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Changes in State Regulations and Future Issues In Land Application of Sludge . Jeff Hutton Permit Section, Division Of Water Pollution Control . Contact People . Jeff Hutton/IEPA 217-782-0610 State Land Application Permits John Colletti /USEPA 312-886-6106

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changes in state regulations and future issues in land application of sludge

Changes in State Regulations and Future Issues In Land Application of Sludge

Jeff Hutton

Permit Section,

Division Of Water Pollution Control

contact people
Contact People

Jeff Hutton/IEPA

217-782-0610

State Land Application Permits

John Colletti/USEPA

312-886-6106

Federal Land Application Permits

why do we land apply sludge
Why Do We Land Apply Sludge

The Agency’s position is that material which can be recycled should be recycled in order to save landfill capacity for non-recyclable items.

Illinois Generates approximately 380,000 dry tons of sludge per year

380,000 dry tons is approximately 845,000 cubic yards

who is generating land applying sludge
Who is Generating & Land Applying Sludge

449 Facilities in Illinois generate sludge on an annual basis

332 Facilities have permits to land apply sludge in Illinois.

Facility size ranges from small towns to the Water Reclamation District of Chicago

10 Private Companies have permits to land apply sludge

immediate changes to state sludge regulations
Immediate Changes to State Sludge Regulations
  • Changes in Winter Application Procedures
  • Changes due to regulation of Technologically enhanced naturally occurring radioactive material (TENORM).
  • Radium Requirements
changes in winter application requirements
Changes in Winter Application Requirements
  • Off-site storage will be reduced to 30 days by act of the State Legislature
  • Off-site storage after November 15 must be on sites approved for winter application
  • If stockpiled material is on unapproved fields after November 15 it must be returned to the generating facility or moved to an approved site..
radium issues
Radium Issues
  • Land application of sludge containing radium is now regulated by the Illinois Emergency Management Agency.
  • The regulatory citation is 32 Ill. Adm. Code 330.40(d).
  • IEMA will notify effected facilities
radium issues8
Radium Issues
  • Contact:

Illinois Emergency Management Agency

Attn: Treatment Residuals Exemption

1035 Outer Park Drive

Springfield, Illinois 62704

Gary Forsee 217-782-1326

existing state regulations
Existing State Regulations
  • Land application of sludge is governed by 35 Ill. Adm. Code Part 391, Design Criteria For Sludge Application on Land.
  • Became effective January 1, 1984
  • Based on a very conservative approach with regard to public safety.
proposed changes to state regulations soils
Proposed Changes To State Regulations-Soils
  • Required Soil pH is reduced to 6.0
  • Site restriction will be based on permeability rates. No application at rates in excess of 20 in/hr. ½ application rate at >6 in/hr but <20 in/hr.
  • Site restriction based on depth to bedrock. Bedrock at 18 inches or less no application. Bedrock at 18 to 36 inches depth application at ½ rate.
proposed changes to state regulations setbacks
Proposed Changes To State Regulations-Setbacks
  • Setback from surface waters will be reduced to 100 feet.
  • Setback of 200 feet from operating sand and gravel pits
  • Setback of 200 feet from homes in all cases
  • Setback of 200 feet from potable wells will remain in regulations
proposed changes to state regulations13
Proposed Changes To State Regulations
  • Application will be allowed in floodplains if protected from flooding but not closer than 30 feet from the waterbody
  • Sludge monitoring and reporting will be based on sludge production as required by 40 CFR Part 503
  • Parameters to be monitored will match 40 CFR Part 503
  • 40 CFR Part 503 Ceiling Limits will be adopted
changes in metal loading lbs acre
Changes In Metal Loading (lbs/acre)

Metal ExistingProposed

Arsenic 100 36

Cadmium 10 34

Copper 250 1335

Lead 1000 267

Mercury 7 15

Nickel 100 373

Manganese 900 Not Included

Selenium 8 89

Zinc 500 2492

proposed changes to state regulations dedicated sites
Proposed Changes To State Regulations-Dedicated Sites
  • Surface Disposal under 40 CFR Part 503 will be incorporated into the State Regulations.
  • Land Reclamation projects applying at greater than agronomic rates will be treated as surface disposal units.
  • Regulations will retain surface water monitoring, groundwater monitoring and runoff controls.
future issues
Future Issues
  • Phosphorous vs. Nitrogen Application Rates
  • Urban Sprawl
  • Updating of State Regulations
  • Public Demand for Exceptional Quality Sludge Treatment
  • State Delegation of Part 503 regulations
  • Misinformation on the Internet
phosphorous concerns
Phosphorous Concerns
  • Confined Animal Feeding Operations (CAFOs) are limited to applying manure at the Phosphorous rate.
  • Municipal Sludge is usually applied at nitrogen rates.
  • Some groups have asked why manure is applied at P rates and sludge is applied at N rates.
  • Existing State regulations allow the application of up to 800 pounds of plant available P per acre (400 pounds on sandy soils) based on the Bray 1 soil test.
application of sludge based on nitrogen vs phosphorous rates
Application of sludge based on nitrogen vs phosphorous rates:

Assume:

  • 50,000 mg/kg Total Kjeldahl nitrogen
  • 5000 mg/kg Ammonia
  • 20,000 mg/kg Phosphorous
  • 1,000 tons of sludge generated (4 MGD plant)
application of sludge based on nitrogen vs phosphorous rates19
Application of sludge based on nitrogen vs. phosphorous rates:
  • Corn for grain at 150 bushels/acre
  • 20% of organic nitrogen available
  • 80% of ammonia nitrogen available
  • 1.3 pound plant available nitrogen/bushel
  • 0.55 pound plant available phosphorous/bushel
application of sludge based on nitrogen vs phosphorous rates20
Application of sludge based on nitrogen vs. phosphorous rates:

N application rate = 7.5 dt/acre

Acreage required 133 acres

P application rate = 3.75 dt/acre

Acreage required = 267 acres

application of sludge based on nitrogen vs phosphorous rates21
Application of sludge based on nitrogen vs. phosphorous rates:

Statewide this means:

Present acreage applied: ~21,000 acres

(based on N)

Acreage at P Rate : ~41,500 acres

The extra acreage required would have significant impact in NE Illinois

phosphorous concerns22
PHOSPHOROUS CONCERNS

What this means to the farmer:

Excess phosphorous applied-no big deal

Additional nitrogen needed-big deal

kane county land use plan
Kane County Land Use Plan

Gray is Urban Corridor

Yellow is Critical Growth

Brown is Towns/Villages

Green is Agricultural

updating state regulations
Updating State Regulations
  • Revised regulations will be open to public comment
  • Various interest groups will be attempting to insert their agendas into the revised sludge regulations
  • Regulated community needs to be involved in the rulemaking process.
public demand for exceptional quality sludge
Public Demand For Exceptional Quality Sludge
  • Most land applied sludge in Illinois is Class B sludge with regard to pathogen reduction.
  • Anti-land application groups in California and Virginia have demanded Class A sludge as a requirement for land application.
  • Class B is safe but this may not make any difference if decisions on sludge application on land become political.
delegation of part 503 to the state of illinois
Delegation of Part 503 to the State of Illinois
  • Presently there are 2 sludge permitting systems in Illinois
  • State Permits under 35 Ill. Adm. Code Part 391
  • Federal Permits under 40 CFR Part 503
  • Delegation means Illinois EPA would assume responsibility for administering the Federal sludge program.
delegation of part 503 to the state of illinois27
Delegation of Part 503 to the State of Illinois
  • The revised State regulations will be more closely aligned with 40 CFR Part 503
  • Illinois has the equivalent of 2 full time employees administering the sludge program. No one is assigned solely to the sludge program.
  • Illinois does not have the resources to accept delegation at this time and in the foreseeable future.
misinformation on the internet
Misinformation on the Internet
  • If claims are made regarding the land application of sludge contact myself or refer concerned individuals to:

Jeff Hutton/ Illinois EPA

217-782-0610

Jeff.Hutton@illinois.gov

general public concerns
General Public Concerns
  • Odor Issues
  • Drinking water protection
  • Disease
  • Stream contamination
  • Winter application
contact people30
Contact People

Jeff Hutton/IEPA

217-782-0610

State Land Application Permits

John Colletti/USEPA

312-886-6106

Federal Land Application Permits