The Impact of Phosphorus Limiting Regulations on Land Application. A Contractor s Perspective

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The Impact of Phosphorus Limiting Regulations on Land Application A Contractor s Perspective

Regulations Ohio Administrative Code, Section 3745-40 Sewage Sludge Regulations New rules governing agronomic rate determination effective July 2013

Objective of Regulations Prevent or limit the movement of phosphorus to waters of the State Improve water quality

Significance of Understanding Impacts Understanding the effects of these new regulations can help ensure that land application of biosolids remains a viable avenue.

Phosphorus Nutrient vital to plant growth Typically applied annually Commercial Fertilizer Manure Biosolids Plants only take up what they require

Phosphorus Depletion Phosphorus leaves an area in one of three ways: Erosion (water or wind) Surface water runoff Crop Uptake Up to 90% of Phosphorus transported from farmed ground is attached to the soil particles

Factors Hindering the Natural Balance Large metropolitan areas & confined feed operations Both lead to phosphorus being moved into concentrated areas Leads to higher potential for water contamination in those areas Mining of phosphate rock for commercial fertilizer Introduces phosphorus into the natural cycle that wasn t originally there

Organic vs. Inorganic Organic phosphorus are phosphorus compounds containing carbon-based molecules Biosolids and manure are sources Organic phosphorus is changed to inorganic phosphorus through mineralization Inorganic phosphorus are phosphorus compounds where phosphorus is bound to other non-carbon based molecules Commercial fertilizers

Water Soluble vs. Water Insoluble Water soluble phosphorus - phosphorus in solution Water insoluble phosphorus Labile phosphorus becomes available to plants Unavailable phosphorus - fixed

Soil Testing Total P A measure of the total phosphorus in a material Available P An indication of the amount of phosphorus available to plants Water Soluble Labile Reported as Phosphate (a compound) Not a good indicator of potential for movement

Phosphorus Indexing Measures the likelihood of phosphorus to escape a particular area Soil tests Method of fertilizer application Application rates Subsurface drainage Distance to surface water Surface water runoff class Buffer zones

Phosphorus Indexing Con t Ohio NRCS Phosphorus Index Ohio Department of Agriculture website http://www.agri.ohio.gov/divs/dlep/regs/appx/a ppendix%20e%20table%201%20901-10-2-14.pdf P Source Coefficients are used for particular P sources that have less probability of impacting water quality (less environmentally relevant) In some States, Biosolids are assigned a lower coefficient than commercial fertilizer

Phosphorus Sources are Not Equal Up to 90% of inorganic P applied to farm ground can become unavailable to plants within 2-4 weeks of application Commercial fertilizer requires mining phosphate rock A limited resource Mining process is environmentally damaging Adds more phosphorus into the environment with the potential to contaminate water

Biosolids as a Phosphorus Source Biosolids naturally contain phosphorus Part of a natural phosphorus cycle Phosphorus removal processes in wastewater treatment can increase the concentration of P in bioslids Biosolids contain less mobile P than other fertilizers (24% vs 60%) P in biosolids can become plant available over time due to microbial activity.

Best Management Practices for Biosolids Nutrient Management Plans - farmer Minimize erosion farmer Application rates contractor Vegetative buffers contractor Proper storage contractor Timing of application - contractor Applying amendments to reduce P solubility farmer or contractor

Buffer Zones Biosolids cannot be applied (by any method) within 33 feet of surface waters of the State Isolation distances are specified from bedrock and sinkholes as well to protect groundwater Buffers are more effective if they contain vegetation The specified zones are minimums

Proper Storage At least 100 feet from surface waters Away from low lying or frequently flooded areas Slope less than 15% Ensure proper drainage, shape stockpiles to shed water Surface water diversion Cover stockpiles

Timing of Application Biosolids are not land applied during a rain event Biosolids are not land applied when there a probable chance of significant precipitation in the 24 hours following application Biosolids are rarely applied to frozen ground and only under stringent circumstances

Application Rates Phosphorus based agronomic rate rules effective July 2013 Prior rates were based upon nitrogen needs N has the most potential for negative impact on surface water N based applications provide enough N for the next crop Leads to over-application of P and under-application of K

Phosphorus Based Application Uses soil test results to determine how rates are calculated Single year application Multi-year application

Rules Comparison Soil Phosphorus Level (Bray Kurtz) Old Rules New Rules <40 ppm N rate A. N rate B. P rate of 250 lb/a C. P rate 251 500 lb/a if certain criteria met >40 ppm, <100 ppm N rate A. N rate B. Multi-year P rate >100 ppm, <150 ppm N rate A. N rate B. Single-year P rate Most limiting rate Most limiting rate Most limiting rate >150 ppm P Index P Index

Ohio EPA Rate Calculation General Information Ohio EPA # Field ID # Generator Name Biosolids Agronomic Rate Calculation Worksheet Phosphorus Index Subvalue Soil Loss #N/A tons/acre/year #N/A Biosolids Data and Beneficial Use Methods Ammonia Nitrogen mg/kg Total Kjeldahl Nitrogen mg/kg Total Phosphorus mg/kg Organic Nitrogen 0.00lbs/ton Available Nitrogen 0.00lbs/ton Phosphate (P₂O₅) #N/A lbs/ton Will Immediate Incorporation / Injection be performed? Beneficial Use Site Information Soil Phosphorus Please note that the agronomic rates and phosphorus index have been calculated within the Calculated Agronomic Rates section; however, based upon the above provided Soil#N/A Phosphorus result, you must utilize the most limiting factor or the Phosphorus Index: #N/A County Soil Type Hydrologic Soil Group Year 1 Crop 1 Crop 2 Crop 3 Crop 4 Crop 5 Crop Type(s) Expected Crop Yield(s)(bu/acre or tons/acre) Year 2 Crop 1 Crop 2 Crop 3 Crop 4 Crop 5 Crop Type(s) Expected Crop Yield(s)(bu/acre or tons/acre) Year 3 Crop 1 Crop 2 Crop 3 Crop 4 Crop 5 Crop Type(s) Expected Crop Yield(s)(bu/acre or tons/acre) Year 4 Crop 1 Crop 2 Crop 3 Crop 4 Crop 5 Crop Type(s) Expected Crop Yield(s)(bu/acre or tons/acre) Year 5 Crop 1 Crop 2 Crop 3 Crop 4 Crop 5 Crop Type(s) Expected Crop Yield(s)(bu/acre or tons/acre) Crop Nitrogen Requirements (Year 1) lbs/acre Existing Available Nitrogen lbs/acre Non-Biosolids Nitrogen Application lbs/acre Phosphate (P₂O₅) Fertilizer Application lbs/acre Non-Biosolids Organic Phosphate (P₂O₅) Application lbs/acre Biosolids Phosphate (P₂O₅) Beneficial Use #N/A lbs/acre Total Organic Phosphate (P₂O₅) Fertilizer Application #N/A lbs/acre ppm ppm Connectivity to "waters of the State" Runoff Class - Slope Range #N/A Soil Phosphorus #N/A Application - Phosphate (P₂O₅) Fertilizer 0 Method - Phosphate (P₂O₅) Fertilizer Application - Organic Phosphate (P₂O₅) Fertilizer Method - Organic Phosphate (P₂O₅) Fertilizer Does runoff flow through a filter strip designed per USDA Ohio-NRCS Field Office Technical Guide Standard 393? Total Phosphorus Index Calculated Agronomic Rates Nitrogen Agronomic Rate i. Calculated Agronomic Rate Single Year Phosphate Agronomic Rate Multi-Year Phosphate Agronomic Rate Phosphorus Index dry #DIV/0! tons/acre dry #DIV/0! tons/acre dry #N/A tons/acre dry #N/A tons/acre #N/A Beneficial Use Site Records Quantity of Biosolids Beneficially Used dry tons Phosphate (P₂O₅) Beneficially Used Per Acre #DIV/0! lbs/acre Acreage Date Biosolids Delivered to Beneficial Use Site Dates of Beneficial Use to Total Days Biosolids Stored at Beneficial Use Site 0.00 Days Date Signage Posted at Beneficial Use Site Date Signage Removed from Beneficial Use Site Ohio EPA (10/13) #N/A #N/A #N/A #N/A #N/A #N/A Is a permanent sign posted at the beneficial use site?

Soil Amendments The application of certain material to farm ground can reduce the solubility of P: Water Treatment Residuals Gypsum P binds to these materials forming compounds that are less prone to movement

How does this change land application of biosolids?

THE GOOD

Multi-year application can be a benefit to farmers: One application will meet phosphorus needs for up to 5 years phosphorus in biosolids will continue to be available Reduces truck traffic in the area Reduces field compaction

THE BAD

Overcome mindset that phosphorus should be applied annually If multi-year application is not possible, nitrogen supplementation necessary Incorporation/Injection is often necessary, but conflicts with no-till operations Unless farmers adhere to similar restrictions in application of commercial fertilizer/manure, benefits of biosolids regulations are null.

THE UGLY

Local Sites Off-Limits Many land application sites within close proximity to plants are phosphorus-limited Longer haul distances are costly!

Example of Haul Distance Increase

Since 2012 Haul distances have more than doubled from around 12 miles round trip to over 28 miles round trip. Daily haul volumes have decreased by about 40% Cost to do the job has increased 38%

Another Example

Acreage Requirements Finding adequate acreage is challenging No till ground is often out Some farmers want nitrogen needs met Certain areas have a large amount of phosphorus-limited ground or less than ideal soil types Sites that are useable are exhausted rapidly

Consequences Significantly more time and effort required to find homes for biosolids Additional cost to contractors and municipalities due to longer haul distances More storage necessary at wastewater plants to store biosolids Larger volumes of valuable biosolids are being landfilled

What Can Be Done?

Contractors Educate farmers regarding the biosolids being applied Work with farmers adhering to NMPs and erosion control measures Ensure adequate training of land application personnel Employ proper equipment for land application Use incorporation/injection whenever possible Work with farmers to allow tillage of spreading boundaries

Municipalities Cake biosolids advantageous Increase plant storage Be prepared for increased cost of land application programs Consider implementing technologies to harvest a portion of the excess nutrients

Farmers Implement and adhere to well constructed Nutrient Management Plans Engage in erosion control measures, specifically utilizing cover crops and vegetative buffer areas Know the potential for phosphorus loss at any given site Become familiar with the different phosphorus sources and their advantages and disadvantages

Regulatory Work together to ensure success in water improvement by implementing similar restrictions for all types of fertilizer applications Ensure adequate personnel are available to quickly and efficiently analyze and turn around new site permit applications.

Why Do We Care?

Why Land Application? Still the most cost effective means of managing biosolids Landfilling & Incineration also have a major environmental impact Continues to be a beneficial resource for farmers Biosolids are less likely to produce P in runoff or leachate than commercial fertilizers or manure

Most Importantly Land Application is Sustainable! Land application maintains the natural nutrient cycle Land application decreases the need to add additional nutrients to the environment by depleting limited resources.

Thank You!