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 has begun comment review and expects to publish a final rule in August 1997. CONTACTS: Sam Hadeed, AMSA (202) 833-4655, or Wendy Bell, U.S. EPA (202) 260-9534.
Radiation Site Cleanup - Anticipated Proposed Rule
Background: EPA's Office of Radiation & Indoor Air
(ORIA) has been considering regulations which set cleanup standards
for contaminated sites if released from federal control, Nuclear
Regulatory Commission (NRC) license or an NRC agreement state
license (states which have signed accords with NRC allowing the
state to regulate the use of radioactive material within that
state). AMSA had been concerned with the radionuclide limit and
the risk analysis used to develop the rule, in that many municipal
biosolids, while not currently regulated for radionuclides, may
exceed the limit of 15 millirems for which the Agency is proposing
as a "safe" level for radiation contaminated sites.
NRC is currently delaying a similar rule until EPA proposes or
finalizes its rule. Under an agreement with EPA, NRC licensees
and agreement states would be exempt from EPA's standard if EPA
finds that NRC's rule is sufficiently protective. The
rule had been anticipated for notice by Spring 1997.
Status: EPA withdrew the Proposed Rule on Radiation
Site Cleanup from OMB this month. DOE reached the conclusion
that any cleanup standard based on a 15 millirem or less exposure
is unworkable and overly protective. CONTACT: Sam Hadeed,
AMSA (202) 833-4655, or John Karhnak , EPA (202) 233-9237.
Streamlining the State Sewage Sludge Management Regulations
- Anticipated 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: A proposal for streamlined regulations is expected
in early Spring 1997. CONTACT: 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 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),
pollutant limits for molybdenum and selenium, measuring temperature
in lieu of measuring THC for incineration.
Status: EPA has indicated that the Round I Final Sludge
Use or Disposal Regulations is 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.
AMSA has learned recently that one of our major recommendations
in response to the proposed Round I regulatory revisions; monitoring
temperature as a surrogate for continuous THC/CO monitoring, may
be allowed as an option for POTWs under the final rule. EPA
expects to finalize Phase I, Round I sewage sludge use or disposal
amendments in March 1997. EPA plans to propose Phase II, Round
I amendments in March 1997. CONTACTS: Sam Hadeed, AMSA
(202) 833-4655 or Bob Southworth, EPA (202) 260-7157.
AMSA-WEF to Issue National Inventory of Biosolids Beneficial
Use Activities
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. The project will also
produce a summary report for distribution. It is anticipated
that this inventory will be maintained to help respond to inquires
for information regarding beneficial use practices and projects.
During the development of the regulations for the use and disposal
of biosolids, EPA reviewed extensive world-wide data, including
findings from field trials and laboratory experiments on the human
health and environmental impacts for the use or disposal of biosolids.
Information gathered from these field trials and biosolids sites
demonstrates no environmental degradation or human health impacts
when used in accordance with federal criteria. Applications of
biosolids have resulted in increased soil fertility due to additions
of macro and micro nutrients, increased organic matter content
of the soil, and increased moisture delivery to the ecosystem.
There were no documented negative human health impacts when the
biosolids that have meet all of the federal regulations have been
applied under good management practices. The report 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.
Status: The report is expected in early Spring 1997 and will be available to the membership at that time. CONTACT: Sam Hadeed, AMSA (202) 833-4655.
Nuclear Regulatory Commission (NRC) Developing POTW
Radioactivity Survey
Background: The NRC and EPA are planning to conduct a small-scale
test survey of nine POTWs to determine levels of radionuclides
in their biosolids. The survey is being conducted as a test run
for a larger radionuclides survey the agencies plan to conduct
with hundreds of POTWs across the country to obtain data on levels
of radioactivity from naturally occurring and man-made isotopes.
The results of this larger survey could lead to NRC/EPA rulemaking
to further control the concentration of radionuclides discharged
to POTWs by NRC licensees. Any rulemaking arising from the survey
is expected to apply additional restrictions to NRC licensed industries
and businesses that discharge radioactive materials into sewer
systems, but will not be used for enforcement purposes by either
NRC or EPA. The results of the survey could also be used to determine
whether POTWs should be given more authority to impose local limits
or controls on NRC licensees discharging into their sewer systems.
Survey information will also be used to further develop NRC/EPA
guidance for POTWs to help them characterize sources of radioactivity,
describe sampling and analysis procedures, and advise them on
appropriate responses for addressing the presence of radioactive
material in their biosolids.
Development of this guidance has already begun, and the agencies
are considering whether to include a table of acceptable concentrations
for each radionuclide in treatment plant's end products. The
agencies' interest in radioactive sludge was sparked in the early
1990's following the discovery of radioactive contamination at
several wastewater treatment facilities caused by the reconcentration
of certain radioactive isotopes during the wastewater treatment
process. The NRC revised its sewer disposal criteria for its
licensees, and began working with EPA on a coordinated regulatory
review of radioactive contamination of biosolids. NRC does not
require POTWs to test for radioactive materials in biosolids unless
some prior evidence of a problem exists. The EPA standard for
the use and disposal of biosolids (Part 503) does not include
radionuclides. EPA had planned to include analysis of radiation
in biosolids and incinerator ash in its 1996-97 national biosolids
survey, but did not have sufficient funding. While AMSA conducted
a voluntary anonymous survey of 75 of its member agencies, NRC
considered the effort limited in scope, and deemed that a more
extensive survey would be needed to justify any future rulemaking
of its licensees. All information collected in the survey will
remain confidential, according to NRC and EPA officials, with
each participating POTW being assigned a code number to ensure
anonymity. The codes will only be known by a small group of EPA
officials, and future access to POTW identities -- if needed due
to elevated radioactivity levels -- will be strictly controlled
on a need to know basis.
Status: AMSA's Biosolids Management Committee has reviewed
a draft OMB clearance scope of work. NRC published in the January
6, 1997 Federal Register, a notice announcing is 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 POTWs from which samples of sewer 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. Public comments are due by March 7, 1997. CONTACT:
Sam Hadeed, AMSA (202) 833-4655 or Brenda Jo. Shelton, NRC (301)415-7233.
Related Items of Interest
Sections of the US EPA's dioxin reassessment are not expected
to be submitted for formal peer review until early 1997. The
delay in review, which was scheduled to take place last month,
is mainly due to the incompleteness of the summary regarding dioxins'
health effects. According to a draft version of the risk characterization,
dated September 24, 1996 several important sections from the earlier
version have not yet been revised or rewritten. The Toxic Equivalency
Factors (TEF) portion and several other missing sections, including
the conclusion, were scheduled to be drafted by EPA staff by late
November. EPA hopes to submit its findings to the Science Advisory
Board by June 1997. EPA's Office of Science and Technology plans
to brief AMSA's National Office on the status of this policy and
implementation for biosolids management programs.