Should Wastewater Treatment Plant Workers Be Concerned About Ebola?

Reports about the spread of the Ebola virus continue to make headlines in the news.  The focus has primarily been on health care workers, but what of those in the wastewater treatment field?  Are they at risk?  According to information on the Water Environment Research Foundation (WERF) website, Ebola is not a waterborne illness.[i]   However, although wastewater treatment processes are designed to inactivate infectious agents, there is little data at this time specifically about Ebola.  The Water Environment Federation (WEF) conducted a conference call with the Centers for Disease Control (CDC) on October 16, 2014 about this issue.  At that time, the CDC announced that it is preparing an interim guidance document for wastewater treatment workers entitled, Interim Guidance for Workers Handling Untreated Sewage from Ebola Cases in the United States.  This document should be available on the CDC website very shortly.  Since they are leading the containment and prevention effort for Ebola, the CDC’s website at www.cdc.gov/ebola is the best resource for current information.

The World Health Organization (WHO) has also issued a report about Ebola and wastewater, stating on their website that, “There is no evidence to date that Ebola has been transmitted via sewerage systems, with or without wastewater treatment.”[ii]

If you are interested in obtaining the very latest information regarding Ebola and wastewater treatment, there will be a webinar addressing worker safety on November 4, 2014 from 2 to 3 PM EST.  It is a joint WEF/WERF Webcast and the registration information and overview are as follows:

Wastewater Worker Safety – Addressing Concerns on Ebola in Wastewater

11/04/2014 – 2:00 – 3:00 pm Eastern
Registration Link

Introduction:

PLEASE NOTE: In order to ensure a smooth connection for all attendees, a maximum of 1,000 computers can log into the webcast.  Make sure you SIGN ON EARLY to reserve your seat.  As a courtesy to others, if multiple people in your office are interested in viewing the webcast, please gather in a conference room.  If you are unable to join the live webcast, the recording will be available within 24 hours of the event.

This joint WEF/WERF Webcast, co-sponsored by APHA, AWWA, ACWA, AMWA, CASA, NACWA, NRWA, WaterISAC, and WateReuse, will address concerns that the Ebola virus poses on wastewater worker safety.  Join us for a discussion on:

  • A general overview of what is known about the survival of the Ebola virus in wastewater and what is needed in terms of research,
  • Sanitation and personal protective practices for wastewater personnel and other WEF resources on operator safety, and
  • The U.S. Centers for Disease Control and Prevention (CDC) Interim Guidance for Workers Handling Untreated Sewage from Ebola Cases in the United States (if released prior to this webcast).

[i] WERF (www.werf.org) reached out to the CDC, U.S. Environmental Protection Agency (EPA), Water Environment Federation (WEF), National Association of Clean Water Agencies (NACWA), and Water Research Foundation (WRF) for research on this issue.

[ii]http://apps.who.int/iris/bitstream/10665/137181/1/WHO_EVD_WSH_14_eng.pdf?ua=1

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Top Soil Blending with EQ Biosolids

Recent enforcement action by PADEP against a biosolids processor and topsoil blender using Exceptional Quality (EQ) biosolids warrants review of State and Federal regulations, as well as interpretation of the regulations and permit conditions. One little known regulatory interpretation in particular affects processors who are involved with top soil blending.

An EPA publication, “Control of Pathogens and Vector Attraction in Sewage Sludge,” is incorporated by reference into the EPA regulation covering biosolids: 40 CFR Part 503. This document states that EQ standards must be maintained as long as the processor maintains control of the material. Therefore, if the biosolids processor is responsible for top soil blending, “…the new product must undergo pathogen and vector attraction reduction processes and be analyzed for Part 503 parameters including pathogens, vector attraction reduction and heavy metals.”

If, however, the EQ product has left the control of the processor (for example, the WWTP or privately owned composting facility sells the EQ biosolids), then the material falls out of the jurisdiction of federal regulations and any subsequent blending of the material with other products is not covered by the Part 503 regulations.

For biosolids processors in Pennsylvania, there are additional specific requirements in the PADEP General Permit for Beneficial Use of Exceptional Quality Biosolids (PAG-07) that should also be reviewed. These permit conditions are summarized below:

  1. The permittee (preparer of EQ biosolids) must provide the following information in writing to the person(s) responsible for the blending operations.
  2. Storage of the EQ biosolids intended for blending and the final product cannot be stored for longer than 1 year.
  3. The amount of EQ biosolids at the blending site cannot exceed 1000 cubic yards and the final product (blended topsoil) stored by the blending operation cannot exceed 7500 cubic yards. Otherwise, a processing permit is required.
  4. Blending and storage activities cannot be conducted in a manner that will create conditions that are conducive to the harboring, breeding, or attraction of vectors. This means no standing water.
  5. Storage must be designed to prevent discharges into surface or groundwater.
  6. Measures must be taken to minimize and control odors and dust emissions.
  7. Best management practices must be implemented to minimize run-on and runoff.
  8. Trucks must be tarped to prevent the potential for dust or spillage.
  9. Trucks/trailers used to transport EQ biosolids or topsoil cannot be used to transport food or feed without proper cleaning.
  10. The blending and storage activities cannot be conducted within 100 feet of a perennial stream, within 33 feet of an intermittent stream, within 11 inches of a seasonal high water table, or within 50 feet of a property boundary.
  11. The person responsible for the blending operations must keep daily records of the weight or volume of exceptional quality biosolids received and final products sold, given away, or otherwise distributed.

Biosolids processors and topsoil blenders need to be aware of these regulations and permit conditions and their interpretations.

Posted in biosolids as fertilizer, biosolids management, disposal of biosolids | Tagged , , , , , , , , , | 2 Comments

Land Applier’s Compliance Checklist

If you are a biosolids manager who land applies biosolids to farmland, or utilizes a contractor to land apply your biosolids, the spring is a great time to check for compliance.  The following is not a complete list, but it does include the most common compliance problems that are found when PADEP conducts inspections: 

Maintain proper set back distances

Biosolids should not be applied within;

100 feet of a perennial stream

33 feet of an intermittent stream,

100 feet of a sink hole

300 feet of an occupied dwelling (unless owner signs a waiver)

300 feet of a well

100 feet of an Exceptional Value wetland

Flag areas where biosolids will be applied

Even if the field borders woodland, when biosolids is spread up to the woodland, flags must be in place when the land application takes place.

Fully Implemented Farm Conservation Plan or Sedimentation and Erosion Control Plan

Most plans contain an Implementation Schedule.  The PADEP inspectors will find your facility in compliance as long as this plan is being implemented on schedule.

Laboratory Accreditation

The lab you use to run tests for metals, PCBs and nutrients, fecal coliform or salmonella, helminth ova, and enteric virus must be accredited by PADEP Bureau of Laboratories for those tests on biosolids.  Accreditations must be renewed periodically so it is wise to check the PADEP Laboratory Accreditation website to verify that the lab doing your testing is up to date.

Holding time for fecal coliform samples

Both Exceptional Quality and non-Exceptional Quality biosolids are subject to 6 + 2 hour holding times.[1]  This means the sample must be delivered to the lab within 6 hours of sampling and the lab must start the analysis within 2 hours.

Exceptional Value Watersheds

The watershed where you have been land applying for years could be proposed as an Exceptional Value Watershed at some point.  If so, land application should be discontinued until the final designation is made as either Exceptional Value or High Quality.  If the final designation is High Quality you may resume land application.  However, if the final designation is Exceptional Value, you would either have to stop land application in that watershed, or apply for an Individual Permit for Land Application of Biosolids with PADEP.

Check the Nutrient Balance Sheets

If the farm mechanically land applies manure, they should have a Nutrient Management Plan, or a Manure Management Plan.  These plans will contain a nutrient balance sheet which shows the demand for nitrogen and/or phosphorus and the amount of nutrients available from manure, biosolids, other residuals, and fertilizer.  Be sure the farmer is not over-applying nutrients.

Test for Phosphorus Source Coefficient

This is not a regulatory requirement.  However, if you can provide the farmer with a phosphorus source coefficient, he may be able to utilize biosolids on more fields.  If you are sending a sample to Penn State AASL for metals and PCBs you can check the box on the Sample Submittal form to request the PSC.  The additional cost is $15.  [For more information on nutrient management see the Biosolids Corner article in the July August September, 2012 issue of Keystone Water Quality Manager.]

[1] The exception is Class A compost, Class B aerobically digested, and Class B anaerobically digested biosolids which has a 24 hour holding time when EPA Method 1680 or 1681 is used.

Posted in agronomic rates, beneficial use, benefits to farmers, biosolids as fertilizer, biosolids management, compliance issues, indicator organisms, land application, Nutrient management, Phosphorus | Tagged , , , , , , , , , | Leave a comment

An Update on Regrowth, Odors, and Sudden Increase in Biosolids Research

Recently, a WERF-sponsored research study addressed the challenge of developing effective ways for utilities to manage the issues of regrowth, odors, and sudden increase (ROSI) of indicator and pathogenic bacteria in biosolids.  A draft of the study’s final report entitled, “Wastewater Treatment Plant Design And Operation Modifications To Improve Management Of Biosolids Regrowth, Odors And Sudden Increase (ROSI) In Indicator Organisms” (WERF SRSK4T08), was released on June 8, 2012.  The principal investigators for this project were Matthew J. Higgins, Ph.D. from BucknellUniversity and Sudhir N. Murthy, Ph.D., P.E. from DC Water.  Garvey Resources was one of several team members who worked on this project.

Matthew J. HIggins, Ph.D.

Sudhir Murthy, Ph.D., P.E.

A previous WERF study in 2005 had suggested that, after thermophilic treatment/anaerobic digestion, some indicator organisms in biosolids were not destroyed but had actually entered a non-culturable state.  It was postulated that this “suspended animation” could be reversed by centrifuge dewatering, resulting in a “sudden increase” (SI) in bacterial densities to a level often exceeding regulatory requirements for acceptable levels of Class A biosolids.   

Based on an additional observation that SI occurs with fecal coliform (a primary indicator organism) but not Salmonella, the new testing focused on E. coli, the main fecal coliform organism.  The researchers found that tests using higher temperatures and longer time frames than are currently recommended were able to eliminate SI.  Indicator organisms were much more robust than actual pathogens. 

The other focus of the current ROSI study is on reducing odors, which are mainly associated with primary sludge, rather than waste activated sludge.  The main persistent odorants in centrifuged biosolids were compounds identified as the breakdown products of organics such as proteins, carbohydrates and fats.  It was suggested that eliminating these precursors would help reduce odors.  Field tests in which several amendments were added to the solids either during or after the dewatering process resulted in significantly reduced odors with the added benefit of reduced regrowth in the biosolids.  Also, incubating digested biosolids with protein degrading enzymes reduced odor after dewatering.  This technique had the added benefit of an increase in gas production, which could be recovered for reuse.  However, these results are preliminary and more research is needed in this area.

 The beneficial reuse of biosolids is often a key component in biosolids management plans.  The demand for beneficial reuse methods is expected to grow as wastewater treatment plants incorporate more sustainable practices into their management plans. With this in mind, the recently reported results of the ongoing WERF study addressing the problem of ROSI after anaerobic digestion are important for biosolids managers who are dealing with issues of public acceptance, especially in the areas of odor control and the perceived safety risk of biosolids reuse.  The researchers hope is that the newly developed approaches can be easily implemented for better biosolids management.

 NOTE:  This blog was based on the final report of the WERF ROSI study.  At the time of publication of this blog, the final report may be available online.  To view the final report, go to www.werf.org

Posted in beneficial use, biosolids management, Exceptional Quality Class A biosolids, Garvey Resources, indicator organisms, odor, wastewater treatment plants | Tagged , , , , , , , , , , , | Leave a comment

REGULATORY ALERT

There has been a shift in how PADEP is implementing the biosolids land application program.  Due to Act 38, related to manure management, this will affect both wastewater treatment plant managers and farmers who land apply biosolids.

What will these changes mean?  What action needs to be taken?

Well, for instance, if Class B biosolids are being land applied to farms permitted for biosolids and the farmer land applies manure, the farm should have a manure management plan or, if they have livestock, they may need a nutrient management plan.  The plans should be reviewed by the biosolids producer and/or land application contractor to verify that there is not a surplus of manure or nutrients overall. 

If the wastewater treatment plant is delivering Exceptional Quality (EQ) biosolids to farmers, they should also check the manure management plan to verify that biosolids is not being applied in excess of agronomic rate.  However, if a wastewater treatment plant produces EQ biosolids and the end users come and pick the product up, then the plant is only required to provide a user information sheet.  This sheet will enable the farmer to determine agronomic rate and to comply with any required management practices.  

Garvey Resources, Inc. provides Nutrient Management Specialist services and can assist wastewater treatment plants and farmers in the development and implementation of Nutrient Management Plans, Manure Management Plans and Odor Management Plans.  If you are interested in this service that we offer, please feel free to call or email us.  You can reach Diane Garvey at 215-36-24444 or diane@garveyresources.com.

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Anticipated Revisions to Federal Standards for Biosolids Land Application (40CFR Part503)

For years we have been hearing from EPA that Class A pathogen reduction Alternatives 3 and 4 will be “going away.”  EPA scientists are concerned that the current analytical procedures are not rigorous enough to identify helminth ova and enteric virus in biosolids.  Alternatives 3 and 4 rely on testing before and/or after processing to determine if these pathogens have been destroyed.  However, the density of these organisms in biosolids is so low that it is difficult to find them.  Since regulations only require taking a 4 gram sample for testing, the concern is how many samples would be necessary to be sure that no pathogens are present. 

The most pressing need for proposed revisions to the Federal standards for the use of biosolids is to introduce new analytical procedures for measurement of fecal coliform.  The earliest a proposed rule amendment would be published would be mid to late 2013.  There would be 60 days for public comment, then several months before the amendment to the regulation is finalized.  The effective date for the regulatory changes would most likely be the beginning of the next reporting period, January 1 of either 2014 or 2015. 

Other changes may include a new regulatory limit for molybdenum (Table 3) and the possible elimination of Table 4, “Annual Pollutant Loading Rates.” 

So, what’s a biosolids manager to do?  Biosolids managers using Alternatives 3 or 4 may want to consider doing a study of alternative ways to achieve Class A pathogen reduction.  Or, they may instead want to look into producing Class B biosolids for land application or disposal.  The advantage of starting to evaluate alternatives well in advance of the proposed changes is that there will be enough time to do pilot testing of new and innovative alternatives.  In addition, if this regulatory change results in increased costs due to necessary changes in biosolids management techniques, budgeting can be planned in advance.  For example, if capital improvements are found to be the best alternative, there will be time to design, build, and start up well before the compliance deadline. 

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Always plan ahead. It wasn’t raining when Noah built the ark.

-          Richard Cushing, novelist

 

Posted in biosolids management, compliance issues, disposal of biosolids, regulations, Uncategorized | Tagged , , , , , , , , , , , | Leave a comment

Nutrient Management Training

Laura Ball, a Research Assistant at Garvey Resources, Inc., is shown here with Dr. Douglas Beegle at a PA Nutrient Management Training Course. 

Dr. Douglas Beegle and Laura Ball

Dr. Beegle is a Distinguished Professor of Agronomy at Penn State University.  The two-day training program on Manure Management is one of five required classes that must be taken before a candidate is allowed to take the PA Nutrient Management Certification Test.  Dr. Beegle is widely known for his research and recommendations on phosphorus in crops and soils.  Laura Ball is a graduate of Delaware Valley College and has been working for Garvey Resources for two years.

As a certified Nutrient Management Specialist, Laura will be able to help farmers plan the safest and best use of biosolids, manure, and fertilizer.  This is important because, when a farmer is using manure, he must have a manure management plan, and if the farmer wants to use biosolids, the plan must show that there is not a surplus of nitrogen or phosphorus for the fields that are owned or rented.

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