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: On August 4, 1999, EPA published final NPDES permit application requirements for Treatment Works Treating Domestic Sewage (TWTDS). All TWTDS must submit required data as specified in revised 40 CFR Part 122.21(q) with their permit applications. Applicants for EPA-issued permits must submit applications on an EPA permit application Form 2S. Applicants for State-issued permits must use State forms which must require at a minimum, the information listed in 40 CFR Part 122.21. Applicants will be required to submit monitoring data for pollutants that have 40 CFR Part 503 limits for the applicant's use or disposal method at the time of permit application. Data from a minimum of three samples taken within the previous four and on-half years must be provided. The final regulations were distributed to the membership via AMSA Regulatory Alert RA 99-17. CONTACT: Mark Hoeke, AMSA 202/833-9106, or Wendy Bell , EPA 202/260-9534.
EPA to Issue Amendments to Part 503 Sewage Sludge Regulation
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 published in the Federal Register on August 4, 1999 its final Round 1, Phase 1 amendments to the 40 CFR Part 503 sewage sludge rule. The amendments provide the regulated community with flexibility in meeting certain Part 503 requirements and make technical corrections to the regulation. The amendments allow the permitting authority to reduce the monitoring frequency after sewage sludge has been monitored for two years, makes the Part 503 incineration requirements self-implementing and provides changes to the Part 403 General Pretreatment Regulations, adding a concentration for total chromium to the list of pollutants eligible for a removal credit if the sewage sludge is land applied. AMSA submitted comments on the proposal in December 1995. The final rule is effective on September 4, 1999. The amendments were distributed to the membership via Regulatory Alert RA 99-16. CONTACTS: Mark Hoeke, AMSA 202/833-9106 or Al Rubin, EPA 202/260-7589.
NRC/EPA Distribute POTW Radioactivity Survey of Biosolids
Background: 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 also approved $25,000 to study comparative risk assessment of radionuclide exposure from biosolids. 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 RA 99-11 in mid-May 1999 to all AMSA members and 500 other wastewater agencies. The guidance document provides information and technical support to POTWs to facilitate participation in the radiation survey.
Status: The Nuclear Regulatory Commission (NRC) and EPA sent questionnaires in late-June 1999 to more than 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. AMSA and WEF also prepared a joint letter encouraging these agencies to collect information on radiation background levels in biosolids and incineration ash and participate in completing the survey form. The sampling program is expected to take a full year to complete. The target date for completing the survey results is in the summer of 2001. The NBP radiation dose modeling report is expected to be completed by the end of October 1999. CONTACT: Mark Hoeke, AMSA 202/833-9106, Bob Bastian, EPA 202/260-7378, or Phyllis Sobel, NRC 301/415-6714
National Biosolids Partnership Meets in June/July
Background: U.S. EPA, AMSA, and the Water Environment Federation formed the National Biosolids Partnership (NBP) in 1997 to respond to increased public attention about the uses and safety of biosolids land application. With funding from EPA and Congressional sources, the Partnership is aggressively moving forward with the development of a national environmental management system for biosolids to ensure responsible management of biosolids, and to enhance community support for various biosolids management options. The Partnership 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.
Status: 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. A large portion of the increased appropriations request from FY1999 is designed to support pilot testing of the EMS at a number of wastewater agencies throughout the country. A follow up brochure describing the EMS initiative was distributed to the entire WEF and AMSA membership as an insert to the June 1999 Highlights publication. 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 late-summer 1999 to develop a ”pretreatment success series” brochure based on agency efforts to improve biosolids quality through enhanced pretreatment programs. The Steering Committee met on June 30-July 1 in Alexandria, VA. Partnership members also met with EPA's state biosolids regulators on June 30 in Potomac, MD. The NBP also filled the positions of EMS Manager and Technical Communications Manager to assist in the administration and coordination of various Partnership projects. The Management Committee will meet July 29-30 in Chicago, IL. CONTACT: Sam Hadeed, NBP 703/684-7741.
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