Biosolids Management
NPDES Permit Application Requirements for POTWs, Form 2S - Proposed Rule
Background: EPA published in the December 6, 1995 Federal Register, a proposed rule which will amend NPDES permit application requirements and application forms for POTWs. As part of the proposed rule, EPA proposes to replace the existing Interim Sewage Sludge form with a Form 2S. The most significant proposed revision, according to EPA, would require POTWs to analyze biosolids and provide data for ten metals, nitrogen, and phosphorus. The proposed rule would also require those POTWs managing pretreatment programs to analyze for most of the priority pollutants. The Interim Sewage Sludge Form only requires the use of existing data. EPA states that it believes the additional information is necessary in order for permitting authorities to issue permits that meet the requirements of the sewage sludge use or disposal regulations. The proposed rule allows waivers where information is already available to the permitting authority.
Status: A copy of the proposed regulations and application forms were sent out to the membership via Regulatory Alert RA 96-4 on January 30, 1996. AMSA comments on the proposal were submitted to EPA on March 28, 1996. EPA expects to publish a final rule in December 1997. CONTACT: Sam Hadeed, AMSA 202/833-4655, or Robin Danesi, U.S. EPA 202/260-2991.
Streamlining the State Sewage Sludge Management Regulations - Proposed Rule
Background: EPA's Office of Wastewater Management is looking at ways to revise the current State sludge program regulations to provide more flexibility to states requesting authorization. EPA has distributed two drafts of proposed changes to Regions, States, and other stakeholders. The streamlined regulations are intended to ease the sludge program authorization process for States.
Status: In the March 11, 1997 Federal Register, EPA published proposed amendments to its regulations that establish requirements for States seeking approval to operate sewage sludge permit programs. The proposed changes would streamline the regulations to ease the authorization process for States, provide flexibility to States in implementing their permit programs, and ensure that permitting determinations are based on environmental and public health considerations. Several highlights of the proposal include: 1) making the requirements for NPDES and non-NPDES sewage sludge management programs the same under 40 CFR Part 501 and deleting provisions in 40 CFR Part 123 that contain State program requirements applying solely to sewage sludge; 2) deleting requirements that State programs have the authority to address sewage sludge storage and transport; 3) allowance for approval of partial sewage sludge management programs, 4) reduced document management requirements; 5) allowing non-NPDES permit terms for up to 10 years; 6) streamlining required permit conditions; 7) deleting requirements that State programs have authority to obtain applications from incinerators and others who request site-specific pollutant limits within 180 days after publication of the applicable standards; and, 8) streamlined public participation requirements. The comment period on the proposed rule ended May 12, 1997. The final rule is scheduled for December 1997. CONTACT: Wendy Bell, EPA 202/260-9534, or Sam Hadeed, AMSA 202/833-4655.
Amendments to Round I Final Sewage Sludge Use or Disposal - Proposed Rule
Background: EPA is amending the Round I Final Sewage Sludge Use or Disposal Regulations in two phases. Phase I was published as a proposed rule in the October 25, 1995 Federal Register and suggested additional amendments to the regulations and the General Pretreatment Regulations in order to clarify existing regulatory requirements and provide increased flexibility to permittees and permit authorities. Phase II, Round I will address issues presented by judicial remand of specific requirements in the final rule and modify technical and implementation requirements. Some of the issues that may be addressed include: certification requirements, land application (time of biosolids application requirement), allowance for vector attraction reduction alternatives, pollutant limits for molybdenum and selenium, and measuring temperature in lieu of measuring THC for incineration. The Round II Rule will cover dioxins, dibenzofurans, and co-planar PCBs. EPA has indicated that the Round I Final Sludge Use or Disposal Regulations are being amended to make the incineration requirements in the regulation self-implementing, to provide permitting authorities and the regulated POTWs flexibility in meeting certain requirements, and to make technical corrections to the regulation.
Status: EPA expects to finalize Phase I, Round I sewage sludge use or disposal amendments in October 1997. EPA plans to propose Round II amendments in December 1999, with promulgation in December 2001. CONTACTS: Sam Hadeed, AMSA 202/833-4655 or Bob Southworth, EPA 202/260-7157.
AMSA-WEF Issue National Inventory of Biosolids Beneficial Use Activities Report
Background: Recently, AMSA, in cooperation with WEF and others, undertook the development of an inventory of the beneficial use of biosolids in the U.S. The inventory will provide baseline information on biosolids beneficial use practices, state regulations and significant implementation issues. Survey questionnaires were distributed to the AMSA membership and state and federal regulators in 1996 to obtain an overview of the beneficial use of biosolids in the U.S. Responses were received from 117 members representing a US sewered population of approximately 65 million and 25 regulators. Information from a recent EPA report was also used to supplement data for the inventory.
Status: The report, distributed to the AMSA membership via Regulatory Alert, RA 97-21, is intended to be a "snapshot" of biosolids practices and regulations, to be compared with future updates as an aid in evaluating the progress in promoting beneficial use and implementing the Part 503 Rule. It provides an estimate of the volume and quantity of municipal biosolids generated each year. The inventory covers the nature of state beneficial use rules, attitudes about beneficial use, the nature of public acceptance activities, and the extent of compliance with the Part 503 sewage sludge regulation. The report also includes a discussion of trends and suggests activities that the wastewater profession should undertake to improve the acceptance of biosolids recycling. The report's key findings include: 1) Beneficial use of municipal solids increased from 35% in 1988 to 54% in 1995; 2) 82% of the POTW respondents believe they are producing solids that comply with the Part 503 federal regulations; and, 3) More than 54% of the POTWs selected land application as the primary mechanism for beneficial use or disposal; 15% selected incineration; 10% surface dispose; and, 20% selected other or primarily landfill. CONTACT: Sam Hadeed, AMSA 202/833-4655
Nuclear Regulatory Commission (NRC) Developing POTW Radioactivity Survey
Background: NRC published in the January 6, 1997 Federal Register, a notice announcing its intent to conduct a joint NRC/EPA survey of sewage sludge ash. The survey will obtain national estimates of the levels of radioactive materials in sludge and ash at POTWs, estimate the extent to which radioactive contamination comes from either NRC/Agreement State licensees or from naturally occurring radioactivity, and support possible rulemaking decisions by NRC and EPA. NRC and EPA will send questionnaires to selected POTWs. Based on the results of that survey, NRC will identify approximately 300-400 POTWs from which samples of sewage sludge/ash will be taken and analyzed. Results of the full survey will be published for use by Federal agencies, States, POTWs and local POTW offices.
Status: Public comments on the survey were due by March 7, 1997. NRC and EPA have identified 300 candidate POTWs for the survey. A Federal Register notice is expected outlining NRC's proposed plans to conduct this survey by the end of the year. AMSA, WEF, EPA and NRC met in Philadelphia on August 4, 1997, to review issues pertaining to the guidance document and survey. AMSA proposed that its members assist NRC with writing sections of the guidance, EPA develop risk criteria for radionucleides before the survey is conducted, survey design be patterned as a random versus a targeted effort and that NRC form a Steering Committee, that includes AMSA, to review the survey results. The National Office forwarded NRC's "Draft Guidance for POTWs on Radioactive Materials in Sewage Sludge/Ash," via Regulatory Alert RA 97-15. AMSA and WEF submitted a joint letter to NRC on September 11, 1997, regarding the conduct of the survey and the need to establish a peer review group to oversee and monitor the results. The National Office submitted comments to NRC and EPA on September 11, 1997. NRC had initially planned to conduct its POTW survey later this year and will ultimately incorporate the results into the final guidance document. NRC and EPA plan to meet on September 16 to review the document and survey. The Radioactivity Group plans to meet on October 20 at WEFTEC. CONTACT: Sam Hadeed, AMSA 202/833-4655 or Brenda Jo. Shelton, NRC 301/415-7233.
Proposed AMSA\WEF\US EPA National Biosolids Partnership Holds Planning Meeting
Background: In February 1993, EPA released its final Part 503 rule governing the use and disposal of biosolids. In 1995, the Agency proposed transferring most of its biosolids management role to states and other stakeholders. In response to the proposal, biosolids stakeholders, including AMSA, developed a "vision" for the national biosolids management program. AMSA and WEF hosted a two-day stakeholder seminar designed to build consensus on the future direction of EPA's biosolids management program on May 15-16, 1997. AMSA, EPA Headquarters, EPA regions, U.S. Department of Agriculture, state government, professional associations, public health representatives, users, processors, applicators, consulting firms, academia and the media participated in the seminar. The seminar helped identify what is missing from the management plan and stakeholder "vision," and to develop further ideas for the successful implementation of a biosolids management plan that protects public health and the environment and instills public confidence. The development of a code of good practice, including a form of an environmental management system for biosolids, was considered that would include training and third-party verification.
Status: Copies of the revised stakeholder report were forwarded jointly by AMSA and WEF in July to EPA. EPA announced in early August that it will reactivate funding and staff resources to the biosolids management program and has invited AMSA and WEF to form a partnership to identify and coordinate activities related to biosolids. A planning meeting was held on August 28, 1997, at WEF's National Office in Alexandria, Virginia, to discuss the goals of a AMSA/ WEF/ EPA National Biosolids Partnership. EPA has identified the following priority areas that it would like to pursue and fund over the next fiscal year, including: 1) preparation of a code of good management practices for biosolids with third-party verification; 2) conducting a biosolids quality survey to compare data from 1988-1989 with post-Part 503 quality; 3) formation of SWAT teams comprised of biosolids experts to assist in the investigation and preparation of quick responses of significant alleged problems; 4) renewed EPA oversight by the Office of Enforcement & Compliance Assurance to develop enforcement priorities and provide compliance assistant; and, 5) work as partners in a biosolids group to provide technical assistance and research into emerging national issues such as radioactivity, dioxin, pathogens, and animal manures. The partnership will be comprised of a National Biosolids Management Committee, which will be established to plan and implement Partnership activities and a Biosolids Advisory Group, which will represent a majority of biosolids stakeholders and will be convened to advise the Partnership. The results of the August 28 meeting will be presented for consideration at the September Board of Directors meeting. A meeting of the Management Committee is planned during WEFTEC in Chicago in October. CONTACT: Sam Hadeed, AMSA 202/833-4655.