Biosolids Program Update. Rick Stevens / U.S. EPA Presentation for the CASA / CWEA Biosolids & Renewable Energy Specialty Workshop May 2015
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1 Biosolids Program Update Rick Stevens / U.S. EPA Presentation for the CASA / CWEA Biosolids & Renewable Energy Specialty Workshop May 2015
2 Today s Presentation Takes a look at statue and regulations Summarizes key issues / challenges Reflects on other key considerations applying science & technology to protect water quality
3 Perspective one hand / other hand applying science & technology to protect water quality
4 2.3 billion acres of land in the USA ü 314,964,600 harvested (2012 Ag Census) 7 M dry tons of sewage sludge generated annually ü ü 3.5 x tons/acre = 700,000 acres applied Applied is 0.2% of harvested (99.8% receive no biosolids) ~140 M tons manure ü 22,072,968 acres of manure ü applied (2012 Ag Census) On the one hand Applied is 7.0% of harvested
5 On the other Estimating the universe of chemicals is important CAS Registry* is an authoritative collection of disclosed chemical substance information ~88 million organic and inorganic substances ~15,000 new substances are added each day ~90,000 chemicals in commerce Tens of thousands of chemicals require evaluation Which chemicals pose the greatest exposure and risk *American Chemical Society s Chemical Abstracts Service: (accessed June 2014)
6 Estimating the Universe Pathogens Known Viruses Hepatitis Adenovirus 12 Norovirus Bacteria Salmonella spp. (to include S. enterica) Escherichia coli Enterococcus spp. Campylobacter spp. Parasites Giardia Cryptosporidium Emerging Bacteria strains: Escherichia coli O157:H7 [enterohemorrhagic / Shigella-toxin] Antibiotic-resistance / Horizontal Gene Transfer Viruses
7 Statute and Regulations applying science & technology to protect water quality
8 Statute Clean Water Act (CWA) Enacted October 18, 1972 (PL )
9 Use of Rivers
10 Use of Rivers
11
12 Beach Closings
13
14 Statute Clean Water Act (CWA) Enacted October 18, 1972 (PL ) Section 405 sets the framework for sewage sludge regulations (i.e., Part 503) Requires EPA to establish standards for proper treatment, use and disposal of sewage sludge Also requires EPA to conduct biennial reviews to determine if additional pollutants should be regulated
15 40 CFR Part 503 Standards for the Use or Disposal of Sewage Sludge Enacted February 1993 Solid, semi-solid, or liquid residue generated during the treatment of domestic sewage in a treatment works Specifies requirements for three management options and applies to a limited number of pollutants Land application Incineration Surface disposal Regulations
16 40 CFR Part 503 Requirements focus on the generator, user, disposer of sewage sludge q General requirements q Numeric limits q Management practices q Operational standards q Monitoring q Recordkeeping q Reporting
17 40 CFR Part 503 Self-implementing rule Federally enforceable without a permit Minimal standards for use or disposal States have adopted Part 503 or something more restrictive Typically additional requirements address environmentally sensitive areas (e.g., shallow ground water) Eight states formally delegated (SD, UT, OK, WI, TX, AZ, OH, MI) Choice of use or disposal practice is a local decision Effective management practices help support the needs of local communities Renewable resource Too valuable to waste
18 Management Practices Apply biosolids at or below the agronomic rate No harm to endangered or listed species Should not apply biosolids to flooded, frozen, or snow-covered land 10 meter (33 feet) buffer to U.S. waters
19 40 CFR Part 503 Heavy Metals Heavy Metals limits Risk based Arsenic, Cadmium, Chromium 1, Copper, Lead, Mercury, Molybdenum 2, Nickel, Selenium, Zinc Regulatory limits ü Ceiling concentration limits (CCL) ü Pollutant concentration limits (PCL) ü Cumulative pollutant loading rate (CLPR) ü Annual pollutant loading rate (APLR) amendment deleted land application limits amendment only retained CCL
20 Microbial standards ü Technology based ü Salmonella sp., fecal coliforms, enteric viruses, viable helminth ova Class A: ü <1000 fecal coliform MPN / g (dry weight) or <3 salmonellae MPN / 4 g (dry weight) and PFRP, defined process, PFRP equivalent, or pre/post to show o o 40 CFR 503 Pathogens / Indicator Organisms <1 PFU enterovirus / 4 g (dry weight) <1 viable helminth ova / 4 g (dry weight) Class B: ü Use of a PSRP or equivalent process or <2 million fecal coliform / g (dry weight)
21 Class B Biosolids Land Applied B + Management = A Public access: 30 days public access when there is a low potential for exposure 1 year public access restriction when there is a high potential for exposure (e.g., turf) Harvest: 30 days food, feed, fiber crops harvest 14 to 38 months depending on type of food crop and likelihood of touching amended soil Grazing: 30 days animals not allowed to graze
22 Vector Attraction Reduction Employ one of the following examples: Biological processes that break down volatile solids, reducing available nutrients for microbial activities and odor producing potential Ø 38 % VS reduction via treatment Chemical or physical conditions that stop microbial activity Ø Alkali to raise ph to at least 12 Physical barriers between vectors and volatile solids in the sewage sludge Ø Soil barrier
23 Key Issues and Challenges applying science & technology to protect water quality
24 Agency Drivers Public Concerns / Uncertainty Lacking Data / Low Priority Some Environmental Impacts Not Regulated Aesthetics - Odor Biosolids Controversies Public Confidence and Acceptance
25 Q: What Chemicals do we find in the Environment / Biosolids? A: All the ones we are using (i.e., assuming we are looking for them) Mostly those that are: Mass-produced Man made chemicals (i.e., PBDEs / PFCs) Not regulated / not routinely monitored Detection does not automatically imply a problem
26 Microconstituents / PPCPs / TOrCs / ECs / COECs / EDCs Interest remains high o What is their fate o Do they have any impact o Illustrates the connection of individuals activities with their environment What does it mean for biosolids management? o Similar reactions / processes for all chemicals o PBT chemicals present highest level of concern Biosolids land application as a tool for managing microconstituents o Assimilative capacities of soils o Best management practices
27 We believe Part 503 is protective No documented evidence to indicate that Part 503 has failed to protect public health (NAS Report, 2002) Much we don t know Is the Current Framework Protective? However, additional scientific work is needed to reduce persistent uncertainty about the potential for adverse health effects from exposure to biosolids (NAS Report, 2002)
28 What has EPA Been Doing to Address Challenges
29 EPA s 2003 Action Plan NAS Report (2002) 53+ recommendations Address public health concerns / scientific uncertainties EPA response ü ü 14-point action plan Significant progress NAS / NRC Report, July 2002
30 Project Title Biennial review pursuant to the CWA Section 405(d)2)(C) Status Completed
31 Project Title Status Compliance Assistance and Enforcement Actions Completed Actively address biosolids violations Require the proper land-application of biosolids to prevent risk to human health or the environment OECA developed a new look for its home page, where a new badge button on their website invites the public to be a part of EPA's work and report possible environmental violations or crimes EPA Region 7 handles enforcement / compliance
32 Project Title Methods development, optimization, and validation for microbial pollutants in sewage sludge Status Completed
33 Project Title Status Development and application of analytical methods for detecting PPCPs in sewage sludge Completed
34 Project Title Support the PEC Status Completed The PEC provides technical assistance and recommendations on process equivalencies for pathogen reduction in sewage sludge Applicants can now easily submit requests online More formal approach for evaluating equivalency HQ-OST signature EPA support is ongoing wastetech/biosolids/pathogen.cfm
35 Project Title Review criteria for molybdenum in land applied biosolids Status In progress Assess the need and appropriate level for a numerical standard for molybdenum Completed assessment Peer reviewed / regulatory decision forthcoming
36 Project Title Targeted National Sewage Sludge Survey Status Completed
37 TNSSS Design Designed to provide nationally representative results Statistically selected 74 POTWs to represent 3,337 POTWs that met the following criteria: o o o Flow greater than 1 MGD Secondary treatment or better Located in the contiguous United States Peer-reviewed both survey design and analytical methods Sampled treated sewage sludge
38 TNSSS Design (cont) Collected 84 samples at 74 POTWs in 35 states August 2006 March 2007 Measured 145 analytes, including: o 97 pharmaceuticals, steroids and hormones ü 72 antibiotics and drugs (Rx and OTC) ü 25 steroids and hormones o o o o o 28 metals 11 polybrominated diphenyl ethers (PBDEs) 4 polycyclic aromatic hydrocarbons (PAHs; pyrene, fluoranthene) 3 inorganic ions (fluoride, WAP, nitrate/nitrite) 2 semivolatile organics (4-chloroaniline, bis(2-ethylhexyl) phthalate)
39 TNSSS Findings Occurrence Wide variation in minimum and maximum levels Wide variation in detection frequency: o o 16 analytes (11%) not detected 129 analytes (89%) detected in at least one sample o Most non-pharmaceuticals were detected in more than 50 of 84 samples o Pharmaceuticals/steroids/hormones ranged from 0 to all 84 samples o 42 analytes detected in 100% of samples (3 pharmaceuticals; 3 steroids & hormones; 36 metals, inorganic ions, organics)
40 TNSSS Next Steps Characterize risk to humans and ecological receptors where data are sufficient Phase I: 10 pollutants (barium, beryllium, manganese, molybdenum, silver, 4-choroaniline, fluoranthene, pyrene, nitrate, nitrite) Phase II: 135 pollutants
41 Ten Phase I Pollutants Ø Ø Ø Ø Ø Evaluated exposure and hazards for barium, beryllium, manganese, molybdenum, silver, 4-chloroaniline, fluoranthene, pyrene, nitrate, nitrite Characterized 95 th percentile risk (HQs or cancer) Peer reviewed Addressing comments Will issue as draft assessments in 2015
42 135 Phase II Pollutants Path to evaluate exposure and effects to human and ecological receptors for the balance of the TNSSS pollutants (135 analytes) Apply peer review comments decisions from the Phase I pollutants Employ screening tools to characterize risk, after completion of any necessary changes to screening tool per recently completed peer review Response to peer review initiated in 2015
43 Available Tools On the few slides I will provide an overview of two models we use for characterizing risk Biosolids Core Risk Assessment Model (BCRAM) BCRAM Screening Tool
44 applying science & technology to protect water quality BCRAM
45 Biosolids Core Risk Assessment Model 3MRA modeling system Multimedia Multipathway Multireceptor BCRAM SAB reviewed core model also used by others Biosolids environmental settings Exposure to individuals on lifestyle farms Recent methodology and data updates Human Health Risk Assessment Protocol (2005) Exposure Factors Handbook (2011) Child Specific Exposure Factors Handbook (2008)
46 Ag Land-Application Exposure-Risk Model
47 14 - Pathway Risk Assessment HUMAN HUMAN WATER 12 DUST SOIL BIOTA HUMAN SOIL BIOTA AIR S o i l + B i o s o l i d s 8 HUMAN GROUND WATER 14 7 A N I MA L PLANT 6 HUMAN 2 PLANT 3 5 PLANT 4 CHILD PLANT ANIMAL GARDENER A N I M A L HUMAN HUMAN
48 POLLUTANT Arsenic Cadmium Lead Mercury Selenium Molybdenum CONTROLLING PATHWAY PATHWAY SCENARIO Child Eating Biosolids Animal Eating Plants Copper Nickel Zinc Plant Phytotoxicity
49 BCRAM Screening Tool applying science & technology to protect water quality
50 BCRAM Screening Tool Leverages existing probabilistic framework Runs in deterministic mode To characterize high-end exposures Key high-end inputs Pollutant concentrations Consumption rates Environmental settings Application rates Screening scenarios Crop Pasture Reclamation 7
51 Use of the Tool BCRAM Screening Tool An easy to use screening-level deterministic model with high end human and ecological hazard estimates o o Screen out pollutants ID pollutants, pathways, and receptors of greatest interest that can facilitate decisions regarding whether to perform more refined modeling / address data gaps / uncertainties As a calculator for allowable concentration of a constituent that may result in a manageable risk level o o Pollutants with no monitoring data Pollutants lacking other critical data
52 applying science & technology to protect water quality Other Key Considerations
53 Collectively Improve the Science Underlying Assessments, Communication and Public Perception Scientific analyses of safety of biosolids use is paramount Public concern is a important Systematic and proactive outreach Constrained Federal and State resources We know how to make compliant low-odor products
54 Improving Science Research Priorities Continue evaluating pollutants Conduct acceptable and informative research Field validation of models Attenuation of pollutants in biosolids systems Evaluate treatment effectiveness Develop a bioassay Define stability Odor classification
55 Take Home Messages Stability / Odors As with any business biosolids managers should meet consumer demands with a designed product which o Meets time and temperature conditions for good disinfection o Is permanently or irreversibly stabilized, unless temporary stabilization can be justified? ü o A well stabilized sludge may be the most important characteristic of a well accepted biosolids. Meets monitoring requirements to insure good disinfection Consider requiring the use of an odor classification system and/or monitoring to insure public acceptance
56 Struvite Magnesium ammonium phosphate: NH4MgPO4.6H2O Uncontrolled Controlled
57 Struvite
58 Struvite (Continued) Historically, products produced from sewage sludge meet EPA s Part 503 regulations Under consideration is whether struvite is derived from sewage sludge Raw wastewater / sewage sludge is the starting material The liquid sidestreams resulting from treatment of sewage sludge is the source of struvite
59 Questions? Rick Stevens U.S. Environmental Protection Agency Office of Water Office of Science and Technology Health and Ecological Criteria Division Washington, D.C
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