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.
CONTACTS: 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.
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. EPA has apprised AMSA
that our option of monitoring temperature as a surrogate for continuous
THC/CO monitoring is being given serious consideration. AMSA is
reviewing an EPA study done by a contractor suggesting that THC/CO
monitoring is not an appropriate surrogate. 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 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 Summer 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: 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 are currently identifying candidate
POTWs for the survey. A revised survey approval package is expected
to be sent to OMB by the end of April with final approval expected
by late June. AMSA, WEF, NRC and EPA met during the National Environmental
Policy Forum to review the survey. Both AMSA and WEF plan to submit
a joint letter to NRC in July, regarding the conduct of the survey
and the need to establish a peer review group to oversee and monitor
the results. The group plans to reconvene in Philadelphia in July
to discuss the next steps. A Federal Register notice is expected
later this Summer announcing NRC plans to conduct the survey later
in 1997. 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. Comments were due to the National Office by July
18, 1997. NRC had initially planned to conduct its POTW survey
later this year and will ultimately incorporate the results into
the final guidance document. The Radioactivity Group plans to
meet in October at WEFTEC. CONTACT: Sam Hadeed, AMSA 202/833-4655
or Brenda Jo. Shelton, NRC 301/415-7233.
AMSA Co-hosts Seminar
on Future of Biosolids Program
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.
Status: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, at the Bolger Center for Leadership in Potomac, Maryland. 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. 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. CONTACT: Sam Hadeed, AMSA 202/833-4655.
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.
CONTACTS: 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.
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. EPA has apprised AMSA
that our option of monitoring temperature as a surrogate for continuous
THC/CO monitoring is being given serious consideration. AMSA is
reviewing an EPA study done by a contractor suggesting that THC/CO
monitoring is not an appropriate surrogate. 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 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 Summer 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: 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 are currently identifying candidate
POTWs for the survey. A revised survey approval package is expected
to be sent to OMB by the end of April with final approval expected
by late June. AMSA, WEF, NRC and EPA met during the National Environmental
Policy Forum to review the survey. Both AMSA and WEF plan to submit
a joint letter to NRC in July, regarding the conduct of the survey
and the need to establish a peer review group to oversee and monitor
the results. The group plans to reconvene in Philadelphia in July
to discuss the next steps. A Federal Register notice is expected
later this Summer announcing NRC plans to conduct the survey later
in 1997. 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. Comments were due to the National Office by July
18, 1997. NRC had initially planned to conduct its POTW survey
later this year and will ultimately incorporate the results into
the final guidance document. The Radioactivity Group plans to
meet in October at WEFTEC. CONTACT: Sam Hadeed, AMSA 202/833-4655
or Brenda Jo. Shelton, NRC 301/415-7233.
AMSA Co-hosts Seminar
on Future of Biosolids Program
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.
Status: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, at the Bolger Center for Leadership in Potomac, Maryland. 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. 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. CONTACT: Sam Hadeed, AMSA 202/833-4655.