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Biosolids Management


NPDES Permit Application Requirements for POTWs, Form 2S - Proposed Rule

Background: On December 6, 1995, EPA published a proposed rule to amend NPDES permit application requirements and application forms for POTWs, replacing the existing Interim Sewage Sludge form, which only requires the use of existing data, with a Form 2S, requiring POTWs to analyze biosolids and provide data for ten metals, nitrogen, and phosphorus. The proposed rule also requires those POTWs managing pretreatment programs to analyze for most of the priority pollutants. The proposed rule allows waivers where information is already available to the permitting authority. A copy of the proposal was distributed via Regulatory Alert RA 96-4 on January 30, 1996. AMSA comments on the proposal were submitted to EPA on March 28, 1996.

Status: EPA is currently finalizing changes to the municipal sludge application requirements and forms which were published in the December 1995 proposed rule. EPA expects to publish the final rule by late June 1999. CONTACT: Sam Hadeed, AMSA 202/833-4655, or Robin Danesi, EPA 202/260-2991.

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. EPA proposed Phase I on October 25, 1995, 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. 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 by late June 1999. EPA plans to make the incineration portion of this rule self-implementing and require either THC or CO monitors installed within 12 months following final promulgation and meet a 100 ppm emissions standard. In addition, these amendments will improve rule clarity and implementation and respond to a number of issues resulting from judicial review. This final rule will also amend the Part 403 General Pretreatment regulations to add a concentration limit for chromium in land-applied biosolids. AMSA met with the Natural Resources Defense Council (NRDC) in November 1998 to discuss AMSA's concerns with relevant issues in the rulemaking, Section 129 of the CAA, dioxin, and opportunities for the two organizations to reach common ground. AMSA also submitted a letter to EPA outlining several recommendations to accomplish this objective. EPA is currently evaluating these options. Round I, Phase II is scheduled for proposal in December 1999, with final promulgation expected in March 2000. These amendments will establish a procedure for biosolids preparers to justify and calculate a site-specific ceiling value for selenium for land-applied biosolids, delete the annual pollutant loading rate option for biosolids sold or given away in a bag or other container, articulate the additional margin of safety afforded by heat dried pelletized biosolids products, allow for vector attraction reduction equivalency for land-applied biosolids, and move and thereby consolidate biosolids analytical methodologies to 40 CFR Part 136. The Agency is currently conducting a multi-media risk assessment for dioxin-like compounds in biosolids. The results of the risk assessment will be used to decide whether the Agency will propose Round II Part 503 numerical standards for biosolids by December 1999. EPA will also propose new numerical standards for molybdenum in land-applied biosolids by December 1999.CONTACTS: Sam Hadeed, AMSA 202/833-4655 or Al Rubin, EPA 202/260-7589.

NRC/EPA to Conduct Survey of Radionuclide Content of POTW Biosolids in June 1999

Background: On January 6, 1997, the Nuclear Regulatory Commission (NRC) published a notice announcing its intent to conduct a joint NRC/EPA survey of sewage sludge ash which will obtain national estimates of the levels of radioactive materials in sludge and ash at POTWs, and 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. On December 2, 1997, NRC published a notice outlining its plans to conduct a joint NRC/EPA survey during the summer of 1998 to characterize radioactive materials in sewage sludge/ash at POTWs and the NRC agreement states. For the planned survey, NRC/EPA will send questionnaires to some 600 POTWs associated with NRC licensees having the highest potential to discharge radioactive material to the sewer system. Using the information gathered, NRC and EPA will identify approximately 300 POTWs for sampling. The objectives of the joint survey are to: 1) obtain national estimates of high probability occurrences of elevated levels of radioactive materials in biosolids and ash at POTWs; 2) estimate the extent to which radioactive contamination comes from either NRC/agreement state licensees or naturally occurring radioactivity; and 3) support rulemaking decisions by NRC and EPA. The information will be used in developing joint NRC/EPA guidance for POTWs to determine sources of radioactive materials, describe sampling and analysis procedures, and advise whether a response is needed to the presence of radioactive material in biosolids. The Federal Register notice and supporting information were forwarded to the membership via Regulatory Alert, RA 97-26.

Status: In early July, 1998, OMB cleared the joint NRC-EPA survey and based on AMSA's recommendations, has required the two agencies to establish a survey review committee, to include Kevin Aiello, AMSA's Pretreatment & Hazardous Waste Committee Vice Chair, and Tom Lenhart with Northeast Ohio Regional Sewer District. The committee will oversee and monitor the results of the survey. In August, 1998 the National Biosolids Partnership approved $6,000 funding for developing a guidance document to assist POTWs in addressing radioactivity potential in sanitary sewers. In October 1998, the National Biosolids Partnership approved $25,000 to study comparative risk assessment of radionuclide exposure from biosolids. The guidance document would provide information and technical support to POTWs to facilitate participation in the radiation survey. The NBP guidance document, “Characterization of Radioactivity Sources at Wastewater Treatment Facilities - A Guidance Document for Pretreatment Coordinators and Biosolids Managers,” was distributed via Regulatory Alert RA99-11 in mid-May 1999 to all AMSA members and 600 other wastewater agencies. Questionnaires are expected to be distributed to the 800 POTWs from NRC/EPA in late-June 1999. CONTACT: Sam Hadeed, AMSA 202/833-4655 or Brenda Jo Shelton, NRC 301/415-7233.

National Biosolids Partnership to Meet in June/July

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. Copies of the revised stakeholder report were forwarded jointly by AMSA and WEF to EPA in July 1997. EPA announced in early August 1997 that it will reactivate funding and staff resources to the biosolids management program and invited AMSA and WEF to form a partnership to identify and coordinate activities related to biosolids.

Status: The Partnership, which includes AMSA, WEF, and EPA, is comprised of a Management Committee, established to plan and implement Partnership activities, a Steering Committee and an Advisory Committee, to represent a majority of biosolids stakeholders. AMSA Board member, Bob Hite, Denver Metro Wastewater Reclamation District, serves as chair of the Management Committee. A Steering Committee is chaired by AMSA's Dr. Cecil Lue-Hing. In September, 1998 the House Appropriations Subcommittee on VA, HUD & Independent Agencies agreed to include a $900,000 appropriation for the National Biosolids Partnership in their 1999 budget recommendation for EPA. AMSA's Board of Directors at its September 1998 leadership meeting passed a motion supporting independent third party verification as an essential element of the Environmental Management System (EMS) for biosolids. Several project leaders within the Steering Committee were identified to lead efforts to coordinate the over $700,000 in EMS-related projects that were issued as requests for proposals for contractor bids. The Sear Brown Group was awarded the contract in April 1999 to proceed with the development of the Manual of Good Practice, which is being coordinated with the Water Environment Research Foundation. Three additional RFPs were distributed in late May 1999; contractor selections will be made by July 1. The Partnership is actively pursuing Congressional approval of a $1.775 million appropriations in EPA's FY 2000 budget to support the Partnership. AMSA members were encouraged to submit letters by mid-February 1999 to their congressional representatives on the Appropriations Subcommittee on VA, HUD & Independent Agencies. A large portion of the increased appropriations request from FY 1999 is designed to support pilot testing of the EMS at a number of wastewater agencies throughout the country. An annual report describing the goals and objectives and activities of the NBP was distributed to the membership in late January. A follow up brochure describing the EMS initiative was published in late May 1999 and will be distributed to the membership via an upcoming Regulatory Alert in June. A CD-ROM program containing all core Part 503 documents and guidance was distributed at no cost to all AMSA members in April 1999 via Regulatory Alert RA 99-6. A radioactivity guidance document for POTWs was distributed to the membership and 600 other POTWs via Regulatory Alert RA 99-11 in anticipation of the joint radioactivity survey by the Nuclear Regulatory Commission and EPA in late June 1999. A total of six gap analyses have been conducted with wastewater agencies that are serving as initial volunteers to help implement the EMS initiative. An additional eight gap analyses will be conducted by the end of summer 1999. AMSA is also taking a lead in preparing a work plan by mid-summer to develop a “pretreatment success series” brochure based on agency efforts to improve biosolids quality through enhanced pretreatment programs. The Steering Committee met in Alexandria, VA on April 19-20 to review and make recommendations on a number of action items for approval by the Management Committee in May. The Management Committee met on March 9-10 in Denver, CO to discuss strategic planning objectives for the NBP and met on May 26 immediately following AMSA's National Environmental Policy Forum. The Management Committee also held a briefing on the NBP for Assistant Administrator for Water Chuck Fox on May 24. The Steering Committee will meet on June 230-July 1 in Alexandria, VA; the Management Committee meets July 29-30 in Chicago, IL. CONTACT: Sam Hadeed, AMSA 202/833-4655.

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