1 / 66

Biosolids Regulatory Compliance

Biosolids Regulatory Compliance. 2004 Joint RMSAWWA/RMWEA Annual Conference September 12-15, 2004 Wesley Carr, Environmental Protection Specialist CDPHE/WQCD. Biosolids Regulation. Why do we Need Biosolids Regulation?. Biosolids Regulation is Necessary to:. Protect Public Health.

livingston
Download Presentation

Biosolids Regulatory Compliance

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


  1. BiosolidsRegulatory Compliance 2004 Joint RMSAWWA/RMWEA Annual Conference September 12-15, 2004 Wesley Carr, Environmental Protection Specialist CDPHE/WQCD

  2. Biosolids Regulation Why do we Need Biosolids Regulation?

  3. Biosolids Regulation is Necessary to: Protect Public Health Biosolids are Safe... When used as directed!

  4. Biosolids Regulation is Necessary to: Protect Our Natural Resources

  5. Biosolids Regulation Also Provides an Avenue for Beneficial Use… Biosolids Complete the Cycle

  6. Biosolids in Colorado are Regulated by… EPA Region 8* - 40 CFR Part 503 “The 503s…” *Presently, EPA Region 8 has the ultimate “Authority” over the program and they have implemented a mechanism to regulate facilities – the General Permit 503s are available at: www.epa.gov/region08/water/wastewater/biohome/biohome.html

  7. Biosolids in Colorado are Also Regulated by… Colorado Department of Public Health and Environment (CDPHE)*- Biosolids Regulation No. 64 *CDPHE regulates individual application sites via NOAs (permits) which are tied to facilities/contractors Regulation 64 is available at: www.cdphe.state.co.us/op/regs/waterqualityregs.asp

  8. Biosolids in Colorado may be Regulated by… Select Counties Health Departments & Local Authorities Contact the local authority

  9. EPA Region 8 Biosolids Program Regulations and Administration

  10. EPA Region 8 General Permit - Facilities Region 8 issued a General Permit effective August 16, 2002 for Colorado facilities whose operations generate, treat, and/or use/dispose of sewage sludge by means of land application, landfill, and surface disposal under the National Pollutant Discharge Elimination System (NPDES) Any of these activities require coverage under the EPA Region 8 General Permit

  11. Basis for the General Permit • Section 405 of the Clean Water Act • 40 CFR Part 503 Section 503.7 - Requirement For a Person Who Prepares Sewage Sludge Any person who prepares sewage sludge shall ensure that the applicable requirements in this part are met when the sewage sludge is applied to the land, placed on a surface disposal site, or fired in a sewage sludge incinerator.

  12. EPA Region 8 General Permit Categories Category 1 – Generate but do not use or dispose Category 2 – Use or dispose with or without treatment Category 3 – Lagoon cleanouts

  13. Notice of Intent (NOI) for Coverage Under the General Permit NOI Requirements - General Facility Information - Biosolids Treatment Provided - Contractor Information - Biosolids Quality (Pathogens, Metals, VAR) - Land Application Site Info

  14. NOI Requirements at the Facility Processing Sewage Sludge to Produce Biosolids Requires Treatment Separate From the Wastewater Treatment Process Examples: Aerobic Digestion Anaerobic Digestion Composting

  15. NOI Requirements at The Facility – Beneficial Use Must meet Table I Metals Pathogen Destruction Criteria Vector Attraction Reduction Criteria

  16. NOI Requirements at the Site – Beneficial Use Similar to the State’s process Site name/owner Location Soils data Waters

  17. NOI Requirements at the Site – Beneficial Use • Management Practices • No harm to Endangered Species • No harm to Historic Sites • Groundwater protection • Frozen/snow covered sites • Wet weather • Storage requirements

  18. NOI Requirements at the Site – Beneficial Use • Agronomic rates • Each cropping cycle • Soil analysis • Cropping history

  19. NOI Requirements at the Site – Deep Soil Monitoring

  20. NOI Requirements at the Site – Deep Soil Monitoring • Deep Soil means 5 feet (principal root zone) • 6 Locations per Field or 320 acres • Sample every foot at each location down to five feet • composite • analyze

  21. 6 6 6 6 6 NOI Requirements at the Site – Deep Soil Monitoring Combine the six 1’ samples in one pail, the 2’s in another, the 3’s in another, etc. 1’ 2’ 3’ 4’ 5’

  22. Other NOI Requirements at the Site – Similar to State’s Phosphorous Control Site Restrictions Monitoring Record Keeping Reporting BDMS

  23. State of Colorado Biosolids Program Regulations and Administration

  24. The State’s Role in Biosolids Regulation is to: …establish requirements, prohibitions, standards and concentration limitations on the use of biosolids as a fertilizer and/or organic soil amendment in a manner so as to protect the public health and prevent the discharge of pollutants into state waters.

  25. Beneficial Use Requires a Letter of Intent (LOI) Facility Information Biosolids Analysis Information - Pathogen Reduction - VAR - Metals - Other Physical Characteristics Site Info, Maps Soils Analyses Surface and Ground Water Information Crop/Agronomic Info Biosolids Management Plan

  26. Receive Letter of Intent (LOI) • Notice is sent to the County Health Department and Commissioners upon receipt by the Division • Health Department or Commissioners may object to the use of biosolids on a particular site Regulation Section 64.10(A)

  27. Division Review Completeness letter sent out to applicant within 30 days of receipt The clock stops if LOI is incomplete and restarts after the Division receives the missing information Regulation Section 64.10(B)

  28. Notice of Authorization NOA NOA is either issued or denied within 30 days of being determined complete The applicant is notified in writing if denied and the reasons for denial Allow for a 30 – 60 day turn-around Regulation Section 64.10(C)

  29. Appeal of Issuance or Denial The applicant or other persons affected by the issuance or denial may request a hearing within 30 days of issuance or denial Only issues of law or fact may be raised at hearing Regulation Section 64.10(D)

  30. Minimum Terms and Conditions of the NOA Issuance date Terms for modifications, revocation or termination Biosolids, soils and other monitoring requirements Grazing and cropping restrictions Reporting, record keeping and labeling requirements Public access restrictions A statement of applicable penalties Regulation Section 64.10(E)

  31. NOA Duration NOAs do not expire unless terms and conditions have been incorporated Exception – no NOA may allow application of biosolids in exceedences of the cumulative pollutant loading limits Regulation Section 64.10(F)

  32. Classification and Use of Biosolids Metals Based Classification Table III, Table I Pathogen Destruction Criteria Class A, Class B Vector Attraction Reduction Methods (VAR) Regulation Section 64.12

  33. METALS BASED CLASSIFICATIONMaximum Concentration mg/kg dry 64.12(A)

  34. Pathogen Destruction Criteria Class A Biosolids* Class B Biosolids* *with respect to pathogens Regulation Section 64.12(B)

  35. Class “A” With Respect to Pathogens • Fecal < 1000 MPN/g or Salmonella s.p. < 3 MPN/4g (based on seven samples per event) AND • Use one of 5 approved methods to Further Reduce Pathogens: • Time/temp depending on solids content • pH/time then dry to at least 50% solids • Testing for enteric viruses/viable helminth ova • Testing • PFRP: composting, heat drying, heat treatment, TAD, beta ray irradiation, gamma ray irradiation, pasteurization, other as approved by EPA Region 8

  36. Class “B” With Respect to Pathogens • 7 samples - Geometric Mean <2,000,000 MPN/g or CFU* (based on seven samples per event) OR • Use 1 of 5 Approved PSRP methods: • Aerobic Digestion: 40 days @ 20 °C no less than 60 days @15 °C • Air Drying: 3 months with two months above 0 °C • Anaerobic Digestion: 15 days @ 35-55 °C no less than 60 days at 20 °C • Composting: Minimum 40 °C for 5 days with min 4 hours at 55 °C • Lime Stabilization: Add lime to raise pH to 12 after two hours of contact • Other as approved by EPA Region 8

  37. Vector Attraction Reduction (VAR) • (3) 38% VSR • (4) Anaerobic - bench scale test (40 days) • (5) Aerobic - bench scale test (30 days) • (6) Aerobic - SOUR =< 1.5mg O2/hr @ 20 °C • (7) Aerobic - 14+ days @ >40 °C (avg >45 °C) • (8) pH ^ 12+ for 2 hr then 11.5+ for 22hr • (9) Dry to 75% when stabilized solids used (digested) • (10) Dry to 90% when unstabilized solids used (undigested) • (11) Sub. injection (no significant after 1hr) • (12) Surface application w/incorporation (w/in 6hrs) Regulation Section 64.12(C)

  38. Storage of Biosolids • NOA Required for > 14 days • Must meet Class B and VAR • Other requirements based on % solids • Maximum of 2 years • Exemptions • CDPS permitted facilities • Designated solid waste disposal sites • Components of an ISDS • Offloading facilities (truck to spreader) & Tanks Regulation Section 64.13

  39. Distribution and Marketing Class A Unrestricted Use (lawn) Class A Restricted Use (containerized) Class B Restricted Use – (agricultural) Regulation Section 64.14

  40. Class “A” Unrestricted Use Must meet Table III Metals Must meet Class A Pathogen Criteria Must meet one of the VAR 3 thru 10

  41. Class “A” Restricted Use* Meet Table I Metals Must meet Class A Pathogen Criteria Must meet one of the VAR 3 thru 10 Subject to Annual Pollutant Loading Limits (APLR) *nobody practices this

  42. Annual Pollutant Loading Limits kg/ha (lbs/Ac)

  43. Land Application Must meet Table I Metals Must meet either Class A or Class B and one of VAR 3 thru 13 Table I subject to Cumulative Pollutant Loading Limits No land application if metals exceed Table I limits Regulation Section 64.15

  44. Cumulative Pollutant Loading Limits kg/ha (lbs/Ac)

  45. Facility Notification Requirements • Provide N concentration to applier • Other info as needed to comply • Written notice to permitting authority prior to land application: • site location • application period • facility name, address, phone, permit # • applier name, address, phone, permit #

  46. Application Near State Waters • No biosolids application: • up gradient and within 1 linear mile of a public water system diversion • up gradient and within 300’ of a Class 1 Recreational Use Reservoir • no surface application within 200’ of any surface water • within 50’ of any surface water if injected • within 33’ of any dry streambed • where soil is saturated or ponding is occurring • agricultural rate: within 100’ of a private well or 300’ of a community well • reclamation rate: within 300’ of a private well or 1500’ of a community well

  47. Groundwater • No biosolids application when annual high groundwater table is within 5’ of the surface • Water table is determined using: • direct observation • Soil Survey maps and/or • well completion maps with other supporting documentation such as lack of seasonal ponding or vegetation and topography suggest adequate depth to GW

  48. Application on Slopes: Agricultural

  49. Application on Slopes: Reclamation

  50. Frozen or Snow Covered Ground • No application where slope exceeds 6% • Slope < 3%, no management practice • If slope is 3 to 6 % then: • 80% vegetative cover, or • Obtain approval based on a SOP describing runoff containment

More Related