
|Ill.S.b. (2)
1
(ii) Emergency |II.2.c
identification/characterization |III.3.c. (3)
+
(iii) Health/environmental |II.2.c
assessment |III.3.c.(3)
+
(iv) Reporting I II. 2. a
| III.2
|III.S.c.(3)
+
(v) Containment |III.3.c.(2)
|III.S.c.(4)
+
(vi) Monitoring |III.3.b.(3)
|III.S.c.(3)
-I 1-
(vii) Treatment, storage, or |III.3.d.(4)
disposal of wastes I
+
(viii) Cleanup procedures I
+
(A) Disposal |III.3.d.(4)
+
(B) Decontamination |III.3.c.(6)
1
(ix) Follow-up report I III. 4. a
-I 1-
-I 1-
EPA's Oil Pollution Prevention Regulation ICP
(40 CFR 112) Citation(s
1
112.7(d)(1) Strong spill contingency plan
and written commitment of manpower,
equipment, and materialslO, 11
1
112.20(g) General response planning Ill.S.d.(3
requirements III.6
1
112.20(h) Response plan elements 1.2
III. 8
1
(1) Emergency response action plan
(Appendix Fl.l)
1
(i) Identity and telephone Ill.S.b. (1
number of qualified individual
(Fl.2.5)
1
(ii) Identity of IIII.2
individuals/organizations to |
contact if there is a discharge |
(Fl.3.1) |
1
(iii) Description of |II.2.a
information to pass to response |
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personnel in event of a
reportable spill (F1.3)
1
(iv) Description of facility's II.2.d.(3)
response equipment and its Ill.S.e. (3)
location (Fl.3.2) III.S.e. (6)
Ill.S.f.(1)
Ill.S.f.(3)
1
(v) Description of response II.2.b
personnel capabilities (Fl.3.4) III.3
Ill.S.e.(5)
Ill.S.f.(2)
1
(vi) Plans for evacuation of Ill.S.b.(3)
the facility and a reference to Ill.S.e.(5)
community evacuation plans
(Fl.3.5)
1
(vii) Description of immediate II.2.d.(2)
measures to secure the source III.S.c. (2)
(Fl.7.1) III.S.c. (4)
1
(viii) Diagram of the facility Ill.l.a - b
(F1.9)
1
(2) Facility information (F1.2, I.4.b - d
F2.0) III . 1
1
(3) Information about emergency
response
-I
(i) Identity of private III.S.c. (2)
personnel and equipment to III.S.c. (4)
remove to the maximum extent - (5)
practicable a WCD or other Ill.S.e. (5)
discharges (Fl.3.2, Fl.3.4)
1
(ii) Evidence of contracts or Ill.S.e. (5)
other approved means for Ill.S.f.(5)
ensuring personnel and
equipment availability
1
(iii) Identity and telephone II. 2. a
of individuals/organizations to III.2.b - d
be contacted in event of a Ill.S.b. (2)
discharge (Fl.3.1)
1
(iv) Description of II.2.a
information to pass to response
personnel in event of a
reportable spill (Fl.3.1)
1
(v) Description of response II.2.b
personnel capabilities (Fl.3.4) III.3
III.S.e.(5)
|Ill.S.f.(2)
1
(vi) Description of a |II.2.d.(3)
facility's response equipment, |III.3.e.(3)
location of the equipment, and |III.S.e. (6)
equipment testing (Fl.3.2, |III.3.f.(l)
Fl.3.3) |Ill.S.f. (3)
1
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(vii) Plans for evacuation of Ill.S.b. (3)
the facility and a reference to Ill.S.e.(5)
community evacuation plans as
appropriate (Fl.3.5)
1
(viii) Diagram of evacuation Ill.S.b. (3)
routes (F1.9)
1
(ix) Duties of the qualified II. 2. c
individual (Fl.3.6) II.2.d.(l)
II .2 .e
III.2.b - c
III.S.c.(3)
Ill.S.d.(1)
Ill.S.f
1
4) Hazard evaluation (F1.4) II.2.c
Ill.S.d.(1)
III. 4.b
1
(5) Response planning levels (F1.5, Ill.S.d.(l)
Fl.5.1, Fl.5.2)
1
(6) Discharge detection systems II. 1
(F1.6, Fl.6.1, Fl.6.2)
-I
(7) Plan implementation (F1.7) II.2.d - f
II.3
II.4
1
(i) Response actions to be II.2
carried out (Fl.7.1.1) Ill.S.d.(2)
1
(ii) Description of response Ill.S.d.(1)
equipment to be used for each
scenario (Fl.7.1.1)
1
(iii) Plans to dispose of III.S.c.(5)
contaminated cleanup materials - (6)
(Fl.7.2)
1
(iv) Measures to provide III.S.c. (2)
adequate containment and III.S.c.(4)
drainage of spilled oil Ill.S.d.(2)
(Fl.7.3) Ill.S.d.(4)
1
(8) Self-inspection, Ill.S.e.(6)
drills/exercises, and response III. 5
training (Fl.8.1 - Fl.8.3.2)
1
(9) Diagrams (F1.9) Ill.l.b
1
(10) Security systems (F1.10) Ill.S.e. (2)
1
(11) Response plan cover sheet
(F2.0)
1
112.21 Facility response training and I III. 5
drills/exercises (Fl.8.2, Fl.8.3) I
1
Appendix F Facility-Specific Response I 1.2
Planl2 |
1
1.0 Model Facility-Specific Response |
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Plan
1 . 1 Emergency Response Action Plan
1 . 2 Facility Information
1.3 Emergency Response Information
1.3.1 Notification
1.3.2 Response Equipment List
1.3.3 Response Equipment
Test ing/ Deployment
1.3.4 Personnel
1.3.5 Evacuation Plans
1.3.6 Qualified Individual's
Duties
1.4 Hazard Evaluation
1.4.1 Hazard Identification
1.4.2 Vulnerability Analysis
1.4.3 Analysis of the
Potential for an Oil Spill
1.4.4 Facility Reportable Oil
Spill History
1.5 Discharge Scenarios
1.5.1 Small and Medium
Discharges
1.5.2 Worst Case Discharge
1.6 Discharge Detection Systems
1.6.1 Discharge Detection By
Personnel
1.6.2 Automated Discharge
Detection
1.3
I. 4. a
I.4.b -
I.4.h
II .2 .a
III.l
II .2 .a
III .2 .a
II. 2. d.
Ill .3.6
Ill.S.f
Ill.S.f
- (4)
III .3.6
II. 2. b
III. 3
Ill.S.f
Ill.S.b
III .3.6
II. 2
II .2 .c
III . l.c
Ill.S.d
II .2 .c
Ill.S.d
Ill.S.d
III . 4.b
Ill.S.d
Ill.S.d
II. 1
II. 1
c
- c
(3)
. (3)
. (D
. (3)
. (6)
. (2)
. (3)
. (5)
- (D
- (D
- (D
- (D
- (D
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1.7 Plan Implementation II. 2
1
1.7.1 Response Resources for II.2.d.(3)
Small, Medium, and Worst Case II. 2. f
Spills III.3.c.(3)
Ill.S.d.(2)
Ill.S.f.(1)
Ill.S.f.(3)
I- (4)
1
1.7.2 Disposal Plans |III.3.c.(5)
I- (6)
|Ill.S.d.(4)
1
1.7.3 Containment and Drainage |II.2.d
Planning I III.3.c. (4)
|Ill.S.d.(2)
-I
1.8 Self-Inspection, I
Drills/Exercises, and Response I
Training I
1
1.8.1 Facility Self-Inspection |III.3.e.(6)
1
1.8.2 Facility IIII.5
Drills/Exercises I
1
1.8.3 Response Training I III. 5
1
1.9 Diagrams I 1.4
|III.l.a - c
1
1.10 Security III.3.e. (2)
1
2.0 Response Plan Cover Sheet I.4.b
1. 4.c
I.4.h
III.l
-I 1-
-I 1-
USCG FRP (33 CFR part 154) ICP
Citation (s)
1
154.1026 Qualified individual and II. 2. a
alternate qualified individual Ill.S.b.(1)
1
154.1028 Availability of response Ill.S.f or
resources by contract or other approved III.8
means III.3.f. (5)
1
154.1029 Worst case discharge III.3.d.(l)
1
154.1030 General response plan contents
1
(a) The plan must be written in
English I
1
(b) Organization of the planlS I 1.2
1
(c) Required contents I
1
(d) Sections submitted to COTP I
1
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Cross-references
III.
1
(f) Consistency with NCP and ACPs Ill.S.d.(3
1
154.1035 Significant and substantial harm
facilities
1
(a) Introduction and plan content III.l
1
(1) Facility's name, physical |I.4.a
and mailing address, county, |I.4.c - d
telephone, and fax |I.4.h - i
1
(2) Description of a |I.4.c
facility's location in a manner |
that could aid in locating the |
facility I
1
(3) Name, address, and |I.4.b
procedures for contacting the |II.2.a
owner/operator on 24-hour basis |
1
(4) Table of contents I 1.2
1
(5) Cross index, if IIII.8
appropriate I
1
(6) Record of change(s) to I 1.3
record information on plan I III. 6
updates I
1
(b) Emergency Response Action Plan |
1
(1) Notification procedures
-I 1-
(i) Prioritized list II.2.a
identifying person(s), III.2.a - c
including name, telephone
number, and role in plan,
to be notified in event
of threat or actual
discharge
1
(ii) Information to be Ill.S.b
provided in initial and III.2.a - c
follow-up notifications
to federal, state, and
local agencies
1
(2) Facility's spill mitigation II.2.d.(2)
procedures!4 III.S.c. (2
1
(i) Volume(s) of
persistent and non-
persistent oil groups
1
(ii) Prioritized I II.2
procedures/task I
delegation to mitigate or |
prevent a potential or |
actual discharge or I
emergencies involving |
certain I
equipment/scenarios I
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(iii) List of equipment
and responsibilities of
facility personnel to
mitigate an average most
probable discharge
(3) Facility response
activitieslS
(i) Description of
facility personnel ' s
responsibilities to
initiate/ supervise
response until arrival of
qualified individual
(ii) Qualified
individual ' s
responsibilities/ author! t
y
II. 2. e - f
Ill.S.f. (3)
III . 3.c. (1)
- (5)
II .2 .c
II. 2. e - f
II. 3
II. 4
III.3.C. (3)
II. 1
II. 2
II. 2
(iii) Facility or
corporate organizational
structure used to manage
response actions
(iv) Oil spill response
organization (s) /spill
management team available
by contract or other
approved means
II. 2. b
II. 3
III . 3. a
Ill.S.b
- (4)
III . 3.c
Ill.S.d
III . S.e
l_
II. 2. d.
Ill . S.c
- (5)
III .S.e
Ill.S.f
- (2)
Ill.S.f
1_
. (2)
- (D
- f
(3)
- (4)
- (6)
- (D
- (5)
(v) For mobile
facilities that operate
in more than one COTP,
the oil spill response
organization(s)/spill
management team in the
applicable geographic-
specific appendix
II.2.d.(3)
(4) Fish and wildlife sensitive
environments
III. l.c
III.S.d.(1)
- (2)
(i) Areas of economic
importance and
environmental sensitivity
as identified in the ACP
that are potentially
impacted by a WCD
II .2 .c
(ii) List areas and
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provide maps/charts and
describe response actions
1
(iii) Equipment and II.2.e - f
personnel necessary to Ill.S.f.(3)
protect identified areas III.S.c. (1)
- (5)
1
(5) Disposal plan |III.3.d.(4)
1
(c) Training and exercises I III. 5
1
(d) Plan review and update III. 6
procedures
1
(e) Appendices I.4.C
Ill.l.b
1
(1) Facility specific III.l
information
-I
(2) List of contacts II.2.a
III.2.a - c
Ill.S.b.(1)
1
(3) Equipment lists and records Ill.S.e. (3)
Ill.S.e.(6)
Ill.S.f.(1)
Ill.S.f.(3)
- (5)
1
(4) Communications plan |III.3.b.(2)
1
(5) Site-specific safety and Ill.S.b. (3)
health plan III.S.c.(7)
III.S.e. (1)
1
(6) List of acronyms and
definitions
h-
(7) A geographic-specific
appendix
h-
154.1040 Specific requirements for
substantial harm facilities
h-
154.1041 Specific response information to
be maintained on mobile MTR facilities
1
154.1045 Groups I- IV petroleum oils
1
154.1047 Group V petroleum oils
1
154.1050 Training III.5
1
154.1055 Drills III.5
1
154.1057 Inspection and maintenance of |III.3.e.(6)
response resources I
1
154.1060 Submission and approval I
procedures I
1
154.1065 Plan revision and amendment I III. 6
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procedures
1
154.1070 Deficiencies
1
154.1075 Appeal Process
1
Appendix C Guidelines for determining and Ill.S.f.(3)
evaluating required response resources for
| facility response plans I
I 1
| Appendix D Training elements for oil spill |III.5
| response plans I
-I
-I
USCG FRP (33 CFR part 154) I ICP
| Citation(s)
1
154.1026 Qualified individual and I II. 2. a
alternate qualified individual |III.3.b.(l)
1
154.1028 Availability of response |III.3.f or
resources by contract or other approved I III. 8
means I III.3.f. (5)
1
154.1029 Worst case discharge |III.3.d.(l)
1
154.1030 General response plan contents I
1
(a) The plan must be written in I
English I
1
(b) Organization of the planlS 1.2
1
(c) Required contents
1
(d) Sections submitted to COTP
1
(e) Cross-references III. 8
1
(f) Consistency with NCP and ACPs Ill.S.d.(3)
1
154.1035 Significant and substantial harm
facilities
1
(a) Introduction and plan content III.l
1
(1) Facility's name, physical 1.4.a
and mailing address, county, I.4.C - d
telephone, and fax I.4.h - i
1
(2) Description of a I.4.C
facility's location in a manner
that could aid in locating the
facility
1
(3) Name, address, and |I.4.b
procedures for contacting the |II.2.a
owner/operator on 24-hour basis |
1
(4) Table of contents I 1.2
1
(5) Cross index, if IIII.8
appropriate I
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(6) Record of change(s) to
record information on plan
updates
1.3
III. 6
(b) Emergency Response Action Plan
(1) Notification procedures
(i) Prioritized list
identifying person(s),
including name, telephone
number, and role in plan,
to be notified in event
of threat or actual
discharge
II.2.a
III.2.a - c
(ii) Information to be
provided in initial and
follow-up notifications
to federal, state, and
local agencies
Ill.S.b
III.2.a - c
(2) Facility's spill mitigation
procedures!4
II.2.d.(2)
III.S.c. (2)
(i) Volume(s) of
persistent and non-
persistent oil groups
(ii) Prioritized II.2
procedures/task
delegation to mitigate or
prevent a potential or
actual discharge or
emergencies involving
certain
equipment/scenarios
1
(iii) List of equipment II.2.e - f
and responsibilities of Ill.S.f.(3
facility personnel to III.S.c.(1
mitigate an average most - (5)
probable discharge
1
(3) Facility response II.2.c
activitieslS II.2.e - f
II.3
II.4
III.S.c.(3
1
(i) Description of II. 1
facility personnel's II. 2
responsibilities to
initiate/supervise
response until arrival of
| qualified individual |
I 1
| (ii) Qualified I II.2
| individual's I
| responsibilities/authorit |
I Y I
+ 4
| (iii) Facility or |II.2.b |
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corporate organizational
structure used to manage
response actions
II.3
III. 3.a
Ill.S.b. (2)
- (4)
III . 3.c
III.3.d.(1)
III.3.e - f
(iv) Oil spill response
organization(s)/spill
management team available
by contract or other
approved means
II.2.d.(3)
III.S.c. (4)
- (5)
III.3.e.
Ill.S.f.
- (2)
Ill.S.f.
(6)
;D
(5)
(v) For mobile II.2.d.(3)
facilities that operate
in more than one COTP,
the oil spill response
organization(s)/spill
management team in the
applicable geographic-
specific appendix
1
(4) Fish and wildlife sensitive III.l.c
environments III.3.d.(l)
- (2)
1
(i) Areas of economic II. 2. c
importance and
environmental sensitivity
as identified in the ACP
that are potentially
impacted by a WCD
h
(ii) List areas and
provide maps/charts and
describe response actions
1
(iii) Equipment and II.2.e - f
personnel necessary to Ill.S.f.(3
protect identified areas III.S.c. (1
- (5)
1
(5) Disposal plan III.3.d.(4
1
(c) Training and exercises III. 5
1
(d) Plan review and update III. 6
procedures
1
(e) Appendices I.4.C
Ill.l.b
1
(1) Facility specific III.l
| information I
+ 4
| (2) List of contacts |II.2.a |
| |III.2.a - c |
| | Ill.S.b. (1) |
I + I
| (3) Equipment lists and records |III.3.e.(3) |
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III.3.e.(6)
Ill.S.f.(1)
Ill.S.f.(3)
- (5)
1
(4) Communications plan Ill.S.b.(2)
1
(5) Site-specific safety and Ill.S.b. (3)
health plan |III.3.c.(7)
| III.3.e. (1)
1
(6) List of acronyms and I
definitions I
1
(7) A geographic-specific I
appendix I
1
154.1040 Specific requirements for I
substantial harm facilities I
1
154.1041 Specific response information to |
be maintained on mobile MTR facilities I
1
154.1045 Groups I- IV petroleum oils I
1
154.1047 Group V petroleum oils I
1
154.1050 Training IIII.5
1
154.1055 Drills IIII.5
1
154.1057 Inspection and maintenance of |III.3.e.(6)
response resources
1
154.1060 Submission and approval
procedures
1
154.1065 Plan revision and amendment III. 6
procedures
1
154.1070 Deficiencies
1
154.1075 Appeal Process
1
Appendix C Guidelines for determining and Ill.S.f.(3
evaluating required response resources for
facility response plans
1
Appendix D Training elements for oil spill III.5
response plans
-I 1-
-I 1-
DOT/RSPA FRP (49 CFR part 194) I ICP
| Citation(s
1
194.101 Operators required to submit plans |
+
194.103 Significant and substantial harm: I III. 8
operator's statement I
+
194.105 Worst case discharge |III.3.d.(l)
+
194.107 General response plan requirements |
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1
(a) Resource planning requirements I III. 3.d
1
(b) Language requirements I
1
(c) Consistency with NCP and ACP(s) |III.3.d.(3)
| III. 8
1
(d) Each response plan must include: |
+
(1) Core Plan Contents I
+
(i) An information | 1.4
summary as required in |III.l
194.113 |
+
194.113 (a) Core plan |
information summary I
+
(1) Name and | 1. 4 . b
address of operator |1. 4 . d
+
(2) Description of |I.4.c
each response zone |
+
(b) Response zone I
appendix information I
summary I
+
(1) Core plan | 1.4
information summary |III.l
+
(2) NamePROMPT(SUBSTDATA() Submission and |III.6
approval procedures I
1
194.121 Response plan review and update I III. 6
procedures I
1
pendix)ecommended guidelines for the I I. 2
preparation of response plans I
1
Section 1 Information summary |I.4.b - c
| II .2 .a
| II.2. f
| III. 8
-I 1-
Section 2 Notification procedures I II. 2. a
| III .2
|Ill.S.b.(2)
|III.3.e.(3)
1
Section 3 Spill detection and on- |II.l
scene spill mitigation procedures |II.2.e - f
|III.3.c. (2)
1
Section 4 Response activities |II.2.b
|Ill.S.b. (1)
+
Section 5 List of contacts I II. 2. a
+
Section 6 Training procedures I III. 5
+
Section 7 Drill procedures I III. 5
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Section 8 Response plan review and I III.6 I
update procedures I I
+ I
Section 9 Response zone appendices |II.2.b |
III.3 |
|III.l.a - c |
|III.3 |
-I 1-
-I 1-
OSHA Emergency Action Plans (29 CFR | ICP
1910.38(a)) and Process Safety (29 CFR | Citation(s)
1910.119) |
+
1910.38(a) Emergency action plan I
+
(1) Scope and applicability |III.3.c.(l)
| Ill.S.d
+
(2) Elements I
+
(i) Emergency escape procedures |II.2
and emergency escape route |II.2.c
assignments |III.3.b.(3)
| III. 3.c
+
(ii) Procedures to be followed |II.2
by employees who remain to |II.2.c
operate critical plant |II.2.e
operations before they evacuate |III.3.c
+
(iii) Procedures to account for |II.2.a
all employees after emergency I III.3.b. (2)
evacuation has been completed I III.3.b. (3)
| III. 3.c
| III. 4
1
(iv) Rescue and medical duties |III.3.b. (3)
for those employees who are to |III.3.c
perform them |III.3.c. (7)
|III.3.e.(1)
1
(v) The preferred means of I II. 2. a
reporting fires and other I III. 3.b
emergencies I
1
(vi) Names or regular job |I.4.f
titles of persons or departments |II.2.a
who can be contacted for further |III.3.b. (2)
information or explanation of I III.3.b. (4)
duties under the plan I
1
(3) Alarm system!6 I II. 2. a
|III.3.c. (3)
| III .3.e. (3)
1
(4) Evacuation |II.2.d
|Ill.S.b.(3)
| III.S.c. (3)
| Ill.S.d
|Ill.S.d.(1)
(5) Training
| Ill.S.e. (5)
| III.5
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1
1910.119 Process safety management of I
highly hazardous chemicals I
1
(e)(3)(ii) Investigation of |III.4
previous incidents I III. 4.b
-I 1-
(e) (3) (iii) Process hazard |III.3.e.(3)
analysis requirements I
+
(g)(1)(i) Employee training in |III.5
process/operating procedures I
+
(j)(4) Inspection/testing of |III.3.e.(6)
process equipment I
+
(j)(5) Equipment repair |III.3.e.(6)
+
(1) Management of change (s) I III. 5
+
(m) Incident investigation I III. 4. a
+
(n) Emergency planning and response I I.I
III.l
| II.2
| II.2.d
| III.2
| III .2 .a
| III.2.b
+
(o) (1) Certification of compliance I III. 6
+
1910.165 Employee alarm systems I
1
(b) General requirements I III.3.e. (3)
1
(b) (1) Purpose of alarm system |III.2
| III .2 .a
1
(b) (4) Preferred means of I III.2
reporting emergencies I
1
(d) Maintenance and testing I III.3.e. (6)
1
1910.272 Grain handling facilities I
1
(d) Development/implementation of I I.I
emergency action plan I III. 2
-I 1-
-I 1-
OSHA HAZWOPER (29 CFR 1910.120) I ICP
| Citation(s)
1
1910.120(k) Decontamination |III.3.c.(6)
1
1910.120(1) Emergency response program I I.I
+
(1) Emergency response plan I
+
(i) An emergency response plan |
shall be developed and I
implemented by all employers I
within the scope of this section |
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to handle anticipated
emergencies prior to the
commencement of hazardous waste
operations
(ii) Employers who will
evacuate their employees from
the workplace when an emergency
occurs, and who do not permit
any of their employees to assist
in handling the emergency, are
exempt from the requirements of
this paragraph if they provide
an emergency action plan
complying with section
1910.38 (a) of this part
(2) Elements of an emergency
response plan
(i) Pre-emergency planning and
coordination with outside
parties
I.4.f
II.2.b
II.2.c
Ill .2 .c
Ill.S.b. (4;
Ill.S.d
(ii) Personnel roles, lines of I.4.f
authority, and communication II. 2. b
III .2 .a
III .2 .c
Ill.S.b. (4)
III .3.e. (4)
------------------------------------------ 1 ------------
(iii) Emergency recognition and II. 1
prevention III. 7
------------------------------------------ 1 ------------
(iv) Safe distances and places Ill.S.b. (3)
of refuge III . 3.d. (2)
------------------------------------------ 1 ------------
(v) Site security and control Ill.S.d. (2)
III .3.e. (2)
------------------------------------------ 1 ------------
(vi) Evacuation routes and II. 2. d
procedures Ill.S.b. (3)
-I --------------------------------------------------------------------------- 1-
(vii) Decontamination III.S.c. (6)
procedures
------------------------------------------ 1 ------------
(viii) Emergency medical II. 2. d
treatment and response III.S.c. (7)
procedures Ill.S.e. (1)
------------------------------------------ 1 ------------
(ix) Emergency alerting and II. 2
response procedures II. 2. a
II. 2. f
II. 4
III .2
III .2 .a
III .2 .c
Ill.S.d
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(x) Critique of response and
follow-up
1
(xi) PPE and emergency Ill.S.e. (6)
equipment Ill.S.f.(3)
Ill.S.d.(2)
Ill.S.e.(6)
Ill.S.f.(3)
+
(3) Procedures for handling
emergency incidents
(i) Additional elements of
emergency response plans
+
(A) Site topography, III.l.c
layout, and prevailing
weather conditions
+
(B) Procedures for II. 2. a
reporting incidents to III.2
local, state, and federal
government agencies
(ii) The emergency response
plan shall be a separate section
of the Site Safety and Health
Plan
II.3
III. 4
III.4.a
III. 6
(iii) The emergency response
plan shall be compatible with
the disaster, fire, and/or
emergency response plans of
local, state, and federal
agencies
III .3.e
(iv) The emergency response
plan shall be rehearsed
regularly as part of the overall
training program for site
operations
III.5
(v) The site emergency response
plan shall be reviewed
periodically and, as necessary,
be amended to keep it current
with new or changing site
conditions or information
(vi) An employee alarm system
shall be installed in accordance
with 29 CFR 1910.165 to notify
employees of an emergency
situation; to stop work
activities if necessary; to
lower background noise in order
to speed communications; and to
begin emergency procedures
(vii) Based upon the
information available at time of
the emergency, the employer
II.2.c
II.2.d
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shall evaluate the incident and
the site response capabilities
and proceed with the appropriate
steps to implement the site
emergency response plan
1910.120(p)(8) Emergency response program
(i) Emergency response plan
(ii) Elements of an emergency
response plan
I
(K) PPE and emergency equipment
| I.4.f
| II.2.b
| II.2.b
|
(A) Pre-emergency planning and
coordination with outside
parties
| III .2 .c
|Ill.S.b. (4
|Ill.S.d
(B) Personnel roles, lines of |I.4.f
authority, and communication |II.2.b
| III .2 .c
| III .2 .c
|Ill.S.b. (4
|Ill.S.e. (4
(C) Emergency recognition and |II.l
prevention I III. 7
-I 1-
| (D) Safe distances and places |III.3.b.(3) |
of refuge I III.S.d. (2)
1
(E) Site security and control |III.3.d.(2)
|III.3.e. (2)
1
(F) Evacuation routes and |II.2.d
procedures |III.3.b. (3)
1
(G) Decontamination procedures |III.3.c.(6)
1
(H) Emergency medical treatment |II.2.d
and response procedures I III.3.c. (7)
|III.S.e.(1)
1
(I) Emergency alerting and I II. 2
response procedures I II. 2. a
| II.2. f
| II. 4
| III .2
| III .2 .a
| III .2 .b
| III .2 .c
|III .S.d
1
(J) Critique of response and |II.3
follow-up | III. 4
| III. 4.a
| III. 6
|Ill.S.e.(6)
|Ill.S.f. (3)
|Ill.S.d.(2)
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(iii) Training
(iv) Procedures for handling
emergency incidents
(A) Additional elements of
emergency response plans
(1) Site topography,
layout, and prevailing
weather conditions
(2) Procedures for
reporting incidents to
local, state, and federal
government agencies
(B) The emergency response plan
shall be compatible and
integrated with the disaster,
fire and/or emergency response
plans of local, state, and
federal agencies
(C) The emergency response plan
shall be rehearsed regularly as
part of the overall training
program for site operations
(D) The site emergency response
plan shall be reviewed
periodically and, as necessary,
be amended to keep it current
with new or changing site
conditions or information
(E) An employee alarm system
shall be installed in accordance
with 29 CFR 1910.165
(F) Based upon the information
available at the time of the
emergency, the employer shall
evaluate the incident and the
site response capabilities and
proceed with the appropriate
steps to implement the site
emergency response plan
1910. 120 (q) Emergency response to hazardous
substance releases
(1) Emergency response plan
(2) Elements of an emergency
response plan
(i) Pre-emergency planning and
coordination with outside
parties
| III .3.e.
| Ill.S.f .
| III . 5
1
1
1
1
| III . l.c
| Ill.S.d.
1
| II. 2. a
| III. 2
1
1
| III .3.6
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
| II. 2. d
| II .2 .e
| III . 3.d.
1
1
1
1
1
1
1
| III .3.1
1
1
| I.4.f
| II. 2. b
| II. 2. c
(6)
(3)
(D
(D
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(ii) Personnel roles, lines of
authority, training, and
communication
(iii) Emergency recognition and
prevention
(iv) Safe distances and places
of refuge
(v) Site security and control
(vi) Evacuation routes and
procedures
(vii) Decontamination
procedures
(viii) Emergency medical
treatment and response
procedures
(ix) Emergency alerting and
response procedures
(x) Critique of response and
follow-up
(xi) PPE and emergency
equipment
(xii) Emergency response plan
coordination and integration
(3) Procedures for handling
emergency response
(i) The senior emergency
response official responding to
an emergency shall become the
individual in charge of a site-
specific Incident Command System
(ICS)
III .2 .c
Ill.S.b.
Ill.S.d
I.4.f
II. 2. b
III.2.b
III .2 .c
Ill.S.b.
Ill .S.e.
II. 1
III. 7
Ill.S.b.
Ill.S.d.
Ill.S.d.
Ill .S.e.
II. 2. d
Ill.S.b.
Ill . S.c.
II. 2. d
III .S.c.
Ill .3.6.
II. 2
II .2 .a
II. 2. f
II. 4
III .2
III .2 .a
III .2 .c
Ill.S.d
II. 3
III . 4
III . 4. a
III . 6
III .S.e.
Ill.S.f.
Ill.S.d.
Ill .3.6.
Ill.S.f.
Ill .3.6
III . 8
II. 2. b
III . 3
III . 3. a
Ill.S.b
Ill.S.b.
Ill.S.b.
(4)
(4)
(4)
(3)
(2)
(2)
(2)
(3)
(6)
(7)
(D
(6)
(3)
(2)
(6)
(3)
(D
(2)
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|III.3.e. (3)
(ii) The individual in charge
of the ICS shall identify, to
the extent possible, all
hazardous substances or
conditions present and shall
address as appropriate site
analysis, use of engineering
controls, maximum exposure
limits, hazardous substance
handling procedures, and use of
any new technologies
(iii) Implementation of
appropriate emergency operations
and use of PPE
(iv) Employees engaged in
emergency response and exposed
to hazardous substances
presenting an inhalation hazard
or potential inhalation hazard
shall wear positive pressure
self-contained breathing
apparatus while engaged in
emergency response
(v) The individual in charge of
the ICS shall limit the number
of emergency response personnel
at the emergency site, in those
areas of potential or actual
exposure to incident or site
hazards, to those who are
actively performing emergency
operations
(vi) Backup personnel shall
stand by with equipment ready to
provide assistance or rescue
(vii) The individual in charge
of the ICS shall designate a
safety official, who is
knowledgeable in the operations
being implemented at the
emergency response site
(viii) When activities are
judged by the safety official to
be an IDLH condition and/or to
II .2 .c
II. 2. d
III . 3.c. (3)
II. 2. c
II. 2. d
II .2 .6
III . 3.c
III.3.C. (1)
Ill.S.d. (1)
Ill.S.d. (2)
II. 2. d
III . 3.c
III .3.e. (5)
II. 2. d
III .3.e. (5)
II. 2. d
Ill.S.b. (3)
Ill.S.b. (3)
involve an imminent danger
condition, the safety official
shall have authority to alter,
suspend, or terminate those
activities
(ix) After emergency operations
have terminated, the individual
III.S.c.(6)
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in charge of the ICS shall I
implement appropriate I
decontamination procedures I
1
(x) When deemed necessary for |
meeting the tasks at hand, I
approved self-contained I
compressed air breathing I
apparatus may be used with I
approved cylinders from other |
approved self-contained I
compressed air breathing I
apparatus provided that such I
cylinders are of the same I
capacity and pressure rating I
+
(4) Skilled support personnel I
+
(5) Specialist employees I
+
(6) Training IIII.5
+
(7) Trainers I
+
(8) Refresher training I
+
(9) Medical surveillance and I
consultation I
+
(10) Chemical protective clothing I
+
(11) Post-emergency response I
operations I
-I 1-
-I 1-
EPA's Risk Management Program ICP
(40 CFR part 68) Citation(s)
1
68.20-36 Offsite consequence analysis Ill.S.d.(1)
1
68.42 Five-year accident history III.4.b
1
68.50 Hazard review III.3.d.(l)
1
68.60 Incident investigation III. 4. a
1
68.67 Process hazards analysis Ill.S.d.(1)
1
68.81 Incident investigation III. 4. a
1
68.95(a) Elements of an emergency response
program
1
(1) Elements of an emergency response
plan
1
(i) Procedures for informing the |II.2.a
public and emergency response I III. 2
agencies about accidental I
releases I
1
(ii) Documentation of proper |III.3.c.(7)
first-aid and emergency medical |III.3.e. (1)
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treatment necessary to treat
accidental human exposures
(iii) Procedures and measures
for emergency response after an
accidental release of a regulated
substance
II. 1
II.2
II.3
II.4
III.3.a - c
(2) Procedures for the use of
emergency response equipment and for
its inspection, testing, and
maintenance
Ill.S.e.(6)
(3) Training for all employees in
relevant procedures
III.5
(4) Procedures to review and update
the emergency response plan
III. 6
68.95(b) Compliance with other federal
contingency plan regulations
68.95(c) Coordination with the community
emergency response plan
Signatures
(date)_
Elliott P. Laws
Assistant Administrator, Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
(date)
Rear Admiral James C. Card
Chief, Marine Safety and Environmental Protection Directorate
U.S. Coast Guard
(date)
Richard B. Felder
Associate Administrator for Pipeline Safety
Research and Special Programs Administration
U.S. Department of Transportation
(date)_
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John B. Moran
Director of Policy
Occupational Safety and Health Administration
Department of Labor
(date)
Thomas Gernhofer
Associate Director, Offshore Minerals Management
Minerals Management Service
Department of the Interior
Billing Code 6560-50-P
Endnotes:
1 Facilities should be aware that most states have been authorized by EPA to implement RCRA
contingency planning requirements in place of the federal requirements listed. Thus, in many cases state
requirements may not track this matrix. Facilities must coordinate with their respective states to ensure an
TCP complies with state RCRA requirements.
2 Facilities should be aware that most states have been authorized by EPA to implement RCRA
contingency planning requirements in place of the federal requirements listed. Thus, in many cases state
requirements may not track this matrix. Facilities must coordinate with their respective states to ensure an
TCP complies with state RCRA requirements.
3 Facilities should be aware that most states have been authorized by EPA to implement RCRA
contingency planning requirements in place of the federal requirements listed. Thus, in many cases state
requirements may not track this matrix. Facilities must coordinate with their respective states to ensure an
TCP complies with state RCRA requirements.
4 Section 264.56 is incorporated by reference at 264.52(a).
5 Incorporates by reference 264.37.
6 Section 265.56 is incorporated by reference at 265.52(a).
7 Incorporates by reference 265.37.
8 Section 279.52(b)(6) is incorporated by reference at 279.52(b)(2)(i).
9 Incorporates by reference 279.52(a)(6).
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10 Non-response planning parts of this regulation (e.g., prevention provisions) require a specified format.
11 If a facility is required to develop a strong oil spill contingency plan under this section, the requirement
can be met through the TCP.
12 The appendix further describes the required elements in 120.20(h). It contains regulatory requirements
as well as recommendations.
13 Specific plan requirements for sections listed under 154.1030(b) are contained in 154.1035(a) - (g).
7¥Note: Sections 154.1045 and 154.1047 contain requirements specific to facilities that handle, store, or
transport Group I-IV oils and Group V oils, respectively.
15 Ibid.
16 Section 1910.38(a)(3) incorporates 29 CFR 1910.165 by reference.
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United States Solid Waste and EPA530-R-93-017
Environmental Protection Emergency Response November 1993
Agency (5305) www.epa.gov/osw
vvEPA Solid Waste Disposal
Facility Criteria
Technical Manual
-------
DISCLAIMER
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under Contract Number 68-WO-0025. Mention of trade names
or commercial products does not constitute endorsement or recommendation for use.
NOTICE
The policies set out in this manual are not final Agency action, but are intended solely as guidance.
They are not intended, nor can they be relied upon, to create any rights enforceable by any party in
litigation with the United States. EPA officials may decide to follow the guidance provided in this
memorandum, or to act at variance with the guidance, based on an analysis of specific site
circumstances. The Agency also reserves the right to change this guidance at any time without
public notice.
-------
TABLE OF CONTENTS
INTRODUCTION iv
CHAPTER 1. SUSP ART A 1
1.1 INTRODUCTION 3
1.2 PURPOSE. SCOPE. AND APPLICABILITY 40 CFR $258.1 (a)(b} 4
1.3 PURPOSE. SCOPE. AND APPLICABILITY (conO 40 CFR $258.1 (cWe^) 5
1.4 SMALL LANDFILL EXEMPTIONS 40 CFR $258.1 (T) 7
1.5 APPLICABILITY 40 CFR $258.1 (g)-(i) 9
1.6 DEFINITIONS 40 CFR $258.2 10
1.7 CONSIDERATION OF OTHER FEDERAL LAWS 40 CFR $258.3 14
CHAPTER 2. SUSP ARTS 15
2.1 INTRODUCTION 18
2.2 AIRPORT SAFETY 40 CFR $258.10 19
2.3 FLOODPLAINS 40 CFR $258.11 24
2.4 WETLANDS 40 CFR $258.12 28
2.5 FAULT AREAS 40 CFR $258.13 37
2.6 SEISMIC IMP ACT ZONES 40 CFR $25 8.14 41
2.7 UNSTABLE AREAS 40 CFR $258.15 45
2.8 CLOSURE OF EXISTING MUNICIPAL SOLID WASTE LANDFILL UNITS
40 CFR $258.16 61
2.9 FURTHER INFORMATION 63
CHAPTERS. SUSP ART C 73
11 INTRODUCTION 76
12 PROCEDURES FOR EXCLUDING THE RECEIPT OF HAZARDOUS
WASTE 40 CFR $258.20 77
H COVER MATERIAL REQUIREMENTS 40 CFR $258.21 84
14 DISEASE VECTOR CONTROL 40 CFR $258.22 85
15 EXPLOSIVE GASES CONTROL 40 CFR $258.23 87
16 AIR CRITERIA 40 CFR $258.24 101
17 ACCESS REQUIREMENT 40 CFR $258.25 103
18 RUN-ON/RUN-OFF CONTROL SYSTEMS 40 CFR $258.26 104
19 SURFACE WATER REQUIREMENTS 40 CFR $258.27 105
3.10 LIQUIDS RESTRICTIONS 40 CFR $258.28 107
3.11 RECORDKEEPING REQUIREMENTS 40 CFR $258.29 110
3.12 FURTHER INFORMATION 114
Revised April 13, 1998
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CHAPTER 4. SUSP ARID 117
4J, INTRODUCTION 121
42 PERFORMANCE-BASED DESIGN 40 CFR $258.40 122
43 COMPOSITE LINER AND LEACHATE COLLECTION SYSTEM 40 CFR
$258.40 149
4,4 RELEVANT POINT OF COMPLIANCE 40 CFR §258.40(d) 188
4,5 PETITION PROCESS 40 CFR S258.40(e^ 191
16 FURTHER INFORMATION 193
CHAPTERS. SUBPARTE 205
5J, INTRODUCTION 211
12 APPLICABILITY 40 CFR $258.50 (a) & fb) 211
13 COMPLIANCE SCHEDULE 40 CFR § 258.50 (c) 214
14 ALTERNATIVE COMPLIANCE SCHEDULES 40 CFR 258.50 (d)(e) & (g)
215
15 QUALIFICATIONS 40 CFR 258.50 (f) 217
16 GROUND-WATER MONITORING SYSTEMS 40 CFR $258.51 (a)(b)(d)
219
17 GROUND-WATER MONITORING WELL DESIGN AND
CONSTRUCTION 40 CFR $258.51 (c) 241
18 GROUND-WATER SAMPLING AND ANALYSIS REQUIREMENTS 40
CFR $258.53 253
19 STATISTICAL ANALYSIS 40 CFR $258.53 (gV(D 268
5.10 DETECTION MONITORING PROGRAM 40 CFR $258.54 274
5.11 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(a)-(f) 281
5.12 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(e) 286
5.13 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(h)-(i) 289
5.14 ASSESSMENT OF CORRECTIVE MEASURES 40 CFR $258.56 291
5.15 SELECTION OF REMEDY 40 CFR $258.57 (a)-fb) 298
5.16 SELECTION OF REMEDY 40 CFR $258.57 (c) 299
5.17 SELECTION OF REMEDY 40 CFR $258.57 (d) 303
5.18 SELECTION OF REMEDY 40 CFR $258.57 (e)-(f) 305
5.19 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM 40
CFR $258.58 (a) 307
5.20 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM 40
CFR $258.58 fb)-(d) 309
5.21 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM 40
CFR $258.58 (e)-(g) 311
5.22 FURTHER INFORMATION 313
Revised April 13, 1998
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CHAPTER 6. SUBPARTF 319
6J, INTRODUCTION 322
£2 FINAL COVER DESIGN 40 CFR §258.60(a) 322
63 ALTERNATIVE FINAL COVER DESIGN 40 CFR §258.60fb) 332
6A CLOSURE PLAN 40 CFR §258.60(c)-(d) 338
£5 CLOSURE CRITERIA 40 CFR §258.60(e)-(i) 339
£6 POST-CLOSURE CARE REQUIREMENTS 40 CFR $258.61 342
6J_ POST-CLOSURE PLAN 40 CFR §258.61(c)-(e) 345
£8 FURTHER INFORMATION 348
APPENDICES
CHAPTER 2
APPENDIX I FAA Order 5200.5A 69
CHAPTER 3
APPENDIX I - SPECIAL WASTE ACCEPTANCE AGREEMENT 115
iii Revised April 13, 1998
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INTRODUCTION
This manual was originally published in November, 1993 as a companion to the Criteria for
Municipal Solid Waste Landfills (MSWLF Criteria) that were promulgated on October 9, 1991 as
40 CFR Part 258. Since that time the MSWLF Criteria have been modified several times due to
statutory revisions and court decisions that are discussed below. Most of the modifications delayed
the effective dates but all provisions are now effective. All changes to the rule are included in the
text of the manual. The technical content of the manual did not require revision and only
typographical errors were corrected.
The manual is now available in electronic format and can be accessed on the Environmental
Protection Agency's (EPA) web site .
Purpose of This Manual
This technical manual has been developed to
assist owners/operators of MSWLFs in achieving
compliance with the revised MSWLF Criteria. This
manual is not a regulatory document, and does not
provide mandatory technical guidance, but does
provide assistance for coming into compliance with
the technical aspects of the revised landfill Criteria.
Implementation of the Landfill Criteria
The EPA fully intends that States and Tribes
maintain the lead role in implementing and enforcing
the revised Criteria. States will achieve this through
approved State permit programs. Due to recent
decisions by the courts, Tribes will do so using a
case-by-case review process.1 Whether in a State or
in Indian Country, landfill owners/operators must
comply with the revised2 MSWLF Criteria.
State Process
Example of Technical and Performance
Standards in 40 CFR Part 258: Liners
Technical standard:
MSWLFs must be built with a composite
liner consisting of a 30 mil flexible mem-
brane liner over 2 feet compacted soil with a
hydraulic conductivity of no more than 1x10"
7 cm/sec.
Performance standard:
MSWLFs must be built in accordance with a
design approved by the Director of an
approved State or as specified in 40 CFR
§ 258.40(e) for unapproved States. The
design must ensure that the concentration
values listed in Table 1 of 40 CFR § 258.40
will not be exceeded in the uppermost aquifer
at the relevant point of compliance, as
specified by the Director of an approved
State under paragraph 40 CFR § 258.40(d).
The Agency's role in the regulation of MSWLFs is to establish national minimum standards
that the states are to incorporate into their MSWLF permitting programs. EPA evaluates state
1 The Agency originally intended to extend to Indian Tribes the same opportunity to apply for permit program
approval as is available to States, but a court decision blocked this approach. See the Tribal Process section
below for complete details.
2EPA finalized several revisions to 40 CFR Part 258 on October 1, 1993 (58 FR 51536) and issued a correction
notice on October 14, 1993 (58 FR 53136). Questions regarding the final rule and requests for copies of the
Federal Register notices should be made to the RCRA/Superfund Hotline at 800 424-9346.
Revised April 13, 1998
IV
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Introduction
MSWLF permitting programs under the procedures set out in 40 CFR Part 239, "Requirements for
State Permit Program Determination of Adequacy," proposed on January 26, 1996 (61 FR 2584),
to determine whether programs are adequate to ensure that MSWLF owners/operators comply with
the federal standards. As of early 1998, 40 States and Territories had received full approval and
another seven had received partial approval.
If their permitting programs have been approved by EPA, States can allow the use of flexible
performance standards established in 40 CFR Part 258 in addition to the self-implementing technical
standards for many of the Criteria. Approved States can provide owners/operators flexibility in
satisfying the location restrictions, operating criteria, and requirements for liner design, ground-
water monitoring, corrective action, closure and post-closure care, and financial assurance. This
flexibility allows for the consideration of site-specific conditions in designing and operating a
MSWLF at the lowest cost possible while ensuring protection of human health and the environment.
In unapproved states, owners/operators must follow the self-implementing technical standards.
EPA continues to work with States toward approval of their programs and recommends that
owners/operators stay informed of the approval status of the programs in their State. States may be
in various stages of the program approval process. The majority of states have received full
program approval and others have received "partial" program approval (i.e., only some portions of
the State program are approved while the remainder of the program is pending approval).
Regardless of a State's program approval status, landfill owners/operators must comply with the
Criteria. States can grant flexibility to owners/operators only in the areas of their program that have
been approved. For example, a state in which only the ground-water monitoring area of the
permitting program has been approved by EPA cannot grant owners/operators flexibility to use
alternative liner designs.
States are free to enact landfill regulations that are more stringent than the MSWLF Criteria.
Certain areas of flexibility provided by the Criteria (e.g., the small landfill exemption) may not be
reflected in a State program. In such instances, the owner/operator must comply with the more
stringent provisions (e.g., no exemption). These regulations would be enforced by the State
independently from the Criteria. NOTE: The program requirements for approved States may
differ from those described in this manual, which are based specifically on the Federal
Criteria. Therefore, owners/operators are urged to work closely with their approved State in
order to ensure that they are fully in compliance with all applicable requirements.
State regulatory personnel will find this document helpful when reviewing permit
applications for landfills. This manual presents technical information to be used in siting, designing,
operating, and closing landfills, but does not present a mandatory approach for demonstrating
compliance with the Criteria. This manual also outlines the types of information relevant to make
the demonstrations required by the Criteria, including demonstrations for restricted locations and
performance-based designs in approved States.
Tribal Process
From the beginning of EPA's development of the permitting program approval process, the
Agency planned to offer permitting program approval to tribes as well as to states. In a 1996 court
v Revised April 13, 1998
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Introduction
decision3, however, the court ruled that EPA cannot approve tribal permitting programs. The
Agency has therefore developed a site-specific rulemaking process to meet its goal of quickly and
efficiently providing owners/operators in Indian Country4 the same flexibility that is available to
landfill owners/operators in states with EPA-approved MSWLF permitting programs. The process
is described in Site-Specific Flexibility Requests for Municipal Solid Waste Landfills in Indian
Country—Draft Guidance (EPA530-R-97-016).
Under this process, an owner or operator can request to use certain alternative approaches
at a specific MSWLF site to meet the 40 CFR Part 258 performance standards. Unless the tribal
government is the owner/operator, the tribal government should review the request for consistency
with tribal law and policy and forward it to EPA with a recommendation. If EPA approves a
request, it will issue a site-specific rule allowing the use of the requested alternative approaches.
Owners/operators in Indian Country should therefore understand that when this manual refers to
areas of flexibility that can be granted by a "State Director," they would instead seek such flexibility
in the form of a site-specific rulemaking from EPA after tribal government review of their petition
for rulemaking. Although tribes will not issue permits as EPA-approved permitting entities under
the Criteria, they are free to enact separate tribal landfill regulations that are more stringent than the
Criteria. Tribal regulations are enforced by the tribe independently of the Criteria.
The site-specific process encourages active dialogue among tribes, MSWLF
owners/operators, EPA, and the public. The guidance is designed so that the Agency works in
partnership with tribes. Because EPA recognizes tribal sovereignty, EPA will respect tribal findings
concerning consistency of proposed approaches with tribal law and policy.
Revisions to Part 258
Some important changes have been made to Part 258 since its original promulgation. In
addition, other regulations that affect solid waste management have been implemented.
Ground-Water Monitoring Exemption for Small, Dry, and Remote Landfills (40 CFR
§258.1(f)(l))
The Land Disposal Program Flexibility Act (LDPFA) of 1996 reestablished an exemption
for ground-water monitoring for owners/operators of certain small MSWLFs. EPA revised 40 CFR
§ 258.1(f)(l) on September 25, 1996 (61 FR 50409) to codify the LDPFA ground-water monitoring
exemption. To qualify for an exemption, owners/operators must accept less than 20 tons per day of
MSW (based on an annual average), have no evidence of ground-water contamination, and be
located in either a dry or remote location. This exemption eases the burden on certain small
MSWLFs without compromising ground-water quality.5
3 Backcountry Against Dumps v. EPA, 100 F.3d 147 (D.C. Cir. 1996).
4 This manual uses the term "Indian Country" as defined in 40 CFR § 258.2.
5 In the original 40 CFR Part 258 rulemaking, promulgated October 9, 1991, the Agency provided an
exemption from ground-water monitoring for small MSWLF units located in dry or remote locations. In 1993, the
U.S. Court of Appeals for the District of Columbia set aside this ground-water monitoring exemption. Sierra Club
v. EPA, 992 F.2d 337 (D.C. Cir. 1993).
Revised April 13, 1998 vi
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Introduction
New Flexibility for Small Landfills (40 CFR §§ 258.21, 258.23, 258.60)
In addition to reestablishing the ground-water exemption for small, dry, and remote
MSWLFs, the LDPFA provided additional flexibility to approved states for any small landfill that
receives 20 tons or less of MSW per day. EPA revised 40 CFR Part 258 to allow approved states
to grant the use of alternative frequencies of daily cover, alternative frequencies of methane
monitoring, and alternative infiltration layers for final cover (62 FR 40707 (July 29, 1997)). The
LDPFA also authorized flexibility to establish alternative means for demonstrating financial
assurance, and this flexibility was granted in another action. The additional flexibility will allow
owners and operators of small MSWLFs the opportunity to reduce their costs of MSWLF operation
while still protecting human health and the environment.
Added Financial Assurance Options (40 CFR § 258.74)
A revision to 40 CFR Part 258, published November 27, 1996 (61 FR 60328), provided
additional options to the menu of financial assurance instruments that MSWLF owners/operators
can use to demonstrate that adequate funds will be readily available for the costs of closure,
post-closure care, and corrective action for known releases associated with their facilities. The
existing regulations specify several mechanisms that owners and operators may use to make that
demonstration, such as trust funds and surety bonds. The additional mechanisms are a financial test
for use by local government owners and operators, and a provision for local governments that wish
to guarantee the closure, post-closure, and corrective action costs for an owner or operator. These
financial assurance options allow local governments to use their financial strength to avoid incurring
the expenses associated with the use of third-party financial instruments. This action granted the
flexibility to all owners and operators (including owners and operators of small facilities) to
establish alternative means for demonstrating financial assurance as envisioned in the LDPFA.
Additionally, EPA promulgated a regulation allowing corporate financial tests and corporate
guarantees as financial assurance mechanisms that private owners and operators of MSWLFs may
use to demonstrate financial assurance (63 FR 17706 (April 10, 1998)). This test extends to private
owners and operators the regulatory flexibility already provided to municipal owners or operators
of MSWLFs. These regulations allow firms to demonstrate financial assurance by passing a financial
test. For firms that qualify for the financial test, this mechanism will be less costly than the use of
a third party financial instrument such as a trust fund or a surety bond.
How to Use This Manual
This document is subdivided into six chapters arranged to follow the order of the Criteria.
The first chapter addresses the general applicability of the Part 258 Criteria; the second covers
location restrictions; the third explains the operating requirements; the fourth discusses design
standards; the fifth covers ground-water monitoring and corrective action; and the sixth chapter
addresses closure and post-closure care. Each chapter contains an introduction to that section of the
Criteria. This document does not include a section on the financial responsibility requirements;
vii Revised April 13, 1998
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Introduction
questions regarding these requirements may be addressed to EPA's RCRA/Superfund Hotline at 800
424-9346.
Within each chapter, the Criteria have been subdivided into smaller segments. The
Statement of Regulation section provides a verbatim recital of the regulatory language. The second
section, entitled Applicability, provides a general explanation of the regulations and who must
comply with them. Finally, for each segment of the regulation, a Technical Considerations section
identifies key technical issues that may need to be addressed to ensure compliance with a particular
requirement. Each chapter ends with a section entitled Further Information, which provides
references, addresses, organizations, and other information that may be of use to the reader.
Limitations of This Manual
The ability of this document to provide current guidance is limited by the technical literature
that was available at the time of preparation. Technology and product development are advancing
rapidly, especially in the areas of geosynthetic materials and design concepts. As experience with
new waste management techniques expands in the engineering and science community, an increase
in published literature, research, and technical information will follow. The owners and operators
of MSWLFs are encouraged to keep abreast of innovation through technical journals, professional
organizations, and technical information developed by EPA. Many of the Criteria contained in Part
258 are performance-based. Future innovative technology may provide additional means for
owners/operators to meet performance standards that previously could not be met by a particular
facility due to site-specific conditions.
Deadlines and Effective Dates
The original effective date for the Criteria, October 9, 1993, was revised for several
categories of landfills, in response to concerns that a variety of circumstances was hampering some
communities' abilities to comply by that date. Therefore, the Agency provided additional time for
certain landfills to come into compliance, especially small units and those that accepted waste from
the 1993 Midwest floods. As the accompanying table indicates, the extended general effective dates
for all MSWLF categories have passed, and all units should now be in compliance.
Revised April 13, 1998 viii
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SUMMARY OF CHANGES TO THE EFFECTIVE DATES OF THE MSWLF CRITERIA
General effective date.1'2'3
This is the effective date for location,
operation, design, and closure/post-
closure.
Date by which to install final cover
if cease receipt of waste by the
general effective date.2 3
Effective date of ground-water
monitoring and corrective action.2 3
Effective date of financial
assurance requirements.3'4
MSWLF Units
Accepting Greater
than 100 TPD
October 9, 1993
October 9, 1994
Prior to receipt of waste
for new units; October
9, 1994 through October
9, 1996 for existing
units and lateral
expansions
April 9, 1997
MSWLF Units Accepting
100 TPD or Less; Are Not
on the NPL; and Are
Located in a State That
Has Submitted an
Application for Approval
by 10/9/93, or on Indian
Lands or Indian Country
April 9, 1994
October 9, 1994
October 9, 1993 for new
units; October 9, 1994
through October 9, 1996 for
existing units and lateral
expansions
April 9, 1997
MSWLF Units That
Meet the Small
Landfill Exemption in
40 CFR §258.1(f)
October 9, 1997; exempt
from the design
requirements
October 9, 1998
Exempt from the
ground-water
monitoring
requirements.5
October 9, 1997
MSWLF Units
Receiving Flood-
Related Waste
Up to October 9, 1994
as determined by State
Within one year of date
determined by State; no
later than October 9,
1995
October 9, 1993 for
new units; October 9,
1994 through October
9, 1996 for existing
units and lateral
expansions
April 9, 1997
1 If a MSWLF unit receives waste after this date, the unit must comply with all of Part 258.
2 See the final rule and preamble published on October 1, 1993 (58 FR 51536) for a full discussion of all changes and related conditions.
3 See the final rule and preamble published on October 6, 1995 (60 FR 52337) for a full discussion of all changes and related conditions.
4 See the final rule and preamble published on April 7, 1995 (60 FR 17649) for a discussion of this delay.
5 See the final rule and preamble published on September 25, 1990 (61 FR 50409) for a discussion of the ground-water monitoring exemption.
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CHAPTER 1
SUBPART A
GENERAL
-------
CHAPTER 1
SUBPART A
TABLE OF CONTENTS
U, INTRODUCTION 3
L2 PURPOSE. SCOPE. AND APPLICABILITY 40 CFR §258.1 (a)(b) 4
1.2.1 Statement of Regulation 4
1.2.2 Applicability 4
1.2.3 Technical Considerations 4
H PURPOSE. SCOPE. AND APPLICABILITY (cont.) 40 CFR §258.1 (c)-(e) 5
1.3.1 Statement of Regulation 5
1.3.2 Applicability 5
1.3.3 Technical Considerations 7
L4 SMALL LANDFILL EXEMPTIONS 40 CFR §258.1 (f) 7
1.4.1 Statement of Regulation 7
1.4.2 Applicability 8
1.4.3 Technical Considerations 8
L5 APPLICABILITY 40 CFR §258.1 (g)-(j) 9
1.5.1 Statement of Regulation 9
1.5.2 Applicability 10
1.5.3 Technical Considerations 10
L6 DEFINITIONS 40 CFR §258.2 10
1.6.1 Statement of Regulation 10
1.6.2 Applicability 13
1.6.3 Technical Considerations 13
L7 CONSIDERATION OF OTHER FEDERAL LAWS 40 CFR §258.3 14
1.7.1 Statement of Regulation 14
1.7.2 Applicability 14
1.7.3 Technical Considerations 14
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CHAPTER 1
SUBPART A
GENERAL
1.1 INTRODUCTION
Under the authority of both the Resource Conservation and Recovery Act (RCRA), as amended by
the Hazardous and Solid Waste Amendments (HSWA) of 1984, and Section 405 of the Clean Water
Act, the EPA issued "Solid Waste Disposal Facility Criteria" (40 CFRPart 258) on October 9, 1991.
These regulations revise the "Criteria for Classification of Solid Waste Disposal Facilities and
Practices," found in 40 CFR Part 257. Part 258 was established to provide minimum national
criteria for all solid waste landfills that are not regulated under Subtitle C of RCRA, and that:
• Receive municipal solid waste; or
• Co-dispose sewage sludge with municipal solid waste; or
• Accept nonhazardous municipal waste combustion ash.
Part 257 remains in effect for all other non-hazardous solid waste facilities and practices.
Subpart A of the regulations defines the purpose, scope, and applicability of Part 258 and provides
definitions necessary for proper interpretation of the requirements. In summary, the applicability
of the Criteria is dependent on the operational status of the MSWLF unit relative to the date of
publication of Part 258 and the effective date of the rule (October 9, 1993). An exemption from the
design requirements is provided for small MSWLF units if specific operating, environmental, and
location conditions are present. [The final rule as promulgated on October 9, 1991 exempted the
owner/operators of small landfill units from both Subparts D and E. On May 7, 1993 the U.S. Court
of Appeals for the District of Columbia Circuit issued an opinion that EPA did not have the
authority to exempt these small landfills from the ground-water monitoring requirements (Subpart
E), therefore, these small landfills can not be exempted from Subpart E. EPA is delaying the date
of compliance for these units until October 9, 1995 (58 FR 51536). In addition, the Agency is
investigating alternative ground-water monitoring procedures for these units.]
Owners or operators of MSWLF units that do not meet the Part 258 Criteria will be considered to
be engaging in the practice of "open dumping" in violation of Section 4005 of RCRA. Similarly,
owners and operators of MSWLF units that receive sewage sludge and do not comply with these
Criteria will also be in violation of applicable sections of the Clean Water Act.
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Subpart A
1.2 PURPOSE, SCOPE, AND
APPLICABILITY
40 CFR §258.1 (a)(b)
1.2.1 Statement of Regulation
(a) The purpose of this part is to
establish minimum national criteria
under the Resource Conservation and
Recovery Act (RCRA or the Act), as
amended, for all municipal solid waste
landfill (MSWLF) units and under the
Clean Water Act, as amended, for
municipal solid waste landfills that are
used to dispose of sewage sludge. These
minimum national criteria ensure the
protection of human health and the
environment.
(b) These Criteria apply to owners
and operators of new MSWLF units,
existing MSWLF units, and lateral
expansions, except as otherwise
specifically provided in this part; all
other solid waste disposal facilities and
practices that are not regulated under
Subtitle C of RCRA are subject to the
criteria contained in Part 257.
1.2.2 Applicability
Owners and operators of MSWLF units that
receive municipal solid waste or that receive
municipal waste combustion ash and are not
currently regulated under Subtitle C of
RCRA must comply with the Criteria.
Furthermore, MSWLF units that receive and
co-dispose sewage sludge must comply with
Part 258 to be in compliance with Sections
309 and 405(e) of the Clean Water Act.
1.2.3 Technical Considerations
Criteria that define a solid waste disposal
facility are contained within Part 257 of
RCRA (Criteria for Classification of Solid
Waste Disposal Facilities and Practices).
Definitions pertaining to the revised Criteria
are included in the definition section of Part
258. A MSWLF unit is defined as a discrete
area of land or excavation that receives
household waste, and that is not considered
a land application unit, surface
impoundment, injection well, or waste pile
as those terms are defined under §257.2. An
existing unit is a solid waste disposal unit
that is receiving solid waste as of October 9,
1993. A lateral expansion is a horizontal
expansion of the waste boundaries of an
existing MSWLF unit. A new unit is a
MSWLF unit that has not received waste
before October 9, 1993.
In addition to household waste, a MSWLF
unit may receive commercial waste, non-
hazardous solid waste from industrial
facilities including non-hazardous sludges,
and sewage sludge from wastewater
treatment plants. The terms commercial
solid waste, industrial waste and household
waste are defined in §258.2 (Definitions).
The types of landfills regulated under Part
257 include those facilities that receive:
• Construction and demolition debris
only;
• Tires only; and
• Non-hazardous industrial waste only.
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General
MSWLF units are not intended, nor
allowed, to receive regulated quantities of
hazardous wastes. Should a MSWLF
owner/operator discover that a shipment
contains regulated quantities of hazardous
waste while still in the possession of the
transporter, the owner/operator should
refuse to accept the waste from the
transporter. If regulated quantities of
hazardous wastes are discovered after
accepting the waste from the transporter, the
owner/operator must return the shipment or
manage the wastes in accordance with
RCRA Subtitle C requirements.
Subtitle C of RCRA establishes procedures
for making a hazardous waste
determination. These procedures are
summarized in Chapter 3 and Appendix B of
this document.
1.3 PURPOSE, SCOPE,
AND APPLICABILITY (cont.)
40 CFR §258.1 (c)-(e)
1.3.1 Statement of Regulation*
*[NOTE: EPA finalized several revisions
to 40 CFR Part 258 on October 1, 1993
(58 FR 51536) and issued a correction
notice on October 14,1993 (58 FR 53136).
These revisions delay the effective date
for some categories of landfills. More
detail on the content of the revisions is
included in the introduction.]
(c) These Criteria do not apply to
municipal solid waste landfill units that do
not receive waste after October 9,1991.
(d) MSWLF units that receive waste
after October 9, 1991 but stop
receiving waste before October 9, 1993
are exempt from all the requirements of
Part 258, except the final cover
requirement specified in Section 258.60(a).
The final cover must be installed within six
months of last receipt of wastes. Owners or
operators of MSWLF units described in
this paragraph that fail to complete cover
installation within this six month period
will be subject to all the requirements of
Part 258, unless otherwise specified.
(e) All MSWLF units that receive
waste on or after October 9, 1993 must
comply with all requirements of Part 258
unless otherwise specified.
1.3.2 Applicability
The applicability of Part 258, in its entirety or
with exemptions to specific requirements, is
based upon the operational status of the
MSWLF unit relative to the date of
publication, October 9, 1991, or the effective
date of the rule, October 9, 1993 (see Figure
1-1). Three possible operational scenarios
exist:
(1) The MSWLF unit received its 1 ast
load of waste prior to October 9, 1991. These
facilities are exempt from all requirements of
the Criteria.
(2) The last load of waste was
received after October 9, 1991, but before
October 9, 1993. The owners and operators
must comply only with the final cover
requirements of §258.60(a). If the final cover
is not installed within six (6) months of the
last receipt of wastes, the owners and
operators will be required to comply with all
requirements of Part 258.
-------
Subpart A
Date of
Publication
(Qetobori, 1991)
C
o
YES
Effective Date
(October9, 1993)
MSWLF Must
Comply with All
of Part 258
Part 258 Does
Not Apply
Finai Cover
Requirements of
§258.60(ai Apply
NO
Figure 1-1
Applicability Flow Chart
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General
(3) The MSWLF unit continues to
receive waste after October 9, 1993. The
owners or operators must comply with all
requirements of Part 258, except where
specified otherwise.
1.3.3 Technical Considerations
MSWLF units that receive the last load of
waste between October 9, 1991 and October
9, 1993, must complete closure within six
months of the last receipt of waste. Closure
requirements are specified in Subpart F;
however, these MSWLF units will be
subject only to the closure requirements of
§258.60(a) unless they fail to complete
closure within the six-month period. The
alternative cover design is not an option for
MSWLF units in unapproved States.
The final cover system must be designed to
minimize infiltration and erosion. The final
cover must have a permeability that is less
than or equal to the permeability of the
bottom liner system or the natural subsoils
present, or a permeability no greater than 1
x 10"5 cm/sec, whichever is less. The system
must be composed of an erosion layer that
consists of at least six inches of an earthen
material capable of sustaining native plant
growth and an infiltration layer that is
composed of at least 18 inches of an earthen
material. However, if a MSWLF unit is
constructed with a synthetic membrane in
the liner system, it is anticipated that the
final cover also will require a synthetic
liner. Currently, it is not possible to
construct an earthen liner with a
permeability less than or equal to a synthetic
membrane. Detailed technical
considerations for the cover requirements
under §258.60(a) are provided in Chapter 6.
1.4 SMALL LANDFILL
EXEMPTIONS
40 CFR §258.1 (f)
1.4.1 Statement of Regulation
(f)(l) Owners or operators of new
MSWLF units, existing MSWLF units,
and lateral expansions that dispose of less
than twenty (20) tons of municipal solid
waste daily, based on an annual average,
are exempt from subparts D [and E]* of
this Part, so long as there is no evidence
of existing ground-water contamination
from the MSWLF unit and the MSWLF
unit serves:
(i) A community that experiences
an annual interruption of at least
three consecutive months of surface
transportation that prevents access to
a regional waste management
facility, or
(ii) A community that has no
practicable waste management
alternative and the landfill unit is located
in an area that annually receives less than
or equal to 25 inches of precipitation.
(2) Owners or operators of new
MSWLF units, existing MSWLF units,
and lateral expansions that meet the
criteria in (f)(l)(i) or (f)(l)(ii) must place
in the operating record information
demonstrating this.
(3) If the owner or operator of a
new MSWLF unit, existing MSWLF unit,
or lateral expansion has knowledge of
ground-water contamination resulting
from the unit that has asserted the
exemption in (f)(l)(i) or (ii), the owner or
operator must notify the State
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Subpart A
Director of such contamination and,
thereafter, comply with Subparts D [mttt
E]* of this Part.
* [Note: On May 7, 1993 the U.S. Court of
Appeals for the District of Columbia Circuit
issued an opinion that EPA did not have the
authority to exempt these small landfills
from the ground-water monitoring
requirements (Subpart E), therefore, these
small landfills can not be exempted from
Subpart E. EPA is delaying the date of
compliance for these units until October 9,
1995 (58 FR 51536; October 1, 1993).]
1.4.2 Applicability
The exemption from Subpart D (Design) is
applicable only to owners or operators of
landfill units that receive, on an annual
average, less than 20 tons of solid waste per
day. The exemption is allowed so long as
there is no evidence of existing ground-
water contamination from the MSWLF unit.
In addition, the MSWLF unit must serve a
community that meets one of the following
two conditions:
• For at least three consecutive months of
the year, the community's municipal
solid waste cannot be transported by
rail, truck, or ship to a regional waste
management facility; or
• There is no practicable alternative for
managing wastes, and the landfill unit
is located in an area that receives less
than 25 inches of annual precipitation.
If either of the above two conditions is met,
and there is no evidence of existing ground-
water contamination, the landfill unit owner
or operator is eligible for the exemption
from the design, ground-water monitoring,
and corrective action requirements. The
owner or operator must place information
documenting eligibility for the exemption in
the facility's operating record. Once an
owner or operator can no longer demon-
strate compliance with any of the conditions
of the exemption, the MSWLF facility must
be in compliance with Subpart D.
1.4.3 Technical Considerations
The weight criterion of 20 tons does not
have to be based on actual weight
measurements but may be based on weight
or volume estimates. If the daily waste
receipt records, which include load weights,
are not available for the facility, waste
volumes can be estimated by using
conversion factors of 1 ton = two to three
cubic yards per ton depending on the type of
compaction used at the MSWLF unit.
Waste weights may be determined by
counting the number of trucks and
estimating an average weight for each.
To determine the daily waste received, an
average may be used. If the facility is not
open on a daily basis, the average number
should reflect that fact. For example, if a
facility is open four days per week (208
days/year) and accepts 25 tons each day,
then the average daily amount of waste
received can be calculated as follows:
Average Daily Waste Calculation
4 days/week x 52 weeks/year = 208 days/year; and
25 tons/day x 208 days/year = 5200 tons/year; then
5200 tons/year •+• 365 days/year = 14.25 tons/day.
The facility would meet the criteria for receiving less than
20 tons per day.
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General
Compliance with the 20 tons per day
criterion should be based on all waste
received, including household waste and
agricultural or industrial wastes. As defined
in the regulations, household waste includes
any solid waste (including garbage, trash,
and sanitary waste in septic tanks) derived
from households (including single and
multiple residences, hotels and motels,
bunkhouses, ranger stations, crew quarters,
campgrounds, picnic grounds, and day-use
recreation areas).
The exemption from Subpart D requires that
there be "no evidence of existing ground-
water contamination" as a condition for
eligibility. Evidence of contamination may
include detected or known contamination of
nearby drinking water wells, or physical
evidence such as stressed vegetation that is
attributable to the landfill.
One of two other conditions must be present
for the exemption to apply. The first of
these conditions is an annual interruption in
transportation for at least three consecutive
months. For example, some rural villages in
Alaska may be restricted from transporting
wastes to a regional facility due to extreme
winter climatic conditions. These villages
would find it impossible to transport wastes
to a regional waste facility for at least three
months out of the year due to snow and ice
accumulation.
The second condition is composed of two
requirements: (1) the lack of a practicable
waste management alternative; and (2) a
location that receives little rainfall. The
exemption applies only to those areas that
meet both requirements.
The determination of a "practicable waste
management alternative" includes
consideration of technical, economic, and
social factors. For example, some small
rural communities, especially in the western
part of the United States, are located great
distances from alternative waste
management units (other MSWLF units,
composting facilities, municipal waste
combustors, transfer stations, etc.) making
regionalization of waste management
difficult.
Furthermore, many rural communities are
located in arid areas that receive 25 inches
or less of precipitation annually, which
reduces the likelihood of ground-water
contamination because of lessened leachate
generation and contaminant migration.
Rainfall information can be obtained from
the National Weather Service, the National
Oceanographic and Atmospheric
Administration (NOAA), and the United
States Geological Survey (USGS) Water
Atlases.
1.5 APPLICABILITY
40 CFR §258.1 (g)-(j)
1.5.1 Statement of Regulation
(g) Municipal solid waste landfill
units failing to satisfy these criteria are
considered open dumps for purposes of
State solid waste management planning
under RCRA.
(h) Municipal solid waste landfill
units failing to satisfy these criteria
constitute open dumps, which are
prohibited under Section 4005 of RCRA.
(i) Municipal solid waste landfill units
containing sewage sludge and failing
-------
Subpart A
to satisfy these Criteria violate sections
309 and 405(e) of the Clean Water Act.
(j) The effective date of this part is
October 9, 1993, unless otherwise
specified.*
*[NOTE: EPA finalized several revisions
to 40 CFR Part 258 on October 1, 1993
(58 FR 51536) and issued a correction
notice on October 14,1993 (58 FR 53136).
These revisions delay the effective date
for some categories of landfills. More
detail on the content of the revisions is
included in the introduction.]
1.5.2 Applicability
All MSWLF facilities that receive waste on
or after the effective date must comply with
all of Part 258 except where otherwise
noted. MSWLF facilities that fail to comply
with the Part 258 Criteria will be in
violation of Section 4005 of RCRA and with
Sections 309 and 405(e) of the Clean Water
Act if the facility receives sewage sludge.
1.5.3 Technical Considerations
Failure to comply with the Part 258 Criteria
will result in a MSWLF unit being
categorized as an open dump under Section
4005 of RCRA. The practice of operating
an open dump is prohibited.
If a MSWLF unit co-disposes sewage sludge
with municipal solid waste and fails to
comply with Part 258, it also will be in
violation of Section 405(e) of the Clean
Water Act (CWA), which requires that
sewage sludge be disposed of in accordance
with regulations established for such
disposal. If found to be in violation, owners
or operators may be liable for both civil and
criminal actions enforced under Section 309
of the Clean Water Act.
1.6 DEFINITIONS
40 CFR §258.2
1.6.1 Statement of Regulation
Unless otherwise noted, all terms
contained in this part are defined by their
plain meaning. This section contains
definitions for terms that appear
throughout this Part; additional
definitions appear in the specific sections
to which they apply.
Active life means the period of operation
beginning with the initial receipt of solid
waste and ending at completion of closure
activities in accordance with §258.60 of
this Part.
Active portion means that part of a
facility or unit that has received or is
receiving wastes and that has not been
closed in accordance with §258.60 of this
Part.
Aquifer means a geological formation,
group of formations, or portion of a
formation capable of yielding significant
quantities of ground water to wells or
springs.
Commercial solid waste means all types
of solid waste generated by stores, offices,
restaurants, warehouses, and other non-
manufacturing activities, excluding
residential and industrial wastes.
10
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General
Director of an approved State means the
chief administrative officer of the State
agency responsible for implementing the
State municipal solid waste permit
program or other system of prior
approval that is deemed to be adequate
by EPA under regulations published
pursuant to section 4005 of RCRA.
Existing MSWLF unit means any
municipal solid waste landfill unit that is
receiving solid waste as of the effective
date of this Part. Waste placement in
existing units must be consistent with
past operating practices or modified
practices to ensure good management.
Facility means all contiguous land and
structures, other appurtenances, and
improvements on the land used for the
disposal of solid waste.
Ground water means water below the
land surface in a zone of saturation.
Household waste means any solid waste
(including garbage, trash, and sanitary
waste in septic tanks) derived from
households (including single and multiple
residences, hotels and motels,
bunkhouses, ranger stations, crew
quarters, campgrounds, picnic grounds,
and day-use recreation areas).
Industrial solid waste means solid waste
generated by manufacturing or industrial
processes that is not a hazardous waste
regulated under Subtitle C of RCRA.
Such waste may include, but is not limit-
ed to, waste resulting from the following
manufacturing processes: Electric power
generation; fertilizer/agricultural
chemicals; food and related products/by-
products; inorganic chemicals; iron and
steel manufacturing; leather and leather
products; nonferrous metals manufac-
turing/foundries; organic chemicals;
plastics and resins manufacturing; pulp
and paper industry; rubber and miscel-
laneous plastic products; stone, glass,
clay, and concrete products; textile
manufacturing; transportation
equipment; and water treatment. This
term does not include mining waste or oil
and gas waste.
Lateral expansion means a horizontal
expansion of the waste boundaries of an
existing MSWLF unit.
Leachate means a liquid that has passed
through or emerged from solid waste and
contains soluble, suspended, or miscible
materials removed from such waste.
Municipal solid waste landfill unit means
a discrete area of land or an excavation
that receives household waste, and that is
not a land application unit, surface
impoundment, injection well, or waste
pile, as those terms are defined under
§257.2. A MSWLF unit also may receive
other types of RCRA Subtitle D wastes,
such as commercial solid waste,
nonhazardous sludge, conditionally
exempt small quantity generator waste,
and industrial solid waste. Such a landfill
may be publicly or privately owned. A
MSWLF unit may be a new MSWLF
unit, an existing MSWLF unit or a lateral
expansion.
New MSWLF unit means any municipal
solid waste landfill unit that has not
received waste prior to the effective date
of this Part.
11
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Subpart A
Open burning means the combustion of
solid waste without:
(1) Control of combustion air to
maintain adequate temperature for
efficient combustion,
(2) Containment of the
combustion reaction in an enclosed device
to provide sufficient residence time and
mixing for complete combustion, and
(3) Control of the emission of the
combustion products.
Operator means the person(s) responsible
for the overall operation of a facility or
part of a facility.
Owner means the person(s) who owns a
facility or part of a facility.
Run-off means any rainwater, leachate,
or other liquid that drains over land from
any part of a facility.
Run-on means any rainwater, leachate, or
other liquid that drains over land onto
any part of a facility.
Saturated zone means that part of the
earth's crust in which all voids are filled
with water.
Sludge means any solid, semi-solid, or
liquid waste generated from a municipal,
commercial, or industrial wastewater
treatment plant, water supply treatment
plant, or air pollution control facility
exclusive of the treated effluent from a
wastewater treatment plant.
Solid waste means any garbage, or refuse,
sludge from a wastewater treatment
plant, water supply treatment plant, or
air pollution control facility and other
discarded material, including solid,
liquid, semi-solid, or contained gaseous
material resulting from industrial,
commercial, mining, and agricultural
operations, and from community
activities, but does not include solid or
dissolved materials in domestic sewage,
or solid or dissolved materials in
irrigation return flows or industrial
discharges that are point sources subject
to permit under 33 U.S.C. 1342, or
source, special nuclear, or by-product
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 Common-
wealth of the Northern Mariana Islands.
State Director means the chief
administrative officer of the State agency
responsible for implementing the State
municipal solid waste permit program or
other system of prior approval.
Uppermost aquifer means the geologic
formation nearest the natural ground
surface that is an aquifer, as well as lower
aquifers that are hydraulically
interconnected with this aquifer within
the facility's property boundary.
Waste management unit boundary means
a vertical surface located at the
hydraulically downgradient limit of the
unit. This vertical surface extends down
into the uppermost aquifer.
12
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General
1.6.2 Applicability
The definitions are applicable to all new,
existing, and lateral expansions of existing
MSWLF units regulated under 40 CFR
§258. Additional definitions are provided
within the body of the regulatory language
and will apply to those particular sections.
Definitions in Subpart A apply to all
Sections of Part 25 8.
1.6.3 Technical Considerations
Selected definitions will be discussed in the
following brief narratives.
Approved State: Section 4005(c) of RCRA
requires that each State adopt and
implement a State permit program. EPA is
required to determine whether the State has
developed an adequate program. States
have primary responsibility for implemen-
tation and enforcement of the Criteria. EPA
has the authority to enforce the Criteria in
States where EPA has deemed the permit
program to be inadequate. The Agency
intended to extend to Indian Tribes the same
opportunity to apply for permit program
approval as is available to States. A federal
court ruled, however, in Backcountry
Against Dumps v. EPA, 100 F.3d 147 (D.C.
Cir. 1996), that EPA cannot do so. The
Agency therefore developed a site-specific
rulemaking process to provide warranted
flexibility to owners and operators of
MSWLFs in Indian Country. Obtain the
draft guidance document Site-Specific
Flexibility Requests for Municipal Solid
Waste Landfills in Indian Country (EPA
530-R-97-016) for further information.
Aquifer: An aquifer is a formation or
group of formations capable of yielding a
significant amount of ground water to wells
or springs. To be an aquifer, a formation
must yield enough water for ground-water
monitoring samples. An unconfmed aquifer
is one where the water table is exposed to
the atmosphere through openings in the
overlying geologic formations. A confined
aquifer is isolated from the atmosphere at
the discharge point by impermeable
geological units. A confined aquifer has
relatively impermeable beds above and
below.
Existing unit: Any MSWLF unit that is
receiving household waste as of October 9,
1993 must continue to operate the facility in
a manner that is consistent with both past
operating practices and modified practices
that continue or improve good waste
management. Changes in operating
practices intended to circumvent the
purpose, intent, or applicability of any
portions of Part 258 will not be considered
in conformance with the Criteria. Facilities
spreading a thin layer of waste over unused
new areas will not be exempt from the
design requirements for new units. The
portion of a facility that is considered to be
an existing unit will include the waste
management area that has received waste
prior to the effective date of Part 258.
Existing units may expand vertically.
However, vertical placement of waste over
a closed unit would cause the unit to be
considered a new unit and would subject the
unit to the design requirements in Part 258.
Note: Not all units that have a valid State
permit are considered existing units. To be
an existing unit, the land surface must be
covered by waste by October 9, 1993.
Lateral expansion: Any horizontal
expansion of the waste boundary of a unit is
a lateral expansion. This means that new
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Subpart A
land surface would be covered by waste
after October 9, 1993. Expansions to the
existing unit have to be consistent with past
operating procedures or operating practices
to ensure good management.
Spreading wastes over a large area to
increase the size of an existing unit, prior to
the effective date would not be consistent
with good management practices. If a new
land surface adjacent to an existing unit first
receives waste after October 9, 1993, that
area is classified as a lateral expansion and
therefore, is subject to the new design
standards. However, Part 258 regulations
provide the flexibility for approved States to
determine what would constitute a lateral
expansion.
Municipal solid waste landfill unit:
Municipal solid waste landfill units are units
that receive household waste, such as that
from single and multiple residences, hotels
and motels, bunkhouses, ranger stations,
crew quarters, campgrounds, picnic grounds
and day-use recreation areas. Other Subtitle
D wastes, such as commercial solid waste,
nonhazardous sludge, and industrial solid
waste, may be disposed of in a municipal
solid waste landfill.
New municipal solid waste landfill unit:
A new MSWLF unit is any unit that has not
received waste prior to October 9, 1993.
Lateral expansions are considered new
MSWLF units for the purpose of location
restrictions and design standards. New
MSWLF units are subject to all
requirements of Part 258.
1.7 CONSIDERATION OF
OTHER FEDERAL LAWS
40 CFR §258.3
1.7.1 Statement of Regulation
The owner or operator of a municipal
solid waste landfill unit must comply with
any other applicable Federal rules, laws,
regulations, or other requirements.
1.7.2 Applicability
Owners and operators of MSWLF units
must comply with Federal regulations, laws,
rules or requirements that are in effect at the
time of publication of Part 258 or that may
become effective at a later date.
1.7.3 Technical Considerations
Specific sections of Part 258 reference
major Federal regulations that also may be
applicable to MSWLF units regulated under
Part 258. These regulations include the
Clean Water Act (wetlands, sludge dis-
posal, point and non-point source dis-
charges), the Clean Air Act, other parts of
RCRA (Subtitle C if the MSWLF unit
inadvertently receives regulated hazardous
waste), and the Endangered Species Act.
Furthermore, additional Federal rules, laws,
or regulations may need to be considered.
The owner or operator of the MSWLF unit
is responsible for deter-mining the
conditions present at the facility that may
require consideration of other Federal Acts,
rules, requirements, or regulations. Careful
review of the Part 258 Criteria will help to
identify most of the major Federal laws that
may be applicable to a particular MSWLF
unit.
14
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CHAPTER 2
SUSPART B
LOCATION CRITERIA
15
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CHAPTER 2
SUBPART B
TABLE OF CONTENTS
2.1 INTRODUCTION 18
2.2 AIRPORT SAFETY 40 CFR $258.10 19
2.2.1 Statement of Regulation 19
2.2.2 Applicability 20
2.2.3 Technical Considerations 20
2.3 FLOODPLAINS 40 CFR $258.11 24
2.3.1 Statement of Regulation 24
2.3.2 Applicability 24
2.3.3 Technical Considerations 25
Floodplain Identification 25
Engineering Considerations 27
2.4 WETLANDS 40 CFR $258.12 28
2.4.1 Statement of Regulation 28
2.4.2 Applicability 30
2.4.3 Technical Considerations 31
2.5 FAULT AREAS 40 CFR $258.13 37
2.5.1 Statement of Regulation 37
2.5.2 Applicability 37
2.5.3 Technical Considerations 38
2.6 SEISMIC IMP ACT ZONES 40 CFR $25 8.14 41
2.6.1 Statement of Regul ati on 41
2.6.2 Applicability 41
2.6.3 Technical Considerations 42
Background on Seismic Activity 42
Information Sources on Seismic Activity 42
Landfill Planning and Engineering in Areas of Seismic Activity 42
16
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2.7 UNSTABLE AREAS 40 CFR §258.15 45
2.7.1 Statement of Regulation 45
2.7.2 Applicability 46
2.7.3 Technical Considerations 47
Types of Failures 49
Subsurface Exploration Programs 54
Methods of Slope Stability Analysis 54
Design for Slope Stabilization 56
Monitoring 60
Engineering Considerations for Karst Terrain 60
2.8 CLOSURE OF EXISTING MUNICIPAL SOLID WASTE LANDFILL UNITS 40
CFRS258.16 61
2.8.1 Statement of Regulation 61
2.8.2 Applicability 62
2.8.3 Technical Considerations 62
2.9 FURTHER INFORMATION 63
2.9.1 References 63
2.9.2 Organizations 65
2.9.3 Models 68
APPENDIX I - FAA Order 5200.5A 69
17
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CHAPTER 2
SUBPART B
LOCATION RESTRICTIONS
2.1 INTRODUCTION
Part 258 includes location restrictions to address both the potential effects that a municipal solid
waste landfill (MSWLF) unit may have on the surrounding environment, and the effects that natural
and human-made conditions may have on the performance of the landfill unit. These criteria pertain
to new and existing MSWLF units and lateral expansions of existing MSWLF units. The location
criteria of Subpart B cover the following:
• Airport safety;
• Floodplains;
• Wetlands;
• Fault areas;
• Seismic impact zones; and
• Unstable areas.
Floodplain, fault area, seismic impact zone, and unstable area restrictions address conditions that
may have adverse effects on landfill performance that could lead to releases to the environment or
disruptions of natural functions (e.g., floodplain flow restrictions). Airport safety, floodplain, and
wetlands criteria are intended to restrict MSWLF units in areas where sensitive natural environments
and/or the public may be adversely affected.
Owners or operators must demonstrate that the location criteria have been met when Part 258 takes
effect. Components of such demonstrations are identified in this section. The owner or operator
of the landfill unit must also comply with all other applicable Federal and State regulations, such
as State wellhead protection programs, that are not specifically identified in the Criteria. Owners
or operators should note that many States are now developing Comprehensive State Ground Water
Protection Programs. These programs are designed to coordinate and implement ground-water
programs in the States; they may include additional requirements. Owners or operators should
check with State environmental agencies concerning Comprehensive State Ground Water Protection
Program requirements. Table 2-1 provides a quick reference to the location standards required by
the Criteria.
18
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Location Criteria
Table 2-1
Location Criteria Standards
Restricted
Location
Airport
Floodplains
Wetlands
Fault Areas
Seismic Impact
Zones
Unstable Areas
Applies to
Existing Units
Yes
Yes
No
No
No
Yes
Applies to
New Units
and Lateral
Expansions
Yes
Yes
Yes
Yes
Yes
Yes
Make
Demonstration to
"Director of an
Approved State"
OR
Retain
Demonstration in
Operating Record
Operating Record
Operating Record
Director
Director
Director
Operating Record
Existing
Units Must
Close if
Demonstra-
tion Cannot
be Made
Yes
Yes
N/A
N/A
N/A
Yes
2.2 AIRPORT SAFETY
40 CFR §258.10
2.2.1 Statement of Regulation
(a) Owners or operators of new
MSWLF units, existing MSWLF units, and
lateral expansions that are located within
10,000 feet (3,048 meters) of any airport
runway end used by turbojet aircraft or
within 5,000 feet (1,524 meters) of any
airport runway end used by only piston-
type aircraft must demonstrate that the
units are designed and operated so that the
MSWLF unit does not pose a bird hazard
to aircraft.
(b) Owners or operators proposing to
site new MSWLF units and lateral
expansions within a five-mile radius of any
airport runway end used by turbojet
or piston-type aircraft must notify the
affected airport and the Federal Aviation
Administration (FAA).
(c) The owner or operator must place
the demonstration in paragraph (a) in the
operating record and notify the State
Director that it has been placed in the
operating record.
(d) For purposes of this section:
19
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Subpart B
(1) Airport means public-use airport
open to the public without prior permission
and without restrictions within the physical
capacities of available facilities.
(2) Bird hazard means an increase in
the likelihood of bird/aircraft collisions
that may cause damage to the aircraft or
injury to its occupants.
2.2.2 Applicability
Owners and operators of new MSWLF units,
existing MSWLF units, and lateral expansions
of existing units that are located near an
airport, who cannot demonstrate that the
MSWLF unit does not pose a bird hazard,
must close their units.
This requirement applies to owners and
operators of MSWLF units located within
10,000 feet of any airport runway end used by
turbojet aircraft or within 5,000 feet of any
airport runway end used only by piston-type
aircraft. This applies to airports open to the
public without prior permission for use, and
where use of available facilities is not
restricted. If the above conditions are present,
the owner or operator must demonstrate that
the MSWLF unit does not pose a bird hazard
to aircraft and notify the State Director that
the demonstration has been placed in the
operating record. If the demonstration is not
made, existing units must be closed in
accordance with §258.16.
The regulation, based on Federal Aviation
Administration (FAA) Order 5200.5 A
(Appendix I), prohibits the disposal of solid
waste within the specified distances unless
the owner or operator is able to make the
required demonstration showing that the
landfill is designed and operated so as not to
pose bird hazards to aircraft. The regulation
defines a "danger zone" within which
particular care must be taken to ensure that no
bird hazard arises.
Owners or operators proposing to site new
units or lateral units within five miles of any
airport runway end must notify both the
affected airport and the FAA. This
requirement is based on the FAA's position
that MSWLF units located within a five mile
radius of any airport runway end, and which
attract or sustain hazardous bird movements
across aircraft flight paths and runways, will
be considered inconsistent with safe flight
operations. Notification by the MSWLF
owner/operator to the appropriate regional
FAA office will allow FAA review of the
proposal.
2.2.3 Technical Considerations
A demonstration that a MSWLF unit does not
pose a bird hazard to aircraft within specified
distances of an airport runway end should
address at least three elements of the
regulation:
• Is the airport facility within the regulated
distance?;
• Is the runway part of a public-use
airport?; and
• Does or will the existence of the landfill
increase the likelihood of bird/aircraft
collisions that may cause damage to the
aircraft or injury to its occupants?
The first element can be addressed using
existing maps showing the relationship of
existing runways at the airport to the
existing or proposed new unit or lateral
20
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Location Criteria
expansion. Topographic maps (USGS 15-
minute series) or State, regional, or local
government agency maps providing similar or
better accuracy would allow direct scaling, or
measurement, of the closest distance from the
end of a runway to the nearest MSWLF unit.
The measurement can be made by drawing a
circle of appropriate radius (i.e., 5,000 ft.,
10,000 ft, or 5 miles, depending on the airport
type) from the centerline of each runway end.
The measurement only should be made
between the end of the runway and the nearest
MSWLF unit perimeter, not between any
other boundaries.
To determine whether the runway is part of a
public use airport and to determine whether
all applicable public airports have been
identified, the MSWLF unit owner/operator
should contact the airport administration or
the regional FAA office. This rule does not
apply to private airfields.
The MSWLF unit design features and
operational practices can have a significant
effect on the likelihood of increased
bird/aircraft collisions. Birds may be attracted
to MSWLF units to satisfy a need for water,
food, nesting, or roosting. Scavenger birds
such as starlings, crows, blackbirds, and gulls
are most commonly associated with active
landfill units. Where bird/aircraft collisions
occur, these types of birds are often involved
due to their flocking, feeding, roosting, and
flight behaviors. Waste management
techniques to reduce the supply of food to
these birds include:
• Frequent covering of wastes that
provide a source of food;
• Shredding, milling, or baling the
waste-containing food sources; and
• Eliminating the acceptance of wastes
at the landfill unit that represent a
food source for birds (by alternative
waste management techniques such as
source separation and composting or
waste minimization).
Frequent covering of wastes that represent a
food source for the birds effectively reduces
the availability of the food supply. Depending
on site conditions such as volume and types
of wastes, waste delivery schedules, and size
of the working face, cover may need to be
applied several times a day to keep the
inactive portion of the working face small
relative to the area accessible to birds. By
maintaining a small working face, spreading
and compaction equipment are concentrated
in a small area that further disrupts
scavenging by the birds.
Milling or shredding municipal solid waste
breaks up food waste into smaller particle
sizes and distributes the particles throughout
non-food wastes, thereby diluting food wastes
to a level that frequently makes the mixture
no longer attractive as a food supply for birds.
Similarly, baling municipal solid waste
reduces the surface area of waste that may be
available to scavenging birds.
The use of varying bird control techniques
may prevent the birds from adjusting to a
single method. Methods such as visual
deterrents or sound have been used with
mixed success in an attempt to discourage
birds from food scavenging. Visual
deterrents include realistic models (still or
animated) of the bird's natural predators
21
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Subpart B
(e.g., humans, owls, hawks, falcons). Sounds
that have had limited success as deterrents
include cannons, distress calls of the
scavenger birds, and sounds of its natural
predators. Use of physical barriers such as
fine wires strung across or near the working
face have also been successfully used (see
Figure 2-1). Labor intensive efforts have
included falconry and firearms. Many of
these methods have limited long-term effects
on controlling bird populations at landfill
units/facilities, as the birds adapt to the
environment in which they find food.
Proper design and operation also can reduce
the attraction of birds to the landfill unit
through eliminating scavenger bird habitat.
For example, the use of the landfill unit as a
source of water can be controlled by
encouraging surface drainage and by
preventing the ponding of water.
Birds also may be attracted to a landfill unit as
a nesting area. Use of the landfill site as a
roosting or nesting area is usually limited to
ground-roosting birds (e.g., gulls). Operational
landfill units that do not operate continuously
often provide a unique roosting habitat due to
elevated ground temperatures (as a result of
waste decomposition within the landfill) and
freedom from disturbance. Nesting can be
minimized, however, by examining the nesting
patterns and requirements of undesirable birds
and designing controls accordingly. For
example, nesting by certain species can be
controlled through the mowing and
maintenance schedules at the landfill.
In addition to design features and
operational procedures to control bird
populations, the demonstration should
address the likelihood that the MSWLF unit
may increase bird/aircraft collisions. One
approach to addressing this part of the airport
safety criterion is to evaluate the attraction of
birds to the MSWLF unit and determine
whether this increased population would be
expected to result in a discernible increase in
bird/aircraft collisions. The evaluation of
bird attraction can be based on field
observations at existing facilities where
similar geographic location, design features,
and operational procedures are present.
All observations, measurements, data,
calculations and analyses, and evaluations
should be documented and included in the
demonstration. The demonstration must be
placed in the operating record and the State
Director must be notified that it has been
placed in the operating record (see Section
3.11 in Chapter 3).
If an owner or operator of an existing
MSWLF unit cannot successfully demonstrate
compliance with §258.10(a), then the unit
must be closed in accordance with §258.60
and post-closure activities must be conducted
in accordance with §258.61 (see §258.16).
Closure must occur by October 9, 1996. The
Director of an approved State can extend the
period up to 2 years if it is demonstrated that
no available alternative disposal capacity
exists and the unit poses no immediate threat
to human health and the environment (see
Section 2.8).
In accordance with FAA guidance, if an
owner or operator is proposing to locate a
new unit or lateral expansion of an existing
MSWLF unit within 5 miles of the end of a
public-use airport runway, the affected airport
and the regional FAA office must be notified
to provide an opportunity to review and
comment on the site. Identification of public
airports in a given area can be
22
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Location Criteria
Monofilament
Rope or Wire
" Guyed to
Movable Anchors
Source: SCS Engineers
Figure 2-1.
Bird Control Device
23
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Subpart B
requested from the FAA. Topographic maps
(e.g., USGS 15-minute series) or other
similarly accurate maps showing the
relationship of the airport runway and the
MSWLF unit should provide a suitable basis
for determining whether the FAA should be
notified.
2.3 FLOODPLAINS
40 CFR §258.11
2.3.1 Statement of Regulation
(a) Owners or operators of new
MSWLF units, existing MSWLF units, and
lateral expansions located in 100-year
floodplains must demonstrate that the unit
will not restrict the flow of the 100-year
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 health and the
environment. The owner or operator must
place the demonstration in the operating
record and notify the State Director that it
has been placed in the operating record.
(b) For purposes of this section:
(1) Floodplain means the lowland and
relatively flat areas adjoining inland and
coastal waters, including flood-prone areas
of offshore islands, that are inundated by
the 100-year flood.
(2) 100-year flood means a flood that
has a 1-percent or greater chance of
recurring in any given year or a flood of a
magnitude equaled or exceeded once in 100
years on the average over a significantly
long period.
(3) Washout means the carrying away
of solid waste by waters of the base flood.
2.3.2 Applicability
Owners/operators of new MSWLF units,
existing MSWLF units, and lateral
expansions of existing units located in a
100-year river floodplain who cannot
demonstrate that the units will not restrict
the flow of a 100-year flood nor reduce the
water storage capacity, and will not result
in a wash-out of solid waste, must close the
unit(s). A MSWLF unit can affect the flow
and temporary storage capacity of a
floodplain. Higher flood levels and greater
flood damage both upstream and
downstream can be created and could cause
a potential hazard to human health and
safety. The rule does not prohibit locating
a MSWLF unit in a 100-year floodplain; for
example, the owner or operator is allowed
to demonstrate that the unit will comply
with the flow restriction, temporary
storage, and washout provisions of the
regulation. If a demonstration can be made
that the landfill unit will not pose threats,
the demonstration must be placed in the
operating record, and the State Director
must be notified that the demonstration was
made and placed in the record. If the
demonstration cannot be made for an
existing MSWLF unit, then the MSWLF
unit must be closed in 5 years in accordance
with §258.60, and the owner or operator
must conduct post-closure activities in
accordance with §258.61 (see §258.16).
The closure deadline may be extended for
up to two years by the Director of an
approved State if the owner or operator can
demonstrate that no available alternative
disposal capacity exists and there
24
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Location Criteria
is no immediate threat to human health and
the environment (see Section 2.8).
2.3.3 Technical Considerations
Compliance with the floodplain criterion
begins with a determination of whether the
MSWLF unit is located in the 100-year
floodplain. If the MSWLF unit is located in
the 100-year floodplain, then the owner or
operator must demonstrate that the unit will
not pose a hazard to human health and the
environment due to:
• Restricting the base flood flow;
• Reducing the temporary water storage;
and
• Resulting in the washout of solid waste.
Guidance for identifying floodplains and
demonstrating facility compliance is provided
below.
Floodplain Identification
River floodplains are readily identifiable as
the flat areas adjacent to the river's normal
channel. One hundred-year floodplains
represent the sedimentary deposits formed by
floods that have a one percent chance of
occurrence in any given year and that are
identified in the flood insurance rate maps
(FIRMs) and flood boundary and floodway
maps published by the Federal Emergency
Management Agency (FEMA) (see Figure
2-2). Areas classified as "A" zones are
subject to the floodplain location restriction.
Areas classified as "B" or "C" zones are not
subject to the restriction, although care should
be taken to design facilities capable of
withstanding some potential flooding.
Guidance on using FIRMs is provided in
"How to Read a Flood Insurance Rate Map"
published by FEMA. FEMA also publishes
"The National Flood Insurance Program
Community Status Book" that lists
communities that may not be involved in the
National Flood Insurance Program but which
have FIRMs or Floodway maps published.
Maps and other FEMA publications may be
obtained from the FEMA Distribution Center
(see Section 2.9.2 for the address). Areas not
covered by the FIRMs or Floodway maps
may be included in floodplain maps available
through the U.S. Army Corps of Engineers,
the U.S. Geological Survey, the U.S. Soil
Conservation Service, the Bureau of Land
Management, the Tennessee Valley
Authority, and State, Tribal, and local
agencies.
Many of the river channels covered by these
maps may have undergone modification for
hydropower or flood control projects and,
therefore, the floodplain boundaries
represented may not be accurate or
representative. It may be necessary to
compare the floodplain map series to recent
air photographs to identify current river
channel modifications and land use
watersheds that could affect floodplain
designations. If floodplain maps are not
available, and the facility is located within a
floodplain, then a field study to delineate the
100-year floodplain may be required. A
floodplain delineation program can be based
primarily on meteorological records and
physiographic information such as existing
and planned watershed land use,
topography, soils and geologic mapping,
and air photo interpretation of
geomorphologic (land form) features. The
United States Water Resource Council
(1977) provides information for determining
25
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Figure 2-2
Example Section of Flood Plain Map
26
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Location Criteria
the potential for floods in a given location by
stream gauge records. Estimation of the peak
discharge also allows an estimation of the
probability of exceeding the 100-year flood.
Engineering Considerations
If the MSWLF unit is within the 100-year
floodplain, it must be located so that the
MSWLF unit does not significantly restrict
the base flood flow or significantly reduce
temporary storage capacity of the floodplain.
The MSWLF unit must be designed to prevent
the washout of solid waste during the
expected flood event. The rule requires that
floodplain storage capacity, and flow
restrictions that occur as the result of the
MSWLF unit, do not pose a hazard to human
health and the environment.
The demonstration that these considerations
are met relies on estimates of the flow
velocity and volume of floodplain storage in
the vicinity of the MSWLF unit during the
base flood. The assessment should consider
the floodplain storage capacity and floodwater
velocities that would likely exist in absence of
the MSWLF unit. The volume occupied by a
MSWLF unit in a floodplain may
theoretically alter (reduce) the storage
capacity and restrict flow. Raising the base
flood level by more than one foot can be an
indication that the MSWLF unit may reduce
and restrict storage capacity flow.
The location of the MSWLF unit relative to
the velocity distribution of floodwaters will
greatly influence the susceptibility to
washout. This type of assessment will
require a conservative estimate of the shear
stress on the landfill components caused by
the depth, velocity, and duration of
impinging river waters. Depending on the
amount of inundation, the landfill unit may
act as a channel side slope or bank or it may
be isolated as an island within the overbank
river channel. In both cases an estimate of
the river velocity would be part of a proper
assessment.
The assessment of flood water velocity
requires that the channel cross section be
known above, at, and below the landfill unit.
Friction factors on the overbank are deter-
mined from the surface conditions and vege-
tation present. River hydrologic models may
be used to simulate flow levels and estimate
velocities through these river cross sections.
The Army Corps of Engineers (COE, 1982)
has developed several numerical models to
aid in the prediction of flood hydrographs,
flow parameters, the effect of obstructions on
flow levels, the simulation of flood control
structures, and sediment transport. These
methods may or may not be appropriate for a
site; however, the following models provide
well-tested analytical approaches:
HEC-1 Flood Hydrograph Package
(watershed model that simulates the
surface run-off response of a river basin
to precipitation);
HEC-2 Water Surface Profiles (computes
water surface profiles due to
obstructions; evaluates floodway
encroachment potential);
HEC-5 Simulation of Flood Control and
Conservation Systems (simulates the
sequential operation of a reservoir
channel system with a branched
network configuration; used to design
27
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Subpart B
routing that will minimize downstream
flooding); and
HEC-6 Scour and Deposition in Rivers
and Reservoirs (calculates water surface
and sediment bed surface profiles).
The HEC-2 model is not appropriate for
simulation of sediment-laden braided stream
systems or other intermittent/dry stream
systems that are subject to flash flood events.
Standard run-off and peak flood hydrograph
methods would be more appropriate for such
conditions to predict the effects of severe
flooding.
There are many possible cost-effective
methods to protect the MSWLF unit from
flood damage including embankment designs
with rip-rap, geotextiles, or other materials.
Guidelines for designing with these materials
may be found in Maynard (1978) and SCS
(1983). Embankment design will require an
estimate of river flow velocities, flow profiles
(depth), and wave activity. Figure 2-3
provides a design example for dike
construction and protection of the landfill
surface from flood water. It addresses height
requirements to control the effects of wave
activity. The use of alternate erosion control
methods such as gabions (cubic-shaped wire
structures filled with stone), paving bricks,
and mats may be considered. It should be
noted, however, that the dike design in Figure
2-3 may further decrease the water storage
and flow capacities.
2.4 WETLANDS
40 CFR §258.12
2.4.1 Statement of Regulation
(a) New MSWLF units and lateral
expansions shall not be located in wetlands,
unless the owner or operator can make the
following demonstrations to the Director of
an approved State:
(1) Where applicable under section 404
of the Clean Water Act or applicable State
wetlands laws, the presumption that a
practicable alternative to the proposed
landfill is available which does not involve
wetlands is clearly rebutted;
(2) The construction and operation of
the MSWLF unit will not:
(i) Cause or contribute to violations of
any applicable State water quality
standard,
(ii) Violate any applicable toxic
effluent standard or prohibition under
Section 307 of the Clean Water Act,
(iii) Jeopardize the continued existence
of endangered or threatened species or
result in the destruction or adverse
modification of a critical habitat, protected
under the Endangered Species Act of 1973,
and
(iv) Violate any requirement under the
Marine Protection, Research, and
Sanctuaries Act of 1972 for the protection
of a marine sanctuary;
28
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ASSUMPTIONS:
* FETCH = 2500 FT'
* WIND SPEED = 50 MPH
* AVE. WATER DEPTH ALONG FETCH = 5 FT
* OVERBANK WATER VELOCITY = 0,25 FT/S
DEFINITIONS
Zs = Wave Setup (tilting of water surface upward at downwind end)
Zw = Capillary Waves Height {developed by wind over water surface)
Zr = Wave Run-up (water run-up along dike from wave impact)
WIND
i
t
RIVER
LANDFILL
EQUATIONS
WIND
Free Board
2500 F x>t Fetch
Dike
Landfill
Flood Plain
Rood Plain
Section A
Total Wave Height (Zt = Zs + Zw + Zr)
\
.100 yr Flood Water
\ A
SECTION A
SOLUTIONS
where:
Zr = Wave run-up along dike
Zr/Zw = Relative run-up rafo from
chart below
A = Wavelength
tw = Wave period
Vw = wind speed (mph)
F = fetch (mites)
Zw= 0.034 V
where:
Zw = ave. height of heighest 1/3rd
of waves (ft)
F = fetch (miles)
140CW
where:
Zs = rise above stiff water [eve! (ft)
Vw = wind speed (mph)
F = fetch (miles)
d = water depth along fetch (ft)
w=-
KjH"
1000(0.0167
-since)'
where:
W = Rip - Rap stone weight (tos)
d - Rip - Rap stone diameter
K = Coefficient (30)
Y = Stone Density (Ib/cf)
H = height of design wave (ft)
o = bank slope (degrees)
From the data provided in the assumptions
at the beginning of the example:
Zs = 0.18 n., Zw = 1.55 ft., Zr = 2.40 ft '
Zt Design Height = 4.13 ft
Base 100 yr flood level = 5 ft
for Factor of Safety of 1.5
Dike Height = (1.5) (4.13 + 5) = 13.7 ft
For the Rip - Rap design given:
K = 30, y= 120, H = 1.55 ft., a = 185
For the protective stone on Dike
d = 0.5ft, W = 12lbs7stone
\~.^_1'*~ , "°: .TiTT -i------• -H
Wave run-up ratios vs. wave steepness and embankment slopes
Re'e^ence 'or Equations: U.S. Department of Interior, Bureau of Land Reclamation (1974)
Reference tor Wave Run-up Chart: L»nsiey and Franani (1972)
Figure 2-3. Example Floodplain Protection Dike Design
29
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Subpart B
(3) The MSWLF unit will not cause or
contribute to significant degradation of
wetlands. The owner or operator must
demonstrate the integrity of the MSWLF
unit and its ability to protect ecological
resources by addressing the following
factors:
(i) Erosion, stability, and migration
potential of native wetland soils, muds and
deposits used to support the MSWLF unit;
(ii) Erosion, stability, and migration
potential of dredged and fill materials used
to support the MSWLF unit;
(iii) The volume and chemical nature
of the waste managed in the MSWLF unit;
(iv) Impacts on fish, wildlife, and
other aquatic resources and their habitat
from release of the solid waste;
(v) The potential effects of
catastrophic release of waste to the wetland
and the resulting impacts on the
environment; and
(vi) Any additional factors, as
necessary, to demonstrate that ecological
resources in the wetland are sufficiently
protected.
(4) To the extent required under
Section 404 of the Clean Water Act or
applicable State wetland laws, steps have
been taken to attempt to achieve no net
loss of wetlands (as defined by acreage
and function) by first avoiding impacts to
wetlands to the maximum extent
practicable as required by paragraph
(a)(l) of this section, then minimizing
unavoidable impacts to the maximum
extent practicable, and finally offsetting
remaining unavoidable wetland impacts
through all appropriate and practicable
compensatory mitigation actions (e.g.,
restoration of existing degraded wetlands
or creation of man-made wetlands); and
(5) Sufficient information is available
to make a reasonable determination with
respect to these demonstrations.
(b) For purposes of this section,
"wetlands" means those areas that are
defined in 40 CFR §232.2(r).
2.4.2 Applicability
New MSWLF units and lateral expansions in
wetlands are prohibited, except in approved
States. The wetland restrictions allow
existing MSWLF units located in wetlands to
continue operations as long as compliance
with the other requirements of Part 258 can
be maintained.
In addition to the regulations listed in 40 CFR
§258.12(a)(2), other Federal requirements
may be applicable in siting a MSWLF unit in
a wetland. These include:
• Sections 401, 402, and 404 of the CWA;
• Rivers and Harbors Act of 1989;
• National Environmental Policy Act;
• Migratory Bird Conservation Act;
• Fish and Wildlife Coordination Act;
• Coastal Zone Management Act;
• Wild and Scenic Rivers Act; and the
• National Historic Preservation Act.
As authorized by the EPA, the use of
wetlands for location of a MSWLF facility
may require a permit from the U.S. Army
30
-------
Location Criteria
Corps of Engineers (COE). The types of
wetlands present (e.g., headwater, isolated, or
adjacent), the extent of the wetland impact,
and the type of impact proposed will
determine the applicable category of COE
permit (individual or general) and the permit
application procedures. The COE District
Engineer should be contacted prior to permit
application to determine the available
categories of permits for a particular site.
Wetland permitting or permit review and
comment can include additional agencies at
the federal, state, regional, and local level.
The requirements for wetland permits should
be reviewed by the owner/operator to ensure
compliance with all applicable regulations.
When proposing to locate a new facility or
lateral expansion in a wetland, owners or
operators must be able to demonstrate that
alternative sites are not available and that the
impact to wetlands is unavoidable.
If it is demonstrated that impacts to the
wetland are unavoidable, then all practicable
efforts must be made to minimize and, when
necessary, compensate for the impacts. The
impacts must be compensated for by restoring
degraded wetlands, enhancing or preserving
existing wetlands, or creating new wetlands.
It is an EPA objective that mitigation
activities result in the achievement of no net
loss of wetlands.
2.4.3 Technical Considerations
The term wetlands, referenced in §258.12(b),
is defined in §232.2(r). The EPA currently is
studying the issues involved in defining and
delineating wetlands. Proposed changes to
the "Federal Manual for Identifying and
Delineating Jurisdictional Wetlands," 1989,
are still being reviewed. [These changes were
proposed in the Federal Register on August
14, 1991 (56 FR 40446) and on December 19,
1991 (56 FR 65964).] Therefore, as of
January 1993, the method used for delineating
a wetland is based on a previously existing
document, "Army Corps of Engineers
Wetlands Delineation Manual," 1987. A
Memorandum of Understanding between
EPA and the Department of the Army, Corps
of Engineers, was amended on January 4,
1993, to state that both agencies would now
use the COE 1987 manual as guidance for
delineating wetlands. The methodology
applied by an owner/operator to define and
delineate wetlands should be in keeping with
the federal guidance in place at the time of the
delineation.
Because of the unique nature of wetlands, the
owner/operator is required to demonstrate that
the landfill unit will not cause or contribute to
significant degradation of wetlands. The
demonstration must be reviewed and
approved by the Director of an approved State
and placed in the facility operating record.
This provision effectively bans the siting of
new MSWLF units or lateral expansions in
wetlands in unapproved States.
There are several key issues that need to be
addressed if an owner or operator proposes to
locate a lateral expansion or a new MSWLF
unit in a wetland. These issues include: (1)
review of practicable alternatives, (2)
evaluation of wetland acreage and function, (3)
evaluation of impacts of MSWLF units on
wetlands, and (4) offsetting impacts. Although
EPA has an objective of no net loss of wetlands
in terms of acreage and function, it recognizes
that regions of the country exist where
proportionally large areas are dominated by
wetlands. In these regions, sufficient
31
-------
Subpart B
acreage and a suitable type of upland may not
be present to allow construction of a new
MSWLF unit or lateral expansion without
wetland impacts. Wetlands evaluations may
become an integral part of the siting, design,
permitting, and environmental monitoring
aspects of a landfill unit/facility (see Figure 2-
4).
Practicable Alternatives
EPA believes that locating new MSWLF units
or lateral expansions in wetlands should be
done only where there are no less damaging
alternatives available. Due to the extent of
wetlands that may be present in certain
regions, the banning of new MSWLF units or
lateral expansions in wetlands could cause
serious capacity problems. The flexibility of
the rule allows owners or operators to
demonstrate that there are no practicable
alternatives to locating or laterally expanding
MSWLF units in wetlands.
As part of the evaluation of practicable
alternatives, the owner/operator should
consider the compliance of the location with
other regulations and the potential impacts of
the MSWLF unit on wetlands and related
resources. Locating or laterally expanding
MSWLF units in wetlands requires
compliance with other environmental
regulations. The owner or operator must
show that the operation or construction of the
landfill unit will not:
• Violate any applicable State water
quality standards;
• Cause or contribute to the violation of
any applicable toxic effluent standard
or prohibition;
• Cause or contribute to violation of
any requirement for the protection of
a marine sanctuary; and
• Jeopardize the continued existence of
endangered or threatened species or
critical habitats.
The MSWLF unit cannot cause or contribute
to significant degradation of wetlands.
Therefore, the owner/operator must:
• Ensure the integrity of the MSWLF
unit, including consideration of the
erosion, stability, and migration of
native wetland soils and dredged/fill
materials;
• Minimize impacts on fish, wildlife,
and other aquatic resources and their
habitat from the release of solid
waste;
• Evaluate the effects of catastrophic
release of wastes on the wetlands; and
• Assure that ecological resources in the
wetlands are sufficiently protected,
including consideration of the volume
and chemical nature of waste
managed in the MSWLF unit.
These factors were partially derived from
Section 404(b)(l) of the Clean Water Act.
These guidelines address the protection of the
ecological resources of the wetland.
After consideration of these factors, if no
practicable alternative to locating the landfill
in wetlands is available, compensatory steps
must be taken to achieve no net loss of
wetlands as defined by acreage and
32
-------
Wetland Study
Not Required
Has a wet-
land Delineation
Study Been
Performed?
Is landfill
Site Adjacent to
of Impinging on
a Wetland''
Contact COE
Regarding a
Wetland
Delineation Study
A Wetland
Delineation Study
Should toe
Performed
Are
Practicable
Alternate
Disposal Optens
or Landfill Sites
Available'
Alternate
Disposal Study
Required
Cannot Build in
WeflarxJ
A/e Alternate
Disposal Options
or Landfill Sites
Available7
Identify Affected Acreage
and Functions ater
Minimizing Impact and
Arrange COE Site Visit
Contact State and COE to
Determine Wetland Offset
Ratios and Functional
Rank of Offset Options
File for Landfill
Permit /404 Permit
1. Impact Minimization Plan
2, Rebuttal of Alternatives
3. Wettartd Offset Plan
4. Offset Monitoring Plan
Figure 2-4
Wetlands Decision Tree for Owners/Operators
in Approved States
33
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Subpart B
function. The owner/operator must try to
avoid and/or minimize impacts to the
wetlands to the greatest extent possible.
Where avoidance and minimization still result
in wetland impacts, mitigation to offset
impacts is required. Mitigation plans must be
approved by the appropriate regulatory
agencies and must achieve an agreed-upon
measure of success. Examples of mitigation
include restoration of degraded wetlands or
creation of wetland acreage from existing
uplands.
Part 258 presumes that practicable alternatives
are available to locating landfill units in
wetlands because landfilling is not a water-
dependent activity. In an approved State, the
owner or operator can rebut the presumption
that a practicable alternative to the proposed
landfill unit or lateral expansion is available.
The term "practicable" pertains to the
economic and social feasibility of alternatives
(e.g., collection of waste at transfer stations
and trucking to an existing landfill facility or
other possible landfill sites). The feasibility
evaluation may entail financial, economic,
administrative, and public acceptability
analyses as well as engineering
considerations. Furthermore, the evaluations
generally will require generation and
assessment of land use, geologic, hydrologic,
geographic, demographic, zoning, traffic
maps, and other related information.
To rebut the presumption that an alternative
practicable site exists generally will require
that a site search for an alternative location
be conducted. There are no standard
methods for conducting site searches due to
the variability of the number and hierarchy
of screening criteria that may be applied in
a specific case. Typical criteria may include:
• Distance from waste generation
sources;
• Minimum landfill facility size
requirements;
• Soil conditions;
• Proximity to ground-water users;
• Proximity of significant aquifers;
• Exclusions from protected natural
areas;
• Degree of difficulty to remediate
features; and
• Setbacks from roadways and
residences.
Wetland Evaluations
The term "wetlands" includes swamps,
marshes, bogs, and any areas that are
inundated or saturated by ground water or
surface water at a frequency and duration to
support, and that under normal circumstances
do support, a prevalence of vegetation
adapted for life in saturated soil conditions.
As defined under current guidelines, wetlands
are identified based on the presence of hydric
soils, hydrophyte vegetation, and the wetland
hydrology. These characteristics also affect
the functional value of a wetland in terms of
its role in: supporting fish and wildlife
habitats; providing aesthetic, scenic, and
recreational value; accommodating flood
storage; sustaining aquatic diversity; and its
relationships to surrounding natural areas
through nutrient retention and productivity
exportation (e.g., releasing nutrients to
downstream areas, providing transportable
food sources).
Often, a wetland assessment will need to be
conducted by a qualified and experienced
34
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Location Criteria
multi-disciplinary team. The assessment
should identify: (1) the limits of the wetland
boundary based on hydrology, soil types and
plant types; (2) the type and relative
abundance of vegetation, including trees; and
(3) rare, endangered, or otherwise protected
species and their habitats (if any).
The current methods used to delineate
wetlands are presented in "COE Wetlands
Delineation Manual," 1987. In January 1993,
EPA and COE agreed to use the 1987 Manual
for purposes of delineation. The Federal
Manual for Identifying and Delineating
Jurisdictional Wetlands (COE, 1989) contains
an extensive reference list of available
wetland literature. For example, lists of
references for the identification of plant
species characteristic of wetlands throughout
the United States, hydric soils classifications,
and related wetland topics are presented.
USGS topographic maps, National Wetland
Inventory (NWI) maps, Soil Conservation
Service (SCS) soil maps, wetland inventory
maps, and aerial photographs prepared locally
also may provide useful information.
After completion of a wetland study, the
impact of the MSWLF unit on wetlands and
its relationship to adjacent wetlands can be
assessed more effectively. During the
permitting process, local, State, and federal
agencies with jurisdiction over wetlands will
need to be contacted to schedule a site visit.
It is usually advantageous to encourage this
collaboration as early as possible in the site
evaluation process, especially if the State
program office that is responsible for
wetland protection is different from the
solid waste management office.
Regulations will vary significantly from
State to State with regard to the size and type
of wetland that triggers State agency
involvement. In general, the COE will
require notification and/or consultation on
any proposed impact on any wetland
regardless of the actual degree of the impact.
Other agencies such as the Fish and Wildlife
Service and the SCS may need to be
contacted in some States.
Evaluation of ecological resource protection
may include assessment of the value of the
affected wetland. Various techniques are
available for this type of evaluation, and the
most appropriate technique for a specific site
should be selected in conjunction with
applicable regulatory agencies. Available
methods include analysis of functional value,
the Wetland Evaluation Technique (WET),
and the Habitat Evaluation Procedure (HEP).
The 1987 Manual does not address functional
value in the detail provided by the 1989
manual. The methodology for conducting a
functional value assessment should be
reviewed by the applicable regulatory
agencies. It is important to note that
functional value criteria may become a
standard part of wetland delineation following
revision of the federal guidance manual(s).
The owner or operator should remain current
with the accepted practices at the time of the
delineation/assessment.
The functional value of a given wetland is
dependent on its soil, plant, and hydrologic
characteristics, particularly the diversity,
prevalence, and extent of wetland plant
species. The relationship between the
wetland and surrounding areas (nutrient sinks
and sources) and the ability of the wetland to
support animal habitats, or rare or endangered
species, contributes to the evaluation of
functional value.
35
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Subpart B
Other wetland and related assessment
methodologies include WET and HEP. WET
allows comparison of the values and functions
of wetlands before and after construction of a
facility, thereby projecting the impact a
facility may have on a wetland. WET was
developed by the Federal Highway
Administration and revised by the COE
(Adamus et a/., 1987). HEP was developed
by the Fish and Wildlife Service to determine
the quality and quantity of available habitat
for selected species. HEP and WET may be
used in conjunction with each other to provide
an integrated assessment.
Impact Evaluation
If the new unit or lateral expansion is to be
located in a wetland, the owner or operator
must demonstrate that the unit will not cause
or contribute to significant degradation of the
wetland. Erosion potential and stability of
wetland soils and any dredged or fill material
used to support the MSWLF unit should be
identified as part of the wetlands evaluation.
Any adverse stability or erosion problems that
could affect the MSWLF or contaminant
effects that could be caused by the MSWLF
unit should be resolved.
All practicable steps are to be taken to
minimize potential impacts of the MSWLF
unit to wetlands. A number of measures
that can aid in minimization of impacts are
available. Appropriate measures are site-
specific and should be incorporated into the
design and operation of the MSWLF unit.
For example, placement of ground water
barriers may be required if soil and shallow
ground-water conditions would cause
dewatering of the wetland due to the
existence of underdrain pipe systems at the
facility. In many instances, however,
wetlands are formed in response to perched
water tables over geologic material of low
hydraulic conductivity and, therefore,
significant drawdown impacts may not occur.
It is possible that the landfill unit/facility will
not directly displace wetlands, but that
adverse effects may be caused by leachate or
run-off Engineered containment systems for
both leachate and run-off should mitigate the
potential for discharge to wetlands.
Additional actions and considerations
relevant to mitigating impacts of fill
material in wetlands that may be
appropriate for MSWLF facilities are
provided in Subpart H (Actions to Minimize
Adverse Effects) of 40 CFR §230
(Guidelines for Specification of Disposal
Sites for Dredged or Fill Materials).
Wetland Offset
All unavoidable impacts must be "offset" or
compensated for to ensure that the facility has
not caused, to the extent practicable, any net
loss of wetland acreage. This compensatory
mitigation may take the form of upgrading
existing marginal or lower-quality wetlands
or creating new wetlands. Wetland offset
studies require review and development on a
site-specific basis.
To identify potential sites that may be
proposed for upgrade of existing wetlands
or creation of new wetlands, a cursory
assessment of surrounding wetlands and
uplands should be conducted. The
assessment may include a study to define
the functional characteristics and inter-
relationships of these potential wetland
mitigation areas. An upgrade of an existing
wetland may consist of transplanting
36
-------
Location Criteria
appropriate vegetation and importing low-
permeability soil materials that would be
conducive to forming saturated soil
conditions. Excavation to form open water
bodies or gradual restoration of salt water
marshes by culvert expansions to promote sea
water influx are other examples of
compensatory mitigation.
Individual States may have offset ratios to
determine how much acreage of a given
functional value is required to replace the
wetlands that were lost or impacted.
Preservation of lands, such as through
perpetual conservation easements, may be
considered as a viable offset option. State
offset ratios may require that for wetlands of
an equivalent functional value, a larger
acreage be created than was displaced.
Due to the experimental nature of creating or
enhancing wetlands, a monitoring program to
evaluate the progress of the effort should be
considered and may be required as a wetland
permit condition. The purpose of the
monitoring program is to verify that the
created/upgraded wetland is successfully
established and that the intended function of
the wetland becomes self-sustaining over
time.
2.5 FAULT AREAS
40 CFR §258.13
2.5.1 Statement of Regulation
(a) New MSWLF units and lateral
expansions shall not be located within 200
feet (60 meters) of a fault that has had
displacement in Holocene time unless the
owner or operator demonstrates to the
Director of an approved State that an
alternative setback distance of less than
200 feet (60 meters) will prevent damage to
the structural integrity of the MSWLF unit
and will be protective of human health and
the environment.
(b) For the purposes of this section:
(1) Fault means a fracture or a zone of
fractures in any material along which
strata on one side have been displaced with
respect to that on the other side.
(2) Displacement means the relative
movement of any two sides of a fault
measured in any direction.
(3) Holocene means the most recent
epoch of the Quaternary period, extending
from the end of the Pleistocene Epoch to
the present.
2.5.2 Applicability
Except in approved States, the regulation bans
all new MSWLF units or lateral expansions of
existing units within 200 feet (60 meters) of
the outermost boundary of a fault that has
experienced displacement during the
Holocene Epoch (within the last 10,000 to
12,000 years). Existing MSWLF units are
neither required to close nor to retrofit if they
are located in fault areas.
A variance to the 200-foot setback is
provided if the owner or operator can
demonstrate to the Director of an approved
State that a shorter distance will prevent
damage to the structural integrity of the
MSWLF unit and will be protective of
human health and the environment. The
demonstration for a new MSWLF unit or
lateral expansion requires review and
37
-------
Subpart B
approval by the Director of an approved State.
If the demonstration is approved, it must be
placed in the facility's operating record. The
option to have a setback of less than 200 feet
from a Holocene fault is not available in
unapproved States.
2.5.3 Technical Considerations
Locating a landfill in the vicinity of an area
that has experienced faulting in recent time
has inherent dangers. Faulting occurs in areas
where the geologic stresses exceed a geologic
material's ability to withstand those stresses.
Such areas also tend to be subject to
earthquakes and ground failures (e.g.,
landslides, soil liquefaction) associated with
seismic activity. A more detailed discussion
of seismic activity is presented in Section 2.6.
Proximity to a fault can cause damage
through:
• Movement along the fault which can
cause displacement of facility structures,
Seismic activity associated with faulting
which can cause damage to facility
structures through vibratory action (see
Figure 2-5), and
Earth shaking which can cause ground
failures such as slope failures.
Consequently, appropriate setbacks from fault
areas are required to minimize the potential
for damage.
To determine if a proposed landfill unit is
located in a Holocene fault area, U.S.
Geological Survey (USGS) mapping can be
used. A series of maps known as the
"Preliminary Young Fault Maps,
Miscellaneous Field Investigation (MF) 916"
was published by the USGS in 1978.
Information about these maps can be obtained
from the USGS by calling 1-800-USA-
MAPS, which reaches the USGS National
Center in Reston, Virginia, or by calling 303-
236-7477, which reaches the USGS Map
Sales Center in Denver, Colorado.
For locations where a fault zone has been
subject to movement since the USGS maps
were published in 1978, a geologic
reconnaissance of the site and surrounding
areas may be required to map fault traces and
to determine the faults along which
movement has occurred in Holocene time.
This reconnaissance also may be necessary to
support a demonstration for a setback of less
than 200 feet. Additional requirements may
need to be met before a new unit or lateral
expansion may be approved.
A site fault characterization is necessary to
determine whether a site is within 200 feet of
a fault that has had movement during the
Holocene epoch. An investigation would
include obtaining information on any
lineaments (linear features) that suggest the
presence of faults within a 3,000-foot radius
of the site. The information could be based
on:
A review of available maps, logs,
reports, scientific literature, or insurance
claim reports;
An aerial reconnaissance of the area
within a five-mile radius of the site,
including aerial photo analysis; or
38
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Location Criteria
Figure 2-5
Potential Seismic Effects
Deformed Leachate
Collection Pipe
\
\Leachate
Collection Pipe
Clay Liner
A schematic diagram of a landfill showing potential deformation of
the leachate collection and removal system by seismic stresses.
Source: US EPA, 1992
39
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Subpart B
A field reconnaissance that includes
walking portions of the area within 3,000
feet of the unit.
If the site fault characterization indicates that
a fault or a set of faults is situated within
3,000 feet of the proposed unit, investigations
should be conducted to determine the
presence or absence of any faults within 200
feet of the site that have experienced
movement during the Holocene period. Such
investigations can include:
Subsurface exploration, including drilling
and trenching, to locate fault zones and
evidence of faulting.
Trenching perpendicular to any faults or
lineaments within 200 feet of the unit.
Determination of the age of any
displacements, for example by examining
displacement of surficial deposits such as
glacial or older deposits (if Holocene
deposits are absent).
• Examination of seismic epicenter
information to look for indications of
recent movement or activity along
structures in a given area.
Review of high altitude, high resolution
aerial photographs with stereo-vision
coverage. The photographs are produced
by the National Aerial Photographic
Program (NAPP) and the National High
Altitude Program (NHAP). Information
on these photos can be obtained from the
USGS EROS Data Center in Sioux Falls,
South Dakota at (605) 594-615
Based on this information as well as
supporting maps and analyses, a qualified
professional should prepare a report that
delineates the location of the Holocene
fault(s) and the associated 200-foot setback.
If requesting an alternate setback, a
demonstration must be made to show that no
damage to the landfill's structural integrity
will result. Examples of engineering
considerations and modifications that may be
included in such demonstrations are as
follows:
• For zones with high probabilities of high
accelerations (horizontal) within the
moderate range of 0. Ig to 0.75g, seismic
designs should be developed.
Seismic stability analysis of landfill
slopes should be performed to guide
selection of materials and gradients for
slopes.
Where in-situ and laboratory tests
indicate that a potential landfill site is
susceptible to liquefaction, ground
improvement measures like grouting,
dewatering, heavy tamping, and
excavation should be implemented.
• Engineering options include:
— Flexible pipes,
— Ground improvement measures
(grouting, dewatering, heavy
tamping, and excavation), and/or
— Redundant precautionary
measures (secondary containment
system).
40
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Location Criteria
In addition, use of such measures needs to be
demonstrated to be protective of human health
and the environment. The types of
engineering controls described above are
similar to those that would be employed in
areas that are likely to experience
earthquakes.
2.6 SEISMIC IMPACT ZONES
40 CFR §258.14
2.6.1 Statement of Regulation
(a) New MSWLF units and lateral
expansions shall not be located in seismic
impact zones, unless the owner or operator
demonstrates to the Director of an
approved State that all containment
structures, including liners, leachate
collection systems, and surface water
control systems, are designed to resist the
maximum horizontal acceleration in
lithified earth material for the site. The
owner or operator must place the
demonstration in the operating record and
notify the State Director that it has been
placed in the operating record.
(b) For the purposes of this section:
(1) Seismic impact zone means an area
with a ten percent or greater probability
that the maximum horizontal acceleration
in lithified earth material, expressed as a
percentage of the earth's gravitational pull
(g), will exceed O.lOg in 250 years.
in
(2) Maximum horizontal acceleration
lithified earth material means the
maximum expected horizontal acceleration
depicted on a seismic hazard map, with a
90 percent or greater probability that the
acceleration will not be exceeded in 250
years, or the maximum expected horizontal
acceleration based on a site-specific seismic
risk assessment.
(3) Lithified earth material means all
rock, including all naturally occurring and
naturally formed aggregates or masses of
minerals or small particles of older rock
that formed by crystallization of magma or
by induration of loose sediments. This
term does not include man-made materials,
such as fill, concrete, and asphalt, or
unconsolidated earth materials, soil, or
regolith lying at or near the earth surface.
2.6.2 Applicability
New MSWLF units and lateral expansions in
seismic impact zones are prohibited, except in
approved States. A seismic impact zone is an
area that has a ten percent or greater
probability that the maximum expected
horizontal acceleration in lithified earth
material, expressed as a percentage of the
earth's gravitational pull (g), will exceed
O.lOg in 250 years.
The regulation prohibits locating new units or
lateral expansions in a seismic impact zone
unless the owner or operator can demonstrate
that the structural components of the unit
(e.g., liners, leachate collection systems, final
cover, and surface water control systems) are
designed to resist the maximum horizontal
acceleration in lithified earth material at the
site. Existing units are not required to be
retrofitted. Owners or operators of new units
or lateral expansions must notify the Director
of an approved State and place the
demonstration of compliance with the
conditions of the restriction in the operating
record.
41
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Subpart B
2.6.3 Technical Considerations
Background on Seismic Activity
To understand seismic activity, it is helpful to
know its origin. A brief introduction to the
geologic underpinnings of seismic activity is
presented below.
The earth's crust is not a static system. It
consists of an assemblage of earthen masses
that are in slow motion. As new crust is
generated from within the earth, old edges of
crust collide with one another, thereby
causing stress. The weaker edge is forced to
move beneath the stronger edge back into the
earth.
The dynamic conditions of the earth's crust
can be manifested as shaking ground (seismic
activity), fracturing (faulting), and volcanic
eruptions. Seismic activity also can result in
types of ground failure. Landslides and mass
movements (e.g., slope failures) are common
on slopes; soil compaction or ground
subsidence tends to occur in unconsolidated
valley sediments; and liquefaction of soils
tends to happen in areas where sandy or silty
soils that are saturated and loosely compacted
become in effect, liquefied (like quicksand)
due to the motion. The latter types of
phenomena are addressed in Section 2.7,
Unstable Areas.
Information Sources on Seismic Activity
To determine the maximum horizontal
acceleration of the lithified earth material
for the site (see Figure 2-6), owners or
operators of MSWLF units should review
the seismic 250-year interval maps in U.S.
Geological Survey Miscellaneous Field
Study Map MF-2120, entitled "Probabilistic
Earthquake Acceleration and Velocity Maps
for the United States and Puerto Rico"
(Algermissen et al., 1991). To view the
original of the map that is shown in Figure 2-
6 (reduced in size), contact the USGS office
in your area. The original map (Horizontal
Acceleration - Base modified from U.S.G.S.
National Atlas, 1970, Miscellaneous Field
Studies, Map MF 2120) shows county lines
within each State. For areas not covered by
the aforementioned map, USGS State seismic
maps may be used to estimate the maximum
horizontal acceleration. The National
Earthquake Information Center, located at the
Colorado School of Mines in Golden,
Colorado, can provide seismic maps of all 50
states. The Center also maintains a database
of known earthquakes and fault zones.
Information on the location of earthquake
epicenters and intensities may be available
through State Geologic Surveys or the
Earthquake Information Center. For
information concerning potential
earthquakes in specific areas, the Geologic
Risk Assessment Branch of USGS may be
of assistance. Other organizations that
study the effects of earthquakes on
engineered structures include the National
Information Service for Earthquake
Engineering, the Building Seismic Safety
Council, the National Institute of Science
and Technology, and the American Institute
of Architects.
Landfill Planning and Engineering in
Areas of Seismic Activity
Studies indicate that during earthquakes,
superficial (shallow) slides and differential
displacement tend to be produced, rather
than massive slope failures (U.S. Navy
1983). Stresses created by superficial
failures can affect the liner and final cover
42
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Principal Islands at
Hawaii
9:111 n.wxe
Explanation
- Jlrti/unial inx
al a pcitunl nf gravity.
Altort Equal AIM Projsdion
H-.HI I '.W«M«">
Figure 2-6. Seismic Impact Zones
(Areas with a 10% or greater probability that the maximum horizontal acceleration will exceed .10g in 250 years)
-------
Subpart B
systems as well as the leachate and gas
collection and removal systems. Tensional
stresses within the liner system can result in
fracturing of the soil liner and/or tearing of
the flexible membrane liner. Thus, when
selecting suitable sites from many potential
sites during the siting process, the
owner/operator should try to avoid a site with:
Holocene fault zones,
Sites with potential ground motion, and
Sites with liquefaction potential.
If one of the above types of sites is selected,
the owner/operator must consider the costs
associated with the development of the site.
If, due to a lack of suitable alternatives, a site
is chosen that is located in a seismic impact
zone, a demonstration must be made to the
Director of an approved State that the design
of the unit's structural components (e.g.,
liners, leachate collection, final covers, run-on
and run-off systems) will resist the maximum
horizontal acceleration in lithified materials at
the site. As part of the demonstration,
owner/operators must:
Determine the expected peak ground
acceleration from a maximum strength
earthquake that could occur in the area,
• Determine the site-specific seismic
hazards such as soil settlement, and
Design the facility to withstand the
expected peak ground acceleration.
The design of the slopes, leachate collection
system, and other structural components
should have built-in conservative design
factors. Additionally, redundant
precautionary measures should be designed
and built into the various landfill systems.
For those units located in an area with an
estimated maximum horizontal acceleration
greater than O.lg, an evaluation of seismic
effects should consider both foundation soil
stability and waste stability under seismic
loading. Conditions that may be considered
for the evaluation include the construction
phase (maximum open excavation depth of
new cell adjacent to an existing unit), closure
activities (prior to final consolidation of both
waste and subsoil), and post-closure care
(after final consolidation of both waste and
foundation soil). If the maximum horizontal
acceleration is less than or equal to O.lg, then
the design of the unit will not have to
incorporate an evaluation of seismic effects
unless the facility will be situated in an area
with low strength foundation soils or soils
with potential for liquefaction. The facility
should be assessed for the effects of seismic
activity even if the horizontal acceleration is
expected to be less than 0. Ig.
In determining the potential effects of seismic
activity on a structure, an engineering
evaluation should examine soil behavior with
respect to earthquake intensity. When
evaluating soil characteristics, it is necessary
to know the soil strength as well as the
magnitude or intensity of the earthquake in
terms of peak acceleration. Other soil
characteristics, including degree of
compaction, sorting (organization of the soil
particles), and degree of saturation, may need
to be considered because of their potential
influence on site conditions. For example,
deposits of loose granular soils may be
compacted by the ground vibrations induced
by an earthquake. Such volume reductions
could result in large uniform or differential
44
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Location Criteria
settlements of the ground surface (Winterkorn
and Fang, 1975).
Well-compacted cohesionless embankments
or reasonably flat slopes in insensitive clay
are less likely to fail under moderate seismic
shocks (up to 0.15g and 0.20g acceleration).
Embankments made of insensitive cohesive
soils founded on cohesive soils or rock may
withstand even greater seismic shocks. For
earthen embankments in seismic regions,
designs with internal drainage and core
material most resistant to fracturing should be
considered. Slope materials vulnerable to
earthquake shocks are described below (U.S.
Navy, 1983):
• Very steep slopes of weak, fractured and
brittle rocks or unsaturated loess are
vulnerable to transient shocks caused by
tensional faulting;
• Loess and saturated sand may be
liquefied by seismic shocks causing the
sudden collapse of structures and flow
slides;
Similar effects are possible in sensitive
cohesive soils when natural moisture
exceeds the soil's liquid limit; and
• Dry cohesionless material on a slope at
an angle of repose will respond to
seismic shock by shallow sloughing and
slight flattening of the slope.
In general, loess, deltaic soils, floodplain
soils, and loose fills are highly susceptible to
liquefaction under saturated conditions
(USEPA, 1992).
Geotechnical stability investigations
frequently incorporate the use of computer
models to reduce the computational time of
well-established analytical methods. Several
computer software packages are available that
approximate the anticipated dynamic forces
of the design earthquake by resolving the
forces into a static analysis of loading on
design cross sections. A conservative
approach would incorporate both vertical and
horizontal forces caused by bedrock
acceleration if it can be shown that the types
of material of interest are susceptible to the
vertical force component. Typically, the
horizontal force caused by bedrock
acceleration is the major force to be
considered in the seismic stability analysis.
Examples of computer models include PC-
Slope by Geoslope Programming (1986), and
FLUSH by the University of California.
Design modifications to accommodate an
earthquake may include shallower waste
sideslopes, more conservative design of dikes
and run-off controls, and additional
contingencies for leachate collection should
primary systems be disrupted. Strengths of
the landfill components should be able to
withstand these additional forces with an
acceptable factor of safety. The use of
professionals experienced in seismic analysis
is strongly recommended for design of
facilities located in areas of high seismic risk.
2.7 UNSTABLE AREAS
40 CFR §258.15
2.7.1 Statement of Regulation
(a) Owners or operators of new
MSWLF units, existing MSWLF units,
and lateral expansions located in an
unstable area must demonstrate that
engineering measures have been
incorporated into the MSWLF unit's
45
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Subpart B
design to ensure that the integrity of the
structural components of the MSWLF unit
will not be disrupted. The owner or
operator must place the demonstration in
the operating record and notify the State
Director that it has been placed in the
operating record. The owner or operator
must consider the following factors, at a
minimum, when determining whether an
area is unstable:
(1) On-site or local soil conditions that
may result in significant differential
settling;
(2) On-site or local geologic or
geomorphologic features; and
(3) On-site or local human-made
features or events (both surface and
subsurface).
(b) For purposes of this section:
(1) Unstable area means a location that
is susceptible to natural or human-induced
events or forces capable of impairing the
integrity of some or all of the landfill
structural components responsible for
preventing releases from a landfill.
Unstable areas can include poor foundation
conditions, areas susceptible to mass
movements, and Karst terrains.
(2) Structural components means
liners, leachate collection systems, final
covers, run-on/run-off systems, and any
other component used in the construction
and operation of the MSWLF that is
necessary for protection of human health
and the environment.
(3) Poor foundation conditions means
those areas where features exist which
indicate that a natural or man-induced
event may result in inadequate foundation
support for the structural components of a
MSWLF unit.
(4)
Areas susceptible to mass
movement means those areas of influence
(i.e., areas characterized as having an
active or substantial possibility of mass
movement) where the movement of earth
material at, beneath, or adjacent to the
MSWLF unit, because of natural or man-
induced events, results in the downslope
transport of soil and rock material by
means of gravitational influence. Areas of
mass movement include, but are not
limited to, landslides, avalanches, debris
slides and flows, solifluction, block sliding,
and rock fall.
(5) Karst terrains means areas where
karst topography, with its characteristic
surface and subterranean features, is
developed as the result of dissolution of
limestone, dolomite, or other soluble rock.
Characteristic physiographic features
present in karst terrains include, but are
not limited to, sinkholes, sinking streams,
caves, large springs, and blind valleys.
2.7.2 Applicability
Owners/operators of new MSWLF units,
existing MSWLF units, and lateral
expansions of units that are located in
unstable areas must demonstrate the
structural integrity of the unit. Existing
units for which a successful demonstration
cannot be made must be closed. The
regulation applies to new units, existing
units, and lateral expansions that are located
on sites classified as unstable areas.
Unstable areas are areas susceptible to
46
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Location Criteria
natural or human-induced events or forces
that are capable of impairing or destroying the
integrity of some or all of the structural
components. Structural components consist
of liners, leachate collection systems, final
cover systems, run-on and run-off control
systems, and any other component necessary
for protection of human health and the
environment.
MSWLF units can be located in unstable
areas, but the owner or operator must
demonstrate that the structural integrity of the
MSWLF unit will not be disrupted. The
demonstration must show that engineering
measures have been incorporated into the
design of the unit to ensure the integrity of the
structural components. Existing MSWLF
units that do not meet the demonstration must
be closed within 5 years in accordance with
§258.60, and owners and operators must
undertake post-closure activities in
accordance with §258.61. The Director of an
approved State can grant a 2-year extension to
the closure requirement under two conditions:
(1) no disposal alternative is available, and (2)
no immediate threat is posed to human health
and the environment.
2.7.3 Technical Considerations
Again, for the purposes of this discussion,
natural unstable areas include those areas that
have poor soils for foundations, are
susceptible to mass movement, or have karst
features.
Areas with soils that make poor
foundations have soils that are
expansive or settle suddenly. Such
areas may lose their ability to support a
foundation when subjected to natural
(e.g., heavy rain) or man-made events
(e.g., explosions).
— Expansive soils usually are clay-
rich soils that, because of their
molecular structure, tend to swell
and shrink by taking up and
releasing water and thus are
sensitive to a variable hydrologic
regime. Such soils include:
smectite (montmorillonite group)
and vermiculite clays; bentonite
is a smectite-rich clay. In
addition, soils rich in "white
alkali" (sodium sulfate),
anhydrite (calcium sulfate), or
pyrite (iron sulfide) also may
exhibit swelling as water content
increases. Such soils tend to be
found in the arid western states.
— Soils that are subject to rapid
settlement (subsidence) include
loess, unconsolidated clays, and
wetland soils. Loess, which is
found in the central states, is a
wind-deposited silt that is
moisture-deficient and tends to
compact upon wetting.
Unconsolidated clays, which can
be found in the southwestern
states, can undergo considerable
compaction when fluids such as
water or oil are removed.
Similarly, wetland soils, which
by their nature are water-bearing,
also tend to be subject to
subsidence when water is
withdrawn.
Another type of unstable area is an
area that is subject to mass
movement. Such areas can be situated
47
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Subpart B
on steep or gradual slopes. They tend to have
rock or soil conditions that are conducive to
downslope movement of soil, rock, and/or
debris (either alone or mixed with water)
under the influence of gravity. Examples of
mass movements include avalanches,
landslides, debris slides and flows, and rock
slides.
Karst terrains tend to be subject to
extreme incidents of differential
settlement, namely complete ground
collapse. Karst is a term used to describe
areas that are underlain by soluble
bedrock, such as limestone, where
solution of the rock by water creates
subterranean drainage systems that may
include areas of rock collapse. These
areas tend to be characterized by large
subterranean and surficial voids (e.g.,
caverns and sinkholes) and unpredictable
surface and ground-water flow (e.g.,
sinking streams and large springs). Other
rocks such as dolomite or gypsum also
may be subject to solution effects.
Examples of human-induced unstable areas
are described below:
The presence of cut and/or fill slopes
during construction of the MSWLF unit
may cause slippage of existing soil or
rock.
Excessive drawdown of ground water
increases the effective overburden on the
foundation soils underneath the MSWLF
unit, which may cause excessive
settlement or bearing capacity failure on
the foundation soils.
A closed landfill as the foundation for a
new landfill ("piggy-backing") may be
unstable unless the closed landfill has
undergone complete settlement of the
underlying wastes.
As part of their demonstration to site a
landfill in an unstable area, owners/operators
must assess the ability of the soils and/or rock
to serve as a foundation as well as the ability
of the site embankments and slopes to
maintain a stable condition. Once these
factors have been evaluated, a MSWLF
design should be developed that will address
these types of concerns and prevent possible
associated damage to MSWLF structural
components.
In designing a new unit or lateral expansion
or re-evaluating an existing MSWLF unit, a
stability assessment should be conducted in
order to avoid or prevent a destabilizing event
from impairing the structural integrity of the
landfill component systems. A stability
assessment involves essentially three
components: an evaluation of subsurface
conditions, an analysis of slope stability, and
an examination of related design needs. An
evaluation of subsurface conditions requires:
Assessing the stability of foundation
soils, adjacent embankments, and slopes;
Investigating the geotechnical and
geological characteristics of the site to
establish soil strengths and other
engineering properties by performing
standard penetration tests, field vane
shear tests, and laboratory tests; and
48
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Location Criteria
Testing the soil properties such as water
content, shear strength, plasticity, and
grain size distribution.
A stability assessment should consider
(USEPA, 1988):
The adequacy of the subsurface
exploration program;
The liquefaction potential of the
embankment, slopes, and foundation
soils;
The expected behavior of the
embankment, slopes, and foundation soils
when they are subjected to seismic
activity;
The potential
failure; and
for seepage-induced
The potential for differential settlement.
In addition, a qualified professional must
assess, at a minimum, natural conditions (e.g.,
soil, geology, geomorphology) as well as
human-made features or events (both
subsurface and surface) that could cause
differential settlement of ground. Natural
conditions can be highly unpredictable and
destructive, especially if amplified by human-
induced changes to the environment. Specific
examples of natural or human-induced
phenomena include: debris flows resulting
from heavy rainfall in a small watershed; the
rapid formation of a sinkhole as a result of
excessive local or regional ground water
withdrawal in a limestone region; earth
displacement by faulting activity; and
rockfalls along a cliff face caused by
vibrations resulting from the detonation of
explosives or sonic booms.
Information on natural features can be
obtained from:
• The USGS National Atlas map
entitled "Engineering Aspects of
Karst," published in 1984;
• Regional or local soil maps;
• Aerial photographs (especially in
karst areas); and
• Site-specific investigations.
To examine an area for possible sources of
human-induced ground instability, the site
and surrounding area should be examined
for activities related to extensive
withdrawal of oil, gas, or water from
subsurface units as well as construction or
other operations that may result in ground
motion (e.g., blasting).
Types of Failures
Failures occur when the driving forces
imposed on the soils or engineered
structures exceed the resisting forces of the
material. The ratio of the resisting force to
the driving force is considered the factor of
safety (FS). At an FS value less than 1.0,
failure will occur by definition. There is a
high probability that, due to natural
variability and the degree of accuracy in
measurements, interpreted soil conditions
will not be precisely representative of the
actual soil conditions. Therefore, failure
may not occur exactly at the calculated
value, so factors of safety greater than 1.0
are required for the design. For plastic soils
such as clay, movement or deformation
(creep) may occur at a higher factor of
safety prior to catastrophic failure.
49
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Subpart B
Principal modes of failure in soil or rock
include:
Rotation (change of orientation) of an
earthen mass on a curved slip surface
approximated by a circular arc;
• Translation (change of position) of an
earthen mass on a planar surface whose
length is large compared to depth below
ground;
• Displacement of a wedge-shaped mass
along one or more planes of weakness;
• Earth and mud flows in loose clayey and
silty soils; and
Debris flows in coarse-grained soils.
For the purposes of this discussion, three
types of failures can occur at a landfill unit:
settlement, loss of bearing strength, and
sinkhole collapse.
• If not properly engineered, a landfill in
an unstable area may undergo extreme
settlement, which can result in structural
failure. Differential settlement is a
particular mode of failure that generally
occurs beneath a landfill in response to
consolidation and dewatering of the
foundation soils during and following
waste loading.
Settlement beneath a landfill unit, both
total and differential, should be assessed
and compared to the elongation strength
and flexure properties of the liner and
leachate collection pipe system. Even
small amounts of settlement can
seriously damage leachate collection
piping and sumps. The analysis will
provide an estimate of maximum
settlement, which can be used to aid in
estimating differential settlement.
Allowable settlement is typically
expressed as a function of total
settlement because differential settlement
is more difficult to predict. However,
differential settlement is a more serious
threat to the integrity of the structure
than total settlement. Differential
settlement also is discussed in Section
6.3 of Chapter 6.
Loss of bearing strength is a failure
mode that tends to occur in areas that
have soils that tend to expand, rapidly
settle, or liquefy, thereby causing failure
or reducing performance of overlying
MSWLF components. Another example
of loss of bearing strength involves
failures that have occurred at operating
sites where excavations for landfill
expansions adjacent to the filled areas
reduced the mass of the soil at the toe of
the slope, thereby reducing the overall
strength (resisting force) of the
foundation soil.
• Catastrophic collapse in the form of
sinkholes is a type of failure that occurs
in karst regions. As water, especially
acidic water, percolates through
limestone (calcium carbonate), the
soluble carbonate material dissolves,
forming cavities and caverns. Land
overlying caverns can collapse suddenly,
resulting in sinkhole features that can be
100 feet or more in depth and 300 feet or
more in width.
Tables 2-2 and 2-3 provide examples of
analytical considerations for mode of failure
assessments in both natural and human-made
slopes.
50
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Location Criteria
1. Slope in Coarse-Grained Soil with
Some Cohesion
Low Groundwater
Failure of thin
wedge, position
influenced by
tension cracks
High Groundwater
Failure at relatively
shallow toe circles
With low groundwater, failure occurs on
shallow, straight, or slightly curved surface.
Presence of a tension crack at the top of the
slope influences failure location. With high
groundwater, failure occurs on the relatively
shallow toe circle whose position is determined
primarily by ground elevation.
Analyze with effective stress using strengths C'
and 0' from CD tests. Pore pressure is
governed by seepage condition. Internal pore
pressures and external water pressures must be
included.
2. Slope in Coarse-Grained,
Soil Cohesion
Low Groundwater
Stable slope angle
= effective friction
angle
High Groundwater
Stable slope angle
= !/2 effective
friction angle
Stability depends primarily on groundwater
conditions. With low groundwater, failures
occur as surface sloughing until slope angle
flattens to friction angle. With high
groundwater, stable slope is approximately 1/2
friction angle.
Analyze with effective stress using strengths C'
and 0' from CD tests. Slight cohesion
appearing in test envelope is ignored. Special
consideration must be given to possible flow
slides in loose, saturated fine sands.
3. Slope in Normally Consolidated or
Slightly Preconsolidated Clay
Location of failure depends on variation of
shear strength with depth.
Strength constant
«,ith depth
Strength constant
with depth
Failure occurs on circular arcs whose position
is governed by theory. Position of
groundwater table does not influence stability
unless its fluctuation changes strength of the
clay or acts in tension cracks.
Analyze with total stresses, zoning cross
section for different values of shear strengths.
Determine shear strength from unconfmed
compression test, unconsolidated undrained
triaxial test or vane shear.
Suff or Hard Stratum
Source: Soil Mechanics, NAVFAC Design Manual 7.01
Table 2-2. Analysis of Stability of Natural Slopes
51
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Subpart B
4. Slope in Stratified Soil Profile
Location of failure depends on relative
strength and orientation of layers.
Strata oflow
strength
Location of failure plane is controlled by
relative strength and orientation of strata.
Failure surface is combination of active and
passive wedges with central sliding block
chosen to conform to stratification.
Analyze with effective stress using strengths C'
and 0' for fine-grained strata and 0' for
cohesionless material.
5. Depth Creep Movements in
Old Slide Mass
Bowl-shaped area of low slope (9 to 11%)
bounded at top by old scarp.
Strength of old slide mass decreases with
magnitude of movement that has occurred
previously. Most dangerous situation is in
stiff, over-consolidated clay which is softened,
fractured, or slickensided in the failure zone.
Failure surface of
low curvature which
is a portion of an
shear surface
Source: Soil Mechanics, NAVFAC Design Manual 7.01
Table 2-2. Analysis of Stability of Natural Slopes (Continued)
52
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Location Criteria
1. Failure of Fill on Soft Cohesive
Foundation with Sand Drains
Location of failure depends on geometry and
strength of cross section.
Usually, minimum stability occurs during
placing of fill. If rate of construction is
controlled, allow for gain in strength with
consolidation from drainage.
Analyze with effective stress using strengths C'
and 0' from CU tests with pore pressure
measurement. Apply estimated pore pressures
or piezometric pressures. Analyze with total
stress for rapid construction without
observation of pore pressures, use shear
strength from unconfmed compression or
unconsolidated undrained triaxial.
2. Failure of Stiff Compacted Fill on
Soft Cohesive Foundation
Failure surface may be rotation on circular arc or
translation with active and passive wedges.
Usually, minimum stability obtained at end of
construction. Failure may be in the form of rotation
or
translation, and both should be considered.
For rapid construction ignore consolidation
from drainage and utilize shear strengths
determined from U or UU tests or vane shear
in total stress analysis. If failure strain of fill
and foundation materials differ greatly, safety
factor should exceed one, ignoring shear
strength of fill. Analyze long-term stability
using C and 0 from CU tests with effective
stress analysis, applying pore pressures of
3. Failure Following Cut in Stiff
Fissured Clay
Original
ground line
Release of horizontal stresses by excavation
causes expansion of clay and opening of
fissures, resulting in loss of cohesive strength.
Analyze for short-term stability using C' and 0'
with total stress analysis. Analyze for long-
term stability with C'r and 0'm based on
residual strength measured in consolidated
drained tests.
Cut at toe
Failure surface depends on pattern of
fissures or depth of softening.
Source: Soil Mechanics, NAVFAC Design Manual 7.01
Table 2-3. Analysis of Stability of Cut and Fill Slopes,
Conditions Varying With Time
53
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Subpart B
Subsurface Exploration Programs
Foundation soil stability assessments for non-
catastrophic failure require field investigations
to determine soil strengths and other soil
properties. In situ field vane shear tests
commonly are conducted in addition to
collection of piston samples for laboratory
testing of undrained shear strengths (biaxial
and triaxial). Field vanes taken at depth
provide a profile of soil strength. The
required field vane depth intervals vary, based
on soil strength and type, and the number of
borings required depends on the variability of
the soils, the site size, and landfill unit
dimensions. Borings and field vane testing
should consider the anticipated design to
identify segments of the facility where critical
cross sections are likely to occur. Critical
sections are where factors of safety are
anticipated to be lowest.
Other tests that are conducted to characterize
a soil include determination of water content,
Atterberg limits, grain size distribution,
consolidation, effective porosity, and
saturated hydraulic conductivity. The site
hydrogeologic conditions should be assessed
to determine if soils are saturated or
unsaturated.
Catastrophic failures, such as sinkhole
collapse in karst terrains or fault displacement
during an earthquake, are more difficult to
predict. Subsurface karst structures may have
surface topographic expressions such as
circular depressions over subsiding solution
caverns. Subsurface borings or geophysical
techniques may provide reliable means of
identifying the occurrence, depth, and size of
solution cavities that have the potential for
catastrophic collapse.
Methods of Slope Stability Analysis
Slope stability analyses are performed for
both excavated side slopes and aboveground
embankments. The analyses are performed as
appropriate to verify the structural integrity of
a cut slope or dike. The design configuration
is evaluated for its stability under all potential
hydraulic and loading conditions, including
conditions that may exist during construction
of an expansion (e.g., excavation). Analyses
typically performed are slope stability,
settlement, and liquefaction. Factor of safety
rationale and selection for different conditions
are described by Huang (1983) and Terzaghi
and Peck (1967). Table 2-4 lists
recommended minimum factor of safety
values for slopes. Many States may provide
their own minimum factor of safety
requirements.
There are numerous methods currently
available for performing slope stability
analyses. Method selection should be based
on the soil properties and the anticipated
mode of failure. Rationale for selecting a
specific method should be provided.
The majority of these methods may be
categorized as "limit equilibrium" methods
in which driving and resisting forces are
determined and compared. The basic
assumption of the limit equilibrium
approach is that the failure criterion is
satisfied along an assumed failure surface.
This surface may be a straight line, circular
arc, logarithmic spiral, or other irregular
plane. A free body diagram of the driving
forces acting on the slope is constructed
using assumed or known values of the
forces. Next, the soil's shear resistance as it
pertains to establishing equilibrium is
calculated. This calculated shear resistance
54
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Location Criteria
Table 2-4
Recommended Minimum Values of Factor of Safety
for Slope Stability Analyses
Uncertainty of Strength Measurements
Consequences of Slope Failure Small, Large,
No imminent danger to human life or 1.25 1.5
major environmental impact if slope (1.2)* (1.3)
fails
Imminent danger to human life or 1.5 2.0 or greater
major environmental impact if slope (1.3) (1.7 or greater)
fails
1 The uncertainty of the strength measurements is smallest when the soil
conditions are uniform and high quality strength test data provide a consistent,
complete, and logical picture of the strength characteristics.
2 The uncertainty of the strength measurements is greatest when the soil
conditions are complex and when available strength data do not provide a
consistent, complete, and logical picture of the strength characteristics.
* Numbers without parentheses apply for static conditions and those within
parentheses apply to seismic conditions.
Source: EPA Guide to Technical Resources for the Design of Land Disposal
Facilities.
55
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Subpart B
then is compared to the estimated or available
shear strength of the soil to give an indication
of the factor of safety (Winterkorn and Fang,
1975).
Methods that consider only the whole free
body as a single unit include the Culmann
method and the friction circle method.
Another approach is to divide the free body
into vertical slices and to consider the
equilibrium of each slice. Several versions of
the slice method are available; the best known
are the Swedish Circle method and the Bishop
method. Discussions of these and other
methods may be found in Winterkorn and
Fang (1975), Lambe and Whitman (1969),
and U.S. Navy (1986).
A computer program that is widely used for
slope stability analysis is PC STABL, a two-
dimensional model that computes the
minimum critical factors of safety between
layer interfaces. This model uses the method
of vertical slices to analyze the slope and
calculate the factor of safety. PC STABL can
account for heterogeneous soil systems,
anisotropic soil strength properties, excess
pore water pressure due to shear, static ground
water and surface water, pseudostatic
earthquake loading, surcharge boundary
loading, and tieback loading. The program is
written in FORTRAN IV and can be run on a
PC. Figure 2-7 presents a typical output from
the model.
Design for Slope Stabilization
Methods for slope stabilization are presented
in Table 2-5 and are summarized below.
• The first illustration shows that stability
can be increased by changing the slope
geometry through reduction of the slope
height, flattening the slope angle, or
excavating a bench in the upper part of
the slope.
The second illustration shows how
compacted earth or rock fill can be
placed in the form of a berm at and
beyond the slope's toe to buttress the
slope. To prevent the development of
undesirable water pressure behind the
berm, a drainage system may be placed
behind the berm at the base of the slope.
The third illustration presents several
types of retaining structures. These
structures generally involve drilling
and/or excavation followed by
constructing cast-in-place concrete piles
and/or slabs.
— The T-shaped cantilever wall
design enables some of the
retained soil to contribute to the
stability of the structure and is
advisable for use on slopes that
have vertical cuts.
— Closely-spaced vertical piles
placed along the top of the slope
area provide reinforcement
against slope failure through a
soil arching effect that is created
between the piles. This type of
retaining system is advisable for
use on steeply cut slopes.
— Vertical piles also may be
designed with a tie back
component at an angle to the
vertical to develop a high
resistance to lateral forces. This
type of wall is recommended for
use in areas
56
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Location Criteria
Figure 2-7
Sample Output from PC STABL Model
CD Subgrade: Internal friction angle = 32 degrees
© Refuse: Internal friction angle of waste = 25 degrees
® Refuse: Internal friction angle of waste = 25 degrees
Sliding Block/Wedge
Failure Surface
Factor of Safety = 1.374
Circular Failure Surface,
Factor of Safety = 1.723
57
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Scheme
Applicable Methods
Comments
1. Changing Geometry
Excavation
1. Reduce slope height by
excavation at top of slope
2. Flatten the slope angle.
3. Excavate a bench in
upper part of slope.
Area has to be accessible
to construction
equipment. Disposal site
needed for excavated soil.
Drainage sometimes
incorporated in this
method.
2. Earth Berm Fill
Compacted earth or rock
berm placed at end
beyond the toe. Drainage
may be provided behind
the berm.
Sufficient width and
thickness of berm
required so failure will
not occur below or
through the berm.
3. Retaining Structures
Retaining
S true cure
Retaining wall: crib or
cantilever type.
Drilled, cast-in-place
vertical piles and/or slabs
founded well below
bottom slide plane.
Generally 18 to 36 inches
in diameter and 4- to 8-
foot spacing. Larger
diameter piles at closer
spacing may be required
in some cases with
mitigate failures of cuts
in highly fissured clays.
1. Usually expensive.
Cantilever walls might
have to be tied back.
2. Spacing should be such
that soil can arch between
piles. Grade beam can be
used to tie piles together.
Very large diameter (6
feett) piles have been
used for deep slide.
Source: Soil Mechanics, NAVFAC Design Manual 7.01
Table 2-5
Methods of Stabilizing Excavation Slopes
-------
Scheme
Applicable Methods
Comments
3.
Retainine Structure'
4.
Retainine Structure
Retaining
Structure
1
Drilled, cast-in-place
vertical piles tied back
with battered piles or a
deadman. Piles founded
well below slide plane.
Generally, 12 to 30
inches in diameter and at
least 4- to 8-foot spacing.
Earth and rock anchors
and rock bolts.
Reinforced earth.
3. Space close enough so
soil will arch between
piles. Piles can be tied
together with grade beam.
4. Can be used for high
slopes, and in very
restricted areas.
Conservative design
should be used, especially
for permanent support.
Use may be essential for
slopes in rocks where
joints dip toward
excavation, and such
joints daylight in the
slope.
5. Usually expensive
4. Other methods
See TABLE 7, NAVFAC DM-
7.2, Chapter 1
Source: Soil Mechanics, NAVFAC Design Manual 7.01
Table 2-5 (continued)
Methods of Stabilizing Excavation Slopes
-------
Subpart B
with steeply cut slopes where soil
arching can be developed between the
piles.
— The last retaining wall shown
uses a cantilever setup along
with soil that has been
reinforced with geosynthetic
material to provide a system that
is highly resistant to vertical and
lateral motion. This type of
system is best suited for use in
situations where vertically cut
slopes must have lateral
movement strictly controlled.
Other potential procedures for stabilizing
natural and human-made slopes include the
use of geotextiles and geogrids to provide
additional strength, the installation of wick
and toe drains to relieve excess pore
pressures, grouting, and vacuum and
wellpoint pumping to lower ground-water
levels. In addition, surface drainage may be
controlled to decrease infiltration, thereby
reducing the potential for mud and debris
slides in some areas. Lowering the ground-
water table also may have stabilizing
effects. Walls or large-diameter piling can
be used to stabilize slides of relatively small
dimension or to retain steep toe slopes so
that failure will not extend back into a larger
mass (U.S. Navy, 1986). For more detailed
information regarding slope stabilization
design, refer to Winterkorn and Fang
(1975), U.S. Navy (1986), and Sowers
(1979). Richardson and Koerner (1987) and
Koerner (1986) provide design guidance for
geosynthetics in both landfill and general
applications.
Monitoring
During construction activities, it may be
appropriate to monitor slope stability
because of the additional stresses placed on
natural and engineered soil systems (e.g.,
slopes, foundations, dikes) as a result of
excavation and filling activities. Post-
closure slope monitoring usually is not
necessary.
Important monitoring parameters may
include settlement, lateral movement, and
pore water pressure. Monitoring for pore
water pressure is usually accomplished with
piezometers screened in the sensitive strata.
Lateral movements of structures may be
detected on the surface by surveying
horizontal and vertical movements.
Subsurface movements may be detected by
use of slope inclinometers. Settlement may
be monitored by surveying ground surface
elevations (on several occasions over a
period of time) and comparing them with
areas that are not likely to experience
changes in elevations (e.g., USGS survey
monuments).
Engineering Considerations for Karst
Terrains
The principal concern with karst terrains is
progressive and/or catastrophic failure of
subsurface conditions due to the presence of
sinkholes, solution cavities, and
subterranean caverns. The unpredictable
and catastrophic nature of subsidence in
these areas makes them difficult to develop
as landfill sites. Before situating a MSWLF
in a karst region, the subject site should be
characterized thoroughly.
60
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Location Criteria
The first stage of demonstration is to
characterize the subsurface. Subsurface
drilling, sinkhole monitoring, and geophysical
testing are direct means that can be used to
characterize a site. Geophysical techniques
include tests using electromagnetic
conductivity, seismic refraction, ground-
penetrating radar, gravity, and electrical
resistivity. Interpretation and applicability of
different geophysical techniques should be
reviewed by a qualified geophysicist. Often
more than one technique should be employed
to confirm and correlate findings and
anomalies. Subsurface drilling is
recommended highly for verifying the results
of geophysical investigations.
Additional information on karst conditions
can come from remote sensing techniques,
such as aerial photograph interpretation.
Surface mapping of karst features can help to
provide an understanding of structural
patterns and relationships in karst terrains.
An understanding of local carbonate geology
and stratigraphy can aid in the interpretation
of both remote sensing and geophysical
techniques.
A demonstration that engineering measures
have been incorporated into a unit located in
a karst terrain may include both initial
design and site modifications. A relatively
simple engineering modification that can be
used to mitigate karst terrain problems is
ground-water and surface water control and
conveyance. Such water control measures are
used to minimize the rate of dissolution within
known near-surface limestone. This means
of controlling karst development may not be
applicable to all karst situations. In areas
where development of karst topography
tends to be minor, loose soils overlying the
limestone may be excavated or
heavily compacted to achieve the needed
stability. Similarly, in areas where the karst
voids are relatively small and limited in
extent, infilling of the void with slurry
cement grout or other material may be an
option.
In general, due to the unpredictable and
catastrophic nature of ground failure in such
areas, engineering solutions that try to
compensate for the weak geologic structures
by constructing manmade ground supports
tend to be complex and costly. For example,
reinforced raft (or mat) foundations could be
used to compensate for lack of ground
strength in some karst areas. Raft foundations
are a type of "floating foundation" that consist
of a concrete footing that extends over a very
large area. Such foundations are used where
soils have a low bearing capacity or where
soil conditions are variable and erratic; these
foundations are able to reduce and distribute
loads. However, it should be noted that, in
some instances, raft foundations may not
necessarily be able to prevent the extreme
type of collapse and settlement that can occur
in karst areas. In addition, the construction of
raft foundations can be very costly, depending
on the size of the area.
2.8 CLOSURE OF EXISTING
MUNICIPAL SOLID WASTE
LANDFILL UNITS
40 CFR §258.16
2.8.1 Statement of Regulation
(a) Existing MSWLF units that
cannot make the demonstration specified
in §§258.10(a), pertaining to airports,
258.11(a), pertaining to floodplains, and
258.15(a), pertaining to unstable areas,
61
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Subpart B
must close by October 9, 1996, in
accordance with §258.60 of this part and
conduct post-closure activities in
accordance with §258.61 of this part.
(b) The deadline for closure required
by paragraph (a) of this section may be
extended up to two years if the owner or
operator demonstrates to the Director of an
approved State that:
(1) There is no available alternative
disposal capacity;
(2) There is no immediate threat to
human health and the environment.
2.8.2 Applicability
These requirements are applicable to all
MSWLF units that receive waste after
October 9, 1993 and cannot meet the airport
safety, floodplain, or unstable area
requirements. The owner or operator is
required to demonstrate that the facility: (1)
will not pose a bird hazard to aircraft under
§258.10(a); (2) is designed to prevent washout
of solid waste, will not restrict floodplain
storage capacity, or increase floodwater flow
in a 100-year floodplain under §258.11 (a);
and 3) can withstand damage to landfill
structural component systems (e.g., liners,
leachate collection, and other engineered
structures) as a result of unstable conditions
under §258.15(a). If any of these
demonstrations cannot be made, the landfill
must close by October 9, 1996. In approved
States, the closure deadline may be extended
up to two additional years if it can be shown
that alternative disposal capacity is not
available and that the MSWLF unit does not
pose an immediate threat to human health and
the environment.
2.8.3 Technical Considerations
The engineering considerations that should be
addressed for airport safety, 100-year
floodplain encroachment, and unstable areas
are discussed in Sections 2.2, 2.3, and 2.7 of
this chapter. Information and evaluations
necessary for these demonstrations also are
presented in these sections. If applicable
demonstrations are not made by the owners or
operators, the landfill unit(s) must be closed
according to the requirements of section
§258.60 by October 9, 1996.
For MSWLF units located in approved States,
this deadline may be extended if there is no
immediate threat to human health and the
environment and no waste disposal alternative
is available. The demonstration of no
disposal alternative should consider all waste
management facilities, including landfills,
municipal waste combustors, and recycling
facilities. The demonstration for the two-year
extension should consider the impacts on
human health and the environment as they
relate to airport safety, 100-year floodplains,
or unstable areas.
§§258.17-258.19 [Reserved].
62
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Location Criteria
2.9 FURTHER INFORMATION
2.9.1 References
General
Linsley and Franzini, (1972). "Water Resources Engineering"; McGraw-Hill; pp. 179-184.
U.S. EPA, (1988). "Guide to Technical Resources for the Design of Land Disposal Facilities";
EPA/625/6-88/018; USEPA; Risk Reduction Engineering Laboratory and Center for
Environmental Research Information; Office of Research and Development; Cincinnati,
Ohio 45268.
USGS. Books and Open File Section, Branch Distribution, Box 25046, Federal Center, Denver,
CO 80225.
Floodplains
COE, (1982). HEC-1, HEC-2, HEC-5, HEC-6 Computer Programs; Hydrologic Engineering
Center (HEC); U.S. Army Corps of Engineers; Hydrologic Engineering Center; Davis
California.
Federal Emergency Management Agency, (1980). "How to Read a Flood Insurance Rate Map";
April 1980. Available from FEMA Regional Offices.
Maynard, S.T., (1978). "Practical Riprap Design"; Hydraulics Laboratory Miscellaneous Paper
H-78-7; U.S. Army Engineers Waterways Experiment Station; Vicksburg, Mississippi. SCS,
(1983).
"Maryland Standards and Specifications for Soil Erosion and Sediment Control"; U.S. Soil
Conservation Service; College Park, Maryland.
U.S. Water Resources Council, (1977). "Guidelines for Determining Flood Flow Frequency";
Bulletin #17A of the Hydrology Committee; revised June 1977.
Wetlands
COE, (1987). "Corps of Engineers Wetlands Delineation Manual," Technical Report (Y-87-1),
Waterways Experiment Station, Jan. 1987.
63
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Subpart B
COE, (1989). "Federal Manual for Identifying and Delineating Jurisdictional Wetlands,"
Federal Interagency Committee for Wetland Delineation; U.S. Army Corps of Engineers,
U.S. Environmental Protection Agency, U.S. Fish and Wildlife Service, and U.S.D.A.,
Soil Conservation Service; Washington, D.C., Cooperative Technical Publication. 1989.
Fault Areas, (1992). "Aspects of Landfill Design for Stability in Seismic Zones," Hilary I.
Inyang, Ph.D.
Seismic Impact Zones
Algermissen, S.T., et al., (1991). "Probabilistic Earthquake Acceleration and Velocity Maps
for the United States and Puerto Rico," USGS Miscellaneous Field Study Map MF-
2120.
Algermissen, S.T., et al., (1976). "Probabilistic Estimates of Maximum Acceleration and
Velocity in Rock in the Contiguous United States"; Open File Report 82-1033; U.S.
Geological Survey; Washington, D.C.
U.S. EPA, (1992). "Aspects of Landfill Design for Stability in Seismic Zones", Hilary I.
Inyang. Ph.D.
U.S. Navy, (1983). "Design Manual-Soil Dynamics, Deep Stabilization, and Special
Geotechnical Construction," NAVFAC DM-7.3; Department of the Navy; Washington,
D.C.; April, 1983.
Winterkorn, H.F. and Fang, H.Y., (1975). "Foundation Engineering Handbook." Van
Nostrand Reinhold. 1975.
Unstable Areas
Geoslope Programming Ltd., (1986). PC-SLOPE, Version 2.0 (May); Calgary, Alberta,
Canada.
Huang, U.K., (1983). "Stability Analysis of Earth Slopes"; Van Nostrand Reinhold Co.; New
York.
Koerner, R.M., (1986). "Designing with Geosynthetics"; Prentice-Hall Publishing Co.;
Englewood Cliffs, New Jersey.
Lambe, W.T. and R.V. Whitman, (1969). "Soil Mechanics"; John Wiley and Sons, Inc.; New
York.
64
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Location Criteria
Richardson, G.N. and R.M. Koerner, (1987). "Geosynthetic Design Guidance for Hazardous
Waste Landfill Cells and Surface Impoundments"; Hazardous Waste Engineering Research
Laboratory; USEPA, Office of Research and Development; Cincinnati, Ohio; Contract No.
68-07-3338.
Sowers, G.F., (1979). "Soil Mechanics and Foundations: Geotechnical Engineering," The
MacMillan Company, New York.
Terzaghi, K. and R.B. Peck, (1967). "Soil Mechanics in Engineering Practice", 2nd Edition; John
Wiley and Sons, Inc.; New York.
U.S. Navy, (1986). "Design Manual-Soil Mechanics, Foundations and Earth Structures,"
NAVFAC DM-7; Department of the Navy; Washington, D.C.; September 1986.
Winterhorn, H.F. and Fang, H.Y., (1975). "Foundation Engineering Handbook," Van Nostrand
Reinhold, 1975.
2.9.2 Organizations
American Institute of Architects
Washington, D.C.
(202) 626-7300
Aviation Safety Institute (ASI)
Box 304
Worthington, OH 43085
(614) 885-4242
American Society of Civil Engineers
345 East 47th St.
New York, NY 10017-2398
(212) 705-7496
Building Seismic Safety Council
201 L Street, Northwest Suite 400
Washington, D.C. 20005
(202) 289-7800
Bureau of Land Management
1849C St. N.W.
Washington, D.C. 20240
(202) 343-7220 (Locator)
(202) 343-5717 (Information)
65
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Subpart B
Federal Emergency Management Agency
Flood Map Distribution Center
6930 (A-F) San Thomas Road
Baltimore, Maryland 21227-6227
1-800-358-9616
Federal Emergency Management Agency
(800) 638-6620 Continental U.S. only, except Maryland
(800) 492-6605 Maryland only
(800) 638-6831 Continental U.S., Hawaii, Alaska, Puerto Rico, Guam, and the Virgin Islands
Note: The toll free numbers may be used to obtain any of the numerous FEMA publications such
as "The National Flood Insurance Program Community Status Book," which is published
bimonthly.
To obtain Flood Insurance Rate Maps and other flood maps, the FEMA Flood Map
Distribution Center should be contacted at 1-800-358-9616.
Federal Highway Administration
400 7th St. S.W.
Washington, D.C. 20590
(202) 366-4000 (Locator)
(202) 366-0660 (Information)
Hydrologic Engineering Center (HEC Models)
U.S. Army Corps of Engineers
609 Second St.
Davis, CA 95616
(916)756-1104
National Information Service for Earthquake Engineering (NISEE)
University of California, Berkeley
404A Davis Hall
Berkeley, CA 94720
(415)642-5113
(415) 643-5246 (FAX)
National Oceanic and Atmospheric Administration
Office of Legislative Affairs
1825 Connecticut Avenue Northwest
Room 627
Washington, DC 20235
(202) 208-5717
66
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Location Criteria
Tennessee Valley Authority
412 First Street Southeast, 3rd Floor
Washington, DC 20444
(202) 479-4412
U.S. Department of Agriculture
Soil Conservation Service
P.O. Box 2890
Washington, DC 20013-2890
(Physical Location: 14th and Independence Ave. N.W.)
(202)447-5157
U.S. Department of the Army
U.S. Army Corps of Engineers
Washington, DC 20314-1000
(202) 272-0660
U.S. Department of the Interior
Fish and Wildlife Service
1849 C Street Northwest
Washington, DC 20240
(202) 208-5634
U.S. Department of Transportation
Federal Aviation Administration
800 Independence Ave., S.W.
Washington, D.C. 20591
(202) 267-3085
U.S. Geological Survey
12201 Sunrise Valley Drive
Reston, Virginia 22092
(800) USA-MAPS
U.S. Geological Survey
Branch of Geologic Risk Assessment
Stop 966 Box 25046
Denver, Colorado 80225
(303) 236-1629
U.S. Geological Survey
EROS Data Center
Sioux Falls, South Dakota 57198
(605)594-6151
67
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Subpart B
U.S. Geological Survey
National Earthquake Information Center
Stop 967 Box 25046
Denver Federal Center
Denver, Colorado 80225
(303)236-1500
2.9.3 Models
Adamus, P.R., et al., (1987). "Wetland Evaluation Technique (WET); Volume II:
Methodology"; Operational Draft Technical Report Y-87; U.S. Army Engineer Waterways
Experiment Station; Vicksburg, MS.
COE, (1982). HEC-1, HEC-2, HEC-5, HEC-6 Computer Programs; Hydrologic Engineering
Center (HEC); U.S. Army Corps of Engineers; Hydrologic Engineering Center; Davis
California.
Geoslope Programming Ltd., (1986). PC-SLOPE, Version 2.0 (May); Calgary, Alberta, Canada.
Lysemer, John, et al., (1979). "FLUSH: A Computer Program for Approximate 3-D Analysis";
University of California at Berkeley; March 1979. (May be obtained through the National
Information Service for Earthquake Engineering at the address provided in subsection 2.9.2
of this document.)
Purdue University, Civil Engineering Dept, (1988). PC STABL, West Lafayette, IN 47907.
United States Fish and Wildlife Service, (1980). "Habitat Evaluation Procedures". ESM 102;
U.S. Fish and Wildlife Service; Division of Ecological Services; Washington, D.C.
68
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APPENDIX I
FAA Order 5200.5A
69
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U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL AVIATION ADMINISTRATION
5200.5A
1/31/90
SUBJ: WASTE DISPOSAL SITES ON OR NEAR AIRPORTS
1. PURPOSE. This order provides guidance concerning the establishment, elimination or monitoring of landfills, open dumps, waste disposal
sites or similarly titled facilities on or in the vicinity of airports.
2. DISTRIBUTION. This order is distributed to the division level in the Offices of Airport Planning and Programming Airport Safety and
Standards, Air Traffic Evaluations and Analysis Aviation Safety Oversight, Air Traffic Operations Service, and Flight Standards Service; to the
division level in the regional Airports, Air Traffic, and Flight Standards Divisions; to the director level at the Aeronautical Center and the FAA
Technical Center, and a limited distribution to all Airport District Offices, Flight Standards Field Offices, and Air Traffic Facilities.
3. CANCELLATION. Order 5200.5, FAA Guidance Concerning Sanitary Landfills On Or Near Airports, dated October 16, 1974, is canceled.
4. BACKGROUND. Landfills, garbage dumps, sewer or fish waste outfalls and other similarly licensed or titled facilities used for operations
to process, bury, store or otherwise dispose of waste, trash and refuse will attract rodents and birds. Where the dump is ignited and produces smoke,
an additional attractant is created. All of the above are undesirable and potential hazards to aviation since they erode the safety of the airport
environment. The FM neither approves nor disapproves locations of the facilities above. Such action is the responsibility of the Environmental
Protection Agency and/or the appropriate state and local agencies. The role of the FAA is to ensure that airport owners and operators meet their
contractual obligations to the United States government regarding compatible land uses in the vicinity of the airport. While the chance of an
unforeseeable, random bird strike in flight will always exist, it is nevertheless possible to define conditions within fairly narrow limits where the risk
is increased. Those high-risk conditions exist in the approach and departure patterns and landing areas on and in the vicinity of airports. The number
of bird strikes reported on aircraft is a matter of continuing concern to the FM and to airport management. Various observations support the conclusion
that waste disposal sites are artificial attractants to birds. Accordingly, disposal sites located in the vicinity of an airport are potentially incompatible
with safe flight operations. Those sites that are not compatible need to be eliminated. Airport owners need guidance in making those decisions and
the FM must be in a position to assist. Some airports are not under the jurisdiction of the community or local governing body having control of land
usage in the vicinity of the airport. In these areas, the airport owner should use its resources and exert its best efforts to close or control waste disposal
operations within the general vicinity of the airport.
5. EXPLANATION OF CHANGES. The following list outlines the major changes to Order 5200.5:
a. Recent developments and new techniques of waste disposal warranted updating and clarification of what constitutes a sanitary landfill.
This listing of new titles for waste disposal was outlined in paragraph 4.
b. Due to a reorganization which placed the Animal Damage Control Branch of the U. S. Department of Interior Fish and Wildlife Service
under the jurisdiction of the U.S. Department of Agriculture an address addition was necessary
c. A zone of notification was added to the criteria which should provide the appropriate FM Airports office an opportunity to comment
on the proposed disposal site during the selection process.
6. ACTION.
a. Waste disposal sites located or proposed to be located within the areas established for an airport by the guidelines set forth in paragraphs 7 a
b, and c of this order should not be allowed to operate. If a waste disposal site is incompatible with an airport in accordance with guidelines of
paragraph 7 and cannot be closed within a reasonable time, it should be operated in accordance with the criteria and instructions issued by Federal
agencies such as the Environmental Protection Agency and the Department of Health and Human Services, and other such regulatory bodies that may
have applicable requirements. The appropriate FM airports office should advise airport owners, operators and waste disposal proponents against
locating, permitting or concurring in the location of a landfill or similar facility on or in the vicinity of airports.
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(1) Additionally, any operator proposing a new or expanded waste disposal site within 5 miles of a runway end should notify the airport
and the appropriate FM Airports office so as to provide an opportunity to review and comment on the site in accordance with the guidance contained
in this order. FM field offices may wish to contact the appropriate State director of the United States Department of Agriculture to assist in this review.
Also, any Air Traffic control tower manager or Flight Standards District Office manager and their staffs that become aware of a proposal to develop
or expand a disposal site should notify the appropriate FM Airports office.
b. The operation of a disposal site located beyond the areas described in paragraph 7 must be properly supervised to ensure compatibility
with the airport.
c. If at any time the disposal site, by virtue of its location or operation, presents a potential hazard to aircraft operations the owner should
take action to correct the situation or terminate operation of the facility. If the owner of the airport also owns or controls the disposal facility and is
subject to Federal obligations to protect compatibility of land uses around the airport, failure to take corrective action could place the airport owner
in noncompliance with its commitments to the Federal government. The appropriate FM office should immediately evaluate the situation to determine
compliance with federal agreements and take such action as may be warranted under the guidelines as prescribed in Order 5190.6, Airports
Compliance Requirements, current edition.
(1) Airport owners should be encouraged to make periodic inspections of current operations of existing disposal sites near a federally
obligated airport where potential bird hazard problems have been reported.
d. This order is not intended to resolve all related problems but is specifically directed toward eliminating waste disposal sites, landfills
and similarly titled facilities in the proximity of airports, thus providing a safer environment for aircraft operations.
e. At airports certified under Federal Aviation Regulations, part 139, the airport certification manual/specifications should require disposal
site inspections at appropriate intervals for those operations meeting the criteria of paragraph 7 that cannot be closed. These inspections are necessary
to assure that bird populations are not increasing and that appropriate control procedures are being established and followed. The appropriate FAA
airport offices should develop working relationships with state aviation agencies and state agencies that have authority over waste disposal and
landfills to stay abreast of proposed developments and expansions and apprise them of the hazards to aviation that these present.
f. When proposing a disposal site, operators should make their plans available to the appropriate state regulatory agencies. Many states
have criteria concerning siting requirements specific to their jurisdictions.
g. Additional information on waste disposal, bird hazard and related problems may be obtained from the following agencies:
U.S. Department of Interior Fish and Wildlife Service
18th and C Streets, NW
Washington, DC 20240
U.S. Department of Agriculture
Animal Plant Health Inspection Service
P.O. Box 96464
Animal Damage Control Program
Room 1624 South Agriculture Building
Washington, DC 20090-6464
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
7. CRITERIA. Disposal sites will be considered as incompatible if located within areas established for the airport through the application
of the following criteria:
a. Waste disposal sites located within 10,000 feet of any runway end used or planned to be used by turbine powered aircraft
b. Waste disposal sites located within 5,000 feet of any runway end used only by piston powered aircraft.
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c. Any waste disposal site located within a 5-mile radius of a runway end that attracts or sustains hazardous bird movements from feeding,
water or roosting areas into, or across the runway and/or approach and departure patterns of aircraft.
Leonard E. Mudd
Director, Office of Airport Safety and Standards
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CHAPTER 3
SUSPART C
OPERATING CRITERIA
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CHAPTER 3
SUBPART C
TABLE OF CONTENTS
3.1 INTRODUCTION 76
32 PROCEDURES FOR EXCLUDING THE RECEIPT OF HAZARDOUS WASTE 40 CFR
§258.20 77
3.2.1 Statement of Regulation 77
3.2.2 Applicability 77
3.2.3 Technical Considerations 77
Inspections 78
Alternative Methods for Detection and Prevention 81
Recordkeeping 82
Training 82
Notification to Authorities and Proper Management of Wastes 82
33. COVER MATERIAL REQUIREMENTS 40 CFR §258.21 84
3.3.1 Statement of Regulation 84
3.3.2 Applicability 84
3.3.3 Technical Considerations 84
3A DISEASE VECTOR CONTROL 40 CFR §258.22 86
3.4.1 Statement of Regulation 86
3.4.2 Applicability 86
3.4.3 Technical Considerations 87
3J EXPLOSIVE GASES CONTROL 40 CFR §258.23 87
3.5.1 Statement of Regulation 87
3.5.2 Applicability 88
3.5.3 Technical Considerations 89
Gas Monitoring 90
Landfill Gas Control Systems 94
Passive Systems 96
Active Systems 96
3_A AIR CRITERIA 40 CFR §258.24 101
3.6.1 Statement of Regulation 101
3.6.2 Applicability 101
3.6.3 Technical Considerations 101
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3.7 ACCESS REQUIREMENT 40 CFR §258.25 103
3.7.1 Statement of Regulation 103
3.7.2 Applicability 103
3.7.3 Technical Considerations 103
M RUN-ON/RUN-OFF CONTROL SYSTEMS 40 CFR §258.26 104
3.8.1 Statement of Regulation 104
3.8.2 Applicability 104
3.8.3 Technical Considerations 104
3_J) SURFACE WATER REQUIREMENTS 40 CFR §258.27 105
3.9.1 Statement of Regulation 105
3.9.2 Applicability 106
3.9.3 Technical Considerations 106
3.10 LIQUIDS RESTRICTIONS 40 CFR §258.28 107
3.10.1 Statement of Regulation 107
3.10.2 Applicability 107
3.10.3 Technical Considerations 108
3.11 RECORDKEEPING REQUIREMENTS 40 CFR §258.29 110
3.11.1 Statement of Regulation 110
3.11.2 Applicability 110
3.11.3 Technical Considerations Ill
3.12 FURTHER INFORMATION 114
3.12.1 References 114
3.12.2 Addresses 114
APPENDIX I - SPECIAL WASTE ACCEPTANCE AGREEMENT Following Page 114
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CHAPTER 3
SUBPART C
OPERATING CRITERIA
3.1 INTRODUCTION
The Solid Waste Disposal Facility Criteria contain a series of operating requirements pertaining to
routine operation, management, and environmental monitoring at municipal solid waste landfill
units (MSWLF units). The operating requirements pertain to new MSWLF units, existing MSWLF
units, and lateral expansions of existing MSWLF units.
The operating requirements have been developed to ensure the safe daily operation and management
at MSWLF units. The operating requirements include:
The exclusion of hazardous waste;
Cover material;
Disease vector control;
Explosive gases control;
Air monitoring;
Facility access;
Run-on/run-off control systems;
Surface water requirements;
Liquid restrictions; and
Recordkeeping requirements.
Any owner or operator of a MSWLF unit must comply with the operating requirements by October
9, 1993.
In specific cases, the operating requirements require compliance with other Federal laws. For
example, surface water discharges from a MSWLF unit into the waters of the United States must
be in conformance with applicable sections of the Clean Water Act. In addition, burning of
municipal solid waste (MSW) is regulated under applicable sections of the Clean Air Act.
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Operating Criteria
3.2 PROCEDURES FOR EXCLUDING
THE RECEIPT OF HAZARDOUS
WASTE 40 CFR §258.20
3.2.1 Statement of Regulation
(a) Owners or operators of all MSWLF
units must implement a program at the
facility for detecting and preventing the
disposal of regulated hazardous wastes as
defined in Part 261 of this title and
polychlorinated biphenyls (PCB) wastes as
defined in Part 761 of this title. This
program must include, at a minimum:
(1) Random inspections of incoming
loads unless the owner or operator takes
other steps to ensure that incoming loads
do not contain regulated hazardous wastes
or PCB wastes;
(2) Records of any inspections;
(3) Training of facility personnel to
recognize regulated hazardous waste and
PCB wastes; and
(4) Notification of State Director of
authorized States under Subtitle C of
RCRA or the EPA Regional Administrator
if in an unauthorized State if a regulated
hazardous waste or PCB waste is
discovered at the facility.
(b) For purposes of this section,
regulated hazardous waste means a solid
waste that is a hazardous waste, as defined
in 40 CFR 261.3, that is not excluded from
regulation as a hazardous waste under 40
CFR 261.4(b) or was not generated by a
conditionally exempt small quantity
generator as defined in §261.5 of this title.
3.2.2 Applicability
This regulation applies to all MSWLF units
that receive wastes on or after October 9,
1993.
The owner or operator must develop a
program to detect and prevent disposal of
regulated hazardous wastes or PCB wastes at
the MSWLF facility. Hazardous wastes may
be gases, liquids, solids, or sludges that are
listed or exhibit the characteristics described
in 40 CFR Part 261. Household hazardous
wastes are excluded from Subtitle C
regulation, and wastes generated by
conditionally exempt small quantity
generators (CESQGs) are not considered
regulated hazardous wastes for purposes of
complying with §258.20; therefore, these
wastes may be accepted for disposal at a
MSWLF unit.
The MSWLF hazardous waste exclusion
program should be capable of detecting and
preventing disposal of PCB wastes. PCB
wastes may be liquids or non-liquids (sludges
or solids) and are defined at 40 CFR Section
761.60. PCB wastes do not include small
capacitors found in fluorescent light ballast,
white goods (e.g., washers, dryers,
refrigerators) or other consumer electrical
products (e.g., radio and television units).
The hazardous waste exclusion program is not
intended to identify whether regulated
hazardous waste or PCB waste was received
at the MSWLF unit or facility prior to the
effective date of the Criteria.
3.2.3 Technical Considerations
A solid waste is a regulated hazardous waste
if it: (1) is listed in Subpart D of 40 CFR
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Subpart C
Part 261 (termed a "listed" waste); (2) exhibits
a characteristic of a hazardous waste as
defined in Subpart C of 40 CFR Part 261; or
(3) is a mixture of a listed hazardous waste
and a non-hazardous solid waste.
Characteristics of hazardous wastes as defined
in Subpart C of 40 CFR Part 261 include
ignitability, corrosivity, reactivity, and
toxicity. The toxicity characteristic leaching
procedure (TCLP) is the test method used to
determine the mobility of organic and
inorganic compounds present in liquid, solid,
and multiphase wastes. The TCLP is
presented in Appendix II of Part 261.
The MSWLF Criteria exclude CESQG waste
(as defined in 40 CFR §261.5) from the
definition of "regulated hazardous wastes."
CESQG waste includes listed hazardous
wastes or wastes that exhibit a characteristic
of a hazardous waste that are generated in
quantities no greater than 100 kg/month, or
for acute hazardous waste, 1 kg/month.
Under 40 CFR §261.5(f)(3)(iv) and (g)(3)(iv),
conditionally exempt small quantity generator
hazardous wastes may be disposed at facilities
permitted, licensed, or registered by a State to
manage municipal or industrial solid waste.
Other solid wastes are excluded from
regulation as a hazardous waste under 40
CFR §261.4(b) and may be accepted for
disposal at a MSWLF unit. Refer to
§261.4(b) for a listing of these wastes.
PCBs are regulated under the Toxic
Substances Control Act (TSCA), but PCB-
containing wastes are considered hazardous
wastes in some States. PCBs typically are not
found in consumer wastes except for
fluorescent ballast and small capacitors in
white goods and electrical appliances.
These sources are not regulated under 40 CFR
Part 761 and, therefore, are not part of the
detection program required by §258.20.
Commercial or industrial sources of PCB
wastes that should be addressed by the
program include:
• Mineral oil and dielectric fluids
containing PCBs;
• Contaminated soil, dredged material,
sewage sludge, rags, and other debris
from a release of PCBs;
• Transformers and other electrical
equipment containing dielectric fluids;
and
• Hydraulic machines.
The owner or operator is required to
implement a program to detect and exclude
regulated hazardous wastes and PCBs from
disposal in the landfill unit(s). This program
must include elements for:
• Random inspections of incoming loads or
other prevention methods;
• Maintenance of inspection records;
• Facility personnel training; and
• Notification to appropriate authorities if
hazardous wastes or PCB wastes are
detected.
Each of these program elements is discussed
separately on the following pages.
Inspections
An inspection is typically a visual observation
of the incoming waste loads by
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Operating Criteria
an individual who is trained to identify
regulated hazardous or PCB wastes that would
not be acceptable for disposal at the MSWLF
unit. An inspection is considered satisfactory
if the inspector knows the nature of all
materials received in the load and is able to
discern whether the materials are potentially
regulated hazardous wastes or PCB wastes.
Ideally, all loads should be screened;
however, it is generally not practical to
inspect in detail all incoming loads. Random
inspections, therefore, can be used to provide
a reasonable means to adequately control the
receipt of inappropriate wastes. Random
inspections are simply inspections made on
less than every load.
The frequency of random inspections may be
based on the type and quantity of wastes
received daily, and the accuracy and
confidence desired in conclusions drawn from
inspection observations. Because statistical
parameters are not provided in the regulation,
a reasoned, knowledge-based approach may
be taken. A random inspection program may
take many forms such as inspecting every
incoming load one day out of every month or
inspecting one or more loads from
transporters of wastes of unidentifiable nature
each day. If these inspections indicate that
unauthorized wastes are being brought to the
MSWLF site, then the random inspection
program should be modified to increase the
frequency of inspections.
Inspection frequency also can vary depending
on the nature of the waste. For example,
wastes received predominantly from
commercial or industrial sources may require
more frequent inspections than wastes
predominantly from households.
Inspection priority also can be given to
haulers with unknown service areas, to loads
brought to the facility in vehicles not typically
used for disposal of municipal solid waste,
and to loads transported by previous would-be
offenders. For wastes of unidentifiable nature
received from sources other than households
(e.g., industrial or commercial
establishments), the inspector should question
the transporter about the source/composition
of the materials.
Loads should be inspected prior to actual
disposal of the waste at the working face of
the landfill unit to provide the facility owner
or operator the opportunity to refuse or accept
the wastes. Inspections can be conducted on
a tipping floor of a transfer station before
transfer of the waste to the disposal facility.
Inspections also may occur at the tipping floor
located near the facility scale house, inside the
site entrance, or near, or adjacent to, the
working face of the landfill unit. An
inspection flow chart to identify, accept, or
refuse solid waste is provided as Figure 3-1.
Inspections of materials may be accomplished
by discharging the vehicle load in an area
designed to contain potentially hazardous
wastes that may arrive at the facility. The
waste should be carefully spread for
observation using a front end loader or other
piece of equipment. Personnel should be
trained to identify suspicious wastes. Some
indications of suspicious wastes are:
• Hazardous placards or marking;
Liquids;
Powders or dusts;
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Waste Inspected by
Personnel Trained to
Recognize Hazardous
Wastes Prior to Delivery at
Working Face
Waste is Identified as
Non-Hazardous
Waste is Not Readily
Identifiable
Waste is Identified as a
Hazardous Waste
Deliver to
Working Face
Isolate Wastes by
Moving to Temporary
Storage Area
Record
Inspection
Refuse Waste
Have Wastes Tested
Including Unidentified
Containerized Wastes
Record
Inspection
Waste Determined to
be Non-Hazardous
Waste Determined to
be Hazardous
Return to Working
Face and Dispose
Record Inspection
Manifest and
Transport Wastes to
a Facility Permitted
to Handle the
Hazardous Waste
(E.G., A Facility with
a RCRA Permit or
Interim Status)
Record Inspection
and Notify State
Director
Figure 3-1
Hazardous Waste Inspection Decision Tree
Inspection Prior to Working Face
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Operating Criteria
• Sludges;
• Bright or unusual colors;
• Drums or commercial size containers; or
• Chemical odors.
The owner or operator should develop
specific procedures to be followed when
suspicious wastes are discovered. The
procedure should include the following
points:
• Segregate the wastes;
• Question the driver;
• Review the manifest (if applicable);
• Contact possible source;
• Call the appropriate State or Federal
agencies;
• Use appropriate protective equipment;
• Contact laboratory support if required; and
• Notify a response agency if necessary.
Containers with contents that are not easily
identifiable, such as unmarked 55-gallon
drums, should be opened only by properly
trained personnel. Because these drums could
contain hazardous waste, they should be
refused whenever possible. Upon verifying
that the solid waste is acceptable, it may then
be transferred to the working face for
disposal.
Some facilities may consider it reasonable to
test unidentified waste, store it, and see that
it is disposed of properly. Most facilities
would not consider this reasonable.
Testing typically would include The Toxicity
Characteristic Leaching Procedure (TCLP)
and other tests for characteristics of hazardous
wastes including corrosivity, ignitability, and
reactivity. Wastes that are suspected of being
hazardous should be handled and stored as a
hazardous waste until a determination is
made.
If the wastes temporarily stored at the site are
determined to be hazardous, the owner or
operator is responsible for the management of
the waste. If the wastes are to be transported
from the facility, the waste must be: (1) stored
at the MSWLF facility in accordance with
requirements of a hazardous waste generator,
(2) manifested, (3) transported by a licensed
transporter, and (4) sent to a permitted
Treatment, Storage, or Disposal (TSD)
facility for disposal. These requirements are
discussed further in this section.
Alternative Methods for Detection and
Prevention
While the regulations explicitly refer to
inspections as an acceptable means of
detecting regulated hazardous wastes and PCB
wastes, preventing the disposal of these
wastes may be accomplished through other
methods. These methods may include
receiving only household wastes and
processed (shredded or baled) wastes that are
screened for the presence of the excluded
wastes prior to processing. A pre-acceptance
agreement between the owner or operator and
the waste hauler is another alternative method.
An example of a pre-acceptance agreement is
presented as Appendix I. The owner or
operator should
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Subpart C
keep any such agreements concerning these
alternatives in the operating record.
Recordkeeping
A record should be kept of each inspection
that is performed. These records should be
included and maintained in the facility
operating record. Larger facilities that take
large amounts of industrial and commercial
wastes may use more detailed procedures than
smaller facilities that accept household
wastes. Inspection records may include the
following information:
• The date and time wastes were received for
inspection;
• Source of the wastes;
• Vehicle and driver identification; and
• All observations made by the inspector.
The Director of an approved State may
establish alternative recordkeeping locations
and requirements.
Training
Owners or operators must ensure that
personnel are trained to identify potential
regulated hazardous waste and PCB wastes.
These personnel could include supervisors,
designated inspectors, equipment operators,
and weigh station attendants who may
encounter hazardous wastes. Documentation
of training should be placed in the operating
record for the facility in accordance with
§258.29.
The training program should emphasize
methods to identify containers and labels
typical of hazardous waste and PCB waste.
Training also should address hazardous waste
handling procedures, safety precautions, and
recordkeeping requirements. This
information is provided in training courses
designed to comply with the Occupational
Safety and Health Act (OSHA) under 29 CFR
§1910.120. Information covered in these
courses includes regulatory requirements
under 40 CFR Parts 260 through 270, 29 CFR
Part 1910, and related guidance documents
that discuss such topics as: general hazardous
waste management; identification of
hazardous wastes; transportation of hazardous
wastes; standards for hazardous waste
treatment; storage and disposal facilities; and
hazardous waste worker health and safety
training and monitoring requirements.
Notification to Authorities and Proper
Management of Wastes
If regulated quantities of hazardous wastes or
PCB wastes are found at the landfill facility,
the owner or operator must notify the proper
authorities. Proper authorities are either the
Director of a State authorized to implement
the hazardous waste program under Subtitle C
of RCRA, or the EPA Regional
Administrator, in an unauthorized State.
If the owner or operator discovers regulated
quantities of hazardous waste or PCB waste
while it is still in the possession of the
transporter, the owner or operator can refuse
to accept the waste at the MSWLF facility,
and the waste will remain the responsibility of
the transporter. If the owner or operator is
unable to identify the transporter who brought
the hazardous waste, the owner or operator
must ensure that the waste is managed in
accordance
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Operating Criteria
with all applicable Federal and State
regulations.
Operators of MSWLF facilities should be
prepared to handle hazardous wastes that are
inadvertently received at the MSWLF facility.
This may include having containers such as
5 5-gallon drums available on-site and
retaining a list of names and telephone
numbers of the nearest haulers licensed to
transport hazardous waste.
Hazardous waste may be stored at the
MSWLF facility for 90 days, provided that
the following procedures required by 40 CFR
§262.34, or applicable State requirements, are
followed:
• The waste is placed in tanks or containers;
• The date of receipt of the waste is clearly
marked and visible on each container;
• The container or tank is marked clearly
with the words "Hazardous Waste";
• An employee is designated as the
emergency coordinator who is responsible
for coordinating all emergency response
measures; and
• The name and telephone number of the
emergency coordinator and the number of
the fire department is posted next to the
facility phone.
Extensions to store the waste beyond 90 days
may be approved pursuant to 40 CFR 262.34.
If the owner or operator transports the wastes
off-site, the owner or operator must comply
with 40 CFR Part 262 or the
analogous State/Tribal requirements.
owner or operator is required to:
The
• Obtain an EPA identification number
(EPA form 8700-12 may be used to
apply for an EPA identification number;
State or Regional personnel may be able
to provide a provisional identification
number over the telephone);
• Package the waste in accordance with
Department of Transportation (DOT)
regulations under 49 CFR Parts 173, 178,
and 179 (The container must be labeled,
marked, and display a placard in
accordance with DOT regulations on
hazardous wastes under 49 CFR Part
172); and
• Properly manifest the waste designating
a permitted facility to treat, store, or
dispose of the hazardous waste.
If the owner or operator decides to treat, store
(for more than 90 days), or dispose of the
hazardous waste on-site, he or she must
comply with the applicable State or Federal
requirements for hazardous waste treatment,
storage, and disposal facilities. This may
require a permit.
PCB wastes detected at a MSWLF facility
must be stored and disposed of according to
40 CFR Part 761. The owner or operator is
required to:
• Obtain an EPA PCB identification
number;
• Properly store the PCB waste;
• Mark containers or items with the words
"Caution: contains PCBs"; and
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Subpart C
Manifest the PCB waste for shipment to a
permitted incinerator, chemical waste
landfill, or high efficiency boiler
(depending on the nature of the PCB
waste) for disposal.
3.3 COVER MATERIAL
REQUIREMENTS
40 CFR §258.21
3.3.1 Statement of Regulation
(a) Except as provided in paragraph (b)
of this section, the owners or operators of
all MSWLF units must cover disposed solid
waste with six inches of earthen material at
the end of each operating day, or at more
frequent intervals if necessary, to control
disease vectors, fires, odors, blowing litter,
and scavenging.
(b) Alternative materials of an
alternative thickness (other than at least six
inches of earthen material) may be
approved by the Director of an approved
State if the owner or operator
demonstrates that the alternative material
and thickness control disease vectors, fires,
odors, blowing litter, and scavenging
without presenting a threat to human
health and the environment.
(c) The Director of an approved State
may grant a temporary waiver from the
requirement of paragraph (a) and (b) of
this section if the owner or operator
demonstrates that there are extreme
seasonal climatic conditions that make
meeting such requirements impractical.
3.3.2 Applicability
The regulation applies to all MSWLF units
receiving waste after October 9, 1993. The
regulation requires MSWLF unit owners and
operators to cover wastes with a 6-inch layer
of earthen material at the end of each
operating day. More frequent application of
soil may be required if the soil cover does not
control:
• Disease vectors (e.g., birds, flies and
other insects, rodents);
• Fires;
• Odors;
• Blowing litter; and
• Scavenging.
The Director of an approved State may allow
an owner or operator to use alternative cover
material of an alternative thickness or grant a
temporary waiver of this requirement. An
alternative material must not present a threat
to human health and the environment, and
must continue to control disease vectors, fires,
odors, blowing litter, and scavenging. The
only basis for a temporary waiver from the
requirement to cover at the end of each
operating day would be where extreme
seasonal climatic conditions make compliance
impractical.
3.3.3 Technical Considerations
Owners and operators of new MSWLF units,
existing MSWLF units, and lateral expansions
are required to cover solid waste at the end of
each operating day with six inches of earthen
material. This cover
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Operating Criteria
material requirement is not related to the final
cover required under §258.60.
The placement of six inches of cover controls
disease vectors (birds, insects, or rodents that
represent the principal transmission pathway
of a human disease) by preventing egress
from the waste and by preventing access to
breeding environments or food sources.
Covering also reduces exposure of
combustible materials to ignition sources and
may reduce the spread of fire if the disposed
waste burns. Odors and blowing litter are
reduced by eliminating the direct contact of
wind and disposed waste. Similarly,
scavenging is reduced by removing the waste
from observation. Should these unwanted
effects of inadequate cover persist, the owner
or operator may increase the amount of soil
used or apply it more frequently. Any soil
type can meet the requirements of the
regulation when placed in a six-inch layer.
Approved States may allow demon-strations
of alternative daily cover materials. The rule
does not specify the time frame for the
demonstration; usually the State decides. A
period of six months should be ample time for
the owner or operator to make the demonstra-
tion. There are no numerical require-ments
for the alternative cover; rather, the
alternative cover must control disease vectors,
fires, odors, blowing litter, and scavenging
without presenting a threat to human health
and the environment.
Demonstrations can be conducted in a variety
of ways. Some suggested methods for
demonstrating alternative covers are:
1) Side by side (six inches of earthen
materials and alternative cover) test pads;
2) Full-scale demonstration; and
3) Short-term full-scale tests.
Alternative daily cover materials may include
indigenous materials or commercially-
available materials. Indigenous materials are
those materials that would be disposed as
waste; therefore, using these materials is an
efficient use of landfill space. Examples of
indigenous materials include (USEPA, 1992):
• Ash from municipal waste
combustors and utility companies;
• Compost-based material;
• Foundry sand from the
manufacturing process of discarding
used dies;
• Yard waste such as lawn clippings,
leaves, and tree branches;
• Sludge-based materials (i.e., sludge
treated with lime and mixed with ash
or soil);
• Construction and demolition debris
(which has been processed to form a
slurry);
• Shredded automobile tires;
Discarded carpets; and
Grit from municipal wastewater
treatment plants.
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Subpart C
Commercially developed alternatives have
been on the market since the mid-1980s.
Some of the commercial alternative materials
require specially designed application
equipment, while others use equipment
generally available at most landfills. Some of
the types of commercially available daily
cover materials include (USEPA, 1992):
• Foam that usually is sprayed on the
working face at the end of the day;
• Geosynthetic products such as a tarp or
fabric panel that is applied at the end of
the working day and removed at the
beginning of the following working
day; and
• Slurry products (e.g., fibers from
recycled newspaper and wood chip
slurry, clay slurry).
Other criteria to consider when selecting an
alternative daily cover material include
availability and suitability of the material,
equipment requirements, and cost.
The temporary climatic waiver of the cover
requirement is available only to owners or
operators in approved States. The State
Director may grant a waiver if the owner or
operator demonstrates that meeting the
requirements would be impractical due to
extreme seasonal climatic conditions.
Activities that may be affected by extreme
seasonal climatic conditions include:
• Obtaining cover soil from a borrow pit;
• Transporting cover soil to the working
face; or
• Spreading and compacting the soil to
achieve the required functions.
Extremely cold conditions may prevent the
efficient excavation of soil from a borrow pit
or the spreading and compaction of the soil on
the waste. Extremely wet conditions (e.g.,
prolonged rainfall, flooding) may prevent
transporting cover soil to the working face
and may make it impractical to excavate or
spread and compact. The duration of waivers
may be as short as one day for unusual rain
storms, or as long as several months for
extreme seasonal climatic conditions.
3.4 DISEASE VECTOR CONTROL
40 CFR §258.22
3.4.1 Statement of Regulation
(a) Owners or operators of all
MSWLF units must prevent or control on-
site populations of disease vectors using
techniques appropriate for the protection
of human health and the environment.
(b) For purposes of this section,
disease vectors means any rodents, flies,
mosquitoes, or other animals, including
insects, capable of transmitting disease to
humans.
3.4.2 Applicability
The regulation applies to existing MSWLF
units, lateral expansions, and new MSWLF
units. The owner or operator is required to
prevent or control on-site disease vector
populations of rodents, flies, mosquitoes, or
other animals, including other insects. The
techniques that may be used in fulfilling this
requirement must be appropriate for the
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protection of human health and the
environment.
3.4.3 Technical Considerations
Disease vectors such as rodents, birds, flies,
and mosquitoes typically are attracted by
putrescent waste and standing water, which
act as a food source and breeding ground.
Putrescent waste is solid waste that contains
organic matter (such as food waste) capable of
being decomposed by micro-organisms. A
MSWLF facility typically accepts putrescent
wastes.
Application of cover at the end of each
operating day generally is sufficient to control
disease vectors; however, other vector control
alternatives may be required. These
alternatives could include: reducing the size
of the working face; other operational
modifications (e.g., increasing cover
thickness, changing cover type, density,
placement frequency, and grading); repellents,
insecticides or rodenticides; composting or
processing of organic wastes prior to disposal;
and predatory or reproductive control of
insect, bird, and animal populations.
Additional methods to control birds are
discussed in Chapter 2 (Airport Safety).
Mosquitoes, for example, are attracted by
standing water found at MSWLFs, which can
provide a potential breeding ground after only
three days. Water generally collects in
surface depressions, open containers, exposed
tires, ponds resulting from soil excavation,
leachate storage ponds, and siltation basins.
Landfill operations that minimize standing
water and that use an insecticide spraying
program ordinarily are effective in controlling
mosquitoes.
Vectors may reach the landfill facility not
only from areas adjacent to the landfill, but
through other modes conducive to harborage
and breeding of disease vectors. Such modes
may include residential and commercial route
collection vehicles and transfer stations.
These transport modes and areas also should
be included in the disease vector control
program if disease vectors at the landfill
facility become a problem. Keeping the
collection vehicles and transfer stations
covered; emptying and cleaning the collection
vehicles and transfer stations; using repellents,
insecticides, or rodenticides; and reproductive
control are all measures available to reduce
disease vectors in these areas.
3.5 EXPLOSIVE GASES CONTROL
40 CFR §258.23
3.5.1 Statement of Regulation
(a) Owners or operators of all MSWLF
units must ensure that:
(1) The concentration of methane gas
generated by the facility does not exceed 25
percent of the lower explosive limit for
methane in facility structures (excluding
gas control or recovery system
components); and
(2) The concentration of methane gas
does not exceed the LEL for methane at the
facility property boundary.
(b) Owners or operators of all MSWLF
units must implement a routine methane
monitoring program to ensure that the
standards of paragraph (a) of this section
are met.
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Subpart C
(1) The type and frequency of
monitoring must be determined based on
the following factors:
(i) Soil conditions;
(ii) The hydrogeologic conditions
surrounding the facility;
(iii) The hydraulic conditions
surrounding the facility; and
(iv) The location of facility
structures and property
boundaries.
(2) The minimum frequency of
monitoring shall be quarterly.
(c) If methane gas levels exceeding the
limits specified in paragraph (a) of this
section are detected, the owner or operator
must:
(1) Immediately take all necessary steps
to ensure protection of human health and
notify the State Director;
(2) Within seven days of detection, place
in the operating record the methane gas
levels detected and a description of the
steps taken to protect human health; and
(3) Within 60 days of detection,
implement a remediation plan for the
methane gas releases, place a copy of the
plan in the operating record, and notify the
State Director that the plan has been
implemented. The plan shall describe the
nature and extent of the problem and the
proposed remedy.
(4) The Director of an approved State
may establish alternative schedules for
demonstrating compliance with paragraphs
(2) and (3).
(d) For purposes of this section, lower
explosive limit (LEL) means the lowest
percent by volume of a mixture of explosive
gases in air that will propagate a flame at
25°C and atmospheric pressure.
3.5.2 Applicability
The regulation applies to existing MSWLF
units, lateral expansions, and new MSWLF
units. The accumulation of methane in
MSWLF structures can potentially result in
fire and explosions that can endanger
employees, users of the disposal site, and
occupants of nearby structures, or cause
damage to landfill containment structures.
These hazards are preventable through
monitoring and through corrective action
should methane gas levels exceed specified
limits in the facility structures (excluding gas
control or recovery system components), or at
the facility property boundary. MSWLF
facility owners and operators must comply
with the following requirements:
• Monitor at least quarterly;
• Take immediate steps to protect human
health in the event of methane gas levels
exceeding 25% of the lower explosive
limit (LEL) in facility structures, such as
evacuating the building;
• Notify the State Director if methane
levels exceed 25% of the LEL in facility
structures or exceed the LEL at the
facility property boundary;
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Operating Criteria
• Within 7 days of detection, place in the
operating record documentation that
methane gas concentrations exceeded the
criteria, along with a description of
immediate actions taken to protect human
health; and
• Within 60 days of detection, implement a
remediation plan for the methane gas
releases, notify the State Director, and
place a copy of the remediation plan in the
operating record.
The compliance schedule for monitoring and
responding to methane levels that exceed the
criteria of this regulation can be changed by
the Director of an approved State.
3.5.3 Technical Considerations
To implement an appropriate routine methane
monitoring program to demonstrate
compliance with allowable methane
concentrations, the characteristics of landfill
gas production and migration at a site should
be understood. Landfill gases are the result of
microbial decomposition of solid waste.
Gases produced include methane (CH4),
carbon dioxide (CO2), and lesser amounts of
other gases (e.g., hydrogen, volatile organic
compounds, and hydrogen sulfide). Methane
gas, the principal component of natural gas, is
generally the primary concern in evaluating
landfill gas generation because it is odorless
and highly combustible. Typically, hydrogen
gas is present at much lower concentra-tions.
Hydrogen forms as decomposition progresses
from the acid production phase to the
methanogenic phase. While hydrogen is
explosive and is occasionally detected in
landfill gas, it readily reacts to form methane
or hydrogen sulfide. Hydrogen sulfide is
toxic and is
readily identified by its "rotten egg" smell at
a threshold concentration near 5 ppb.
Landfill gas production rates vary spatially
within a landfill unit as a result of pockets of
elevated microbial activity but, due to partial
pressure gradients, differences in gas
composition are reduced as the gases
commingle within and outside the landfill
unit. Although methane gas is lighter than air
and carbon dioxide is heavier, these gases are
concurrently produced at the microbial level
and will not separate by their individual
density. The gases will remain mixed and
will migrate according to the density gradients
between the landfill gas and the surrounding
gases (i.e., a mixture of methane and carbon
dioxide in a landfill unit or in surrounding soil
will not separate by rising and sinking
respectively, but will migrate as a mass in
accordance with the density of the mixture
and other gradients such as temperature and
partial pressure).
When undergoing vigorous microbial
production, gas pressures on the order of 1 to
3 inches of water relative to atmospheric
pressure are common at landfill facilities, with
much higher pressures occasionally reported.
A barometric pressure change of 2 inches of
mercury is equivalent to 27.2 inches of water.
Relative gauge pressures at a particular
landfill unit or portion of a landfill unit, the
ability of site conditions to contain landfill
gas, barometric pressure variations, and the
microbial gas production rate control
pressure-induced landfill gas migration.
Negative gas pressures are commonly
observed and are believed to occur as a result
of the delayed response within a landfill unit
to the passage of a high pressure system
outside the landfill unit. Barometric highs
will tend to introduce atmospheric oxygen
into surface soils in
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Subpart C
shallow portions of the landfill unit, which
may alter microbial activity, particularly
methane production and gas composition.
Migration of landfill gas is caused by
concentration gradients, pressure gradients,
and density gradients. The direction in which
landfill gas will migrate is controlled by the
driving gradients and gas permeability of the
porous material through which it is migrating.
Generally, landfill gas will migrate through
the path of least resistance.
Coarse, porous soils such as sand and gravel
will allow greater lateral migration or
transport of gases than finer-grained soils.
Generally, resistance to landfill gas flow
increases as moisture content increases and,
therefore, an effective barrier to gas flow can
be created under saturated conditions. Thus,
readily drained soil conditions, such as sands
and gravels above the water table, may
provide a preferred flowpath, but unless finer-
grained soils are fully saturated, landfill gases
also can migrate in a "semi-saturated" zone.
Figure 3-2 illustrates the potential effects of
surrounding geology on gas migration.
While geomembranes may not eliminate
landfill gas migration, landfill gas in a closed
MSWLF unit will tend to migrate laterally if
the final cover contains a geomembrane and if
the side slopes of the landfill do not contain
an effective gas barrier. Lateral gas migration
is more common in older facilities that lack
appropriate gas control systems. The degree
of lateral migration in older facilities also may
depend on the type of natural soils
surrounding the facility.
Stressed vegetation may indicate gas
migration. Landfill gas present in the soil
atmosphere tends to make the soil anaerobic
by displacing the oxygen, thereby
asphyxiating the roots of plants. Generally,
the higher the concentration of combustible
gas and/or carbon dioxide and the lower the
amount of oxygen, the greater the extent of
damage to vegetation (Flowers, et. al, 1982).
Gas Monitoring
The owner or operator of a MSWLF
unit/facility must implement a routine
methane monitoring program to comply with
the lower explosive limit (LEL) requirements
for methane. Methane is explosive when
present in the range of 5 to 15 percent by
volume in air. When present in air at
concentrations greater than 15 percent, the
mixture will not explode. This 15 percent
threshold is the Upper Explosive Limit
(UEL). The UEL is the maximum
concentration of a gas or vapor above which
the substance will not explode when exposed
to a source of ignition. The explosive hazard
range is between the LEL and the UEL. Note,
however, that methane concentrations above
the UEL remain a significant concern; fire
and asphyxiation can still occur at these
levels. In addition, even a minor dilution of
the methane by increased ventilation can bring
the mixture back into the explosive range.
To demonstrate compliance, the
owner/operator would sample air within
facility structures where gas may accumulate
and in soil at the property boundary. Other
monitoring methods may include: (1)
sampling gases from probes within the landfill
unit or from within the leachate collection
system; or (2) sampling gases
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Clay or Synthetic Cap
(Low Permeability)
Clay Soil, Frozen or
Saturated Soil, or Pavement
(Low Permeability)
Sand and Gravel Soil
(High Permeability)
EXTENSIVE LATERAL MIGRATION
Clay or Synthetic Liner
~ (Low Permeability)
Daily Cover
(High Permeability)
Clay Soil
(Low PermeabMBy)
EXTENSIVE VERTICAL MIGRATION
Source: Emcon, 1981.
Figure 3-2
Potential Effects of
Surrounding Geology on Gas Migration
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Subpart C
from monitoring probes installed in soil
between the landfill unit and either the
property boundary or structures where gas
migration may pose a danger. A typical gas
monitoring probe installation is depicted in
Figure 3-3.
Although not required by the regulations,
collection of data such as water presence and
level, gas probe pressure, ambient
temperature, barometric pressure, and the
occurrence of precipitation during sampling,
provides useful information in assessing
monitoring results. For example, falling
barometric pressure may cause increased
subsurface (gas) pressures and corresponding
increased methane content as gas more readily
migrates from the landfill. Gas probe
pressure can be measured using a portable
gauge capable of measuring both vacuum and
pressure in the range of zero to five inches of
water pressure (or other suitable ranges for
pressure conditions); this pressure should be
measured prior to methane measurement or
sample collection in the gas probe. A
representative sample of formation
(subsurface) gases can be collected directly
from the probe. Purging typically is not
necessary due to the small volume of the
probe. A water trap is recommended to
protect instrumentation that is connected
directly to the gas probe. After measurements
are obtained, the gas probe should be capped
to reduce the effects of venting or barometric
pressure variations on gas composition in the
vicinity of the probe.
The frequency of monitoring should be
sufficient to detect landfill gas migration
based on subsurface conditions and changing
landfill conditions such as partial or complete
capping, landfill expansion, gas migration
control system operation or failure,
construction of new or replacement
structures, and changes in landscaping or land
use practices. The rate of landfill gas
migration as a result of these anticipated
changes and the site-specific conditions
provides the basis for establishing monitoring
frequency. Monitoring is to be conducted at
least quarterly.
The number and location of gas probes is also
site-specific and highly dependent on
subsurface conditions, land use, and location
and design of facility structures. Monitoring
for gas migration should be within the more
permeable strata. Multiple or nested probes
are useful in defining the vertical
configuration of the migration pathway.
Structures with basements or crawl spaces are
more susceptible to landfill gas infiltration.
Elevated structures are typically not at risk.
Measurements are usually made in the field
with a portable methane meter, explosimeter,
or organic vapor analyzer. Gas samples also
may be collected in glass or metal containers
for laboratory analysis. Instruments with
scales of measure in "percent of LEL" can be
calibrated and used to detect the presence of
methane. Instruments of the hot-wire
Wheatstone bridge type (i.e., catalytic
combustion) directly measure combustibility
of the gas mixture withdrawn from the probe.
The thermal conductivity type meter is
susceptible to interference as the relative gas
composition and, therefore, the thermal
conductivity, changes. Field instruments
should be calibrated prior to measurements
and should be rechecked after each day's
monitoring activity.
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Operating Criteria
Source: Warzyn Inc.
PVC caps with
petcocks
Protective casing
with lock
Bentonite soil seal
Bentonite seal
1 inch PVC pipe
1/2 inch PVC pipe
1 inch perforated
PVC pipe
Gravel backfill
Bentonite seal
Sand and gravel
Probe screen
Figure 3-3
Typical Gas Monitoring Probe
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Subpart C
Laboratory measurements with organic vapor
analyzers or gas chromatographs may be used
to confirm the identity and concentrations of
gas.
In addition to measuring gas composition,
other indications of gas migration may be
observed. These include odor (generally
described as either a "sweet" or a rotten egg
(H2S) odor), vegetation damage, septic soil,
and audible or visual venting of gases,
especially in standing water. Exposure to
some gases can cause headaches and nausea.
If methane concentrations are in excess of 25
percent of the LEL in facility structures or
exceed the LEL at the property boundary, the
danger of explosion is imminent. Immediate
action must be taken to protect human health
from potentially explosive conditions. All
personnel should be evacuated from the area
immediately. Venting the building upon exit
(e.g., leaving the door open) is desirable but
should not replace evacuation procedures.
Owners and operators in unapproved States
have 60 days after exceeding the methane
level to prepare and implement a remediation
plan. The remediation plan should describe
the nature and extent of the methane problem
as well as a proposed remedy.
To comply with this 60-day schedule, an
investigation of subsurface conditions may be
needed in the vicinity of the monitoring probe
where the criterion was exceeded. The
objectives of this investigation should be to
describe the frequency and lateral and vertical
extent of excessive methane migration (that
which exceeds the criterion). Such an
investigation also may yield additional
characterization of unsaturated
soil within the area of concern. The
investigation should consider possible causes
of the increase in gas concentrations such as
landfill operational procedures, gas control
system failure or upset, climatic conditions, or
closure activity. Based on the extent and
nature of the excessive methane migration, a
remedial action should be described, if the
exceedance is persistent, that can be
implemented within the prescribed schedule.
The sixty-day schedule does not address the
protection of human health and the
environment. The owner or operator still
must take all steps necessary to ensure
protection of human health, including interim
measures.
Landfill Gas Control Systems
Landfill gas may vent naturally or be
purposely vented to the atmosphere by
vertical and/or lateral migration controls.
Systems used to control or prevent gas
migration are categorized as either passive or
active systems. Passive systems provide
preferential flowpaths by means of natural
pressure, concentration, and density gradients.
Passive systems are primarily effective in
controlling convective flow and have limited
success controlling diffusive flow. Active
systems are effective in controlling both types
of flow. Active systems use mechanical
equipment to direct or control landfill gas by
providing negative or positive pressure
gradients. Suitability of the systems is based
on the design and age of the landfill unit, and
on the soil, hydrogeologic, and hydraulic
conditions of the facility and surrounding
environment. Because of these variables, both
systems have had varying degrees of success.
Passive systems may be used in conjunction
with active systems. An example of this
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may be the use of a low-permeability passive
system for the closed portion of a landfill unit
(for remedial purposes) and the installation of
an active system in the active portion of the
landfill unit (for future use).
Selection of construction materials for either
type of gas control system should consider the
elevated temperature conditions within a
landfill unit as compared to the ambient air or
soil conditions in which gas control system
components are constructed. Because
ambient conditions are typically cooler, water
containing corrosive and possibly toxic waste
constituents may be expected to condense.
This condensate should be considered in
selecting construction materials. Provisions
for managing this condensate should be
incorporated to prevent accumulation and
possible failure of the collection system. The
condensate can be returned to the landfill unit
if the landfill is designed with a composite
liner and leachate collection system per
§258.40(a)(2). See Chapter 4 for information
regarding design. See Section 3.10 of this
Chapter for information regarding liquids in
landfills.
Additional provisions (under the Clean Air
Act) were proposed on May 30, 1991 (56 FR
24468), that would require the owners/
operators of certain landfill facilities to install
gas collection and control systems to reduce
the emissions of nonmethane organic
compounds (NMOCs). The proposed rule
amends 40 CFR Parts 51, 52, and 60. For
new municipal solid waste landfill units (those
for which construction was begun after May
30, 1991), and for those units that have a
design capacity greater than 111,000 tons, a
gas collection and control system must be
installed if emissions evaluations indicate that
the NMOC emissions rate is
150 megagrams per year (167 tons per year)
or greater. Allowable control systems include
open and enclosed flares, and on-site or off-
site facilities that process the gas for
subsequent sale or use. EPA believes that,
depending on landfill design, active collection
systems may be more cost-effective than
passive systems in ensuring that the system
effectively captures the gas that is generated
within the landfill unit. The provisions for
new landfill units are self-implementing and
will be effective upon promulgation of the
rule.
In addition to the emissions standards for new
municipal solid waste landfill units, the
regulations proposed on May 30, 1991
establish guidelines for State programs for
reducing NMOC emissions from certain
existing municipal landfill units. These
provisions apply to landfill units for which
construction was commenced before May 30,
1991, and that have accepted waste since
November 8, 1987 or that have remaining
capacity. Essentially, the State must require
the same kinds of collection and control
systems for landfill units that meet the size
criteria and emissions levels outlined above
for new landfill units. The requirements for
existing facilities will be effective after the
State revises its State Implementation Plan
and receives approval from EPA.
The rule is scheduled to be promulgated in
late 1993; the cutoff numbers for landfill size
and emission quantity may be revised in the
final rule. EPA expects that the new
regulations will affect less than 9% of the
municipal landfill facilities in the U.S.
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Subpart C
Passive Systems
Passive gas control systems rely on natural
pressure and convection mechanisms to vent
landfill gas to the atmosphere. Passive
systems typically use "high-permeability" or
"low-permeability" techniques, either
singularly or in combination at a site. High-
permeability systems use conduits such as
ditches, trenches, vent wells, or perforated
vent pipes surrounded by coarse soil to vent
landfill gas to the surface and the atmosphere.
Low-permeability systems block lateral
migration through barriers such as synthetic
membranes and high moisture-containing
fine-grained soils.
Passive systems may be incorporated into a
landfill design or may be used for remedial or
corrective purposes at both closed and active
landfills. They may be installed within a
landfill unit along the perimeter, or between
the landfill and the disposal facility property
boundary. A detailed discussion of passive
systems for remedial or corrective purposes
may be found in U.S. EPA (1985).
A passive system may be incorporated into
the final cover system of a landfill closure
design and may consist of perforated gas
collection pipes, high permeability soils, or
high transmissivity geosynthetics located just
below the low-permeability gas and hydraulic
barrier or infiltration layer in the cover
system. These systems may be connected to
vent pipes that vent gas through the cover
system or that are connected to header pipes
located along the perimeter of the landfill
unit. Figure 3-4 illustrates a passive system.
The landfill gas collection system also may be
connected with the leachate collection system
to vent gases in the headspace of leachate
collection pipes.
Some problems have been associated with
passive systems. For example, snow and dirt
may accumulate in vent pipes, preventing gas
from venting. Vent pipes
at the surface are susceptible to clogging by
vandalism. Biological clogging of the system
is also more common in passive systems.
Active Systems
Active gas control systems use mechanical
means to remove landfill gas and consist of
either positive pressure (air injection) or
negative pressure (extraction) systems.
Positive pressure systems induce a pressure
greater than the pressure of the migrating gas
and drive the gas out of the soil and/or back to
the landfill unit in a controlled manner.
Negative pressure systems extract gas from a
landfill by using a blower to pull gas out of
the landfill. Negative pressure systems are
more commonly used because they are more
effective and offer more flexibility in
controlling gas migration. The gas may be
recovered for energy conversion, treated, or
combusted in a flare system. Typical
components of a flare system are shown in
Figure 3-5. Negative pressure systems may
be used as either perimeter gas control
systems or interior gas collection/recovery
systems. For more information regarding
negative pressure gas control systems, refer to
U.S. EPA (1985).
An active gas extraction well is depicted in
Figure 3-6. Gas extraction wells may be
installed within the landfill waste or, as
depicted in Figure 3-7A and Figure 3-7B,
perimeter extraction trenches could be used.
One possible configuration of an interior gas
collection/recovery system is illustrated in
96
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Operating Criteria
Gas Vent
Figure 3-4
Passive Gas Control System
(Venting to Atmosphere)
Top Layer
Low-Permeability Laye
Vent Layer
Waste
97
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Subpart C
77T—Waste Gas
Inlet Valve
Concrete Base
Gas From
Landfill
Source; E.G. Jordan Co., 1990.
Figure 3-5. Example Schematic Diagram of a
Ground-based Landfill Gas Flare
98
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48" Corr. Steel Pipe
w/ Hinged Lid
Backfill, Compact by
Hand in 6" Layers
Exist Ground Elev
Butterfly Valve
Monitoring Port
Header with 3"
Dia. Branch Saddle
Kanaflex PVC Hose
Source CH,H Hill. 1992
3'-0"
4" Dia Sch 80 PVC
Solid Pipe
Soil Backfill
*-
T
Varies
Bentonite/Soil Seal
4" Dia Sch 80 PVC
Slotted Pipe
Gravel Backfill
2'-C'
12"
Slotted Length
Varies
(2/3 Landfill
Depth)
4" Sch 80 PVC Cap-
Slotted Length
Varies
(1/2 Well Depth)
!
I
1 24" Dia
1— M
i Bore i
Figure 3-6 Example of a Gas Extraction Well
99
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- Geotextile
Existing Cover
Existing Cover
• Refuse
Washed Gravel
Oo
Sourca: Swana. 1991
Bottom of Trench Excavation
Figure 3-7A. Perimeter Extraction Trench System
Quick Connect
Coupling
Flexible Hose
Butterfly Valve
Source: Swana, 1991
Washed Gravel
Ground Surface
Clean Soil Backfill
HOPE Pipe
Figure 3-7B. Perimeter Extraction Trench System
100
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Operating Criteria
Figure 3-8. The performance of active
systems is not as sensitive to freezing or
saturation of cover soils as that of passive
systems. Although active gas systems are
more effective in withdrawing gas from the
landfill, capital, operation, and maintenance
costs of such systems will be higher and these
costs can be expected to continue throughout
the post-closure period. At some future time,
owners and operators may wish to convert
active gas controls into passive systems when
gas production diminishes. The conversion
option and its environmental effect (i.e., gas
release causing odors and health and safety
concerns) should be addressed in the original
design.
There are many benefits to recovering landfill
gas. Landfill gas recovery systems can reduce
landfill gas odor and migration, can reduce
the danger of explosion and fire, and may be
used as a source of revenue that may help to
reduce the cost of closure. Landfill gas can be
used with a minimal amount of treatment or
can be upgraded to pipeline standards
(SWANA, 1992). An upgraded gas is one
which has had the carbon dioxide and other
noncombustible constituents removed.
Raw landfill gas may be used for heating
small facilities and water, and may require
removal of only water and particulates for this
application. A slightly upgraded gas can be
used for both water and space heating as well
as lighting, electrical generation,
cogeneration, and as a fuel for industrial
boilers-burners. Landfill gas also may be
processed to pipeline quality to be sold to
utility companies and may even be used to
fuel conventional vehicles. The amount of
upgrading and use of landfill gas is dependent
on the landfill size.
3.6 AIR CRITERIA
40 CFR §258.24
3.6.1 Statement of Regulation
(a) Owners or operators of all
MSWLFs must ensure that the units do not
violate any 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.
(b) Open burning of solid waste, except
for the infrequent burning of agricultural
wastes, silvicultural wastes, land-clearing
debris, diseased trees, or debris from
emergency clean-up operations, is
prohibited at all MSWLF units.
3.6.2 Applicability
The regulation applies to existing MSWLF
units, lateral expansions to existing MSWLF
units, and new MSWLF units. Routine open
burning of municipal solid waste is
prohibited. Infrequent burning of agricultural
and silvicultural wastes, diseased trees, or
debris from land clearing or emergency clean-
up operations is allowed when in compliance
with any applicable requirements developed
under a State Implementation Plan (SIP) of
the Clean Air Act. Agricultural waste does
not include empty pesticide containers or
waste pesticides.
3.6.3 Technical Considerations
Air pollution control requirements are
developed under a SIP, which is developed by
the State and approved by the EPA
Administrator. The owner or operator of a
101
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Gas
Treatment/Processing
Facility
Source: Emcon, 1981
Figure 3-8
Example of an Interior Gas Collection/Recovery System
102
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Operating Criteria
MSWLF unit should consult the State or local
agency responsible for air pollution control to
ascertain that the burning of wastes complies
with applicable requirements developed under
the SIP. The SIP may include variances,
permits, or exemptions for burning
agricultural wastes, silvicultural wastes, land-
clearing debris, diseased trees, or debris from
emergency clean-up operations. Routine
burning of wastes is banned in all cases, and
the SIP may limit burning of waste such as
agricultural wastes to certain hours of the day;
days of the year; designated burn areas;
specific types of incinerators; atmospheric
conditions; and distance from working face,
public thoroughfares, buildings, and
residences.
Requirements under the SIP also may include
notifying applicable State or local agencies
whose permits may: (1) restrict times when
limited burning of waste may occur; (2)
specify periods when sufficient fire protection
is deemed to be available; or (3) limit burning
to certain areas.
Open burning is defined under §258.2 as the
combustion of solid waste: (1) without
control of combustion air to maintain
adequate temperature for efficient
combustion; (2) without containment of the
combustion reaction in an enclosed device to
provide sufficient residence time and mixing
for complete combustion; and (3) without the
control of the emission of the combustion
products. Trench or pit burners, and air
curtain destructors are considered open
burning units because the particulate
emissions are similar to particulate emissions
from open burning,
and these devices do not control the emission
of combustion products.
[Note: The Agency plans to issue regulations
under the Clean Air Act to control landfill gas
emissions from large MSWLF units in 1993.
These regulations are found at 40 CFR Parts
51, 52, and 60.]
3.7 ACCESS REQUIREMENT
40 CFR §258.25
3.7.1 Statement of Regulation
Owners or operators of all MSWLF units
must control public access and prevent
unauthorized vehicular traffic and illegal
dumping of wastes by using artificial
barriers, natural barriers, or both, as
appropriate to protect human health and
the environment.
3.7.2 Applicability
The regulation applies to existing MSWLF
units, lateral expansions, and new MSWLF
units. The owner or operator is required to
prevent public access to the landfill facility,
except under controlled conditions during
hours when wastes are being received.
3.7.3 Technical Considerations
Owners and operators are required to control
public access to prevent illegal dumping,
public exposures to hazards at MSWLF units,
and unauthorized vehicular traffic.
Frequently, unauthorized persons are
unfamiliar with the hazards associated with
landfill facilities, and consequences of
uncontrolled access may include injury and
even death. Potential hazards are related to
inability of equipment operators to see
unauthorized individuals during operation of
equipment and haul vehicles; direct exposure
to waste (e.g., sharp objects and pathogens);
103
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Subpart C
inadvertent or deliberate fires; and earth-
moving activities.
Acceptable measures used to limit access of
unauthorized persons to the disposal facility
include gates and fences, trees, hedges, berms,
ditches, and embankments. Chain link,
barbed wire added to chain link, and open
farm-type fencing are examples of fencing
that may be used. Access to facilities should
be controlled through gates that can be locked
when the site is unsupervised. Gates may be
the only additional measure needed at remote
facilities.
3.8 RUN-ON/RUN-OFF
CONTROL SYSTEMS
40 CFR §258.26
3.8.1 Statement of Regulation
(a) Owners or operators of all MSWLF
units must design, construct, and maintain:
(1) A run-on control system to prevent
flow onto the active portion of the landfill
during the peak discharge from a 25-year
storm;
(2) A run-off control system from the
active portion of the landfill to collect and
control at least the water volume resulting
from a 24-hour, 25-year storm.
(b) Run-off from the active portion of
the landfill unit must be handled in
accordance with §258.27(a) of this Part.
3.8.2 Applicability
The regulation applies to existing MSWLF
units, lateral expansions, and new MSWLF
units. The owner or operator is required to
prevent run-on onto the active portion of the
landfill units and to collect and control run-off
from the active portion for a 24-hour, 25-year
storm. Management of run-off must comply
with the point and non-point source discharge
requirements of the Clean Water Act.
3.8.3 Technical Considerations
If stormwater enters the landfill unit and
contacts waste (including water within daily
cover), the stormwater becomes leachate and
must be managed as leachate. The purpose of
a run-on control system is to collect and
redirect surface waters to minimize the
amount of surface water entering the landfill
unit. Run-on control can be accomplished by
constructing berms and swales above the
filling area that will collect and redirect the
water to stormwater control structures.
As stated above, stormwater that does enter
the landfill unit should be managed as
leachate. Run-off control systems are
designed to collect and control this run-off
from the active portion of the landfill,
including run-off from areas that have
received daily cover, which may have
contacted waste materials. Run-off control
can be accomplished through stormwater
conveyance structures that divert this run-
off/1 eachate to the leachate storage device.
After a landfill unit has been closed with a
final cover, stormwater run-off from this unit
can be managed as stormwater and not
leachate. Therefore, waters running off the
final cover system of closed areas may not
104
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Operating Criteria
require treatment and generally can be
combined with run-on waters. For landfills
with steep side slopes, a bench system may
provide the best solution for run-off control.
A bench creates a break in the slope where the
velocity of the stormwater run-off is expected
to become erosive. The bench converts sheet
flow run-off into channel flow. Benches
typically are spaced 30 to 50 feet apart up the
slope. An alternative to benches is a system
of downchutes whereby stormwater is
collected off the top of the landfill and
conveyed down the slope through a pipe or
channel. Caution should be taken not to
construct downchutes with heavy material
because of possible subsidence. Corrugated
metal pipes or plastic-lined channels are
examples of lightweight materials that can be
used for downchute construction.
Run-on and run-off must be managed in
accordance with the requirements of the Clean
Water Act including, but not limited to, the
National Pollutant Discharge Elimination
System (NPDES). [See Section 3.9 of this
chapter for further information on compliance
with the Clean Water Act.]
Run-on and run-off control systems must be
designed based on a 24-hour, 25-year storm.
Information on the 24-hour, 25-year recurring
storm can be obtained from Technical Paper
40 "Rainfall Frequency Atlas of the United
States for Durations from 30 Minutes to 24
Hours and Return Periods from 1 to 100
Years", prepared by the Weather Bureau
under the Department of Commerce.
Alternatively, local meteorological data can
be analyzed to estimate the criterion storm.
To estimate run-on, the local watershed
should be identified and evaluated to
document the basis for run-on design flows.
The Soil Conservation Service (SCS) Method
and/or the Rational Method are generally
adequate for estimating storm flows for
designing run-on and/or run-off control
systems. The SCS method estimates run-off
volume from accumulated rainfall and then
applies the run-off volume to a simplified
triangular unit hydrograph for peak discharge
estimation and total run-off hydrograph. A
discussion of the development and use of this
method is available from the U. S.
Department of Agriculture, Soil Conservation
Service (1986).
The Rational Method approximates the
majority of surface water discharge supplied
by the watershed upstream from the facility.
The Rational Method generally is used for
areas of less than 200 acres. A discussion of
the Rational Method may be found in U.S.
EPA (1988).
Run-on/run-off control structures, both
temporary and permanent, may be
incorporated into the system design. Other
structures (not mentioned above) most
frequently used for run-on/run-off control are
waterways, seepage ditches, seepage basins,
and sedimentation basins. U.S. EPA (1985)
provides an in-depth discussion for each of
these structures.
3.9 SURFACE WATER
REQUIREMENTS
40 CFR §258.27
3.9.1 Statement of Regulation
MSWLF units shall not:
(a) Cause a discharge of pollutants into
waters of the United States, including
105
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Subpart C
wetlands, that violates any requirements of
the Clean Water Act, including, but not
limited to, the National Pollutant Discharge
Elimination System (NPDES)
requirements, pursuant to section 402.
(b) Cause the discharge of a nonpoint
source of pollution to waters of the United
States, including wetlands, that violates
any requirement of an area-wide or State-
wide water quality management plan that
has been approved under section 208 or
319 of the Clean Water Act, as amended.
3.9.2 Applicability
The regulation applies to existing MSWLF
units, lateral expansions, and new MSWLF
units. The owner or operator is required to
comply with the Clean Water Act for any
discharges to surface water or wetlands.
3.9.3 Technical Considerations
The owner or operator of a MSWLF facility
should determine if the facility is in
conformance with applicable requirements of
water quality plans developed under Sections
208 and 319 of the Clean Water Act, and the
National Pollutant Discharge Elimination
System (NPDES) requirements under Section
402 of the Clean Water Act. The EPA and
approved States have jurisdiction over
discharge of pollutants (other than dredge and
fill materials) in waters of the United States
including wetlands. MSWLF units
discharging pollutants or disposing of fill
material into waters of the United States
require a Section 402 (NPDES) permit.
Discharge of dredge and fill material into
waters of the United States is under the
jurisdiction of the U.S. Army Corps of
Engineers.
A MSWLF unit(s) that has a point source
discharge must have a NPDES permit. Point
source discharges for landfills include, but are
not limited to: (1) the release of leachate
from a leachate collection or on-site treatment
system into the waters of the United States;
(2) disposal of solid waste into waters of the
United States; or (3) release of surface water
(stormwater) run-off which is directed by a
run-off control system into the waters of the
United States. Leachate that is piped or
trucked off-site to a treatment facility is not
regarded as a point source discharge.
The Clean Water Act (CWA) provides
clarifications of terms such as point source,
waters of the United States, pollutants, and
discharge of pollutants.
Owners/operators also should be aware that
there are regulations promulgated pursuant to
the CWA regarding stormwater discharges
from landfill facilities. These regulations
require stormwater discharge permit
applications to be submitted by certain
landfills that accept or have accepted specific
types of industrial waste. See 40 CFR Section
122.26(a)-(c), which originally appeared in
the Federal Register on November 16, 1990
(55 FR 47990).
In addition, EPA codified several provisions
pursuant to the Intermodal Surface
Transportation Efficiency Act of 1991 into the
NPDES regulations. These regulations only
affect the deadlines for submitting permit
applications for stormwater discharges, and
they apply to both uncontrolled and controlled
sanitary landfills. "Uncontrolled sanitary
landfills" are defined as landfills or open
dumps that do not meet the requirements for
run-on or run-off controls that are found in
the
106
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Operating Criteria
MSWLF Criteria, Section 258.25.
"Controlled sanitary landfills" are those that
do meet the run-on and run-off requirements.
The NPDES regulations specify that
uncontrolled sanitary landfills owned or
operated by municipalities of less than
100,000 (population) must submit a NPDES
permit application for their stormwater
discharge or obtain coverage under a general
permit. For controlled sanitary landfills
owned or operated by a municipality with a
population less than 100,000, there is no
requirement to submit a stormwater discharge
permit application (before October 1, 1992)
unless a permit is required under Section
402(p)(2)(A) or (E) of the Clean Water Act.
Other deadlines are set for municipalities with
a population less than 250,000 that own or
operate a municipal landfill. For further
information contact the Stormwater Hotline
(703) 821-4823. See the April 2, 1992
Federal Register (57 FR 11394), 40 CFR
122.26.
3.10 LIQUIDS RESTRICTIONS
40 CFR §258.28
3.10.1 Statement of Regulation
(a) Bulk or noncontainerized liquid
waste may not be placed in MSWLF units
unless:
(1) The waste is household waste other
than septic waste; or
(2) The waste is leachate or gas
condensate derived from the MSWLF unit
and the MSWLF unit, whether it is an
existing or new unit, is designed with a
composite liner and leachate collection
system as described in §258.40 (a)(2) of
this part. The owner or operator must
place the demonstration in the operating
record and notify the State Director that it
has been placed in the operating record.
(b) Containers holding liquid waste
may not be placed in a MSWLF unit
unless:
(1) The container is a small container
similar in size to that normally found in
household waste;
(2) The container is designed to hold
liquids for use other than storage; or
(3) The waste is household waste.
(c) For purposes of this section:
(1) Liquid waste means any waste
material that is determined to contain
"free liquids" as defined by Method 9095
(Paint Filter Liquids Test), as described in
"Test Methods for Evaluating Solid
Wastes, Physical/Chemical Methods" (EPA
Pub. No. SW-846).
(2) Gas condensate means the liquid
generated as a result of gas recovery
process(es) at the MSWLF unit.
3.10.2 Applicability
The regulation applies to new MSWLF units,
existing MSWLF units, and lateral expansions
of existing MSWLF units. The owner or
operator is prohibited from placing bulk or
non-containerized liquid waste, or
containerized liquid waste into the MSWLF
unit. Liquids from households are exempt.
Tank trucks of wastes are not exempt.
107
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Subpart C
3.10.3 Technical Considerations
The restriction of bulk or containerized
liquids is intended to control a source of
liquids that may become a source of leachate.
Liquid waste refers to any waste material that
is determined to contain free liquids as
defined by SW-846 (U.S. EPA, 1987) Method
9095 - Paint Filter Liquids Test. The paint
filter test is performed by placing a 100
milliliter sample of waste in a conical, 400
micron paint filter. The waste is considered a
liquid waste if any liquid from the waste
passes through the filter within five minutes.
The apparatus used for performing the paint
filter test is illustrated in Figure 3-9.
If the waste is considered a liquid waste,
absorbent materials may be added to render a
"solid" material (i.e., waste/absorbent mixture
that no longer fails the paint filter liquids
test). One common waste stream that may
contain a significant quantity of liquid is
sludge. Sludge is a mixture of water and
solids that has been concentrated from, and
produced during, water and wastewater
treatment. Sludges may be produced as a
result of providing municipal services (e.g.,
potable water supply, sewage treatment, storm
drain maintenance) or commercial or
industrial operations. Sewage sludge is a
mixture of organic and inorganic solids and
water, removed from wastewater containing
domestic sewage. Sludge disposal is
acceptable provided the sludge passes the
paint filter test.
[NOTE: Additional Federal regulations
restricting the use and disposal of sewage
sludge were published on February 19, 1993
in the Federal Register (58 FR 9248). These
regulations, however, do not establish
additional treatment standards or other
special management requirements for sewage
sludge that is codisposed with solid waste.]
Owners and operators of MSWLF units may
return leachate and gas condensate generated
from a gas recovery process to the MSWLF,
provided the MSWLF unit has been designed
and constructed with a composite liner and
leachate collection system in compliance with
40 CFR §258.40(a)(2). Approved States may
allow leachate and landfill gas condensate
recirculation in MSWLF units with alternative
designs.
Recirculating leachate or landfill gas
concentrate may require demonstrating that
the added volume of liquid will not increase
the depth of leachate on the liner to more than
30cm.
Returning gas condensate to the landfill unit
may represent a reasonable long-term solution
for relatively small volumes of condensate.
Gas condensate recirculation can be
accomplished by pumping the condensate
through pump stations at the gas recovery
system and into dedicated drain fields (buried
pipe) atop the landfill, or into other discharge
points (e.g., wells).
Because gas condensate may be odorous,
spray systems for recirculation are not used
unless combined with leachate recirculation
systems.
Leachate recirculation to a MSWLF unit has
been used as a measure for managing leachate
or as a means of controlling and managing
liquid and solid waste decomposition.
Leachate recirculation can be accomplished in
the same manner as recirculation of landfill
gas condensate. Because of the larger
volume, however, discharge points may not
be as effective as drainfields. In some cases,
discharge points
108
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Operating Criteria
Paint Filter
Ring Stand
Funnel
•Graduated Cylinder
Figure 3-9. Paint Filter Test Apparatus
109
-------
Subpart C
have been a source of odor. In addition, a
discharge point may not allow for dissipation
of the leachate. (For additional information
regarding the effectiveness of using leachate
recirculation to enhance the rate of organic
degradation, see (Reinhart and Carson,
1993).)
3.11 RECORDKEEPING
REQUIREMENTS
40 CFR §258.29
3.11.1 Statement of Regulation
(a) The owner or operator of a
MSWLF unit must record and retain near
the facility in an operating record, or in an
alternative location approved by the
Director of an approved state, the following
information as it becomes available:
(1) Any location restriction
demonstration required under Subpart B
of this part;
(2) Inspection records, training
procedures, and notification procedures
required in §258.20 of this Part;
(3) Gas monitoring results from
monitoring and any remediation plans
required by §258.23 of this Part;
(4) Any MSWLF unit design
documentation for placement of leachate or
gas condensate in a MSWLF unit as
required under §258.28 (a)(2) of this Part;
(5) Any demonstration, certification,
finding, monitoring, testing, or analytical
data required by Subpart E of this Part;
(6) Closure and post-closure care plans
and any monitoring, testing, or analytical
data as required by §§258.60 and 258.61 of
this Part; and
(7) Any cost estimates and financial
assurance documentation required by
Subpart G of this Part.
(8) Any information demonstrating
compliance with small community
exemption as required by §258.1(f)(2).
(b) The owner/operator must notify
the State Director when the documents
from paragraph (a) of this section have
been placed or added to the operating
record, and all information contained in
the operating record must be furnished
upon request to the State Director or be
made available at all reasonable times for
inspection by the State Director.
(c) The Director of an approved State
can set alternative schedules for
recordkeeping and notification
requirements as specified in paragraphs (a)
and (b), except for the notification
requirements in §258.10(b) and
§258.55(g)(l)(iii).
3.11.2 Applicability
The regulation applies to existing MSWLF
units, lateral expansions of existing MSWLF
units, and new MSWLF units. The
recordkeeping requirements are intended to be
self-implementing so that owners/ operators in
unapproved States can comply without State
or EPA involvement. The owner or operator
is required to maintain records of
demonstrations, inspections, monitoring
results, design documents, plans, operational
110
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Operating Criteria
procedures, notices, cost estimates, and
financial assurance documentation.
3.11.3 Technical Considerations
The operating record should be maintained in
a single location. The location may be at the
facility, at corporate headquarters, or at city
hall, but should be near the facility. Records
should be maintained throughout the life of
the facility, including the post-closure care
period. Upon placement of each required
document in the operating record, the State
Director should be notified. The Director of
an approved State may establish alternative
requirements for recordkeeping, including
using the State permit file for recordkeeping.
Recordkeeping at the landfill facility should
include the following:
(a) Location restriction demonstrations:
Demonstrations are required for any location
restrictions under Subpart B. The location
restrictions apply to:
• Airports;
• Floodplains;
• Wetla
• Fault areas;
• Seismic impact zones; and
• Unstable areas.
(b) Inspection records. training
procedures, and notification procedures:
Inspection records should include:
• Date and time wastes were received during
the inspection;
• Names of the transporter and the driver;
• Source of the wastes;
• Vehicle identification numbers; and
• All observations made by the inspector.
Training records should include procedures
used to train personnel on hazardous waste
and on PCB waste recognition. Notification
to EPA, State, and local agencies should be
documented.
(c) Gas monitoring results and any
remediation plans: If gas levels exceed 25
percent of the LEL for methane in any facility
structures or exceed the LEL for methane at
the facility boundary, the owner or operator
must place in the operating record, within
seven days, the methane gas levels detected,
and a description of the steps taken to protect
human health. Within 60 days of detection,
the owner or operator must place a copy of
the remediation plan used for gas releases in
the operating record.
(d) MSWLF unit design
documentation for placement of leachate or
gas condensate in a MSWLF unit: If leachate
and/or gas condensate are recirculated into the
MSWLF unit, documentation of a composite
liner and a leachate collection system capable
of maintaining a maximum of 30 cm of
leachate head in the MSWLF unit must be
placed in the operating record.
Ill
-------
Subpart C
(e) Demonstration. certification.
monitoring, testing, or analytical Finding
required by the ground-water criteria:
Documents to be placed in the operating
record include:
• Documentation of design, installation,
development, and decommission of any
monitoring wells, piezometers, and other
measurement, sampling, and analytical
devices;
• Certification by a qualified ground-water
scientist of the number, spacing, and
depths of the monitoring systems;
• Documentation of sampling and analysis
programs and statistical procedures;
• Notice of finding a statistically significant
increase over background for one or more
of the constituents listed in Appendix I of
Part 258 (or alternative list in approved
States) at any monitoring well at the waste
management unit boundary (States with
inadequate program) or the relevant point
of compliance (approved States);
• Certification by a qualified ground-water
scientist that an error in sampling, analysis,
statistical evaluation, or natural variation in
ground water caused an increase (false
positive) of Appendix I constituents, or
that a source other than the MSWLF unit
caused the contamination (if appropriate);
• A notice identifying any Appendix II (Part
258) constituents that have been detected
in ground water and their concentrations;
• A notice identifying the Part 258
Appendix II constituents that have
exceeded the ground-water protection standard;
• A certification by a qualified ground-
water scientist that a source other than
the MSWLF unit caused the
contamination or an error in sampling,
analysis, statistical evaluation, or natural
ground-water variation caused a
statistically significant increase (false
positive) in Appendix II (Part 258)
constituents (if applicable);
• The remedies selected to remediate
ground-water contamination; and
• Certification of remediation completion.
(f) Closure and post-closure plans and
any monitoring, testing, or analytical data
associated with these plans: The landfill
facility owner or operator is required to place
a copy of the closure plan, post-closure plan,
and a notice of intent to close the facility in
the operating record. Monitoring, testing, or
analytical data associated with closure and
post-closure information generated from
ground-water and landfill gas monitoring
must be placed in the operating record. A
copy of the notation on the deed to the
MSWLF facility property, as required
following closure, along with certification and
verification that closure and post-closure
activities have been completed in accordance
with their respective plans, also must be
placed in the operating record.
(g) Estimates and financial assurance
documentation required: The following
documents must be placed in the operating
record:
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Operating Criteria
• An estimate of the cost of hiring a third
party to close the largest area of all
MSWLF units that will require final cover;
• Justification for the reduction of the
closure cost estimate and the amount of
financial assurance (if appropriate);
• A cost estimate of hiring a third party to
conduct post-closure care;
• The justification for the reduction of the
post-closure cost estimate and financial
assurance (if appropriate);
• An estimate and financial assurance for the
cost of a third party to conduct corrective
action, if necessary; and
• A copy of the financial assurance
mechanisms.
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Subpart C
3.12 FURTHER INFORMATION
3.12.1 References
Flower, et al., (1982). "Vegetation Kills in Landfill Environs"; Franklin B. Flower, Ida A. Leone,
Edward F. Oilman and John J. Arthur; Cook College, Rutgers University; New Brunswick, New
Jersey 08903.
Reinhart, D.R., and D. Carson, (1993). "Experiences with Full-Scale Application of Landfill
Bioreactor Technology," Thirty-First Annual Solid Waste Exposition of the Solid Waste
Association of North America, August 2-5, 1993.
SWANA, (1992). "A Compilation of Landfill Gas Field Practices and Procedures"; Landfill Gas
Division of the Solid Waste Association of North America (SWANA); March 1992.
U.S. Department of Agriculture Soil Conservation Service, (1986). "Urban Hydrology for Small
Watersheds"; PB87-101580.
U.S. Department of Commerce, Weather Bureau, "Rainfall Frequency Atlas of the United States for
Durations from 30 Minutes to 24 Hours and Return Periods from 1 to 100 Years."
U.S. EPA, (1985). "Handbook - Remedial Action at Waste Disposal Sites"; EPA/625/6-85/006;
U.S. EPA, Office of Research and Development; Cincinnati, Ohio 45268.
U.S. EPA, (1986). "Test Methods for Evaluating Solid Wastes: Physical/Chemical Methods";
Third Edition as amended by Updates I and II. U.S. EPA SW-846; Office of Solid Waste and
Emergency Response; Washington, D.C.
U.S. EPA, (1988). "Guide to Technical Resources for the Design of Land Disposal Facilities";
EPA/625/6-88/018; U.S. EPA; Risk Reduction Engineering Laboratory and Center for
Environmental Research Information; Cincinnati, Ohio 45268.
U.S. EPA, (1992). "Alternative Daily Cover Materials for Municipal Solid Waste Landfills;"
U.S. EPA Region IX; San Francisco, California 94105.
3.12.2 Addresses
Solid Waste Association of North America (SWANA/GRCDA)
P.O.Box 7219
Silver Spring, MD 20910
(301)585-2898
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APPENDIX I
Special Waste Acceptance Agreement
115
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Code*
Generator Name:
Address:
Special Waste Acceptance Application
Originating Division:^
Disposal Facility
Location:
Telephone: ( )
Generator Contact:
General Material Description: _
Waste Quantities:,
Units: Cubic Ws.3 Tons 3
Frequency of Receipt: Daily a Weekly O Monthly 3 One Time 3
Other
Process Generating Waste:
Physical Properties: Physical State at 7(fF: Solida SemisolidU iiquida Density:,
Viscosity: low O Medium !3 High Q Flash Point:
Water Content: % by Weight Paint Filter Test: Passed 3 Failed1!
Reactive: No 3 YesO With
f/CY Color:
Odor. YesD No 3
Waste pH:
Chemical Properties: (Concentrations in mg/l)
(TCLP) Arsenic
Barium
Benzene
Cadmium
Carbon Tetrach/oride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
Other (iist):
Other Information: Delivery Method: Bulk 3
Regulatory Agency Appro\
Infectious: Yes 3 No J
m-Cresol
p-Cresol
Cresol
2,4-D
1,4 Dichlorobemene
1,2 Dich/oroethane
1, 1-Dichloroethylene
2,4-Dinitrotoluene
Endrirt
Heptach/or
Other
tal Received: VesQ AtoO
Hexachiorobenzene
Hexach/orobutadiene
Hexach/oroethane
Lead
Lindane
Mercurv
Methoxvchlor
Methyl Ethyl Ketone
Nitrobenzene
Pentachlorophenol
Permit Number:
Pyridine
Selenium
Silver
Tetrachloroethv/ene
Toxaohene
Trichloroethvlene
2. 4. S-Trich/oroohenol
2.4.6-Trichlorophenol
2.4.5-TP (Silvexl
Vinvl Chloride
Material Safety Data Sheet Provided: Yes 3
GENERA TOR CER TIFICA TION
To the best of my knowledge, the information
provided above is accurate anrj the material is
not classified as a hazardous waste in
accordance with current regulations-.
Authorised Representative
Signature
Name
Title
Date
|| FOR OFFICE USE ONLY ||
Conditions for Acceptance
1 Originating Division Manager
2 Disposal Facility Manager
3. District Manager
4 Regional Engineer
Date
Date
Date
Date
Recertification Frequency: HI Annual 3 Annual Q Semi Annual 3
"age Ic Owner'Cperator Second Page to Customer, Third Page to Laboratory
Appendix I. Example Special Waste Acceptance Agreement
116
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CHAPTER 4
SUBPART D
DESIGN CRITERIA
-------
CHAPTER 4
SUBPART D
TABLE OF CONTENTS
4J. INTRODUCTION 121
42. PERFORMANCE-BASED DESIGN
40 CFR §258.40 122
4.2.1 Statement of Regulation 122
4.2.2 Applicability 123
4.2.3 Technical Considerations 123
Demonstration Requirements 123
Leachate Characterization 124
Assessment of Leakage Through Liners 125
Leachate Migration in the Subsurface 126
Physical Processes Controlling Contaminant Transport in the Subsurface . . 126
Chemical Processes Controlling Contaminant Transport in the Subsurface
128
Biological Processes Controlling Contaminant Transport in the Subsurface
129
Leachate Migration Models 130
Overview of the Modeling Process 130
Model Selection 135
Analytical Versus Numerical Models 135
Spatial Characteristics of the System 136
Steady-State Versus Transient Models 136
Boundary and Initial Conditions 137
Homogeneous Versus Heterogeneous Aquifer/Soil Properties 137
Availability of Data 138
Summary of Available Models 138
The EPA Multimedia Exposure Assessment Model (MULTIMED) 139
Overview of the Model 147
Application of MULTIMED to MSWLF Units 147
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4.3 COMPOSITE LINER AND LEACHATE COLLECTION SYSTEM
40 CFR §258.40 149
4.3.1 Statement of Regulation 149
4.3.2 Applicability 150
4.3.3 Technical Considerations 150
Standard Composite Liner Systems 150
Soil Liner 151
Thickness 151
Lift Thickness 151
Bonding Between Lifts 152
Placement of Soil Liners on Slopes 152
Hydraulic Conductivity 152
Soil Properties 153
Amended Soils 154
Testing 154
Soil Liner Construction 159
Geomembranes 160
Material Types and Thicknesses 160
Chemical and Physical Stress Resistance 160
Installation 162
Leachate Collection Systems 165
Grading of Low-Permeability Base 166
High-Permeability Drainage Layer 167
Soil Drainage Layers 167
Geosynthetic Drainage Nets 168
Leachate Collection Pipes 171
Protection of Leachate Collection Pipes 173
Protection of the High-Permeability Drainage Layer 178
Soil Filter Layers 178
Geotextile Filter Layers 179
Leachate Removal System 181
Other Design Considerations 182
Construction Quality Assurance and Quality Control 182
COA/COC Objectives 182
Soil Liner Quality Assurance/Quality Control 183
Soil Liner Pilot Construction (Test Fill) 185
Geomembrane Quality Assurance/Quality Control Testing 185
Destructive Testing 185
Non-Destructive Testing 186
Geomembrane Construction Quality Assurance Activities 186
Leachate Collection System Construction Quality Assurance 187
119
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4.4 RELEVANT POINT OF COMPLIANCE 40 CFR §258.40(d) 188
4.4.1 Statement of Regulation 188
4.4.2 Applicability 189
4.4.3 Technical Considerations 189
Site Hydrogeology 189
Leachate Volume and Physical Characteristics 189
Quality. Quantity and Direction of Ground-Water Flow 189
Ground-Water Receptors 190
Alternative Drinking Water Supplies 190
Existing Ground-Water Quality 190
Public Health. Welfare. Safety 190
Practicable Capability of the Owner or Operator 191
4_J PETITION PROCESS 40 CFR §258.40(e^ 191
4.5.1 Statement of Regulation 191
4.5.2 Applicability 191
4A FURTHER INFORMATION 193
4.6.1 REFERENCES (Specific to Performance-Based Design Assessment and Solute
Transport Modeling) 193
4.6.2 REFERENCES (Specific to Design Criteria^ 199
4.6.3 Models 202
120
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CHAPTER 4
SUBPART D
DESIGN CRITERIA
4.1 INTRODUCTION
New MSWLF facilities and lateral expansions of existing units must comply with either a design
standard or a performance standard for landfill design. The Federal Criteria do not require existing
units to be retrofitted with liners. The design standard requires a composite liner composed of two
feet of soil with a hydraulic conductivity of no more than 1 x 10"7 cm/sec, overlain by a flexible
membrane liner (FML) and a leachate collection system. A performance-based design must
demonstrate the capability of maintaining contaminant concentrations below maximum contaminant
levels (MCLs) at the unit's relevant point of compliance. The performance standard has been
established to allow design innovation and consideration of site-specific conditions; approved States
may have adopted alternative design standards. Owners/operators are advised to work closely with
State permitting agencies to determine the applicable design standard. Owners/operators in
unapproved States may use the petition process (§258.40(c)) to allow for use of a performance-
based design. This process is discussed in Section 4.5.
The technical considerations discussed in this chapter are intended to identify the key design features
and system components for the composite liner and leachate collection system standards, and for
the performance standard. The technical considerations include 1) design concepts, 2) design
calculations, 3) physical properties, and 4) construction methods for the following:
1) Designs Based on the Performance Standard
• Leachate characterization and leakage assessment;
• Leachate migration in the subsurface;
• Leachate migration models; and
• Relevant point of compliance assessment.
2) Composite Liners and Leachate Collection Systems
• Soil liner component (soil properties lab testing, design, construction, and quality
assurance/quality control testing);
• Flexible membrane liners (FML properties, design installation, and quality
assurance/quality control testing);
• Leachate collection systems (strength and compatibility, grading and drainage, clogging
potential, and filtration);
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Subpart D
• Leachate removal systems (pumps, sumps, and standpipes); and
• Inspections (field observations and field and laboratory testing).
Designs based on the performance standard are described in Section 4.2. Requirements for
composite liners are discussed in Section 4.3. These sections address the minimum regulatory
requirements that should be considered during the design, construction, and operation of MSWLF
units to ensure that they perform in a manner protective of human health and the environment.
Additional features or procedures may be used to demonstrate conformance with the regulations or
to control leachate release and subsequent effects. For example, during construction of a new
MSWLF unit, or a lateral expansion of an existing MSWLF unit, quality control and quality
assurance procedures and documentation may be used to ensure that material properties and
construction methods meet the design specifications that are intended to achieve the expected level
of performance. Section 4.4 presents methods to assess ground-water quality at the relevant point
of compliance for performance-based designs. Section 4.5 describes the applicability of the petition
process for States wishing to petition to use the performance standard.
4.2 PERFORMANCE-BASED DESIGN
40 CFR §258.40(a)(l)
4.2.1 Statement of Regulation
(a) New MSWLF units and lateral
expansions shall be constructed:
(1) In accordance with a design
approved by the Director of an approved
State or as specified in §258.40(e) for
unapproved States. The design must ensure
that the concentration values listed in
Table 1 will not be exceeded in the
uppermost aquifer at the relevant point of
compliance as specified by the Director of
an approved State under paragraph (d) of
this section, or
(2) (See Statement of Regulation in
Section 4.3.1 of this guidance document for
the regulatory language for composite liner
requirements).
(b) (See Statement of Regulation in
Section 4.3.1 of this guidance document for
the regulatory language for requirements
pertaining to composite liner and leachate
collection systems).
(c) When approving a design that
complies with paragraph (a)(l) of this
section, the Director of an approved State
shall consider at least the following factors:
(1) The hydrogeologic characteristics
of the facility and surrounding land;
(2) The climatic factors of the area;
and
(3) The volume and physical and
chemical characteristics of the leachate.
(d) (See Statement of Regulation in
Section 4.4.1 of this guidance document for a
discussion of the determination of the relevant
point of compliance.)
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Design Criteria
TABLE 1
(40 CFR 258.40; 56 FR 51022;
October 9, 1991)
Chemical
MCL(mg/l)
Arsenic 0.05
Barium 1.0
Benzene 0.005
Cadmium 0.01
Carbon tetrachloride 0.005
Chromium (hexavalent) 0.05
2,4-Dichlorophenoxy
acetic acid 0.1
1,4-Dichlorobenzene 0.075
1,2-Dichloroethane 0.005
1,1-Dichloroethylene 0.007
Endrin 0.0002
Fluoride 4.0
Lindane 0.004
Lead 0.05
Mercury 0.002
Methoxychlor 0.1
Nitrate 10.0
Selenium 0.01
Silver 0.05
Toxaphene 0.005
l,l?l-Trichloroethane 0.2
Trichloroethylene 0.005
2,4,5-Trichlorophenoxy
acetic acid 0.01
Vinyl Chloride 0.002
4.2.2 Applicability
The Director of an approved State may
approve a performance-based design for new
MSWLF units and lateral expansions of
existing units (see Section 4.3.2), if it meets
the requirements specified in 40 CFR
258.40(a)(l). A performance-based design is
an alternative to the design standard
(composite liner with a leachate collection
system). The composite design is required in
unapproved States; however, if EPA does not
promulgate procedures for State approval by
October 9, 1993, the performance-based
design may be available through the petition
process (see Section 4.5).
4.2.3 Technical Considerations
Demonstration Requirements
For approval of landfill designs not
conforming to the uniform design standard of
a composite liner system and a leachate
collection system (40 CFR §258.40(a)(2)), the
owner or operator of the proposed MSWLF
unit must demonstrate to the Director of an
approved State that the design will not allow
the compounds listed in Table 1 of §258.40 to
exceed the MCLs in ground water at the
relevant point of compliance. The
demonstration should consider an assessment
of leachate quality and quantity, leachate
leakage to the subsurface, and subsurface
transport to the relevant point of compliance.
These factors are governed by site
hydrogeology, waste characteristics, and
climatic conditions.
The nature of the demonstration is essentially
an assessment of the potential for leachate
production and leakage from the landfill to
ground water, and the anticipated fate and
transport of constituents listed in Table 1 to
the proposed relevant point of compliance at
the facility. Inherent in this approach is the
need to evaluate whether contaminants in
ground water at the relevant point of
compliance will exceed the concentration
values listed in Table 1. If so, then the owner
or operator needs to obtain sufficient site-
specific data to adequately characterize the
existing ground-
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Subpart D
water quality and the existing ground-water
flow regime (e.g., flow direction, horizontal
and vertical gradients, hydraulic conductivity,
stratigraphy, and aquifer thickness).
An assessment should be made of the effect
MSWLF facility construction will have on
site hydrogeology. The assessment should
focus on the reduced infiltration over the
landfill area and altered surface water run-off
patterns. Reduction of ground-water recharge
and changes in surface water patterns
resulting from landfill construction may affect
ground-water gradients in some cases and
may result in changes in lateral flow
directions. One example of a hypothetical
performance-based demonstration follows.
It is possible that a MSWLF unit located in an
arid climatic zone would not produce leachate
from sources of water (e.g., precipitation)
other than that existing within the waste at the
time of disposal. In such an environment, an
owner or operator may demonstrate that
significant quantities of leachate would not be
produced. The demonstration should be
supported by evaluating historic precipitation
and evaporation data and the likelihood that
the unit could be flooded as the result of
heavy rains, surface run-off, or high water
tables. It may be possible, through
operational controls, to avoid exposing waste
to precipitation or infiltration of water
through overlying materials. If significant
leachate production would not be expected,
the regulatory authority, when reviewing the
demonstration, should consider the
hydrogeologic characteristics of the facility
and the surrounding area, in addition to the
expected volume of leachate and climatic
factors.
Assuming leachate is produced, the
demonstration should evaluate whether
constituents listed in Table 1 can be expected
to be present at concentrations greater than the
MCLs. If such a demonstration is possible, it
must address the hydrogeologic characteristics
of the facility and the surrounding land to
comply with §258.40(d). The following
sections describe the various parts of a
demonstration in greater detail.
Leachate Characterization
Leachate characterization should include an
assessment and demonstration of the quantity
and composition of leachate anticipated at the
proposed facility. Discussion of this
assessment follows.
Estimates of volumetric production rates of
leachate are important in evaluating the fate
and transport of the constituents listed in
Table 1. Leachate production rates depend on
rainfall, run-on, run-off, evapotranspiration,
water table elevation relative to the bottom of
the landfill unit, in-place moisture content of
waste, and the prevention of liquid disposal at
the site. Run-on, run-off, and water table
factors can be managed traditionally through
design and operational controls. The MSWLF
Criteria prohibit bulk or containerized liquid
disposal. Incident precipitation and
evapotranspiration can be evaluated using
models (e.g., HELP) or other methods of
estimating site-specific leachate production
(e.g., local historical meteorologic data).
If leachate composition data that are
representative of the proposed facility are not
available, then leachate data with a similar
expected composition should be presented.
Landfill leachate composition is influenced
by:
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Design Criteria
(1) The annual infiltration of precipitation
and rate of leaching;
(2) The type and relative amounts of
materials in the waste stream; and
(3) The age and the biological maturity of
the landfill unit, which may affect the
types of organic and inorganic acids
generated, oxidation/reduction potential
(Eh), and pH conditions.
An existing landfill unit in the same region,
with similar waste stream characteristics, may
provide information that will allow the owner
or operator to anticipate leachate composition
of the proposed landfill unit. A review of
existing literature also may be required to
assess anticipated leachate composition if
actual data are unavailable (see U.S. EPA,
1987b). A wide range of leachate
concentrations are reported in the literature
with higher concentrations of specific
constituents typically reported for the initial
leachate from laboratory or field experimental
test fills or test cells. These "batch" one-day
landfill tests do not account for the long-term
climatic and meteorological influences on a
full-scale landfill operation. Such high initial
concentrations are not typical of full-scale
operations (which are subject to the dilution
effects of incidental rainfall on unused
portions of the unit).
Assessment of Leakage Through Liners
An assessment of leakage (the volumetric
release of leachate from the proposed
performance-based design) should be based
on analytical approaches supported by
empirical data from other existing operational
facilities of similar design, particularly those
that have leak detection monitoring systems
(see U.S. EPA, 1990b).
In lieu of the existence or availability of such
information, conservative analytical
assumptions may be used to estimate
anticipated leakage rates.
The transport of fluids and waste constituents
through geomembranes differs in principle
from transport through soil liner materials.
The dominant mode of leachate transport
through liner components is flow through
holes and penetrations of the geomembrane,
and Darcian flow through soil components.
Transport through geomembranes where tears,
punctures, imperfections, or seam failures are
not involved is dominated by molecular
diffusion. Diffusion occurs in response to a
concentration gradient and is governed by
Pick's first law. Diffusion rates through
geomembranes are very low in comparison to
hydraulic flow rates in soil liners, including
compacted clays. For synthetic liners, the
most significant factor influencing liner
performance is penetration of the liner,
including imperfect seams or pinholes caused
by construction defects in the geomembrane
(U.S. EPA, 1989).
A relatively new product now being used in
liner systems is the geosynthetic clay liner
(GCL). GCLs consist of a layer of pure
bentonite clay backed by one or two
geotextiles. GCLs exhibit properties of both
soil liners and geomembranes, and have
successfully substituted for the soil
component in composite liner designs. GCLs
are believed to transport fluids primarily
through diffusion according to their low
hydraulic conductivities (i.e., 1 x 10"9 cm/sec
reported by manufacturers). Applications for
GCLs are discussed further in the sections that
follow.
Several researchers have studied the flow of
fluids through imperfections in single
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Subpart D
geomembrane and composite liner systems.
Further discussion of liner leakage rates can
be found in Section 4.3.3 below. For
empirical data and analytical methods the
reader is referred to Jayawickrama et al.
(1988), Kastman (1984), Haxo (1983), Haxo
et al. (1984), Radian (1987), Giroud and
Bonaparte (1989, Parts I and II), and Giroud
et al. (1989). Leakage assessments also may
be conducted with the use of the HELP model
(U.S. EPA, 1988). Version 3.0 of the model
is under revision and will include an updated
method to assess leakage that is based on
recent research and data compiled by Giroud
and Bonaparte.
Leachate Migration in the Subsurface
Leachate that escapes from a landfill unit may
migrate through the unsaturated zone and
eventually reach the uppermost aquifer. In
some instances, however, the water table may
be located above the base of the landfill unit,
so that only saturated flow and transport from
the landfill unit need to be considered. Once
leachate reaches the water table, contaminants
may be transported through the saturated zone
to a point of discharge (i.e., a pumping well,
a stream, a lake, etc.).
The migration of leachate in the subsurface
depends on factors such as the volume of the
liquid component of the waste, the chemical
and physical properties of the leachate
constituents, the loading rate, climate, and the
chemical and physical properties of the
subsurface (saturated and unsaturated zones).
A number of physical, chemical, and
biological processes also may influence
migration. Complex interactions between
these processes may result in specific
contaminants being transported through the
subsurface at different rates. Certain
processes result in the attenuation and
degradation of contaminants. The degree of
attenuation is dependent on the time that the
contaminant is in contact with the subsurface
material, the physical and chemical
characteristics of the subsurface material, the
distance that the contaminant has traveled,
and the volume and characteristics of the
leachate. Some of the key processes affecting
leachate migration are discussed briefly here.
The information is based on a summary in
Travers and Sharp-Hansen (1991), who in
turn relied largely on Aller et al. (1987),
Keely (1987), Keely (1989), Lu et al. (1985),
and U.S. EPA(1988a).
Physical Processes Controlling
Contaminant Transport in the Subsurface
Physical processes that control the transport of
contaminants in the subsurface include
advection, mixing and dilution as a result of
dispersion and diffusion, mechanical
filtration, physical sorption, multi-phase fluid
flow, and fracture flow. These processes, in
turn, are affected by hydrogeologic
characteristics, such as hydraulic conductivity
and porosity, and by chemical processes.
Advection is the process by which solute
contaminants are transported by the overall
motion of flowing ground water. A non-
reactive solute will be transported at the same
rate and in the same direction as ground water
flow (Freeze and Cherry, 1979). Advective
transport is chiefly a function of the
subsurface hydraulic conductivity distribution,
porosity, and hydraulic gradients.
Hydrodynamic dispersion is a non-steady,
irreversible mixing process by which a
contaminant plume spreads as it is transported
through the subsurface. Dispersion results
from the effects of two
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Design Criteria
components operating at the microscopic
level: mechanical dispersion and molecular
diffusion. Mechanical dispersion results from
variations in pore velocities within the soil or
aquifer and may be more significant than
molecular diffusion in environments where
the flow rates are moderate to high.
Molecular diffusion occurs as a result of
contaminant concentration gradients;
chemicals move from high concentrations to
low concentrations. At very slow ground-
water velocities, as occur in clays and silts,
diffusion can be an important transport
mechanism.
Mechanical filtration removes from ground
water contaminants that are larger than the
pore spaces of the soil. Thus, the effects of
mechanical filtration increase with decreasing
pore size within a medium. Filtration occurs
over a wide range of particle sizes. The
retention of larger particles may effectively
reduce the permeability of the soil or aquifer.
Physical sorption is a function of Van der
Waals forces, and the hydrodynamic and
electrokinetic properties of soil particles.
Sorption is the process by which contaminants
are removed from solution in ground water
and adhere or cling to a solid surface. The
distribution of a contaminant between the
solution and the solid phase is called
partitioning.
Multiphase fluid flow occurs because many
solvents and oils are highly insoluble in water
and may migrate in the subsurface as a
separate liquid phase. If the viscosity and
density of a fluid differ from that of water, the
fluid may flow at a different rate and direction
than the ground water. If the fluid is more
dense than water it may reach the bottom of
the aquifer (top of an aquitard)
and alter its flow direction to conform to the
shape and slope of the aquitard surface.
Hydraulic conductivity is a measure of the
ability of geologic media to transmit fluids
(USGS, 1987). It is a function of the size and
arrangement of water-transmitting openings
(pores and fractures) in the media and of the
characteristics of the fluids (density, viscosity,
etc.). Spatial variations in hydraulic
conductivity are referred to as heterogeneities.
A variation in hydraulic conductivity with the
direction of measurement is referred to as
anisotropy.
Variable hydraulic conductivity of the
geologic formation may cause ground-water
flow velocities to vary spatially. Variations in
the rate of advection may result in non-
uniform plume spreading. The changes in
aquifer properties that lead to this variability
in hydraulic conductivity may be three-
dimensional. If the geologic medium is
relatively homogeneous, it may be
appropriate, in some instances, to assume that
the aquifer properties also are homogeneous.
Secondary porosity in rock may be caused by
the dissolution of rock or by regional
fracturing; in soils, secondary porosity may be
caused by desiccation cracks or fissures.
Fractures or macropores respond quickly to
rainfall events and other fluid inputs and can
transmit water rapidly along unexpected
pathways. Secondary porosity can result in
localized high concentrations of contaminants
at significant distances from the facility. The
relative importance of secondary porosity to
hydraulic conductivity of the subsurface
depends on the ratio of fracture hydraulic
conductivity to intergranular hydraulic
conductivity (Kincaid et al., 1984a). For
scenarios in which fracture flow is dominant,
the relationships
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Subpart D
used to describe porous flow (Darcy's Law)
do not apply.
Chemical Processes Controlling
Contaminant Transport in the Subsurface
Chemical processes that are important in
controlling subsurface transport include
precipitation/dissolution, chemical sorption,
redox reactions, hydrolysis, ion exchange, and
complexation. In general, these processes,
except for hydrolysis, are reversible. The
reversible processes tend to retard transport,
but do not permanently remove a contaminant
from the system. Sorption and precipitation
are generally the dominant mechanisms
retarding contaminant transport in the
saturated zone.
Precipitation/dissolution reactions can control
contaminant concentration levels. The
solubility of a solid controls the equilibrium
state of a chemical. When the soluble
concentration of a contaminant in leachate is
higher than that of the equilibrium state,
precipitation occurs. When the soluble
concentration is lower than the equilibrium
value, the contaminant exists in solution. The
precipitation of a dissolved substance may be
initiated by changes in pressure, temperature,
pH, concentration, or redox potential (Aller et
al., 1987). Precipitation of contaminants in
the pore space of an aquifer can decrease
aquifer porosity. Precipitation and dissolution
reactions are especially important processes
for trace metal migration in soils.
Chemical adsorption/desorption is the most
common mechanism affecting contaminant
migration in soils. Solutes become attached
to the solid phase by means of adsorption.
Like precipitation/dissolution,
adsorption/desorption is a reversible process.
However, adsorption/desorption
generally occurs at a relatively rapid rate
compared to precipitation reactions.
The dominant mechanism of organic sorption
is the hydrophobic attraction between a
chemical and natural organic matter that exists
in some aquifers. The organic carbon content
of the porous medium, and the solubility of
the contaminant, are important factors for this
type of sorption.
There is a direct relationship between the
quantity of a substance sorbed on a particle
surface and the quantity of the substance
suspended in solution. Predictions about the
sorption of contaminants often make use of
sorption isotherms, which relate the amount of
contaminant in solution to the amount
adsorbed to the solids. For organic
contaminants, these isotherms are usually
assumed to be linear and the reaction is
assumed to be instantaneous and reversible.
The linear equilibrium approach to sorption
may not be adequate for all situations.
Oxidation and reduction (redox) reactions
involve the transfer of electrons and occur
when the redox potential in leachate is
different from that of the soil or aquifer
environment. Redox reactions are important
processes for inorganic compounds and
metallic elements. Together with pH, redox
reactions affect the solubility, complexing
capacity, and sorptive behavior of
constituents, and thus control the presence and
mobility of many substances in water.
Microorganisms are responsible for a large
proportion of redox reactions that occur in
ground water. The redox state of an aquifer,
and the identity and quantity of redox-active
reactants, are difficult to determine.
128
-------
Design Criteria
Hydrolysis is the chemical breakdown of
carbon bonds in organic substances by water
and its ionic species H+ and OH". Hydrolysis
is dependent on pH and Eh and is most
significant at high temperatures, low pH, and
low redox potential. For many biodegradable
contaminants, hydrolysis is slow compared to
biodegradation.
Ion exchange originates primarily from
exchange sites on layered silicate clays and
organic matter that have a permanent negative
charge. Cation exchange balances negative
charges in order to maintain neutrality. The
capacity of soils to exchange cations is called
the cation exchange capacity (CEC). CEC is
affected by the type and quantity of clay
mineral present, the amount of organic matter
present, and the pH of the soil. Major cations
in leachate (Ca, Mg, K, Na) usually dominate
the CEC sites, resulting in little attenuation in
soils of trace metals in the leachate.
A smaller ion exchange effect for anions is
associated with hydrous oxides. Soils
typically have more negatively charged clay
particles than positively charged hydrous
oxides. Therefore, the transport of cations is
attenuated more than the transport of anions.
Complexation involves reactions of metal ions
with inorganic anions or organic ligands. The
metal and the ligand bind together to form a
new soluble species called a complex.
Complexation can either increase the
concentration of a constituent in solution by
forming soluble complex ions or decrease the
concentration by forming a soluble ion
complex with a solid. It is often difficult to
distinguish among sorption, solid-liquid
Complexation, and ion exchange.
Therefore, these processes are usually
grouped together as one mechanism.
Biological Processes Controlling
Contaminant Transport in the Subsurface
Biodegradation of contaminants may result
from the enzyme-catalyzed transformation of
organic compounds by microbes.
Contaminants can be degraded to harmless
byproducts or to more mobile and/or toxic
products through one or more of several
biological processes. Biodegradation of a
compound depends on environmental factors
such as redox potential, dissolved oxygen
concentration, pH, temperature, presence of
other compounds and nutrients, salinity, depth
below land surface, competition among
different types of organisms, and
concentrations of compounds and organisms.
The transformations that occur in a subsurface
system are difficult to predict because of the
complexity of the chemical and biological
reactions that may occur. Quantitative
predictions of the fate of biologically reactive
substances are subject to a high degree of
uncertainty, in part, because little information
is available on biodegradation rates in soil
systems or ground water. First-order decay
constants are often used instead.
The operation of Subtitle D facilities can
introduce bacteria and viruses into the
subsurface. The fate and transport of bacteria
and viruses in the subsurface is an important
consideration in the evaluation of the effects
of MSWLF units on human health and the
environment. A large number of biological,
chemical, and physical processes are known to
influence virus and bacterial survival and
transport in the subsurface. Unfortunately,
knowledge of the processes and the available
data are insufficient to develop models that
can
129
-------
Subpart D
simulate a wide variety of site-specific
conditions.
Leachate Migration Models
After reviewing the hydrogeologic
characteristics of the site, the nature of liner
leakage, and the leachate characteristics, it
may be appropriate to use a mathematical
model to simulate the expected fate and
transport of the constituents listed in Table 1
to the relevant point of compliance. Solute
transport and ground-water modeling efforts
should be conducted by a qualified ground-
water scientist (see Section 5.5). It is
necessary to consider several factors when
selecting and applying a model to a site.
Travers and Sharp-Hansen (1991) provide a
thorough review of these issues. The text
provided below is a summary of their review.
Overview of the Modeling Process
A number of factors can influence leachate
migration from MSWLF units. These
include, but are not limited to, climatic
effects, the hydrogeologic setting, and the
nature of the disposed waste. Each facility is
different, and no one generic model will be
appropriate in all situations. To develop a
model for a site, the modeling needs and the
objectives of the study should be determined
first. Next, it will be necessary to collect data
to characterize the hydrological, geological,
chemical, and biological conditions of the
system. These data are used to assist in the
development of a conceptual model of the
system, including spatial and temporal
characteristics and boundary conditions. The
conceptual model and data are then used to
select a mathematical model that accurately
represents the conceptual model. The model
selected should have been tested and
evaluated by qualified investigators, should
adequately simulate the significant processes
present in the actual system, and should be
consistent with the complexity of the study
area, amount of available data, and objectives
of the study.
First, an evaluation of the need for modeling
should be made (Figure 4-1). When selecting
a model to evaluate the potential for soil and
ground-water contamination (Boutwell et al.,
1986), three basic determinations must be
made (Figure 4-2). Not all studies require the
use of a mathematical model. This decision
should be made at the beginning of the study,
since modeling may require a substantial
amount of resources and effort. Next, the
level of model complexity required for a
specific study should be determined (Figure
4-3). Boutwell et al. (1986) classify models
as Level I (simple/analytical) and Level II
(complex/numerical) models. A flowchart for
determining the level of model complexity
required is shown in Figure 4-3. Finally, the
model capabilities necessary to represent a
particular system should be considered
(Figure 4-4). Several models may be equally
suitable for a particular study. In some cases,
it may be necessary to link or couple two or
more computer models to accurately represent
the processes at the site. In the section that
follows, specific issues that should be
considered when developing a scenario and
selecting a model are described.
Models are a simplified representation of the
real system, and as such, cannot fully
reproduce or predict all site characteristics.
Errors are introduced as a result of: 1)
simplifying assumptions; 2) a lack of data; 3)
uncertainty in existing data; 4) a poor
understanding of the processes influencing the
fate and transport of contaminants; and
130
-------
Model Selection is
Not Required
Is Modeling
Necessary?
(See Figure
4.10)
What
Level of
Modeling is
Required?
(See Figure
4.10)
Complex/Numerical
Complex/Numerical
What are
the Required
Level II Model
Capabilities?
(See Figure
4-12)
What are
the Required
Level I Model
Capabilities?
(See Figure
4-12)
Figure 4-1
Three Basic Decisions in Model Selection
(Boutwell et. al., 1986)
131
-------
Develop Conceptual
Understanding of Site
Can
Assumptions
be Confirmed
with Existing
Data?
Will
Additional
Data Improve
Understanding?
Do
You Need
Quantitative
Estimates of
Future
Conditions?
Specify
Sampling
Requirements
Determine Level
of Modeling
Required
Figure 4-2
Flow Chart to Determine if Modeling is Required
(Boutwell et. al., 1986)
132
-------
Level of Modeling Required 1
r i
Level 1: Analytical Models 1 Level II: Numerical Models 1
j j
Identification of Remedial 1 Model Selection Criteria 1
Action-Specific Models I I
\
|
1 1 1 1
• r^- • r.. 1 Time I Resources/ I
Processes I Dimensionality I c 1 Data 1
*
Model Selection 1 Model Selection 1
Figure 4-3
Flow Chart to Determine the Level of Modeling Required for
Soil and Groundwater Systems
(Boutwell et. al., 1986)
133
-------
Are
OitJer of
Magnitude
Predictions
Acceptable
Reassess Goals
and Data Needs
is Ft
Reasonable
to Assume mat
Media Properties
are Uniform, and
Do Not Vary
is it
Reasonable
to Assume that
tr>e Ro* Fiatg
Uniform. Steady
and Regular''
IS it
Reasonabto
to Assume that
the 5» Geometry
is Regular
Are (ne
Selected
Remed4aj Actions
Reiatrveiy S«mpie in
ConAgurason'
Does
me PoUutant Have
ReBBvsty the Same
Density as
Water?
Do You Have Sufficient
Resources and Available
Data tor Numerical Models?
Use Level!: Anarylical Model
Use Level II: Numencal Model
Figure 4-4
Flow Chart for Required Model Capabilities for Soil and Groundwater Systems
(Boutwell et. al., 1986)
134
-------
Design Criteria
5) limitations of the model itself. Therefore,
model results should be interpreted as
estimates of ground-water flow and
contaminant transport. Bond and Hwang
(1988) recommend that models be used for
comparing various scenarios, since all
scenarios would be subject to the same
limitations and simplifications.
The quality of model results can depend to a
large extent on the experience and judgement
of the modeler, and on the quality of the data
used to develop model input. The process of
applying the model may highlight data
deficiencies that may require additional data
collection. The model results should be
calibrated to obtain the best fit to the observed
data. The accuracy of the results obtained
from modeling efforts should then be
validated. Model validation, which is the
comparison of model results with
experimental data or environmental data, is a
critical aspect of model application, and is
particularly important for site-specific
evaluations.
Several recent reports present detailed
discussions of the issues associated with
model selection, application, and validation.
Donigian and Rao (1990) address each of
these issues, and present several options for
developing a framework for model validation.
EPA's Exposure Assessment Group has
developed suggested recommendations and
guidance on model validation (Versar Inc.,
1987). A recent report by the National
Research Council (1990) discusses the issues
related to model application and validation,
and provides recommendations for the proper
use of ground-water models. Weaver et al.
(1989) discuss options for selection and field
validation of mathematical models.
Model Selection
Ground-water flow and solute transport
models range from simple, analytical
calculations to sophisticated computer
programs that use numerical solutions to solve
mathematical equations describing flow and
transport. A sophisticated model may not
yield an exact estimate of water quality at the
relevant point of compliance for a given set of
site conditions, but it may allow an estimate
of the effects of complex physical and
chemical processes. Depending on the
complexity of site conditions and the
appropriateness of the simplifying
assumptions, a fairly sophisticated numerical
model may provide useful estimates of water
quality at the relevant point of compliance.
The following considerations should be
addressed when selecting a model.
Analytical Versus Numerical Models
Mathematical models use either analytical,
semi-analytical, or numerical solutions for
ground-water flow and transport equations.
Each technique has advantages and
disadvantages. Analytical solutions are
computationally more efficient than numerical
simulations and are more conducive to
uncertainty analysis (i.e., Monte Carlo
techniques). Typically, input data for
analytical models are simple and do not
require detailed familiarity with the computer
model or extensive modeling experience.
Analytical solutions are typically used when
data necessary for characterization of the site
are sparse and simplifying assumptions are
appropriate (Javandel et al., 1984). The
limited data available in most field situations
may not justify the use of a detailed numerical
model; in some cases, results from simple
analytical models may be appropriate
135
-------
Subpart D
(Huyakorn et al., 1986). Analytical models
require simplifying assumptions about the
system. Therefore, complex interactions
involving several fate and transport processes
cannot be addressed in detail. Analytical
models generally require a limited number of
parameters that are often assumed to be
constant in space and time (van der Heijde
andBeljin, 1988).
Semi-analytical models approximate complex
analytical solutions using numerical
techniques (van der Heijde and Beljin, 1988).
Semi-analytical methods allow for more
complex site conditions than those that can be
simulated with a purely analytical solution.
Semi-analytical solution methods can consider
multiple sources or recharging and
discharging wells. However, they still require
simplifying assumptions about the
dimensionality and homogeneity of the
system.
Numerical models are able to evaluate more
complex site conditions than either analytical
or semi-analytical models. Numerical models
provide the user with a large amount of
flexibility; irregular boundaries and spatial
and temporal variations in the system can be
considered. Numerical models require
significantly more data than analytical
models, and are typically more
computationally intensive. Use of a
numerical model requires an experienced
modeler, and can involve a larger amount of
computer time than simulations using an
analytical or semi-analytical method.
To select an appropriate model, the
complexity of the site hydrology and the
availability of data should be considered. If
data are insufficient, a highly sophisticated
and complex model should not be used. In
some situations, it is beneficial to use an
analytical or semi-analytical model as a
"screening level" model to define the range of
possible values, and to use a numerical model
when there are sufficient data.
A highly complex hydrogeologic system
cannot be accurately represented with a
simple analytical model. Heterogeneous or
anisotropic aquifer properties, multiple
aquifers, and complicated boundary
conditions can be simulated using numerical
models. In addition, sophisticated numerical
models are available that can simulate
processes such as fracture flow. Because each
site is unique, the modeler should determine
which conditions and processes are important
at a specific site, and then select a suitable
model.
Spatial Characteristics of the System
Although actual landfill units and
hydrogeologic systems are three-dimensional,
it is often desirable to reduce the number of
dimensions simulated in a mathematical
model to one or two. Two- and three-
dimensional models are generally more
complex and computationally expensive than
one-dimensional models, and therefore
require more data. In some instances, a one-
dimensional model may adequately represent
the system; the available data may not warrant
the use of a multi-dimensional model.
However, modeling a truly three-dimensional
system using a two-dimensional model may
produce results without adequate spatial
detail. The choice of the number of
dimensions in the model should be made for
a specific site, based on the complexity of the
site and the availability of data.
Steady-State Versus Transient Models
Models can simulate either steady-state or
transient flow conditions. It may be
136
-------
Design Criteria
appropriate to assume that some ground-water
flow systems have reached approximate
"steady-state" conditions, which implies that
the system has reached equilibrium and no
significant changes are occurring over time.
The assumption of steady-state conditions
generally simplifies the mathematical
equations used to describe flow processes, and
reduces the amount of input data required.
However, assuming steady-state conditions in
a system that exhibits transient behavior may
produce inaccurate results. For example,
climatic variables, such as precipitation, vary
over time and may have strong seasonal
components. In such settings, the assumption
of constant recharge of the ground-water
system would be incorrect. Steady-state
models also may not be appropriate for
evaluating the transport of chemicals which
sorb or transform significantly (Mulkey et al.,
1989). The choice of simulating steady-state
or transient conditions should be based on the
degree of temporal variability in the system.
Boundary and Initial Conditions
The solution of differential equations
describing flow and transport processes
requires that initial and boundary conditions
be specified. The initial conditions describe
the conditions present in the system at the
beginning of the simulation. In many ground-
water flow and transport models, these
conditions are related to the initial hydraulic
conditions in the aquifer and the initial
concentration of contaminants. Boundary
conditions define the conditions present on the
borders of the system, which may be steady-
state or temporally variable. The initial and
boundary conditions chosen to represent a site
can significantly affect the results of the
simulation.
One of the most significant boundary
conditions in solute transport models is the
introduction of a contaminant to the system.
A source of ground-water contamination
should be described in terms of its spatial,
chemical, and physical characteristics, and its
temporal behavior. Spatially, a source may be
classified as a point source, line source, a
distributed source of limited areal or three-
dimensional extent, or as a non-point source
of unlimited extent (van der Hjeide et al.,
1988). Typically, temporal descriptions of the
source term boundary conditions for models
with analytical solutions are constant, constant
pulse, and/or exponential decay (Mulkey et
al., 1989). Numerical models typically handle
a much wider range of source boundary
conditions, allowing for a wide range of
contaminant loading scenarios.
Homogeneous Versus
Aquifer/Soil Properties
Heterogeneous
The extent of the spatial variability of the
properties of each aquifer will significantly
affect the selection of a mathematical model.
Many models assume uniform aquifer
properties, which simplifies the governing
equations and improves computational
efficiency. For example, a constant value of
hydraulic conductivity may be assumed at
every point in the aquifer. However, this
assumption may ignore the heterogeneity in
the hydrogeologic system. Bond and Hwang
(1988) present guidelines for determining
whether the assumption of uniform aquifer
properties is justified at a particular site.
They state that the error associated with using
an average value versus a spatial distribution
is site-specific and extremely difficult to
determine.
When site-specific data are limited, it is
common to assume homogeneous and
137
-------
Subpart D
isotropic aquifer properties, and to develop a
"reasonable worst-case" scenario for
contaminant migration in the subsurface.
However, as Auerbach (1984) points out, the
assumption of homogeneous and isotropic
aquifers often will not provide a "worst-case"
scenario. For example, a continuous zone of
higher hydraulic conductivity in the direction
of ground-water flow can result in much
higher rates of contaminant movement than
would be predicted in a completely
homogeneous aquifer. To develop a true
"worst-case" model, information on the
probable heterogeneity and anisotropy of the
site should be collected.
The number of aquifers in the hydrogeologic
system also will affect the selection of a
mathematical model. Some systems include
only a single unconfmed or confined aquifer,
which is hydraulically isolated from the
surrounding layers. Some mathematical
models, and in particular those with analytical
solutions, can simulate only single layers. In
other cases, the upper aquifer may be
hydraulically connected to underlying
aquifers. The MSWLF Criteria specify that
MCLs not be exceeded at the relevant point of
compliance within the uppermost aquifer.
The uppermost aquifer includes not only the
aquifer that is nearest the ground surface, but
also all lower aquifers that are hydraulically
connected to the uppermost aquifer within the
vicinity of the facility.
Availability of Data
Although computer models can be used to
make predictions about leachate generation
and migration, these predictions are highly
dependent on the quantity and quality of the
available data. One of the most common
limitations to modeling is insufficient data.
Uncertainty in model predictions results from
the inability to characterize a site in terms of
the boundary conditions or the key parameters
describing the significant flow and transport
processes (National Research Council, 1990).
The application of a mathematical model to a
site typically requires a large amount of data.
Inexperienced modelers may attempt to apply
a model with insufficient data and, as a result,
produce model results that are inconclusive.
To obtain accurate model results, it is
essential to use data that are appropriate for
the particular site being modeled. Models that
include generic parameters, based on average
values for similar sites, can be used to provide
initial guidance and general information about
the behavior of a system, but it is
inappropriate to apply generic parameters to a
specific hydrogeologic system. An excellent
summary of the data required to model
saturated and unsaturated flow, surface water
flow, and solute transport is presented in
Mercer et al. (1983). This report provides
definitions and possible ranges of values for
source terms, dependent variables, boundary
conditions, and initial conditions.
Summary of Available Models
Several detailed reviews of ground-water
models are available in the literature. A
number of ground-water models, including
saturated flow, solute transport, heat transport,
fracture flow, and multiphase flow models,
are summarized in van der Heijde et al.
(1988). A report by van der Heijde and Beljin
(1988) provides detailed descriptions of 64
ground-water flow and solute transport
models that were selected for use in
determining wellhead protection areas. A
review of ground-water flow and
138
-------
Design Criteria
transport models for the unsaturated zone is
presented in Oster (1982). A large number of
ground-water flow and transport models are
summarized by Bond and Hwang (1988).
Finally, Travers and Sharp-Hansen (1991)
summarize models that may be applicable to
problems of leachate generation and migration
from MSWLF units. (See References
supplied in Section 4.6.)
Table 4-1 (adapted from Travers and Sharp-
Hansen (1991)) provides information on
select leachate generation models. Tables 4-
la, b, and c list some of the available models
that can be used to predict contaminant
transport. The factors used to select these
models include availability, documentation,
uniqueness, and the size of the user
community. These models are categorized by
the techniques used to solve flow and
transport equations. Table 4-la lists
analytical and semi-analytical models, and
Tables 4-lb and 4-lc list numerical models
that are solved by the finite-difference and the
finite-element method, respectively.
The types of models that are available for
application to the evaluation of MSWLF
designs include leachate generation models
and saturated and unsaturated zone flow and
transport models. The level of sophistication
of each of these types of models is based on
the complexity of the processes being
modeled. The majority of the models
consider flow and transport based on
advection dispersion equations. More
complex models consider physical and
chemical transformation processes, fracture
flow, and multiphase fluid flow.
Leachate generation models predict the
quantity and characteristics of leachate that is
released from the bottom of a landfill. These
models are used to estimate
contaminant source terms and the releases of
contaminants to the subsurface. Flow and
transport models simulate the transport of
contaminants released from the source to the
unsaturated and saturated zones.
Geochemical models are available that
consider chemical processes that may be
active in the subsurface such as adsorption,
precipitation, oxidation/reduction, aqueous
speciation, and kinetics.
Complex flow models have been developed to
simulate the effects of nearby pumping and
discharging wells, fracture flow, conduit flow
in karst terrane, and multiphase flow for fluids
that are less dense or more dense than water.
However, the use of the more complex
models requires additional data based on a
thorough investigation of the subsurface
characteristics at a site as well as well-trained
users to apply the model correctly.
Most of the ground-water flow and solute
transport models are deterministic. However,
the use of stochastic models, which allow for
characterization of spatial and temporal
variability in systems, is increasing. A few of
the models include a Monte Carlo capability
for addressing the uncertainty inherent in the
input parameters.
The EPA Multimedia Exposure
Assessment Model (MULTIMED)
EPA has developed a modeling package to
meet the needs of a large percentage of
MSWLF unit owners and operators who will
require fate and transport modeling as part of
the performance-based design demonstration.
This model, the Multimedia Exposure
Assessment Model (MULTIMED), is
intended for use at sites where certain
simplifying assumptions can be made.
MULTIMED can be used in
139
-------
Table 4-1. Models for Application to Leachate Generation Problems (adapted from Travers and Sharp-Hansen, 1991)
Model
Reference
Bonazountas
and Wagner
(1984);
SESOIL
Carsel et al.
(1984) PRZM
EPRI (1981)
UNSAT1D
Knisel et al.
(1989)
GLEAMS
Schroeder et
al. (1984)
HELP
Model Flow Aquifer
Dimensions Conditions Conditions
1D/FD Ss.Unsat L,Hom,Iso
9
1D/FD Usat.Ss.Tr L.Hom.Iso
1D/FD Sat.Usat, Het.Hom.L
Ss.Tr Iso
1D/FD Usat.Tr.Ss Hom.Iso.L
quasi-2D FD Tr.Sat.Usat L.Homo,
Iso
Model
Processes
Ppt.Inf,
RO.ET,
Adv.Dif,
Ads.Vol,
Dec
Adv.Dis,
Dif.Dec,
Rxn.ET,
Vol.Inf
Ppt.Inf,
RO.ET
Inf.Dec.R
O.ET.Ads
ET.Ppt.In
f.Dra.RO
Chemical Additional Information
Species
single Seasonal Soil Compartment Model. Simulates transport of
water, sediment, and contaminants in soils. Includes affects of
capillary rise, biological transformation, hydrolysis, cation
exchange, complexation chemistry (metals by organic ligands).
Hydrology based on generalized annual water balance
dynamics model.
1 ,2, or 3 Pesticide Root £one M_odel. Also includes plant uptake,
leaching, runoff, management practices, and foliar washoff.
Hydrologic flow solved by water routing scheme, chemical
transport solved by finite difference scheme. Requires
meteorological data. Water balance model.
flow only Solves one-dimensional Richard's equation. Accounts for
capillary and gravitational effects. Requires landfill design
data.
single Groundwater Loading Effects of Agricultural Systems model.
Developed by modifying CREAMS (Knisel, 1980) to add
capability to estimate groundwater loadings. Simulates
erosion. Water balance computations.
flow only A quasi-two-dimensional, deterministic water budget for
landfills. Requires landfill design data. Model may be applied
to open, partially open, and closed landfills. Requires
meteorological data.
ID = One-dimensional Sat
2D = Two-dimensional Usat
3D = Three-dimensional Horn
H = Horizontal Het
V = Vertical Iso
Ss = Steady-State An
Tr = Transient C
Saturated Uc
Unsaturated Adv
Homogeneous Dis
Heterogeneous Dif
Isotropic Dec
Anisotropic Ads
Confined Aquifer Ret
Unconfined aquifer In
Advection ET
Decay Ppt
Diffusion RO
Decay Run
Adsorption W
Retardation L
Infiltration
Evapotranspiration
Precipitation
Runoff
Reaction
Discharge or pumping wells
Layers
-------
Table 4-la. Analytical and Semi-Analytical Models for Application to Leachate Migration Problems
(adapted from Travers and Sharp-Hansen, 1991)
Model Model Flow Aquifer Model Chemical
Reference Dimensions Conditions Conditions Processes Species
Additional Information
Bcljin (1983) ID(H), 2D(H) Ss, Sat
SOLUTE or 3D
C, Horn, Iso Adv, Dis, Ads, single
Dec
A package of 8 analytical models for solute transport
in groundwater. Also includes a program lor unit
conversion and error and function calculation.
Domcnicoand IDadvection Ss, Sal
Palciauakcs 2D dispcrsioh
(1982) VMS
C, Horn, Iso Adv, Dis
single
Model for Vertical and Horizontal Spreading.
Assumes infinite aquifer thickness. EPA considers
VHS to he a conservative model since retardation,
sorptions, precipitation, aquifer recharge not
considered. Source is continuous constant strip source.
Domenico and 3D (transport) Ss, Sat C, Horn, Iso Adv, Dis single
Rohbms
(1985)
Huyaknm el 3D Ss, Sal C, Uc, Horn, Adv, Dis, Ads, single
;U. (1987) Iso, An Dec
Conlaminanl transport from a finite or continuous
source in a continuous flow regimen. Assumes infinilc
thickness.
Model allows for estimation of maximum
concentration distribution along center line of a
leachate plume. Gaussian vertical strip source.
Javandcl ct 2D(H)
al. (1984)
RESSQ
Lindstrom 1D(H)
and Bocrams
(1989)
CXPHPH
Ss, Sat C, Horn, Iso Adv, Ads single
Ss, Sat C, Horn, Iso Adv, Dis, Dec, single
Ads, Rxn
Calculate transport by advcclion and adsorption in a
homogeneous, isotropic, uniform-thickness, confined
aquifer. Uses semi-analytical solution methods.
Analytical solutions of the general one-dimensional
transport equation for confined aquifers, will) several
differenl initial and boundary conditions.
Nelson and 2D(H)
Schur(1983)
PATHS
Ss, Tr, Sat C, Horn, Iso Adv, Ads single
Groundwater How equations solved analytically,
characteristic pathlines solved by Ruage-Kulls method.
Ostcndorf cl ID(H.V) Ss, Sat Uc, Horn, Iso Adv, Ads, Dec single
al. (1984)
Assumes transport of a simply reactive contaminant
through a landfill and initially pure, underlying,
shallow, aquifer with plane, sloping bottom.
Prakash ID, 2D or 3D Ss, Sat C, Horn, Iso Adv, Dis, Ads, single
(1984) I**
Source boundary condition: instantaneous or finite-lime
release of contaminants from a point, line, plane, or
parallel piped source.
-------
Table 4-la. Analytical and Semi-Analytical Models for Application to Leachate Migration Problems
(adapted from Travers and Sharp-Hansen, 1991) (continued)
Model
Reference
Model
Dimensions
Salhotrc el lD(vadosc
al. (1990) /one), 3D
MULTIMED (transport in
saturated /.one)
Flow
Conditions
Ss, Sal, Usai
Unge cl al.
(1986);
Summers cl
al. (1989)
MYGRT
(Version 1.0,
2.0)
I,2(H,V)
Ss, Sat
Aquifer
Conditions
tic, Horn, Iso,
I. (Usal)
Model
Processes
Chemical
Species
Adv, Dis, Ads, single
Dec, Vol
tic, Horn, Iso Adv, Dis, Rel, single
Dec
Additional Information
van 1D(H,V) Ss, Sal
Gcnuchtcn
and Alvcs
(1982)
Yen (1981) ID, 2D or 3D Tr, Sal
AT123D
C, Horn, Iso Adv, Dis, Dif, single
Ads
C, Uc, Horn, Adv, Dis, Dif, single
Iso, An Ads, Dec
Model simulates movement of contaminants in
saturated and unsaluraled groundwaler /.ones. In
surface water and emissions lo air. Includes Monte
Carlo capability. Unsalurated zone transport solution
is analytical, saturated zone is semi-analytical.
Gaussian or palch source boundary condition.
Simulates migration of organic and inorganic solulcs.
Constant pulse source boundary condition. Proprietary
code.
Three types of source boundary conditions are
considered: constant, exponential decay, and pulse step
function.
Analytical, semi-analytical, solution techniques based
on Green's function. Source boundary conditions
include: constant, instantaneous pulse, or finite-lime
release from a point, line, area, or volume source
ID = One-dimensional Sal
2D = Two-dimensional Usal
3D = Three-dimensional Horn
II = Horizontal Hel
V = Vertical Iso
Ss = Steady-state An
Tr = Transient C
Saturaled Uc
Unsaluratcd Adv
Homogeneous Dis
Heterogeneous Dif
Isolropic Dec
Anisotropic Ads
Confined aquifer Ret
Unconfincd aquifer Inf
Adveclion ET
Dispersion Ppl
Diffusion RO
Decay Rxn
Adsorption W
Retardation L
Infiltration
Evapoiranspiralion
Precipitation
Run-off
Reaction
Discharge or pumping wells
layers
-------
Table 4-lb. Finite-Difference Models for Application to Leachate Migration Problems
(adapted from Travers and Sharp-Hansen, 1991)
--••
Model Model
Reference Dimensions
Ahriclc and ID
Pinder (19X3)
»
Dillion ct al. 3D
(1981; 1986)
SWIFT/
SWIFT II
Erdogcnand ID
Hcufcld
(1983)
GeoTrans 3D
(1985); Faust
el al. (1989)
SWAN-
FLOW
Kipp(1987) 3D
NST3D
Konikow and 2D (H,V)
Bradshocfl
(1985)
USGS-NOC
Flow Aquifer
Conditions (Conditions
Ss, Tr, Sat, Uc, Iso, Horn
Usal
Ss, Tr, Sat C, Horn, Het,
Iso, An
Tr, Sal Horn, Iso
Ss, Tr, Sat, Uc, Horn, Hot,
Usat Iso, An
Tr, Sat C, Uc, Horn,
Hcl, Iso, An
Ss, Tr, Sat C, Uc, Horn,
Hel, Iso, An
Model Chemical
Processes Species
Dis. Dif multiphase
Adv, Dis, Dif, single
Dec, Rxn, W
Adv, Dis, Ads, single
Ppt
multiphase
Adv, Dis, Dif, single
Ads, Dec, W
Adv, Dis, Dif, single
Ads, Dec, ET,
W
Additional Information
Multiphase model for modeling aquifer contamination
by organic compounds. Simulates simultaneous
transport of contaminant in a nonaqucous phase,
aqueous phase and as a mobile fraction of gas phase.
Effects of capillarity, interphase mass transfer,
diffusion, and dispersion considered.
Coupled groundwaler flow, and heal or solute
transport. Includes fracture flow, ion exchange, salt
dissolution, in confined aquifer. SWIFT-II includes
dual porosity for fractured media.
Model describes the desorption process using
intraparliclc and external file diffusion resistances as
rate controlling mechanism (considers fluid velocity
and particle si/e). Predicts Icachale concentration
profiles at the boundary of the landfill. Simulates
precipitation with interrupted flow condilions.
Faust (1989) extends SWANFLOW to include a
solution technique which lakes advantage of parallel
computer processing.
Simulates coupled density dependent groundwater flow
and heal or mass transport in an anisotropic,
heterogeneous aquifer.
Groundwater flow solved by finite difference, solute
transport by the melliod of characteristics.
-------
Table 4-lb. Finite-Difference Models for Application to Leachate Migration Problems
(adapted from Travers and Sharp-Hansen, 1991) (continued)
Model
Reference
Harasiinhiin
cl al. (1986)
DYNAMIX
Prickctt cl al.
(19X1)
RANDOM
WALK or
TRANS
Ruachcl
(1985)
PORFLOW-
11 and III
Travis (1984)
TRACR3D
Walton
(1984) 35
Micro-
computer
Programs
Model
Dimensions
3D
ID or 2D(H)
2D(H,V) or
3D
3D
ID, 2D(H) or
3D (radial,
cyl)
Flow Aquifer
Conditions Conditions
Ss, Tr, Sal C, Uc, Horn,
Hcl, Iso, An
Ss, Tr, Sal C, Uc, Horn,
I lei, Iso, An,
L
Ss, Tr, Sal C, Uc, Horn,
Hct, Iso, An,
L.
Ss, Tr, Sat, C, Horn, Het,
Usat Iso, An
Ss, Tr, Sal C, Uc, Horn,
Hel, L
Model
Processes
Adv, Dis, Dif,
Dec
Adv, Dis, Ads,
Dec, ET, W
Adv, Dis, Dif,
Ads, Dec,
Rxn, W
Adv, Dis, Dif,
Ads, Dec
Adv, Dis, Rel
Chemical
Species
multiple
single
single
two-phase,
multiple
single
Additional Information
Model couples a chemical specification model
PHREEQE (Parkhursl cl al, 1980) with a modified
form of the transport code TRUMP (Edwards, 1969,
1972). Considers equilibrium reactions (see
gcochcinical codes).
Finite difference solution lo groundwatcr How,
random walk approach used lo simulate dispersion.
Simulates random movement. Aquifer properties vary
spatially and temporally.
Simulates density dependent How, heat and mass
transport. Aquifer and fluid properties may he
spatially and temporally variable. Integrated finite
difference solution. Includes phase change.
Simulates transient two-phase flow and multi-
component transport in deformablc, heterogeneous,
reactive, porous media.
A series of analytical and simple numerical programs
lo analyze flow and transport of solutes in aquifers
with simple geometry.
ID = One-dimensional Sat
2D = Two-dimensional Usat
3D = Three-dimensional Horn
H = Horizontal Hct
V = Vertical Iso
Ss = Steady-slate An
Tr = Transient C
Saturated
Unsaturaled
Homogeneous
Heterogeneous
Isotropic
Anisotropic
Confined aquifer
Uc = Unconfined aquifer Inf
Adv = Advection ET
Dis = Dispersion Ppt
Dif = Diffusion RO
Dec = Decay Rxn
Ads = Adsorption W
Ret = Retardation L
Infiltration
Evapotranspiration
Prccipilalion
Run-off
Reaction
Discharge or pumping wells
Layers
-------
Table 4-lc. Finite-Element Models for Application to Leachate Migration Problems
(adapted from Travers and Sharp-Hansen, 1991)
Model
Reference
Ccdcrbcrg el
al. (1985)
TRANQL
(19X9)
RUSTIC
Gupla el al.
(1982)
CFEST
Gureghian el
al. (1980)
Guvanssen
(1986)
NOT IF
Haji-Djalari
and Wells
(1982)
GEOFLOW
Huyakorn et
al. (1984)
SEFTRAN
Huyakorn el
al. (1986)
TRAFRAP
Osbomc and
Sykes(1986)
WST1F
Model
Dimensions
1 D, radial
vadose /.one);
2DH.V, radial
(saturated
/one)
2D(H,V) or
3D
2D
ID, 2D, or 3D
3D
ID or
2D(H,V)
2D(H,V)
2D
Flow
Conditions
Ss, Sat
Ss Tr Usat
Sal
Ss, Tr, Sal
Ss, Sal
Ss, Tr, Sal,
Usat
Ss, Tr, Sal
Ss, Tr, Sal
Ss, Tr, Sat
Tr, Sat, Usat
Aquifer
Conditions
C, Uc, Horn
C Uc Horn
Hct, Iso, An,
L
C, Uc, Horn,
Hel, Iso, An,
L
C, Uc, Iso, An
C, Uc, Horn,
Hel, Iso, An
C, Uc, Horn,
Hel, Iso, An,
L
C, Uc, Horn,
Hel, Iso, An,
L
C, Uc, Horn,
Hel, Iso, An
Uc, Horn, Hel,
Iso, An, L
Model
1'rocesses
Adv, Dis, Dif,
Ads, Dec
Adv, Dis, Ads,
Dif, Dec, ET,
W, Ppt, RO,
Ret
Adv, Dis, Dif,
Ads, Dec, W
Adv, Dis, Ads,
Dec
Adv, Dis, Dif,
Ads, Dec
Adv, Dis, Dif,
Dec, Rxn, Rel,
W
Adv, Dis, Dif,
Ads, Dec, W
Adv, Dis, Dif,
Ads, Dec,
Rxn, W
Chemical
Species
multiple
1, 2, or 3
single
single
single
single
single
single
two- phase
Additional Information
Multicomponenl transport model which links chemical
equilibrium code MICROQL (Weslfall, 1976) and
transport axle ISOQUAD (Pinder, unpublished
manuscripl, 1976). Includes a complexation in aqueous
phase.
Simulates fate and transport of chemicals through three
linked modules: root, values, and saturated /one.
Includes PRZN (Carsel et al., 1984). RUSTIC is in
Beta-lcsling phase. Includes Monte Carlo capability
PRZN solution by finite difference.
Solves coupled groundwater How, solute and heat
transport equations. Fluid may be heterogeneous.
Source boundary condition: Gaussian distributed
source. Transport only.
Groundwaler How and solute transport in fractured
porous media.
Simulation of arcal configuration only. Proprietary
axle.
Proprietary axle.
Simulates groundwater Row and solute transport in
fractured porous media. Includes precipitalion.
Model sirnulales Iransporl of immiscible organics in
groundwater. Assumes no mass transport belween
phases.
-------
Table 4-lc. Finite-Element Models for Application to Leachate Migration Problems
(adapted from Travers and Sharp-Hansen, 1991) (continued)
Model Model
Reference Dimensions
Thcis ct al. ID
(14X2)
FIESTA
van 1D(V)
Gcnuchlen
(1978)
SUMATRA-
I
Voss (19X4) 2D(H,V)
SUTRA
Ychand 2D(H,V)
Ward (1981)
FEMWATER
FEM WASTE
Ych (1990) 2D/3D
LEWASTE,
3DLEWASTE
Flow
Conditions
Sal
Tr, Sat, Usat
Ss, Tr, Sat,
Usat
Ss, Tr, Sat,
Usat
Ss, Tr, Sat,
Usat
Aquifer
Conditions
Horn, Iso
C, Uc, Horn,
Hcl, Iso, L
C, Uc, Horn,
Hct, Iso, An
Uc, Horn, Hct,
Iso, An
Uc, C, Horn,
Hct, Iso, An
Model
Processes
Adv, Dis, Ads,
Dec
Adv, Dis, Ads,
Dec, Ret
Adv, Dis, Oil,
Ads, Dec,
Rxn, W
Adv, Dis, Ads,
Dec, Ppt, W
Adv, Dis, Ads,
Dec, W
Chemical
Species Additional Information
multiple Combinations of a component transport model, FEAP,
and the chemical equilibrium speciation model
NINEQL (Wcstfall el al. 1976). Simulates up to 6
chemical components, including all solution and sorhcd
phase complexes.
single Simulates simultaneous How of water and solutes in a
one-dimensional, vertical soil profile.
single Fluid may be heterogeneous (density-dependent
groundwaler flow).
single FEMWATER simulates groundwaler flow.
FEMWASTE simulales waste Iransporl through
saturated unsaturaled porous media. Simulates
capillarity, infiltration, and recharge/discharge -sources
(e.g., lakes, reservoirs, and streams).
single Transport codes based on (lie Lagrangian-Eulcrian
approach, can be applied to Pcciel Numbers from 0 lo
infinity. LEWASTE is intended to simulate 2D local
How systems. 3DLEWASTE can simulate regional or
local flow systems. The LEWASTE series replaces the
FEMWASTE models.
ID = One-dimensional Sat =
2D = Two-dimensional Usat =
3D = Three-dimensional Horn =
II = Horizontal Hct =
V = Vertical Iso =
Ss = Steady-slate An =
Tr = Transient C • =
Saturated Uc
Unsaturaied Adv
Homogeneous Dis
Heterogeneous Dif
Isolropic Dec
Anisolropic Ads
Confined aquifer Re I
Unconfincd aquifer Inf
Adveclion ET
Dispersion Ppl
Diffusion RO
Decay Rxn
Adsorption W
Retardation L
Infiltration
Evapolranspiralion
Precipilation
Run-off
Reaction
Discharge or pumping wells
Layers
-------
Design Criteria
conjunction with a separate leachate source
model, such as HELP (Schroeder et al., 1984).
Output from HELP is then used in
MULTIMED to demonstrate that either a
landfill design or the specific hydrogeologic
conditions present at a site will prevent
contaminant concentrations in ground water
from exceeding the concentrations listed in
Table 1 of §258.40. (Refer to pp. 4-53 and 6-
8 for further discussion of HELP.) A
description of MULTIMED follows with
guidance for determining if its use is
appropriate for a given site.
[NOTE: Version 3.0 of the HELP model will
be available during the fall of 1993. To
obtain a copy, call EPA's Office of Research
and Development (ORD) in Cincinnati at
(513)569-7871.]
Overview of the Model
The MULTIMED model consists of modules
that estimate contaminant releases to air, soil,
ground water, or surface water. General
information about the model and its theory is
provided in Salhotra et al. (1990).
Additionally, information about the
application of MULTIMED to MSWLF units
(developed by Sharp-Hansen et al. [1990]) is
summarized here. In MULTIMED, a steady-
state, one-dimensional, semi-analytical
module simulates flow in the unsaturated
zone. The output from this module, which is
water saturation as a function of depth, is used
as input to the unsaturated zone transport
module. The latter simulates transient, one-
dimensional (vertical) transport in the
unsaturated zone and includes the effects of
dispersion, linear adsorption, and first-order
decay. Output from the unsaturated zone
modules is used as input to the semi-analytical
saturated zone transport module. The latter
considers three-dimensional flow
because the effects of lateral or vertical
dispersion may significantly affect the model
results.
Therefore, reducing the dimensions to one in
this module would produce inaccurate results.
The saturated zone transport module also
considers linear adsorption, first-order decay,
and dilution as a result of ground-water
recharge. In addition, MULTIMED has the
capability to assess the impact of uncertainty
in the model inputs on the model output
(contaminant concentration at a specified
point), using the Monte Carlo simulation
technique.
The simplifying assumptions required to
obtain the analytical solutions limit the
complexity of the systems that can be
evaluated with MULTIMED. The model does
not account for site-specific spatial variability
(e.g., aquifer heterogeneities), the shape of the
land disposal facility, site-specific boundary
conditions, or multiple aquifers and pumping
wells. Nor can MULTIMED simulate
processes, such as flow in fractures and
chemical reactions between contaminants, that
may have a significant effect on the
concentration of contaminants at a site. In
more complex systems, it may be beneficial to
use MULTIMED as a "screening level" model
to allow the user to obtain an understanding of
the system. A more complex model could
then be used if there are sufficient data.
Application of MULTIMED to MSWLF
Units
Procedures have been developed for the
application of MULTIMED to the design of
MSWLF units. They are explained in Sharp-
Hansen et al. (1990) and are briefly
summarized here. The procedures are:
147
-------
Subpart D
• Collect site-specific hydrogeologic data,
including amount of leachate generated
(see Section 4.3.3);
• Identify the contaminant(s) to be
simulated and the point of compliance;
• Propose a landfill design and determine
the corresponding infiltration rate; then
• Run MULTIMED and calculate the
dilution attenuation factor (DAF) (i.e.,
the factor by which the concentration is
expected to decrease between the
landfill unit and the point of
compliance); and
• Multiply the initial contaminant
concentration by the DAF and compare
the resulting concentration to the MCLs
to determine if the design will meet the
standard.
At this time, only contaminant transport in the
unsaturated and/or saturated zones can be
modeled, because the other options (i.e.,
surface water, air) have not yet been
thoroughly tested. In addition, only steady-
state transport simulations are allowed. No
decay of the contaminant source term is
permitted; the concentration of contaminants
entering the aquifer system is assumed to be
constant over time. The receptor (e.g., a
drinking water well) is located directly
downgradient of the facility and intercepts the
contaminant plume; also, the contaminant
concentration is calculated at the top of the
aquifer.
The user should bear in mind that
MULTIMED may not be an appropriate
model for some sites. Some of the issues that
should be considered before modeling efforts
proceed are summarized in Table
4-2. A "no" answer to any of the questions in
Table 4-2 may indicate that MULTIMED is
not the most appropriate model to use. As
stated above, MULTIMED utilizes analytical
and semi-analytical solution techniques to
solve the mathematical equations describing
flow and transport. As a result, the
representation of a system simulated by the
model is simple, and little or no spatial or
temporal variability is allowed for the
parameters in the system. Thus, a highly
complex hydrogeologic system cannot be
accurately represented with MULTIMED.
The spatial characteristics assumed in
MULTIMED should be considered when
applying MULTIMED to a site. The
assumption of vertical, one-dimensional
unsaturated flow may be valid for facilities
that receive uniform areal recharge.
However, this assumption may not be valid
for facilities where surface soils (covers or
daily backfill) or surface slopes result in an
increase of run-off in certain areas of the
facility, and ponding of precipitation in
others. In addition, the simulation of one-
dimensional, horizontal flow in the saturated
zone requires several simplifying
assumptions. The saturated zone is treated as
a single, horizontal aquifer with uniform
properties (e.g., hydraulic conductivity). The
effects of pumping or discharging wells on the
ground-water flow system cannot be
addressed with the MULTIMED model.
The MULTIMED model assumes steady-state
flow in all applications. Some ground-water
flow systems are in an approximate "steady-
state," in which the amount of water entering
the flow system equals the amount of water
leaving the system. However, assuming
steady-state conditions in a system that
exhibits transient behavior may produce
inaccurate results.
148
-------
Design Criteria
TABLE 4-2
ISSUES TO BE CONSIDERED
BEFORE APPLYING MULTIMED
(from Sharp-Hansen et al., 1990)
Objectives of the Study
• Is a "screening level" approach
appropriate?
• Is modeling a "worst-case scenario"
acceptable?
Significant Processes Affecting Contaminant
Transport
• Does MULTIMED simulate all the
significant processes occurring at the site?
• Is the contaminant soluble in water and of
the same density as water?
Accuracy and Availability of the Data
• Have sufficient data been collected to
obtain reliable results?
• What is the level of uncertainty associated
with the data?
• Would a Monte Carlo simulation be
useful? If so, are the cumulative
probability distributions for the parameters
with uncertain values known?
Complexity of the Hydrogeologic System
• Are the hydrogeologic properties of the
system uniform?
• Is the flow in the aquifer uniform and
steady?
• Is the site geometry regular?
• Does the source boundary condition
require a transient or steady-state solution?
MULTIMED may be run in either a
deterministic or a Monte Carlo mode. The
Monte Carlo method provides a means of
estimating the uncertainty in the results of a
model, if the uncertainty of the input variables
is known or can be estimated. However, it
may be difficult to determine the cumulative
probability distribution for a given parameter.
Assuming a parameter probability distribution
when the distribution is unknown does not
help reduce uncertainty. Furthermore, to
obtain a valid estimate of the uncertainty in
the output, the model must be run numerous
times (typically several hundred times), which
can be time-consuming. These issues should
be considered before utilizing the Monte
Carlo technique.
4.3 COMPOSITE LINER AND
LEACHATE COLLECTION
SYSTEM
40 CFR §258.40
4.3.1 Statement of Regulation
(a) New MSWLF units and lateral
expansions shall be constructed:
(1) See Statement of Regulation in
Section 4.2.1 of this guidance document for
performance-based design requirements.
(2) With a composite liner, as defined
in paragraph (b) of this section and a
leachate collection system that is designed
and constructed to maintain less than a 30-
cm depth of leachate over the liner,
(b) For purposes of this section,
composite liner means a system consisting
of two components; the upper component
must consist of a minimum 30-mil flexible
149
-------
Subpart D
membrane liner (FML), and the lower
component must consist of at least a two-
foot layer of compacted soil with a
hydraulic conductivity of no more than 1 x
10~7 cm/sec. FML components consisting of
high density polyethylene (HDPE) shall be
at least 60-mil thick. The FML component
must be installed in direct and uniform
contact with the compacted soil
component.
4.3.2 Applicability
New MSWLF units and expansions of
existing MSWLF units in States without
approved programs must be constructed with
a composite liner and a leachate collection
system (LCS) that is designed to maintain a
depth of leachate less than 30 cm (12 in.)
above the liner. A composite liner consists of
a flexible membrane liner (FML) installed on
top of, and in direct and uniform contact with,
two feet of compacted soil. The FML must be
at least 30-mil thick unless the FML is made
of FIDPE, which must be 60-mil thick. The
compacted soil liner must be at least two feet
thick and must have a hydraulic conductivity
of no more than 1 x 10"7 cm/sec.
Owners and operators of MSWLF units
located in approved States have the option of
proposing a performance-based design
provided that certain criteria can be met (see
Section 4.2.2).
4.3.3 Technical Considerations
This section provides information on the
components of composite liner systems
including soils, geomembranes, and leachate
collection systems.
Standard Composite Liner Systems
The composite liner system is an effective
hydraulic barrier because it combines the
complementary properties of two different
materials into one system: 1) compacted soil
with a low hydraulic conductivity; and
2) a FML (FMLs are also referred to as
geomembranes). Geomembranes may contain
defects including tears, improperly bonded
seams, and pinholes. In the absence of an
underlying low-permeability soil liner, flow
through a defect in a geomembrane is
essentially unrestrained. The presence of a
low-permeability soil liner beneath a defect in
the geomembrane reduces leakage by limiting
the flow rate through the defect.
Flow through the soil component of the liner
is controlled by the size of the defect in the
geomembrane, the available air space between
the two liners into which leachate can flow,
the hydraulic conductivity of the soil
component, and the hydraulic head. Fluid
flow through soil liners is calculated by
Darcy's Law, where discharge (Q) is
proportional to the head loss through the soil
(dh/dl) for a given cross-sectional flow area
(A) and hydraulic conductivity (K) where:
Q = KA(dh/dl)
Leakage through a geomembrane without
defects is controlled by Pick's first law, which
describes the process of liquid diffusion
through the membrane liner. The diffusion
process is similar to flow governed by Darcy's
law for soil liners except that diffusion is
driven by concentration gradients and not by
hydraulic head. Although diffusion rates in
geomembranes are several orders of
magnitude lower than comparable hydraulic
flow rates in low-permeability soil liners,
construction of a completely impermeable
geomembrane is
150
-------
Design Criteria
difficult. The factor that most strongly
influences geomembrane performance is the
presence of imperfections such as improperly
bonded seams, punctures and pinholes. A
detailed discussion of leakage through
geomembranes and composite liners can be
found in Giroud and Bonaparte (1989 (Part I
and Part II)). A geomembrane installed with
excellent control over defects may yield the
equivalent of a one-centimeter-diameter hole
per acre of liner installed (Giroud and
Bonaparte, 1989 (Part I and Part II)). If the
geomembrane were to be placed over sand,
this size imperfection under one foot of
constant hydraulic head could be expected to
account for as much as 3,300 gal/acre/day
(31,000 liters/hectare/ day) of leakage. Based
upon measurements of actual leakage through
liners at facilities that have been built under
rigorous control, Bonaparte and Gross (1990)
have estimated an actual leakage rate, under
one foot of constant head, of 200
liters/hectare/day or about 21 gallons/acre/day
for landfill units.
The uniformity of the contact between the
geomembrane and the soil liner is extremely
important in controlling the effective flow
area of leachate through the soil liner. Porous
material, such as drainage sand, filter fabric,
or other geofabric, should not be placed
between the geomembrane and the low
permeability soil liner. Porous materials will
create a layer of higher hydraulic
conductivity, which will increase the amount
of leakage below an imperfection in the
geomembrane. Construction practices during
the installation of the soil and the
geomembrane affect the uniformity of the
geomembrane/soil interface, and strongly
influence the performance of the composite
liner system.
Soil Liner
The following subsections discuss soil liner
construction practices including thickness
requirements, lift placement, bonding of lifts,
test methods, prerequisite soil properties,
quality control, and quality assurance
activities.
Thickness
Two feet of soil is generally considered the
minimum thickness needed to obtain adequate
compaction to meet the hydraulic conductivity
requirement. This thickness is considered
necessary to minimize the number of cracks
or imperfections through the entire liner
thickness that could allow leachate migration.
Both lateral and vertical imperfections may
exist in a compacted soil. The two-foot
minimum thickness is believed to be sufficient
to inhibit hydraulic short-circuiting of the
entire layer.
Lift Thickness
Soil liners should be constructed in a series of
compacted lifts. Determination of appropriate
lift thickness is dependent on the soil
characteristics, compaction equipment,
firmness of the foundation materials, and the
anticipated compactive effort needed to
achieve the required soil hydraulic
conductivity. Soil liner lifts should be thin
enough to allow adequate compactive effort to
reach the lower portions of the lift. Thinner
lifts also provide greater assurance that
sufficient compaction can be achieved to
provide good, homogeneous bonding between
subsequent lifts. Adequate compaction of lift
thickness between five and ten inches is
possible if appropriate equipment is used
(USEPA, 1988). Nine-inch loose lift
thicknesses that will yield a 6-
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Subpart D
inch soil layer also have been recommended
prior to compaction (USEPA, 1990a).
Soil liners usually are designed to be of
uniform thickness with smooth slopes over the
entire facility. Thicker areas may be
considered wherever recessed areas for
leachate collection pipes or collection sumps
are located. Extra thickness and compactive
efforts near edges of the side slopes may
enhance bonding between the side slopes and
the bottom liner. In smaller facilities, a soil
liner may be designed for installation over the
entire area, but in larger or multi-cell
facilities, liners may be designed in segments.
If this is the case, the design should address
how the old and new liner segments will be
bonded together (U.S. EPA, 1988).
Bonding Between Lifts
It is not possible to construct soil liners
without some microscopic and/or macroscopic
zones of higher and lower hydraulic
conductivity. Within individual lifts, these
preferential pathways for fluid migration are
truncated by the bonded zone between the
lifts. If good bonding between the lifts is not
achieved during construction, the vertical
pathways may become connected by
horizontal pathways at the lift interface,
thereby diminishing the performance of the
hydraulic barrier.
Two methods may be used to ensure proper
bonding between lifts. Kneading or blending
a thinner, new lift with the previously
compacted lift may be achieved by using a
footed roller with long feet that can fully
penetrate a loose lift of soil. If the protruding
rods or feet of a sheepsfoot roller are
sufficient in length to penetrate the top lift and
knead the previous lift, good bonding may be
achieved. Another method
includes scarifying (roughening), and possibly
wetting, the top inch or so of the last lift
placed with a disc harrow or other similar
equipment before placing the next lift.
Placement of Soil Liners on Slopes
The method used to place the soil liner on side
slopes depends on the angle and length of the
slope. Gradual inclines from the toe of the
slope enable continuous placement of the lifts
up the slopes and provide better continuity
between the bottom and sidewalls of the soil
liner. When steep slopes are encountered,
however, lifts may need to be placed and
compacted horizontally due to the difficulties
of operating heavy compaction equipment on
steeper slopes.
When sidewalls are compacted horizontally,
it is important to tie in the edges with the
bottom of the soil liner to reduce the
probability of seepage planes (USEPA, 1988).
A significant amount of additional soil liner
material will be required to construct the
horizontal lifts since the width of the lifts has
to be wide enough to accommodate the
compaction equipment. After the soil liner is
constructed on the side slopes using this
method, it can be trimmed back to the
required thickness. The trimmed surface of
the soil liner should be sealed by a smooth-
drum roller. The trimmed excess materials
can be reused provided that they meet the
specified moisture-density requirements.
Hydraulic Conductivity
Achieving the hydraulic conductivity standard
depends on the degree of compaction,
compaction method, type of clay, soil
moisture content, and density of the soil
during liner construction. Hydraulic
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Design Criteria
conductivity is the key design parameter when
evaluating the acceptability of the constructed
soil liner. The hydraulic conductivity of a soil
depends, in part, on the viscosity and density
of the fluid flowing through it. While water
and leachate can cause different test results,
water is an acceptable fluid for testing the
compacted soil liner and source materials.
The effective porosity of the soil is a function
of size, shape, and area of the conduits
through which the liquid flows. The
hydraulic conductivity of a partially saturated
soil is less than the hydraulic conductivity of
the same soil when saturated. Because
invading water only flows through water-
filled voids (and not air-filled voids), the
dryness of a soil tends to lower permeability.
Hydraulic conductivity testing should be
conducted on samples that are fully saturated
to attempt to measure the highest possible
hydraulic conductivity.
EPA has published Method 9100 in
publication SW-846 (Test Methods for
Evaluating Solid Wasted to measure the
hydraulic conductivity of soil samples. Other
methods appear in the U.S. Army Corps of
Engineers Engineering Manual 1110-2-1906
(COE, 1970) and the newly published
"Measurement of Hydraulic Conductivity of
Saturated Porous Materials Using a Flexible
Wall Permeameter" (ASTM D-5084). To
verify full saturation of the sample, this latter
method may be performed with back pressure
saturation and electronic pore pressure
measurement.
Soil Properties
Soils typically possess a range of physical
characteristics, including particle size,
gradation, and plasticity, that affect their
ability to achieve a hydraulic conductivity of
1 x 10"7 cm/sec. Testing methods used to
characterize proposed liner soils should
include grain size distribution (ASTM D-
422), Atterberg limits (ASTM D-4318), and
compaction curves depicting moisture and
density relationships using the standard or
modified Proctor (ASTM D-698 or ASTM D-
1557), whichever is appropriate for the
compaction equipment used and the degree of
firmness of the foundation materials.
Liner soils usually have at least 30 percent
fines (fine silt- and clay-sized particles).
Some soils with less than 30 percent fines
may be worked to obtain hydraulic
conductivities below 1 x 10"7 cm/sec, but use
of these soils requires greater control of
construction practices and conditions.
The soil plasticity index (PI), which is
determined from the Atterberg limits (defined
by the liquid limit minus the plastic limit),
should generally be greater than 10 percent.
However, soils with very high PI, (greater
than 30 percent), are cohesive and sticky and
become difficult to work with in the field.
When high PI soils are too dry during
placement, they tend to form hard clumps
(clods) that are difficult to break down during
compaction. Preferential flow paths may be
created around the clods allowing leachate to
migrate at a relatively high rate.
Soil particles or rock fragments also can
create preferential flow paths. For this
reason, soil particles or rock fragments should
be less than 3 inches in diameter so as not to
affect the overall hydraulic performance of
the soil liner (USEPA, 1989).
The maximum density of a soil will be
achieved at the optimum water content, but
this point generally does not correspond to the
point at which minimum hydraulic
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Subpart D
conductivity is achieved. Wet soils, however,
have low shear strength and high potential for
desiccation cracking. Care should be taken
not to compromise other engineering
properties such as shear strengths of the soil
liner by excessively wetting the soil liner.
Depending on the specific soil characteristics,
compaction equipment and compactive effort,
the hydraulic conductivity criterion may be
achieved at moisture values of 1 to 7 percent
above the optimum moisture content.
Although the soil may possess the required
properties for successful liner construction,
the soil liner may not meet the hydraulic
conductivity criterion if the construction
practices used to install the liner are not
appropriate and carefully controlled.
Construction quality control and quality
assurance will be discussed in a later section.
Amended Soils
If locally available soils do not possess
properties to achieve the specified hydraulic
conductivity, soil additives can be used. Soil
additives, such as bentonite or other clay
materials, can decrease the hydraulic
conductivity of the native soil (USEPA,
1988b).
Bentonite may be obtained in a dry, powdered
form that is relatively easy to blend with on-
site soils. Bentonite is a clay mineral
(sodium-montmorillonite) that expands when
it comes into contact with water (hydration),
by absorbing the water within the mineral
matrix. This property allows relatively small
amounts of bentonite (5 to 10 percent) to be
added to a noncohesive soil (sand) to make it
more cohesive (U.S. EPA, 1988b). Thorough
mixing of additives to cohesive soils (clay)
is difficult and may lead to inconsistent results
with respect to complying with the hydraulic
conductivity criterion.
The most common additive used to amend
soils is sodium bentonite. The disadvantage
of using sodium bentonite includes its
vulnerability to degradation as a result of
contact with chemicals and waste leachates
(U.S. EPA, 1989).
Calcium bentonite, although more permeable
than sodium bentonite, also is used as a soil
amendment. Approximately twice as much
calcium bentonite typically is needed to
achieve a hydraulic conductivity comparable
to that of sodium bentonite.
Soil/bentonite mixtures generally require
central plant mixing by means of a pugmill,
cement mixer, or other mixing equipment
where water can be added during the process.
Water, bentonite content, and particle size
distribution must be controlled during mixing
and placement. Spreading of the
soil/bentonite mixture may be accomplished
in the same manner as the spreading of natural
soil liners, by using scrapers, graders,
bulldozers, or a continuous asphalt paving
machine (U.S. EPA, 1988).
Materials other than bentonite, including lime,
cement, and other clay minerals such as
atapulgite, may be used as soil additives (U.S.
EPA, 1989). For more information
concerning soil admixtures, the reader is
referred to the technical resource document on
the design and construction of clay liners
(U.S. EPA, 1988).
Testing
Prior to construction of a soil liner, the
relationship between water content, density,
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Design Criteria
and hydraulic conductivity for a particular soil
should be established in the laboratory.
Figure 4-5 shows the influence of molding
water content (moisture content of the soil at
the time of compaction) on hydraulic
conductivity of the soil. The lower half of the
diagram is a compaction curve and shows the
relationship between dry unit weight, or dry
density of the soil, and water content of the
soil. The optimum moisture content of the
soil is related to a peak value of dry density
known as maximum dry density. Maximum
dry density is achieved at the optimum
moisture content.
The lowest hydraulic conductivity of
compacted clay soil is achieved when the soil
is compacted at a moisture content slightly
higher than the optimum moisture content,
generally in the range of 1 to 7 percent (U.S.
EPA, 1989). When compacting clay, water
content and compactive effort are the two
factors that should be controlled to meet the
maximum hydraulic conductivity criterion.
It is impractical to specify and construct a
clay liner to a specific moisture content and a
specific compaction (e.g., 5 percent wet of
optimum and 95 percent modified Proctor
density). Moisture content can be difficult to
control in the field during construction;
therefore, it may be more appropriate to
specify a range of moisture contents and
corresponding soil densities (percent
compaction) that are considered appropriate to
achieve the required hydraulic conductivity.
Benson and Daniel (U.S. EPA, 1990) propose
water content and density criteria for the
construction of clay liners in which the
moisture-density criteria ranges are
established based on hydraulic conductivity
test results. This type of approach is
recommended because of the flexibility and
guidance it provides to the
construction contractor during soil placement.
Figure 4-6 presents compaction data as a
function of dry unit weight and molding water
content for the construction of clay liners.
The amount of soil testing required to
determine these construction parameters is
dependent on the degree of natural variability
of the source material.
Quality assurance and quality control of soil
liner materials involve both laboratory and
field testing. Quality control tests are
performed to ascertain compaction
requirements and the moisture content of
material delivered to the site. Field tests for
quality assurance provide an opportunity to
check representative areas of the liner for
conformance to compaction specifications,
including density and moisture content.
Quality assurance laboratory testing is usually
conducted on field samples for determination
of hydraulic conductivity of the in-place liner.
Laboratory testing allows full saturation of the
soil samples and simulates the effects of large
overburden stress on the soil, which cannot be
done conveniently in the field (U.S. EPA,
1989).
Differences between laboratory and field
conditions (e.g., uniformity of material,
control of water content, compactive effort,
compaction equipment) may make it unlikely
that minimum hydraulic conductivity values
measured in the laboratory on remolded, pre-
construction borrow source samples are the
same as the values achieved during actual
liner construction. Laboratory testing on
remolded soil specimens does not account for
operational problems that may result in
desiccation, cracking, poor bonding of lifts,
and inconsistent degree of compaction on
sidewalls (U.S. EPA, 1988b). The
relationship between field and laboratory
hydraulic conductivity testing has been
investigated by the U.S. Environmental
155
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Hydraulic
Conductivity
Dry Unit
Weight
Molding Water Content
Source: U.S. EPA, 1989.
Note: The optimum moisture content occurs at the point at which maximum density is achieved.
The lowest hydraulic conductivity generally occurs at water contents higher than optimum.
Figure 4-5
Hydraulic Conductivity and Dry Unit Weight as a
Function of Molding Water Content
156
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£
*s
120
110
100
90
10
Acceptable
Zone
15 20
Molding Water Content (%)
An
D
OJ
Compactive Effort
25
Compaction Data for a Silty Clay (from Mitchell et al.. 1965).
Solid symbols represent specimens with a hydraulic
conductivity < 1 x 10'7 cm/s and open symbols represent
specimens with hydraulic conductivity > 1 x 10'7 cm/s.
Source: CERI 90-50 (USEPA, 1990)
Figure 4-6. Compaction Data for Silty Clay
157
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Subpart D
Protection Agency using field case studies
(U.S. EPA, 1990c).
In situ, or field, hydraulic conductivity testing
operates on the assumption that by testing
larger masses of soil in the field, one can
obtain more realistic results. Four types of in
situ hydraulic conductivity tests generally are
used: borehole tests, porous probes,
infiltrometer tests, and underdrain tests. A
borehole test is conducted by drilling a hole,
then filling the hole with water, and
measuring the rate at which water percolates
into the borehole. In the borehole test, water
also can percolate through the sidewalls of the
borehole. As a result, the measured hydraulic
conductivity is usually higher than that
measured by other one-dimensional field
testings.
The second type of test involves driving or
pushing a porous probe into the soil and
pouring water through the probe into the soil.
With this method, however, the advantage of
testing directly in the field is somewhat offset
by the limitations of testing such a small
volume of soil.
A third method of testing involves a device
called an infiltrometer. This device is
embedded into the surface of the soil liner
such that the rate of flow of a liquid into the
liner can be measured. The two types of
infiltrometers most widely used are open and
sealed. Open rings are less desirable because,
with a hydraulic conductivity of 10"7 cm/sec,
it is difficult to detect a 0.002 inch per day
drop in water level of the pond from
evaporation and other losses.
With sealed rings, very low rates of flow can
be measured. However, single-ring
infiltrometers allow lateral flow beneath the
ring, which can complicate the interpretation
of test results. Single rings are also
susceptible to the effects of temperature
variation; as the water temperature increases,
the entire system expands. As it cools down,
the system contracts. This situation could
lead to erroneous measurements when the rate
of flow is small.
The sealed double-ring infiltrometer has
proven to be the most successful method and
is the one currently used. The outer ring
forces infiltration from the inner ring to be
more or less one-dimensional. Covering the
inner ring with water insulates it substantially
from temperature variation.
Underdrains, the fourth type of in situ test, are
the most accurate in situ permeability testing
device because they measure exactly what
migrates from the bottom of the liner.
However, under-drains are slow to generate
data for low permeability liners, because of
the length of time required to accumulate
measurable flow. Also, underdrains must be
installed during construction, so fewer
underdrains are used than other kinds of
testing devices.
Field hydraulic conductivity tests are not
usually performed on the completed liner
because the tests may take several weeks to
complete (during which time the liner may be
damaged by desiccation or freezing
temperatures) and because large penetrations
must be made into the liner. If field
conductivity tests are performed, they are
usually conducted on a test pad. The test pad
should be constructed using the materials and
methods to be used for the actual soil liner.
The width of a test pad is usually the width of
three to four construction vehicles, and the
length is one to two times the width.
Thickness is usually two to three feet. Test
pads can be used as a means for verifying that
the proposed
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Design Criteria
materials and construction procedures will
meet performance objectives. If a test pad is
constructed, if tests verify that performance
objectives have been met, and if the actual
soil liner is constructed to standards that equal
or exceed those used in building the test pad
(as verified through quality assurance), then
the actual soil liner should meet or exceed
performance objectives.
Other than the four types of field hydraulic
conductivity tests described earlier, ASTM D
2937 "Standard Test Method for Density of
Soil in Place by the Drive-Cylinder Method"
may be used to obtain in-place hydraulic
conductivity of the soil liner. This test
method uses a U.S. Army Corps of Engineers
surface soil sampler to drive a thin-walled
cylinder (typically 3-inch by 3-inch) into a
completed lift of the soil liner to obtain
relatively undisturbed samples for laboratory
density and hydraulic conductivity testings.
This test can provide useful correlation to
other field and quality assurance testing
results (e.g, Atterberg limits, gradation, in-
place moisture and density of the soil liner) to
evaluate the in-place hydraulic conductivity of
the soil liner.
Soil Liner Construction
Standard compaction procedures are usually
employed when constructing soil liners. The
following factors influence the degree and
quality of compaction:
• Lift thickness;
• Full scale or segmented lift placement;
• Number of equipment passes;
• Scarification between lifts;
• Soil water content; and
• The type of equipment and compactive
effort.
The method used to compact the soil liner is
an important factor in achieving the required
minimum hydraulic conductivity. Higher
degrees of compactive effort increase soil
density and lower the soil hydraulic
conductivity for a given water content. The
results of laboratory compaction tests do not
necessarily correlate directly with the amount
of compaction that can be achieved during
construction.
Heavy compaction equipment (greater than
25,000 Ibs or 11,300 kg) is typically used
when building the soil liner to maximize
compactive effort (U.S. EPA, 1989). The
preferred field compaction equipment is a
sheepsfoot roller with long feet that fully
penetrates loose lifts of soil and provides
higher compaction while kneading the clay
particles together. The shape and depth of the
feet are important; narrow, rod-like feet with
a minimum length of about seven inches
provide the best results. A progressive change
from the rod-like feet to a broader foot may
be necessary in some soils after initial
compaction, to allow the roller to walk out of
the compacted soil. The sheepsfoot feet also
aid in breaking up dry clods (see Soil
Properties in this section). Mechanical road
reclaimers, which are typically used to strip
and re-pave asphalt, can be extremely
effective in reducing soil clod size prior to
compaction and in scarifying soil surfaces
between lifts. Other equipment that has been
used to compact soil includes discs and
rototillers.
To achieve adequate compaction, the lift
thickness (usually five to nine inches) may be
decreased or the number of passes over
159
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Subpart D
the lift may be increased. Generally,
compaction equipment should pass over the
soil liner five to twenty times to attain the
compaction needed to comply with the
minimum hydraulic conductivity criterion
(U.S. EPA, 1989).
Efforts made to reduce clod size during
excavation and placement of the soil for the
liner should improve the chances for
achieving low hydraulic conductivity in
several ways. Keeping clods in the soil liner
material small will facilitate a more uniform
water content. Macropores between clod
remnants can result in unacceptably high field
hydraulic conductivity.
Opinions differ on acceptable clod sizes in the
uncompacted soil. Some suggest a maximum
of one to three inches in diameter, or no larger
than one-half the lift thickness. The main
objective is to remold all clods in the
compaction process to keep hydraulic
conductivity values consistent throughout the
soil liner (U.S. EPA, 1988).
Geomembranes
Geomembranes are relatively thin sheets of
flexible thermoplastic or thermoset polymeric
materials that are manufactured and
prefabricated at a factory and transported to
the site. Because of their inherent
impermeability, use of geomembranes in
landfill unit construction has increased. The
design of the side slope, specifically the
friction between natural soils and
geosynthetics, is critical and requires careful
review.
Material Types and Thicknesses
Geomembranes are made of one or more
polymers along with a variety of other
ingredients such as carbon black, pigments,
fillers, plasticizers, processing aids,
crosslinking chemicals, anti-degradants, and
biocides. The polymers used to manufacture
geomembranes include a wide range of
plastics and rubbers differing in properties
such as chemical resistance and basic
composition (U.S. EPA, 1983 and U.S. EPA,
1988e). The polymeric materials may be
categorized as follows:
Thermoplastics such
chloride (PVC);
as polyvinyl
• Crystalline thermoplastics such as high
density polyethylene (HDPE), very low
density polyethylene (VLDPE), and
linear low density polyethylene
(LLDPE); and
• Thermoplastic elastomers such as
chlorinated polyethylene (CPE) and
chlorosulfonated polyethylene (CSPE).
The polymeric materials used most frequently
as geomembranes are HDPE, PVC, CSPE,
and CPE. The thicknesses of geomembranes
range from 20 to 120 mil (1 mil = 0.001 inch)
(U.S. EPA, 1983 and U.S. EPA, 1988e). The
recommended minimum thickness for all
geomembranes is 30 mil, with the exception
of HDPE, which must be at least 60 mil to
allow for proper seam welding. Some
geomembranes can be manufactured by a
calendering process with fabric reinforcement,
called scrim, to provide additional tensile
strength and dimensional stability.
Chemical and Physical Stress Resistance
The design of the landfill unit should consider
stresses imposed on the liner by the design
configuration. These stresses include the
following:
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Design Criteria
• Differential settlement in foundation
soils;
• Strain requirements at the anchor trench;
and
• Strain requirements over long, steep side
slopes.
An extensive body of literature has been
developed by manufacturers and independent
researchers on the physical properties of
liners. Geosynthetic design equations are
presented in several publications including
Kastman (1984), Koerner (1990), and U.S.
EPA(1988e).
The chemical resistance of a geomembrane to
leachate has traditionally been considered a
critical issue for Subtitle C (hazardous waste)
facilities where highly concentrated solvents
may be encountered. Chemical resistance
testing of geomembranes may not be required
for MSWLF units containing only municipal
solid waste; EPA's data base has shown that
leachate from MSWLF units is not aggressive
to these types of materials. Testing for
chemical resistance may be warranted
considering the waste type, volumes,
characteristics, and amounts of small quantity
generator waste or other industrial waste
present in the waste stream. The following
guidance is provided in the event such testing
is of interest to the owner or operator.
EPA's Method 9090 in SW-846 is the
established test procedure used to evaluate
degradation of geomembranes when exposed
to hazardous waste leachate. In the
procedure, the geomembrane is immersed in
the site-specific chemical environment for at
least 120 days at two different temperatures.
Physical and mechanical properties of the
tested material are then compared to those
of the original material every thirty days. A
software system entitled Flexible Liner
Evaluation Expert (FLEX), designed to assist
in the hazardous waste permitting process,
may aid in interpreting EPA Method 9090 test
data (U.S. EPA, 1989). A detailed discussion
of both Method 9090 and FLEX is available
from EPA.
It is imperative that a geomembrane liner
maintain its integrity during exposure to
short-term and long-term mechanical stresses.
Short-term mechanical stresses include
equipment traffic during the installation of a
liner system, as well as thermal expansion and
shrinkage of the geomembrane during the
construction and operation of the MSWLF
unit. Long-term mechanical stresses result
from the placement of waste on top of the
liner system and from subsequent differential
settlement of the subgrade (U.S. EPA, 1988a).
Long-term success of the liner requires
adequate friction between the components of
a liner system, particularly the soil subgrade
and the geomembrane, and between
geosynthetic components, so that slippage or
sloughing does not occur on the slopes of the
unit. Specifically, the foundation slopes and
the subgrade materials must be considered in
design equations to evaluate:
• The ability of a geomembrane to
support its own weight on the side
slopes;
The ability of a geomembrane to
withstand down-dragging during and
after waste placement;
• The best anchorage configuration for the
geomembrane;
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Subpart D
• The stability of a soil cover on top of a
geomembrane; and
• The stability of other geosynthetic
components such as geotextile or geonet
on top of a geomembrane.
These requirements may affect the choice of
geomembrane material, including polymer
type, fabric reinforcement, thickness, and
texture (e.g., smooth or textured for HDPE)
(U.S. EPA, 1988). PVC also can be obtained
in a roughened or file finish to increase the
friction angle.
Design specifications should indicate the type
of raw polymer and manufactured sheet to be
used as well as the requirements for the
delivery, storage, installation, and sampling of
the geomembrane. Material properties can be
obtained from the manufacturer-supplied
average physical property values, which are
published in the Geotechnical Fabrics Report's
Specifier's Guide and updated annually. The
minimum tensile properties of the
geomembrane must be sufficient to satisfy the
stresses anticipated during the service life of
the geomembrane. Specific raw polymer and
manufactured sheet specifications and test
procedures include (U.S. EPA, 1988e, and
Koerner, 1990):
Raw Polymer Specifications
• Density (ASTMD-1505);
• Melt index (ASTM D-1238);
• Carbon black (ASTM D-1603); and
• Thermogravimetric analysis (TGA)
or differential scanning calorimetry
(DSC).
Manufactured Sheet Specifications
• Thickness (ASTMD-1593);
• Tensile properties (ASTM D-638);
• Tear resistance (ASTM D-1004);
• Carbon black content (ASTM D-
1603);
• Carbon black dispersion (ASTM D-
3015);
• Dimensional stability (ASTM D-
1204); and
• Stress crack resistance (ASTM D-
1693).
Geomembranes may have different physical
characteristics, depending on the type of
polymer and the manufacturing process used,
that can affect the design of a liner system.
When reviewing manufacturers' literature, it
is important to remember that each
manufacturer may use more than one polymer
or resin type for each grade of geomembrane
and that the material specifications may be
generalized to represent several grades of
material.
Installation
Installation specifications should address
installation procedures specific to the
properties of the liner installed. The
coefficient of thermal expansion of the
geomembrane sheet can affect its installation
and its service performance. The
geomembrane should lie flat on the
underlying soil. However, shrinkage and
expansion of the sheeting, due to changes in
temperature during installation, may result in
excessive wrinkling or tension in the
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Design Criteria
geomembrane. Wrinkles on the
geomembrane surface will affect the
uniformity of the soil-geomembrane interface
and may result in leakage through
imperfections. Excessive tautness of the
geomembrane may affect its ability to resist
rupture from localized stresses on the seams
or at the toe of slopes where bridging over the
subgrade may occur during installation. In
addition to thermal expansion and contraction
of the geomembrane, residual stresses from
manufacturing remain in some geomembranes
and can cause non-uniform expansion and
contraction during construction. Some
flexibility is needed in the specifications for
geomembrane selection to allow for
anticipated dimensional changes resulting
from thermal expansion and contraction (U.S.
EPA, 1988).
Technical specifications for geomembranes
also should include: information for
protection of the material during shipping,
storage and handling; quality control
certifications provided by the manufacturer or
fabricator (if panels are constructed); and
quality control testing by the contractor,
installer, or a construction quality assurance
(CQA) agent. Installation procedures
addressed by the technical specifications
include a geomembrane layout plan,
deployment of the geomembrane at the
construction site, seam preparation, seaming
methods, seaming temperature constraints,
detailed procedures for repairing and
documenting construction defects, and sealing
of the geomembrane to appurtenances, both
adjoining and penetrating the liner. The
performance of inspection activities, including
both non-destructive and destructive quality
control field testing of the sheets and seams
during installation of the geomembrane,
should be addressed in the technical
specifications. Construction quality assurance
is addressed
in an EPA guidance document (USEPA,
1992).
The geomembrane sheeting is shipped in rolls
or panels from the supplier, manufacturer, or
fabricator to the construction site. Each roll
or panel may be labeled according to its
position on the geomembrane layout plan to
facilitate installation. Upon delivery, the
geomembrane sheeting should be inspected to
check for damage that may have occurred
during shipping. (U.S. EPA, 1992).
Proper storage of the rolls or panels prior to
installation is essential to the final
performance of the geomembrane. Some
geomembrane materials are sensitive to
ultraviolet exposure and should not be stored
in direct sunlight prior to installation. Others,
such as CSPE and CPE, are sensitive to
moisture and heat and can partially crosslink
or block (stick together) under improper
storage conditions. Adhesives or welding
materials, which are used to join
geomembrane panels, also should be stored
appropriately (U.S. EPA, 1992).
Visual inspection and acceptance of the soil
liner subgrade should be conducted prior to
installing the geomembrane. The surface of
the subgrade should meet design
specifications with regard to lack of
protruding objects, grades, and thickness.
Once these inspections are conducted and
complete, the geomembrane may be installed
on top of the soil liner. If necessary, other
means should be employed to protect the
subgrade from precipitation and erosion, and
to prevent desiccation, moisture loss, and
erosion from the soil liner prior to
geomembrane placement. Such methods may
include placing a plastic tarp on top of
completed portions of the soil liner
163
-------
Subpart D
(USEPA, 1992). In addition, scheduling soil
liner construction slightly ahead of the
geomembrane and drainage layer placement
can reduce the exposure of the soil liner to the
elements.
Deployment, or placement, of the
geomembrane panels or rolls should be
described in the geomembrane layout plan.
Rolls of sheeting, such as HDPE, generally
can be deployed by placing a shaft through
the core of the roll, which is supported and
deployed using a front-end loader or a winch.
Panels composed of extremely flexible liner
material such as PVC are usually folded on
pallets, requiring workers to manually unfold
and place the geomembrane. Placement of
the geomembrane goes hand-in-hand with the
seaming process; no more than the amount of
sheeting that can be seamed during a shift or
work day should be deployed at any one time
(USEPA, 1988). Panels should be weighted
with sand bags if wind uplift of the membrane
or excessive movement from thermal
expansion is a potential problem. Proper
stormwater control measurements should be
employed during construction to prevent
erosion of the soil liner underneath the
geomembrane and the washing away of the
geomembrane.
Once deployment of a section of the
geomembrane is complete and each section
has been visually inspected for imperfections
and tested to ensure that it is the specified
thickness, seaming of the geomembrane may
begin. Quality control/quality assurance
monitoring of the seaming process should be
implemented to detect inferior seams.
Seaming can be conducted either in the
factory or in the field. Factory seams are
made in a controlled environment and are
generally of high quality, but the entire seam
length (100 percent) still should be
tested non-destructively (U.S. EPA, 1988).
Destructive testing should be done at regular
intervals along the seam (see page 4-66).
Consistent quality in fabricating field seams is
critical to liner performance, and conditions
that may affect seaming should be monitored
and controlled during installation. An
inspection should be conducted in accordance
with a construction quality assurance plan to
document the integrity of field seams. Factors
affecting the seaming process include (U.S.
EPA, 1988):
• Ambient temperature at which the seams
are made;
• Relative humidity;
• Control of panel lift-up by wind;
• The effect of clouds on the
geomembrane temperature;
• Water content of the subsurface beneath
the geomembrane;
• The supporting surface on which the
seaming is bonded;
• The skill of the seaming crew;
• Quality and consistency of the chemical
or welding material;
• Proper preparation of the liner surfaces
to be joined;
• Moisture on the seam interface; and
• Cleanliness of the seam interface (e.g.,
the amount of airborne dust and debris
present).
164
-------
Design Criteria
Depending on the type of geomembrane,
several bonding systems are available for the
construction of both factory and field seams.
Bonding methods include solvents, heat seals,
heat guns, dielectric seaming, extrusion
welding, and hot wedge techniques. To
ensure the integrity of the seams, a
geomembrane should be seamed using the
bonding system recommended by the
manufacturer (U.S. EPA, 1988). EPA has
developed a field seaming manual for all
types of geomembranes (U.S. EPA, 199la).
Thermal methods of seaming require
cleanliness of the bonding surfaces, heat,
pressure, and dwell time to produce high
quality seams. The requirements for adhesive
systems are the same as those for thermal
systems, except that the adhesive takes the
place of the heat. Sealing the geomembrane
to appurtenances and penetrating structures
should be performed in accordance with
detailed drawings included in the design plans
and approved specifications.
An anchor trench along the perimeter of the
cell generally is used to secure the
geomembrane during construction (to prevent
sloughing or slipping down the interior side
slopes). Run out calculations (Koerner, 1990)
are available to determine the depth of burial
at a trench necessary to hold a specified length
of membrane, or combination of membrane
and geofabric or geotextile. If forces larger
than the tensile strength of the membrane are
inadvertently developed, then the membrane
could tear. For this reason, the geomembrane
should be allowed to slip or give in the trench
after construction to prevent such tearing.
However, during construction, the
geomembrane should be anchored according
to the detailed drawings provided in the
design plans and specifications (USEPA,
1988).
Geomembranes that are subject to damage
from exposure to weather and work activities
should be covered with a layer of soil as soon
as possible after quality assurance activities
associated with geomembrane testing are
completed. Soil should be placed without
driving construction vehicles directly on the
geomembrane. Light ground pressure
bulldozers may be used to push material out
in front over the liner, but the operator must
not attempt to push a large pile of soil forward
in a continuous manner over the membrane.
Such methods can cause localized wrinkles to
develop and overturn in the direction of
movement. Overturned wrinkles create sharp
creases and localized stresses in the
geomembrane that could lead to premature
failure. Instead, the operator should
continually place smaller amounts of soil or
drainage material working outward over the
toe of the previously placed material.
Alternatively, large backhoes can be used to
place soil over the geomembrane that can later
be spread with a bulldozer or similar
equipment. Although such methods may
sound tedious and slow, in the long run they
will be faster and more cost-effective than
placing too much material too fast and having
to remobilize the liner installer to repair
damaged sections of the geomembrane. The
QA activities conducted during construction
also should include monitoring the
contractor's activities on top of the liner to
avoid damage to installed and accepted
geomembranes.
Leachate Collection Systems
Leachate refers to liquid that has passed
through or emerged from solid waste and
contains dissolved, suspended, or immiscible
165
-------
Subpart D
materials removed from the solid waste. At
MSWLF units, leachate is typically aqueous
with limited, if any, immiscible fluids or
dissolved solvents. The primary function of
the leachate collection system is to collect and
convey leachate out of the landfill unit and to
control the depth of the leachate above the
liner. The leachate collection system (LCS)
should be designed to meet the regulatory
performance standard of maintaining less than
30 cm (12 inches) depth of leachate, or
"head," above the liner. The 30-cm head
allowance is a design standard and the Agency
recognizes that this design standard may be
exceeded for relatively short periods of time
during the active life of the unit. Flow of
leachate through imperfections in the liner
system increases with an increase in leachate
head above the liner. Maintaining a low
leachate level above the liner helps to improve
the performance of the composite liner.
Leachate is generally collected from the
landfill through sand drainage layers,
synthetic drainage nets, or granular drainage
layers with perforated plastic collection pipes,
and is then removed through sumps or gravity
drain carrier pipes. LCS's should consist of
the following components (U.S. EPA, 1988):
• A low-permeability base (in this case a
composite liner);
• A high-permeability drainage layer,
constructed of either natural granular
materials (sand and gravel) or synthetic
drainage material (e.g., geonet) placed
directly on the FML, or on a protective
bedding layer (e.g., geofabric) directly
overlying the liner;
• Perforated leachate collection pipes
within the high-permeability drainage
layer to collect leachate and carry it
rapidly to a sump or collection header
pipe;
• A protective filter layer over the high
permeability drainage material, if
necessary, to prevent physical clogging
of the material by fine-grained material;
and
• Leachate collection sumps or header
pipe system where leachate can be
removed.
The design, construction, and operation of the
LCS should maintain a maximum height of
leachate above the composite liner of 30 cm
(12 in). Design guidance for calculating the
maximum leachate depth over a liner for
granular drainage systems materials is
provided in the reference U.S. EPA (1989).
The leachate head in the layer is a function of
the liquid impingement rate, bottom slope,
pipe spacing, and drainage layer hydraulic
conductivity. The impingement rate is
estimated using a complex liquid routing
procedure. If the maximum leachate depth
exceeds 30 cm for the system, except for
short-term occurrences, the design should be
modified to improve its efficiency by
increasing grade, decreasing pipe spacing, or
increasing the hydraulic conductivity
(transmissivity) of the drainage layer (U.S.
EPA, 1988).
Grading of Low-Permeability Base
The typical bottom liner slope is a minimum
of two percent after allowances for settlement
at all points in each system. A slope is
necessary for effective gravity drainage
through the entire operating and post-closure
period. Settlement estimates of the
foundation soils should set this two-
166
-------
Design Criteria
percent grade as a post-settlement design
objective (U.S. EPA, 1991b).
High-Permeability Drainage Layer
The high-permeability drainage layer is
placed directly over the liner or its protective
bedding layer at a slope of at least two percent
(the same slope necessary for the composite
liner). Often the selection of a drainage
material is based on the on-site availability of
natural granular materials. In some regions of
the country, hauling costs may be very high
for sand and gravel, or appropriate materials
may be unavailable; therefore, the designer
may elect to use geosynthetic drainage nets
(geonets) or synthetic drainage materials as an
alternative. Frequently, geonets are
substituted for granular materials on steep
sidewalls because maintaining sand on the
slope during construction and operation of the
landfill unit is more difficult (U.S. EPA,
1988).
Soil Drainage Layers
If the drainage layer of the leachate collection
system is constructed of granular soil
materials (e.g., sand and gravel), then it
should be demonstrated that this granular
drainage layer has sufficient bearing strength
to support expected loads. This
demonstration will be similar to that required
for the foundations and soil liner (U.S. EPA,
1988).
If the landfill unit is designed on moderate-to-
steep (15 percent) grades, the landfill design
should include calculations demonstrating that
the selected granular drainage materials will
be stable on the most critical slopes (e.g.,
usually the steepest slope) in the design. The
calculations and assumptions should be
shown, especially the
friction angle between the geomembrane and
soil, and if possible, supported by laboratory
and/or field testing (USEPA, 1988).
Generally, gravel soil with a group
designation of GW or GP on the Unified Soils
Classification Chart can be expected to have
a hydraulic conductivity of greater than 0.01
cm/sec, while sands identified as SW or SP
can be expected to have a coefficient of
permeability greater than 0.001 cm/sec. The
sand or gravel drains leachate that enters the
drainage layer to prevent 30 cm (12 in) or
more accumulation on top of the liner during
the active life of the MSWLF unit LCS. The
design of a LCS frequently uses a drainage
material with a hydraulic conductivity of 1 x
10"2 cm/sec or higher. Drainage materials
with hydraulic conductivities in this order of
magnitude should be evaluated for biological
and particulate clogging (USEPA, 1988).
Alternatively, if a geonet is used, the design is
based on the transmissivity of the geonet.
If a filter layer (soil or geosynthetic) is
constructed on top of a drainage layer to
protect it from clogging, and the LCS is
designed and operated to avoid drastic
changes in the oxidation reduction potential of
the leachate (thereby avoiding formation of
precipitates within the LCS), then there is no
conceptual basis to anticipate that
conductivity will decrease over time. Where
conductivity is expected to decrease over
time, the change in impingement rate also
should be evaluated over the same time period
because the reduced impingement rate and
hydraulic conductivity may still comply with
the 30 cm criterion.
Unless alternative provisions are made to
control incident precipitation and resulting
surface run-off, the impingement rate during
the operating period of the MSWLF unit is
167
-------
Subpart D
usually at least an order of magnitude greater
than the impingement rate after final closure.
The critical design condition for meeting the
30 cm (12 in) criterion can therefore be
expected during the operating life. The
designer may evaluate the sensitivity of a
design to meet the 30 cm (12 in) criterion as
a result of changes in impingement rates,
hydraulic conductivity, pipe spacing, and
grades. Such sensitivity analysis may indicate
which element of the design should be
emphasized during construction quality
monitoring or whether the design can be
altered to comply with the 30 cm (12 in)
criterion in a more cost-effective manner.
The soil material used for the drainage layer
should be investigated at the borrow pit prior
to use at the landfill. Typical borrow pit
characterization testing would include
laboratory hydraulic conductivity and grain
size distribution. If grain size distribution
information from the borrow pit
characterization program can be correlated to
the hydraulic conductivity data, then the grain
size test, which can be conducted in a short
time in the field, may be a useful construction
quality control parameter. Compliance with
this parameter would then be indicative that
the hydraulic conductivity design criterion
was achieved in the constructed drainage
layer. This information could be incorporated
into construction documents after the borrow
pit has been characterized. If a correlation
cannot be made between hydraulic
conductivity and grain size distribution, then
construction documents may rely on direct
field or laboratory measurements to
demonstrate that the hydraulic conductivity
design criterion was met in the drainage layer.
Granular materials are generally placed using
conventional earthmoving equipment,
including trucks, scrapers, bulldozers, and
front-end loaders. Vehicles should not be
driven directly over the geosynthetic
membrane when it is being covered. (U.S.
EPA, 1988a).
Coarse granular drainage materials, unlike
low-permeability soils, can be placed dry and
do not need to be heavily compacted.
Compacting granular soils tends to grind the
soil particles together, which increases the
fine material and reduces hydraulic
conductivity. To minimize settlement
following material placement, the granular
material may be compacted with a vibratory
roller. The final thickness of the drainage
layer should be checked by optical survey
measurements or by direct test pit
measurements (U.S. EPA, 1988).
Geosynthetic Drainage Nets
Geosynthetic drainage nets (geonets) may be
substituted for the granular layers of the LCRs
on the bottom and sidewalls of the landfill
cells. Geonets require less space than
perforated pipe or gravel and also promote
rapid transmission of liquids. They do,
however, require geotextile filters above them
and can experience problems with creep and
intrusion. Long-term operating and
performance experience of geonets is limited
because the material and its application are
relatively new (U.S. EPA, 1989).
If a geonet is used in place of a granular
drainage layer, it must provide the same level
of performance (maintaining less than 30 cm
of leachate head above the liner). An
explanation of the calculation used to compute
the capacity of a geonet may be found in U.S.
EPA(1987a). The
168
-------
Design Criteria
transmissivity of a geonet can be reduced
significantly by intrusion of the soil or a
geotextile. A protective geotextile between
the soil and geonet will help alleviate this
concern. If laboratory transmissivity tests are
performed, they should be done under
conditions, loads, and configurations that
closely replicate the actual field conditions. It
is important that the transmissivity value used
in the leachate collection system design
calculations be selected based upon those
loaded conditions (U.S. EPA, 1988). It is also
important to ensure that appropriate factors of
safety are used (Koerner, 1990).
The flow rate or transmissivity of geonets
may be evaluated by ASTM D-4716. This
flow rate may then be compared to design-by-
function equations presented in U.S. EPA
(1989). In the ASTM D-4716 flow test, the
proposed collector cross section should be
modeled as closely as possible to actual field
conditions (U.S. EPA, 1989).
Figure 4-7 shows the flow rate "signatures" of
a geonet between two geomembranes (upper
curves) and the same geonet between a layer
of clay soil and a geomembrane (lower
curves). The differences between the two sets
of curves represent intrusion of the
geotextile/clay into the apertures of the
geonet. The curves are used to obtain a flow
rate for the particular geonet being designed
(U.S. EPA, 1989). Equations to determine the
design flow rate or transmissivity are also
presented in U.S. EPA (1989), Giroud (1982),
Carroll (1987), Koerner (1990), and FHWA
(1987).
Generally, geonets perform well and result in
high factors of safety or performance design
ratios, unless creep (elongation under constant
stress) becomes a problem or adjacent
materials intrude into apertures (U.S. EPA,
1989). For geonets, the most
critical specification is the ability to transmit
fluids under load. The specifications also
should include a minimum transmissivity
under expected landfill operating (dynamic)
or completion (static) loads. The
specifications for thickness and types of
material should be identified on the drawings
or in the materials section of the
specifications, and should be consistent with
the design calculations (U.S. EPA, 1988).
Geonets are often used on the sidewalls of
landfills because of their ease of installation.
They should be placed with the top ends in a
secure anchor trench with the strongest
longitudinal length extending down the slope.
The geonets need not be seamed to each other
on the slopes, only tied at the edges, butted, or
overlapped. They should be placed in a loose
condition, not stretched or placed in a
configuration where they are bearing their
own weight in tension. The construction
specifications should contain appropriate
installation requirements as described above
or the requirements of the geonet
manufacturer. All geonets need to be
protected by a filter layer or geotextile to
prevent clogging (U.S. EPA, 1988).
The friction factors against sliding for
geotextiles, geonets, and geomembranes often
can be estimated using manufacturers data
because these materials do not exhibit the
range of characteristics as seen in soil
materials. However, it is important that the
designer perform the actual tests using site
materials and that the sliding stability
calculations accurately represent the actual
design configuration, site conditions, and the
specified material characteristics (U.S. EPA,
1988).
169
-------
c
E
"co
•S
d>
75
en
o
c
E
OJ
75
CE
_o
LL
5,000 10,000 15,000
Normal Stress (1lbs./sq. R)
(a) FML - Geonet - FML Composite
20,000
20,000
5,000 10,000 15,000
Normal Stress (1lbs./sq. R)
(b) FML - Geonet - Geotextile - Clay Soil Composite
Source: U.S. EPA. 1989.
Figure 4-1. Flow Rate Curves for Geonets in Two Composite Liner Configurations
170
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Design Criteria
Leachate Collection Pipes
All components of the leachate collection
system must have sufficient strength to
support the weight of the overlying waste,
cover system, and post-closure loadings, as
well as the stresses from operating
equipment. The component that is most
vulnerable to compressive strength failure is
the drainage layer piping. Leachate
collection system piping can fail by
excessive deflection, which may lead to
buckling or collapse (USEPA, 1988). Pipe
strength calculations should include
resistance to wall crushing, pipe deflection,
and critical buckling pressure. Design
equations and information for most pipe
types can be obtained from the major pipe
manufacturers. For more information
regarding pipe structural strength, refer to
U.S. EPA (1988).
Perforated drainage pipes can provide good
long-term performance. These pipes have
been shown to transmit fluids rapidly and to
maintain good service lives. The depth of
the drainage layer around the pipe should be
deeper than the diameter of the pipe. The
pipes can be placed in trenches to provide
the extra depth. In addition, the trench
serves as a sump (low point) for leachate
collection. Pipes can be susceptible to
particulate and biological clogging similar
to the drainage layer material. Furthermore,
pipes also can be susceptible to deflection.
Proper maintenance and design of pipe
systems can mitigate these effects and
provide systems that function properly.
Acceptable pipe deflections should be
evaluated for the pipe material to be used
(USEPA, 1989).
The design of perforated collection pipes
should consider the following factors:
• The required flow using known
percolation impingement rates and pipe
spacing;
• Pipe size using required flow and
maximum slope; and
• The structural strength of the pipe.
The pipe spacing may be determined by the
Mound Model. In the Mound Model (see
Figure 4-8), the maximum height of fluid
between two parallel perforated drainage
pipes is equal to (U.S. EPA, 1989):
_ L\fc r tan2a _ tana
s 2 c c
where c = q/k
k = permeability
q = inflow rate
a = slope.
The two unknowns in the equation are:
L = distance between the pipes; and
c = amount of leachate.
Using a maximum allowable head, hmax, of 30
cm (12 in), the equation is usually solved for
"L" (U.S. EPA, 1989).
The amount of leachate, "c", can be estimated
in a variety of ways including the Water
Balance Method (U.S. EPA, 1989) and the
computer model Hydrologic Evaluation of
Landfill Performance (HELP). The HELP
Model is a quasi-two-dimensional hydrologic
model of water movement across, into,
through, and out of landfills. The model uses
climatologic, soil, and landfill design data and
incorporates a solution technique that
accounts for the effects of surface storage,
run-off, infiltration, percolation, soil-moisture
171
-------
Subpart D
Inflow
Source: L'.5. £W. /9S9
Figure 4-8. Definition of Terms for Mound Model
Flow Rate Calculations
172
-------
Design Criteria
storage, evapotranspiration, and lateral
drainage. The program estimates run-off
drainage and leachate that are expected to
result from a wide variety of landfill
conditions, including open, partially open, and
closed landfill cells. The model also may be
used to estimate the depth of leachate above
the bottom liner of the landfill unit. The
results may be used to compare designs or to
aid in the design of leachate collection
systems (U.S. EPA, 1988).
Once the percolation and pipe spacing are
known, the design flow rate can be obtained
using the curve in Figure 4-9. The amount of
leachate percolation at the particular site is
located on the x-axis.
The required flow rate is the point at which
this value intersects with the pipe spacing
value determined from the Mound Model.
Using this value of flow rate and the bottom
slope of the site, the required diameter for the
pipe can be determined (see Figure 4-10).
Finally, the graphs in Figures 4-11 and 4-12
show two ways to determine whether the
strength of the pipe is adequate for the landfill
design. In Figure 4-11, the vertical soil
pressure is located on the y-axis. The density
of the backfill material around the pipe is not
governed by strength, so it will deform under
pressure rather than break. Ten percent is the
absolute limiting deflection value for plastic
pipe. Using Figure 4-11, the applied pressure
on the pipe is located and traced to the trench
geometry, and then the pipe deflection value
is checked for its adequacy (U.S. EPA, 1989).
The LCS specifications should include (U.S.
EPA, 1988):
• Type of piping material;
• Diameter and wall thickness;
• Size and distribution of slots and
perforations;
• Type of coatings (if any) used in the
pipe manufacturing; and
• Type of pipe bedding material and
required compaction used to support the
pipes.
The construction drawings and specifications
should clearly indicate the type of bedding to
be used under the pipes and the dimensions of
any trenches. The specifications should
indicate how the pipe lengths are joined. The
drawings should show how the pipes are
placed with respect to the perforations. To
maintain the lowest possible leachate head,
there should be perforations near the pipe
invert, but not directly at the invert. The pipe
invert itself should be solid to allow for
efficient pipe flow at low volumes (U.S. EPA,
1988).
When drainage pipe systems are embedded in
filter and drainage layers, no unplugged ends
should be allowed. The filter materials in
contact with the pipes should be appropriately
sized to prevent migration of the material into
the pipe. The filter media, drainage layer, and
pipe network should be compatible and should
represent an integrated design.
Protection of Leachate Collection Pipes
The long-term performance of the LCS
depends on the design used to protect pipes
from physical clogging (sedimentation) by the
granular drainage materials. Use of a graded
material around the pipes is most effective if
accompanied by proper sizing of pipe
perforations. The Army Corps of
173
-------
Subpart D
Percolation, in Inches per Month
*Where b = width of area contributing to leachate collection pipe
Source: U.S. EPA. 1989
Figure 4-9. Required Capacity of Leachate Collection Pipe
174
-------
1000
o
o
600
300
200
1
0.9
0.8
0.7
0.6
0.5
0.4
\
A
V
\
\
\
\
\ \
\ \
\ V
V
\
\
\
\
\
•Sy"*-*^
U
c
A3
K
«-:
\---\
^s:
^
f^b
P
_c
&
ca
•s
VI
a
100
\^
'"k
"
*
0.2
50
0.1
V
\
V*
Pipe Flowing Full
Based on Manning's Equation n=0.010
0.1
0.2 0.3 0.4 0.5 0.6 0.8 1.0
2.0 3.0 4.0 5.0 6.0 8.0 10
10 20 30 40 60
Source: U.S. EPA, 1989
Slope of Pipe in Feet per Thousand Feet
Figure 4-10. Leachate Collection Pipe Sizing Chart
-------
Subpart D
n
95% Soil
Density
12.000
10.000
8.000
6.000
4.000
2.000
Initial Effect of Ring Stiffness i
i i
85% Soil
Density
90%
75% Soil
Density
75% Soil Density Plot of
Vertical Soil Strain £
0 5 10 15 20 25
Ring Deflection, AY/D (%) = 6 Except as Noted
Source: U.S. EPA. 1989
Figure 4-11. Vertical Ring Deflection Versus Vertical Soil Pressure for
18-inch Corrugated Polyethylene in High Pressure Soil Cell
176
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Design Criteria
a
•
B/D = 7.73
B/D = 7.5
B/D = 1.8
Vertical Soil Strain £
for Native Soil @
75% Density
25
30
Ring Deflection, AY/D (%)
Source: U.S. EPA, 1989
Figure 4-12. Example of the Effect of Trench Geometry
and Pipe Sizing on Ring Deflection
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Subpart D
Engineers (GCA Corporation, 1983) has
established design criteria using graded filters
to prevent physical clogging of leachate
drainage layers and piping by soil sediment
deposits. When installing graded filters,
caution should be taken to prevent segregation
of the material (USEPA, 199la).
Clogging of the pipes and drainage layers of
the leachate collection system can occur
through several other mechanisms, including
chemical and biological fouling (USEPA,
1988). The LCS should be designed with a
cleanout access capable of reaching all parts
of the collection system with standard pipe
cleaning equipment.
Chemical clogging can occur when dissolved
species in the leachate precipitate in the
piping. Clogging can be minimized by
periodically flushing pipes or by providing a
sufficiently steep slope in the system to allow
for high flow velocities for self-cleansing.
These velocities are dependent on the
diameter of the precipitate particles and on
their specific gravity. ASCE (1969) discusses
these relationships. Generally, flow velocities
should be in the range of one or two feet per
second to allow for self-cleansing of the
piping (U.S. EPA, 1988).
Biological clogging due to algae and bacterial
growth can be a serious problem in MSWLF
units. There are no universally effective
methods of preventing such biological
growth. Since organic materials will be
present in the landfill unit, there will be a
potential for biological clogging. The system
design should include features that allow for
pipe system cleanings. The components of
the cleaning system should include (U.S.
EPA, 1991b):
• A minimum of six-inch diameter pipes
to facilitate cleaning;
• Access located at major pipe
intersections or bends to allow for
inspections and cleaning; and
• Valves, ports, or other appurtenances to
introduce biocides and/or cleaning
solutions.
In its discussion of drainage layer protection,
the following section includes further
information concerning protection of pipes
using filter layers.
Protection of the High-Permeability
Drainage Layer
The openings in drainage materials, whether
holes in pipes, voids in gravel, or apertures in
geonets, must be protected against clogging
by accumulation of fine (silt-sized) materials.
An intermediate material that has smaller
openings than those of the drainage material
can be used as a filter between the waste and
drainage layer. Sand may be used as filter
material, but has the disadvantage of taking
up vertical space (USEPA, 1989). Geotextiles
do not use up air space and can be used as
filter materials.
Soil Filter Layers
There are three parts to an analysis of a sand
filter that is placed above drainage material.
The first determines whether or not the filter
allows adequate flow of liquids. The second
evaluates whether the void spaces are small
enough to prevent solids from being lost from
the upstream materials. The third estimates
the long-term clogging behavior of the filter
(U.S. EPA, 1989).
The particle-size distribution of the drainage
system and the particle-size distribution of the
invading (or upstream) soils are required
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Design Criteria
in the design of granular soil (sand filter)
materials. The filter material should have its
large and small size particles intermediate
between the two extremes. Equations for
adequate flow and retention are:
• Adequate Flow:
d85f> (3 to 5)d15ds
• Adequate Retention:
d15f< (3 to 5)d85wf
Where f = required filter soil;
d.s. = drainage stone; and
w.f = water fines.
There are no quantitative methods to assess
soil filter clogging, although empirical
guidelines are found in geotechnical
engineering references.
The specifications for granular filter layers
that surround perforated pipes and that protect
the drainage layer from clogging are based on
a well-defined particle size distribution. The
orientation and configuration of filter layers
relative to other LCS components should be
shown on all drawings and should be
described, with ranges of particle sizes, in the
materials section of the specifications (U.S.
EPA, 1988a).
Thickness is an important placement criterion
for granular filter material. Generally, the
granular filter materials will be placed around
perforated pipes by hand, forming an
"envelope." The dimensions of the envelope
should be clearly stated on the drawings or in
the specifications. This envelope can be
placed at the same time as the granular
drainage layer, but it is important that the
filter envelope protect all areas of the pipe
where the clogging potential exists. The plans
and
specifications should indicate the extent of the
envelope. The construction quality control
program should document that the envelope
was installed according to the plans and
specifications (U.S. EPA, 1988).
A granular filter layer is generally placed
using the same earthmoving equipment as the
granular drainage layer. The final thickness
should be checked by optical survey or by
direct test pit measurement (U.S. EPA, 1988).
This filter layer is the uppermost layer in the
leachate collection system. A landfill design
option includes a buffer layer, 12 inches thick
(30 cm) or more, to protect the filter layer and
drainage layer from damage due to traffic.
This final layer can be general fill, as long as
it is no finer than the soil used in the filter
layer (U.S. EPA, 1988). However, if the
layer has a low permeability, it will affect
leachate recirculation attempts.
Geotextile Filter Layers
Geotextile filter fabrics are often used. The
open spaces in the fabric allow liquid flow
while simultaneously preventing upstream
fine particles from fouling the drain.
Geotextiles save vertical space, are easy to
install, and have the added advantage of
remaining stationary under load. Geotextiles
also can be used as cushioning materials
above geomembranes (USEPA, 1989).
Because geotextile filters are susceptible to
biological clogging, their use in areas
inundated by leachate (e.g., sumps, around
leachate collection pipes, and trenches) should
be avoided.
Geotextile filter design parallels sand filter
design with some modifications (U.S. EPA,
1989). Adequate flow is assessed by
179
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Subpart D
comparing the material (allowable)
permittivity to the design imposed
permittivity. Permittivity is measured by the
ASTM D-4491 test method. The design
permittivity utilizes an adapted form of
Darcy's law. The resulting comparison yields
a design ratio, or factor of safety, that is the
focus of the design (U.S. EPA, 1989):
DR = 0allow/0reqd
where:
0aiiow = permittivity from ASTM
D-4491
0reqd= (q/a) (l/hmax)
q/a = inflow rate per unit area
h max = 12 inches
The second part of the geotextile filter design
is determining the opening size necessary for
retaining the upstream soil or particulates in
the leachate. It is well established that the 95
percent opening size is related to particles to
be retained in the following type of
relationship:
095 < fct. (d50, CU, DR)
where:
O95 = 95% opening size of
geotextile;
d50 = 50% size of upstream particles;
CU = Uniformity of the upstream
particle size; and
DR = Relative density of the
upstream particles.
The O95 size of a geotextile in the equation is
the opening size at which 5 percent of a given
value should be less than the particle size
characteristics of the invading materials. In
the test for the O95 size of the geotextile, a
sieve with a very coarse mesh in the bottom is
used as a support. The geotextile is placed on
top of the mesh and is bonded
to the inside so that the glass beads used in the
test cannot escape around the edges of the
geotextile filter. The particle-size distribution
of retained glass beads is compared to the
allowable value using any of a number of
existing formulas (U.S. EPA, 1989).
The third consideration in geotextile design is
long-term clogging. A test method for this
problem that may be adopted by ASTM is
called the Gradient Ratio Test. In this test,
the hydraulic gradient of 1 inch of soil plus
the underlying geotextile is compared with the
hydraulic gradient of 2 inches of soil. The
higher the gradient ratio, the more likely that
a clog will occur. The final ASTM gradient
ratio test will include failure criteria. An
alternative to this test method is a long-term
flow test that also is performed in a
laboratory. The test models a soil-to-fabric
system at the anticipated hydraulic gradient.
The flow rate through the system is
monitored. A long-term flow rate will
gradually decrease until it stops altogether
(U.S. EPA, 1989).
The primary function of a geotextile is to
prevent the migration of fines into the
leachate pipes while allowing the passage of
leachate. The most important specifications
are those for hydraulic conductivity and
retention. The hydraulic conductivity of the
geotextile generally should be at least ten
times the soil it is retaining. An evaluation of
the retention ability for loose soils is based on
the average particle size of the soil and the
apparent opening size (AOS) of the geotextile.
The maximum apparent opening size,
sometimes called equivalent opening size, is
determined by the size of the soil that will be
retained; a geotextile is then selected to meet
that specification. The material specifications
should contain a range of AOS values for the
geotextile, and
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Design Criteria
these AOS values should match those used in
the design calculations (U.S. EPA, 1988).
One of the advantages of geotextiles is their
light weight and ease of placement. The
geotextiles are brought to the site, unrolled,
and held down with sandbags until they are
covered with a protective layer. They are
usually overlapped, not seamed; however, on
slopes or in other configurations, they may be
sewn (U.S. EPA, 1988).
As with granular filter layers, it is important
that the design drawings be clear in their
designation of geotextile placement so that no
potential route of pipe or drainage layer
clogging is left unprotected. If geotextiles are
used on a slope, they should be secured in an
anchor trench similar to those for
geomembranes or geonets (U.S. EPA, 1988).
Leachate Removal System
Sumps, located in a recess at the low point(s)
within the leachate collection drainage layer,
provide one method for leachate removal
from the MSWLF unit. In the past, low
volume sumps have been constructed
successfully from reinforced concrete pipe on
a concrete footing, and supported above the
geomembrane on a steel plate to protect the
geomembrane from puncture. Recently,
however, prefabricated polyethylene
structures have become available. These
structures may be suitable for replacing the
concrete components of the sump and have
the advantage of being lighter in weight.
These sumps typically house a submersible
pump, which is positioned close to the sump
floor to pump the leachate and to maintain a
30 cm (12 in) maximum leachate depth.
Low-volume sumps, however, can present
operational problems. Because they may run
dry frequently, there is an increased
probability of the submersible pumps burning
out. For this reason, some landfill operators
prefer to have sumps placed at depths between
1.0 and 1.5 meters. While head levels of 30
cm or less are to be maintained on the liner,
higher levels are acceptable in sumps.
Alternatively, the sump may be designed with
level controls and with a backup pump to
control initiation and shut-off of the pumping
sequence and to have the capability of
alternating between the two pumps. The
second pump also may be used in conjunction
with the primary pump during periods of high
flow (e.g., following storm events) and as a
backup if the primary pump fails to function.
A visible alarm warning light to indicate
pump failure to the operator also may be
installed.
Pumps used to remove leachate from the
sumps should be sized to ensure removal of
leachate at the maximum rate of generation.
These pumps also should have a sufficient
operating head to lift the leachate to the
required height from the sump to the access
port. Portable vacuum pumps can be used if
the required lift height is within the limit of
the pump. They can be moved in sequence
from one leachate sump to another. The type
of pump specified and the leachate sump
access pipes should be compatible and should
consider performance needs under operating
and closure conditions (U.S. EPA, 1988).
Alternative methods of leachate removal
include internal standpipes and pipe
penetrations through the geomembrane, both
of which allow leachate removal by gravity
flow to either a leachate pond or exterior
pump station. If a leachate removal standpipe
is used, it should be extended through the
entire landfill from liner to
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Subpart D
cover and then through the cover itself. If a
gravity drainage pipe that requires
geomembrane penetration is used, a high
degree of care should be exercised in both the
design and construction of the penetration.
The penetration should be designed and
constructed in a manner that allows
nondestructive quality control testing of 100
percent of the seal between the pipe and the
geomembrane. If not properly constructed
and fabricated, geomembrane penetrations can
become a source of leakage through the
geomembrane.
Other Design Considerations
The stability of the individual leachate
collection system components placed on
geomembrane-covered slopes should be
considered. A method for calculating the
factor of safety (FS) against sliding for soils
placed on a sloped geomembrane surface is
provided in Koerner (1990). This method
considers the factors affecting the system,
including the slope length, the slope angle,
and the friction angle between the
geomembrane and its cover soil. Generally,
the slope angle is known and is specified on
the design drawings. A minimum FS is then
selected. From the slope angle and the FS, a
minimum allowable friction angle is
determined, and the various components of
the liner system are selected based on this
minimum friction angle. If the design
evaluation results in an unacceptably low FS,
then either the sidewall slope or the materials
should be changed to produce an adequate
design (U.S. EPA, 1988). For short slopes in
a landfill unit, the FS can be as low as 1.1 to
1.2 if the slope will be unsupported (i.e., no
waste will be filled against it) for only a short
time, and if any failures that do occur can be
repaired fairly easily. Longer slopes may
require higher factors of safety due to the
potential of
sliding material to tear the geomembrane
along the slope or near the toe of the slope.
Construction Quality Assurance and
Quality Control
The following section is excerpted from U.S.
EPA (1992). This section discusses quality
assurance and quality control (QA/QC)
objectives. For a more detailed discussion on
QA/QC and specific considerations, refer to
U.S. EPA (1992).
CQA/CQC Objectives
Construction quality assurance (CQA)
consists of a planned series of observations
and tests to ensure that the final product meets
project specifications. CQA plans,
specifications, observations, and tests are used
to provide quantitative criteria with which to
accept the final product.
On routine construction projects, CQA is
normally the concern of the owner and is
obtained using an independent third-party
testing firm. The independence of the third-
party inspection firm is important, particularly
when the owner is a corporation or other legal
entity that has under its corporate "umbrella"
the capacity to perform the CQA activities.
Although "in-house" CQA personnel may be
registered professional engineers, a perception
of misrepresentation may exist if CQA is not
performed by an independent third party.
The CQA officer should fully disclose any
activities or relationships with the owner
that may impact his impartiality or
objectivity. If such activities or
relationships exist, the CQA officer should
describe actions that have been or can be
taken to avoid, mitigate, or neutralize the
possibility they might affect the CQA
182
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Design Criteria
officer's objectivity. Regulatory
representatives can then evaluate whether
these mechanisms are sufficient to ensure an
acceptable CQA product.
Construction quality control (CQC) is an
on-going process of measuring and
controlling the characteristics of the product
in order to meet manufacturer's or project
specifications. CQC is a production tool
that is employed by the manufacturer of
materials and by the contractor installing the
materials at the site. CQA, by contrast, is a
verification tool employed by the facility
owner or regulatory agency to ensure that
the materials and installations meet project
specifications. CQC is performed
independently of the CQA Plan. For
example, while a geomembrane liner
installer will perform CQC testing of field
seams, the CQA program will require
independent CQA testing of those same
seams by a third-party inspector.
The CQA/CQC plans are implemented
through inspection activities that include
visual observations, field testing and
measurements, laboratory testing, and
evaluation of the test data. Inspection
activities typically are concerned with four
separate functions:
• Quality Control (QC) Inspection by
the Manufacturer provides an in-
process measure of the product quality
and its conformance with the project
plans and specifications. Typically,
the manufacturer will QC test results
to certify that the product conforms to
project plans and specifications.
Construction Quality Control (CQC)
Inspection by the Contractor provides
an in-process measure of construction
quality and conformance with the
project plans and specifications,
thereby allowing the contractor to
correct the construction process if the
quality of the product is not meeting
the specifications and plans.
Construction Quality Assurance
(CQA) Testing by the Owner
(Acceptance Inspection) performed by
the owner usually through the third-
party testing firm, provides a measure
of the final product quality and its
conformance with project plans and
specifications. Due to the size and
costs of a typical MSWLF unit
construction project, rejection of the
project at completion would be costly
to all parties. Acceptance Inspections
as portions of the project become
complete allow deficiencies to be
found and corrected before they
become too large and costly.
Regulatory Inspection often is
performed by a regulatory agency to
ensure that the final product conforms
with all applicable codes and
regulations. In some cases, the
regulatory agency will use CQA
documentation and the as-built plans
or "record drawings" to confirm
compliance with the regulations.
Soil Liner Quality Assurance/Quality
Control
Quality control testing performed on
materials used in construction of the landfill
unit includes source testing and construction
testing. Source testing defines material
properties that govern material placement.
Source testing commonly includes moisture
content, soil density, Atterberg limits, grain
size, and laboratory hydraulic conductivity.
Construction testing ensures that landfill
183
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Subpart D
construction has been performed in
accordance with the plans and technical
specifications. Construction testing
generally includes tests of soil moisture
content, density, lift thickness, and
hydraulic conductivity.
The method of determining compliance with
the maximum hydraulic conductivity
criterion should be specified in the QA/QC
plan. Some methods have included the use
of the criterion as a maximum value that
never should be exceeded, while other
methods have used statistical techniques to
estimate the true mean. The sample
collection program should be designed to
work with the method of compliance
determination. Selection of sample
collection points should be made on a
random basis.
Thin wall sampling tubes generally are used
to collect compacted clay samples for
laboratory hydraulic conductivity testing. It
is important to minimize disturbance of the
sample being collected. Tubes pushed into
the soil by a backhoe may yield disturbed
samples. A recommended procedure (when
a backhoe is available during sample
collection) is to use the backhoe bucket as a
stationary support and push the tube into the
clay with a jack positioned between the clay
and the tube. The sample hole should be
filled with bentonite or a bentonite clay
mixture, and compacted using short lifts of
material.
If geophysical methods are used for
moisture and density measurements, it is
recommended that alternative methods be
used less frequently to verify the accuracy
of the faster geophysical methods.
Additional information on testing
procedures can be found in U.S. EPA
(1988b) and U.S. EPA (1990a).
Quality assurance testing for soil liners
includes the same testing requirements as
specified above for control testing.
Generally, the tests are performed less
frequently and are performed by an
individual or an entity independent of the
contractor. Activities of the construction
quality assurance (CQA) officer are
essential to document quality of
construction. The CQA officer's
responsibilities and those of the CQA
officer's staff members may include:
• Communicating with the contractor;
• Interpreting and clarifying project
drawings and specifications with the
designer, owner, and contractor;
• Recommending acceptance or
rejection by the owner/operator of
work completed by the construction
contractor;
• Submitting blind samples (e.g.,
duplicates and blanks) for analysis by
the contractor's testing staff or one or
more independent laboratories, as
applicable;
• Notifying owner or operator of
construction quality problems not
resolved on-site in a timely manner;
• Observing the testing equipment,
personnel, and procedures used by the
construction contractor to check for
detrimentally significant changes over
time;
• Reviewing the construction
contractor's quality control recording,
maintenance, summary, and
interpretations of test data for
accuracy and appropriateness; and
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Design Criteria
• Reporting to the owner/operator on
monitoring results.
Soil Liner Pilot Construction (Test Fill)
A pilot construction or test fill is a small-
scale test pad that can be used to verify that
the soil, equipment, and construction
procedures can produce a liner that performs
according to the construction drawings and
specifications. An owner or operator may
want to consider the option of constructing
a test fill prior to the construction of the
liner. A test pad is useful not only in
teaching people how to build a soil liner, it
also can function as a construction quality
assurance tool. If the variables used to build
a test pad that achieves a IxlO"7 cm/sec
hydraulic conductivity are followed exactly,
then the completed full-size liner should
meet the regulatory requirements (U.S.
EPA, 1989). A test fill may be a cost-
effective method for the contractor to
evaluate the construction methods and
borrow source. Specific factors that can be
examined/tested during construction of a
test fill include (U.S. EPA, 1988b):
• Preparation and compaction of
foundation material to the required
bearing strength;
• Methods of controlling uniformity of
the soil material;
• Compactive effort (e.g., type of
equipment, number of passes) to
achieve required soil density and
hydraulic conductivity;
• Lift thickness and placement
procedures to achieve uniformity of
density throughout a lift and the
absence of apparent boundary effects
between lifts or between placements in
the same lift;
• Procedures for protecting against
desiccation cracking or other site- and
season-specific failure mechanisms for
the finished liner or intermediate lifts;
• Measuring the hydraulic conductivity
on the test fill in the field and
collecting samples of field-compacted
soil for laboratory testing;
• Test procedures for controlling the
quality of construction;
• Ability of different types of soil to
meet hydraulic conductivity
requirements in the field; and
• Skill and competence of the
construction team, including
equipment operators and quality
control specialists.
Geomembrane Quality Assurance/
Quality Control Testing
As with the construction of soil liners,
installation of geomembrane liners should
be in conformance with a quality
assurance/quality control plan. Tests
performed to evaluate the integrity of
geomembrane seams are generally
considered to be either "destructive" or
"non-destructive."
Destructive Testing
Quality control testing of geomembranes
generally includes peel and shear testing of
scrap test weld sections prior to
commencing seaming activities and at
periodic intervals throughout the day.
Additionally, destructive peel and shear
field
185
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Subpart D
tests are performed on samples from the
installed seams.
Quality assurance testing generally requires
that an independent laboratory perform peel
and shear tests of samples from installed
seams. The samples may be collected
randomly or in areas of suspect quality.
HDPE seams are generally tested at
intervals equivalent to one sample per every
300 to 400 feet of installed seam for
extrusion welds, and every 500 feet for
fusion-welded seams. Extrusion seams on
HDPE require grinding prior to welding,
which can greatly diminish parent material
strengths if excessive grinding occurs.
Detailed discussion of polyethylene welding
protocol can be found in U.S. EPA (1991a).
For dual hot wedge seams in HDPE, both
the inner and outer seam may be subjected
to destructive shear tests at the independent
laboratory. Destructive samples of installed
seam welds are generally cut into several
pieces and distributed to:
• The installer to perform construction
quality control field testing;
• The owner/operator to retain and
appropriately catalog or archive; and
• An independent laboratory for peel
and shear testing.
If the test results for a seam sample do not
pass the acceptance/rejection criteria, then
samples are cut from the same field seam on
both sides of the rejected sample location.
Samples are collected and tested until the
areal limits of the low quality seam are
defined. Corrective measures should be
undertaken to repair the length of seam that
has not passed the acceptance/rejection
criteria. In many cases, this involves
seaming a cap over the length of the rejected
seam or reseaming the affected area (U.S.
EPA, 1988). In situations where the seams
continually fail testing, the seaming crews
may have to be retrained.
Non-Destructive Testing
Non-destructive test methods are conducted
in the field on an in-place geomembrane.
These test methods determine the integrity
of the geomembrane field seams. Non-
destructive test methods include the probe
test, air lance, vacuum box, ultrasonic
methods (pulse echo, shadow and
impedance plane), electrical spark test,
pressurized dual seam, electrical resistivity,
and hydrostatic tests. Detailed discussion of
these test methods may be found in U.S.
EPA (199la). Seam sections that fail
appropriate, non-destructive tests must be
carefully delineated, patched or reseamed,
and retested. Large patches or reseamed
areas should be subjected to destructive test
procedures for quality assurance purposes.
The specifications should clearly describe
the degree to which non-destructive and
destructive test methods will be used in
evaluating failed portions of non-destructive
seam tests.
Geomembrane Construction Quality
Assurance Activities
The responsibilities of the construction
quality assurance (CQA) personnel for the
installation of the geomembrane are
generally the same as the responsibilities for
the construction of a soil liner with the
following additions:
• Observation of liner storage area and
liners in storage, and handling of the
liner as the panels are positioned in the
cell;
186
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Design Criteria
• Observation of seam overlap, seam
preparation prior to seaming, and
material underlying the liner;
• Observation of destructive testing
conducted on scrap test welds prior to
seaming;
• Observation of destructive seam
sampling, submission of the samples
to an independent testing laboratory,
and review of results for conformance
to specifications;
• Observation of all seams and panels
for defects due to manufacturing
and/or handling and placement;
• Observation of all pipe penetration
boots and welds in the liner;
• Preparation of reports indicating
sampling conducted and sampling
results, locations of destructive
samples, locations of patches,
locations of seams constructed, and
any problems encountered; and,
• Preparation of record drawings of the
liner installation, in some cases.
The last responsibility is frequently assigned
to the contractor, the owner's representative,
or the engineer.
Leachate Collection System
Construction Quality Assurance
The purpose of leachate collection system
CQA is to document that the system
construction is in accordance with the
design specifications. Prior to construction,
all materials should be inspected to confirm
that
they meet the construction plans and
specifications. These include (U.S. EPA,
1988):
• Geonets;
• Geotextiles;
• Pipe size, materials, and perforations;
• Granular material gradation and
prefabricated structures (sumps,
manholes, etc.);
• Mechanical, electrical, and monitoring
equipment; and
• Concrete forms and reinforcement.
The leachate collection system foundation
(geomembrane or low permeability soil
liner) should be inspected and surveyed
upon its completion to ensure that it has
proper grading and is free of debris and
liquids (U.S. EPA, 1988).
During construction, the following
activities, as appropriate, should be
observed and documented (U.S. EPA,
1988):
• Pipe bedding placement including
quality, thickness, and areal coverage;
• Granular filter layer placement
including material quality and
thickness;
• Pipe installation including location,
configuration, grades, joints, filter
layer placement, and final flushing;
• Granular drainage layer placement
including protection of underlying
liners, thickness, overlap with filter
187
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Subpart D
fabrics and geonets if applicable, and
weather conditions;
• Geonet placement including layout,
overlap, and protection from clogging
by granular material carried by wind
or run-off during construction;
• Geotextile/geofabric placement
including coverage and overlap;
• Sumps and structure installation; and
• Mechanical and electrical equipment
installation including testing.
In addition to field observations, actual field
and laboratory testing may be performed to
document that the materials meet the design
specifications. These activities should be
documented and should include the
following (U.S. EPA, 1988):
• Geonet and geotextile sampling and
testing;
• Granular drainage and filter layer
sampling and testing for grain size
distribution; and
• Testing of pipes for leaks,
obstructions, and alignments.
Upon completion of construction, each
component should be inspected to identify
any damage that may have occurred during
its installation, or during construction of
another component (e.g., pipe crushing
during placement of granular drainage
layer). Any damage that does occur should
be repaired, and these corrective measures
should be documented in the CQA records
(U.S. EPA, 1988).
4.4 RELEVANT POINT OF
COMPLIANCE
40 CFR §258.40(d)
4.4.1 Statement of Regulation
(a) (See Statement of Regulation in
Section 4.2.1 of this guidance document for
the regulatory language for performance-
based design requirements.)
(b) (See Statement of Regulation in
Section 4.3.1 of this guidance document for
the regulatory language for requirements
pertaining to composite liner and leachate
collection systems.)
(c) (See Statement of Regulation in
Section 4.2.1 of this guidance document for
the regulatory language for performance-
based design requirements.)
(d) The relevant point of compliance
specified by the Director of an approved
State shall be no more than 150 meters
from the waste management unit
boundary and shall be located on land
owned by the owner of the MSWLF unit.
In determining the relevant point of
compliance, the State Director shall
consider at least the following factors:
(1) The
characteristics of
surrounding land;
hydrogeologic
the facility and
(2) The volume and physical and
chemical characteristics of the leachate;
(3) The quantity, quality, and
direction of flow of ground water;
(4) The proximity and withdrawal
rate of the ground-water users;
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Design Criteria
(5) The availability of alternative
drinking water supplies;
(6) The existing quality of the
ground water, including other sources of
contamination and their cumulative
impacts on the ground water and whether
the ground water is currently used or
reasonably expected to be used for
drinking water;
(7) Public health, safety, and welfare
effects; and
(8) Practicable capability of the
owner or operator.
4.4.2 Applicability
In States with approved permit programs,
owners/operators may have the opportunity
to employ an alternative liner design, as per
§258.40(a)(l). In these situations, some
flexibility is allowed in terms of
establishing a relevant point of compliance.
The relevant point of compliance may be
located a maximum of 150 meters from the
waste management unit boundary; however,
the location must be on property owned by
the MSWLF unit owner or operator.
In unapproved States the relevant point of
compliance is set at the waste management
unit boundary. The waste management unit
boundary is defined as the vertical surface
located at the hydraulically downgradient
limit of the unit. This vertical surface
extends down into and through the entire
thickness of the uppermost aquifer.
4.4.3 Technical Considerations
At least eight factors should be considered
in establishing the relevant point of
compliance for any design under §258.40.
The factors provide information needed to
determine if the alternative boundary is
sufficiently protective of human health and
the environment and if the relevant point of
compliance is adequate to measure the
performance of the disposal unit.
Site Hydrogeology
The first factor to be considered when
determining the relevant point of
compliance is site hydrogeology. Site
hydrogeologic characteristics should be
used to identify additional information
required to set the relevant point of
compliance. The site data should be
sufficient to determine the lateral well-
spacing required to detect contaminant
releases to the uppermost aquifer.
Hydrogeologic information required to fully
characterize a site is presented in greater
detail in Section 5.6.3.
Leachate Volume and Physical
Characteristics
Data on leachate volume and quality are
needed to make a determination of the
"detectability" of leakage from the facility
at the relevant point of compliance. The net
concentration at any given point resulting
from the transport of contaminants from the
landfill is a function of contaminant type,
initial contaminant concentration, and
leakage rate. Assessment of leachate
volume is discussed in Sections 4.2 and 4.3.
The assessment of contaminant fate and
transport was discussed in Section 4.3.
Quality, Quantity and Direction of
Ground-Water Flow
The hydrogeologic data collected should
provide information to assess the ground-
water flow rate, ground-water flow
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Subpart D
direction, and the volume of ground-water
flow. Background ground-water quality
data should be used to establish baseline
concentrations of the monitoring
constituents. This information will be
required as input to determine if
contaminants from the landfill unit have
been released and have migrated to the
relevant point of compliance.
Ground-Water Receptors
The goal of establishing the relevant point
of compliance is to ensure early detection of
contamination of the uppermost aquifer.
The distance to the relevant point of
compliance should allow sufficient time for
corrective measures to be implemented prior
to the migration of contaminants to private
or public water supply wells.
Existing users of ground water immediately
downgradient from the facility should be
identified on a map. Users located at a
downgradient point where contaminants
might be expected to migrate during the
active life and post-closure care period of
the facility should be identified.
Alternative Drinking Water Supplies
Consideration should be given to the
availability of alternate drinking water
supplies in the event of a ground-water
contamination problem. If the uppermost
aquifer is the sole water supply source
available, all reasonable efforts should be
made to locate the relevant point of
compliance as close as possible to the actual
waste management unit boundary.
Existing Ground-Water Quality
The existing ground-water quality, both
upgradient and downgradient of the
MSWLF
unit, should be determined prior to
establishing the relevant point of
compliance (see Section 5.6.3). The
performance standard for landfill design
requires that landfill units be designed so
that the concentrations listed in Table 1 are
not exceeded at a relevant point of
compliance. Issues for approved States to
consider are whether the ground water is
currently used or is reasonably expected to
be used as a drinking water source when
setting a relevant point of compliance. If
the ground water is not currently or
reasonably expected to be used for drinking
water, the State may allow the relevant
point of compliance to be set near the 150-
meter limit.
Public Health, Welfare, Safety
Consideration should be given to the
potential overall effect on public health,
welfare, and safety of the proposed relevant
point of compliance. Issues that should be
considered include:
• Distance to the nearest ground-water
user or potentially affected surface
water;
• The response time (based on the
distance to the proposed relevant point
of compliance) required to identify
and remediate or otherwise contain
ground water that may become
impacted and potentially affect
downgradient water supplies; and
• The risk that detection monitoring data
may not be representative of a worst
case release of contaminants to ground
water.
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Design Criteria
Practicable Capability of the Owner or
Operator
If the relevant point of compliance is placed
farther from the waste management unit
boundary, the volume of water requiring
treatment, should the ground water become
contaminated, will increase. One or more of
the following conditions could affect the
owner's or operator's practicable capability
(technical and financial) to remediate
contaminant releases:
• Area of impact, remedial costs, scope
of remedial investigation, and site
characterization;
• Increased response time due to higher
costs and increased technical scope of
selected remedial method;
• A reduction of the removal efficiency
of treatment technologies; and
• Increased difficulty in ground-water
extraction or containment if these
technologies are chosen.
The Director may require some indication of
financial capability of the owner or operator
to maintain a longer and more costly
remedial program due to the longer
detection time frame associated with a
relevant point of compliance located at a
greater distance from the waste management
unit boundary. Additional information on
remedial actions for ground water is
provided in this document in Chapter 5.
4.5 PETITION PROCESS
40 CFR §258.40(e)
4.5.1 Statement of Regulation
(a) - (d) (See Statement of Regulation
in Sections 4.2.1, 4.3.1, and 4.4.1 of this
guidance document for regulatory
language.)
(e) If EPA does not promulgate a
rule establishing the procedures and
requirements for State compliance with
RCRA Section 4005(c)(l)(B) by October
9, 1993, owners and operators in
unapproved States may utilize a design
meeting the performance standard in
§258.40(a)(l) if the following conditions
are met:
(1) The State determines the design
meets the performance standard in
§258.40(a)(l);
(2) The State petitions EPA to
review its determination; and
(3) EPA approves the State
determination or does not disapprove the
determination within 30 days.
[Note to Subpart D: 40 CFR Part 239 is
reserved to establish the procedures and
requirements for State compliance with
RCRA Section 4005(c)(l)(B).]
4.5.2 Applicability
If EPA does not promulgate procedures and
requirements for state approval by October
9, 1993, owners and operators of MSWLF
units located in unapproved States may be
able to use an alternative design (in
compliance with §258.40(a)(l)) under
certain circumstances.
191
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Subpart D
Owners or operators of MSWLF units
should contact the municipal solid waste
regulatory department in their State to
determine if their State has been approved
by the U.S. EPA.
192
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Design Criteria
4.6 FURTHER INFORMATION
4.6.1 REFERENCES
(Specific to Performance-Based Design Assessment and Solute Transport Modeling)
Abriola, L.M., and G.F. Finder, (1985a). A Multiphase Approach to the Modeling of Porous
Media Contamination by Organic Compounds 1. Equation Development. Water Resources
Research 21(1):11-18.
Abriola, L.M., and G.F. Finder, (1985b). A Multiphase Approach to the Modeling of Porous
Media Contamination by Organic Compounds 2. Numerical Simulation. Water Resources
Research 21(1): 19-26.
Aller, L., T. Bennett, J.H. Lehr, R.J. Petty, and G. Hackett, (1987). DRASTIC: A Standardized
System for Evaluation Ground Water Pollution Potential Using Hydrogeologic Settings.
EPA-600/2-87-035, Kerr Environmental Research Lab, U.S. Environmental Protection
Agency, Ada, Oklahoma. 455 pp.
Auerbach, S.I., C. Andrews, D. Eyman, D.D. Huff, P.A. Palmer, and W.R. Uhte, (1984).
Report of the Panel on Land Disposal. In: Disposal of Industrial and Domestic Wastes:
Land and Sea Alternatives. National Research Council. National Academy Press.
Washington, DC. pp. 73-100.
Beljin, M.S., (1985). A Program Package of Analytical Models for Solute Transport in
Groundwater "SOLUTE". BASIS, International Groundwater Modeling Center, Holcomb
Research Institute, Butler University, Indianapolis, Indiana. 163 pp.
Bond, F., and S. Hwang, (1988). Selection Criteria for Mathematical Models Used in Exposure
Assessments: Groundwater Models. EPA/600/8-88/075, U.S. Environmental Protection
Agency, Washington, DC.
Boutwell, S.H., S.M. Brown, B.R. Roberts, and D.F. Atwood, (1986). Modeling Remedial
Actions at Uncontrolled Hazardous Waste Sites. EPA/540/2-85/001, U.S. Environmental
Protection Agency, Athens, Georgia.
Cederberg, G.A., R.L. Street, and J.O. Leckie, (1985). A Groundwater Mass Transport and
Equilibrium Chemistry Model for Multicomponent Systems. Water Resources Research,
21(8):1095-1104.
Dean, J.D., P.S. Huyakorn, A.S. Donigian, Jr., K.S. Voos, R.W. Schanz, YJ.Meeks, and R.F.
Carsel, (1989). Risk of Unsaturated/Saturated Transport and Transformation of Chemical
Concentrations (RUSTIC). EPA/600/3-89/048a, U.S. EPA, Athens, Georgia.
193
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Subpart D
de Marsily, G., (1986). Quantitative Hydrogeology: Groundwater Hydrology for Engineers.
Academic Press, San Diego, California. 440 pp.
Dillon, R.T., R.M. Cranwell, R.B. Lantz, S.B. Pahwa, and D.S. Ward, (1978). Risk
Methodology for Geologic Disposal of Radioactive Waste: The Sandia Waste Isolation
Flow and Transport (SWIFT) model. Sand 78-1267/NUREG-CR-0424, Sandia national
Laboratories, Albuquerque, New Mexico.
Domenico, P.A., and V.V. Palciauskas, (1982). Alternative Boundaries in Solid Waste
Management. Ground Water, 20(3):303-311.
Domenico, P.A., and G.A. Robbins, (1985). A New Method for Contaminant Plume Analysis.
Ground Water, 23(4):476-485.
Donigian, A.S., and P.S.C. Rao, (1990). Selection, Application, and Validation of
Environmental Models. In: Proceedings of the International Symposium on Water Quality
Modeling of Agricultural Non-Point Sources, Part 2. D.G. DeCoursey (ed.). ARS-81,
U.S. Department of Agriculture Agricultural Research Services, pp. 577-600.
Erdogen, H., and R.D. Heufeld, (1983). Modeling Leachates at Landfill Boundaries. Journal
of Environmental Engineering, 109(5): 1181-1194.
Faust, C.R., J.H. Guswa, and J.W. Mercer, (1989). Simulation of Three-Dimensional Flow of
Immiscible Fluids Within and Below the Unsaturated Zone. Water Resources Research,
25(12):2449-2464.
Freeze, R.A., and J.A. Cherry, (1979). Ground Water. Prentice-Hall, Englewood Cliffs, New
Jersey. 604 pp.
GeoTrans, Inc., (1985). SWANFLOW: Simultaneous Water, Air and Non-Aqueous Phase
Flow, Version 1.0-Code Documentation. Herndon, Virginia. 97 pp.
Grove, D.B., and K.G. Stollenwerk, (1987). Chemical Reactions Simulated by Groundwater
Quality Models. Water Resources Bulletin, 23(4):601-615.
Gupta, S.K., C.R. Cole, C.T. Kincaid, and F.E. Kaszeta, (1982). Description and Applications
of the FE3DGW and CFEST Three-dimensional Finite Element Models, Battelle Pacific
NW Laboratories, Richland, Washington.
Gupta, S.K., C.T. Kincaid, P. Meyer, C. Newbill, and C.R. Cole, (1982). CFEST:
Multidimensional Finite Element Code for the Analysis of Coupled Fluid, Energy and
Solute Transport. PNL-4260, Battelle Pacific NW Laboratories, Richland, Washington.
194
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Design Criteria
Gureghian, A.B., D.S. Ward, and R.W. Cleary, (1980). A Finite Element Model for the
Migration of Leachate from a Sanitary Landfill in Long Island, New York - Part I:
Theory. Water Resources Bulletin, 16(5):900-906.
Guvanasen, V., (1984). Development of A Finite Element Code and Its Application to
Geoscience Research. Proceedings 17th Information Meeting of the Nuclear Fuel Waste
Management Program, Atomic Energy of Canada, Ltd. Technical Record TR-199. pp.
554-566.
Haji-Djafari, S., (1983). User's Manual GEOFLOW Groundwater Flow and Mass Transport
Computer Program. D'Appolonia, Pittsburgh, Pennsylvania.
Huyakorn, P.S. et al., (1984). Testing and Validation of Models for Simulating Solute
Transport in Groundwater: Development, Evaluation and Comparison of Benchmark
Techniques. GWMI 84-13, International Groundwater Modeling Center, Holcomb
Research Institute, Indianapolis, Indiana.
Huyakorn, P.S., M.J. Ungs, L.A. Mulkey, and E.A. Sudicky, (1987). A Three-Dimensional
Analytical Method for Predicting Leachate Migration. Ground Water, 25(5):588-598.
Huyakorn, P.S., H.O. White, Jr., V.M. Guvanasen, and B.H. Lester, (1986). TRAFRAP: A
Two-dimensional Finite Element Code for Simulating Fluid Flow and Transport of
Radionuclides in Fractured Porous Media. FOS-33, International Groundwater Modeling
Center, Holcomb Research Institute, Butler University, Indianapolis, Indiana.
Javandel, I., C. Doughty, and C.F. Tsang, (1984). Groundwater Transport: Handbook of
Mathematical Models. Water Resources Monogram 10, American Geophysical Union,
Washington, DC 228 pp.
Keely, J.F., (1987). The Use of Models in Managing Ground-Water Protection Programs. U.S.
Environmental Protection Agency. EPA/600/8-87/003, Ada, Oklahoma. 72 pp.
Keely, J.F., (1989). Performance Evaluations of Pump-and-Treat Remediations. EPA/540/4-
89/005, U.S. Environmental Protection Agency, Ada, Oklahoma. 19 pp.
Kincaid, C.T., J.R. Morrey, and I.E. Rogers, (1984a). Geohydrochemical Models for Solute
Migration- Volume 1: Process Description and Computer Code Selection. EA-3417,
Electric Power Research Institute, Palo Alto, California.
Kincaid, C.T., J.R. Morrey, S.B. Yabusaki, A.R. Felmy, and I.E. Rogers, (1984b).
Geohydrochemical Models for Solute Migration- Volume 2: Preliminary Evaluation of
Selected Computer Codes. EA-3417, Electric Power Research Institute, Palo Alto,
California.
195
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Subpart D
Kipp, K.L., Jr., (1987). HST3D: A Computer Code for Simulation of Heat and Solute Transport
in Three-Dimensional Groundwater Flow Systems. WRI 86-4095, U.S. Geological
Survey, Lakewood, Colorado.
Konikow, L.F., and J.D. Bredehoeft, (1985). Method-of-Characteristics Model for Solute
Transport (1985 revision). U.S. Geological Survey.
Lindstrom, F.T., and L. Boersma, (1989). Analytical Solutions for Convective-Dispersive
Transport in Confined Aquifers with Different Initial and Boundary Conditions. Water
Resources Research, 25(2):241-256.
Lu, J.C.S., B. Eichenberger, and R.J. Stearns, (1985). Leachate Migration from Municipal
Landfills. Pollution Technology Review No. 19. Noyes Publications, Park Ridge, New
Jersey. 453 pp.
Mercer, J.W., S.D. Thomas, and B. Ross, (1983). Parameters and Variables Appearing in
Repository Siting Models. NUREG/CR-3066. Prepared for U.S. Nuclear Regulatory
Commission, Washington, DC. 244 pp.
Mulkey, L.A., A.S. Donigian, Jr., T.L. Allison, and C.S. Raju, (1989). Evaluation of Source
Term Initial Conditions for Modeling Leachate Migration from Landfills. U.S. EPA,
Athens, Georgia.
Narasimhan, T.N., A.F. White, and T. Tokunaga. 1986. Groundwater Contamination From an
Inactive Uranium Mill Tailings Pile 2. Application of a Dynamic Mixing Model. Water
Resources Research, 22(13): 1820-1834.
National Research Council, (1990). Ground Water Models: Scientific and Regulatory
Applications. National Academy Press, Washington, DC. 320 pp.
Nelson, R.W., and J.A. Schur, (1980). PATHS Groundwater Hydrologic Model. PNL-3162,
Battelle Pacific NW Laboratories, Richland, Washington.
Osborne, M., and J. Sykes, (1986). Numerical Modeling of Immiscible Organic Transport at
the Hyde Park Landfill. Water Resources Research, 22(l):25-33.
Ostendorf, D.W., R.R. Noss, and D.O. Lederer, (1984). Landfill Leachate Migration through
Shallow Unconfmed Aquifers, Water Resources Research, 20(2):291-296.
Oster, P. A. Review of Ground-Water Flow and Transport Models in the Unsaturated Zone,
(1982). NUREG/CR-2917, PNL-4427. Pacific Northwest Laboratory, Richland,
Washington.
Prakash, A., (1984). Groundwater Contamination Due to Transient Sources of Pollution. J. of
Hydraulic Engineering, 110(11): 1642-1658.
196
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Design Criteria
Prickett, T.A., T.G. Naymik, and C.G. Lonnquist, (1981). A Random-Walk Solute Transport
Model for Selected Groundwater Quality Evaluations. Bulletin 65, Illinois State Water
Survey, Champaign, Illinois.
Runchal, A.K., (1985). PORFLOW: A General Purpose Model for Fluid Flow, Heat Transfer
and Mass Transport in Anisotropic, Inhomogeneous, Equivalent Porous Media, Volume
I: Theory, Volume II: User's Manual. ACRI/TN-O11. Analytic and Computational
Research, Inc. West Los Angeles, California.
Runchal, A.K., (1985). Theory and Application of the PORFLOW Model for Analysis of
Coupled Flow, Heat and Radionuclide Transport in Porous Media. Proceedings,
international Symposium on Coupled Processes Affecting the Performance of a Nuclear
Waste Repository, Berkeley, California.
Salhotra, A.M., P. Mineart, S. Sharp-Hansen, and T. Allison, (1990). Multimedia Exposure
Assessment Model (MULTIMED) for Evaluating the Land Disposal of Wastes—Model
Theory. Prepared for U.S. Environmental Protection Agency, Environmental Research
Laboratory, Athens, Georgia.
Schroeder, A.C., A.C. Gibson, and M.D. Smolen, (1984). The Hydrologic Evaluation of
Landfill Performance (HELP) Model, Volumes I and II. EPA/530/SW-009 and
EPA/530/SW-010, U.S. Environmental Protection Agency, Cincinnati, Ohio.
Sharp-Hansen, S., C. Travers, P. Hummel, and T. Allison, (1990). A Subtitle D Landfill
Application Manual for the Multimedia Exposure Assessment Model (MULTIMED).
Prepared for the U.S. EPA, Environmental Research Laboratory, Athens, Georgia.
Summers, K.V., S.A. Gherini, M.M. Lang, M.J. Ungs, and K.J. Wilkinson, (1989). MYGRT
Code Version 2.0: An IBM Code for Simulating Migration of Organic and Inorganic
Chemicals in Groundwater. EN-6531. Electric Power Research Institute, Palo Alto,
California.
Temple, Barker and Sloane, Inc., (1988). Draft Regulatory Impact Analysis of Proposed
Revisions to Subtitle D Criteria for Municipal Solid Waste Landfills. Prepared for Office
of Solid Waste, U.S. Environmental Protection Agency.
Theis, T.L., D.J. Kirkner and A.A. Jennings, (1982). Multi-Solute Subsurface Transport
Modeling for Energy Solid Wastes. Technical Progress Report for the Period September
1, 1981-August 31, 1982, COO-10253-3, Prepared for Ecological Research Division,
Office of Health and Environmental Research, U.S. Department of Energy.
Travers, C.L., and S. Sharp-Hansen, (1991). Leachate Generation and Migration at Subtitle D
Facilities: A Summary and Review of Processes and Mathematical Models. Prepared for
U.S. EPA, Environmental Research Laboratory, Athens, Georgia.
197
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Subpart D
Travis, B., (1984). TRACR3D: A Model of Flow and Transport in Porous/Fractured Media.
LA-9667-MS. Los Alamos National Laboratory, Los Alamos, New Mexico.
Unge, M.J., K.V. Summers, and S.A. Gherini, (1986). MYGRT: An IBM Personal Computer
Code for Simulation Solute Migration in Groundwater, User's Manual. EA-4545-CCM.
Electric Power Research Institute, Palo Alto, California.
U.S. EPA, (1988). Superfund Exposure Assessment Manual. EPA/540/1-88/001, Washington,
DC. NTISNo. PB89-135859. 157pp.
U.S. EPA, (1993). Compilation of Ground-Water Models; PB93-209401; U.S. EPA; Office of
Solid Waste; Washington, D.C.
van der Heijde, P.K., Y. Bachmat, J. Bredehoeft, B. Andrews, D. Holtz, and S. Sebastian,
(1985). Groundwater Management: The Use of Numerical Models. American
Geophysical Union, Washington, D.C.
van der Heijde, P.K., and M.S. Beljin, (1988a). Model Assessment for Delineating Wellhead
Protection Areas. EPA-440/6-88-002, U.S. EPA, Washington, DC.
van der Heijde, P.K., El-Kadi, A.I., and S.A. Williams, (1988b). Groundwater Modeling: An
Overview and Status Report. EPA/600/2-89/028, U.S. EPA, Ada, Oklahoma.
van Genuchten, M.T., (1978). Simulation Models and Their Application to Landfill Disposal
Siting; A Review of Current Technology. In Land Disposal of Hazardous Wastes. EPA-
660/9-78-016, U.S. EPA, Cincinnati, Ohio.
van Genuchten, M.T., and WJ. Alves, (1982). Analytical Solutions of the One-Dimensional
Convective-Dispersive Solute Transport Equation. USDA, Technique Bulletin No. 1661.
U.S. Department of Agriculture, Washington, DC.
Versar, Inc., (1987). Current and Suggested Practices in the Validation of Exposure Assessment
Models, Draft Report. Prepared for U.S. EPA Office of Health and Environmental
Assessment, Exposure Assessment Group, Washington, DC. EPA Contract No. 69-02-
4254, Work Assignment No. 55.
Voss, C.I., (1984). SUTRA: A Finite Element Simulation Model for Saturated-Unsaturated
Fluid Density-Dependent Groundwater Flow with Energy Transport or Chemically
Reactive Single Species Solute Transport. Water Resources Investigations 84-4369, U.S.
Geological Survey.
Walton, W.C., (1984). 35 Basic Groundwater Model Programs for Desktop Microcomputers.
GWMI 84-06/4, International Groundwater Modeling Center, Holcomb Research Institute,
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198
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Design Criteria
Weaver, I, C.G. Enfield, S. Yates, D. Kreamer, and D. White, (1989). Predicting Subsurface
Contaminant Transport and Transformation: Considerations for Model Selection and Field
Validation. U.S. EPA, Ada, Oklahoma.
Yeh, G.T., (1981). AT123D: Analytical, Transient, One-, Two-, Three-Dimensional
Simulation of Waste Transport in the Aquifer System. Publication No. 1439. Oak Ridge
National Laboratory, Oak Ridge, Tennessee.
Yeh, G.T., (1990). Users' Manual of a Three-Dimensional Hybrid Lagrangian-Eulerian Finite
Element Model of WASTE Transport through Saturated-Unsaturated Media. Pennsylvania
State University, University Park, PA.
Yeh, G.T., and D.S. Ward, (1981). FEMWASTE: A Finite-Element Model of Waste Transport
through Saturated-Unsaturated Porous Media. ORNL-5601. Oak Ridge National
Laboratory, Oak Ridge, Tennessee.
Yeh, G.T., and D.S. Ward, (1987). FEMWATER: A Finite-Element Model of Water Flow
through Saturated-Unsaturated Porous Media. ORNL-5567/R1. Oak Ridge National
Laboratory, Oak Ridge, Tennessee.
4.6.2 REFERENCES
(Specific to Design Criteria)
ASCE, (1969). "Design and Construction of Sanitary and Storm Sewers"; ASCE Manual on
Engineering Practice; No. 37.
Bear, Jacob and Arnold Veruijt, (1987). "Modeling Groundwater Flow and Pollution"; D.
Reidel Publishing Company; Dordracht, Holland.
Benson, Craig H. and David E. Daniel, (1990). "Influence of Clods on Hydraulic Conductivity
of Compacted Clay"; Journal of Geotechnical Engineering; Volume 116, No. 8; August,
1990.
Bonaparte, R. and Gross, B.A., (1990). "Field Behavior of Double-Liner Systems. In Waste
Containment Systems: Construction, Regulation, and Performance, Edited by R.
Bonaparte. Geotechnical Pub 1.26, ASCE.
Carroll, Jr., R.G., (1987). "Hydraulic Properties of Geotextiles." Geotextile Testing and the
Design Engineers, ASTEM 952, American Society for Testing and Materials, Philadelphia,
PA, pp 7-20.
COE, (1970). "Laboratory Soils Testing"; EMI 110-2-1906; Headquarters, Department of the
Army; Office of the Chief of Engineers; Washington, DC 20314.
199
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Subpart D
FHWA, (1985). "FHWA Geotextile Engineering Manual." Contract No.l DTP H61-83-C-
00150.
FHWA, (1990). "Geotextile Design & Construction Guidelines. Contract No. FHWA
DTFH61-86-C-00102.
GCA Corporation, (1983). "Draft Permit Writers' Guidance Manual for Hazardous Waste
Treatment, Storage, and Disposal Facility"; 1983.
Giroud, J.P., (1982). "Filter Criteria for Geotextiles," Proceeding 2nd International Conference
on Geotextiles, Las Vegas, Nevada.
Giroud, J.P. and R. Bonaparte, (1989). "Leakage Through Liners Constructed with
Geomembranes - Part I: Geomembrane Liners"; Geotextiles and Geomembranes 8(2);
0266-1144/89; pp. 27-67; Elsevier Science Publishers Ltd., England, Great Britain.
Giroud, J.P. and R. Bonaparte, (1989). "Leakage Through Liners Constructed with
Geomembranes - Part II: Composite Liners"; Geotextiles and Geomembranes 8(2); 0266-
1144/89; pp. 71-111; Elsevier Science Publishers Ltd., England, Great Britain.
Giroud, J.P., A. Khatami and K. Badu-Tweneboah, (1989). "Technical Note - Evaluation of the
Rate of Leakage Through Composite Liners"; Geotextiles and Geomembranes 8; 0266-
1144/89; pp. 337-340; Elsevier Science Publishers Ltd., England, Great Britain.
Haxo, H.E., Jr., (1983). "Analysis and Fingerprinting of Unexposed and Exposed Polymeric
Membrane Liners"; Proceedings of Ninth Annual Research Symposium: Land Disposal,
Incineration, and Treatment of Hazardous Waste; EPA/600/9-83/018; U.S. EPA;
Cincinnati, Ohio.
Haxo, H.E., Jr., J.A. Miedema and H.A. Nelson, (1984). "Permeability of Polymeric Membrane
Lining Materials"; Matrecon, Inc.; Oakland, California; International Conference on
Geomembranes; Denver, Colorado.
Industrial Fabrics Association International (1990). "1991 Specifiers Guide;" Geotechnical
Fabrics Report, Volume 8, No. 7, 1990.
Javendale, I., C. Doughty and C.F. Tsang, (1984). "Groundwater Transport; Handbook of
Mathematical Models"; American Geophysical Union; Washington, DC 20009.
Jayawickrama, P.W., K.W. Brown, J.C. Thomas and R.L. Lytton, (1988). "Leakage Rates
Through Flaws in Membrane Liners"; Journal of Environmental Engineering; Vol. 114,
No. 6; December, 1988.
200
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Design Criteria
Kastman, Kenneth A., (1984). "Hazardous Waste Landfill Geomembrane: Design, Installation
and Monitoring"; Woodward-Clyde Consultants, Chicago, Illinois; International
Conference on Geomembranes; Denver, Colorado.
Koerner, Robert M., (1990). "Designing with Geosynthetics"; 2nd Edition; Prentice Hall;
Englewood-Cliffs, New Jersey 07632.
Radian Corporation, (1987). "Technical Data Summary: Hydraulic Performance of Minimum
Technology Double Liner Systems"; Radian Corporation; Austin, Texas 78766 for U.S.
EPA; Contract No. 68-01-7310; Task 7-4.
U.S. EPA, (1982). "Landfill and Surface Impoundment Performance Evaluation"; SW-869;
Charles A. Moore; U.S. EPA. NTIS PB-81-166357.
U.S. EPA, (1983). "Lining of Waste Impoundment and Disposal Facilities"; SW-870; U.S.
EPA; Office of Solid Waste and Emergency Response; Washington, DC 20460. NTIS PB-
81-166365 Revised: PB-86-192796.
U.S. EPA, (1987a). "Background Document on Bottom Liner Performance in Double-Lined
Landfills and Surface Impoundments"; EPA/530/SW-87/013; U.S. EPA; Washington, DC.
NTISPB-87-182291.
U.S. EPA, (1987b) " Characterization of MWC Ashes and Leachates from MSW Landfills,
Monofills and Co-Disposal Sites: Volume VI of VII; Characterization of Leachates from
Municipal Solid Waste Disposal Sites and Co-Disposal Sites"; EPA/530/SW-87/028F,
Washington, D.C. NTIS PB-88-127998.
U.S. EPA, (1988). "Guide to Technical Resources for the Design of Land Disposal Facilities";
EPA/625/6-88/018; U.S. EPA; Risk Reduction Engineering Laboratory; Center for
Environmental Research Information; Cincinnati, Ohio 45268.
U.S. EPA, (1988a). Superfund Exposure Assessment Manual. EPA/540/1-88/001, Washington,
D.C., NTIS No. PB89-135.859, 157 pp.
U.S. EPA, (1988b). "Design, Construction and Evaluation of Clay Liners for Waste
Management Facilities; EPA/530/SW-86/007F; U.S. EPA; Office of Solid Waste and
Emergency Response; Washington, DC 20460. NTIS PB-86-184496.
U.S. EPA, (1988c). "Groundwater Modeling: An Overview and Status Report";
EPA/600/2-89/028; U.S. EPA; Environmental Research Laboratory; Ada, Oklahoma
74820. NTIS PB-89-224497.
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Subpart D
U.S. EPA, (1988d). "Multimedia Exposure Assessment Model for Evaluating the Land
Disposal of Hazardous Wastes, Volume I"; Woodward-Clyde Consultants, Oakland, CA
94607-4014 for U.S. EPA; Environmental Research Laboratory; Office of Research and
Development; Athens, Georgia 30613.
U.S. EPA, (1988e). "Lining of Waste Containment and Other Impoundment Facilities";
EPA/600/2-88/052; U.S. EPA; Risk Reduction Engineering Laboratories; Cincinnati, Ohio
45268. NTISPB-89-129670.
U.S. EPA, (1989). "Seminar Publication - Requirements for Hazardous Waste Landfill Design,
Construction and Closure"; EPA/625/4-89/022; U.S. EPA; Center for Environmental
Research Information; Office of Research and Development; Cincinnati, Ohio 45268.
U.S. EPA, (1990a). "Seminars - Design and Construction of RCRA/CERCLA Final Covers",
CERI 90-50; U.S. EPA; Office of Research and Development; Washington, DC 20460.
U.S. EPA, (1990b). "Draft - LDCRS Flow Data from Operating Units - Technical Support for
Proposed Liner/Leak Detection System Rule"; Geoservices, Inc. Consulting Engineers;
Norcross, Georgia 30093.
U.S. EPA, (1990c). "Relationship of Laboratory- and Field-Determined Hydraulic
Conductivity in Compacted Clay Layer"; EPA/600/2-90/025; U.S. EPA; Risk Reduction
Engineering Laboratory; Cincinnati, Ohio 45268. NTIS PB-90-257775.
U.S. EPA, (1991a). "Technical Guidance Document: Inspection Techniques for the Fabrication
of Geomembrane Field Seams"; EPA 530/SW-91/051, May 1991, Cincinnati, Ohio.
U.S. EPA, (1991b). "Landfill Leachate Clogging of Geotextiles (and Soil) Filters";
EPA/600/2-91/025, August 1991; Risk Reduction Engineering Laboratory; Cincinnati,
Ohio, 45268. NTIS PB-91-213660.
U.S. EPA, (1992). "Technical Guidance Document: Construction Quality Management for
Remedial Action and Remedial Design Waste Containment Systems"; EPA/540/R-92/073,
October 1992; Risk Reduction Engineering Laboratory, Cincinnati, Ohio 45268 and
Technology Innovation Office, Washington, D.C. 20460.
4.6.3 Models
List of Contacts for Obtaining Leachate Generation and Leachate Migration Models
Center for Exposure Assessment Modeling (CEAM), U.S. EPA, Office of Research and
Development, Environmental Research Laboratory, Athens, Georgia 30605-2720, Model
Distribution Coordinator (706) 546-3549, Electronic Bulletin Board System (706) 546-3402:
MULTIMED, PRZM, FEMWATER/FEMWASTE, LEWASTE/3DLEWASTE
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Design Criteria
Electric Power Research Institute, Palo Alto, California, (214) 655-8883: MYGRT,
FASTCHEM
Geo-Trans Inc., 46050 Manekin Plaza, Suite 100, Sterling, VA 20166, (703) 444-7000:
SWANFLOW, SWIFT, SWIFT II, SWIFT III, SWIFT/386.
Geraghty & Miller, Inc., Modeling Group, 10700 Parkridge Boulevard, Suite 600 Reston,
VA 22091: MODFLOW386, MODPATH386, MOC386, SUTRA386, Quickflow,
International Groundwater Modeling Center, Colorado School of Mines, Golden, Colorado
(303) 273-3103: SOLUTE, Walton35, SEFTRAN, TRAFRAP,
National Technical Information Services (NTIS), 5285 Port Royal Road, Springfield, VA
22161, (703) 487-4650: HELP
Dr. Zubair Saleem, U.S. EPA, 401 M Street SW, Washington, DC, 20460, (202) 260-4767:
EPACML, VHS
Scientific Software Group, P.O. Box 23041, Washington, DC 20026-3041 (703) 620-9214:
HST3D, MODFLOW, MOC, SUTRA, AQUA, SWIMEV.
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CHAPTER 5
SUBPART E
GROUND-WATER MONITORING
AND CORRECTIVE ACTION
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CHAPTER 5
SUBPART E
TABLE OF CONTENTS
5J, INTRODUCTION 211
12 APPLICABILITY 40 CFR $258.50 (a) & fb) 211
5.2.1 Statement of Regulation 211
5.2.2 Applicability 212
5.2.3 Technical Considerations 212
53. COMPLIANCE SCHEDULE 40 CFR $ 258.50 (c) 214
5.3.1 Statement of Regulation 214
5.3.2 Applicability 214
5.3.3 Technical Considerations 214
14 ALTERNATIVE COMPLIANCE SCHEDULES 40 CFR 258.50 (d)(e) & (a) 215
5.4.1 Statement of Regulation 215
5.4.2 Applicability 216
5.4.3 Technical Considerations 217
15 QUALIFICATIONS 40 CFR 258.50 (f) 217
5.5.1 Statement of Regulation 217
5.5.2 Applicability 218
5.5.3 Technical Considerations 218
16 GROUND-WATER MONITORING SYSTEMS 40 CFR $258.51 (a)fb)(d) 219
5.6.1 Statement of Regulation 219
5.6.2 Applicability 220
5.6.3 Technical Considerations 221
Uppermost Aquifer 221
Determination of Background Ground-Water Quality 221
Multi-Unit Monitoring Systems 222
Hydrogeological Characterization 224
Characterizing Site Geology 225
Monitoring Well Placement 235
206
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17 GROUND-WATER MONITORING WELL DESIGN AND CONSTRUCTION 40
CFRS258.51 (c) 241
5.7.1 Statement of Regulation 241
5.7.2 Applicability 241
5.7.3 Technical Considerations 241
Monitoring Well Design 244
Well Casing 244
Filter Pack Design 248
Surface Completion 250
18 GROUND-WATER SAMPLING AND ANALYSIS REQUIREMENTS
40 CFR $258.53 253
5.8.1 Statement of Regulation 253
5.8.2 Applicability 254
5.8.3 Technical Considerations 255
Sample Collection 255
Frequency 255
Water Level Measurements 256
Well Purging 256
Field Analyses 258
Sample Withdrawal and Collection 258
Sample Preservation and Handling 260
Sample Containers 262
Sample Preservation 262
Sample Storage and Shipment 262
Chain-of-Custody Record 263
Sample Labels 263
Sample Custody Seal 264
Field Logbook 264
Sample Analysis Request Sheet 265
Laboratory Records 265
Analytical Procedures 265
Quality Assurance/Quality Control 266
Field Quality Assurance/Quality Control 266
Validation 267
Documentation 268
207
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12 STATISTICAL ANALYSIS 40 CFR $258.53 (g)-(i) 268
5.9.1 Statement of Regulation 268
5.9.2 Applicability 270
5.9.3 Technical Considerations 271
Multiple Well Comparisons 272
Tolerance and Prediction Intervals 273
Individual Well Comparisons 274
Intra-Well Comparisons 274
Treatment of Non-Detects 274
5.10 DETECTION MONITORING PROGRAM 40 CFR $258.54 274
5.10.1 Statement of Regulation 274
5.10.2 Applicability 276
5.10.3 Technical Considerations 277
Independent Sampling for Background 277
Alternative List/Removal of Parameters 279
Alternative Frequency 279
Notification 280
Demonstrations of Other Reasons For Statistical Increase 280
Demonstrations of Other Sources of Error 281
5.11 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(a)-(f) 281
5.11.1 Statement of Regulation 281
5.11.2 Applicability 283
5.11.3 Technical Considerations 285
Alternative List 285
Alternative Frequency 285
5.12 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(e) 286
5.12.1 Statement of Regulation 286
5.12.2 Applicability 287
5.12.3 Technical Considerations 287
Release Investigation 288
Property Boundary Monitoring Well 288
Notification of Adjoining Residents and Property Owners 288
Demonstrations of Other Sources of Error 288
Return to Detection Monitoring 289
5.13 ASSESSMENT MONITORING PROGRAM 40 CFR §258.55(h)-(i) 289
5.13.1 Statement of Regulation 289
5.13.2 Applicability 290
5.13.3 Technical Considerations 290
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5.14 ASSESSMENT OF CORRECTIVE MEASURES 40 CFR $258.56 291
5.14.1 Statement of Regulation 291
5.14.2 Applicability 291
5.14.3 Technical Considerations 291
Source Evaluation 292
Plume Delineation 292
Ground-Water Assessment 294
Corrective Measures Assessment 295
Active Restoration 296
Plume Containment 297
Source Control 298
Public Participation 298
5.15 SELECTION OF REMEDY 40 CFR $258.57 (a)-fb) 298
5.15.1 Statement of Regulation 298
5.15.2 Applicability 299
5.15.3 Technical Considerations 299
5.16 SELECTION OF REMEDY 40 CFR $258.57 (c) 299
5.16.1 Statement of Regulation 299
5.16.2 Applicability 300
5.16.3 Technical Considerations 301
Effectiveness of Corrective Action 301
Effectiveness of Source Reduction 302
Implementation of Remedial Action 302
Practical Capability 302
Community Concerns 303
5.17 SELECTION OF REMEDY 40 CFR $258.57 (d) 303
5.17.1 Statement of Regulation 303
5.17.2 Applicability 304
5.17.3 Technical Considerations 304
5.18 SELECTION OF REMEDY 40 CFR $258.57 (e)-(f) 305
5.18.1 Statement of Regulation 305
5.18.2 Applicability 306
5.18.3 Technical Considerations 306
209
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5.19 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM
40 CFR $258.58 (a) 307
5.19.1 Statement of Regulation 307
5.19.2 Applicability 308
5.19.3 Technical Considerations 308
Monitoring Activities 308
Interim Measures 308
5.20 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM
40 CFR $258.58 fb)-(d) 309
5.20.1 Statement of Regulation 309
5.20.2 Applicability 309
5.20.3 Technical Considerations 310
5.21 IMPLEMENTATION OF THE CORRECTIVE ACTION PROGRAM
40 CFR $258.58 (e)-(g) 311
5.21.1 Statement of Regulation 311
5.21.2 Applicability 311
5.21.3 Technical Considerations 312
5.22 FURTHER INFORMATION 313
5.22.1 References 313
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CHAPTER 5
SUBPART E
GROUND-WATER MONITORING
AND CORRECTIVE ACTION
5.1 INTRODUCTION
The Criteria establish ground-water monitoring and corrective action requirements for all existing
and new MSWLF units and lateral expansions of existing units except where the Director of an
approved State suspends the requirements because there is no potential for migration of leachate
constituents from the unit to the uppermost aquifer. The Criteria include requirements for the
location, design, and installation of ground-water monitoring systems and set standards for ground-
water sampling and analysis. They also provide specific statistical methods and decision criteria for
identifying a significant change in ground-water quality. If a significant change in ground-water
quality occurs, the Criteria require an assessment of the nature and extent of contamination followed
by an evaluation and implementation of remedial measures.
Portions of this chapter are based on a draft technical document developed for EPA's hazardous
waste program. This document, "RCRA Ground-Water Monitoring: Draft Technical Guidance"
(EPA/530-R-93-001), is undergoing internal review, and may change. EPA chose to incorporate
the information from the draft document into this chapter because the draft contained the most
recent information available.
5.2 APPLICABILITY
40 CFR §258.50 (a) & (b)
5.2.1 Statement of Regulation
(a) The requirements in this Part apply to
MSWLF units, except as provided in
paragraph (b) of this section.
(b) Ground-water monitoring
requirements under §258.51 through
§258.55 of this Part may be suspended by
the Director of an approved State for a
MSWLF unit if the owner or operator can
demonstrate that there is no potential for
migration of hazardous constituents from
that MSWLF unit to the uppermost
aquifer (as defined in §258.2) during the
active life of the unit and the post-closure
care period. This demonstration must be
certified by a qualified ground-water
scientist and approved by the Director of
an approved State, and must be based
upon:
(1) Site-specific field collected
measurements, sampling, and analysis of
physical, chemical, and biological processes
affecting contaminant fate and transport,
and
(2) Contaminant fate and transport
predictions that maximize contaminant
migration and consider impacts on human
health and environment.
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Subpart E
5.2.2 Applicability
The ground-water monitoring requirements
apply to all existing MSWLF units, lateral
expansions of existing units, and new
MSWLF units that receive waste after
October 9, 1993. The requirements for
ground-water monitoring may be suspended if
the Director of an approved State finds that no
potential exists for migration of hazardous
constituents from the MSWLF unit to the
uppermost aquifer during the active life of the
unit, including closure or post-closure care
periods.
The "no potential for migration" demonstra-
tion must be based upon site-specific informa-
tion relevant to the fate and transport of any
hazardous constituents that may be expected
to be released from the unit. The predictions
of fate and transport must identify the max-
imum anticipated concentrations of constitu-
ents migrating to the uppermost aquifer so
that a protective assessment of the potential
effects to human health and the environment
can be made. A successful demonstration
could exempt the MSWLF unit from
requirements of §§258.51 through 258.55,
which include installation of ground-water
monitoring systems, and sampling and
analysis for both detection and assessment
monitoring constituents. Preparing No-
Migration Demonstrations for Municipal
Solid Waste Disposal Facilities-Screening
Tool is a guidance document describing a
process owners/ operators can use to prepare
a no-migration demonstration (NMD)
requesting suspension of the ground-water
monitoring requirements.
5.2.3 Technical Considerations
All MSWLF units that receive waste after the
effective date of Part 258 must comply with
the ground-water monitoring requirements.
The Director of an approved State may
exempt an owner/operator from the ground-
water monitoring requirements at
§258.51 through §258.55 if the owner or
operator demonstrates that there is no
potential for hazardous constituent migration
to the uppermost aquifer throughout the
operating, closure, and post-closure care
periods of the unit. Owners and operators of
MSWLFs not located in approved States will
not be eligible for this waiver and will be
required to comply with all ground-water
monitoring requirements. The "no-migration"
demonstration must be certified by a qualified
ground-water scientist and approved by the
Director of an approved State. It must be
based on site-specific field measurements and
sampling and analyses to determine the
physical, chemical, and biological processes
affecting the fate and transport of hazardous
constituents. The demonstration must be
supported by site-specific data and predictions
of the maximum contaminant migration.
Site-specific information must include, at a
minimum, the information necessary to
evaluate or interpret the effects of the
following properties or processes on
contaminant fate and transport:
Physical Properties or Processes:
• Aquifer Characteristics. including
hydraulic conductivity, hydraulic gradient,
effective porosity, aquifer thickness, de-
gree of saturation, stratigraphy, degree of
fracturing and secondary porosity of soils
and bedrock, aquifer heterogeneity,
ground-water discharge, and ground-water
recharge areas;
• Waste Characteristics, including quantity,
type, and origin (e.g., commercial,
industrial, or small quantity generators of
unregulated hazardous wastes);
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Ground-Water Monitoring and Corrective Action
• Climatic Conditions, including annual
precipitation, leachate generation
estimates, and effects on leachate
quality;
• Leachate Characteristics, including
leachate composition, solubility, density,
the presence of immiscible constituents,
Eh, and pH; and
• Engineered Controls, including liners,
cover systems, and aquifer controls (e.g.,
lowering the water table). These should
be evaluated under design and failure
conditions to estimate their long-term
residual performance.
Chemical Properties or Processes:
• Attenuation of contaminants in the
subsurface, including adsorption/
desorption reactions, ion exchange,
organic content of soil, soil water pH,
and consideration of possible reactions
causing chemical transformation or
chelation.
Biological Processes:
• Microbiological Degradation, which may
attenuate target compounds or cause
transformations of compounds,
potentially forming more toxic chemical
species.
The alternative design section of Chapter
5.0 discusses these and other processes that
affect contaminant fate and solute transport.
When owners or operators prepare a no-
migration demonstration, they must use
predictions that are based on maximum
contaminant migration both from the unit
and through the subsurface media.
Assumptions about variables affecting
transport should be biased toward over-
estimating transport and the anticipated
concentrations. Assumptions and site
specific data that are used in the fate and
transport predictions should conform with
transport principles and processes,
including adherence to mass-balance and
chemical equilibria limitations. Within
these physicochemical limitations,
assumptions should be biased toward the
objective of assessing the maximum
potential impact on human health and the
environment. The evaluation of site-
specific data and assumptions may include
some of the following approaches:
• Use of the upper bound of known aquifer
parameters and conditions that will
maximize contaminant transport (e.g.,
hydraulic conductivity, effective
porosity, horizontal and vertical
gradients), rather than average values
• Use of the lower range of known aquifer
conditions and parameters that tend to
attenuate or retard contaminant transport
(e.g., dispersivities, decay coefficients,
cation exchange capacities, organic
carbon contents, and recharge
conditions), rather than average values
• Consideration of the cumulative impacts
on water quality, including both existing
water quality data and cumulative health
risks posed by hazardous constituents
likely to migrate from the MSWLF unit
and other potential or known sources.
A discussion of mathematical approaches
for evaluating contaminant or solute
transport is provided in Chapter 5.
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Subpart E
5.3 COMPLIANCE SCHEDULE
40 CFR § 258.50 (c)
5.3.1 Statement of Regulation*
*[NOTE: EPA finalized several revisions
to 40 CFR Part 258 on October 1, 1993
(58 FR 51536), and these revisions delay
the effective date for some categories of
landfills. More detail on the content of
the revisions is included in the
introduction.]
(c) Owners and operators of MSWLF
units must comply with the ground-water
monitoring requirements of this part
according to the following schedule unless
an alternative schedule is specified under
paragraph (d):
(1) Existing MSWLF units and lateral
expansions less than one mile from a
drinking water intake (surface or
subsurface) must be in compliance with
the ground-water monitoring
requirements specified in §§258.51 -
258.55 by October 9, 1994;
(2) Existing MSWLF units and lateral
expansions greater than one mile but less
than two miles from a drinking water
intake (surface or subsurface) must be in
compliance with the ground-water
monitoring requirements specified in
§§258.51 - 258.55 by October 9, 1995;
(3) Existing MSWLF units and lateral
expansions greater than two miles from a
drinking water intake (surface or
subsurface) must be in compliance with
the ground-water monitoring
requirements specified in §§258.51 -
258.55 by October 9, 1996;
(4) New MSWLF units must be in
compliance with the ground-water
monitoring requirements specified in
§§258.51 - 258.55 before waste can be
placed in the unit.
5.3.2 Applicability
The rule establishes a self-implementing
schedule for owners or operators in States
with programs that are deemed inadequate
or not yet approved. As indicated in the
Statement of Regulation, this schedule
depends on the distance of the MSWLF unit
from drinking water sources. Approved
States may specify an alternative schedule
under §258.50 (d), which is discussed in
Section 5.4.
Existing units and lateral expansions less
than one mile from a drinking water intake
must be in compliance with the ground-
water monitoring requirements by October
9, 1994. If the units are greater than one
mile but less than two miles from a drinking
water intake, they must be in compliance by
October 9, 1995. Those units located more
than two miles from a drinking water intake
must be in compliance by October 9, 1996
(see Table 5-1).
New MSWLF units, defined as units that
have not received waste prior to October 9,
1993, must be in compliance with these
requirements before receiving waste
regardless of the proximity to a water
supply intake.
5.3.3 Technical Considerations
For most facilities, these requirements will
become applicable 3 to 5 years after the
promulgation date of the rule. This period
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Ground-Water Monitoring and Corrective Action
Table 5-1. Compliance Schedule for Existing Units and Lateral Expansions
in States with Unapproved Programs
Distance From Water Supply Intake
One mile or less
More than one mile but less than two
miles
More than two miles
Time to Comply
From October 9, 1991
3 Years
4 Years
5 Years
should provide sufficient time for the owner
or operator to conduct site investigation and
characterization studies to comply with the
requirements of 40 CFR §258.51 through
§258.55. For those facilities closest to
drinking water intakes, the period provides
2 to 3 years to assess seasonal variability in
ground-water quality. A drinking water
intake includes water supplied to a user
from either a surface water or ground-water
source.
5.4 ALTERNATIVE COMPLIANCE
SCHEDULES
40 CFR 258.50 (d)(e) & (g)
5.4.1 Statement of Regulation
(d) The Director of an approved State
may specify an alternative schedule for
the owners or operators of existing
MSWLF units and lateral expansions to
comply with the ground-water
monitoring requirements specified in
§§258.51 - 258.55. This schedule must
ensure that 50 percent of all existing
MSWLF units are in compliance by
October 9, 1994 and all existing MSWLF
units are in
compliance by October 9, 1996. In
setting the compliance schedule, the
Director of an approved State must
consider potential risks posed by the unit
to human health and the environment.
The following factors should be
considered in determining potential risk:
(1) Proximity of human and
environmental receptors;
(2) Design of the MSWLF unit;
(3) Age of the MSWLF unit;
(4) The size of the MSWLF unit;
(5) Types and quantities of wastes
disposed, including sewage sludge; and
(6) Resource value of the underlying
aquifer, including:
(i) Current and future uses;
(ii) Proximity and withdrawal rate of
users; and
(iii) Ground-water quality and
quantity.
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Subpart E
(e) Once established at a MSWLF
unit, ground-water monitoring shall be
conducted throughout the active life and
post-closure care period of that MSWLF
unit as specified in §258.61.
(f) (See Section 5.5 for technical
guidance on qualifications of a ground-
water scientist.)
(g) The Director of an approved State
may establish alternative schedules for
demonstrating compliance with
§258.51(d)(2), pertaining to notification
of placement of certification in operating
record; § 258.54(c)(l), pertaining to
notification that statistically significant
increase (SSI) notice is in operating
record; § 258.54(c)(2) and (3), pertaining
to an assessment monitoring program;
§ 258.55(b), pertaining to sampling and
analyzing Appendix II constituents;
§258.55(d)(l), pertaining to placement of
notice (Appendix II constituents detected)
in record and notification of notice in
record; § 258.55(d)(2), pertaining to
sampling for Appendix I and II;
§ 258.55(g), pertaining to notification
(and placement of notice in record) of SSI
above ground-water protection standard;
§ 258.55(g)(l)(iv) and § 258.56(a),
pertaining to assessment of corrective
measures; § 258.57(a), pertaining to
selection of remedy and notification of
placement in record; § 258.58(c)(4),
pertaining to notification of placement in
record (alternative corrective action
measures); and § 258.58(f), pertaining to
notification of placement in record
(certification of remedy completed).
5.4.2 Applicability
The Director of an approved State may
establish an alternative schedule for
requiring owners/operators of existing units
and lateral expansions to comply with the
ground-water monitoring requirements.
The alternative schedule is to ensure that at
least fifty percent of all existing MSWLF
units within a given State are in compliance
by October 9, 1994 and that all units are in
compliance by October 9, 1996.
In establishing the alternative schedule, the
Director of an approved State may use site-
specific information to assess the relative
risks posed by different waste management
units and will allow priorities to be
developed at the State level. This site-
specific information (e.g., proximity to
receptors, proximity and withdrawal rate of
ground-water users, waste quantity, type,
containment design and age) should enable
the Director to assess potential risk to the
uppermost aquifer. The resource value of
the aquifer to be monitored (e.g., ground-
water quality and quantity, present and
future uses, and withdrawal rate of ground-
water users) also may be considered.
Once ground-water monitoring has been
initiated, it must continue throughout the
active life, closure, and post-closure care
periods. The post-closure period may last
up to 30 years or more after the MSWLF
unit has received a final cover.
In addition to establishing alternative
schedules for compliance with ground-
water monitoring requirements, the Director
of an approved State may establish
alternative schedules for certain
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Ground-Water Monitoring and Corrective Action
sampling and analysis requirements of
§§258.54 and 258.55, as well as corrective
action requirements of §§258.56, 258.57,
and 258.58. See Table 5-2 for a summary
of notification requirements for which
approved States may establish alternative
schedules.
5.4.3 Technical Considerations
The rule allows approved States flexibility
in establishing alternate ground-water
monitoring compliance schedules. In
setting an alternative schedule, the State
will consider potential impacts to human
health and the environment. Approved
States have the option to address MSWLF
units that have environmental problems
immediately. In establishing alternative
schedules for installing ground-water
monitoring systems
at existing MSWLF units, the Director of an
approved State may consider information
including the age and design of existing
facilities. Using this type of information, in
conjunction with a knowledge of the wastes
disposed, the Director should be able to
qualitatively assess or rank facilities based
on their risk to local ground-water
resources.
5.5 QUALIFICATIONS
40 CFR 258.50 (f)
5.5.1 Statement of Regulation
(f) For the purposes of this Subpart, a
qualified ground-water scientist is a
scientist or engineer who has received a
baccalaureate or post-graduate degree in
Table 5-2. Summary of Notification Requirements
Section
§258.51(d)(2)
§258.54(c)(l)
§258.55(d)(l)
§258.57(a)
§258.58(c)(4)
§258.58(f)
Description
14 day notification period after well installation
certification by a qualified ground-water scientist (GWS)
14 day notification period after finding a statistical increase
over background for detection parameter(s)
14 day notification period after detection of Appendix II
constituents
14 day notification period after selection of corrective
measures
14 day notification period prior to implementing alternative
measures
14 day notification period after remedy has been completed
and certified by GWS
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Subpart E
the natural sciences or engineering and
has sufficient training and experience in
ground-water hydrology and related
fields as may be demonstrated by State
registration, professional certifications,
or completion of accredited university
programs that enable that individual to
make sound professional judgements
regarding ground-water monitoring,
contaminant fate and transport, and
corrective action.
5.5.2 Applicability
The qualifications of a ground-water
scientist are defined to ensure that
professionals of appropriate capability and
judgement are consulted when required by
the Criteria. The ground-water scientist
must possess the fundamental education and
experience necessary to evaluate ground-
water flow, ground-water monitoring
systems, and ground-water monitoring
techniques and methods. A ground-water
scientist must understand and be able to
apply methods to solve solute transport
problems and evaluate ground-water
remedial technologies. His or her education
may include undergraduate or graduate
studies in hydrogeology, ground-water
hydrology, engineering hydrology, water
resource engineering, geotechnical
engineering, geology, ground-water
modeling/ground-water computer modeling,
and other aspects of the natural sciences.
The qualified ground-water scientist must
have a college degree but need not have
professional certification, unless required at
the State or Tribal level. Some
States/Tribes may have certification
programs for ground-water scientists;
however, there are no recognized Federal
certification programs.
5.5.3 Technical Considerations
A qualified ground-water scientist must
certify work performed pursuant to the
following provisions of the ground-water
monitoring and corrective action
requirements:
No potential for
demonstration (§258.50(b))
migration
Specifications concerning the number,
spacing, and depths of monitoring wells
(§258.51(d))
Determination that contamination was
caused by another source or that a
statistically significant increase resulted
from an error in sampling, analysis, or
evaluation (§§258.54 (c)(3) and 258.55
• Determination that compliance with a
remedy requirement is not technically
practicable (§258. 58(c)(l))
• Completion of remedy (§25 8.5 8(f)).
The owner or operator must determine that
the professional qualifications of the
ground-water specialist are in accordance
with the regulatory definition. In general, a
certification is a signed document that
transmits some finding (e.g., that
monitoring wells were installed according
to acceptable practices and standards at
locations and depths appropriate for a given
facility). The certification must be placed
in the operating record of the facility, and
the State Director must be notified that the
certification has been made. Specific
details of these certifications will be
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Ground-Water Monitoring and Corrective Action
addressed in the order in which they appear
in this guidance document.
Many State environmental regulatory
agencies have ground-water scientists on
staff. The owner or operator of a MSWLF
unit or facility is not necessarily required to
obtain certification from an independent
(e.g., consulting) ground-water scientist and
may, if agreed to by the Director in an
approved State, obtain approval by the
Director in lieu of certification by an
outside individual.
5.6 GROUND-WATER
MONITORING SYSTEMS
40 CFR §258.51 (a)(b)(d)
5.6.1 Statement of Regulation
(a) A ground-water monitoring system
must be installed that consists of a
sufficient number of wells, installed at
appropriate locations and depths, to yield
ground-water samples from the upper-
most aquifer (as defined in §258.2) that:
(1) Represent the quality of background
ground water that has not been affected
by leakage from a unit. A determination
of background quality may include
sampling of wells that are not
hydraulically upgradient of the waste
management area where:
(i) Hydrogeologic conditions do not
allow the owner or operator to determine
what wells are hydraulically upgradient;
or
(ii) Sampling at other wells will provide
an indication of background ground-
water quality that is as representative or
more
representative than that provided by the
upgradient wells; and
(2) Represent the quality of ground
water passing the relevant point of
compliance specified by the Director of
an approved State under §258.40(d) or at
the waste management unit boundary in
unapproved States. The downgradient
monitoring system must be installed at
the relevant point of compliance specified
by the Director of an approved State
under §258.40(d) or at the waste
management unit boundary in
unapproved States that ensures detection
of ground-water contamination in the
uppermost aquifer. When physical
obstacles preclude installation of ground-
water monitoring wells at the relevant
point of compliance at existing units, the
down-gradient monitoring system may be
installed at the closest practicable
distance hydraulically down-gradient
from the relevant point of compliance or
specified by the Director of an approved
State under §258.40 that ensures
detection of ground-water contamination
in the uppermost aquifer.
(b) The Director of an approved State
may approve a multi-unit ground-water
monitoring system instead of separate
ground-water monitoring systems for
each MSWLF unit when the facility has
several units, provided the multi-unit
ground-water monitoring system meets
the requirement of §258.51(a) and will be
as protective of human health and the
environment as individual monitoring
systems for each MSWLF unit, based on
the following factors:
(1) Number, spacing, and orientation of
the MSWLF units;
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Subpart E
(2) Hydrogeologic setting;
(3) Site history;
(4) Engineering design of the MSWLF
units; and
(5) Type of waste accepted at the
MSWLF units.
(c) (See Section 5.7 for technical
guidance on monitoring well design and
construction.)
(d) The number, spacing, and depths of
monitoring systems shall be:
(1) Determined based upon site-specific
technical information that must include
thorough characterization of:
(i) Aquifer thickness, ground-water
flow rate, ground-water flow direction
including seasonal and temporal
fluctuations in ground-water flow; and
(ii) Saturated and unsaturated
geologic units and fill materials overlying
the uppermost aquifer, materials
comprising the uppermost aquifer, and
materials comprising the confining unit
defining the lower boundary of the
uppermost aquifer; including, but not
limited to: thicknesses, stratigraphy,
lithology, hydraulic conductivities,
porosities and effective porosities.
(2) Certified by a qualified ground-
water scientist or approved by the
Director of an approved State. Within 14
days of this certification, the owner or
operator must notify the State Director
that the certification has been placed in
the operating record.
5.6.2 Applicability
The requirements for establishing a ground-
water monitoring system pursuant to
§258.51 apply to all new units, existing
units, and lateral expansions of existing
units according to the schedules identified
in 40 CFR §258.50. A ground-water
monitoring system consists of both
background wells and wells located at the
point of compliance or waste management
unit boundary (i.e., downgradient wells).
The ground-water monitoring network must
be capable of detecting a release from the
MSWLF unit. A sufficient number of
monitoring wells must be located
downgradient of the unit and be screened at
intervals in the uppermost aquifer to ensure
contaminant detection. Generally,
upgradient wells are used to determine
background ground-water quality.
The downgradient wells must be located at
the relevant point of compliance specified
by the Director of an approved State, or at
the waste management unit boundary in
States that are not in compliance with
regulations. If existing physical structures
obstruct well placement, the downgradient
monitoring system should be placed as close
to the relevant point of compliance as
possible. Wells located at the relevant point
of compliance must be capable of detecting
contaminant releases from the MSWLF unit
to the uppermost aquifer. As discussed
earlier in the section pertaining to the
designation of a relevant point of
compliance (Section 4.4), the point of
compliance must be no greater than 150
meters from the unit boundary.
The Director of an approved State may
allow the use of a multi-unit ground-water
monitoring system. MSWLF units in
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Ground-Water Monitoring and Corrective Action
States that are deemed not in compliance
with the regulations must have a monitoring
system for each unit.
A qualified ground-water scientist must
certify that the number, spacing, and depths
of the monitoring wells are appropriate for
the MSWLF unit. This certification must be
placed in the operating records. The State
Director must be notified within 14 days
that the certification was placed in the
operating record.
5.6.3 Technical Considerations
The obj ective of a ground-water monitoring
system is to intercept ground water that has
been contaminated by leachate from the
MSWLF unit. Early contaminant detection
is important to allow sufficient time for
corrective measures to be developed and
implemented before sensitive receptors are
significantly affected. To accomplish this
objective, the monitoring wells should be
located to sample ground water from the
uppermost aquifer at the closest practicable
distance from the waste management unit
boundary. An alternative distance that is
protective of human health and the
environment may be granted by the Director
of an approved State. Since the monitoring
program is intended to operate through the
post-closure period, the location, design,
and installation of monitoring wells should
address both existing conditions and
anticipated facility development, as well as
expected changes in ground-water flow.
Uppermost Aquifer
Monitoring wells must be placed to provide
representative ground-water samples from
the uppermost aquifer. The uppermost
aquifer is defined in §258.2 as "the geologic
formation nearest to the natural ground
surface that is an aquifer, as well as lower
aquifers that are hydraulically
interconnected with this aquifer within the
facility property boundary." These lower
aquifers may be separated physically from
the uppermost aquifer by less permeable
strata (having a lower hydraulic
conductivity) that are often termed
aquitards. An aquitard is a less permeable
geologic unit or series of closely layered
units (e.g., silt, clay, or shale) that in itself
will not yield significant quantities of water
but will transmit water through its
thickness. Aquitards may include thicker
stratigraphic sequences of clays, shales, and
dense, unfractured crystalline rocks (Freeze
and Cherry, 1979).
To be considered part of the uppermost
aquifer, a lower zone of saturation must be
hydraulically connected to the uppermost
aquifer within the facility property
boundary. Generally, the degree of
communication between aquifers is
evaluated by ground-water pumping tests.
Methods have been devised for use in
analyzing aquifer test data. A summary is
presented in Handbook: Ground Water,
Vol. II (USEPA, 1991). The following
discussions under this section (5.6.3) should
assist the owner or operator in
characterizing the uppermost aquifer and
the hydrogeology of the site.
Determination of Background Ground-
Water Quality
The goal of monitoring-well placement is to
detect changes in the quality of ground
water resulting from a release from the
MSWLF unit. The natural chemical
composition of ground water is controlled
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Subpart E
primarily by the mineral composition of the
geologic unit comprising the aquifer. As
ground water moves from one geologic unit
to another, its chemical composition may
change. To reduce the probability of
detecting naturally occurring differences in
ground-water quality between background
and downgradient locations, only ground-
water samples collected from the same
geologic unit should be compared.
Ground-water quality in areas where the
geology is complex can be difficult to
characterize. As a result, the rule allows the
owner or operator flexibility in determining
where to locate wells that will be used to
establish background water quality.
If the facility is new, ground-water samples
collected from both upgradient and
downgradient locations prior to waste
disposal can be used to establish background
water quality. The sampling should be
conducted to account for both seasonal and
spatial variability in ground-water quality.
Determining background ground-water
quality by sampling wells that are not
hydraulically upgradient may be necessary
where hydrogeologic conditions do not
allow the owner or operator to determine
which wells are hydraulically upgradient.
Additionally, background ground-water
quality may be determined by sampling
wells that provide ground-water samples as
representative or more representative than
those provided by upgradient wells. These
conditions include the following:
• The facility is located above an aquifer
in which ground-water flow directions
change seasonally.
• The facility is located near production
wells that influence the direction of
ground-water flow.
• Upgradient ground-water quality is
affected by a source of contamination
other than the MSWLF unit.
• The proposed or existing landfill
overlies a ground-water divide or local
source of recharge.
• Geologic units present at downgradient
locations are absent at upgradient
locations.
• Karst terrain or fault zones modify flow.
• Nearby surface water influences ground-
water flow directions.
• Waste management areas are located
close to a property boundary that is
upgradient of the facility.
Multi-Unit Monitoring Systems
A multi-unit ground-water monitoring
system does not have wells at individual
MSWLF unit boundaries. Instead, an
imaginary line is drawn around all of the
units at the facility. (See Figure 5-1 for a
comparison of single unit and multi-unit
systems.) This line constitutes the relevant
point of compliance. The option to
establish a multi-unit monitoring system is
restricted to facilities located in approved
States. A multi-unit system must be
approved by the Director of an approved
State after consideration has been given to
the:
• Number, spacing, and orientation of the
MSWLF units
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Figure 5-1. Comparison of Single Unit and Multi-Unit Monitoring System
Single-Unit System
Ground-Water
Flow
Multi-Unit System
V G
V
Ground-Water
Flow
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Subpart E
• Hydrogeologic setting
• Site history
• Engineering design of the MSWLF units
• Type of wastes accepted at the facility.
The purpose of a multi-unit system is to
reduce the number of monitoring wells that
can provide the same information. The
conceptual design of the multi-unit system
should consider the use and management of
the facility with respect to anticipated unit
locations. In some cases, it may be possible
to justify a reduction in the number of wells
if the waste management units are aligned
along the same flow path in the ground-
water system.
The multi-unit monitoring system must
provide a level of protection to human
health and the environment that is
comparable to monitoring individual units.
The multi-unit system should allow
adequate time after detection of
contamination to develop and implement
corrective measures before sensitive
receptors are adversely affected.
Hydrogeological Characterization
Adequate monitoring-well placement
depends on collecting and evaluating
hydrogeological information that can be
used to form a conceptual model of the site.
The goal of a hydrogeological investigation
is to acquire site-specific data concerning:
• The lateral and vertical extent of the
uppermost aquifer
• The lateral and vertical extent of the
upper and lower confining units/layers
• The geology at the owner's/operator's
facility (e.g, stratigraphy, lithology, and
structural setting)
• The chemical properties of the
uppermost aquifer and its confining
layers relative to local ground-water
chemistry and wastes managed at the
facility
• Ground-water flow, including:
- The vertical and horizontal directions
of ground-water flow in the uppermost
aquifer
- The vertical and horizontal
components of the hydraulic gradient
in the uppermost and any hydraulically
connected aquifer
- The hydraulic conductivities of the
materials that comprise the upper-most
aquifer and its confining units/layers
- The average linear horizontal velocity
of ground-water flow in the uppermost
aquifer.
The elements of a program to characterize
the hydrogeology of a site are discussed
briefly in the sections that follow and are
addressed in more detail in "RCRA Ground-
Water Monitoring: Draft Technical
Guidance" (USEPA, 1992a).
Prior to initiating a field investigation, the
owner or operator should perform a
preliminary investigation. The preliminary
investigation will involve reviewing all
available information about the site, which
may consist of:
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Ground-Water Monitoring and Corrective Action
Information on the waste management
history of the site, including:
- A chronological history of the site,
including descriptions of wastes
managed on-site
- A summary of documented releases
- Details on the structural integrity of
the MSWLF unit and physical controls
on waste migration
A literature review, including:
- Reports of research performed in the
area of the site
- Journal articles
- Studies and reports available from
local, regional, and State offices (e.g.,
geologic surveys, water boards, and
environmental agencies)
- Studies available from Federal offices,
such as USGS or USEPA
Information
including:
from file searches,
- Reports of previous investigations at
the site
- Geological and environmental
assessment data from State and Federal
reports.
The documentation itemized above is by no
means a complete listing of information
available for a preliminary investigation.
Many other sources of hydrogeological
information may be available for review
during the preliminary investigation.
Characterizing Site Geology
After the preliminary investigation is
complete, the owner/operator will have
information that he/she can use to develop a
plan to characterize site hydrogeology
further.
Nearly all hydrogeological investigations
include a subsurface boring program. A
boring program is necessary to define site
hydrogeology and the small-scale geology
of the area beneath the site. The program
usually requires more than one iteration.
The objective of the initial boreholes is to
refine the conceptual model of the site
derived from the preliminary investigation.
The subsurface boring program should be
designed as follows:
• The initial number of boreholes and their
spacing is based on the information
obtained during the preliminary
investigation.
• Additional boreholes should be installed
as needed to provide more information
about the site.
• Samples should be collected from the
borings at changes in lithology. For
boreholes that will be completed as
monitoring wells, at least one sample
should be collected from the interval that
will be the screened interval. Boreholes
that will not be completed as monitoring
wells must be properly decommissioned.
Geophysical techniques, cone penetrometer
surveys, mapping programs, and laboratory
analyses of borehole samples can be used to
plan and supplement the subsurface boring
program. Downhole geophysical techniques
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Subpart E
include electric, sonic, and nuclear logging.
Surface geophysical techniques include
seismic reflection and refraction, as well as
electromagnetic induction and resistivity.
The data obtained from the subsurface
boring program should enable the owner or
operator to identify:
• Lithology, soil types, and stratigraphy
• Zones of potentially high hydraulic
conductivity
• The presence of confining formations or
layers
• Unpredicted geologic features, such as
fault zones, cross-cutting structures, and
pinch-out zones
• Continuity of petrographic features, such
as sorting, grain size distribution, and
cementation
• The potentiometric surface or water
table.
Characterizing
Beneath the Site
Ground-Water Flow
In addition to characterizing site geology,
the owner/operator should characterize the
hydrology of the uppermost aquifer and its
confining layer(s) at the site. The owner or
operator should install wells and/or
piezometers to assist in characterizing site
hydrology. The owner/operator should
determine and assess:
• The direct!on(s) and rate(s) of ground-
water flow (including both horizontal
and vertical components of flow)
• Seasonal/temporal, natural, and
artificially induced (e.g., off-site
production well-pumping, agricultural
use) short-term and long-term
variations in ground-water elevations
and flow patterns
• The hydraulic conductivities of the
stratigraphic units at the site, including
vertical hydraulic conductivity of the
confining layer(s).
Determining Ground-Water Flow
Direction and Hydraulic Gradient
Installing monitoring wells that will provide
representative background and
downgradient water samples requires a
thorough understanding of how ground
water flows beneath a site. Developing such
an understanding requires obtaining
information regarding both ground-water
flow direction(s) and hydraulic gradient.
Ground-water flow direction can be thought
of as the idealized path that ground-water
follows as it passes through the subsurface.
Hydraulic gradient (i) is the change in static
head per unit of distance in a given
direction. The static head is defined as the
height above a standard datum of the surface
of a column of water (or other liquid) that
can be supported by the static pressure at a
given point (i.e., the sum of the elevation
head and pressure head).
To determine ground-water flow directions
and hydraulic gradient, owners and
operators should develop and implement a
water level-monitoring program. This
program should be structured to provide
precise water level measurements in a
sufficient number of piezometers or wells at
a sufficient frequency to gauge both
seasonal average flow directions and
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Ground-Water Monitoring and Corrective Action
temporal fluctuations in ground-water flow
directions. Ground-water flow direction(s)
should be determined from water levels
measured in wells screened in the same
hydro-stratigraphic position. In
heterogeneous geologic settings (i.e.,
settings in which the hydraulic
conductivities of the subsurface materials
vary with location in the subsurface), long
well screens can intercept stratigraphic
horizons with different (e.g., contrasting)
ground-water flow directions and different
heads. In this situation, the resulting water
levels will not provide the depth-discrete
head measurements required for accurate
determination of the ground-water flow
direction.
In addition to evaluating the component of
ground-water flow in the horizontal
direction, a program should be undertaken
to assess the vertical component of ground-
water flow. Vertical ground-water flow
information should be based, at least in part,
on field data from wells and piezometers,
such as multi-level wells, piezometer
clusters, or multi-level sampling devices,
where appropriate. The following sections
provide acceptable methods for assessing
the vertical and horizontal components of
flow at a site.
Ground-Water Level Measurements
To determine ground-water flow directions
and ground-water flow rates, accurate water
level measurements (measured to the nearest
0.01 foot) should be obtained. Section 5.8
delineates procedures for obtaining water
level measurements. At facilities where it is
known or plausible that immiscible
contaminants (i.e., non-aqueous phase
liquids (NAPLs)) occur (or are determined
to be potentially present after considering
the waste types managed at the facility) in
the subsurface at the facility, both the
depth(s) to the immiscible layer(s) and the
thickness(es) of the immiscible layer(s) in
the well should be recorded.
For the purpose of measuring total head,
piezometers and wells should have as short
a screened interval as possible.
Specifically, the screens in piezometers or
wells that are used to measure head should
generally be less than 10 feet long. In
circumstances including the following, well
screens longer than 10 feet may be
warranted:
• Natural water level fluctuations
necessitate a longer screen length.
• The interval monitored is slightly
greater than the appropriate screen
length (e.g., the interval monitored is
12 feet thick).
• The aquifer monitored is homogeneous
and extremely thick (e.g., greater than
300 feet); thus, a longer screen (e.g., a
20-foot screen) represents a fairly
discrete interval.
The head measured in a well with a long
screened interval is a function of all of the
different heads over the entire length of the
screened interval. Care should be taken
when interpreting water levels collected
from wells that have long screened intervals
(e.g., greater than 10 feet).
The water-level monitoring program should
be structured to provide precise water level
measurements in a sufficient number of
piezometers or wells at a sufficient
frequency to gauge both seasonal average
flow directions and temporal fluctuations in
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Subpart E
ground-water flow directions. The
owner/operator should determine and assess
seasonal/temporal, natural, and artificially
induced (e.g., off-site production well-
pumping, agricultural use) short-term and
long-term variations in ground-water
elevations, ground-water flow patterns, and
ground-water quality.
Establishing Horizontal Flow Direction
and the Horizontal Component of
Hydraulic Gradient
After the water level data and measurement
procedures are reviewed to determine that
they are accurate, the data should be used
to:
• Construct potentiometric surface maps
and water table maps based on the
distribution of total head. The data
used to develop water table maps
should be from piezometers or wells
screened across the water table. The
data used to develop potentiometric
surface maps should be from
piezometers or wells screened at
approximately the same elevation in
the same hydrostratigraphic unit;
• Determine the horizontal direction(s)
of ground-water flow by drawing flow
lines on the potentiometric surface map
or water table map (i.e., construct a
flow net);
• Calculate value(s) for the horizontal
and vertical components of hydraulic
gradient.
Methods for constructing potentiometric
surface and water table maps, constructing
flow nets, and determining the direction(s)
of ground-water flow are provided by
USEPA (1989c) and Freeze and Cherry
(1979). Methods for calculating hydraulic
gradient are provided by Heath (1982) and
USEPA (1989c).
A potentiometric surface or water table map
will give an approximate idea of general
ground-water flow directions. However, to
locate monitoring wells properly, ground-
water flow direction(s) and hydraulic
gradient(s) should be established in both the
horizontal and vertical directions and over
time at regular intervals (e.g., over a 1-year
period at 3-month intervals).
Establishing Vertical Flow Direction and
the Vertical Component of Hydraulic
Gradient
To make an adequate determination of the
ground-water flow directions, the vertical
component of ground-water flow should be
evaluated directly. This generally requires
the installation of multiple piezometers or
wells in clusters or nests, or the installation
of multi-level wells or sampling devices. A
piezometer or well nest is a closely spaced
group of piezometers or wells screened at
different depths, whereas a multi-level well
is a single device. Both piezometer/well
nests and multi-level wells allow for the
measurement of vertical variations in
hydraulic head.
When reviewing data obtained from
multiple placement of piezometers or wells
in single boreholes, the construction details
of the well should be carefully evaluated.
Not only is it extremely difficult to seal
several piezometers/wells at discrete depths
within a single borehole, but sealant
materials may migrate from the seal of one
piezometer/well to the screened interval of
another piezometer/well. Therefore, the
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design of a piezometer/well nest should be
considered carefully. Placement of
piezometers/wells in closely spaced
boreholes, where piezometers/wells have
been screened at different, discrete depth
intervals, is likely to produce more accurate
information. The primary concerns with the
installation of piezometers/wells in closely
spaced, separate boreholes are: 1) the
disturbance of geologic and soil materials
that occurs when one piezometer is installed
may be reflected in the data obtained from
another piezometer located nearby, and 2)
the analysis of water levels measured in
piezometers that are closely spaced, but
separated horizontally, may produce
imprecise information regarding the vertical
component of ground-water flow. The
limitations of installing multiple
piezometers either in single or separate
boreholes may be overcome by the
installation of single multi-level monitoring
wells or sampling devices in single
boreholes. The advantages and
disadvantages of these types of devices are
discussed by USEPA (1989f).
The owner or operator should determine the
vertical direction(s) of ground-water flow
using the water levels measured in multi-
level wells or piezometer/well nests to
construct flow nets. Flow nets should depict
the piezometer/well depth and length of the
screened interval. It is important to portray
the screened interval accurately on the flow
net to ensure that the piezometer/well is
actually monitoring the desired
water-bearing unit. A flow net should be
developed from information obtained from
piezometer/ well clusters or nests screened
at different, discrete depths. Detailed
guidance for the construction and evaluation
of flow nets in cross section (vertical flow
nets) is provided by USEPA (1989c).
Further information can be obtained from
Freeze and Cherry (1979).
Determining Hydraulic Conductivity
Hydraulic conductivity is a measure of a
material's ability to transmit water.
Generally, poorly sorted silty or clayey
materials have low hydraulic conductivities,
whereas well-sorted sands and gravels have
high hydraulic conductivities. An aquifer
may be classified as either homogeneous or
heterogeneous and either isotropic or
anisotropic according to the way its
hydraulic conductivity varies in space. An
aquifer is homogeneous if the hydraulic
conductivity is independent of location
within the aquifer; it is heterogeneous if
hydraulic conductivities are dependent on
location within the aquifer. If the hydraulic
conductivity is independent of the direction
of measurement at a point in a geologic
formation, the formation is isotropic at that
point. If the hydraulic conductivity varies
with the direction of measurement at a
point, the formation is anisotropic at that
point.
Determining Hydraulic Conductivity
Using Field Methods
Sufficient aquifer testing (i.e., field
methods) should be performed to provide
representative estimates of hydraulic
conductivity. Acceptable field methods
include conducting aquifer tests with single
wells, conducting aquifer tests with multiple
wells, and using flowmeters. This section
provides brief overviews of these methods,
including two methods for obtaining
vertically discrete measurements of
hydraulic conductivity. The identified
references provide detailed descriptions of
the methods summarized in this section.
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Subpart E
A commonly used test for determining
horizontal hydraulic conductivity with a
single well is the slug test. A slug test is
performed by suddenly adding, removing,
or displacing a known volume of water from
a well and observing the time that it takes
for the water level to recover to its original
level (Freeze and Cherry, 1979). Similar
results can be achieved by pressurizing the
well casing, depressing the water level, and
suddenly releasing the pressure to simulate
the removal of water from the well. In most
cases, EPA recommends that water not be
introduced into wells during aquifer tests to
avoid altering ground-water chemistry.
Single-well tests are limited in scope to the
area directly adjacent to the well screen.
The vertical extent of the well screen
generally defines the part of the geologic
formation that is being tested.
A modified version of the slug test, known
as the multilevel slug test, is capable of
providing depth-discrete measurements of
hydraulic conductivity. The drawback of
the multilevel slug test is that the test relies
on the ability of the investigator to isolate a
portion of the aquifer using a packer.
Nevertheless, multilevel slug tests, when
performed properly, can produce reliable
measurements of hydraulic conductivity.
Multiple-well tests involve withdrawing
water from, or injecting water into, one
well, and obtaining water level
measurements over time in observation
wells. Multiple-well tests are often
performed as pumping tests in which water
is pumped from one well and drawdown is
observed in nearby wells. A step-drawdown
test should precede most pumping tests to
determine an appropriate discharge rate.
Aquifer tests conducted with wells screened
in the same water-bearing zone can be used
to provide hydraulic conductivity data for
that zone. Multiple-well tests for hydraulic
conductivity characterize a greater
proportion of the subsurface than single-
well tests and, thus, provide average values
of hydraulic conductivity. Multiple-well
tests require measurement of parameters
similar to those required for single-well
tests (e.g., time, drawdown). When using
aquifer test data to determine aquifer
parameters, it is important that the solution
assumptions can be applied to site
conditions. Aquifer test solutions are
available for a wide variety of
hydrogeologic settings, but are often applied
incorrectly by inexperienced persons.
Incorrect assumptions regarding
hydrogeology (e.g., aquifer boundaries,
aquifer lithology, and aquifer thickness)
may translate into incorrect estimations of
hydraulic conductivity. A qualified ground-
water scientist with experience in designing
and interpreting aquifer tests should be
consulted to ensure that aquifer test solution
methods fit the hydrogeologic setting.
Kruseman and deRidder (1989) provide a
comprehensive discussion of aquifer tests.
Multiple-well tests conducted with wells
screened in different water-bearing zones
furnish information concerning hydraulic
communication among the zones. Water
levels in these zones should be monitored
during the aquifer test to determine the type
of aquifer system (e.g., confined,
unconfmed, semi-confined, or semi-
unconfmed) beneath the site, and their
leakance (coefficient of leakage) and
drainage factors (Kruseman and deRidder,
1989). A multiple-well aquifer test should
be considered at every site as a method to
establish the vertical extent of the
uppermost aquifer and to evaluate hydraulic
connection between aquifers.
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Certain aquifer tests are inappropriate for
use in karst terrains characterized by a
well-developed conduit flow system, and
they also may be inappropriate in fractured
bedrock. When a well located in a karst
conduit or a large fracture is pumped, the
water level in the conduit is lowered. This
lowering produces a drawdown that is not
radial (as in a granular aquifer) but is
instead a trough-like depression parallel to
the pumped conduit or fracture. Radial flow
equations do not apply to drawdown data
collected during such a pump test. This
means that a conventional semi-log plot of
drawdown versus time is inappropriate for
the purpose of determining the aquifer's
transmissivity and storativity. Aquifer tests
in karst aquifers can be useful, but valid
determinations of hydraulic conductivity,
storativity, and transmissivity may be
impossible. However, an aquifer test can
provide information on the presence of
conduits, on storage characteristics, and on
the percentage of Darcian flow. McGlew
and Thomas (1984) provide a more detailed
discussion of the appropriate use of aquifer
tests in fractured bedrock and on the
suitable interpretation of test data. Dye
tracing also is used to determine the rate and
direction of ground-water flow in karst
settings (Section 5.2.4).
Several additional factors should be
considered when planning an aquifer test:
• Owners and operators should provide
for the proper storage and disposal of
potentially contaminated ground water
pumped from the well system.
• Owners and operators should consider
the potential effects of pumping on
existing plumes of contaminated
ground water.
• In designing aquifer tests and
interpreting aquifer test data,
owners/operators should account and
correct for seasonal, temporal, and
anthropogenic effects on the
potentiometric surface or water table.
This is usually done by installing
piezometers outside the influence of
the stressed aquifer. These
piezometers should be continuously
monitored during the aquifer test.
• Owners and operators should be aware
that, in a very high hydraulic
conductivity aquifer, the screen size
and/or filter pack used in the test well
can affect an aquifer test. If a very
small screen size is used, and the pack
is improperly graded, the test may
reflect the characteristics of the filter
pack, rather than the aquifer.
• EPA recommends the use of a step-
drawdown test to provide a basis for
selecting discharge rates prior to
conducting a full-scale pumping test.
This will ensure that the pumping rate
chosen for the subsequent pumping
test(s) can be sustained without
exceeding the available drawdown of
the pumped wells. In addition, this test
will produce a measurable drawdown
in the observation wells.
Certain flowmeters recently have been
recognized for their ability to provide
accurate and vertically discrete
measurements of hydraulic conductivity.
One of these, the impeller flowmeter, is
available commercially. More sensitive
types of flowmeters (i.e., the heat-pulse
flowmeter and electromagnetic flowmeter)
should be available in the near future. Use
of the impeller flowmeter requires running
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Subpart E
a caliper log to measure the uniformity of
the diameter of the well screen. The well is
then pumped with a small pump operated at
a constant flow rate. The flowmeter is
lowered into the well, and the discharge rate
is measured every few feet by raising the
flowmeter in the well. Hydraulic
conductivity values can be calculated from
the recorded data using the Cooper-Jacob
(1946) formula for horizontal flow to a
well. Use of the impeller flowmeter is
limited at sites where the presence of low
permeability materials does not allow
pumping of the wells at rates sufficient to
operate the flowmeter. The application of
flowmeters in the measure of hydraulic
conductivity is described by Molz et al.
(1990) and Molz et al. (1989).
Determining Hydraulic Conductivity
Using Laboratory Methods
It may be beneficial to use laboratory
measurements of hydraulic conductivity to
augment the results of field tests. However,
field methods provide the best estimates of
hydraulic conductivity in most cases.
Because of the limited sample size,
laboratory tests can fail to account for
secondary porosity features, such as
fractures and joints, and hence, can greatly
underestimate overall aquifer hydraulic
conductivities. Laboratory tests may
provide valuable information about the
vertical component of hydraulic
conductivity of aquifer materials. However,
laboratory test results always should be
confirmed by field measurements, which
sample a much larger portion of the aquifer.
In addition, laboratory test results can be
profoundly affected by the test method
selected and by the manner in which the
tests are carried out (e.g., the extent to
which sample collection and preparation
have changed the in situ
hydraulic properties of the tested material).
Special attention should be given to the
selection of the appropriate test method and
test conditions and to quality control of
laboratory results. McWhorter and Sunada
(1977), Freeze and Cherry (1979), and
Sevee (1991) discuss determining hydraulic
conductivity in the laboratory. Laboratory
tests may provide the best estimates of
hydraulic conductivity for materials in the
unsaturated zone, but they are likely to be
less accurate than field methods for
materials in the saturated zone (Cantor et
al., 1987).
Determining Ground-Water Flow Rate
The calculation of the average ground-water
flow rate (average linear velocity of ground-
water flow), or seepage velocity, is
discussed in detail in USEPA (1989c), in
Freeze and Cherry (1979), and in Kruseman
and deRidder (1989). The average linear
velocity of ground-water flow (v) is a
function of hydraulic conductivity (K),
hydraulic gradient (i), and effective porosity
(ne):
v = - Ki
Methods for determining hydraulic gradient
and hydraulic conductivity have been
presented previously. Effective porosity,
the percentage of the total volume of a given
mass of soil, unconsolidated material, or
rock that consists of interconnected pores
through which water can flow, should be
estimated from laboratory tests or from
values cited in the literature. (Fetter (1980)
provides a good discussion of effective
porosity. Barari and Hedges (1985) provide
default values for effective porosity.)
USEPA (1989c) provides methods for
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determining flow rates in heterogeneous
and/or anisotropic systems and should be
consulted prior to calculating flow rates.
Interpreting and Presenting Data
The following sections offer guidance on
interpreting and presenting hydrogeologic
data collected during the site
characterization process. Graphical
representations of data, such as cross
sections and maps, are typically extremely
helpful both when evaluating data and when
presenting data to interested individuals.
Interpreting Hydrogeologic Data
Once the site characterization data have
been collected, the following tasks should
be undertaken to support and develop the
interpretation of these data:
• Review borehole and well logs to
identify major rock, unconsolidated
material, and soil types and establish
their horizontal and vertical extent and
distribution.
• From borehole and well log (and
outcrop, where available) data,
construct representative cross-sections
for each MSWLF unit, one in the
direction of ground-water flow and one
orthogonal to ground-water flow.
• Identify zones of suspected high
hydraulic conductivity, or structures
likely to influence contaminant
migration through the unsaturated and
saturated zones.
• Compare findings with other studies
and information collected during the
preliminary investigation to verify the
collected information.
• Determine whether laboratory and
field data corroborate and are
sufficient to define petrology, effective
porosity, hydraulic conductivity,
lateral and vertical stratigraphic
relationships, and ground-water flow
directions and rates.
After the hydrogeologic data are interpreted,
the findings should be reviewed to:
• Identify information gaps
• Determine whether the collection of
additional data or reassessment of
existing data is required to fill in the
gaps
• Identify how information gaps are
likely to affect the ability to design a
RCRA monitoring system.
Generally, lithologic data should correlate
with hydraulic properties (e.g., clean, well-
sorted, unconsolidated sands should exhibit
high hydraulic conductivity). Additional
boreholes should be drilled and additional
samples should be collected to describe the
hydrogeology of the site if the investigator
is unable to 1) correlate stratigraphic units
between borings, 2) identify zones of
potentially high hydraulic conductivity and
the thickness and lateral extent of these
zones, or 3) identify confining
formations/layers and the thickness and
lateral extent of these formation layers.
When establishing the locations of wells
that will be used to monitor ground water in
hydrogeologic settings characterized by
ground-water flow in porous media, the
following should be documented:
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Subpart E
• The ground-water flow rate should be
based on accurate measurements of
hydraulic conductivity and hydraulic
gradient and accurate measurements or
estimates of effective porosity
• The horizontal and vertical
components of flow should be
accurately depicted in flow nets and
based on valid data
• Any seasonal or temporal variations in
the water table or potentiometric
surface, and in vertical flow
components, should be determined.
Once an understanding of horizontal and
vertical ground-water flow has been
established, it is possible to estimate where
monitoring wells will most likely intercept
contaminant flow.
Presenting Hydrogeologic Data
Subsequent to the generation and
interpretation of site-specific geologic data,
the data should be presented in geologic
cross-sections, topographic maps, geologic
maps, and soil maps. The Agency suggests
that owners/operators obtain or prepare and
review topographic, geologic, and soil maps
of the facility, in addition to site maps of the
facility and MSWLF units. In cases where
suitable maps are not available, or where the
information contained on available maps is
not complete or accurate, detailed mapping
of the site should be performed by qualified
and experienced individuals. An aerial
photograph and a topographic map of the
site should be included as part of the
presentation of hydrogeologic data. The
topographic map should be constructed
under the supervision of a qualified
surveyor and should provide contours at a
maximum of 2-foot intervals.
Geologic and soil maps should be based on
rock, unconsolidated material, and soil
identifications gathered from borings and
outcrops. The maps should use colors or
symbols to represent each soil,
unconsolidated material, and rock type that
outcrops on the surface. The maps also
should show the locations of outcrops and
all borings placed during the site
characterization. Geologic and soil maps
are important because they can provide
information describing how site geology fits
into the local and regional geologic setting.
Structure contour maps and isopach maps
should be prepared for each water-bearing
zone that comprises the uppermost aquifer
and for each significant confining layer,
especially the one underlying the uppermost
aquifer. A structure contour map depicts
the configuration (i.e., elevations) of the
upper or lower surface or boundary of a
particular geologic or soil formation, unit,
or zone. Structure contour maps are
especially important in understanding dense
non-aqueous phase liquid (DNAPL)
movement because DNAPLs (e.g.,
tetrachloroethylene) may migrate in the
direction of the dip of lower permeability
units. Separate structure contour maps
should be constructed for the upper and
lower surfaces (or contacts) of each zone of
interest. Isopach maps should depict
contours that indicate the thickness of each
zone. These maps are generated from
borings and geologic logs and from
geophysical measurements. In conjunction
with cross-sections, isopach maps may be
used to help determine monitoring well
locations, depths, and screen lengths during
the design of the detection monitoring
system.
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A potent!ometric surface map or water table
map should be prepared for each water-
bearing zone that comprises the uppermost
aquifer. Potentiometric surface and water
table maps should show both the direction
and rate of ground-water flow and the
locations of all piezometers and wells on
which they are based. The water level
measurements for all piezometers and wells
on which the potentiometric surface map or
water table map is based should be shown
on the potentiometric surface or water table
map. If seasonal or temporal variations in
ground-water flow occur at the site, a
sufficient number of potentiometric surface
or water table maps should be prepared to
show these variations. Potentiometric
surface and water table maps can be
combined with structure contour maps for a
particular formation or unit. An adequate
number of cross sections should be prepared
to depict significant stratigraphic and
structural trends and to reflect stratigraphic
and structural features in relation to local
and regional ground-water flow.
Hydrogeological Report
The hydrogeological report should contain,
at a minimum:
• A description of field activities
• Drilling and/or well construction logs
• Analytical data
• A discussion and interpretation of the
data
• Recommendations to address data gaps.
The final output of the site characterization
phase of the hydrogeological investigation
is
a conceptual model. This model is the
integrated picture of the hydrogeologic
system and the waste management setting.
The final conceptual model must be a site-
specific description of the unsaturated zone,
the uppermost aquifer, and its confining
units. The model should contain all of the
information necessary to design a ground-
water monitoring system.
Monitoring Well Placement
This section separately addresses the lateral
placement and the vertical sampling
intervals of point of compliance wells.
However, these two aspects of well
placement should be evaluated together in
the design of the monitoring system. Site-
specific hydrogeologic data obtained during
the site characterization should be used to
determine the lateral placement of detection
monitoring wells and to select the length
and vertical position of monitoring well
intakes. Potential pathways for contaminant
migration are three-dimensional.
Consequently, the design of a detection
monitoring network that intercepts these
potential pathways requires a
three-dimensional approach.
Lateral Placement of Point of
Compliance Monitoring Wells
Point of compliance monitoring wells
should be as close as physically possible to
the edge of the MSWLF unit(s) and should
be screened in all transmissive zones that
may act as contaminant transport pathways.
The lateral placement of monitoring wells
should be based on the number and spatial
distribution of potential contaminant
migration pathways and on the depths and
thicknesses of stratigraphic horizons that
can serve as contaminant migration
pathways.
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Subpart E
Point of compliance monitoring wells
should be placed laterally along the
downgradient edge of the MSWLF unit to
intercept potential pathways for
contaminant migration. The local ground-
water flow direction and gradient are the
major factors in determining the lateral
placement of point of compliance wells. In
a homogeneous, isotropic hydrogeologic
setting, well placement can be based on
general aquifer characteristics (e.g.,
direction and rate of ground-water flow),
and potential contaminant fate and transport
characteristics (e.g., advection, dispersion).
More commonly, however, geology is
variable and preferential pathways exist that
control the migration of contaminants.
These types of heterogeneous, anisotropic
geologic settings can have numerous,
discrete zones within which contaminants
may migrate.
Potential migration pathways include zones
of relatively high intrinsic (matrix)
hydraulic conductivities, fractured/faulted
zones, and subsurface material that may
increase in hydraulic conductivity if the
material is exposed to waste(s) managed at
the site (e.g., a limestone layer that
underlies an acidic waste). In addition to
natural hydrogeologic features, human-
made features may influence the ground-
water flow direction and, thus, the lateral
placement of point of compliance wells.
Such human-made features include ditches,
areas where fill material has been placed,
buried piping, buildings, leachate collection
systems, and adjacent disposal units. The
lateral placement of monitoring wells
should be based on the number and spatial
distribution of potential contaminant
migration pathways and on the depths and
thicknesses of stratigraphic horizons that
can serve as contaminant migration
pathways.
In some settings, the ground-water flow
direction may reverse seasonally (depending
on precipitation), change as a result of tidal
influences or river and lake stage
fluctuations, or change temporally as a
result of well-pumping or changing land use
patterns. In other settings, ground water
may flow away from the waste management
area in all directions. In such cases, EPA
recommends that monitoring wells be
installed on all sides (or in a circular
pattern) around the waste management area
to allow for the detection of contamination.
In these cases, certain wells may be
downgradient only part of the time, but such
a configuration should ensure that releases
from the unit will be detected.
The lateral placement of monitoring wells
also should be based on the physical/
chemical characteristics of the contaminants
of concern. While the restriction of liquids
in MSWLFs may limit the introduction of
hazardous constituents into landfills, it is
important to consider the physical/chemical
characteristics of contaminants when
designing the well system. These
characteristics include solubility, Henry's
Law constant, partition coefficients, specific
gravity, contaminant reaction or degradation
products, and the potential for contaminants
to degrade confining layers. For example,
contaminants with low solubilities and high
specific gravities that occur as DNAPLs
may migrate in the subsurface in directions
different from the direction of ground-water
flow. Therefore, in situations where the
release of DNAPLs is a concern, the lateral
placement of compliance point ground-
water monitoring wells should not
necessarily only be along the downgradient
edge of the MSWLF unit. Considering both
contaminant characteristics and
hydrogeologic properties is important when
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Ground-Water Monitoring and Corrective Action
determining the lateral placement of
monitoring wells.
Vertical Placement and Screen Lengths
Proper selection of the vertical sampling
interval is necessary to ensure that the
monitoring system is capable of detecting a
release from the MSWLF unit. The vertical
position and lengths of well intakes are
functions of (1) hydro-geologic factors that
determine the distribution of, and
fluid/vapor phase transport within, potential
pathways of contaminant migration to and
within the uppermost aquifer, and (2) the
chemical and physical characteristics of
contaminants that control their transport and
distribution in the subsurface. Well intake
length also is determined by the need to
obtain vertically discrete ground-water
samples. Owners and operators should
determine the probable location, size, and
geometry of potential contaminant plumes
when selecting well intake positions and
lengths.
Site-specific hydrogeologic data obtained
during the site characterization should be
used to select the length and vertical
position of monitoring well intakes. The
vertical positions and lengths of monitoring
well intakes should be based on the number
and spatial distribution of potential
contaminant migration pathways and on the
depths and thicknesses of stratigraphic
horizons that can serve as contaminant
migration pathways. Figure 5-2 illustrates
examples of complex stratigraphy that
would require multiple vertical monitoring
intervals.
The depth and thickness of a potential
contaminant migration pathway can be
determined from soil, unconsolidated
material, and rock samples collected during
the boring program, and from samples
collected while drilling the monitoring well.
Direct physical data can be supplemented by
geophysical data, available regional/local
hydrogeological data, and other data that
provide the vertical distribution of hydraulic
conductivity. The vertical sampling interval
is not necessarily synonymous with aquifer
thickness. Monitoring wells are often
screened at intervals that represent a portion
of the thickness of the aquifer. When
monitoring an unconfined aquifer, the well
screen typically should be positioned so that
a portion of the well screen is in the
saturated zone and a portion of the well
screen is in the unsaturated zone (i.e., the
well screen straddles the water table).
While the restriction of liquids in MSWLFs
may limit the introduction of hazardous
constituents into landfills, it is important to
consider the physical/chemical
characteristics of contaminants when
designing the well system.
The vertical positions and lengths of
monitoring well intakes should be based on
the same physical/chemical characteristics
of the contaminants of concern that
influence the lateral placement of
monitoring wells. Considering both
contaminant characteristics and
hydrogeologic properties is important when
choosing the vertical position and length of
the well intake. Some contaminants may
migrate within very narrow zones. Of
course, for well placement at a new site, it is
unlikely that the owner or operator will be
able to assess contaminant characteristics.
Different transport processes control
contaminant migration depending on
whether the contaminant dissolves or is
immiscible in water. Immiscible
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Subpart E
Piezometric
Surface
Down Gradient Zone
Flow Path
69
65
Figure 5-2
Upgradient and Downgradient
Designations for Idealized MSWLF
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Ground-Water Monitoring and Corrective Action
contaminants may occur as light non
aqueous phase liquids (LNAPLs), which are
lighter than water, and DNAPLs, which are
denser than water. LNAPLs migrate in the
capillary zone just above the water table.
Wells installed to monitor LNAPLs should
be screened at the water table/capillary zone
interface, and the screened interval should
intercept the water table at its minimum and
maximum elevation. LNAPLs may become
trapped in residual form in the vadose zone
and become periodically remobilized and
contribute further to aquifer contamination,
either as free phase or dissolved phase
contaminants, as the water table fluctuates
and precipitation infiltrates the subsurface.
The migration of free-phase DNAPLs may
be influenced primarily by the geology,
rather than the hydrogeology, of the site.
That is, DNAPLs migrate downward
through the saturated zone due to density
and then migrate by gravity along less
permeable geologic units (e.g., the slope of
confining units, the slope of clay lenses in
more permeable strata, bedrock troughs),
even in aquifers with primarily horizontal
ground-water flow. Consequently, if wastes
disposed at the site are anticipated to exist
in the subsurface as a DNAPL, the potential
DNAPL should be monitored:
• At the base of the aquifer (immediately
above the confining layer)
• In structural depressions (e.g., bedrock
troughs) in lower hydraulic
conductivity geologic units that act as
confining layers
• Along lower hydraulic conductivity
lenses and units within units of higher
hydraulic conductivity
• "Down-the-dip" of lower hydraulic
conductivity units that act as confining
layers, both upgradient and
downgradient of the waste
management area.
Because of the nature of DNAPL migration
(i.e., along structural, rather than hydraulic,
gradients), wells installed to monitor
DNAPLs may need to be installed both
upgradient and downgradient of the waste
management area. It may be useful to
construct a structure contour map of lower
permeability strata and identify lower
permeability lenses upgradient and
downgradient of the unit along which
DNAPLs may migrate. The wells can then
be located accordingly.
The lengths of well screens used in
ground-water monitoring wells can
significantly affect their ability to intercept
releases of contaminants. The complexity
of the hydrogeology of a site is an important
consideration when selecting the lengths of
well screens. Most hydrogeologic settings
are complex (heterogeneous and
anisotropic) to a certain degree. Highly
heterogeneous formations require shorter
well screens to allow sampling of discrete
portions of the formation that can serve as
contaminant migration pathways. Well
screens that span more than a single
saturated zone or a single contaminant
migration pathway may cause cross-
contamination of transmissive units, thereby
increasing the extent of contamination.
Well intakes should be installed in a single
saturated zone. Well intakes (e.g., screens)
and filter pack materials should not
interconnect, or promote the interconnection
of, zones that are separated by a confining
layer.
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Subpart E
Even in hydrologically simple formations,
or within a single potential pathway for
contaminant migration, the use of shorter
well screens may be necessary to detect
contaminants concentrated at particular
depths. A contaminant may be concentrated
at a particular depth because of its
physical/chemical properties and/or because
of hydrogeologic properties. In
homogeneous formations, a long well screen
can permit excessive amounts of
uncontaminated formation water to dilute
the contaminated ground water entering the
well. At best, dilution can make
contaminant detection difficult; at worst,
contaminant detection is impossible if the
concentrations of contaminants are diluted
to levels below the detection limits for the
prescribed analytical methods. The use of
shorter well screens allows for contaminant
detection by reducing excessive dilution.
When placed at depths of predicted
preferential flow, shorter well screens are
effective in monitoring the aquifer or the
portion of the aquifer of concern.
Generally, screen lengths should not exceed
10 feet. However, certain hydrogeologic
settings may warrant or necessitate the use
of longer well screens for adequate
detection monitoring. Unconfmed aquifers
with widely fluctuating water tables may
require longer screens to intercept the water
table surface at both its maximum and
minimum elevations and to provide
monitoring for the presence of contaminants
that are less dense than water. Saturated
zones that are slightly greater in thickness
than the appropriate screen length (e.g., 12
feet thick) may warrant monitoring with
longer screen lengths. Extremely thick
homogeneous aquifers (e.g., greater than
300 feet) may be monitored with a longer
screen (e.g., a 20-foot screen) because a
slightly longer screen
would represent a fairly discrete interval in
a very thick formation. Formations with
very low hydraulic conductivities also may
require the use of longer well screens to
allow sufficient amounts of formation water
to enter the well for sampling. The
importance of accurately identifying such
conditions highlights the need for a
complete hydrogeologic site investigation
prior to the design and placement of
detection wells.
Multiple monitoring wells (well clusters or
multilevel sampling devices) should be
installed at a single location when (1) a
single well cannot adequately intercept and
monitor the vertical extent of a potential
pathway of contaminant migration, or (2)
there is more than one potential pathway of
contaminant migration in the subsurface at
a single location, or (3) there is a thick
saturated zone and immiscible contaminants
are present, or are determined to be
potentially present after considering waste
types managed at the facility. Conversely, at
sites where ground water may be
contaminated by a single contaminant,
where there is a thin saturated zone, and
where the site is hydrogeologically
homogeneous, the need for multiple wells at
each sampling location is reduced. The
number of wells that should be installed at
each sampling location increases with site
complexity.
The following sources provided additional
information on monitoring well placement:
USEPA (1992a), USEPA (1990), USEPA
(1991), and USEPA (1986a).
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5.7 GROUND-WATER
MONITORING WELL DESIGN
AND CONSTRUCTION
40 CFR §258.51 (c)
5.7.1 Statement of Regulation
(c) Monitoring wells must be cased in a
manner that maintains the integrity of
the monitoring well bore hole. This
casing must be screened or perforated
and packed with gravel or sand, where
necessary, to enable collection of ground-
water samples. The annular space (i.e.,
the space between the bore hole and well
casing) above the sampling depth must be
sealed to prevent contamination of
samples and the ground water.
(1) The owner or operator must notify
the State Director that the design,
installation, development, and
decommission of any monitoring wells,
piezometers and other measurement,
sampling, and analytical devices
documentation has been placed in the
operating record; and
(2) The monitoring wells, piezometers,
and other measurement, sampling, and
analytical devices must be operated and
maintained so that they perform to design
specifications throughout the life of the
monitoring program.
§258.52 [Reserved].
5.7.2 Applicability
The requirements for monitoring well
design, installation, and maintenance are
applicable to all wells installed at existing
units, lateral expansions of units, and new
MSWLF units. The design, installation, and
decommissioning of any monitoring well
must be documented in the operating record
of the facility and certified by a qualified
ground-water scientist. Documentation is
required for wells, piezometers, sampling
devices, and water level measurement
instruments used in the monitoring program.
The monitoring wells must be cased to
protect the integrity of the borehole. The
design and construction of the well directly
affects the quality and representativeness of
the samples collected. The well casing must
have a screened or perforated interval to
allow the entrance of water into the well
casing. The annular space between the well
screen and the formation wall must be
packed with material to inhibit the
migration of formation material into the
well. The well screen must have openings
sized according to the packing material
used. The annular space above the filter
pack must be sealed to provide a discrete
sampling interval.
All monitoring wells, piezometers, and
sampling and analytical devices must be
maintained in a manner that ensures their
continued performance according to design
specifications over the life of the monitoring
program.
5.7.3 Technical Considerations
The design, installation, and maintenance of
monitoring wells will affect the consistency
and accuracy of samples collected. The
design must be based on site-specific
information. The formation material
(lithology and grain size distribution) will
determine the selection of proper packing
and sealant materials, and the stratigraphy
will determine the screen length for the
interval to be monitored. Installation
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Subpart E
practices should be specified and overseen
to ensure that the monitoring well is
installed as designed and will perform as
intended. This section will discuss the
factors that must be considered when
designing monitoring wells. Each well must
be tailored to suit the hydrogeological
setting, the contaminants to be monitored,
and other site-specific factors. Figure 5-3
depicts the components of a typical
monitoring well installation.
The following sections provide a brief
overview of monitoring well design and
construction. More comprehensive
discussions are provided in USEPA (1989f)
andUSEPA(1992a).
Selection of Drilling Method
The method chosen for drilling a monitoring
well depends largely on the following
factors (USEPA, 1989f):
• Versatility of the drilling method
• Relative drilling cost
• Sample reliability (ground-water, soil,
unconsolidated material, or rock
samples)
• Availability of drilling equipment
• Accessibility of the drilling site
• Relative time required for well
installation and development
• Ability of the drilling technology to
preserve natural conditions
• Ability to install a well of desired
diameter and depth
• Relative ease of well completion and
development, including the ability to
install the well in the given
hydrogeologic setting.
In addition to these factors, USEPA (1989f)
includes matrices to assist in selecting an
appropriate drilling method. These matrices
list the most commonly used drilling
techniques for monitoring well installation,
taking into consideration hydrogeologic
settings and the objectives of the monitoring
program.
The following basic performance objectives
should guide the selection of drilling
procedures for installing monitoring wells:
• Drilling should be performed in a
manner that preserves the natural
properties of the subsurface materials.
• Contamination and/or cross-
contamination of ground water and
aquifer materials during drilling should
be avoided.
• The drilling method should allow for
the collection of representative
samples of rock, unconsolidated
materials, and soil.
• The drilling method should allow the
owner/operator to determine when the
appropriate location for the screened
interval has been encountered.
• The drilling method should allow for
proper placement of the filter pack and
annular sealants. The borehole should
be at least 4 inches larger in diameter
than the nominal diameter of the well
casing and screen to allow adequate
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Protective Cover
with Locking Cap
6 in (152mm)
Clearance for Sampler
Top of Riser 3 ft
(1.0m) Above Grade
2 ft (606mm) x 4" (101mm) Thic
Neat Concrete Pad
3 tt-5 ft (1.0-1.5m) Surface Seal of
Neat Cement Extended to at Least 1
ft below Frost Line
Minimum 2" (50mm) ID Riser with
Flush Threaded Connections
Well Identification Labeled Inside
and Outside the Cap
Vented Cap
Protective Casing
1/4" (6.3mm) Weep Hole at 6" Above Ground Level
3 ft-5 ft. (1.0 to'l.Sm) Protective Casing
Anchored Below Frost Line
Grout Length Varies
Borehole
Centralizer(s) As
Necessary
Plug
3 ft-5 ft (1.0m-1.5m) Bentonite Seal
1 ft-2 ft (303mm-€06mm) Filter Pack
Extended 2 ft (606mm) Above Slotted Well
Screen
Well Screen Length Varies
Sediment Sump (As Appropriate)
Figure 5.3. Example of a Monitoring Well Design-Single Cased Well
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Subpart E
space for placement of the filter pack
and annular sealants.
• The drilling method should allow for
the collection of representative ground-
water samples. Drilling fluids
(including air) should be used only
when minimal impact to the
surrounding formation and ground
water can be ensured.
The following guidelines apply to the use of
drilling fluids, drilling fluid additives, and
lubricants when drilling ground-water
monitoring wells:
• Drilling fluids, drilling fluid additives,
or lubricants that affect the analysis of
hazardous constituents in ground-water
samples should not be used.
• The owner/operator should
demonstrate the inertness of drilling
fluids, drilling fluid additives, and
lubricants by performing analytical
testing of drilling fluids, drilling fluid
additives, and lubricants and/or by
providing information regarding the
composition of drilling fluids, drilling
fluid additives, or lubricants obtained
from the manufacturer.
• The owner/operator should consider
the potential impact of drilling fluids,
drilling fluid additives, and lubricants
on the physical and chemical
characteristics of the subsurface and on
ground-water quality.
• The volume of drilling fluids, drilling
fluid additives, and lubricants used
during the drilling of a monitoring well
should be recorded.
Monitoring Well Design
Well Casing
Well Casing and Screen Materials
A casing and well screen are installed in a
ground-water monitoring well for several
reasons: to provide access from the surface
of the ground to some point in the
subsurface, to prevent borehole collapse,
and to prevent hydraulic communication
between zones within the subsurface. In
some cases, State or local regulations may
specify the casing and material that the
owner or operator should use. A
comprehensive discussion of well casing
and screen materials is provided in USEPA
(1989f) and in USEPA (1992a). The
following discussion briefly summarizes
information contained in these references.
Monitoring well casing and screen materials
may be constructed of any of several types
of materials, but should meet the following
performance specifications:
• Monitoring well casing and screen
materials should maintain their
structural integrity and durability in
the environment in which they are used
over their operating life.
• Monitoring well casings and screens
should be resistant to chemical and
microbiological corrosion and
degradation in contaminated and
uncontaminated waters.
• Monitoring well casings and screens
should be able to withstand the
physical forces acting upon them
during and following their installation
and during their use — including forces
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Ground-Water Monitoring and Corrective Action
due to suspension in the borehole,
grouting, development, purging,
pumping, and sampling and forces
exerted on them by the surrounding
geologic materials.
• Monitoring well casing and screen
materials should not chemically alter
ground-water samples, especially with
respect to the analytes of concern, as a
result of their sorbing, desorbing, or
leaching analytes. For example, if
chromium is an analyte of interest, the
well casing or screen should not
increase or decrease the amount of
chromium in the ground water. Any
material leaching from the casing or
screen should not be an analyte of
interest or interfere in the analysis of
an analyte of interest.
In addition, monitoring well casing and
screen materials should be relatively easy to
install into the borehole during construction
of the monitoring well.
The selection of the most suitable well
casing and screen materials should consider
site-specific factors, including:
• Depth to the water-bearing zone(s) to
be monitored and the anticipated well
depth
• Geologic environment
• Geochemistry of soil, unconsolidated
material, and rock over the entire
interval in which the well is to be cased
• Geochemistry of the ground water at
the site, as determined through an
initial analysis of samples from both
background wells and downgradient
wells and including:
- Natural ground-water geochemistry
- Nature of suspected or known
contaminants
- Concentration of suspected or known
contaminants
• Design life of the monitoring well.
Casing materials widely available for use in
ground-water monitoring wells can be
divided into three categories:
1) Fluoropolymer materials, including
polytetrafluoroethylene (PTFE),
tetrafluoroethylene (TFE), fluorinated
ethylene propylene (FEP),
perfluoroalkoxy (PFA), and
polyvinylidene fluoride (PVDF)
2) Metallic materials, including carbon
steel, low-carbon steel, galvanized
steel, and stainless steel (304 and 316)
3) Thermoplastic materials, including
polyvinyl chloride (PVC) and
acrylonitrile butadiene styrene (ABS).
In addition to these three categories of
materials, fiberglass-reinforced plastic
(FRP) has been used for monitoring
applications. Because FRP has not yet been
used in general application across the
country, very little data are available on its
characteristics and performance. All well
construction materials possess
strength-related characteristics and chemical
resistance/chemical interference
characteristics that influence their
performance in site-specific hydrogeologic
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Subpart E
and contaminant-related monitoring
situations.
The casing must be made of a material
strong enough to last for the life of the well.
Tensile strength is needed primarily during
well installation when the casing is lowered
into the hole. The joint strength will
determine the maximum length of a section
that can be suspended from the surface in an
air-filled borehole.
Collapse strength is the capability of a
casing to resist collapse by any external
loads to which it is subjected both during
and after installation. A casing is most
susceptible to collapse during installation
before placement of the filter pack or
annular seal materials around the casing.
Once a casing is installed and supported,
collapse is seldom a concern. Several steps
that can be taken to avoid casing collapse
are:
1) Drilling a straight, clean borehole
2) Uniformly distributing filter pack
materials at a slow, even rate
3) Avoiding use of quick-setting (high
temperature) cements for thermoplastic
casings installation.
Compressive strength of the casing is a
measure of the greatest compressive stress
that a casing can bear without deformation.
Casing failure due to a compressive strength
limitation generally is not an important
factor in a properly installed well. This type
of failure results from soil friction on
unsupported casing.
Chemical resistance/interference
characteristics must be evaluated before
selecting monitoring well materials.
Metallic casing materials are more subject
to corrosion, while thermoplastic casing
materials are more susceptible to chemical
degradation. The geochemistry of the
formation water influences the degree to
which these processes occur. If ground-
water chemistry affects the structural
integrity of the casing, then the samples
collected from the well are likely to be
affected.
Materials used for monitoring well casing
must not exhibit a tendency to sorb or leach
chemical constituents from, or into, water
sampled from the well. If a casing material
sorbs constituents from ground water, those
constituents may either not be detected
during monitoring or be detected at a lower
concentration. Chemical constituents also
can be leached from the casing materials by
aggressive aqueous solutions. These
constituents may be detected in samples
collected from the well. The results may
indicate contamination that is due to the
casing rather than the formation water.
Casing materials must be selected with care
to avoid degradation of the well and to
avoid erroneous results.
In certain situations it may be advantageous
to design a well using more than one
material for well components. For example,
where stainless steel or fluoropolymer
materials are preferred in a specific
chemical environment, costs may be saved
by using PVC in non-critical portions of the
well. These savings may be considerable,
especially in deep wells where only the
lower portion of the well is in a critical
chemical environment and where tens of
feet of lower-cost PVC may be used in the
upper portion of the well. In a composite
well design, dissimilar metallic
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Ground-Water Monitoring and Corrective Action
components should not be used unless an
electrically isolating design is incorporated
(i.e., a dielectric coupling) (USEPA, 1986).
Coupling Procedures for Joining Casing
Only a limited number of methods are
available for joining lengths of casing or
casing and screen together. The joining
method depends on the type of casing and
type of casing joint.
There are generally two options available
for joining metallic well casings: welding
via application of heat, or threaded joints.
Threaded joints provide inexpensive, fast,
and convenient connections and greatly
reduce potential problems with chemical
resistance or interference (due to corrosion)
and explosion potential. Wrapping the male
threads with fluoropolymer tape prior to
joining sections improves the watertightness
of the joint. One disadvantage to using
threaded joints is that the tensile strength of
the casing string is reduced to
approximately 70 percent of the casing
strength. This reduction in strength does
not usually pose a problem because strength
requirements for small diameter wells (such
as typical monitoring wells) are not as
critical and because metallic casing has a
high initial tensile strength.
Joints should create a uniform inner and
outer casing diameter in monitoring well
installations. Solvent cementing of
thermoplastic pipe should never be used in
the construction of ground-water monitoring
wells. The cements used in solvent welding,
which are organic chemicals, have been
shown to adversely affect the integrity of
ground-water samples for more than 2 years
after well installation; only factory-
threaded joints should be used on
thermoplastic well material.
Well Casing Diameter
Although the diameter of the casing for a
monitoring well depends on the purpose of
the well, the casing size is generally selected
to accommodate downhole equipment.
Additional casing diameter selection criteria
include the 1) drilling or well installation
method used, 2) anticipated depth of the
well and associated strength requirements,
3) anticipated method of well development,
4) volume of water required to be purged
prior to sampling, 5) rate of recovery of the
well after purging, and 6) anticipated
aquifer testing.
Casing Cleaning Requirements
Well casing and screen materials should be
cleaned prior to installation to remove any
coatings or manufacturing residues. Prior to
use, all casing and screen materials should
be washed with a mild, non-phosphate,
detergent/potable water solution and rinsed
with potable water. Hot pressurized water,
such as in steam cleaning, should be used to
remove organic solvents, oils, or lubricants
from casing and screens composed of
materials other than plastic. At sites where
volatile organic contaminants may be
monitored, the cleaning of well casing and
screen materials should include a final rinse
with deionized water or potable water that
has not been chlorinated. Once cleaned,
casings and screens should be stored in an
area that is free of potential contaminants.
Plastic sheeting can generally be used to
cover the ground in the decontamination
area to provide protection from
contamination. USEPA (1989f) describes
the procedures
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Subpart E
that should be used to clean casing and
screen materials.
Well Intake Design
The owner/operator should design and
construct the intakes of monitoring wells to
(1) accurately sample the aquifer zone that
the well is intended to sample, (2) minimize
the passage of formation materials
(turbidity) into the well, and (3) ensure
sufficient structural integrity to prevent the
collapse of the intake structure. The goal of
a properly completed monitoring well is to
provide low turbidity water that is
representative of ground-water quality in
the vicinity of the well. Close attention to
proper selection of packing materials and
well development procedures for wells
installed in fine-grained formations (e.g.,
clays and silty glacial tills) is important to
minimize sample turbidity from suspended
and colloidal solids. There may be
instances where wells completed in rock do
not require screens or filter packs; the State
regulatory agency should be consulted prior
to completion of unscreened wells.
The selection of screen length usually
depends on the objective of the well.
Piezometers and wells where only a discrete
flow path is monitored (such as thin gravel
interbedded with clays) are generally
completed using short screens (2 feet or
less). To avoid dilution, the well screens
should be kept to the minimum length
appropriate for intercepting a contaminant
plume, especially in a high-yielding aquifer.
The screen length should generally not
exceed 10 feet. If construction of a water
table well is the objective, either for
defining gradient or detecting floating
phases, then a longer screen is acceptable
because the owner/operator will need to
provide a margin of safety that will
guarantee that at least a portion of the
screen always contacts the water table
regardless of its seasonal fluctuations. The
owner or operator should not employ well
intake designs that cut across hydraulically
separated geologic units.
Well screen slot size should be selected to
retain from 90 percent to 100 percent of the
filter pack material (discussed below) in
artificially filter packed wells. Well screens
should be factory-slotted. Manual slotting
of screens in the field should not be
performed under any circumstances.
Filter Pack Design
The primary filter pack material should be a
chemically inert material and well rounded,
with a high coefficient of uniformity. The
best filter pack materials are made from
industrial grade glass (quartz) sand or beads.
The use of other materials, such as local,
naturally occurring clean sand, is
discouraged unless it can be shown that the
material is inert (e.g., low cation exchange
capacity), coarse-grained, permeable, and
uniform in grain size. The filter pack should
extend at least 2 feet above the screened
interval in the well.
Although design techniques for selecting
filter pack size vary, all use the filter pack
ratio to establish size differential between
formation materials and filter pack
materials. Generally, this ratio refers to
either the average (50 percent retained)
grain size of the formation material or to the
70 percent retained size of the formation
material. Barcelona et al. (1985b)
recommend using a uniform filter pack
grain size that is three to five times the size
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Ground-Water Monitoring and Corrective Action
of the 50 percent retained size of the
formation material (USEPA, 1990).
Filter pack material should be installed in a
manner that prevents bridging and particle-
size segregation. Filter pack material
installed below the water table should
generally be tremied into the annular space.
Allowing filter pack material to fall by
gravity (free fall) into the annular space is
only appropriate when wells are relatively
shallow, when the filter pack has a uniform
grain size, and when the filter pack material
can be poured continuously into the well
without stopping.
At least 2 inches of filter pack material
should be installed between the well screen
and the borehole wall. The filter pack
should extend at least 2 feet above the top of
the well screen. In deep wells, the filter
pack may not compress when initially
installed. Consequently, when the annular
and surface seals are placed on the filter
pack, the filter pack compresses sufficiently
to allow grout into, or very close to, the
screen. Consequently, filter packs may need
to be installed as high as 5 feet above the
screened interval in monitoring wells that
are deep (i.e., greater than 200 feet). The
precise volume of filter pack material
required should be calculated and recorded
before placement, and the actual volume
used should be determined and recorded
during well construction. Any significant
discrepancy between the calculated volume
and the actual volume should be explained.
Prior to installing the annular seal, a 1- to
2-foot layer of chemically inert fine sand
may be placed over the filter pack to prevent
the intrusion of annular or surface sealants
into the filter pack. When designing
monitoring wells, owners and
operators should remember that the entire
length of the annular space filled with filter
pack material or sand is effectively the
monitored zone. Moreover, if the filter
pack/sand extends from the screened zone
into an overlying zone, a conduit for
hydraulic connection is created between the
two zones.
Annular Sealants
Proper sealing of the annular space between
the well casing and the borehole wall is
required to prevent contamination of
samples and the ground water. Adequate
sealing will prevent hydraulic connection
within the well annulus. The materials used
for annular sealants should be chemically
inert with the highest anticipated
concentration of chemical constituents
expected in the ground water at the facility.
In general, the permeability of the sealing
material should be one to two orders of
magnitude lower than the least permeable
part of the formation in contact with the
well. The precise volume of annular
sealants required should be calculated and
recorded before placement, and the actual
volume used should be determined and
recorded during well construction. Any
significant discrepancy between the
calculated volume and the actual volume
should be explained.
When the screened interval is within the
saturated zone, a minimum of 2 feet of
sealant material, such as raw (>10 percent
solids) bentonite, should be placed
immediately over the protective sand layer
overlying the filter pack. Granular
bentonite, bentonite pellets, and bentonite
chips may be placed around the casing by
means of a tremie pipe in deep wells
(greater than approximately 30 feet deep),
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Subpart E
or by dropping them directly down the
annulus in shallow wells (less than
approximately 30 feet deep). Dropping the
bentonite pellets down the annulus presents
a potential for bridging (from premature
hydration of the bentonite), leading to gaps
in the seal below the bridge. In shallow
monitoring wells, a tamping device should
be used to prevent bridging from occurring.
A neat cement or shrinkage-compensated
neat cement grout seal should be installed
on top of the bentonite seal and extend
vertically up the annular space between the
well casing and the borehole wall to within
a few feet of land surface. Annular sealants
in slurry form (e.g., cement grout, bentonite
slurry) should be placed by the tremie/pump
(from the bottom up) method. The bottom
of the placement pipe should be equipped
with a side discharge deflector to prevent
the slurry from jetting a hole through the
protective sand layer, filter pack, or
bentonite seal. The bentonite seal should be
allowed to completely hydrate, set, or cure
in conformance with the manufacturer's
specifications prior to installing the grout
seal in the annular space. The time required
for the bentonite seal to completely hydrate,
set, or cure will differ with the materials
used and the specific conditions
encountered, but is generally a minimum of
4 to 24 hours. Allowing the bentonite seal
to hydrate, set, or cure prevents the invasion
of the more viscous and more chemically
reactive grout seal into the screened area.
When using bentonite as an annular sealant,
the appropriate clay should be selected on
the basis of the environment in which it is to
be used, such as the ion-exchange potential
of the sediments, sediment permeability,
and compatibility with expected
contaminants. Sodium bentonite is usually
acceptable.
When the annular sealant must be installed
in the unsaturated zone, neat cement or
shrinkage-compensated neat cement
mixtures should be used for the annular
sealant. Bentonite is not recommended as
an annular sealant in the unsaturated zone
because the moisture available is
insufficient to fully hydrate bentonite.
Surface Completion
Monitoring wells are commonly either
above-ground completions or flush-to-
ground completions. The design of both
types must consider the prevention of
infiltration of surface runoff into the well
annulus and the possibility of accidental
damage or vandalism. Completing a
monitoring well involves installing the
following components:
• Surface seal
• Protective casing
• Ventilation hole
• Drain hole
• Cap and lock
• Guard posts when wells are completed
above grade.
A surface seal, installed on top of the grout
seal, extends vertically up the well annulus
to the land surface. To protect against frost
heave, the seal should extend at least 1 foot
below the frost line. The composition of the
surface seal should be neat cement or
concrete. In an above-ground completion,
the surface seal should form at least a 2-foot
wide, 4-inch thick apron.
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Ground-Water Monitoring and Corrective Action
A locking protective casing should be
installed around the well casing to prevent
damage or unauthorized entry. The
protective casing should be anchored below
the frost line (where applicable) into the
surface seal and extend at least 18 inches
above the surface of the ground. A 1/4-inch
vent hole pipe is recommended to allow the
escape of any potentially explosive gases
that may accumulate within the well. In
addition, a drain hole should be installed in
the protective casing to prevent water from
accumulating and, in freezing climates,
freezing around the well casing. The space
between the protective casing and the well
casing may be filled with gravel to allow the
retrieval of tools and to prevent small
animal/insect entrance through the drain. A
suitable cap should be placed on the well to
prevent tampering or the entry of any
foreign materials. A lock should be
installed on the cap to provide security. To
prevent corrosion or jamming of the lock, a
protective cover should be used. Care
should be taken when using such lubricants
as graphite or petroleum-based sprays to
lubricate the lock, as lubricants may
introduce a potential for sample
contamination.
To guard against accidental damage to the
well from facility traffic, the owner/operator
should install concrete or steel bumper
guards around the edge of the concrete
apron. These should be located within 3 or
4 feet of the well and should be painted
orange or fitted with reflectors to reduce the
possibility of vehicular damage.
The use of flush-to-ground surface
completions should be avoided because this
design increases the potential for surface
water infiltration into the well. In cases
where flush-to-ground completions are
unavoidable, such as in active roadways, a
protective structure, such as a utility vault
or meter box, should be installed around the
well casing. In addition, measures should
be taken to prevent the accumulation of
surface water in the protective structure and
around the well intake. These measures
should include outfitting the protective
structure with a steel lid or manhole cover
that has a rubber seal or gasket and ensuring
that the bond between the cement surface
seal and the protective structure is
watertight.
Well Surveying
The location of all wells should be surveyed
by a licensed professional surveyor (or
equivalent) to determine their X-and-Y
coordinates as well as their distances from
the units being monitored and their
distances from each other. A State Plane
Coordinate System, Universal Transverse
Mercator System, or Latitude/Longitude
should be used, as approved by the Regional
Administrator. The survey should also note
the coordinates of any temporary
benchmarks. A surveyed reference mark
should be placed on the top of the well
casing, not on the protective casing or the
well apron, for use as a measuring point
because the well casing is more stable than
the protective casing or well apron (both the
protective casing and the well apron are
more susceptible to frost heave and
spalling). The height of the reference
survey datum, permanently marked on top
of the inner well casing, should be
determined within ±0.01 foot in relation to
mean sea level, which in turn is determined
by reference to an established National
Geodetic Vertical Datum. The reference
marked on top of inner well casings should
be re surveyed at least once every 5 years,
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Subpart E
unless changes in ground-water flow
patterns/direction, or damage caused by
freeze/thaw or desiccation processes, are
noted. In such cases, the Regional
Administrator may require that well casings
be resurveyed on a more frequent basis.
Well Development
All monitoring wells should be developed to
create an effective filter pack around the
well screen, to rectify damage to the
formation caused by drilling, to remove fine
particles from the formation near the
borehole, and to assist in restoring the
natural water quality of the aquifer in the
vicinity of the well. Development stresses
the formation around the screen, as well as
the filter pack, so that mobile fines, silts,
and clays are pulled into the well and
removed. The process of developing a well
creates a graded filter pack around the well
screen. Development is also used to remove
any foreign materials (drilling water, muds,
etc.) that may have been introduced into the
well borehole during drilling and well
installation and to aid in the equilibration
that will occur between the filter pack, well
casing, and the formation water.
The development of a well is extremely
important to ensuring the collection of
representative ground-water samples. If the
well has been properly completed, then
adequate development should remove fines
that may enter the well either from the filter
pack or the formation. This improves the
yield, but more importantly it creates a
monitoring well capable of producing
samples of acceptably low turbidity. Turbid
samples from an improperly constructed and
developed well may interfere with
subsequent analyses.
When development is initiated, a wide range
of grain sizes of the natural material is
drawn into the well, and the well typically
produces very turbid water. However, as
development continues and the natural
materials are drawn into the filter pack, an
effective filter will form through a sorting
process. Inducing movement of ground
water into the well (i.e., in one direction)
generally results in bridging of the particles.
A means of inducing flow reversal is
necessary to break down bridges and
produce a stable filter.
The commonly accepted methods for
developing wells are described in USEPA
(1989f) and Driscoll (1986) and include:
• Pumping and overpumping
• Surging with a surge block
• Bailing.
USEPA (1989f) provides a detailed
overview of well development and should
be consulted when evaluating well
development methods.
Documentation of Well Design.
Construction, and Development
Information on the design, construction, and
development of each well should be
compiled. Such information should include
(1) a boring log that documents well drilling
and associated formation sampling and (2)
a well construction log and well
construction diagram ("as built").
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Ground-Water Monitoring and Corrective Action
Decommissioning Ground-Water
Monitoring Wells and Boreholes
Ground-water contamination resulting from
improperly decommissioned wells and
boreholes is a serious concern. Any
borehole that will not be completed as a
monitoring well should be properly
decommissioned. The USEPA (1975) and
the American Water Works Association
(1985) provide the following reasons,
summarized by USEPA (1989f), as to why
improperly constructed or unused wells
should be properly decommissioned:
• To eliminate physical hazards
To prevent
contamination
ground-water
• To conserve aquifer yield and
hydrostatic head
• To prevent intermixing of subsurface
water.
Should an owner or operator have a
borehole or an improperly constructed or
unused well at his or her facility, the well or
borehole should be decommissioned in
accordance with specific guidelines.
USEPA (1989f) provides comprehensive
guidance on performing well
decommissioning that can be applied to
boreholes. In addition, any State/Tribal
regulatory guidance should be consulted
prior to decommissioning monitoring wells,
piezometers, or boreholes. Lamb and
Kinney (1989) also provide information on
decommissioning ground-water monitoring
wells.
Many States require that specific procedures
be followed and certain paperwork be filed
when decommissioning water supply wells.
In some States, similar regulations may
apply to the decommissioning of monitoring
wells and boreholes. The EPA and other
involved regulatory agencies, as well as
experienced geologists, geotechnical
engineers, and drillers, should be consulted
prior to decommissioning a well or borehole
to ensure that decommissioning is
performed properly and to ensure
compliance with State law. If a well to be
decommissioned is contaminated, the safe
removal and proper disposal of the well
materials should be ensured by the
owner/operator. Appropriate measures
should be taken to protect the health and
safety of individuals when decommissioning
a well or borehole.
5.8 GROUND-WATER SAMPLING
AND ANALYSIS
REQUIREMENTS
40 CFR §258.53
5.8.1 Statement of Regulation
(a) The ground-water monitoring
program must include consistent
sampling and analysis procedures that
are designed to ensure monitoring results
that provide an accurate representation
of ground-water quality at the
background and downgradient wells
installed in compliance with §258.51(a) of
this Part. The owner or operator must
notify the State Director that the
sampling and analysis program
documentation has been placed in the
operating record and the program must
include procedures and techniques for:
(1) Sample collection;
(2) Sample preservation and shipment;
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Subpart E
(3) Analytical procedures;
(4) Chain of custody control; and
(5) Quality assurance and quality
control.
(b) The ground-water monitoring
program must include sampling and
analytical methods that are appropriate
for ground-water sampling and that
accurately measure hazardous
constituents and other monitoring
parameters in ground-water samples.
Ground-water samples shall not be field-
filtered prior to laboratory analysis.
(c) The sampling procedures and
frequency must be protective of human
health and the environment.
(d) Ground-water elevations must be
measured in each well immediately prior
to purging, each time ground water is
sampled. The owner or operator must
determine the rate and direction of
ground-water flow each time ground
water is sampled. Ground-water
elevations in wells which monitor the
same waste management area must be
measured within a period of time short
enough to avoid temporal variations in
ground-water flow which could preclude
accurate determination of ground-water
flow rate and direction.
(e) The owner or operator must
establish background ground-water
quality in a hydraulically upgradient or
background well(s) for each of the
monitoring parameters or constituents
required in the particular ground-water
monitoring program that applies to the
MSWLF unit, as determined under
§258.54(a), or
§258.55(a) of this Part. Background
ground-water quality may be established
at wells that are not located hydraulically
upgradient from the MSWLF unit if it
meets the requirements of §258.51(a)(l).
(f) The number of samples collected to
establish ground-water quality data must
be consistent with the appropriate
statistical procedures determined
pursuant to paragraph (g) of this section.
The sampling procedures shall be those
specified under §258.54(b) for detection
monitoring, §258.55(b) and (d) for
assessment monitoring, and §258.56(b) of
corrective action.
5.8.2 Applicability
The requirements for sampling and analysis
apply to all facilities required to conduct
ground-water monitoring throughout the
active life, closure, and post-closure periods
of operation. Quality assurance and quality
control measures for both field and
laboratory activities must be implemented.
The methods and procedures constituting
the program must be placed in the operating
record of the facility.
For the sampling and analysis program to be
technically sound, the sampling procedures
and analytical methods used should provide
adequate accuracy, precision, and detection
limits for the analyte determinations. Prior
to sampling, the static ground-water
elevations in the wells must be measured to
allow determination of the direction of
ground-water flow and estimates of rate of
flow. The time interval between
measurements at different wells must be
minimized so that temporal changes in
ground-water elevations do not cause an
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Ground-Water Monitoring and Corrective Action
incorrect determination of ground-water
flow direction.
Background ground-water quality must be
established at all upgradient or background
wells. The background water quality may
be determined from wells that are not
upgradient of the MSWLF unit, provided
that the wells yield representative ground-
water samples.
The sampling program must be designed in
consideration of the anticipated statistical
method applied by the owner or operator.
The data objectives of the monitoring
program, in terms of the number of samples
collected and the frequency of collection,
should be appropriate for the statistical
method selected for data comparison.
5.8.3 Technical Considerations
The purpose of a ground-water sampling
and analysis program is to establish a
protocol that can be followed throughout the
monitoring period of the site (operating,
closure, and post-closure). The protocol is
necessary so that data acquired can be
compared over time and accurately
represent ground-water quality. Sample
collection, preservation, shipment, storage,
and analyses should always be performed in
a consistent manner, even as monitoring
staff change during the monitoring period.
The owner's/operator's ground-water
monitoring program must include a
description of procedures for the following:
• Sample collection
• Sample preservation and shipment
• Analytical procedures
• Chain of custody control
• Quality assurance and quality control.
The ground-water monitoring program must
be documented in the operating record of
the facility.
The objectives of the monitoring program
should clearly define the quality of the data
required to detect significant changes in
ground-water chemistry due to the operation
of the solid waste disposal facility. These
data quality objectives should address:
• Accuracy and precision of methods used
in the analysis of samples, including
field measurements
• Quality control and quality assurance
procedures used to ensure the validity of
the results (e.g., use of blank samples,
record keeping, and data validation)
• Number of samples required to obtain a
certain degree of statistical confidence
of monitoring
• Location and number
wells required.
Sample Collection
Frequency
The frequency of sample collection under
detection monitoring should be evaluated
for each site according to hydrogeologic
conditions and landfill design. In States, the
minimum sampling frequency should be
semiannual. The background
characterization should include four
independent samples at each monitoring
location during the first semi-annual event
(i.e., during the first 6 months of
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Subpart E
monitoring). (See the discussion under
Section 5.10.3 on collecting independent
samples to determine background.) More
frequent sampling may be selected. For
example, quarterly sampling may be
conducted to evaluate seasonal effects on
ground-water quality.
The frequency of sample collection during
assessment monitoring activities will
depend on site-specific hydrogeologic
conditions and contaminant properties. The
frequency of sampling is intended to obtain
a data set that is statistically independent of
the previous set. Guidance to estimate this
minimum time to obtain independent
samples is provided in "Statistical Analysis
of Ground-water Monitoring Data at RCRA
Facilities - Interim Final Guidance"
(USEPA, 1989).
Water Level Measurements
The ground-water monitoring program must
include provisions for measuring static
water level elevations in each well prior to
purging the well for sampling.
Measurements of ground-water elevations
are used for determining horizontal and
vertical hydraulic gradients for estimation
of flow rates and direction.
Field measurements may include the
following:
• Depth to standing water from a surveyed
datum on the top of the well riser (static
water level)
• Total depth of well from the top of the
riser (to verify condition of well)
• Thickness of immiscible layers, if
present.
Measurements of the static water level and
the depth to the well bottom can be made
with a wetted steel tape. Electronic water
level measuring devices may also be used.
Accepted standard operating procedures call
for the static water level to be accurately
measured to within 0.01 foot (USEPA,
1992a). Water level measurements should
be made at all monitoring wells and well
clusters in a time frame that avoids changes
that may occur as a result of barometric
pressure changes, significant infiltration
events, or aquifer pumping. To prevent
possible cross contamination of wells, water
level measurement devices must be
decontaminated prior to use at each well.
The ground-water monitoring program
should include provisions for detecting
immiscible fluids (i.e., LNAPLs or
DNAPLs). LNAPLs are relatively
immiscible liquids that are less dense than
water and that spread across the water table
surface. DNAPLs are relatively immiscible
liquids that are more dense than the ground
water and tend to migrate vertically
downward in aquifers. The detection of an
immiscible layer may require specialized
equipment and should be performed before
the well is evacuated for conventional
sampling. The ground-water monitoring
program should specify how DNAPLs and
LNAPLs will be detected. The program
also should include a contingency plan
describing procedures for sampling and
analyzing these liquids. Guidance for
detecting the presence of immiscible layers
can be found in USEPA (1992a).
Well Purging
Because the water standing in a well prior to
sampling may not represent in-situ
ground-water quality, stagnant water should
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Ground-Water Monitoring and Corrective Action
be purged from the well and filter pack prior
to sampling. The QAPjP should include
detailed, step-by-step procedures for
purging wells, including the parameters that
will be monitored during purging and the
equipment that will be used for well
purging.
Purging should be accomplished by
removing ground water from the well at low
flow rates using a pump. The use of bailers
to purge monitoring wells generally should
be avoided. Research has shown that the
"plunger" effect created by continually
raising and lowering the bailer into the well
can result in continual development or
overdevelopment of the well. Moreover, the
velocities at which ground water enters a
bailer can actually correspond to
unacceptably high purging rates (Puls and
Powell, 1992; Barcelona et al., 1990).
The rate at which ground water is removed
from the well during purging ideally should
be approximately 0.2 to 0.3 L/min or less
(Puls and Powell, 1992; Puls et al., 1991;
Puls and Barcelona, 1989a; Barcelona, et
al., 1990). Wells should be purged at rates
below those used to develop the well to
prevent further development of the well, to
prevent damage to the well, and to avoid
disturbing accumulated corrosion or
reaction products in the well (Kearl et al.,
1992; Puls et al., 1990; Puls and Barcelona,
1989a; Puls and Barcelona, 1989b;
Barcelona, 1985b). Wells also should be
purged at or below their recovery rate so
that migration of water in the formation
above the well screen does not occur. A low
purge rate also will reduce the possibility of
stripping VOCs from the water, and will
reduce the likelihood of mobilizing colloids
in the subsurface that are immobile under
natural flow conditions. The owner/operator
should
ensure that purging does not cause
formation water to cascade down the sides
of the well screen. At no time should a well
be purged to dryness if recharge causes the
formation water to cascade down the sides
of the screen, as this will cause an
accelerated loss of volatiles. This problem
should be anticipated; water should be
purged from the well at a rate that does not
cause recharge water to be excessively
agitated. Laboratory experiments have
shown that unless cascading is prevented, up
to 70 percent of the volatiles present could
be lost before sampling.
To eliminate the need to dispose of large
volumes of purge water, and to reduce the
amount of time required for purging, wells
may be purged with the pump intake just
above or just within the screened interval.
This procedure eliminates the need to purge
the column of stagnant water located above
the well screen (Barcelona et al., 1985b;
Robin and Gillham, 1987; Barcelona,
1985b; Kearl et al., 1992). Purging the well
at the top of the well screen should ensure
that fresh water from the aquifer moves
through the well screen and upward within
the screened interval. Pumping rates below
the recharge capability of the aquifer must
be maintained if purging is performed with
the pump placed at the top of the well
screen, below the stagnant water column
above the top of the well screen (Kearl et
al., 1992). The Agency suggests that a
packer be placed above the screened interval
to ensure that "stagnant" casing water is not
drawn into the pump. The packer should be
kept inflated in the well until after ground-
water samples are collected.
In certain situations, purging must be
performed with the pump placed at, or
immediately below, the air/water interface.
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Subpart E
If a bailer must be used to sample the well,
the well should be purged by placing the
pump intake immediately below the
air/water interface. This will ensure that all
of the water in the casing and filter pack is
purged, and it will minimize the possibility
of mixing and/or sampling stagnant water
when the bailer is lowered down into the
well and subsequently retrieved (Keeley and
Boateng, 1987). Similarly, purging should
be performed at the air/water interface if
sampling is not performed immediately after
the well is purged without removing the
pump. Pumping at the air/water interface
will prevent the mixing of stagnant and
fresh water when the pump used to purge
the well is removed and then lowered back
down into the well for the purpose of
sampling.
In cases where an LNAPL has been detected
in the monitoring well, special procedures
should be used to purge the well. These
procedures are described in USEPA
(1992a).
For most wells, the Agency recommends
that purging continue until measurements of
turbidity, redox potential, and dissolved
oxygen in in-line or downhole analyses of
ground water have stabilized within
approximately 10% over at least two
measurements (Puls and Powell, 1992; Puls
and Eychaner, 1990; Puls et al., 1990; Puls
and Barcelona, 1989a; Puls and Barcelona,
1989b; USEPA, 1991; Barcelona et al.,
1988b). If a well is purged to dryness or is
purged such that full recovery exceeds two
hours, the well should be sampled as soon as
a sufficient volume of ground water has
entered the well to enable the collection of
the necessary ground-water samples.
All purging equipment that has been or will
be in contact with ground water should be
decontaminated prior to use. If the purged
water or the decontamination water is
contaminated (e.g., based on analytical
results), the water should be stored in
appropriate containers until analytical
results are available, at which time proper
arrangements for disposal or treatment
should be made (i.e., contaminated purge
water may be a hazardous waste).
Field Analyses
Several constituents or parameters that
owners or operators may choose to include
in a ground-water monitoring program may
be physically or chemically unstable and
should be tested after well purging and
before the collection of samples for
laboratory analysis. Examples of unstable
parameters include pH, redox (oxidation-
reduction) potential, dissolved oxygen,
temperature, and specific conductance.
Field analyses should not be performed on
samples designated for laboratory analysis.
Any field monitoring equipment or field-
test kits should be calibrated at the
beginning of each use, according to the
manufacturers' specifications and consistent
with methods in SW-846 (USEPA, 1986b).
Sample Withdrawal and Collection
The equipment used to withdraw a ground-
water sample from a well must be selected
based on consideration of the parameters to
be analyzed in the sample. To ensure the
sample is representative of ground water in
the formation, it is important to keep
physical or chemical alterations of the
sample to a minimum. USEPA (1992a)
provides an overview of the issues involved
in selecting ground-water sampling
equipment, and a summary of the
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Ground-Water Monitoring and Corrective Action
application and limitations of various
sampling mechanisms. Sampling materials
and equipment should be selected to
preserve sample integrity. Sampling
equipment should be constructed of inert
material. Sample collection equipment
should not alter analyte concentrations,
cause loss of analytes via sorption, or cause
gain of analytes via desorption, degradation,
or corrosion. Sampling equipment should
be designed such that Viton®, Tygon®,
silicone, or neoprene components do not
come into contact with the ground-water
sample. These materials have been
demonstrated to cause sorptive losses of
contaminants (Barcelona et al., 1983;
Barcelona et al., 1985b; Barcelona et al.,
1988b; Barcelona et al., 1990). Barcelona
(1988b) suggests that sorption of volatile
organic compounds on silicone,
polyethylene, and PVC tubing may result in
gross errors when determining
concentrations of trace organics in ground-
water samples. Barcelona (1985b)
discourages the use of PVC sampling
equipment when sampling for organic
contaminants. Fluorocarbon resin (e.g.,
Teflon®) or stainless steel sampling devices
which can be easily disassembled for
thorough decontamination are widely used.
Dedicating sampling equipment to each
monitoring well will help prevent cross-
contamination problems that could arise
from improper decontamination procedures.
Sampling equipment should cause minimal
sample agitation and should be selected to
reduce/eliminate sample contact with the
atmosphere during sample transfer.
Sampling equipment should not allow
volatilization or aeration of samples to the
extent that analyte concentrations are
altered.
Bladder pumps are generally recognized as
the best overall sampling device for both
organic and inorganic constituents, although
other types of pumps (e.g., low-rate
submersible centrifugal pumps, helical rotor
electric submersible pumps) have been
found suitable in some applications.
Bailers, although inexpensive and simple to
use, have been found to cause volatilization
of samples, mobilization of particulates in
wells and imprecise results (USEPA,
1992a).
The following recommendations apply to
the use and operation of ground-water
sampling equipment:
• Check valves should be designed and
inspected to ensure that fouling
problems do not reduce delivery
capabilities or result in aeration of
samples.
• Sampling equipment should never be
dropped into the well, as this will
cause degassing of the water upon
impact.
• Contents of the sampling device should
be transferred to sample containers in
a controlled manner that will minimize
sample agitation and aeration.
• Decontaminated sampling equipment
should not be allowed to come into
contact with the ground or other
contaminated surfaces prior to
insertion into the well.
• Ground-water samples should be
collected as soon as possible after the
well is purged. Water that has
remained in the well casing for more
than about 2 hours has had the
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Subpart E
opportunity to exchange gases with the
atmosphere and to interact with the
well casing material (USEPA, 1991b).
The rate at which a well is sampled
should not exceed the rate at which the
well was purged. Low sampling rates,
approximately 0.1 L/min, are
suggested. Low sampling rates will
help to ensure that particulates,
immobile in the subsurface under
ambient conditions, are not entrained
in the sample and that volatile
compounds are not stripped from the
sample (Puls and Barcelona, 1989b;
Barcelona, et al., 1990; Puls et al.,
1991; Kearl et al., 1992; USEPA,
1991b). Pumps should be operated at
rates less than 0.1 L/min when
collecting samples for volatile organics
analysis.
Pump lines should be cleared at a rate
of 0.1 L/min or less before collecting
samples for volatiles analysis so that
the samples collected will not be from
the period of time when the pump was
operating more rapidly.
Pumps should be operated in a
continuous manner so that they do not
produce samples that are aerated in the
return tube or upon discharge.
When sampling wells that contain
LNAPLs, a stilling tube should be
inserted in the well. Ground-water
samples should be collected from the
screened interval of the well below the
base of the tube.
Ground-water samples collected for
analysis for organic constituents or
parameters should not be filtered in the
field.
Once appropriate sampling equipment has
been selected and operating procedures
established, samples should be collected and
containerized in the order of the
volatilization sensitivity of the parameter.
The preferred collection order for some of
the more common ground-water analytes is
depicted on the flow chart shown in Figure
5-4.
The ground-water monitoring program
documentation should include explicit
procedures for disassembly and
decontamination of sampling equipment
before each use. Improperly
decontaminated equipment can affect
samples in several ways. For example,
residual contamination from the previous
well may remain on equipment, or improper
decontamination may not remove all of the
detergents or solvents used during
decontamination. Specific guidance
regarding decontamination of the sampling
equipment is available (USEPA 1992a). To
keep sample cross-contamination to a
minimum, sampling should proceed from
upgradient or background locations to
downgradient locations that would contain
higher concentrations of contaminants.
Sample Preservation and Handling
The procedures for preserving and handling
samples are nearly as important for ensuring
the integrity of the samples as the collection
device itself. Detailed procedures for
sample preservation must be provided in the
Quality Assurance Project Plan (QAPjP)
that is included in the sampling and analysis
program description.
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STEP
PROCEDURE
ESSENTIAL ELEMENTS
Well Inspection
Well Purging
Hydrotogic Measurements
I
Removal or Isolation of Stagnant Water
Water Level Measurements
Representative Water
Access
Sample Collection'
Field
Determinations*
Determination of Well-Purging Parameters
(pH, Eh, -n, Q )*
Volatile Organics, TOX
Dissolved Gases, TOC
Large Volume
Samples for
Organic Compound
Determinations
Verification of
Representative Water
Sample Access
Sample Collection by
Appropriate Mechanism
Minimal Sample Handling
Head-Space
Free Samples
Head Space
Free Samples
Minimal Aeration or
Depressurization
Metal Samples
Cyanides
Adequate Rinsing against
Contamination
Preservation
Field Blanks
Standards
Assorted Sensitive
Inorganic Species
Nm"; Fe(lt)
Major Cations and
Anions
Storage Transport
(as needed for good
QA/QC)
Minimal Air Contact,
Preservation
Minimal Loss of Sample
Integrity Prior to Analysis
Denotes analytical determinations which should be made in the field.
'This is a suggested order tor sampling, not all parameters are required by Part 258.
Figure 5-4
Generalized Flow Diagram of
Ground-Water Sampling Steps
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Subpart E
Sample Containers
To avoid altering sample quality, the
samples should be transferred from the
sampling equipment directly into a prepared
container. Proper sample containers for
each constituent or group of constituents are
identified in SW-846 (USEPA, 1986b).
Samples should never be composited in a
common container in the field and then
split. Sample containers should be cleaned
in a manner that is appropriate for the
constituents to be analyzed. Cleaning
procedures are provided by USEPA
(1986b). Sample containers that have been
cleaned according to these procedures can
be procured commercially.
Most vendors will provide a certification of
cleanliness.
Sample Preservation
During ground-water sampling, every
attempt should be made to minimize
changes in the chemistry of the samples. To
assist in maintaining the natural chemistry
of the samples, it is necessary to preserve
the sample. The owner or operator should
refer to SW-846 (USEPA, 1986b) for the
specific preservation method and holding
times for each constituent to be analyzed.
Methods of sample preservation are
relatively limited and are intended to retard
chemical reactions, such as oxidation,
retard, biodegradation, and to reduce the
effects of sorption. Preservation methods
are generally limited to pH control,
refrigeration, and protection from light.
Sample Storage and Shipment
The storage and transport of ground-water
samples must be performed in a manner that
maintains sample quality. Samples should
be cooled to 4°C as soon as possible after
they are collected. These conditions should
be maintained until the samples are received
at the laboratory. Sample containers
generally are packed in picnic coolers or
special containers for shipment.
Polystyrene foam, vermiculite, and "bubble
pack" are frequently used to pack sample
containers to prevent breakage. Ice is
placed in sealed plastic bags and added to
the cooler. All related paperwork is sealed
in a plastic bag and taped to the inside top of
the cooler. The cooler top is then taped
shut. Custody seals should be placed across
the hinges and latches on the outside of the
cooler.
Transportation arrangements should
maintain proper storage conditions and
provide for effective sample pickup and
delivery to the laboratory. Sampling plans
should be coordinated with the laboratory so
that appropriate sample receipt, storage,
analysis, and custody arrangements can be
provided.
Most analyses must be performed within a
specified period (holding time) from sample
collection. Holding time refers to the period
that begins when the sample is collected
from the well and ends with its extraction or
analysis. Data from samples not analyzed
within the recommended holding times
should be considered suspect. Some
holding times for Appendix I constituents
are as short as 7 days. To provide the
laboratory with operational flexibility in
meeting these holding times, samples
usually are shipped via overnight courier.
Laboratory capacity or operating hours may
influence sampling schedules. Coordination
with laboratory staff during
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Ground-Water Monitoring and Corrective Action
planning and sampling activities is
important in maintaining sample and
analysis quality.
The documentation that accompanies
samples during shipment to the laboratory
usually includes chain-of-custody (including
a listing of all sample containers), requested
analyses, and full identification of the origin
of samples (including contact names, phone
numbers, and addresses). Copies of all
documents shipped with the samples should
be retained by the sampler.
Chain-of-Custody Record
To document sample possession from the
time of collection, a chain-of-custody record
should be filled out to accompany every
sample shipment. The record should
contain the following types of information:
• Sample number
• Signature of collector
• Date and time of collection
• Media sampled (e.g., ground water)
• Sample type (e.g., grab)
• Identification of sampling location/well
• Number of containers
• Parameters requested for analysis
• Signatures of persons involved in the
chain of possession
• Inclusive dates of possession with time
in 24-hour notation
• Internal temperature of shipping
container when samples were sealed into
the container for shipping
• Internal temperature of container when
opened at the laboratory
• Any remarks regarding potential hazards
or other information the laboratory may
need.
An adequate chain-of-custody program
allows for tracing the possession and
handling of individual samples from the
time of collection through completion of
laboratory analysis. A chain-of-custody
program should include:
Sample labels to
misidentification of samples
prevent
• Sample custody seals to preserve the
integrity of the samples from the time
they are collected until they are opened
in the laboratory
• Field notes to record information about
each sample collected during the ground-
water monitoring program
• Chain-of-custody record to document
sample possession from the time of
collection to analysis
• Laboratory storage and analysis records,
which are maintained at the laboratory
and which record pertinent information
about the sample.
Sample Labels
Each sample's identification should be
marked clearly in waterproof ink on the
sample container. To aid in labeling, the
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information should be written on each
container prior to filling with a sample. The
labels should be sufficiently durable to
remain legible even when wet and should
contain the following information:
• Sample identification number
• Name and signature of the sampler
• Date and time of collection
• Sample location
• Analyses requested.
Sample Custody Seal
Sample custody seals should be placed on
the shipping container and/or individual
sample bottle in a manner that will break the
seal if the container or sample is tampered
with.
Field Logbook
To provide an account of all activities
involved in sample collection, all sampling
activities, measurements, and observations
should be noted in a field log. The
information should include visual
appearance (e.g., color, turbidity, degassing,
surface film), odor (type, strength), and
field measurements and calibration results.
Ambient conditions (temperature, humidity,
wind, precipitation) and well purging and
sampling activities should also be recorded
as an aid in evaluating sample analysis
results.
The field logbook should document the
following:
• Well identification
Well depth
Static water level depth and
measurement technique
Presence and thickness of immiscible
layers and the detection method
Well yield (high or low) and well
recovery after purging (slow, fast)
Well purging procedure and equipment
Purge volume and pumping rate
Time well purged
Collection method for immiscible
layers
Sample withdrawal procedure and
equipment
Date and time of sample collection
Results of field analysis
Well sampling sequence
Types of sample bottles used and
sample identification numbers
Preservatives used
Parameters requested for analysis
Field observations of sampling event
Name of collector
Weather conditions, including air
temperature
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• Internal temperature of field and
shipping containers.
Sample Analysis Request Sheet
A sample analysis request sheet should
accompany the sample(s) to the laboratory
and clearly identify which sample
containers have been designated for each
requested parameter and the preservation
methods used. The record should include
the following types of information:
• Name of person receiving the sample
• Laboratory sample number (if different
from field number)
• Date of sample receipt
• Analyses to be performed (including
desired analytical method)
• Information that may be useful to the
laboratory (e.g., type and quantity of
preservatives added, unusual conditions).
Laboratory Records
Once the sample has been received in the
laboratory, the sample custodian and/or
laboratory personnel should clearly
document the processing steps that are
applied to the sample. All sample
preparation (e.g., extraction) and
determinative steps should be identified in
the laboratory records. Deviations from
established methods or standard operating
procedures (SOPs), such as the use of
specific reagents (e.g., solvents, acids),
temperatures, reaction times, and instrument
settings, should be noted. The results of the
analyses of all quality control samples
should be identified for each batch of
ground-water samples analyzed. The
laboratory logbook should include the time,
date, and name of the person who performed
each processing step.
Analytical Procedures
The requirements of 40 CFR Part 258
include detection and assessment
monitoring activities. Under detection
monitoring, the constituents listed in 40
CFR Part 258, Appendix I are to be
analyzed for. This list includes volatile
organic compounds (VOCs) and selected
inorganic constituents. No specific
analytical methods are cited in the
regulations, but there is a requirement (40
CFR §258.53(h)(5)) that any practical
quantitation limit (PQL) used in subsequent
statistical analysis "be the lowest
concentration level that can be reliably
achieved within specified limits of precision
and accuracy during routine laboratory
operating conditions that are available to the
facility." Suggested test methods are listed
in Appendix II of Part 258 for informational
purposes only. Method 8240 (gas
chromatography with packed column; mass
spectrometry) and Method 8260 (gas
chromatography with capillary column;
mass spectrometry) are typical methods
used for all Appendix I VOCs. The
inorganic analyses can be performed using
inductively coupled plasma atomic emission
spectroscopy (ICP) Method 6010. These
methods, as well as other methods
appropriate to these analyses, are presented
in Tests Methods for Evaluating Solid
Waste, Physical/Chemical Methods,
SW-846 (USEPA, 1986), and are routinely
performed by numerous analytical testing
laboratories. These methods typically
provide PQLs in the 1 to 50 |ig/L range.
The ground-water monitoring plan must
specify the analytical method to be used.
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Evaluation and documentation of analytical
performance requires that quality control
samples be collected and analyzed along
with the ground-water monitoring samples.
Chapter One of SW-846 (Quality
Assurance) describes the types of quality
control samples necessary, as well as the
frequency at which they must be collected
and analyzed. In general, these quality
control samples may include trip blanks,
equipment rinsate samples, field duplicates,
method blanks, matrix spikes and
duplicates, and laboratory control samples.
Other mechanisms, including sample
holding times, surrogate constituents, and
standard additions, are also used to control
and document data quality. The
specification of and adherence to sample
holding times minimizes the sample
degradation that occurs over time.
Evaluating the recovery of surrogate
constituents spiked into organic samples
allows the analyst and data user to monitor
the efficiency of sample extraction and
analysis. The method of standard additions
is used to eliminate the effects of matrix
interferences in inorganic analyses.
Quality Assurance/Quality Control
One of the fundamental responsibilities of
the owner or operator is to establish a
continuing program to ensure the reliability
and validity of field and analytical
laboratory data gathered as part of the
overall ground-water monitoring program.
The owner or operator must explicitly
describe the QA/QC program that will be
used in the laboratory. Most owners or
operators will use commercial laboratories
to conduct analyses of ground-water
samples. In these cases, the owner or
operator is responsible for ensuring that the
laboratory of choice is exercising an
appropriate QA/QC program.
The owner or operator should provide for
the use of standards, laboratory blanks,
duplicates, and spiked samples for
calibration and identification of potential
matrix interferences, especially for metal
determinants. Refer to Chapter One of
SW-846 for guidance. The owner or
operator should use adequate statistical
procedures (e.g., QC charts) to monitor and
document performance and to implement an
effective program to resolve testing
problems (e.g., instrument maintenance,
operator training). Data from QC samples
(e.g., blanks, spiked samples) should be
used as a measure of performance or as an
indicator of potential sources of cross-
contamination, but should not be used by
the laboratory to alter or correct analytical
data. All laboratory QC data should be
submitted with the ground-water monitoring
sample results.
Field Quality Assurance/Quality Control
To verify the precision of field sampling
procedures, field QC samples, such as trip
blanks, equipment blanks, and duplicates,
should be collected. Additional volumes of
sample also should be collected for
laboratory QC samples.
All field QC samples should be prepared
exactly as regular investigation samples
with regard to sample volume, containers,
and preservation. The concentrations of any
contaminants found in blank samples should
not be used to correct the ground-water
data. The contaminant concentrations in
blanks should be documented, and if the
concentrations are more than an order of
magnitude greater than the field sample
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results, the owner/operator should resample
the ground water. The owner/operator
should prepare the QC samples as
recommended in Chapter One of SW-846
and at the frequency recommended by
Chapter One of SW-846 and should analyze
them for all of the required monitoring
parameters. Other QA/QC practices, such
as sampling equipment calibration,
equipment decontamination procedures, and
chain-of-custody procedures, are discussed
in other sections of this chapter and should
be described in the owner/operator's QAPjP.
Validation
The analytical data report provided by the
laboratory will present all data measured by
the laboratory but will not adjust those data
for field or laboratory quality control
indicators. This means that just because
data have been reported, they are not
necessarily an accurate representation of the
quality of the ground water. For example,
acetone and methylene chloride are often
used in laboratories as cleaning and
extraction solvents and, consequently, are
often laboratory contaminants, transmitted
through the ambient air into samples.
Method blanks are analyzed to evaluate the
extent of laboratory contamination.
Constituents found as contaminants in the
method blanks are "flagged" in the sample
data. The sample data are not, however,
adjusted for the contaminant concentration.
Other kinds of samples are analyzed to
assess other data quality indicators. Trip
blanks are used to assess contamination by
volatile organic constituents during sample
shipment and storage. Matrix spike/matrix
spike duplicate sample pairs are used to
evaluate analytical bias and precision.
Equipment rinsate samples are used to
assess the efficacy of sampling equipment
decontamination procedures. The data
validation process uses the results from all
of these QC samples to determine if the
reported analytical data accurately describe
the samples. All reported data must be
evaluated — a reported value of "non-detect"
is a quantitative report just like a numerical
value and must be validated.
The data validation process must also
consider the presence and quality of other
kinds of data used to ensure data quality
(e.g., calibration frequency and descriptors,
matrix specific detection limits). All of the
criteria for data quality are described in the
quality assurance project plan (QAPjP) or
sampling and analysis plan (SAP). These
documents may reference criteria from some
other source, (e.g., the USEPA Contract
Laboratory Program). The performance
criteria must be correctly specified and must
be used for data validation. It is a waste of
time and money to evaluate data against
standards other than those used to generate
them. Several documents are available to
assist the reviewer in validation of data by
different criteria (i.e., Chapter One of Test
Methods for Evaluating Solid Waste,
Physical/Chemical Methods, USEPA CLP
Functional Guidelines for Evaluating
Organics Analyses, USEPA CLP Functional
Guidelines for Evaluating Pesticides/PCBs
Analyses, etc.).
In addition to specific data that describe
data quality, the validator may consider
other information that may have an impact
on the end-use of the data, such as
background concentrations of the
constituent in the environment. In any
event, the QAPjP or SAP also should
describe the validation procedures that will
be used. The result of
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this validation should be the classification
of data as acceptable or unacceptable for the
purposes of the project. In some cases, data
may be further qualified, based either on
insufficient data or marginal performance
(i.e., qualitative uses only, estimated
concentration, etc.).
Documentation
The ground-water monitoring program
required by §258.50 through §258.55 relies
on documentation to demonstrate
compliance. The operating record of the
MSWLF should include a complete
description of the program as well as
periodic implementation reports.
At a minimum, the following aspects of the
ground-water monitoring program should be
described or included in the operating
record:
• The Sampling and Analysis plan that
details sample parameters, sampling
frequency, sample collection,
preservation, and analytical methods to
be used, shipping procedures, and chain-
of-custody procedures;
• The Quality Assurance Project Plan
(QAPjP) and Data Quality Objectives
(DQOs);
• The locations of monitoring wells;
• The design, installation, development,
and decommission of monitoring wells,
piezometers, and other measurement,
sampling, and analytical devices;
• Site hydrogeology;
Statistical methods to be used to evaluate
ground-water monitoring data and
demonstrate compliance with the
performance standard;
Approved demonstration that monitoring
requirements are suspended (if
applicable);
Boring logs;
Piezometer and well construction logs
for the ground-water monitoring system.
5.9 STATISTICAL ANALYSIS
40 CFR §258.53 (g)-(i)
5.9.1 Statement of Regulation
(g) The owner or operator must specify
in the operating record one of the
following statistical methods to be used in
evaluating ground-water monitoring data
for each hazardous constituent. The
statistical test chosen shall be conducted
separately for each hazardous constituent
in each well.
(1) A parametric analysis of variance
(ANOVA) followed by multiple
comparisons procedures to identify
statistically significant evidence of
contamination. The method must include
estimation and testing of the contrasts
between each compliance well's mean and
the background mean levels for each
constituent.
(2) An analysis of variance (ANOVA)
based on ranks followed by multiple
comparisons procedures to identify
statistically significant evidence of
contamination. The method must include
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estimation and testing of the contrasts
between each compliance well's median
and the background median levels for
each constituent.
(3) A tolerance or prediction interval
procedure in which an interval for each
constituent is established from the
distribution of the background data, and
the level of each constituent in each
compliance well is compared to the upper
tolerance or prediction limit.
(4) A control chart approach that gives
control limits for each constituent.
(5) Another statistical test method that
meets the performance standards of
§258.53(h). The owner or operator must
place a justification for this alternative in
the operating record and notify the State
Director of the use of this alternative test.
The justification must demonstrate that
the alternative method meets the
performance standards of §258.53(h).
(h) Any statistical method chosen under
§258.53(g) shall comply with the
following performance standards, as
appropriate:
(1) The statistical method used to
evaluate ground-water monitoring data
shall be appropriate for the distribution
of chemical parameters or hazardous
constituents. If the distribution of the
chemical parameters or hazardous
constituents is shown by the owner or
operator to be inappropriate for a normal
theory test, then the data should be
transformed or a distribution-free theory
test should be used. If the distributions
for the constituents differ, more than one
statistical method may be needed.
(2) If an individual well comparison
procedure is used to compare an
individual compliance well constituent
concentration with background
constituent concentrations or a ground-
water protection standard, the test shall
be done at a Type I error level of no less
than 0.01 for each testing period. If a
multiple comparisons procedure is used,
the Type I experiment wise error rate for
each testing period shall be no less than
0.05; however, the Type I error of no less
than 0.01 for individual well comparisons
must be maintained. This performance
standard does not apply to tolerance
intervals, prediction intervals, or control
charts.
(3) If a control chart approach is used to
evaluate ground-water monitoring data,
the specific type of control chart and its
associated parameter values shall be
protective of human health and the
environment. The parameters shall be
determined after considering the number
of samples in the background data base,
the data distribution, and the range of the
concentration values for each constituent
of concern.
(4) If a tolerance interval or a
predictional interval is used to evaluate
ground-water monitoring data, the levels
of confidence and, for tolerance intervals,
the percentage of the population that the
interval must contain, shall be protective
of human health and the environment.
These parameters shall be determined
after considering the number of samples
in the background data base, the data
distribution, and the range of the
concentration values for each constituent
of concern.
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(5) The statistical method shall account
for data below the limit of detection with
one or more statistical procedures that
are protective of human health and the
environment. Any practical quantitation
limit (PQL) that is used in the statistical
method shall be the lowest concentration
level that can be reliably achieved within
specified limits of precision and accuracy
during routine laboratory operating
conditions that are available to the
facility.
(6) If necessary, the statistical method
shall include procedures to control or
correct for seasonal and spatial
variability as well as temporal correlation
in the data.
(i) The owner or operator must
determine whether or not there is a
statistically significant increase over
background values for each parameter or
constituent required in the particular
ground-water monitoring program that
applies to the MSWLF unit, as
determined under §§258.54(a) or
258.55(a) of this part.
(1) In determining whether a
statistically significant increase has
occurred, the owner or operator must
compare the ground-water quality of
each parameter or constituent at each
monitoring well designated pursuant to
§258.51(a)(2) to the background value of
that constituent, according to the
statistical procedures and performance
standards specified under paragraphs (g)
and (h) of this section.
(2) Within a reasonable period of time
after completing sampling and analysis,
the owner or operator must determine
whether there has been a statistically
significant increase over background at
each monitoring well.
5.9.2 Applicability
The statistical analysis requirements are
applicable to all existing units, new units,
and lateral expansions of existing units for
which ground-water monitoring is required.
The use of statistical procedures to evaluate
monitoring data shall be used for the
duration of the monitoring program,
including the post-closure care period.
The owner or operator must indicate in the
operating record the statistical method that
will be used in the analysis of ground-water
monitoring results. The data objectives of
the monitoring, in terms of the number of
samples collected and the frequency of
collection, must be consistent with the
statistical method selected.
Several options for analysis of ground-water
data are provided in the criteria. Other
methods may be used if they can be shown
to meet the performance standards. The
approved methods include both parametric
and nonparametric procedures, which differ
primarily in constraints placed by the
statistical distribution of the data. Control
chart, tolerance interval, and prediction
interval approaches also may be applied.
The owner or operator must conduct the
statistical comparisons between upgradient
and downgradient wells after completion of
each sampling event and receipt of validated
data. The statistical procedure must
conform to the performance standard of a
Type I error level of no less than 0.01 for
inter-well comparisons. Control chart,
tolerance interval, and prediction interval
approaches must incorporate decision values
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that are protective of human health and the
environment. Generally, this is meant to
include a significance level of a least 0.05.
Procedures to treat data below analytical
method detection levels and seasonality
effects must be part of the statistical
analysis.
5.9.3 Technical Considerations
The MSWLF rule requires facilities to
evaluate ground-water monitoring data
using a statistical method provided in
§258.53(g) that meets the performance
standard of §258.53(h). Section 258.53(g)
contains a provision allowing for the use of
an alternative statistical method as long as
the performance standards of §258.53(h) are
met.
The requirements of §258.53(g) specify that
one of five possible statistical methods be
used for evaluating ground-water
monitoring data. One method should be
specified for each constituent. Although
different methods may be selected for each
constituent at new facilities, use of a method
must be substantiated by demonstrating that
the distribution of data obtained on that
constituent is appropriate for that method
(§258.53(h)). Selection of a specific
method is described in Statistical Analysis
of Ground- Water Monitoring Data at RCRA
Facilities - Interim Final Guidance"
(USEPA, 1989) and in Statistical Analysis
of Ground- Water Monitoring Data at RCRA
Facilities - Addendum to Interim Final
Guidance (USEPA, 1992b). EPA also
offers software, entitled User
Documentation of the Ground-Water
Information Tracking System (GRITS) with
Statistical Analysis Capability, GRITSTAT
Version 4.2. In addition to the statistical
guidance provided by EPA, the following
references may be
useful for selecting other methods (Dixon
and Massey, 1969; Gibbons, 1976;
Aitchison and Brown, 1969; and Gilbert,
1987). The statistical methods that may be
used in evaluating ground-water monitoring
data include the following:
• Parametric analysis of variance
(ANOVA) with multiple comparisons
• Rank-based (nonparametric) ANOVA
with multiple comparisons
• Tolerance interval or prediction interval
• Control chart
• An alternative statistical method (e.g.,
CABF t-test or confidence intervals).
If an alternative method is used, then the
State Director must be notified, and a
justification for its use must be placed in the
operating record.
The statistical analysis methods chosen must
meet performance standards specified under
§258.53(h), which include the following:
1) The method must be appropriate for the
observed distribution of the data
2) Individual well comparisons to
background ground-water quality or a
ground-water protection standard shall
be done at a Type I error level of no less
than 0.01 or, if the multiple comparisons
procedure is used, the experiment-wise
error rate for each testing period shall be
no less than 0.05
3) If a control chart is used, the type of
chart and associated parameter values
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Subpart E
shall be protective of human health and
the environment
4) The level of confidence and percentage
of the population contained in an interval
shall be protective of human health and
the environment
5) The method must account for data below
the limit of detection (less than the PQL)
in a manner that is protective of human
health and the environment
6) The method must account for seasonal
and spatial variability and temporal
correlation of the data, if necessary.
These statistical analysis methods shall be
used to determine whether a significant
increase over background values has
occurred. Monitoring data must be
statistically analyzed after validated results
from each sampling and analysis event are
received.
The statistical performance standards
provide a means to limit the possibility of
making false conclusions from the
monitoring data. The specified error level
of 0.01 for individual well comparisons for
probability of Type I error (indication of
contamination when it is not present or false
positive) essentially means that the analysis
is predicting with 99-percent confidence
that no significant increase in contaminant
levels is evident when in fact no increase is
present. Non-detect results must be treated
in an appropriate manner or their influence
on the statistical method may invalidate the
statistical conclusion. Non-detect results
are discussed in greater detail later in this
section.
Multiple Well Comparisons
If more than two wells (background and
downgradient combined) are screened in the
same stratigraphic unit, then the appropriate
statistical comparison method is a multiple
well comparison using the ANOVA
procedure. The parametric ANOVA
procedure assumes that the data from each
well group come from the same type (e.g.,
Normal) of distribution with possibly
different mean concentrations. The
ANOVA tests for a difference in means. If
there are multiple background wells, one
should consider the possibility of trying to
pool these background data into one group.
Such an increase in sample size often allows
for more accurate statistical comparisons,
primarily because better information is
known about the background concentrations
as a whole. Downgradient wells should not
be pooled, as stated in the regulations.
Ground-water monitoring data tend to
follow a log normal distribution (USEPA,
1989), and usually need to be transformed
prior to applying a parametric ANOVA
procedure. By conducting a log
transformation, ground-water monitoring
data will generally be converted to a normal
distribution. By applying a Shapiro-Wilk
test, probability plots, or other normality
tests on the residuals (errors) from the
ANOVA procedure, the normality of the
transformed data can be determined. In
addition, data variance for each well in the
comparison must be approximately
equivalent; this condition can be checked
using Levene's or Bartlett's test. These tests
are provided in USEPA (1992b) and
USEPA (1989).
If the transformed data do not conform to
the normality assumption, a nonparametric
ANOVA procedure may be used. The
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nonparametric statistical procedures do not
depend as much on the mathematical
properties of a specified distribution. The
nonparametric equivalent to the parametric
ANOVA is the Kruskal-Wallis test, which
analyzes variability of the average ranks of
the data instead of the measurements
themselves.
If the data display seasonality (regular,
periodic, and time-dependent increases or
decreases in parameter values), a two-way
ANOVA procedure should be used. If the
seasonality can be corrected, a one-way
ANOVA procedure may still be appropriate.
Methods to treat seasonality are described in
USEPA(1989).
ANOVA procedures attempt to determine
whether different wells have significantly
different average concentrations of
constituents. If a difference is indicated, the
ANOVA test is followed by a multiple
comparisons procedure to investigate which
specific wells are different among those
tested. The overall experiment-wise
significance level of the ANOVA must be
kept to a minimum of 0.05, while the
minimum significance level of each
individual comparison must be set at 0.01.
USEPA (1992b) provides alternative
methods that can be used when the number
of individual contrasts to be tested is very
high.
Tolerance and Prediction Intervals
Two types of statistical intervals are often
constructed from data: tolerance intervals
and prediction intervals. A comprehensive
discussion of these intervals is provided in
USEPA 1992b. Though often confused, the
interpretations and uses of these intervals
are quite distinct. A tolerance interval is
designed to contain a designated proportion
of the population (e.g., 95 percent of all
possible sample measurements). Because
the interval is constructed from sample data,
it also is a random interval. And because of
sampling fluctuations, a tolerance interval
can contain the specified proportion of the
population only with a certain confidence
level.
Tolerance intervals are very useful for
ground-water data analysis because in many
situations one wants to ensure that at most a
small fraction of the compliance well
sample measurements exceed a specific
concentration level (chosen to be protective
of human health and the environment).
Prediction intervals are constructed to
contain the next sample value(s) from a
population or distribution with a specified
probability. That is, after sampling a
background well for some time and
measuring the concentration of an analyte,
the data can be used to construct an interval
that will contain the next analyte sample or
samples (assuming the distribution has not
changed). Therefore, a prediction interval
will contain a future value or values with
specified probability. Prediction intervals
can also be constructed to contain the
average of several future observations.
In summary, a tolerance interval contains a
proportion of the population, and a
prediction interval contains one or more
future observations. Each has a probability
statement or "confidence coefficient"
associated with it. It should be noted that
these intervals assume that the sample data
used to construct the intervals are normally
distributed.
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Individual Well Comparisons
When only two wells (e.g., a single
background and a single compliance point
well) are being compared, owners or
operators should not perform the parametric
or nonparametric ANOVA. Instead, a
parametric t-test, such as Cochran's
Approximation to the Behrens-Fisher
Students' t-test, or a nonparametric test
should be performed. When a single
compliance well group is being compared to
background data and a nonparametric test is
needed, the Wilcoxin Rank-Sum test should
be performed. These tests are discussed in
more detail in standard statistical references
andinUSEPA(1992b).
Intra-Well Comparisons
Intra-well comparisons, where data of one
well are evaluated over time, are useful in
evaluating trends in individual wells and for
identifying seasonal effects in the data. The
intra-well comparison methods do not
compare background data to compliance
data. Where some existing facilities may
not have valid background data, however,
intra-well comparisons may represent the
only valid comparison available. In the
absence of a true background well, several
monitoring events may be required to
determine trends and seasonal fluctuations
in ground-water quality.
Control charts may be used for intra-well
comparisons but are only appropriate for
uncontaminated wells. If a well is
intercepting a release, then it is already in
an "out-of-control" state, which violates the
principal assumption underlying control
chart procedures. Time series analysis (i.e.,
plotting concentrations over time) is
extremely useful for identifying trends in
monitoring data. Such data may be adjusted
for seasonal effects to aid in assessing the
degree of change over time. Guidance for
and limitations of intra-well comparison
techniques are provided in USEPA (1989)
andUSEPA(1992b).
Treatment of Non-Detects
The treatment of data below the detection
limit of the analytical method (non-detects)
used depends on the number or percentage
of non-detects and the statistical method
employed. Guidance on how to treat non-
detects is provided in USEPA (1992b).
5.10 DETECTION MONITORING
PROGRAM
40 CFR §258.54
5.10.1 Statement of Regulation
(a) Detection monitoring is required at
MSWLF units at all ground-water
monitoring wells defined under
§§258.51(a)(l) and (a)(2) of this part. At
a minimum, a detection monitoring
program must include the monitoring for
the constituents listed in Appendix I of
this part.
1) The Director of an approved State
may delete any of the Appendix I
monitoring parameters for a MSWLF
unit if it can be shown that the
removed constituents are not
reasonably expected to be in or
derived from the waste contained in
the unit.
2) The Director of an approved State
may establish an alternative list of
inorganic indicator parameters for a
MSWLF unit, in lieu of some or all of
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Ground-Water Monitoring and Corrective Action
the heavy metals (constituents 1-15 in
Appendix I), if the alternative
parameters provide a reliable
indication of inorganic releases from
the MSWLF unit to the ground water.
In determining alternative
parameters, the Director shall
consider the following factors:
(i) The types, quantities, and
concentrations of constituents in
wastes managed at the MSWLF unit;
(ii) The mobility, stability, and
persistence of waste constituents or
their reaction products in the
unsaturated zone beneath the
MSWLF unit;
(iii) The detectability of indicator
parameters, waste constituents, and
reaction products in the ground
water; and
(iv) The concentration or values and
coefficients of variation of
monitoring parameters or
constituents in the background
ground-water.
(b) The monitoring frequency for all
constituents listed in Appendix I, or the
alternative list approved in accordance
with paragraph (a)(2), shall be at least
semiannual during the active life of the
facility (including closure) and the post-
closure period. A minimum of four
independent samples from each well
(background and downgradient) must be
collected and analyzed for the Appendix
I constituents, or the alternative list
approved in accordance with paragraph
(a)(2), during the first semiannual
sampling event. At least one sample from
each well(background and downgradient)
must be collected and analyzed during
subsequent semiannual sampling events.
The Director of an approved State may
specify an appropriate alternative
frequency for repeated sampling and
analysis for Appendix I constituents, or
the alternative list approved in
accordance with paragraph (a)(2), during
the active life (including closure) and the
post-closure care period. The alternative
frequency during the active life
(including closure) shall be no less than
annual. The alternative frequency shall
be based on consideration of the following
factors:
1) Lithology of the aquifer and
unsaturated zone;
2) Hydraulic conductivity of the aquifer
and unsaturated zone;
3) Ground-water flow rates;
4) Minimum distance between
upgradient edge of the MSWLF unit
and downgradient monitoring well
screen (minimum distance of travel);
and
5) Resource value of the aquifer.
(c) If the owner or operator determines,
pursuant to §258.53(g) of this part, that
there is a statistically significant increase
over background for one or more of the
constituents listed in Appendix I or the
alternative list approved in accordance
with paragraph (a)(2), at any monitoring
well at the boundary specified under
§258.51(a)(2), the owner or operator:
(1) Must, within 14 days of this finding,
place a notice in the operating record
indicating which constituents have shown
statistically significant changes from
275
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Subpart E
background levels, and notify the State
Director that this notice was placed in the
operating record; and
(2) Must establish an assessment
monitoring program meeting the
requirements of §258.55 of this part
within 90 days, except as provided for in
paragraph (3) below.
(3) The owner/operator may
demonstrate that a source other than a
MSWLF unit caused the contamination
or that the statistically significant
increase resulted from error in sampling,
analysis, statistical evaluation, or natural
variation in ground-water quality. A
report documenting this demonstration
must be certified by a qualified ground-
water scientist or approved by the
Director of an approved State and be
placed in the operating record. If a
successful demonstration is made and
documented, the owner or operator may
continue detection monitoring as
specified in this section. If after 90 days,
a successful demonstration is not made,
the owner or operator must initiate an
assessment monitoring program as
required in §258.55.
5.10.2 Applicability
Except for the small landfill exemption and
the no migration demonstration, detection
monitoring is required at existing MSWLF
units, lateral expansions of units, and new
MSWLF units. Monitoring must occur at
least semiannually at both background wells
and downgradient well locations. The
Director of an approved State may specify
an alternative sampling frequency.
Monitoring parameters must include all
Appendix I constituents unless an
alternative
list has been established by the Director of
an approved State.
During the first semiannual monitoring
event, the owner or operator must collect at
least four independent ground-water
samples from each well and analyze the
samples for all constituents in the Appendix
I or alternative list. Each subsequent
semiannual event must include, at a
minimum, the collection and analysis of one
sample from all wells. The monitoring
requirement continues throughout the active
life of the landfill and the post-closure care
period.
If an owner or operator determines that a
statistically significant increase over
background has occurred for one or more
Appendix I constituents (or constituents on
an alternative list), a notice must be placed
in the facility operating record (see Table 5-
2). The owner or operator must notify the
State Director within 14 days of the finding.
Within 90 days, the owner or operator must
establish an assessment monitoring program
conforming to the requirements of §258.55.
If evidence exists that a statistically
significant increase is due to factors
unrelated to the unit, the owner or operator
may make a demonstration to this effect to
the Director of an approved State or place a
certified demonstration in the operating
record. The potential reasons for an
apparent statistical increase may include:
• A contaminant source other than the
landfill unit
• A natural variation in ground-water
quality
• An analytical error
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Ground-Water Monitoring and Corrective Action
• A statistical error
• A sampling error.
The demonstration that one of these reasons
is responsible for the statistically significant
increase over background must be certified
by a qualified ground-water scientist or
approved by the Director of an approved
State. If a successful demonstration is made
and documented, the owner or operator may
continue detection monitoring.
If a successful demonstration is not made
within 90 days, the owner or operator must
initiate an assessment monitoring program.
A flow chart for a detection monitoring
program in a State whose program has not
been approved by EPA is provided in Figure
5-5.
5.10.3 Technical Considerations
If there is a statistically significant increase
over background during detection
monitoring for one or more constituents
listed in Appendix I of Part 258 (or an
alternative list of parameters in an approved
State), the owner or operator is required to
begin assessment monitoring. The
requirement to conduct assessment
monitoring will not change, even if the
Director of an approved State allows the
monitoring of geochemical parameters in
lieu of some or all of the metals listed in
Appendix I. If an owner or operator
suspects that a statistically significant
increase in a geochemical parameter is
caused by natural variation in ground-water
quality or a source other than a MSWLF
unit, a demonstration to this effect must be
documented in a report to avoid proceeding
to assessment monitoring.
Independent Sampling for Background
The ground-water monitoring requirements
specify that four independent samples be
collected from each well to establish
background during the first semiannual
monitoring event. This is because almost all
statistical procedures are based on the
assumption that samples are independent of
each other. In other words, independent
samples more accurately reflect the true
range of natural variability in the ground
water, and statistical analyses based on
independent samples are more accurate.
Replicate samples, whether field replicates
or lab splits, are not statistically
independent measurements.
It may be necessary to gather the
independent samples over a range of time
sufficient to account for seasonal
differences. If seasonal differences are not
taken into account, the chance for false
positives increases (monitoring results
indicate a release, when a release has not
occurred). The sampling interval chosen
must ensure that sampling is being done on
different volumes of ground water. To
determine the appropriate interval between
sample collection events that will ensure
independence, the owner or operator can
determine the site's effective porosity,
hydraulic conductivity, and hydraulic
gradient and use this information to
calculate ground-water velocity (USEPA,
1989). Knowing the velocity of the ground
water should enable an owner/operator to
establish an interval that ensures the four
samples are being collected from four
different volumes of water. For additional
information on establishing sampling
interval, see Statistical Analysis of
Groundwater Monitoring Data at RCRA
Til
-------
Semiannual Monitoring for all Appendix I
• First semiannual monitoring-
Four independent samples from each well
(background and downgradient)
• Subsequent semiannual monitoring-
One sample from each well (background
and downgradient)
Subsequent significant
increase over background
for one or more Appendix
1 constituents?
Continue
semiannual
monitoring
YES
Within 14 days notify State director that
notice placed in record
Within 90 days establish assessment
monitoring program
May demonstrate other source responsible
or an error in sampling/analysis/statistics
Figure 5-5. Detection Monitoring Program
278
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Ground-Water Monitoring and Corrective Action
Facilities - Interim Final Guidance,
(USEPA, 1989).
Alternative List/Removal of Parameters
An alternative list of Appendix I
constituents may be allowed by the Director
of an approved State. The alternative list
may use geochemical parameters, such as
pH and specific conductance, in place of
some or all of the metals (Parameters 1
through 15) in Appendix I. These
alternative parameters must provide a
reliable indication of inorganic releases
from the MSWLF unit to ground water. The
option of establishing an alternative list
applies only to Parameters 1 through 15 of
Appendix I. The list of ground-water
monitoring parameters must include all of
the volatile organic compounds (Appendix
I, Parameters 16 through 62).
A potential problem in substituting
geochemical parameters for metals on the
alternative list is that many of the
geochemical parameters are naturally
occurring. However, these parameters have
been used to indicate releases from MSWLF
units. Using alternative geochemical
parameters is reasonable in cases where
natural background levels are not high
enough to mask the detection of a release
from a MSWLF unit. The decision to use
alternative parameters also should consider
natural spatial and temporal variability in
the geochemical parameters.
The types, quantities, and concentrations of
wastes managed at the MSWLF unit play an
important role in determining whether
removal of parameters from Appendix I is
appropriate. If an owner or operator has
definite knowledge of the nature of wastes
accepted at the facility, then removal of
constituents from Appendix I may be
acceptable. Usually, a waste would have to
be homogeneous to allow for this kind of
determination. The owner or operator may
submit a demonstration that documents the
presence or absence of certain constituents
in the waste. The owner or operator also
would have to demonstrate that constituents
proposed for deletion from Appendix I are
not degradation or reaction products of
constituents potentially present in the waste.
Alternative Frequency
In approved States, 40 CFR §258.54(b)
allows the Director to specify an alternative
frequency for ground-water monitoring.
The alternative frequency is applicable
during the active life, including the closure
and the post-closure periods. The
alternative frequency can be no less than
annual.
The need to vary monitoring frequency must
be evaluated on a site-specific basis. For
example, for MSWLF units located in areas
with low ground-water flow rates, it may be
acceptable to monitor ground water less
frequently. The sampling frequency chosen
must be sufficient to protect human health
and the environment. Depending on the
ground-water flow rate and the resource
value of the aquifer, less frequent
monitoring may be allowable or more
frequent monitoring may be necessary. An
approved State may specify an alternative
frequency for repeated sampling and
analysis of Appendix I constituents based on
the following factors:
1) Lithology of the aquifer and the
unsaturated zone
279
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Subpart E
2) Hydraulic conductivity of the aquifer
and the unsaturated zone
3) Ground-water flow rates
4) Minimum distance between the
upgradient edge of the MSWLF unit and
the downgradient well screen
5) The resource value of the aquifer.
Approved States also can set alternative
frequencies for monitoring during the post-
closure care period based on the same
factors.
Notification
The notification requirement under 40 CFR
§258.54(c) requires an owner or operator to
1) place a notice in the operating record that
indicates which constituents have shown
statistically significant increases and 2)
notify the State Director that the notice was
placed in the operating record. The
constituents can be from either Appendix I
or from an alternative list.
Demonstrations of Other Reasons
For Statistical Increase
An owner or operator is allowed 90 days to
demonstrate that the statistically significant
increase of a contaminant/constituent was
caused by statistical, sampling, or analytical
errors or by a source other than the landfill
unit. The demonstration allowed in
§258.54(c)(3) may include:
1) A demonstration that the increase
resulted from another contaminant
source
2) A comprehensive audit of sampling,
laboratory, and data evaluation
procedures
3) Resampling and analysis to verify the
presence and concentration of the
constituents for which the increase was
reported.
A demonstration that the increase in
constituent concentration is the result of a
source other than the MSWLF unit should
document that:
• An alternative source exists.
• Hydraulic connection exists between the
alternative source and the well with the
significant increase.
• Constituent(s) (or precursor constituents)
are present at the alternative source or
along the flow path from the alternative
source prior to possible release from the
MSWLF unit.
• The relative concentration and
distribution of constituents in the zone of
contamination are more strongly linked
to the alternative source than to the
MSWLF unit when the fate and transport
characteristics of the constituents are
considered.
• The concentration observed in ground
water could not have resulted from the
MSWLF unit given the waste
constituents and concentrations in the
MSWLF unit leachate and wastes, and
site hydrogeologic conditions.
• The data supporting conclusions
regarding the alternative source are
historically consistent with
hydrogeologic
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Ground-Water Monitoring and Corrective Action
conditions and findings of the
monitoring program.
The demonstration must be documented,
certified by a qualified ground-water
scientist, and placed in the operating record
of the facility.
Demonstrations of Other Sources of
Error
A successful demonstration that the
statistically significant change is the result
of an error in sampling, analysis, or data
evaluation may include the following:
• Clear indication of a transcription or
calculation error
• Clear indication of a systematic error in
analysis or data reduction
• Resampling, analysis, and evaluation of
results
• Corrective measures to prevent the
recurrence of the error and incorporation
of these measures into the ground-water
monitoring program.
If resampling is necessary, the sample(s)
taken must be independent of the previous
sample. More than one sample may be
required to substantiate the contention that
the original sample was not representative
of the ground-water quality in the affected
well(s).
5.11 ASSESSMENT MONITORING
PROGRAM
40 CFR §258.55(a)-(f)
5.11.1 Statement of Regulation
(a) Assessment monitoring is required
whenever a statistically significant
increase over background has been
detected for one or more of the
constituents listed in Appendix I or in the
alternate list approved in accordance
with § 258.54(a)(2).
(b) Within 90 days of triggering an
assessment monitoring program, and
annually thereafter, the owner or
operator must sample and analyze the
ground water for all constituents
identified in Appendix II of this part. A
minimum of one sample from each
downgradient well must be collected and
analyzed during each sampling event.
For any new constituent detected in the
downgradient wells as a result of the
complete Appendix II analysis, a
minimum of four independent samples
from each well (background and
downgradient) must be collected and
analyzed to establish background for the
new constituents. The Director of an
approved State may specify an
appropriate subset of wells to be sampled
and analyzed for Appendix II
constituents during assessment
monitoring. The Director of an approved
State may delete any of the Appendix II
monitoring parameters for a MSWLF
unit if it can be shown that the removed
constituents are not reasonably expected
to be contained in or derived from the
waste contained in the unit.
281
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Subpart E
(c) The Director of an approved State
may specify an appropriate alternate
frequency for repeated sampling and
analysis for the full set of Appendix II
constituents required by §258.55(b) of
this part, during the active life (including
closure) and post-closure care of the unit
considering the following factors:
(1) Lithology of the aquifer and
unsaturated zone;
(2) Hydraulic conductivity of the
aquifer and unsaturated zone;
(3) Ground-water flow rates;
(4) Minimum distance between
upgradient edge of the MSWLF unit and
downgradient monitoring well screen
(minimum distance of travel);
(5) Resource value of the aquifer; and
(6) Nature (fate and transport) of any
constituents detected in response to this
section.
(d) After obtaining the results from the
initial or subsequent sampling events
required in paragraph (b) of this section,
the owner or operator must:
(1) Within 14 days, place a notice in the
operating record identifying the
Appendix II constituents that have been
detected and notify the State Director
that this notice has been placed in the
operating record;
(2) Within 90 days, and on at least a
semiannual basis thereafter, resample all
wells specified by § 258.51(a), conduct
analyses for all constituents in Appendix
I to this Part or in the alternative list
approved in accordance with
§258.54(a)(2), and for those constituents
in Appendix II that are detected in
response to paragraph (b) of this section,
and record their concentrations in the
facility operating record. At least one
sample from each well (background and
downgradient) must be collected and
analyzed during these sampling events.
The Director of an approved State may
specify an alternative monitoring
frequency during the active life
(including closure) and the post closure
period for the constituents referred to in
this paragraph. The alternative
frequency for Appendix I constituents or
the alternate list approved in accordance
with §258.54(a)(2) during the active life
(including closure) shall be no less than
annual. The alternative frequency shall
be based on consideration of the factors
specified in paragraph (c) of this section;
(3) Establish background concentrations
for any constituents detected pursuant to
paragraphs (b) or (d)(2) of this section;
and
(4) Establish ground-water protection
standards for all constituents detected
pursuant to paragraph (b) or (d)(2) of
this section. The ground-water
protection standards shall be established
in accordance with paragraphs (h) or (i)
of this section.
(e) If the concentrations of all Appendix
II constituents are shown to be at or
below background values, using the
statistical procedures in §258.53(g), for
two consecutive sampling events, the
owner or operator must notify the State
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Ground-Water Monitoring and Corrective Action
Director of this finding and may return to
detection monitoring.
(f) If the concentrations of any
Appendix II constituents are above
background values, but all concentrations
are below the ground-water protection
standard established under paragraphs
(h) or (i) of this section, using the
statistical procedures in §258.53(g), the
owner or operator must continue
assessment monitoring in accordance
with this section.
5.11.2 Applicability
Assessment monitoring is required at all
existing units, lateral expansions, and new
facilities whenever any of the constituents
listed in Appendix I are detected at a
concentration that is a statistically
significant increase over background values.
Figure 5-6 presents a flow chart pertaining
to applicability requirements.
Within 90 days of beginning assessment
monitoring, the owner or operator must
resample all downgradient wells and
analyze the samples for all Appendix II
constituents. If any new constituents are
identified in this process, four independent
samples must be collected from all
upgradient and downgradient wells and
analyzed for those new constituents to
establish background concentrations. The
complete list of Appendix II constituents
must be monitored in each well annually for
the duration of the assessment monitoring
program. In an approved State, the Director
may reduce the number of Appendix II
constituents to be analyzed if it can be
reasonably shown that those constituents are
not present in or derived from the wastes.
The Director of an approved State
may specify an appropriate subset of wells
to be included in the assessment monitoring
program. The Director of an approved State
also may specify an alternative frequency
for repeated sampling and analysis of
Appendix II constituents. This frequency
may be decreased or increased based upon
consideration of the factors in
§258.55(c)(l)-(6). These options for
assessment monitoring programs are
available only with the approval of the
Director of an approved State.
Within 14 days of receiving the results of
the initial sampling for Appendix II
constituents under assessment monitoring,
the owner or operator must place the results
in the operating record and notify the State
Director that this notice has been placed in
the operating record.
Within 90 days of receiving these initial
results, the owner or operator must resample
all wells for all Appendix I and detected
Appendix II constituents. This combined
list of constituents must be sampled at least
semiannually thereafter, and the list must be
updated annually to include any newly
detected Appendix II constituents.
Within the 90-day period, the owner or
operator must establish background values
and ground-water protection standards
(GWPSs) for all Appendix II constituents
detected. The requirements for determining
GWPSs are provided in §258.55(h). If the
concentrations of all Appendix II
constituents are at or below the background
values after two independent, consecutive
sampling events, the owner or operator may
return to detection monitoring after
notification has been made to the State
Director. If, after these two
283
-------
Figure 5-6
ASSESSMENT MONITORING
YES
Is There a
Statistically
Significant Increase
in Appendix I
Constituents?
YES
Continue/Return to
Detection Monitoring
iiiiiiiiiiiiiiiiiinnin iiimiiiiiiiiiiiimllin
[null
Assessment Monitoring (258.55)
• Sample for All Appendix II Constituents
• Set Ground-Water Protection Standard for Detected
Appendix II Constituents
• Resample for Detected Appendix II Constituents and All
Appendix I Constituents Semi-Annually
• Repeat Annual Monitoring for All Appendix II Constituents
• Characterize Nature and Extent of Release
Is There
a Statistically
Significant increase in
Appendix II Constituents
Over Ground-Water
Protection
Standard?
Are all
Appendix II
Constituents Below
Background?
Proceed to
Corrective Action
Continue Assessment
Monitoring
» IIIHIllllllllllHIIIIIIHIIlllllllllllllllllllllllL
284
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Ground-Water Monitoring and Corrective Action
sampling events, any detected Appendix II
constituent is statistically above background
but below the GWPSs, the assessment
monitoring program must be continued.
5.11.3 Technical Considerations
The purpose of assessment monitoring is to
evaluate the nature and extent of
contamination. The assessment monitoring
program is phased. The first phase assesses
the presence of additional assessment
monitoring constituents (Appendix II or a
revised list designated by an approved State)
in all downgradient wells or in a subset of
ground-water monitoring wells specified by
the Director of an approved State. If
concentrations of all Appendix II
constituents are at or below background
values using the statistical procedures in
§258.53(g) for two consecutive sampling
periods, then the owner or operator can
return to detection monitoring.
Following notification of a statistically
significant increase of any Appendix I
constituent above background, the owner or
operator has 90 days to develop and
implement the assessment monitoring
program. Implementation of the program
involves sampling downgradient monitoring
wells for ground water passing the relevant
point of compliance for the unit (i.e., the
waste management unit boundary or
alternative boundary specified by the
Director of an approved State).
Downgradient wells are identified in
§258.51(a)(2). Initiation of assessment
monitoring does not stop the detection
monitoring program. Section 258.55(d)(2)
specifies that analyses must continue for all
Appendix I constituents on at least a
semiannual basis. Within the 90-day period,
the owner or operator must collect at least
one sample from each downgradient well
and analyze the samples for the Appendix II
parameters. If a downgradient well has
detectable quantities of a new Appendix II
constituent, four independent samples must
be collected from all background and
downgradient wells to establish background
for the new constituent(s). The date, well
locations, parameters detected, and their
concentrations must be documented in the
operating record of the facility, and the
State Director must be notified within 14
days of the initial detection of Appendix II
parameters. On a semiannual basis
thereafter, both background and
downgradient wells must be sampled for all
Appendix II constituents.
Alternative List
In an approved State, the Director may
delete Appendix II parameters that the
owner or operator can demonstrate would
not be anticipated at the facility. A
demonstration would be based on a
characterization of the wastes contained in
the unit and an assessment of the leachate
constituents. Additional information on the
alternative list can be found in Section
5.10.3.
Alternative Frequency
The Director of an approved State may
specify an alternate sampling frequency for
the entire Appendix II list for both the
active and post-closure periods of the
facility. The decision to change the
monitoring frequency must consider:
1) Lithology of the aquifer and unsaturated
zone;
285
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Subpart E
2) Hydraulic conductivity of the aquifer
and unsaturated zone;
3) Ground-water flow rates;
4) Minimum distance of travel (between the
MSWLF unit edge to downgradient
monitoring wells); and
5) Nature (fate and transport) of the
detected constituents.
The Director of an approved State also may
allow an alternate frequency, other than
semiannual, for the monitoring of Appendix
I and detected Appendix II constituents.
The monitoring frequency must be
sufficient to allow detection of ground-
water contamination. If contamination is
detected early, the volume of ground water
contaminated will be smaller and the
required remedial response will be less
burdensome. Additional information on the
alternate frequency can be found in Section
5.10.3.
In an approved State, the Director may
specify a subset of wells that can be
monitored for Appendix II constituents to
confirm a release and track the plume of
contamination during assessment
monitoring. The owner or operator should
work closely with the State in developing a
monitoring plan that targets the specific
areas of concern, if possible. This may
represent a substantial cost savings,
especially at large facilities for which only
a very small percentage of wells showed
exceedances above background. The use of
a subset of wells likely will be feasible only
in cases where the direction and rate of flow
are relatively constant.
5.12 ASSESSMENT MONITORING
PROGRAM
40 CFR §258.55(g)
5.12.1 Statement of Regulation
(g) If one or more Appendix II
constituents are detected at statistically
significant levels above the ground-water
protection standard established under
paragraphs (h) or (i) of this section in any
sampling event, the owner or operator
must, within 14 days of this finding, place
a notice in the operating record
identifying the Appendix II constituents
that have exceeded the ground-water
protection standard and, notify the State
Director and all appropriate local
government officials that the notice has
been placed in the operating record. The
owner or operator also:
(1) (i) Must characterize the nature and
extent of the release by installing
additional monitoring wells as necessary;
(ii) Must install at least one additional
monitoring well at the facility boundary
in the direction of contaminant migration
and sample this well in accordance with
§258.55(d)(2);
(iii) Must notify all persons who own
the land or reside on the land that
directly overlies any part of the plume of
contamination if contaminants have
migrated off-site if indicated by sampling
of wells in accordance with §258.55(g)(i);
and
(iv) Must initiate an assessment of
corrective measures as required by
§255.56 of this part within 90 days; or
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Ground-Water Monitoring and Corrective Action
(2) May demonstrate that a source
other than a MSWLF unit caused the
contamination, or that the statistically
significant increase resulted from error in
sampling, analysis, statistical evaluation,
or natural variation in ground-water
quality. A report documenting this
demonstration must be certified by a
qualified ground-water scientist or
approved by the Director of an approved
State and placed in the operating record.
If a successful demonstration is made the
owner or operator must continue
monitoring in accordance with the
assessment monitoring program pursuant
to §258.55, and may return to detection
monitoring if the Appendix II
constituents are below background as
specified in §258.55(e). Until a successful
demonstration is made, the owner or
operator must comply with §258.55(g)
including initiating an assessment of
corrective measures.
5.12.2 Applicability
This requirement applies to facilities in
assessment monitoring and is applicable
during the active life, closure, and post-
closure care periods.
5.12.3 Technical Considerations
If an Appendix II constituent(s) exceeds a
GWPS in any sampling event, the owner or
operator must notify the State Director
within 14 days and place a notice of these
findings in the operating record of the
MSWLF facility. In addition, the owner or
operator must:
1) Characterize the lateral and vertical
extent of the release or plume by
installing and sampling an appropriate
number of additional monitoring wells
2) Install at least one additional
downgradient well at the facility
property boundary in the direction of
migration of the contaminant plume and
sample that well for all Appendix II
compounds initially and thereafter, in
conformance with the assessment
monitoring program
3) Notify all property owners whose land
overlies the suspected plume, if the
sampling of any property boundary
well(s) indicates that contaminants have
migrated offsite
4) Initiate an assessment of corrective
measures, as required by §258.56, within
90 days.
In assessment monitoring, the owner or
operator may demonstrate that a source
other than the MSWLF unit caused the
contamination or that the statistically
significant increase was the result of an
error in sampling, analysis, statistical
evaluation, or natural variation in ground-
water quality. The demonstration must be
certified by a qualified ground-water
scientist or approved by the Director of an
approved State. Until a successful
demonstration is made, the owner or
operator must comply with §258.55(g) and
initiate assessment of corrective measures.
If the demonstration is successful, the owner
or operator must return to assessment
monitoring and may return to the detection
program provided that all Appendix II
constituents are at or below background for
two consecutive sampling periods.
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Release Investigation
If the GWPS is exceeded, a series of actions
must be taken. These actions are described
in the next several paragraphs. The owner
or operator must investigate the extent of
the release by installing additional
monitoring wells and obtaining additional
ground-water samples. The investigation
should identify plume geometry, both
laterally and vertically. Prior to such field
activities, records of site operation and
maintenance activities should be reviewed
to identify possible release locations within
the landfill and whether such releases are
expected to be transient (e.g., one time
release due to repaired liner) or long-term.
Due to the presence of dissolved ionic
constituents, such as iron, magnesium,
calcium, sodium, potassium, chloride,
sulfate, and carbonate, typically associated
with MSWLF unit leachates, geophysical
techniques, including resistivity and terrain
conductivity, may be useful in defining the
plume. Characterizing the nature of the
release should include a description of the
rate and direction of contaminant migration
and the chemical and physical
characteristics of the contaminants.
Property Boundary Monitoring Well
At least one monitoring well must be
installed at the facility boundary in the
direction of contaminant migration.
Additional wells may be required to
delineate the plume. Monitoring wells at
the facility boundary should be screened to
monitor all stratigraphic units that could be
preferential pathways for contaminant
migration in the uppermost aquifer. In
some cases, this may require installation of
nested wells or individual wells screened at
several discrete intervals. The well installed
at the facility boundary must be sampled
semiannually or at an alternative frequency
determined by the Director of an approved
State. The initial sample must be analyzed
for all Appendix II constituents.
Notification of Adjoining Residents and
Property Owners
If ground-water monitoring indicates that
contamination has migrated offsite, the
owner or operator must notify property
owners or residents whose land surface
overlies any part of the contaminant release.
Although the requirement does not describe
the contents of the notice, it is expected that
the notice could include the following
items:
• Date of detected release
• Chemical composition of release
• Reference to the constituent(s), reported
concentration(s), and the GWPS
• Representatives of the MSWLF facility
with whom to discuss the finding,
including their telephone numbers
• Plans and schedules for future activities
• Interim recommendations or remedies to
protect human health and the
environment.
Demonstrations of Other Sources of
Error
The owner or operator may demonstrate that
the source of contamination was not the
MSWLF unit. This demonstration is
discussed in Section 5.10.3.
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Return to Detection Monitoring
A facility conducting assessment monitoring
may return to detection monitoring if the
concentrations of all Appendix II
constituents are at or below background
levels for two consecutive sampling periods
using the statistical procedures in
§25 8.5 3 (g). The requirement that
background concentrations must be
maintained for two consecutive sampling
events will reduce the possibility that the
owner or operator will fail to detect
contamination or an increase in a
concentration of a hazardous constituent
when one actually exists. The Director of
an approved State can establish an
alternative time period (§258.54(b).
5.13 ASSESSMENT MONITORING
PROGRAM
40 CFR §258.55(h)-(j)
5.13.1 Statement of Regulation
(h) The owner or operator must
establish a ground-water protection
standard for each Appendix II
constituent detected in the ground water.
The ground-water protection standard
shall be:
(1) For constituents for which a
maximum contaminant level (MCL) has
been promulgated under Section 1412 of
the Safe Drinking Water Act (codified)
under 40 CFR Part 141, the MCL for that
constituent;
(2) For constituents for which MCLs
have not been promulgated, the
background concentration for the
constituent established from wells in
accordance with §258.51(a)(l); or
(3) For constituents for which the
background level is higher than the MCL
identified under subparagraph (1) above
or health based levels identified under
§258.55(i)(l), the background
concentration.
(i) The Director of an approved State
may establish an alternative ground-
water protection standard for
constituents for which MCLs have not
been established. These ground-water
protection standards shall be appropriate
health based levels that satisfy the
following criteria:
(1) The level is derived in a manner
consistent with Agency guidelines for
assessing the health risks of
environmental pollutants (51 FR 33992,
34006, 34014, 34028);
(2) The level is based on scientifically
valid studies conducted in accordance
with the Toxic Substances Control Act
Good Laboratory Practice Standards (40
CFR Part 792) or equivalent;
(3) For carcinogens, the level represents
a concentration associated with an excess
lifetime cancer risk level (due to
continuous lifetime exposure) with the 1
x 10"4 to 1 x 10"6 range; and
(4) For systemic toxicants, the level
represents a concentration to which the
human population (including sensitive
subgroups) could be exposed to on a daily
basis that is likely to be without
appreciable risk of deleterious effects
during a lifetime. For purposes of this
subpart, systemic toxicants include toxic
chemicals that cause effects other than
cancer or mutation.
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(j) In establishing ground-water
protection standards under paragraph
(i), the Director of an approved State may
consider the following:
(1) Multiple contaminants in the ground
water;
(2) Exposure threats to sensitive
environmental receptors; and
(3) Other site-specific exposure or
potential exposure to ground water.
5.13.2 Applicability
The criteria for establishing GWPSs are
applicable to all facilities conducting
assessment monitoring where any Appendix
II constituents have been detected. The
owner or operator must establish a GWPS
for each Appendix II constituent detected.
If the constituent has a promulgated
maximum contaminant level (MCL), then
the GWPS is the MCL. If no MCL has been
published for a given Appendix II
constituent, the background concentration of
the constituent becomes the GWPS. In
cases where the background concentration is
higher than a promulgated MCL, the GWPS
is set at the background level.
In approved States, the Director may
establish an alternative GWPS for
constituents for which MCLs have not been
established. Any alternative GWPS must be
health-based levels that satisfy the criteria in
§258.55(i). The Director may also consider
any of the criteria identified in §258.55(j).
In cases where the background
concentration is higher than the health-
based levels, the GWPS is set at the
background level.
5.13.3 Technical Considerations
For each Appendix II constituent detected,
a GWPS must be established. The GWPS is
to be set at either the MCL or background.
Where the background concentration is
higher than the MCL, then the GWPS is
established at background.
Directors of approved States have the option
of establishing an alternative GWPS for
constituents without MCLs. This alternative
GWPS must be an appropriate health-based
level, based on specific criteria. These
levels must:
• Be consistent with EPA health risk
assessment guidelines
• Be based on scientifically valid studies
• Be within a risk range of IxlO"4 to IxlO"6
for carcinogens
• For systemic toxicants (causing effects
other than cancer or mutations), be a
concentration to which the human
population could be exposed on a daily
basis without appreciable risk of
deleterious effects during a lifetime.
The health-based GWPS may be established
considering the presence of more than one
constituent, exposure to sensitive
environmental receptors, and other site-
specific exposure to ground water. Risk
assessments to establish the GWPS must
consider cumulative effects of multiple
pathways to receptors and cumulative
effects on exposure risk of multiple
contaminants. Guidance and procedures for
establishing a health-based risk assessment
may be found in Guidance on Remedial
Actions for
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Contaminated Groundwater at Superfund
Sites, (USEPA, 1988).
5.14 ASSESSMENT OF
CORRECTIVE MEASURES
40 CFR §258.56
5.14.1 Statement of Regulation
(a) Within 90 days of finding that any of
the constituents listed in Appendix II
have been detected at a statistically
significant level exceeding the ground-
water protection standards defined under
§258.55(h) and (i) of this part, the owner
or operator must initiate an assessment of
corrective measures. Such an assessment
must be completed within a reasonable
period of time.
(b) The owner or operator must
continue to monitor in accordance with
the assessment monitoring program as
specified in §258.55.
(c) The assessment shall include an
analysis of the effectiveness of potential
corrective measures in meeting all of the
requirements and objectives of the
remedy as described under §258.57,
addressing at least the following:
(1) The performance, reliability, ease of
implementation, and potential impacts of
appropriate potential remedies, including
safety impacts, cross-media impacts, and
control of exposure to any residual
contamination;
(2) The time required to begin and
complete the remedy;
(3) The costs of remedy implementation;
and
(4) The institutional requirements such
as State or local permit requirements or
other environmental or public health
requirements that may substantially
affect implementation of the remedy(s).
(d) The owner or operator must discuss
the results of the corrective measures
assessment, prior to the selection of
remedy, in a public meeting with
interested and affected parties.
5.14.2 Applicability
An assessment of corrective measures must
be conducted whenever any Appendix II
constituents are detected at statistically
significant levels exceeding the GWPS. The
assessment of corrective measures must be
initiated within 90 days of the finding.
During the initiation of an assessment of
corrective measures, assessment monitoring
must be continued. The assessment of
corrective measures must consider
performance (including potential impacts),
time, and cost aspects of the remedies. If
implementation requires additional State or
local permits, such requirements should be
identified. Finally, the results of the
corrective measures assessment must be
discussed in a public meeting with
interested and affected parties.
5.14.3 Technical Considerations
An assessment of corrective measures is
site-specific and will vary significantly
depending on the design and age of the
facility, the completeness of the facility's
historical records, the nature and
concentration of the contaminants found in
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the ground water, the complexity of the site
hydrogeology, and the facility's proximity
to sensitive receptors. Corrective measures
are generally approached from two
directions: 1) identify and remediate the
source of contamination and 2) identify and
remediate the known contamination.
Because each case will be site-specific, the
owner or operator should be prepared to
document that, to the best of his or her
technical and financial abilities, a diligent
effort has been made to complete the
assessment in the shortest time practicable.
The factors listed in §258.56(c)(l) must be
considered in assessing corrective measures.
These general factors are discussed below in
terms of source evaluation, plume
delineation, ground-water assessment, and
corrective measures assessment.
Source Evaluation
As part of the assessment of corrective
measures, the owner or operator will need to
identify the nature of the source of the
release. The first step in this identification
is a review of all available site information
regarding facility design, wastes received,
and onsite management practices. For
newer facilities, this may be a relatively
simple task. However, at some older
facilities, detailed records of the facility's
history may not be as well documented,
making source definition more difficult.
Design, climatological, and waste-type
information should be used to evaluate the
duration of the release, potential seasonal
effects due to precipitation (increased
infiltration and leachate generation), and
possible constituent concentrations. If
source evaluation is able to identify a
repairable engineering condition that likely
contributed to the cause of contamination
(e.g., unlined leachate storage ponds, failed
cover system, leaky leachate transport pipes,
past conditions of contaminated storm
overflow), such information should be
considered as part of the assessment of
corrective measures.
Existing site geology and hydrogeology
information, ground-water monitoring
results, and topographic and cultural
information must be documented clearly and
accurately. This information may include
soil boring logs, test pit and monitoring well
logs, geophysical data, water level elevation
data, and other information collected during
facility design or operation. The
information should be expressed in a
manner that will aid interpretation of data.
Such data may include isopach maps of the
thickness of the upper aquifer and important
strata, isoconcentration maps of
contaminants, flow nets, cross-sections, and
contour maps. Additional guidance on data
interpretation that may be useful in a source
evaluation is presented in RCRA Facility
Investigation Guidance: Volume I -
Development of an RFI Work Plan and
General Considerations for RCRA Facility
Investigations, (USEPA 1989a), RCRA
Facility Investigation Guidance: Volume IV
- Case Study Examples, (USEPA 1989d),
and Practical Guide For Assessing and
Remediating Contaminated Sites (USEPA
1989e).
Plume Delineation
To effectively assess corrective measures,
the lateral and vertical extent of
contamination must be known. When it is
determined that a GWPS is exceeded during
the assessment monitoring program, it may
be necessary to install additional wells to
characterize the contaminant plume(s). At
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least one additional well must be added at
the property boundary in the direction of
contaminant migration to allow timely
notification to potentially affected parties if
contamination migrates offsite.
The following circumstances may require
additional monitoring wells:
• Facilities that have not determined the
horizontal and vertical extent of the
contaminant plume
• Locations where the subsurface is
heterogeneous or where ground-water
flow patterns are difficult to establish
• Mounding associated with MSWLF
units.
Because the requirements for additional
monitoring are site-specific, the regulation
does not specifically establish cases where
additional wells are necessary or establish
the number of additional wells that must be
installed.
During the plume delineation process, the
owner or operator is not relieved from
continuing the assessment monitoring
program.
The rate of plume migration and the change
in contaminant concentrations with time
must be monitored to allow prediction of the
extent and timing of impact to sensitive
receptors. The receptors may include users
of both ground-water and surface water
bodies where contaminated ground water
may be discharged. In some cases, transfer
of volatile compounds from ground water to
the soil and to the air may provide an
additional migration pathway. Information
regarding the aquifer characteristics (e.g.,
hydraulic conductivity, storage coefficients,
and effective porosity) should be developed
for modeling contaminant transport if
sufficient data are not available. Anisotropy
and heterogeneity of the aquifer must be
evaluated, as well as magnitude and
duration of source inputs, to help explain
present and predicted plume configuration.
Currently, most treatment options for
ground-water contamination at MSWLF
units involve pump and treat or in-situ
biological technologies (bio-remediation).
The cost and duration of treatment depends
on the size of the plume, the pumping
characteristics of the aquifer, and the
chemical transport phenomena. Source
control and ground-water flow control
measures to reduce the rate of contaminant
migration should be included in the costs of
any remedial activity undertaken. Ground-
water modeling of the plume may be
initiated to establish the following:
• The locations and pumping rates of
withdrawal and/or injection wells
• Predictions of contaminant
concentrations at exposure points
• Locations of additional monitoring wells
• The effect that source control options
may have on ground-water remediation
• The effects of advection and dispersion,
retardation, adsorption, and other
attenuation processes on the plume
dimensions and contaminant
concentrations.
Any modeling effort must consider that
simulations of remedial response measures
and contaminant transport are based on
many necessary simplifying assumptions,
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which affect the accuracy of the model.
These assumptions include boundary
conditions, the degree and spatial variability
of anisotropy, dispersivity, effective
porosity, stratigraphy, and the algorithms
used to solve contaminant transport
equations. Model selection should be
appropriate for the amount of data available,
and the technical uncertainty of the model
results must be documented by a sensitivity
analysis on the input parameters. A
sensitivity analysis is generally done after
model calibration by varying one input
parameter at a time over a realistic range
and then evaluating changes in model
output. For additional information on
modeling, refer to the Further Information
Section of Chapter 5.0 and the RCRA
Facility Investigation Guidance: Volume II
- Soil, Groundwater and Subsurface Gas
Releases (USEPA, 1989b).
Ground-Water Assessment
To assess the potential effectiveness of
corrective measures for ground-water
contamination, the following information is
needed:
• Plume definition (includes the types,
concentration, and spatial distribution of
the contaminants)
• The amenability of the contaminants to
specific treatment and potential for
contaminants to interfere with
treatability
• Fate of the contaminants (whether
chemical transformations have, are, or
may be occurring, and the degree to
which the species are sorbed to the
geologic matrix)
• Stratigraphy and hydraulic properties of
the aquifer
• Treatment concentration goals and
objectives.
The owner or operator should consider
whether immediate measures to limit further
plume migration (e.g., containment options)
or measures to minimize further
introduction of contaminants to ground
water are necessary.
The process by which a remedial action is
undertaken will generally include the
following activities:
• Hydrogeologic investigation, which may
include additional well installations,
detailed vertical and lateral sampling to
characterize the plume, and core
sampling to determine the degree of
sorption of constituents on the geologic
matrix
• Risk assessment, to determine the impact
on sensitive receptors, which may
include identification of the need to
develop treatment goals other than
GWPSs
• Literature and technical review of
treatment technologies considered for
further study or implementation
• Evaluation of costs of different treatment
options
• Estimation of the time required for
completion of remediation under the
different treatment options
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• Bench-scale treatability studies
conducted to assess potential
effectiveness of options
• Selection of technology(ies) and
proposal preparation for regulatory and
public review and comment
• Full-scale pilot study for verification of
treatability and optimization of the
selected technology
• Initiation of full-scale treatment
technology with adjustments, as
necessary
• Continuation of remedial action until
treatment goals are achieved.
Corrective Measures Assessment
To compare different treatment options,
substantial amounts of technical information
must be assembled and assessed. The
objective of this information-gathering task
is to identify the following items for each
treatment technology:
• The expected performance of individual
approaches
• The time frame when individual
approaches can realistically be
implemented
• The technical feasibility of the
remediation, including new and
innovative technologies, performance,
reliability and ease of implementation,
safety and cross media impacts
• The anticipated time frame when
remediation should be complete
• The anticipated cost of the remediation,
including capital expenditures, design,
ongoing engineering, and monitoring of
results
• Technical and financial capability of the
owner or operator to successfully
complete the remediation
• Disposal requirements for treatment
residuals
• Other regulatory or institutional
requirements, including State and local
permits, prohibitions, or environmental
restrictions that may affect the
implementation of the proposed remedial
activity.
The performance objectives of the
corrective measures should be considered in
terms of source reduction, cleanup goals,
and cleanup time frame. Source reduction
would include measures to reduce or stop
further releases and may include the repair
of existing facility components (liner
systems, leachate storage pond liners, piping
systems, cover systems), upgrading of
components (liners and cover systems), or
premature closure in extreme cases. The
technology proposed as a cleanup measure
should be the best available technology,
given the practicable capability of the owner
or operator.
The technologies identified should be
reliable, based on their previous
performance; however, new innovative
technologies are not discouraged if they can
be shown, with a reasonable degree of
confidence, to be reliable.
Because most treatment processes, including
biorestoration, potentially produce
byproducts or release contaminants to
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different media (e.g., air stripping of
volatile compounds), the impacts of such
potential releases must be evaluated.
Releases to air may constitute a worker
health and safety concern and must be
addressed as part of the alternatives
assessment process. Other cross media
impacts, including transfer of contaminants
from soils to ground water, surface water, or
air, should be assessed and addressed in the
assessment of corrective actions. Guidance
for addressing air and soil transport and
contamination is provided in USEPA
(1989b) and USEPA (1989c).
Analyses should be conducted on treatment
options to determine whether or not they are
protective of human health and the
environment. Environmental monitoring of
exposure routes (air and water) may
necessitate health monitoring for personnel
involved in treatment activities if
unacceptable levels of exposure are
possible. On a case-by-case basis,
implementation plans may require both
forms of monitoring.
The development and screening of
individual corrective measures requires an
understanding of the physio-chemical
relationships and interferences between the
constituents and the sequence of treatment
measures that must be implemented. Proper
sequencing of treatment methods to produce
a feasible remedial program must be
evaluated to avoid interference between the
presence of some constituents and the
effective removal of the targeted compound.
In addition, screening and design parameters
of potential treatment options should be
evaluated in the early stages of conceptual
development and planning to eliminate
technically unsuitable treatment methods.
In general, selection of an appropriate
treatment method will require the
experience
of a qualified professional and will
necessitate a literature review of the best
available treatment technologies.
Numerous case studies and published papers
from scientific and engineering technical
journals exist on treatability of specific
compounds and groups of related
compounds. Development of new
technologies and refinements of
technologies have been rapid. A
compendium of available literature that
includes treatment technologies for organic
and inorganic contaminants, technology
selection, and other sources of information
(e.g., literature search data bases pertinent
to ground-water extraction, treatment, and
responses) is included in Practical Guide
for Assessing and Remediating
Contaminated Sites (USEPA, 1989e).
The general approach to remediation
typically includes active restoration, plume
containment, and source control as
discussed below. The selection of a
particular approach or combination of
approaches must be based on the corrective
action objectives. These general approaches
are outlined in Table 5-3. It should be
emphasized that the objective of a treatment
program should be to restore ground water
to pre-existing conditions or to levels below
applicable ground-water protection
standards while simultaneously restricting
further releases of contaminants to ground
water. Once treatment objectives are met,
the chance of further contamination should
be mitigated to the extent practicable.
Active Restoration
Active restoration generally includes
ground-water extraction, followed by onsite
or offsite wastewater treatment. Offsite
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wastewater treatment may include sending
the contaminated water to a local publicly
owned treatment works (POTW) or to a
facility designed to treat the contaminants of
concern. Treated ground water may be re-
injected, sent to a local POTW, or
discharged to a local body of surface water,
depending on local, State, and Federal
requirements. Typical treatment practices
that may be implemented include
coagulation and precipitation of metals,
chemical oxidation of a number of organic
compounds, air stripping to remove volatile
organic compounds, and biological
degradation of other organics.
The rate of contaminant removal from
ground water will depend on the rate of
ground-water removal, the cation exchange
capacity of the soil, and partition
coefficients of the constituents sorbed to the
soil (USEPA, 1988). As the concentration
of contaminants in the ground water is
reduced, the rate at which constituents
become partitioned from the soil to the
aqueous phase may also be reduced. The
amount of flushing of the aquifer material
required to remove the contaminants to an
acceptable level will generally determine
the time frame required for restoration. This
time frame is site-specific and may last
indefinitely.
In-situ methods may be appropriate for
some sites, particularly where pump and
treat technologies create serious adverse
effects or where it may be financially
prohibitive. In-situ methods may include
biological restoration requiring pH control,
addition of specific micro-organisms, and/or
addition of nutrients and substrate to
augment and encourage degradation by
indigenous microbial populations.
Bioremediation requires laboratory
treatability studies and
pilot field studies to determine the
feasibility and the reliability of full-scale
treatment. It must be demonstrated that the
treatment techniques will not cause
degradation of a target chemical to another
compound that has unacceptable health risks
and that is subject to further degradation.
Alternative in-situ methods may also be
designed to increase the effectiveness of
desorption or removal of contaminants from
the aquifer matrix. Such methodologies
may include steam stripping, soil flushing,
vapor extraction, thermal desorption, and
solvent washing, and extraction for removal
of strongly sorbed organic compounds.
These methods also may be used in
unsaturated zones where residual
contaminants may be sorbed to the geologic
matrix during periodic fluctuations of the
water table. Details of in-situ methods may
be found in several sources: USEPA (1988);
USEPA (1985); and Eckenfelder (1989).
Plume Containment
The purpose of plume containment is to
limit the spread of the contaminants.
Methods to contain plume movement
include passive hydraulic barriers, such as
grout curtains and slurry walls, and active
gradient control systems involving pumping
wells and french drains. The types of
aquifer characteristics that favor plume
containment include:
• Water naturally unsuited for human
consumption
• Contaminants present in low
concentration with low mobility
• Low potential for exposure to
contaminants and low risk associated
with exposure
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• Low transmissivity and low future user
demand.
Often, it may be advantageous for the owner
or operator to consider implementing
ground-water controls to inhibit further
contamination or the spread of
contamination. If ground-water pumping is
considered for capturing the leading edge of
the contaminant plume, the contaminated
water must be managed in conformance
with all applicable Federal and State
requirements. Under most conditions, it is
necessary to consult with the regulatory
agencies prior to initiating an interim
remedial action.
Source Control
Source control measures should be
evaluated to limit the migration of the
plume. The regulation does not limit the
definition of source control to exclude any
specific type of remediation. Remedies
must control the source to reduce or
eliminate further releases by identifying and
locating the cause of the release (e.g., torn
geomembrane, excessive head due to
blocked leachate collection system, leaking
leachate collection well or pipe). Source
control measures may include the following:
• Modifying the operational procedures
(e.g., banning specific wastes or
lowering the head over the leachate
collection system through more frequent
leachate removal)
• Undertaking more extensive and
effective maintenance activities (e.g.,
excavate waste to repair a liner failure or
a clogged leachate collection system)
• Preventing additional leachate
generation that may reach a liner failure
(e.g., using a portable or temporary rain
shelter during operations or capping
landfill areas that contribute to leachate
migrating from identified failure areas).
In extreme cases, excavation of deposited
wastes for treatment and/or off site disposal
may be considered.
Public Participation
The owner or operator is required to hold a
public meeting to discuss the results of the
corrective action assessment and to identify
proposed remedies. Notifications, such as
contacting local public agencies, town
governments, and State/Tribal governments,
posting a notice in prominent local
newspapers, and making radio
announcements are effective. The public
meeting should provide a detailed
discussion of how the owner or operator has
addressed the factors at §258.56(c)(l)-(4).
5.15 SELECTION OF REMEDY
40 CFR §258.57 (a)-(b)
5.15.1 Statement of Regulation
(a) Based on the results of the corrective
measure assessment conducted under
§258.56, the owner or operator must
select a remedy that, at a minimum,
meets the standards listed in paragraph
(b) below. The owner or operator must
notify the State Director, within 14 days
of selecting a remedy, that a report
describing the selected remedy has been
placed in the operating record and how it
meets the standards in paragraph (b) of
this section.
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(b) Remedies must:
(1) Be protective of human health and
the environment;
(2) Attain the ground-water protection
standard as specified pursuant to
§§258.55(h) or (i);
(3) Control the source(s) of releases so as
to reduce or eliminate, to the maximum
extent practicable, further releases of
Appendix II constituents into the
environment that may pose a threat to
human health or the environment; and
(4) Comply with standards for
management of wastes as specified in
§258.58(d).
5.15.2 Applicability
These provisions apply to facilities that
have been required to perform corrective
measures. The selection of a remedy is
closely related to the assessment process and
cannot be accomplished unless a sufficiently
thorough evaluation of alternatives has been
completed. The process of documenting the
rationale for selecting a remedy requires
that a report be placed in the facility
operating record that clearly defines the
corrective action objectives and
demonstrates why the selected remedy is
anticipated to meet those objectives. The
State Director must be notified within 14
days of the placement of the report in the
operating records of the facility. The study
must identify how the remedy will be
protective of human health and the
environment, attain the GWPS (either
background, MCLs, or, in approved States,
health-based standards, if applicable), attain
source control objectives,
and comply with waste management
standards.
5.15.3 Technical Considerations
The final method selected for
implementation must satisfy the criteria in
§258.57(b)(l)-(4). The report documenting
the capability of the selected method to
meet these four criteria should include such
information as:
• Theoretical calculations
• Comparison to existing studies and
results of similar treatment case
histories
• Bench-scale or pilot-scale treatability
test results
• Waste management practices.
The demonstration presented in the report
must document the alternative option
selection process.
5.16 SELECTION OF REMEDY
40 CFR §258.57 (c)
5.16.1 Statement of Regulation
(c) In selecting a remedy that meets the
standards of §258.57(b), the owner or
operator shall consider the following
evaluation factors:
(1) The long- and short-term
effectiveness and protectiveness of the
potential remedy(s), along with the
degree of certainty that the remedy will
prove successful based on consideration
of the following:
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(i) Magnitude of reduction of existing
risks;
(ii) Magnitude of residual risks in
terms of likelihood of further releases due
to waste remaining following
implementation of a remedy;
(iii) The type and degree of long-term
management required, including
monitoring, operation, and maintenance;
(iv) Short-term risks that might be
posed to the community, workers, or the
environment during implementation of
such a remedy, including potential
threats to human health and the
environment associated with excavation,
transportation, and redisposal or
containment;
(v) Time
achieved;
until full protection is
(vi) Potential for exposure of humans
and environmental receptors to
remaining wastes, considering the
potential threat to human health and the
environment associated with excavation,
transportation, redisposal, or
containment;
(vii) Long-term reliability of the
engineering and institutional controls;
and
(viii) Potential need for replacement of
the remedy.
(2) The effectiveness of the remedy in
controlling the source to reduce further
releases based on consideration of the
following factors:
(i) The extent to which containment
practices will reduce further releases;
(ii) The extent to which treatment
technologies may be used.
(3) The ease or difficulty of
implementing a potential remedy(s) based
on consideration of the following types of
factors:
(i) Degree of difficulty associated with
constructing the technology;
(ii) Expected operational reliability of
the technologies;
(iii) Need to coordinate with and obtain
necessary approvals and permits from
other agencies;
(iv) Availability of necessary
equipment and specialists; and
(v) Available capacity and location of
needed treatment, storage, and disposal
services.
(4) Practicable capability of the owner
or operator, including a consideration of
the technical and economic capability.
(5) The degree to which community
concerns are addressed by a potential
remedy(s).
5.16.2 Applicability
These provisions apply to facilities that are
selecting a remedy for corrective action.
The rule presents the considerations and
factors that the owner or operator must
evaluate when selecting the appropriate
corrective measure.
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5.16.3 Technical Considerations
The owner or operator must consider
specific topics to satisfy the performance
criteria under selection of the final
corrective measure. These topics must be
addressed in the report documenting the
selection of a particular corrective action.
The general topic areas that must be
considered include the following:
• The anticipated long- and short-term
effectiveness of the corrective action
• The anticipated effectiveness of source
reduction efforts
• The ease or difficulty of implementing
the corrective measure
• The technical and economic practicable
capability of the owner or operator
• The degree to which the selected remedy
will address concerns raised by the
community.
Effectiveness of Corrective Action
In selecting the remedial action, the
anticipated long-term and short-term
effectiveness should be evaluated. Long-
term effectiveness focuses on the risks
remaining after corrective measures have
been taken. Short-term effectiveness
addresses the risks during construction and
implementation of the corrective measure.
Review of case studies where similar
technologies have been applied provide the
best measures to judge technical
uncertainty, especially when relatively new
technologies are applied. The long-term,
post-cleanup effectiveness may be judged
on the ability of the proposed remedy to
mitigate further
releases of contaminants to the environment,
as well as on the feasibility of the proposed
remedy to meet or exceed the GWPSs. The
owner or operator must make a reasonable
effort to estimate and quantify risks, based
on exposure pathways and estimates of
exposure levels and durations. These
estimates include risks for both ground-
water and cross-media contamination.
The source control measures that will be
implemented, including excavation,
transportation, re-disposal, and
containment, should be evaluated with
respect to potential exposure and risk to
human health and the environment. The
source control measures should be viewed
as an integral component of the overall
corrective action. Health considerations
must address monitoring risks to workers
and the general public and provide
contingency plans should an unanticipated
exposure occur. Potential exposure should
consider both long- and short-term cases
before, during, and after implementation of
corrective actions.
The time to complete the remedial activity
must be estimated, because it will have
direct financial impacts on the project
management needs and financial capability
of the owner or operator to meet the
remedial objectives. The long-term costs of
the remedial alternatives and the long-term
financial condition of the owner or operator
should be reviewed carefully. The
implementation schedule should indicate
quality control measures to assess the
progress of the corrective measure.
The operational reliability of the corrective
measures should be considered. In addition,
the institutional controls and management
practices developed to assess the reliability
should be identified.
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Effectiveness of Source Reduction
Source control measures identified in
previous sections should be discussed in
terms of their expected effectiveness. If
source control consists of the removal and
re-disposal of wastes, the residual materials,
such as contaminated soils above the water
table, should be quantified and their
potential to cause further contamination
evaluated. Engineering controls intended to
upgrade or repair deficient conditions in
landfill component systems, including cover
systems, should be quantified in terms of
anticipated effectiveness according to
current and future conditions. This
assessment may indicate to what extent it is
technically and financially practicable to
make use of existing technologies. The
decision against using a certain technology
may be based on health considerations and
the potential for unacceptable exposure(s) to
both workers and the public.
Implementation of Remedial Action
The ease of implementing the proposed
remedial action will affect the schedule and
startup success of the remedial action. The
following key factors need to be assessed:
• The availability of technical expertise
of equipment
Construction
technology
or
The ability to properly manage and
dispose of wastes generated by
treatment
The likelihood of obtaining local
permits and public support for the
proposed project.
Technical considerations, including pH
control, ground-water extraction feasibility,
or the ability to inject nutrients, may need to
be considered, depending on the proposed
treatment method. Potential impacts, such
as potential cross-media contamination,
need to be reviewed as part of the overall
feasibility of the project.
The schedule of remedial activities should
identify the start and end points of the
following periods:
• Permitting phase
• Construction and startup period, during
which initial implementation success
will be evaluated, including time to
correct any unexpected problems
• Time when full-scale treatment will be
initiated and duration of treatment period
• Implementation and completion of
source control measures, including the
timeframe for solving problems
associated
with interim management and disposal of
waste materials or treatment residuals.
Items that require long lead times should be
identified early in the process and those
tasks should be initiated early to ensure that
implementation occurs in the shortest
practicable period.
Practical Capability
The owner or operator must be technically
and financially capable of implementing the
chosen remedial alternative and ensuring
project completion, including provisions for
future changes to the remedial plan after
progress is reviewed. If either technical or
financial capability is inadequate for a
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particular alternative, then other alternatives
with similar levels of protectiveness should
be considered for implementation.
Community Concerns
The public meetings held during assessment
of alternative measures are intended to elicit
public comment and response. The owner
or operator must, by means of meeting
minutes and a record of written comments,
identify which public concerns have been
expressed and addressed by corrective
measure options. In reality, the final
remedy selected and implemented will be
one that the State regulatory agency, the
public, and the owner or operator agree to.
5.17 SELECTION OF REMEDY
40 CFR §258.57 (d)
5.17.1 Statement of Regulation
(d) The owner or operator shall specify
as part of the selected remedy a
schedule(s) for initiating and completing
remedial activities. Such a schedule must
require the initiation of remedial
activities within a reasonable period of
time taking into consideration the factors
set forth in paragraphs (d) (1-8). The
owner or operator must consider the
following factors in determining the
schedule of remedial activities:
(1) Extent and nature of contamination;
(2) Practical capabilities of remedial
technologies in achieving compliance with
ground-water protection standards
established under §§258.55(g) or (h) and
other objectives of the remedy;
(3) Availability of treatment or disposal
capacity for wastes managed during
implementation of the remedy;
(4) Desirability of utilizing technologies
that are not currently available, but
which may offer significant advantages
over already available technologies in
terms of effectiveness, reliability, safety,
or ability to achieve remedial objectives;
(5) Potential risks to human health and
the environment from exposure to
contamination prior to completion of the
remedy;
(6) Resource value of the aquifer
including:
(i) Current and future uses;
(ii) Proximity and withdrawal rate of
users;
(iii) Ground-water
quality;
quantity and
(iv) The potential damage to wildlife,
crops, vegetation, and physical structures
caused by exposure to waste constituent;
(v) The hydrogeologic characteristic of
the facility and surrounding land;
(vi) Ground-water
treatment costs; and
removal and
(vii) The cost and availability
alternative water supplies.
of
(7) Practicable capability of the owner
or operator.
(8) Other relevant factors.
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5.17.2 Applicability
The requirements of §258.57(d) apply to
owners or operators of all new units,
existing units, and laterally expanded units
at all facilities required to implement
corrective actions. The requirements must
be complied with prior to implementing
corrective measures. The owner or operator
must specify the schedule for remedial
activities based on the following
considerations:
• The size and nature of the contaminated
area at the time the corrective measure is
to be implemented
• The practicable capabilities of the
remedial technology selected
• Available treatment and disposal
capacity
• Potential use of alternative innovative
technologies not currently available
• Potential risks to human health and the
environment existing prior to completion
of the remedy
• Resource value of the aquifer
• The practicable capability of the
owner/operator
• Other relevant factors.
5.17.3 Technical Considerations
The time schedule for implementing and
completing the remedial activity is
influenced by many factors that should be
considered by the owner or operator. The
most critical factor is the nature and extent
of the contamination, which significantly
affects the ultimate treatment rate. The size
of the treatment facility and the ground-
water extraction and injection rates must be
balanced for system optimization, capital
resources, and remedial timeframe
objectives. The nature of the contamination
will influence the degree to which the
aquifer must be flushed to remove adsorbed
species. These factors, which in part define
the practicable capability of the alternative
(treatment efficiency, treatment rate, and
replenishment of contaminants by natural
processes), should be considered when
selecting the remedy.
In addition, the rate at which treatment may
occur may be restricted by the availability
or capacity to handle treatment residues and
the normal flow of wastes during
remediation. Alternative residue treatment
or disposal capacity must be identified as
part of the implementation plan schedule.
If contaminant migration is slow due to low
transport properties of the aquifer,
additional time may be available to evaluate
the value of emerging and promising
innovative technologies. The use of such
technologies is not excluded as part of the
requirement to implement a remedial action
as soon as practicable. Delaying
implementation to increase the availability
of new technologies must be evaluated in
terms of achievable cleanup levels, ultimate
cost, additional environmental impact, and
potential for increased risk to sensitive
receptors. If a new technology clearly is
superior to existing options in attaining
remediation objectives, it may be
appropriate to delay implementation. This
may require that existing risks be controlled
through interim measures.
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In setting the implementation schedule, the
owner or operator should assess the risk to
human health and the environment within
the timeframe of reaching treatment
objectives. If the risk is unacceptable,
considering health-based assessments of
exposure paths and exposure limits, the
implementation time schedule must be
accelerated or the selected remedy altered to
provide an acceptable risk level in a timely
manner.
Establishment of the schedule also may
include consideration of the resource value
of the aquifer, as it pertains to current and
future use, proximity to users, quality and
quantity of ground water, agricultural value
and uses (irrigation water source or impact
on adjacent agricultural lands), and the
availability of alternative supplies of water
of similar quantity and quality. Based on
these factors, a relative assessment of the
aquifer's resource value to the local
community can be established. Impacts to
the resource and the degree of financial or
health-related distress by users should be
considered. The implementation timeframe
should attempt to minimize the loss of value
of the resource to users. The possibility that
alternative water supplies will have to be
developed as part of the remedial activities
may need to be considered.
Because owners or operators may not be
knowledgeable in remediation activities,
reliance on the owner or operator to devise
the schedule for remediation may be
impracticable. In these instances, use of an
outside firm to coordinate remediation
scheduling may be necessary. Similarly,
development of a schedule for which the
owner or operator cannot finance, when
other options exist that do allow for owner
or operator financing, should be prevented.
5.18 SELECTION OF REMEDY
40 CFR §258.57 (e)-(f)
5.18.1 Statement of Regulation
(e) The Director of an approved State
may determine that remediation of a
release of an Appendix II constituent
from a MSWLF unit is not necessary if
the owner or operator demonstrates to
the satisfaction of the Director of an
approved State that:
(1) The ground water is additionally
contaminated by substances that have
originated from a source other than a
MSWLF unit and those substances are
present in concentrations such that
cleanup of the release from the MSWLF
unit would provide no significant
reduction in risk to actual or potential
receptors; or
(2) The constituent(s) is present in
ground water that:
(i) Is not currently or reasonably
expected to be a potential source of
drinking water; and
(ii) Is not hydraulically connected with
waters to which the hazardous
constituents are migrating or are likely to
migrate in a concentration(s) that would
exceed the ground-water protection
standards established under §258.55(h)
or (i); or
(3) Remediation of the release(s) is
technically impracticable; or
(4) Remediation results in unacceptable
cross-media impacts.
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(f) A determination by the Director of
an approved State pursuant to paragraph
(e) above shall not affect the authority of
the State to require the owner or operator
to undertake source control measures or
other measures that may be necessary to
eliminate or minimize further releases to
the ground water, to prevent exposure to
the ground water, or to remediate the
ground water to concentrations that are
technically practicable and significantly
reduce threats to human health or the
environment.
5.18.2 Applicability
The criteria under §258.57(e) and (f) apply
in approved States only. Remediation of the
release of an Appendix II constituent may
not be necessary if 1) a source other than the
MSWLF unit is partly responsible for the
ground-water contamination, 2) the resource
value of the aquifer is extremely limited, 3)
remediation is not technically feasible, or 4)
remediation will result in unacceptable
cross-media impacts. The Director may
determine that while total remediation is not
required, source control measures or partial
remediation of ground water to
concentrations that are technically
practicable and significantly reduce risks is
required.
5.18.3 Technical Considerations
There are four situations where an approved
State may not require cleanup of hazardous
constituents released to ground water from
a MSWLF unit. If sufficient evidence exists
to document that the ground water is
contaminated by a source other than the
MSWLF unit, the Director of an approved
State may grant a waiver
from implementing some or all of the
corrective measure requirements. The
owner or operator must demonstrate that
cleanup of a release from its MSWLF unit
would provide no significant reduction in
risk to receptors due to concentrations of
constituents from the other source.
A waiver from corrective measures also may
be granted if the contaminated ground water
is not a current or reasonably expected
potential future drinking water source, and
it is unlikely that the hazardous constituents
would migrate to waters causing an
exceedance of GWPS. The owner or
operator must demonstrate that the
uppermost aquifer is not hydraulically
connected with a lower aquifer. The owner
or operator may seek an exemption if it can
be demonstrated that attenuation,
advection/dispersion or other natural
processes can remove the threat to
interconnected aquifers. The owner or
operator may seek the latter exemption if
the contaminated zone is not a drinking
water resource.
The Director of an approved State may
waive cleanup requirements if remediation
is not technically feasible. In addition, the
Director may wave requirements if
remediation results in unacceptable cross-
media impacts. A successful demonstration
that remediation is not technically feasible
must document specific facts that attribute
to this demonstration. Technical
impracticabilities may be related to the
accessibility of the ground water to
treatment, as well as the treatability of the
ground water using practicable treatment
technologies. If the owner or operator can
demonstrate that unacceptable cross-media
impacts are uncontrollable under a given
remedial option
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(e.g., movement in response to ground-
water pumping or release of volatile
organics to the atmosphere) and that the no
action option is a less risky alternative, then
the Director of an approved State may
determine that remediation is not necessary.
A waiver of remedial obligation does not
necessarily release the owner or operator
from the responsibility of conducting source
control measures or minimal ground-water
remediation. The State may require that
source control be implemented to the
maximum extent practicable to minimize
future risk of releases of contaminants to
ground water or that ground water be treated
to the extent technically feasible.
5.19 IMPLEMENTATION OF THE
CORRECTIVE ACTION
PROGRAM
40 CFR §258.58 (a)
5.19.1 Statement of Regulation
(a) Based on the schedule established
under §258.57(d) for initiation and
completion of remedial activities the
owner/operator must:
(1) Establish and implement a corrective
action ground-water monitoring program
that:
(i) At a minimum, meets the
requirements of an assessment
monitoring program under §258.55;
(ii) Indicates the effectiveness of the
corrective action remedy; and
(iii) Demonstrates compliance with
ground-water protection standard
pursuant to paragraph (e) of this section.
(2) Implement the corrective action
remedy selected under §258.57; and
(3) Take any interim measures necessary
to ensure the protection of human health
and the environment. Interim measures
should, to the greatest extent practicable,
be consistent with the objectives of and
contribute to the performance of any
remedy that may be required pursuant to
§258.57. The following factors must be
considered by an owner or operator in
determining whether interim measures
are necessary:
(i) Time required to develop
implement a final remedy;
and
(ii) Actual or potential exposure of
nearby populations or environmental
receptors to hazardous constituents;
(iii) Actual or potential contamination
of drinking water supplies or sensitive
ecosystems;
(iv) Further degradation of the ground
water that may occur if remedial action is
not initiated expeditiously;
(v) Weather conditions that may cause
hazardous constituents to migrate or be
released;
(vi) Risks of fire or explosion, or
potential for exposure to hazardous
constituents as a result of an accident or
failure of a container or handling system;
and
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(vii) Other situations that may pose
threats to human health and the
environment.
5.19.2 Applicability
These provisions apply to facilities that are
required to initiate and complete corrective
actions.
The owner or operator is required to
continue to implement its ground water
assessment monitoring program to evaluate
the effectiveness of remedial actions and to
demonstrate that the remedial objectives
have been attained at the completion of
remedial activities.
Additionally, the owner or operator must
take any interim actions to protect human
health and the environment. The interim
measures must serve to mitigate actual
threats and prevent potential threats from
being realized while a long-term
comprehensive response is being developed.
5.19.3 Technical Considerations
Implementation of the corrective measures
encompass all activities necessary to initiate
and continue remediation. The owner or
operator must continue assessment
monitoring to anticipate whether interim
measures are necessary, and to determine
whether the corrective action is meeting
stated objectives.
Monitoring Activities
During the implementation period, ground-
water monitoring must be conducted to
demonstrate the effectiveness of the
corrective action remedy. If the remedial
action is not effectively curtailing further
ground water degradation or the spread of
the contaminant plume, replacement of the
system with an alternative measure may be
warranted. The improvement rate of the
condition of the aquifer must be monitored
and compared to the cleanup objectives. It
may be necessary to install additional
monitoring wells to more clearly evaluate
remediation progress. Also, if it becomes
apparent that the GWPS will not be
achievable technically, in a realistic time-
frame, the performance objectives of the
corrective measure must be reviewed and
amended as necessary.
Interim Measures
If unacceptable potential risks to human
health and the environment exist prior to or
during implementation of the corrective
action, the owner or operator is required to
take interim measures to protect receptors.
These interim measures are typically short-
term solutions to address immediate
concerns and do not necessarily address
long-term remediation objectives. Interim
measures may include activities such as
control of ground-water migration through
high-volume withdrawal of ground water or
response to equipment failures that occur
during remediation (e.g., leaking drums). If
contamination migrates offsite, interim
measures may include providing an
alternative water supply for human,
livestock, or irrigation needs. Interim
measures also pertain to source control
activities that may be implemented as part
of the overall corrective action. This may
include activities such as excavation of the
source material or in-situ treatment of the
contaminated source. Interim measures
should be developed with consideration
given to maintaining conformity with the
objectives of the final corrective action.
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5.20 IMPLEMENTATION OF THE
CORRECTIVE ACTION
PROGRAM
40 CFR §258.58 (b)-(d)
5.20.1 Statement of Regulation
(b) An owner or operator may
determine, based on information
developed after implementation of the
remedy has begun or other information,
that compliance with requirements of
§258.57(b) are not being achieved
through the remedy selected. In such
cases, the owner or operator must
implement other methods or techniques
that could practicably achieve compliance
with the requirements, unless the owner
or operator makes the determination
under §258.58(c).
(c) If the owner or operator determines
that compliance with requirements under
§258.57(b) cannot be practically achieved
with any currently available methods, the
owner or operator must:
(1) Obtain certification of a qualified
ground-water specialist or approval by
the Director of an approved State that
compliance with requirements under
§258.57(b) cannot be practically achieved
with any currently available methods;
(2) Implement alternate measures to
control exposure of humans or the
environment to residual contamination,
as necessary to protect human health and
the environment; and
(3) Implement alternate measures for
control of the sources of contamination,
or for removal or decontamination of
equipment, units, devices, or structures
that are:
(i) Technically practicable; and
(ii) Consistent with the overall
objective of the remedy.
(4) Notify the State Director within 14
days that a report justifying the
alternative measures prior to
implementing the alternative measures
has been placed in the operating record.
(d) All solid wastes that are managed
pursuant to a remedy required under
§258.57, or an interim measure required
under §258.58(a)(3), shall be managed in
a manner:
(1) That is protective of human health
and the environment; and
(2) That complies with applicable RCRA
requirements.
5.20.2 Applicability
The requirements of the alternative
measures are applicable when it becomes
apparent that the remedy selected will not
achieve the GWPSs or other significant
objectives of the remedial program (e.g.,
protection of sensitive receptors). In
determining that the selected corrective
action approach will not achieve desired
results, the owner or operator must
implement alternate corrective measures to
achieve the GWPSs. If it becomes evident
that the cleanup goals are not technically
obtainable by existing practicable
technology, the owner or operator must
implement actions to control exposure of
humans or the environment from residual
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contamination and to control the sources of
contamination. Prior to implementing
alternative measures, the owner or operator
must notify the Director of an approved
State within 14 days that a report justifying
the alternative measures has been placed in
the operating record.
All wastes that are managed by the MSWLF
unit during corrective action, including
interim and alternative measures, must be
managed according to applicable RCRA
requirements in a manner that is protective
of human health and the environment.
5.20.3 Technical Considerations
An owner or operator is required to continue
the assessment monitoring program during
the remedial action. Through monitoring,
the short and long term success of the
remedial action can be gauged against
expected progress. During the remedial
action, it may be necessary to install
additional ground-water monitoring wells or
pumping or injection wells to adjust to
conditions that vary from initial assessments
of the ground-water flow system. As
remediation progresses and data are
compiled, it may become evident that the
remediation activities will not protect
human health and the environment, meet
GWPSs, control sources of contamination,
or comply with waste management
standards. The reasons for unsatisfactory
results may include:
• Refractory compounds that are not
amenable to removal or destruction
(detoxification)
• The presence of compounds that
interfere with treatment methods
identified for target compounds
• Inappropriately applied technology
• Failure of source control measures to
achieve desired results
• Failure of ground-water control systems
to achieve adequate containment or
removal of contaminated ground water
• Residual concentrations above GWPSs
that cannot be effectively reduced further
because treatment efficiencies are too
low
• Transformation or degradation of target
compounds to different forms that are
not amenable to further treatment by
present or alternative technologies.
The owner or operator should compare
treatment assumptions with existing
conditions to determine if assumptions
adequately depict site conditions. If
implementation occurred as designed, the
owner or operator should attempt to modify
or upgrade existing remedial technology to
optimize performance and to improve
treatment effectiveness. If the existing
technology is found to be unable to meet
remediation objectives, alternative
approaches must be evaluated that could
meet these objectives while the present
remediation is continued. During this re-
evaluation period, the owner or operator
may suspend treatment only if continuation
of remedial activities clearly increases the
threat to human health and the environment.
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5.21 IMPLEMENTATION OF THE
CORRECTIVE ACTION
PROGRAM
40 CFR §258.58 (e)-(g)
5.21.1 Statement of Regulation
(e) Remedies selected pursuant to
§258.57 shall be considered complete
when:
(1) The owner or operator complies with
the ground-water protection standards
established under §§258.55(h) or (i) at all
points within the plume of contamination
that lie beyond the ground-water
monitoring well system established under
§258.51(a).
(2) Compliance with the ground-water
protection standards established under
§§258.55(h) or (i) has been achieved by
demonstrating that concentrations of
Appendix II constituents have not
exceeded the ground-water protection
standard(s) for a period of three
consecutive years using the statistical
procedures and performance standards in
§258.53(g) and (h). The Director of an
approved State may specify an
alternative length of time during which
the owner or operator must demonstrate
that concentrations of Appendix II
constituents have not exceeded the
ground-water protection standard(s)
taking into consideration:
(i) Extent and concentration of the
release(s);
(ii) Behavior characteristics of the
hazardous constituents in the ground
water;
(iii) Accuracy of monitoring or
modeling techniques, including any
seasonal, meteorological, or other
environmental variabilities that may
affect the accuracy; and
(iv) Characteristics of the ground
water.
(3) All actions required to complete the
remedy have been satisfied.
(f) Upon completion of the remedy, the
owner or operator must notify the State
Director within 14 days that a
certification that the remedy has been
completed in compliance with the
requirements of §258.58(e) has been
placed in the operating record. The
certification must be signed by the owner
or operator and by a qualified ground-
water specialist or approved by the
Director of an approved State.
(g) When, upon completion of the
certification, the owner or operator
determines that the corrective action
remedy has been completed in accordance
with the requirements under paragraph
(e) of this section, the owner or operator
shall be released from the requirements
for financial assurance for corrective
action under §258.73.
§258.59 [Reserved].
5.21.2 Applicability
These criteria apply to facilities conducting
corrective action. Remedies are considered
complete when, after 3 consecutive years of
monitoring (or an alternative length of time
as identified by the Director), the results
show significant statistical evidence that
ill
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Subpart E
Appendix II constituent concentrations are
below the GWPSs. Upon completion of all
remedial actions, the owner or operator
must certify to such, at which point the
owner or operator is released from financial
assurance requirements.
5.21.3 Technical Considerations
The regulatory period of compliance is 3
consecutive years at all points within the
contaminant plume that lie beyond the
ground-water monitoring system unless the
Director of an approved State specifies an
alternative length of time. Compliance is
achieved when the concentrations of
Appendix II constituents do not exceed the
GWPSs for a predetermined length of time.
Statistical procedures in §258.53 must be
used to demonstrate compliance with the
GWPSs.
The preferred statistical
comparison is to construct a
method for
99 percent
confidence interval around the mean of the
last 3 years of data and compare the upper
limit of the confidence interval to the
GWPS. An upper limit less than the GWPS
is considered significant evidence that the
standard is no longer being exceeded. The
confidence interval must be based on the
appropriate model describing the
distribution of the data.
Upon completion of the remedy, including
meeting the GWPS at all points within the
contaminant plume, the owner or operator
must notify the State Director within
fourteen days that a certification that the
remedy has been completed has been placed
in the operating record. The certification
must be signed by the owner or operator and
a qualified ground-water scientist or
approved by the Director of an approved
State. Upon completion of the remedial
action, in accordance with §258.58(e), the
owner or operator is released from the
financial assurance requirements pertaining
to corrective actions.
The Director of an approved State may
require an alternate time period (other than
3 years) to demonstrate compliance. In
determining an alternate period the Director
must consider the following:
• The extent and concentration of the
release(s)
• The behavior characteristics (fate and
transport) of the hazardous constituents
in the ground water (e.g., mobility,
persistence, toxicity, etc.)
• Accuracy of monitoring or modeling
techniques, including any seasonal,
meteorological or other environmental
variabilities that may affect accuracy
• The characteristics of the ground water
(e.g., flow rate, pH, etc.).
Consideration of these factors may result in
an extension or shortening of the time
required to show compliance with
remediation objectives.
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Ground-Water Monitoring and Corrective Action
5.22 FURTHER INFORMATION
5.22.1 References
Aitchison, J., and J.A.C. Brown (1969). "The Lognormal Distribution"; Cambridge University
Press; Cambridge.
American Water Works Association (1984). "Abandonment of Test Holes, Partially Completed
Wells and Completed Wells." Appendix I. American Water Works Association Standard for
Water Wells, American Water Works Association, Denver, CO, pp 45-47.
Barari, A., and L.S. Hedges (1985). "Movement of Water in Glacial Till." Proceedings of the
17th International Congress of International Association of Hydrogeologists.
Barcelona, M.J., J.A. Helfrich and E.E. Garske, (1985). "Sampling Tube Effects on
Groundwater Samples"; Analytical Chemistry 47(2): 460-464.
Barcelona, M.J., J.P. Gibb, J.A. Helfrich, and E.E. Garske, (1985b). "Practical Guide for
Ground-Water Sampling," USEPA, Cooperative Agreement #CR-809966-01, EPA/600/2-
85/104, 169pp.
Barcelona, M.J., et al. 1990. Contamination of Ground Water: Prevention. Assessment.
Restoration. Pollution Technology Review No. 184, Noyes Data Corporation, Park Ridge, NJ,
213 pp.
Cantor, L.W., R.C. Knox, and D.M. Fairchild (1987). Ground-Water Quality Protection. Lewis
Publishers, Inc., Chelsea, MI.
Cooper, H.H., Jr., and C.E. Jacob (1946). "A Generalized Graphical Method for Evaluating
Formation Constants and Summarizing Well-Field History." American Geophys. Union Trans.,
V. 27, No. 4.
Daniel, D.E., H.M. Liljestrand, G.P. Broderick, and J.J. Bounders, Jr. (1988). "Interaction of
Earthen Linear Materials with Industrial Waste Leachate in Hazardous Waste and Hazardous
Materials," Vol. 5, No. 2.
Dixon, W.J. and F.J. Massey, Jr. (1969). "Introduction to Statistical Analysis"; 3rd Edition;
McGraw-Hill Book Co.; New York, New York.
Driscoll, F.G., (1986). "Groundwater and Wells"; Johnson and Johnson; St. Paul, Minnesota.
Eckenfelder, W.W., Jr., (1989). Industrial Water Pollution Control. McGraw-Hill, Inc., Second
Edition.
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Subpart E
Fetter, C.W., Jr. (1980). Applied Hydrogeology. Charles E. Merrill Publishing Co., Columbus,
OH.
Freeze, R.A. and J.A. Cherry, (1979). Groundwater: Prentice-Hall, Inc.; Englewood Cliffs,
New Jersey.
Gibbons, J.D., (1976). "Nonparametric Methods for Quantitative Analysis"; Holt, Rinehart, and
Winston Publishing Co.; New York, New York.
Gilbert, R.O., (1987). Statistical Methods for Environmental Pollution Monitoring: Van
Nostrand Reinhold Co.; New York, New York.
Heath, R.C. (1982). Basic Ground-Water Hydrology. U.S. Geological Survey Water Supply
Paper 2220, 84pp.
Hsieh, P.A., and S.P. Neuman (1985). "Field Determination of the Three - Dimensional
Hydraulic Conductivity Teasor of Anisotropic Media." Water Resources Research, V. 21, No.
11.
Kearl, P.M., N.E. Korte, and T.A. Cronk. 1992. "Suggested Modifications to Ground Water
Sampling Procedures Based on Observations from the Colloidal Borescope." Ground-Water
Monitoring Review, Spring, pp. 155-160.
Kruseman, G.P., and N. A. de Ridder (1989). "Analysis and Evaluation of Pumping Test Data,"
International Institute for Land Reclamation and Improvement/ILRI, Bulletin II, 4th Edition.
Lamb, B. and T. Kinney (1989). "Decommissioning Wells - Techniques and Pitfalls."
Proceedings of the Third National Outdoor Action Conference on Aquifer Restoration, Ground-
Water Monitoring and Geophysical Methods, NWWA, May 22-25, 1989, pp 217-228.
McGlew, P.J. and J.E. Thomas (1984). "Determining Contaminant Migration Pathways in
Fractured Bedrock." Proceedings of the Fifth National Conference on Management of
Uncontrolled Hazardous Waste Sites.
McWhorter, D.B., and O.K. Sunada (1977). Ground-Water Hydrology and Hydraulics. Water
Resources Publications, Fort Collins, CO.
Miller, J.C. and J.N. Miller, (1986). Statistics for Analytical Chemistry: John Wiley and Sons;
New York, New York.
Molz, F.J., O. Guven and J.G. Melville (1990). "A New Approach and Methodologies for
Characterizing the Hydrogeologic Properties of Aquifers." EPA Project Summary. EPA
600/52-90/002.
114
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Ground-Water Monitoring and Corrective Action
Molz, F.J., R.H. Norin, A.E. Hess, J.G. Melville, and O. Guven (1989) "The Impeller Meter for
Measuring Aquifer Permeability Variations: Evaluation and Comparison with Other Tests."
Water Resources Research, V 25, No. 7, pp 1677-1683.
Puls, R.W. and R.M. Powell. 1992. "Acquisition of Representative Ground Water Quality
Samples for Metals." Ground-Water Monitoring Review, Summer, pp. 167-176.
Puls, R.W., R.M. Powell, D.A. Clark, and C.J. Paul. 1991. "Facilitated Transport of Inorganic
Contaminants in Ground Water: Part II." Colloidal Transport, EPA/600/M-91/040, 12pp.
Puls, R.W., and MJ. Barcelona. 1989a. "Filtration of Ground Water Samples for Metals
Analysis." Hazardous Waste and Hazardous Materials, v. 6, No. 4.
Puls, R.W., and MJ. Barcelona. 1989b. "Ground Water Sampling for Metals Analysis."
USEPA Superfund Ground Water Issue, EPA/504/4-89/001, 6 pp.
Sevee, J. (1991). "Methods and Procedures for Defining Aquifer Parameters," in D.M. Nielsen,
ed., Practical Handbook of Ground-Water Monitoring. Lewis Publishers, Chelsea, MI.
USEPA (1975). Manual of Water Well Construction Practices. USEPA Office of Water Supply,
Report No. EPA-570/9-75-001, 156 pp.
USEPA, (1985). "Handbook: Remedial Action at Waste Disposal Sites"; EPA/540/G-88/003;
U.S. EPA; Office of Emergency and Remedial Response; Washington, D.C.
USEPA, (1986a). "RCRA Groundwater Monitoring Technical Enforcement Guidance
Document"; Office of Solid Waste and Emergency Response - 9950.1.
USEPA, (1986b). "Test Methods for Evaluating Solid Waste - Physical/Chemical Methods";
EPA SW-846, 3rd edition; PB88-239-233; U.S. EPA; Office of Solid Waste and Emergency
Response; Washington, D.C.
USEPA, (1986c). "Superfund Public Health Evaluation Manual"; PB87-183-125; U.S. EPA;
Office of Emergency and Remedial Response; Washington, D.C. 20460.
USEPA, (1986d). "Superfund Risk Assessment Information Directory"; PB87-188-918; U.S.
EPA; Office of Emergency and Remedial Response; Washington, D.C. 20460.
USEPA, (1988). "Guidance on Remedial Actions for Contaminated Groundwater at Superfund
Sites"; PB89-184-618; U.S. EPA; Office of Emergency and Remedial Response; Washington,
D.C.20460.
115
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Subpart E
USEPA, (1989). "Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities-
Interim Final Guidance"; EPA/530-SW-89-026; U.S. EPA; Office of Solid Waste; Washington,
D.C.
USEPA, (1989a). "RCRA Facility Investigation (RFI) Guidance; Interim Final; Vol. I
Development of an RFI Work Plan and General Considerations for RCRA Facility
Investigations"; PB89-200-299; U.S. EPA; Office of Solid Waste; Washington, D.C.
USEPA, (1989b). "RCRA Facility Investigation (RFI) Guidance; Interim Final; Vol. II - Soil,
Ground Water and Subsurface Gas Releases"; PB89-200-299; U.S. EPA; Office of Solid Waste;
Washington, D.C.
USEPA, (1989c). "Criteria for Identifying Areas of Vulnerable Hydrogeology Under the
Resource Conservation and Recovery Act, Interim Final. Appendix B -Ground-Water Flow
Net/Flow Line Construction and Analysis."
USEPA, (1989d). "RCRA Facility Investigation (RFI) Guidance; Vol IV: Case Study
Examples;" PB89-200-299; U.S. EPA; Office of Solid Waste; Washington, D.C.
USEPA, (1989e). "Practical Guide for Assessing and Remediating Contaminated Sites - Draft";
U.S. EPA; Waste Management Division, Office of Solid Waste, 401 M Street, S.W.;
Washington, D.C. May 1989.
USEPA, (1989f). "Handbook of Suggested Practices for the Design and Installation of Ground-
Water Monitoring Wells"; PB90-159-807; U.S EPA; Office of Research and Development;
Washington, D.C.
USEPA, (1990). "Handbook: Groundwater Vol I;" EPA/625/6-90/016a; U.S. EPA; Office of
Research and Development; Cincinnati, Ohio.
USEPA, (1991). "Handbook: Groundwater Vol II"; EP A/625/6-90/016b; U.S. EPA; Office of
Research and Development; Cincinnati, Ohio.
USEPA, (1992a). "RCRA Ground-Water Monitoring: Draft Technical Guidance"; EPA/530-R-
93-001; U.S. EPA; Office of Solid Waste; Washington, D.C. PB93-139-350.
USEPA, (1992b). "Statistical Training Course for Ground-Water Monitoring Data Analysis",
EPA/530-R-93-003; U.S. EPA; Office of Solid Waste; Washington, D.C.
USEPA, (1992c). "User Documentation of the Ground-Water Information Tracking System
(GRITS) with Statistical Analysis Capability, GRITSTAT Version 4.2;" EPA/625/11-91/002;
USEPA Office of Research and Development, Center for Environmental Research, ORD
Publications.
116
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Ground-Water Monitoring and Corrective Action
USGS, (1989). "Chapter C2, Computer Model of Two-Dimensional Solute Transport and
Dispersion in Groundwater"; L.F. Konikow and J.D. Bredehoeft; Book 7; U.S. Geological
Survey; U.S. Department of Interior.
Way, S.C., and C.R. McKee (1982). "In-Situ Determination of Three-Dimensional Aquifer
Permeabilities." Ground Water, V. 20, No. 5.
117
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Subpart E
118
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CHAPTER 6
SUBPART F
CLOSURE AND POST-CLOSURE
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CHAPTER 6
SUBPART F
TABLE OF CONTENTS
6.1 INTRODUCTION 322
62. FINAL COVER DESIGN 40 CFR §258.60(a) 322
6.2.1 Statement of Regulation 322
6.2.2 Applicability 323
6.2.3 Technical Considerations 323
Infiltration Layer 324
Geomembranes 329
Erosion Layer 330
63. ALTERNATIVE FINAL COVER DESIGN 40 CFR §258.60(b) 332
6.3.1 Statement of Regulation 332
6.3.2 Applicability 332
6.3.3 Technical Considerations 333
Other Considerations 333
Drainage Layer 333
Gas Vent Layer 335
Biotic Layer 336
Settlement and Subsidence 336
Sliding Instability 337
6A CLOSURE PLAN 40 CFR §258.60(c)-(d) 338
6.4.1 Statement of Regul ati on 338
6.4.2 Applicability 338
6.4.3 Technical Considerations 338
6J. CLOSURE CRITERIA 40 CFR §258.60(e)-(j) 339
6.5.1 Statement of Regulation 339
6.5.2 Applicability 340
6.5.3 Technical Considerations 341
6J> POST-CLOSURE CARE REQUIREMENTS 40 CFR $258.61 342
6.6.1 Statement of Regulation 342
6.6.2 Applicability 343
6.6.3 Technical Considerations 343
320
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6.7 POST-CLOSURE PLAN 40 CFR §258.61(c)-(e) 345
6.7.1 Statement of Regulation 345
6.7.2 Applicability 346
6.7.3 Technical Considerations 346
6.8 FURTHER INFORMATION 348
6.8.1 References 348
6.8.2 Organizations 349
6.8.3 Models 349
6.8.4 Databases 349
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CHAPTER 6
SUBPART F
CLOSURE AND POST-CLOSURE
6.1 INTRODUCTION
The criteria for landfill closure focus on two central themes: (1) the need to establish low-
maintenance cover systems and (2) the need to design a final cover that minimizes the
infiltration of precipitation into the waste. Landfill closure technology, design, and maintenance
procedures continue to evolve as new geosynthetic materials become available, as performance
requirements become more specific, and as limited performance history becomes available for
the relatively small number of landfills that have been closed using current procedures and
materials. Critical technical issues that must be faced by the designer include the:
• Degree and rate of post-closure settlement and stresses imposed on soil liner components;
• Long-term durability and survivability of cover system;
• Long-term waste decomposition and management of landfill leachate and gases; and
• Environmental performance of the combined bottom liner and final cover system.
Full closure and post-closure care requirements apply to all MSWLF units that receive wastes
on or after October 9, 1993. For MSWLF units that stop receiving wastes prior to October 9,
1993, only the final cover requirements of §258.60(a) apply.
*[NOTE: EPA finalized several revisions to 40 CFR Part 258 on October 1, 1993 (58 FR
51536) and issued a correction notice on October 14, 1993 (58 FR 53136). Questions regarding
the final rule and requests for copies of the Federal Register notices should be made to the
RCRA/Superfund Hotline at (800) 424-9346. These revisions delay the effective date for some
categories of landfills. More detail on the content of the revisions is included in the
introduction.
6.2 FINAL COVER DESIGN
40 CFR §258.60(a)
6.2.1 Statement of Regulation
(a) Owners or operators of all
MSWLF units must install a final cover
system that is designed to minimize
infiltration and erosion. The final cover
system must be designed and constructed
to:
(1) Have permeability less than or
equal to the permeability of any bottom
liner system or natural subsoils present,
or a permeability no greater than 1 x 10 5
cm/sec, whichever is less, and
(2) Minimize infiltration through
the closed MSWLF unit by the use of an
infiltration layer that contains a
minimum of 18-inches of an earthen
material, and
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Closure and Post-Closure
(3) Minimize erosion of the final
cover by the use of an erosion layer that
contains a minimum 6-inches of earthen
material that is capable of sustaining
native plant growth.
6.2.2 Applicability
These final cover requirements apply to all
MSWLF units required to close in
accordance with Part 258, including
MSWLF units that received wastes after
October 9, 1991 but stopped receiving
wastes prior to October 9, 1993. Units
closing during this two-year period are
required to install a final cover.
The final cover system required to close a
MSWLF unit, whether the unit is an existing
unit, a new unit, or a lateral expansion of an
existing unit, must be composed of an
infiltration layer that is a minimum of 18
inches thick, overlain by an erosion layer
that is a minimum of 6 inches thick.
The final cover should minimize, over the
long term, liquid infiltration into the waste.
The final cover must have a hydraulic
conductivity less than or equal to any
bottom liner system or natural subsoils
present to prevent a "bathtub" effect. In no
case can the final cover have a hydraulic
conductivity greater than 1 x 10"5 cm/sec
regardless of the permeability of underlying
liners or natural subsoils. If a synthetic
membrane is in the bottom liner, there must
be a flexible membrane liner (FML) in the
final cover to achieve a permeability that is
less than or equal to the permeability of the
bottom liner. Currently, it is not possible to
construct an earthen liner with a
permeability less than or equal to a synthetic
membrane.
In approved States, an alternate cover
system may be approved by the Director
(see Section 6.3).
6.2.3 Technical Considerations
Design criteria for a final cover system
should be selected to:
• Minimize infiltration of precipitation
into the waste;
• Promote good surface drainage;
• Resist erosion;
• Control landfill gas migration and/or
enhance recovery;
• Separate waste from vectors (e.g.,
animals and insects);
• Improve aesthetics;
• Minimize long-term maintenance;
• Protect human health and the
environment; and
• Consider final use.
The first three points are directly related to
the regulatory requirements. The other
points typically are considered in designing
cover systems for landfills.
Reduction of infiltration in a well-designed
final cover system is achieved through good
surface drainage and run-off with minimal
erosion, transpiration of water by plants in
the vegetative cover and root zone, and
restriction of percolation through earthen
material. The cover system should be
designed to provide the desired level of
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Subpart F
long-term performance with minimal
maintenance. Surface water run-off should
be properly controlled to prevent excessive
erosion and soil loss. Establishment of a
healthy vegetative layer is key to protecting
the cover from erosion. However,
consideration also must be given to
selecting plant species that are not deeply
rooted because they could damage the
underlying infiltration layer. In addition,
the cover system should be geotechnically
stable to prevent failure, such as sliding,
that may occur between the erosion and
infiltration layers, within these layers, or
within the waste. Figure 6-1 illustrates the
minimum requirements for the final cover
system.
Infiltration Layer
The infiltration layer must be at least 18
inches thick and consist of earthen material
that has a hydraulic conductivity
(coefficient of permeability) less than or
equal to the hydraulic conductivity of any
bottom liner system or natural subsoils.
MSWLF units with poor or non-existent
bottom liners possessing hydraulic
conductivities greater than 1 x 10"5 cm/sec
must have an infiltration layer that meets the
1 x 10"5 cm/sec minimum requirement.
Figure 6-2 presents an example of a final
cover with a hydraulic conductivity less
than or equal to the hydraulic conductivity
of the bottom liner system.
For units that have a composite liner with a
FML, or naturally occurring soils with very
low permeability (e.g., 1 x 10"8 cm/sec), the
Agency anticipates that the infiltration layer
in the final cover will include a synthetic
membrane as part of the final cover. A final
cover system for a MSWLF unit with a
FML combined with a soil liner and
leachate collection system is presented in
Figure 6-3a. Figure 6-3b shows a final
cover system for a MSWLF unit that has
both a double FML and double leachate
collection system.
The earthen material used for the infiltration
layer should be free of rocks, clods, debris,
cobbles, rubbish, and roots that may
increase the hydraulic conductivity by
promoting preferential flow paths. To
facilitate run-off while minimizing erosion,
the surface of the compacted soil should
have a minimum slope of 3 percent and a
maximum slope of 5 percent after allowance
for settlement. It is critical that side slopes,
which are frequently greater than 5 percent,
be evaluated for erosion potential.
Membrane and clay layers should be placed
below the maximum depth of frost
penetration to avoid freeze-thaw effects
(U.S. EPA, 1989b). Freeze-thaw effects
may include development of microfractures
or realignment of interstitial fines, which
can increase the hydraulic conductivity of
clays by more than an order of magnitude
(U.S. EPA, 1990). Infiltration layers may
be subject to desiccation, depending on
climate and soil water retention in the
erosion layer. Fracturing and volumetric
shrinking of the clay due to water loss may
increase the hydraulic conductivity of the
infiltration layer. Figure 6-4 shows the
regional average depth of frost penetration;
however, these values should not be used to
find the maximum depth of frost penetration
for a particular area of concern at a
particular site. Information regarding the
maximum depth of frost penetration for a
particular area can be obtained from the Soil
Conservation Service, local utilities,
construction companies, and local
universities.
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Closure and Post-Closure
Erosion Layer:
Min. 6" Soil
• Infiltration Layer:
Min. 18" Compacted Soil (1 x
10-5 cm/sec)
Existing Subgrade
Figure 6-1
Example of Minimum Final Cover Requirements
325
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Subpart F
Erosion Layer: ^^^^^^^^^^^^^^^^ Infiltration Layer:
Min. 6" Soil ^ ' ^^F^^^^""""^^"^^^^^^^^ - Min-18" Compacted Soil (1 x 10-6
cm / sec)
=?/ . «=
2 Feet Compacted
Soil (1 x 10-6 cm/sec)
Figure 6-2
Example of Final Cover With Hydraulic Conductivity(K) < K of Liner
326
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Erosion Layer
To sustain vegetation
FML
Infiltration Layer: Min. 18"
compacted soil (1 x 10-5
cm/sec)
FML
Feet Compacted Soil
(1 x 10-7 cm/sec)
Figure 6-3a
Example of Final Cover Design for a MSWLF Unit With a FML
and Leachate Collection System
Erosion Layer:
To sustain vegetation
FML
2 Feet Compacted
Soil (1 x 10-7 cm/sec)
Infiltration Layer: Min. 18"
compacted soil (1 x
10-5cm/sec)
FML
12" Compacted
Soil (1 x 1.0-7 cm/sec)
Figure 6-3b
Example of Final Cover Design for a MSWLF Unit With a Double FML and
Leachate Collection System
327
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Subpart F
Source: USEPA (1989)
Figure 6-4
Regional Depth of Frost Penetration in Inches
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Closure and Post-Closure
The infiltration layer is designed and
constructed in a manner similar to that used
for soil liners (U.S. EPA, 1988), with the
following differences:
• Because the cover is generally not
subject to large overburden loads, the
issue of compressive stresses is less
critical unless post-closure land use will
entail construction of objects that exert
large amounts of stress.
• The soil cover is subject to loadings
from settlement of underlying
materials. The extent of settlement
anticipated should be evaluated and a
closure and post-closure maintenance
plan should be designed to compensate
for the effects of settlement.
• Direct shear tests performed on
construction materials should be
conducted at lower shear stresses than
those used for liner system designs.
The design of a final cover is site-specific
and the relative performance of cover design
options may be compared and evaluated by
the HELP (Hydrologic Evaluation of
Landfill Performance) model. The HELP
model was developed by the U.S. Army
Corps of Engineers for the U.S. EPA and is
widely used for evaluating expected
hydraulic performance of landfill
cover/liner systems (U.S. EPA, 1988).
The HELP program calculates daily,
average, and peak estimates of water
movement across, into, through, and out of
landfills. The input parameters for the
model include soil properties, precipitation
and other climatological data, vegetation
type, and landfill design information.
Default climatologic and soil data are
available but should be verified as
reasonable for the site modeled. Outputs
from the model include precipitation, run-
off, percolation through the base of each
cover layer subprofile, evapotranspiration,
and lateral drainage from each profile. The
model also calculates the maximum head on
the barrier soil layer of each subprofile and
the maximum and minimum soil moisture
content of the evaporative zone. Data from
the model are presented in a tabular report
format and include the input parameters
used and a summary of the simulation
results. Results are presented in several
tables of daily, monthly, and annual totals
for each year specified. A summary of the
outputs also is produced, including average
monthly totals, average annual totals, and
peak daily values for several simulation
variables (U.S. EPA, 1988).
The HELP model may be used to estimate
the hydraulic performance of the cover
system designed for a MSWLF unit. Useful
information provided by the HELP model
includes surface run-off, duration and
quantity of water storage within the erosion
layer, and net infiltration through the cover
system to evaluate whether leachate will
accumulate within the landfill. For the
model to be used properly, the HELP Model
User's Guide and documentation should be
consulted.
Geomembranes
If a geomembrane is used as an infiltration
layer, the geomembrane should be at least
20 mils (0.5 mm) in thickness, although
some geomembrane materials may need to
be a greater thickness (e.g., a minimum
thickness of 60 mils is recommended for
HOPE because of the difficulties in making
consistent field seams in thinner material).
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Subpart F
Increased thickness and tensile strengths
may be necessary to prevent failure under
stresses caused by construction and waste
settlement during the post-closure care
period. The strength, resistance to sliding,
hydraulic performance, and actual thickness
of geomembranes should be carefully
evaluated. The quality and performance of
some textured sheets may be difficult to
evaluate due to the variability of the
textured surface.
Erosion Layer
The thickness of the erosion layer is
influenced by depth of frost penetration and
erosion potential. This layer is also used to
support vegetation. The influence of frost
penetration was discussed previously on
page 6-3.
Erosion can adversely affect the
performance of the final cover of a MSWLF
unit by causing rills that require
maintenance and repair. As previously
stated, a healthy vegetative layer can protect
the cover from erosion; conversely, severe
erosion can affect the vegetative growth.
Extreme erosion may lead to the exposure of
the infiltration layer, initiate or contribute to
sliding failures, or expose the waste.
Anticipated erosion due to surface water
run-off for given design criteria may be
approximated using the USDA Universal
Soil Loss Equation (U.S. EPA, 1989a). By
evaluating erosion loss, the design may be
optimized to reduce maintenance through
selection of the best available soil materials
or by initially adding excess soil to increase
the time required before maintenance is
needed. Parameters in the equation include
the following:
X = RKLSCP
where X = Soil loss (tons/acre/year)
R = Rainfall erosion index
K = Soil erodibility index
L = Slope length factor
S = Slope gradient factor
C = Crop management factor
P = Erosion control practice.
Values for the Universal Soil Loss Equation
parameters may be obtained from the U. S.
Soil Conservation Service (SCS) technical
guidance document entitled "Predicting
Rainfall Erosion Losses, Guidebook 537"
(1978), available at local SCS offices
located throughout the United States. State
or local SCS offices can provide factors to
be used in the soil loss equation that are
appropriate to a given area of the country.
Figure 6-5 can be used to find the soil loss
ratio due to the slope of the site as used in
the Universal Soil Loss Equation. Loss
from wind erosion can be determined by the
following equation (U.S. EPA, 1989a):
X = I'K'C'L'V
where
X =
r =
K' =
c =
L' =
V' =
Annual wind erosion
Field roughness factor
Soil erodibility index
Climate factor
Field length factor
Vegetative cover factor.
A vegetative cover not only improves the
appearance of the site, but it also controls
erosion of the final cover; a vegetated cover
may require only minimal maintenance.
The vegetation component of the erosion
layer should have the following
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Closure and Post-Closure
0 100
200 300
400 500 600 700
800
Source L'SEPA. 1989
iOpe Length (Feet)
Figure 6-5
Soil Erosion Due to Slope
331
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Subpart F
specifications
EPA, 1989b):
and characteristics (U.S.
• Locally adapted perennial plants that
are resistant to drought and temperature
extremes;
• Roots that will not disrupt the low-
permeability layer;
• The ability to thrive in low-nutrient soil
with minimum nutrient addition;
• Sufficient plant density to minimize
cover soil erosion;
• The ability to survive and function with
little or no maintenance (i.e., self-
supportive); and
• Sufficient variety of plant species to
continue to achieve these characteristics
and specifications over time.
The use of deep-rooted shrubs and trees is
generally inappropriate because the root
systems may penetrate the infiltration layer
and create preferential pathways of
percolation. Plant species with fibrous or
branching root systems are suited for use at
landfills, and can include a large variety of
grasses, herbs (i.e., legumes), and shallow-
rooted plants. The suitable species in a
region will vary, dependent on climate and
site-specific factors such as soil type and
slope gradient and aspect. The timing of
seeding (spring or fall in most climates) is
critical to successful germination and
establishment of the vegetative cover (U.S.
EPA, 1989b). Temporary winter covers
may be grown from fast-growing seed stock
such as winter rye.
Selection of the soil for the vegetative cover
(erosion layer) should include consideration
of soil type, nutrient and pH levels, climate,
species of the vegetation selected, mulching,
and seeding time. Loamy soils with a
sufficient organic content generally are
preferred. The balance of clay, silt, and
sand in loamy soils provides an environment
conducive to seed germination and root
growth (USEPA, 1988).
The Director of an approved State can allow
alternate designs to address vegetative
problems (e.g., the use of pavement or other
material) in areas that are not capable of
sustaining plant growth.
6.3 ALTERNATIVE FINAL COVER
DESIGN
40 CFR §258.60(b)
6.3.1 Statement of Regulation
(b) The Director of an approved
State may approve an alternative final
cover design that includes:
(1) An infiltration layer that
achieves an equivalent reduction in
infiltration as the infiltration layer
specified in paragraphs (a)(l) and (a)(2)
of this section, and
(2) An erosion layer that provides
equivalent protection from wind and
water erosion as the erosion layer
specified in (a)(3) of this section.
6.3.2 Applicability
The Director of an approved State may
approve alternative final cover systems that
can achieve equivalent performance as
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Closure and Post-Closure
the minimum design specified in
§258.60(a). This provides an opportunity to
incorporate different technologies or
improvements into cover designs, and to
address site-specific conditions.
6.3.3 Technical Considerations
An alternative material and/or an alternative
thickness may be used for an infiltration
layer as long as the infiltration layer
requirements specified in §258.60(a)(l) and
(a)(2) are met.
For example, an armored surface (e.g., one
composed of cobble-rich soils or soils rich
in weathered rock fragments) could be used
as an alternative to the six-inch erosion
layer. An armored surface, or hardened cap,
is generally used in arid regions or on steep
slopes where the establishment and
maintenance of vegetation may be hindered
by lack of soil or excessive run-off
The materials used for an armored surface
typically are (U.S. EPA, 1989b):
• Capable of protecting the underlying
infiltration layer during extreme
weather events of rainfall and/or wind;
• Capable of accommodating settlement
of the underlying material without
compromising the component;
• Designed with a surface slope that is
approximately the same as the
underlying soil (at least 2 percent
slope); and
• Capable of controlling the rate of soil
erosion.
The erosion layer may be made of asphalt or
concrete. These materials promote run-off
with negligible erosion. However, asphalt
and concrete deteriorate due to thermal
expansion and due to deformation caused by
subsidence. Crushed rock may be spread
over the landfill cover in areas where
weather conditions such as wind, heavy
rain, or temperature extremes commonly
cause deterioration of vegetative covers
(U.S. EPA, 1989b).
Other Considerations
Additional Cover System Components
To reduce the generation of post-closure
leachate to the greatest extent possible,
owners and operators can install a
composite cover made of a geomembrane
and a soil component with low hydraulic
conductivity. The hydraulic properties of
these components are discussed in Chapter
4 (Subpart D).
Other components that may be used in the
final cover system include a drainage layer,
a gas vent layer, and a biotic barrier layer.
These components are discussed in the
following sections and are shown in Figure
6-6.
Drainage Layer
A permeable drainage layer, constructed of
soil or geosynthetic drainage material, may
be constructed between the erosion layer
and the underlying infiltration layer. The
drainage layer in a final cover system
removes percolating water that has
infiltrated through the erosion layer after
surface run-off and evapotranspiration
losses. By removing water in contact with
the low-permeability layer, the potential for
333
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20-mii FML—
or
60-mi I HDPE
60 cm
30cm
30cm
60cm
\ N N S \ -WS
/ f S /->-.••—
N. \ \ S X^^S
}
Vegetation/
Soil Top Layer
Filler Layer
Biotic Barrier Layer
Drainage Layer
- Low-Permeability
FML/Soil Layer
Gas Venting Layer
Waste
Figure 6-6
Example of an Alternative Final Cover Design
-------
Closure and Post-Closure
leachate generation is diminished. Caution
should be taken when using a drainage layer
because this layer may prematurely draw
moisture from the erosion layer that is
needed to sustain vegetation.
If a drainage layer is used, owners or
operators should consider methods to
minimize physical clogging of the drainage
layer by root systems or soil particles. A
filter layer, composed of either a low
nutrient soil or geosynthetic material, may
be placed between the drainage layer and
the cover soil to help minimize clogging.
If granular drainage layer material is used,
the filter layer should be at least 12 in. (30
cm) thick with a hydraulic conductivity in
the range of 1 x 10"2 cm/sec to 1 x 10"3
cm/sec. The layer should be sloped at least
3 percent at the bottom of the layer. Greater
thickness and/or slope may be necessary to
provide sufficient drainage flow as
determined by site-specific modeling (U.S.
EPA, 1989b). Granular drainage material
will vary from site to site depending on the
type of material that is locally available and
economical to use. Typically, the material
should be no coarser than 3/8 inch (0.95
cm), classified according to the Universal
Soil Classification System (USCS) as type
SP, smooth and rounded, and free of debris
that could damage an underlying
geomembrane (U.S. EPA, 1989b).
Crushed stone generally is not appropriate
because of the sharpness of the particles. If
the available drainage material is of poor
quality, it may be necessary to increase the
thickness and/or slope of the drainage layer
to maintain adequate drainage. The HELP
model can be used as an analytical tool to
evaluate the relative expected performance
of alternative final cover designs.
If geosynthetic materials are used as a
drainage layer, the fully saturated effective
transmissivity should be the equivalent of
12 inches of soil (30 cm) with a hydraulic
conductivity range of 1 x 10"2 cm/sec to 1 x
10"3 cm/sec. Transmissivity can be
calculated as the hydraulic conductivity
multiplied by the drainage layer thickness.
A filter layer (preferably a non-woven
needle punch fabric) should be placed above
the geosynthetic material to minimize
intrusion and clogging by roots or by soil
material from the top layer.
Gas Vent Layer
Landfill gas collection systems serve to
inhibit gas migration. The gas collection
systems typically are installed directly
beneath the infiltration layer. The function
of a gas vent layer is to collect combustible
gases (methane) and other potentially
harmful gases (hydrogen sulfide) generated
by micro-organisms during biological decay
of organic wastes, and to divert these gases
via a pipe system through the infiltration
layer. A more detailed discussion
concerning landfill gas, including the use of
active and passive collection systems, is
provided in Chapter 3 (Subpart C).
The gas vent layer is usually 12 in. (30 cm)
thick and should be located between the
infiltration layer and the waste layer.
Materials used in construction of the gas
vent layer should be medium to coarse-
grained porous materials such as those used
in the drainage layer. Geosynthetic
materials may be substituted for granular
materials in the vent layer if equivalent
performance can be demonstrated. Venting
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Subpart F
to an exterior collection point can be
provided by means such as horizontal pipes
patterned laterally throughout the gas vent
layer, which channel gases to vertical risers
or lateral headers. If vertical risers are used,
their number should be minimized (as they
are frequently vandalized) and located at
high points in the cross-section (U.S. EPA,
1989b). Condensates will form within the
gas collection pipes; therefore, the design
should address drainage of condensate to
prevent blockage by its accumulation in low
points.
The most obvious potential problem with
gas collection systems is the possibility of
gas vent pipe penetrations through the cover
system. Settlement within the landfill may
cause concentrated stresses at the
penetrations, which could result in
infiltration layer or pipe failure. If a
geomembrane is used in the infiltration
layer, pipe sleeves, adequate flexibility and
slack material should be provided at these
connections when appropriate.
Alternatively, if an active gas control
system is planned, penetrations may be
carried out through the sides of the cover
directly above the liner anchor trenches
where effects of settlement are less
pronounced. The gas collection system also
may be connected to the leachate collection
system, both to vent gases that may form
inside the leachate collection pipes and to
remove gas condensates that form within the
gas collection pipes. This method generally
is not preferred because if the leachate
collection pipe is full, gas will not be able to
move through the system. Landfill gas
systems are also discussed in Chapter 3
(Subpart C).
Biotic Layer
Deep plant roots or burrowing animals
(collectively called biointruders) may
disrupt the drainage and the low hydraulic
conductivity layers, thereby interfering with
the drainage capability of the layers. A 30-
cm (12-inch) biotic barrier of cobbles
directly beneath the erosion layer may stop
the penetration of some deep-rooted plants
and the invasion of burrowing animals.
Most research on biotic barriers has been
done in, and is applicable to arid areas.
Geosynthetic products that incorporate a
time-released herbicide into the matrix or on
the surface of the polymer also may be used
to retard plant roots. The longevity of these
products requires evaluation if the cover
system is to serve for longer than 30 to 50
years (USEPA, 1991).
Settlement and Subsidence
Excessive settlement and subsidence, caused
by decomposition and consolidation of the
wastes, can impair the integrity of the final
cover system. Specifically, settlement can
contribute to:
• Ponding of surface water on the cap;
• Disruption of gas collection pipe
systems;
• Fracturing of low permeability
infiltration layers; and
• Failure of geomembranes.
The degree and rate of waste settlement are
difficult to estimate. Good records
regarding the type, quantity, and location of
waste materials disposed will improve the
estimate. Settlement due to consolidation
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Closure and Post-Closure
may be minimized by compacting the waste
during daily operation of the landfill unit or
by landfilling baled waste. Organic wastes
will continue to degrade and deteriorate
after closure of the landfill unit.
Several models have been developed to
analyze the process of differential
settlement. Most models equate the layered
cover to a beam or column undergoing
deflection due to various loading conditions.
While these models are useful to designers
in understanding the qualitative relationship
between the various land disposal unit
characteristics and in identifying the
constraining factors, accurate quantitative
analytical methods have not been developed
(U.S. EPA, 1988).
If the amount of total settlement can be
estimated, either from an analytical
approach or from empirical relationships
from data collected during the operating life
of the facility, the designer should attempt
to estimate the potential strain imposed on
the cover system components. Due to the
uncertainties inherent in the settlement
analysis, a biaxial strain calculation should
be sufficient to estimate the stresses that
may be imposed on the cover system. The
amount of strain that a liner is capable of
enduring may be as low as several percent;
for geomembranes, it may be 5 to 12 percent
(U.S. EPA, 1990). Geomembrane testing
may be included as part of the design
process to estimate safety factors against
cover system failure.
The cover system may be designed with a
greater thickness and/or slope to compensate
for settlement after closure. However, even
if settlement and subsidence are considered
in the design of the final cover, ponding
may still occur after closure and can be
corrected during post-closure maintenance.
The cost estimate for post-closure
maintenance should include earthwork
required to regrade the final cover due to
total and differential settlements. Based on
the estimates of total and differential
settlements from the modeling methods
described earlier, it may be appropriate to
assume that a certain percentage of the total
area needs regrading and then incorporate
the costs into the overall post-closure
maintenance cost estimate.
Sliding Instability
The slope angle, slope length, and overlying
soil load limit the stability of component
interfaces (geomembrane with soil,
geotextile, and geotextile/soil). Soil water
pore pressures developed along interfaces
also can dramatically reduce stability. If the
design slope is steeper than the effective
friction angles between the material, sliding
instability generally will occur. Sudden
sliding has the potential to cause tears in
geomembranes, which require considerable
time and expense to repair. Unstable slopes
may require remedial measures to improve
stability as a means of offsetting potential
long-term maintenance costs.
The friction angles between various media
are best determined by laboratory direct
shear tests that represent the design loading
conditions. Methods to improve stability
include using designs with flatter slopes,
using textured material, constructing
benches in the cover system, or reinforcing
the cover soil above the membrane with
geogrid or geotextile to minimize the
driving force on the interface of concern.
Methods for applying these design features
can be found in (U.S. EPA 1989), (U.S.EPA
1991), and (Richardson and Koerner 1987).
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Subpart F
6.4 CLOSURE PLAN
40 CFR §258.60(c)-(d)
6.4.1 Statement of Regulation
(c) The owner or operator must
prepare a written closure plan that
describes the steps necessary to close all
MSWLF units at any point during their
active life in accordance with the cover
design requirements in §258.60(a) or (b),
as applicable. The closure plan, at a
minimum, must include the following
information:
(1) A description of the final
cover, designed in accordance with
§258.60(a) and the methods and
procedures to be used to install the cover;
(2) An estimate of the largest area
of the MSWLF unit ever requiring a final
cover as required under §258.60(a) at any
time during the active life;
(3) An estimate of the maximum
inventory of wastes ever on-site over the
active life of the landfill facility; and
(4) A schedule for completing all
activities necessary to satisfy the closure
criteria in §258.60.
(d) The owner or operator must
notify the State Director that a closure
plan has been prepared and placed in the
operating record no later than the
effective date of this part, or by the initial
receipt of waste, whichever is later.
6.4.2 Applicability
An owner or operator of any MSWLF unit
that receives wastes on or after October 9,
1993, must prepare a closure plan and place
the plan in the operating record. The plan
must describe specific steps and activities
that will be followed to close the unit at any
time after it first receives waste through the
time it reaches its waste disposal capacity.
The closure plan must include at least the
following information:
• A description of the final cover and the
methods and procedures to be used to
install the cover;
• An estimate of the largest area that will
have to be covered (typically this is the
area that will exist when the final full
capacity is attained); and
• A schedule for completing closure.
The area requiring cover should be
estimated for the operating period from
initial receipt of waste through closure.
The closure plan must be prepared and
placed in the operating record before
October 9, 1993 or by the initial receipt of
waste, whichever is later. The owner or
operator must notify the State Director
when the plan has been completed and
placed in the operating record.
6.4.3 Technical Considerations
The closure plan is a critical document that
describes the steps that an owner or operator
will take to ensure that all units will be
closed in a manner that is protective of
human health and the environment. Closure
plans provide the basis for cost estimates
that in turn establish the amount of financial
responsibility that must be demonstrated.
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Closure and Post-Closure
The closure plan must describe all areas of
the MSWLF unit that are subject to Part 258
regulations and that are not closed in
accordance with §258.60. Portions of the
landfill unit that have not received a final
cover must be included in the estimate. The
area to be covered at any point during the
active life of the operating unit can be
determined by examining design and
planned operation procedures and by
comparing the procedures with construction
records, operation records, and field
observations. Units are operated frequently
in phases, with some phases conducted on
top of previously deposited waste. If the
owner or operator routinely closes landfill
cells as they are filled, the plan should
indicate the greatest number of cells open at
one time.
The estimate must account for the maximum
amount of waste on-site that may need to be
disposed in the MSWLF unit over the life of
the facility (this includes any waste on-site
yet to be disposed). The maximum volume
of waste ever on-site can be estimated from
the maximum capacity of each unit and any
operational procedures that may involve
transfer of wastes to off-site facilities.
Where insufficient design, construction, and
operational records are found, areas and
volumes may be estimated from topographic
maps and/or aerial photographs.
Steps that may be included in the closure
plan are as follows:
• Notifying State Director of intent to
initiate closure §258.60(e);
• Determining the area to receive final
cover;
• Developing the closure schedule;
• Preparing construction contract
documents and securing a contractor;
• Hiring an independent registered
professional engineer to observe
closure activities and provide
certification;
• Securing borrow material;
• Constructing the cover system;
• Obtaining signed certificate and placing
it in operating record;
• Notifying State Director that certificate
was placed in operating record; and
• Recording notation in deed to land or
other similar instrument.
The closure plan should include a
description of the final cover system and the
methods and procedures that will be used to
install the cover. The description of the
methods, procedures, and processes may
include design documents; construction
specifications for the final cover system,
including erosion control measures; quality
control testing procedures for the
construction materials; and quality
assurance procedures for construction. A
general discussion of the methods and
procedures for cover installation is
presented in Section 6.3.3.
6.5 CLOSURE CRITERIA
40 CFR §258.60(e)-(j)
6.5.1 Statement of Regulation
(e) Prior to beginning closure of
each MSWLF unit as specified in
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Subpart F
§258.60(f), an owner or operator must
notify the State Director that a notice of
the intent to close the unit has been
placed in the operating record.
(f) The owner or operator must
begin closure activities of each MSWLF
unit no later than 30 days after the date
on which the MSWLF unit receives the
known final receipt of wastes or, if the
MSWLF unit has remaining capacity and
there is a reasonable likelihood that the
MSWLF unit will receive additional
wastes, no later than one year after the
most recent receipt of wastes. Extensions
beyond the one-year deadline for
beginning closure may be granted by the
Director of an approved State if the
owner or operator demonstrates that the
MSWLF unit has the capacity to receive
additional wastes and the owner or
operator has taken and will continue to
take all steps necessary to prevent threats
to human health and the environment
from the unclosed MSWLF unit.
(g) The owner or operator of all
MSWLF units must complete closure
activities of each MSWLF unit in
accordance with the closure plan within
180 days following the beginning of
closure as specified in paragraph (f).
Extensions of the closure period may be
granted by the Director of an approved
State if the owner or operator
demonstrates that closure will, of
necessity, take longer than 180 days and
he has taken and will continue to take all
steps to prevent threats to human health
and the environment from the unclosed
MSWLF unit.
(h) Following closure of each MSWLF
unit, the owner or operator must
notify the State Director that a
certification, signed by an independent
registered professional engineer or
approved by Director of an approved
State, verifying that closure has been
completed in accordance with the closure
plan, has been placed in the operating
record.
(i)(l) Following closure of all
MSWLF units, the owner or operator
must record a notation on the deed to the
landfill facility property, or some other
instrument that is normally examined
during title search, and notify the State
Director that the notation has been
recorded and a copy has been placed in
the operating record.
(2) The notation on the deed must
in perpetuity notify any potential
purchaser of the property that:
(i) The land has been used as a
landfill facility; and
(ii) Its use is restricted under
§258.61(c)(3).
(j) The owner or operator may
request permission from the Director of
an approved State to remove the notation
from the deed if all wastes are removed
from the facility.
6.5.2 Applicability
These closure requirements are applicable to
all MSWLF units that receive wastes on or
after October 9, 1993. The owner or
operator is required to:
• Notify the State Director of the intent
to close;
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Closure and Post-Closure
• Begin closure within 30 days of the last
receipt of waste (or 1 year if there is
remaining capacity and it is likely that it
will be used);
• Complete closure within 180 days
following the beginning of closure (in
approved States, the period of time to
begin or complete closure may be
extended by the Director);
• Obtain a certification, by an independent
registered professional engineer, that
closure was completed in accordance
with the closure plan;
• Place the certificate in the operating
record and notify the State Director; and
• Note on a deed (or some other
instrument) that the land was used as a
landfill and that its use is restricted.
Should all wastes be removed from the
unit in an approved State, the owner or
operator may request permission from
the Director to remove the note on the
deed.
6.5.3 Technical Considerations
Closure activities must begin within 30 days
of the last receipt of waste and must be
completed within 180 days. Some MSWLF
units, such as those in seasonal population
areas, may have remaining capacity but will
not receive the next load of waste for a
lengthy period of time. These MSWLF
units must receive waste within one year or
they must close. Extensions to both the
1-year and the 180-day requirements may be
available to owners or operators of MSWLF
units in approved States. An extension may
be granted if the owner or
operator can demonstrate that there is
remaining capacity or that additional time is
needed to complete closure. These
extensions could be granted to allow
leachate recirculation or to allow for
settlement. The owner or operator must
take, and continue to take, all steps
necessary to prevent threats to human health
and the environment from the unclosed
MSWLF unit. In general, this requirement
should be established for a unit in
compliance with the requirements of Part
258. The owner or operator may need to
demonstrate how access to the unclosed unit
will be controlled prior to closure or receipt
of waste and how the various environmental
control and monitoring systems (e.g.,
surface run-off, surface run-on, leachate
collection, gas control system, and ground-
water and gas monitoring) will be operated
and maintained while the unit remains
unclosed.
Following closure of each MSWLF unit, the
owner or operator must have a certification,
signed by an independent registered
professional engineer, verifying closure. In
approved States, the Director can approve
the certification. The certificate should
verify that closure was completed in
accordance with the closure plan. This
certification should be based on knowledge
of the closure plan, observations made
during closure, and documentation of
closure activities provided by the owner or
operator. The signed certification must be
placed in the operating record and the State
Director must be notified that the
certification was completed and placed in
the record.
After closure of all units at a MSWLF
facility, the owner or operator must record
a notation in the deed, or in records
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Subpart F
typically examined during a title search, that
the property was used as a MSWLF unit and
that its use is restricted under 40 CFR
§258.61(c)(3). Section 258.61(c)(3) states:
"... Post-closure use of the property shall
not disturb the integrity of the final cover,
liner(s), or any other components of the
containment systems or the function of the
monitoring systems unless necessary to
comply with the requirements of Part
258...and... The Director of an approved
State may approve any other disturbance if
the owner or operator demonstrates that
disturbance of the final cover, liner, or other
component of the containment system,
including any removal of waste, will not
increase the potential threat to human health
or the environment."
These restrictions are described further in
Section 6.7 (Post-Closure Plan) of this
document.
The owner or operator may request
permission from the Director of an approved
State to remove the notation to a deed. The
request should document that all wastes
have been removed from the facility. Such
documentation may include photographs,
ground-water and soil testing in the area
where wastes were deposited, and reports of
waste removal activity.
6.6 POST-CLOSURE CARE
REQUIREMENTS
40 CFR §258.61
6.6.1 Statement of Regulation
(a) Following closure of each MSWLF
unit, the owner or operator must conduct
post-closure care. Post-closure
care must be conducted for 30 years,
except as provided under paragraph (b)
of this part, and consist of at least the
following:
(1) Maintaining the integrity and
effectiveness of any final cover, including
making repairs to the cover as necessary
to correct the effects of settlement,
subsidence, erosion, or other events, and
preventing run-on and run-off from
eroding or otherwise damaging the final
cover;
(2) Maintaining and operating the
leachate collection system in accordance
with the requirements in §258.40, if
applicable. The Director of an approved
State may allow the owner or operator to
stop managing leachate if the owner or
operator demonstrates that leachate no
longer poses a threat to human health
and the environment;
(3) Monitoring the ground water
in accordance with the requirements of
Subpart E and maintaining the ground-
water monitoring system, if applicable;
and
(4) Maintaining and operating the
gas monitoring system in accordance with
the requirements of §258.23.
(b) The length of the post-closure
care period may be:
(1) Decreased by the Director of
an approved State if the owner or
operator demonstrates that the reduced
period is sufficient to protect human
health and the environment and this
demonstration is approved by the
Director of an approved State; or
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(2) Increased by the Director of an
approved State if the Director of an
approved State determines that the
lengthened period is necessary to protect
human health and the environment.
6.6.2 Applicability
Post-closure care requirements apply to
MSWLF units that stop receiving waste
after October 9, 1993. They also apply to
units that stop receiving waste between
October 9, 1991, and October 9, 1993, and
fail to complete closure within six months
of the final receipt of waste.
Post-closure care requirements are focused
on operating and maintaining the proper
functions of four systems that prevent or
monitor releases from the MSWLF unit:
• Cover system;
• Leachate collection system;
• Ground-water monitoring system; and
• Gas monitoring system.
Owners or operators must comply with these
requirements for a period of 30 years
following closure. In approved States, the
post-closure care period may be shortened if
the owner or operator demonstrates to the
satisfaction of the Director that human
health and the environment are protected.
Conversely, the Director may determine that
a period longer than 30 years is necessary.
The requirement to operate and maintain the
leachate collection system may be
eliminated by the Director of an approved
State if the owner or operator demonstrates
that leachate
does not pose a threat to human health and
the environment.
6.6.3 Technical Considerations
When the final cover is installed, repairs
and maintenance may be necessary to keep
the cover in good working order.
Maintenance may include inspection,
testing, and cleaning of leachate collection
and removal system pipes, repairs of final
cover, and repairs of gas and ground-water
monitoring networks.
Inspections should be made on a routine
basis. A schedule should be developed to
check that routine inspections are
completed. Records of inspections detailing
observations should be kept in a log book so
that changes in any of the MSWLF units can
be monitored; in addition, records should be
kept detailing changes in post-closure care
personnel to ensure that changing personnel
will not affect post-closure care due to lack
of knowledge of routine activities. The
activities and frequency of inspections are
subject to State review to ensure that units
are monitored and maintained for as long as
is necessary to protect human health and the
environment.
Inspection of the final cover may be
performed on the ground and through aerial
photography. Inspections should be
conducted at appropriate intervals and the
condition of the facility should be recorded
with notes, maps, and photographs. The
inspector should take notice of eroded
banks, patches of dead vegetation, animal
burrows, subsidence, and cracks along the
cover. The inspector also should note the
condition of concrete structures (e.g.,
manholes), leachate collection and removal
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Subpart F
pipes, gas monitoring systems, and
monitoring wells.
For larger facilities, annual aerial
photography may be a useful way to
document the extent of vegetative stress and
settlement if either of these has been
observed during routine inspections. It is
important to coordinate the photography
with the site "walkover" to verify
interpretations made from aerial
photographs. Aerial photography should
not be used in place of a site walkover but in
conjunction with the site walkover. An
EPA document (U.S. EPA 1987) provides
further information on using aerial
photography for inspecting a landfill
facility. (See the Reference section at the
end of this chapter.)
Topographic surveys of the landfill unit(s)
may be used to determine whether
settlement has occurred. These should be
repeated every few years until settlement
behavior is established. If settlement plates
are used, they should be permanent and
protected from vandalism and accidental
disturbance (U.S. EPA, 1987). Depressions
caused by settlement may lead to ponding
and should be filled with soil. Excessive
settlement may warrant reconstructing or
adding to portions of the infiltration layer.
Damage caused by settlement such as
tension cracks and tears in the synthetic
membrane should be repaired.
Cover systems that have areas where the
slope is greater than 5 percent may be
susceptible to erosion. Large and small rills
(crevices) may form along the cover where
water has eroded the cover. This may lead
to exposure of the synthetic geomembrane
and, in severe cases, depending on the cover
system installed, exposure of the waste.
Erosion may lead to increased infiltration of
surface water into the landfill. Areas
showing signs of erosion should be repaired.
Certain types of vegetative cover (e.g., turf-
type grasses) may require mowing at least
two times a year. Mowing can aid in
suppression of weed and brush growth, and
can increase the vigor of certain grass
species. Alternatively, certain cover types
(e.g., native prairie grasses) require less
frequent mowing (once every three years)
and may be suitable for certain climates and
facilities where a low-maintenance regime
is preferable. For certain cover types,
fertilization schedules may be necessary to
sustain desirable vegetative growth.
Fertilization schedules should be based on
the cover type present. Annual or biennial
fertilization may be necessary for certain
grasses, while legumes and native
vegetation may require little or no fertilizer
once established. Insecticides may be used
to eliminate insect populations that are
detrimental to vegetation. Insecticides
should be carefully selected and applied
with consideration for potential effects on
surface water quality.
Some leachate collection and removal
systems have been designed to allow for
inspections in an effort to ensure that they
are working properly. Leachate collection
and removal pipes may be flushed and
pressure-cleaned on a regular schedule (e.g.,
annually) to reduce the accumulation of
sediment and precipitation and to prevent
biological fouling.
Similarly, gas collection systems should be
inspected to ensure that they are working
properly. Vents should be checked to
ensure they are not clogged by foreign
matter such as rocks. If not working
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properly, the gas collection systems should
be flushed and pressure-cleaned.
At some landfill facilities, leachate
concentrations eventually may become low
enough so as not to pose a threat to human
health or the environment. In an approved
State, the Director may allow an owner or
operator to cease managing leachate if the
owner or operator can demonstrate that the
leachate no longer poses a threat to human
health and the environment. The
demonstration should address direct
exposures of leachate releases to ground
water, surface water, or seeps. Indirect
effects, such as accumulated leachate
adversely affecting the chemical, physical,
and structural containment systems that
prevent leachate release, also should be
addressed in the demonstration.
The threat posed by direct exposures to
leachate released to ground water, to surface
waters, or through seeps may be assessed
using health-based criteria. These criteria
and methods are available through the
Integrated Risk Information System (IRIS)
(a database maintained by U.S. EPA), the
RCRA Facility Investigation Guidance
(U.S. EPA, 1989c), the Risk Assessment
Guidance for Superfund (U.S. EPA, 1989d),
and certain U.S. EPA regulations, including
MCLs established under the Safe Drinking
Water Act and the ambient water quality
criteria under the Clean Water Act. These
criteria and assessment procedures are
described in Chapter 5 (Subpart E) of this
document. Concentrations at the points of
exposure, rather than concentrations in the
leachate in the collection system, may be
used when assessing threats.
6.7 POST-CLOSURE PLAN
40CFR§258.61(c)-(e)
6.7.1 Statement of Regulation
(c) The owner or operator of all
MSWLF units must prepare a written
post-closure plan that includes, at a
minimum, the following information:
(1) A description of the
monitoring and maintenance activities
required in §258.61(a) for each MSWLF
unit, and the frequency at which these
activities will be performed;
(2) Name, address, and telephone
number of the person or office to contact
about the facility during the post-closure
period; and
(3) A description of the planned
uses of the property during the post-
closure period. Post-closure use of the
property shall not disturb the integrity of
the final cover, liner(s), or any other
components of the containment system,
or the function of the monitoring systems
unless necessary to comply with the
requirements in Part 258. The Director
of an approved State may approve any
other disturbance if the owner or
operator demonstrates that disturbance
of the final cover, liner or other
component of the containment system,
including any removal of waste, will not
increase the potential threat to human
health or the environment.
(d) The owner or operator must
notify the State Director that a post-
closure plan has been prepared and
placed in the operating record no later
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Subpart F
than the effective date of this part,
October 9, 1993, or by the initial receipt
of waste, whichever is later.
(e) Following completion of the
post-closure care period for each
MSWLF unit, the owner or operator
must notify the State Director that a
certification, signed by an independent
registered professional engineer or
approved by the Director of an approved
State, verifying that post-closure care has
been completed in accordance with the
post-closure plan, has been placed in the
operating record.
6.7.2 Applicability
Owners and operators of existing units, new
units, and lateral expansions of existing
MSWLF units that stop receiving waste
after October 9, 1993 are required to
provide a post-closure plan. MSWLF units
that received the final waste shipment
between October 9, 1991 and October 9,
1993 but failed to complete installation of a
final cover system within six months of the
final receipt of waste also are required to
provide a post-closure plan.
The post-closure plan describes the
monitoring activities that will be conducted
throughout the 30-year period. The plan
also establishes:
• The schedule or frequency at which
these activities are conducted;
• Name, address, and telephone number of
a person to contact about the facility;
• A description of a planned use that does
not disturb the final cover; and
• The procedure for verifying that post-
closure care was provided in
accordance with the plan.
In approved States only, the owner or
operator may request the Director to
approve a use that disturbs the final cover
based on a demonstration that the use will
not increase the potential threat to human
health and the environment.
6.7.3 Technical Considerations
The State Director must be notified that a
post-closure plan, describing the
maintenance activities required for each
MSWLF unit, has been placed in the
operating record. The post-closure plan
should provide a schedule for routine
maintenance of the MSWLF unit systems.
These systems include the final cover
system, the leachate collection and removal
system, and the landfill gas and ground-
water monitoring systems.
The plan must include the name, address,
and telephone number of the person or
office to contact regarding the facility
throughout the post-closure period.
Additionally, the planned uses of the
property during the post-closure period must
be provided in the plan. These uses may not
disturb the integrity of the final cover
system, the liner system, and any other
components of the containment or
monitoring systems unless necessary to
comply with the requirements of Part 258.
Any other disturbances to any of the
MSWLF components must be approved by
the Director of an approved State. An
example of an acceptable disturbance may
include remedial action necessary to
minimize the threat to human health and the
environment.
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Closure and Post-Closure
Following completion of the post-closure
care period, the State Director must be
notified that an independent registered
professional engineer has verified and
certified that post-closure care has been
completed in accordance with the post-
closure plan and that this certification has
been placed in the operating record.
Alternatively, the Director of an approved
State may approve the certification.
Certification of post-closure care should be
submitted for each MSWLF unit.
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Subpart F
6.8 FURTHER INFORMATION
6.8.1 References
Giroud, J.P., Bonaparte, R., Beech, J.F., and Gross, B.A., "Design of Soil Layer -Geosynthetic
Systems Overlying Voids". Journal of Geotextiles and Geomembranes, Vol. 9, No. 1, 1990,
pp. 11-50.
Richardson, G.N. and R.M. Koerner, (1987). "Geosynthetic Design Guidance for Hazardous
Waste Landfill Cells and Surface Impoundments"; Hazardous Waste Engineering Research
Laboratory; USEPA, Office of Research and Development; Cincinnati, Ohio; Contract No.
68-07-3338.
U.S. EPA, (1987). "Design, Construction and Maintenance of Cover Systems for Hazardous
Waste: An Engineering Guidance Document"; PB87-19156; EPA/600/2-87/039; U.S.
Department of Commerce, National Technical Information Service; U.S. Army Engineering
Waterways Experiment Station; Vicksburg, Mississippi.
U.S. EPA, (1988). "Guide to Technical Resources for the Design of Land Disposal Facilities";
EPA/625/6-88/018; U.S. EPA; Risk Reduction Engineering Laboratory and Center for
Environmental Research Information; Office of Research and Development; Cincinnati,
Ohio 45268.
U.S. EPA, (1989a). "Seminar Publication - Requirements for Hazardous Waste Landfill
Design, Construction and Closure"; EPA/625/4-89/022; U.S. EPA; Center for
Environmental Research Information; Office of Research and Development; Cincinnati,
Ohio 45268.
U.S. EPA, (1989b). "Technical Guidance Document: Final Covers on Hazardous Waste
Landfills and Surface Impoundments"; EPA/530-SW-89-047; U.S. EPA; Office of Solid
Waste and Emergency Response; Washington, D.C. 20460.
U.S. EPA, (1989c). "Interim Final: RCRA Facility Investigation (RFI) Guidance"; EPA
530/SW-89-031; U.S. EPA; Waste Management Division; Office of Solid Waste; U.S.
Environmental Protection Agency; Volumes I-IV; May 1989.
U.S. EPA, (1989d). "Interim Final: Risk Assessment Guidance For Superfund; Human Health
Evaluation Manual Part A"; OS-230; U.S. EPA; Office of Solid Waste and Emergency
Response; July 1989.
U.S. EPA, (1991). "Seminar Publications - Design and Construction of RCRA/CERCLA Final
Covers"; EPA/625/4-91/025; U.S. EPA, Office of Research and Development; Washington,
D.C.20460.
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6.8.2 Organizations
U.S. Department of Agriculture
Soil Conservation Service (SCS)
P.O. Box 2890
Washington, D.C. 20013-2890
(Physical Location: 14th St. and Independence Ave. NW.)
(202)447-5157
Note: This is the address of the SCS headquarters. To obtain the SCS technical guidance
document concerning the Universal Soil Loss Equation (entitled "Predicting Rainfall
Erosion Loss, Guidebook 537," 1978), contact SCS regional offices located
throughout the United States.
6.8.3 Models
Schroeder, et al., (1988). "The Hydrologic Evaluation of Landfill Performance (HELP)
Model"; U.S.EPA; U.S. Army Engineer Waterways Experiment Station; Vicksburg, MS
39181-0631; October 1988.
Schroeder, P.R., A.C. Gibson, J.M. Morgan, T.M. Walski, (1984). "The Hydrologic Evaluation
of Landfill Performance (HELP) Model, Volume I - Users Guide for Version I (EPA/530-
SW-84-009), and Volume II - Documentation for Version I (EPA/530-SW-84-010); U.S.
Army Engineer Waterways Experiment Station, Vicksburg, MS, June 1984.
6.8.4 Databases
Integrated Risk Information System (IRIS), U.S. Environmental Protection Agency, Office of
Research and Development, Cincinnati, Ohio.
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