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 August 1997. CONTACTS: Sam Hadeed, AMSA 202/833-4655, or Wendy Bell, U.S. EPA 202/260-9534.
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. EPA has solicited comment on the
proposed rule by May 12, 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. EPA expects to finalize Phase I, Round
I sewage sludge use or disposal amendments by the end of May.
EPA plans to propose Phase II, Round I amendments in November,
with promulgation by June 1998. 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: 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 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. A draft NRC/EPA guidance document has undergone
subcommittee review and may be released for review by AMSA in
early May. AMSA, WEF and EPA will meet on May 6, in conjunction
with AMSA's National Environmental Policy Forum, to review the
EPA/NRC survey of POTWs, NRC radioactivity guidance document,
AMSA survey of radionucleides in biosolids, state regulation of
radioactive waste discharges to POTWs, and educational tools needed
to communicate with the wastewater community and general public.
The POTW survey is expected by late Summer/early Fall 1997.
CONTACT: Sam Hadeed, AMSA 202/833-4655 or Brenda Jo. Shelton,
NRC 301/415-7233.
AMSA to Co-host 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 will host 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 have all been invited
to participate in the seminar. The upcoming seminar will be used
to determine 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. An
environmental management system for biosolids is being considered
that would include a code of good practice, training, and third-party
verification. CONTACT: Sam Hadeed, AMSA 202/833-4655.