Member Pipeline - Regulatory - Alert (RA 00-19)
Action Please By:
To: Members & Affiliates From: National Office Date: October 2, 2000 Subject: AMSA’s Voluntary Year 2000 Dioxin in Biosolids Survey Reference: RA 00-19
November 1, 2000AMSA’s Biosolids Management Committee, with the approval of AMSA’s Board of Directors, has decided to conduct a voluntary survey to determine current levels of dioxin-like compounds (e.g., dioxin, dibenzofurans and coplanar PCBs) in biosolids. This data is needed to:
1. Determine whether or not dioxin concentrations in biosolids are remaining the same or diminishing.
2 Ensure that an environmentally sound and technically correct dioxin limit is established for biosolids that are land applied.
AMSA is encouraging each of its member agencies and interested non-members to participate in this very important survey. Cost to each participant will be $1,500 per sample of biosolids analyzed.
Wastewater treatment agencies, publicly-owned treatment works (POTWs) and/or firms wishing to participate in this survey should contact Joe Palausky of Midwest Research Institute at (816) 753-7600 ext. 1626 or via e-mail at jpalausky@mriresearch.org.
If you have any questions or require additional information concerning AMSA’s Year 2000 Dioxin in Biosolids Survey, please contact Bob Dominak (Northeast Ohio Regional Sewer District) at 216-881-6600 (e-mail address: dominakr@neorsd.org) or Ray Kearney (City of Los Angeles) at 310-684-5360 (e-mail address: rjk@san.ci.la.ca.us). Bob and Ray are the Co-Chairs of AMSA’s Biosolids Management Committee.
Please Return the "Intent to Participate" Form, Contained in
Attachment "B", to Bob Dominak by November 1, 2000
Background
On December 23, 1999, the United States Environmental Protection Agency (EPA) published in the Federal Register a proposed rule to limit dioxin, dibenzofurans and dioxin-like coplanar PCBs (hereinafter Adioxin@) in biosolids that are land aplied.The proposed rule would prohibit the land application of biosolids that have dioxin concentrations of 300 ppt TEQ or greater. The proposed rule would also require that:
1. POTWs, whose biosolids contain between 30 and 300 ppt TEQ dioxin, must analyze their biosolids once per year for dioxin.
2. POTWs, whose biosolids contain less than 30 ppt TEQ dioxin, must analyze their biosolids once every five-years for dioxin.
EPA personnel have indicated that the dioxin rule will be promulgated on or before December 15, 2001, and that the final dioxin limit for biosolids that are land applied could be considerably lower than the proposed limit of 300 ppt TEQ.
Additional Testing of Biosolids for Dioxin
Historical data from EPA's 1988 National Sewage Sludge Survey and AMSA's 1994 Survey of Dioxin in Biosolids formed the basis for EPA’s proposed rule. Approximately 40 AMSA member agencies participated in the 1994 survey, during which 104 samples of biosolids were analyzed for dioxin. The average dioxin concentration was approximately 104 ppt TEQ, while the median dioxin concentration was approximately 67 ppt TEQ. These AMSA data have contributed significantly not only to EPA’s proposed biosolids rule, but also to EPA’s ongoing dioxin reassessment.While EPA’s risk analysis for the proposed limit of 300 ppt TEQ assumes that dioxin levels in biosolids are remaining constant or diminishing, there is a need for current data to support this assumption. Earlier this year, EPA announced that it had retained DynCorp Environmental to collect and analyze biosolids samples for dioxin, at 23 of the 33 POTWs that tested positive for PCBs during EPA’s 1988 National Sewage Sludge Survey. However, EPA personnel announced on August 31, 2000, that this survey has been cancelled, due to a reallocation of funds.
In addition, EPA personnel suggested that AMSA conduct a second Dioxin in Biosolids Survey to determine current dioxin concentrations in biosolids through-out the United States. Given that additional dioxin data is needed to ensure that an environmentally sound and technically correct dioxin limit is
established for biosolids that are land applied, AMSA's Biosolids Management Committee recommended to AMSA’s Board of Directors that:
1. AMSA conduct a second voluntary survey of dioxin in biosolids, in the year 2000.
2. Cambridge Environmental Inc. be retained to assist AMSA in designing a sampling program, identifying potential testing laboratories, receiving analytical data from the testing laboratory, conducting statistical analyses of the data, preparing a detailed "Survey" report, and participating in discussions with EPA concerning dioxin in biosolids.
On February 4, 2000, AMSA's Board of Directors approved the Biosolids Management Committee’s recommendations. EPA’s Office of Water has indicated its willingness to work with AMSA and Cambridge Environmental to review the new data that will be obtained during the AMSA’s year 2000 Dioxin in Biosolids Survey.
The Biosolids Management Committee is requesting that each of the 40 AMSA member agencies that participated in the 1994 survey, along with all other AMSA member agencies and any interested non-AMSA member agencies, voluntarily participate in this extremely important survey.
Biosolids Sampling and Analysis – AMSA Survey
AMSA received proposals from two nationally renowned-testing laboratories for assistance in the year 2000 Dioxin in Biosolids Survey. After thoroughly reviewing the proposals, AMSA selected Midwest Research Institute to perform the dioxin analyses of biosolids samples.Any publicly-owned treatment works (POTW) willing to voluntarily participate in this survey should contact Joe Palausky of Midwest Research Institute at (816) 753-7600 ext. 1626 or via e-mail at jpalausky@mriresearch.org.
AMSA has negotiated a cost of $1,500 per biosolids sample, which is in line with costs charged by other laboratories and reflects a volume discount. The sampling and laboratory test methodologies used by Midwest Research Institute have been reviewed by EPA's Office of Water and are consistent with EPA's standards for dioxin biosolids analysis. Participants in AMSA's year 2000 Dioxin in Biosolids Survey will receive from Midwest Research Institute:
- Sampling instruction;
- A sample bottle(s);
- A questionnaire (See Attachment "A") which asks for some basic information about the POTW where the sample originated. This important information will help Cambridge Environmental to analyze and interpret the dioxin results
- A container, including packing material, in which to send the sample(s) and the questionnaire(s) back to Midwest Research Institute, and
- A prepaid mailing sticker.
This will be a "blind" survey. This means that only the test data and POTW ID Numbers will be presented in the final report. As was the case in AMSA’s 1994 Survey, the results of the AMSA year 2000 Dioxin in Biosolids Survey will not link participants with the test data. In addition, neither Cambridge Environmental nor EPA personnel will have access to the information that links the ID Numbers to the participants.
Each participant will receive a summary report from Midwest Research Institute that contains its raw test data, dioxin concentration in "ppt TEQ", and the POTW ID Number that will be listed in the final report for its sample. It is the Biosolids Management Committee’s intent to complete the analytical work before March 1, 2001 and to publish the final report in April 2001. Therefore, biosolids samples must be received by Midwest Research Institute as soon as possible, but no later than January 15, 2001.
Purchase Orders, Invoices and Payment for Analytical Services
Participants in this Survey will be required to send a purchase order or a purchase order number for the required analytical services to Midwest Research Institute, along with their biosolids sample(s) and their completed questionnaire(s). After the analytical work is completed, Midwest Research Institute will send an invoice directly to participant. Participants should send payment for the analytical services directly to Midwest Research Institute.
Notification of Intent to Participate
Given the importance of this survey, AMSA would like all recipients of this announcement to let us know whether or not they are planning on participating in the survey. As a result, it is requested that you complete the "Intent to Participate" form contained in Attachment "B" and return it to Bob Dominak by Wednesday, November 1, 2000.
Existing Dioxin Data
AMSA would also appreciate receiving any existing data that you might have concerning dioxin in your biosolids. The data (on a dry weight basis – ppt raw and ppt TEQ), along with all pertinent test information (e.g., test methods utilized, size of sample, name of laboratory) and a completed questionnaire (See Attachment "A") should be mailed to:
Bob Dominak (RE: Dioxin Survey)
Northeast Ohio Regional Sewer District
3826 Euclid Avenue
Cleveland, OH 44115
- Attachments A and B (MS-Word format ~ 70KB)
- Attachments A and B (PDF format ~ 220 KB)
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