MABA Summer Technical Symposium and David A. Long Memorial Educational Service Award

Diane will be attending the Mid-Atlantic Biosolids Association Conference on July 18th and 19th.

MABA Summer Technical Symposium in Linthicum Heights, MD

Tuesday, July 18 to Wednesday, July 19th, 2017

Making Connections for Effective Biosolids Management


Diane Garvey was recently awarded the David A. Long Memorial Educational Service Award by the Pennsylvania Water Environment Association!

This award was established in honor of Dr. David A. Long in recognition of his lifelong service and dedication toward the education and training of wastewater and water treatment plant operators and environmental professionals.

This award is presented to individuals who distinguish themselves through their efforts and contributions to the education of water quality professionals.

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PA’s Legislative Budget and Finance Committee Recommends Odor Management Plans

Last year, the Pennsylvania General Assembly passed House Resolution 2016-60, directing the Legislative Budget and Finance Committee to review the state’s regulations for the use of biosolids via land application. In July of 2017, this review was completed, including an evaluation of how biosolids are currently used, the associated costs, and the potential alternatives. The resolution also required review of the Pennsylvania Department of Environmental Protections’ implementation of the biosolid land application program. The title of the report is “PA’s Program for Beneficial Use of Biosolids (Sewage Sludge) by Land Application.”

One of the notable points raised by the report is that Pennsylvania sends more of its biosolids to landfills than most other states. Whereas Pennsylvania sends approximately 46 percent of its biosolids to landfills, others send only about 20 percent to landfills. Additionally, while Pennsylvania uses about 38 percent of its biosolids for land application, other states use almost 60 percent of their own biosolids for the same purpose.

This is important because the report identifies land application of biosolids to be the least expensive method of biosolids management. A 2007 report from the Center for Rural Pennsylvania is cited identifying the average cost for large-scale land application of biosolids to be $145 per dry ton; the other two leading methods for biosolid disposal, landfills and incineration, cost an average of $260 and $290 per dry ton respectively.

The Legislative Budget and Finance Committee report goes on to describe the other benefits of biosolid land applications – namely, their role in reducing fertilizer costs for farmers. The report states that the nitrogen, phosphorous, and other various micronutrients contained in most biosolids are beneficial to plant growth, while also reducing surface runoff and erosion and improving the capacity of the treated soil to hold water and nutrients. Some biosolids have also been used to assist in the reclamation of surface mines in Dauphin, Centre, Clearfield, and Schuylkill Counties.

Continuing, the report addresses the protections for biosolid recycling under the Right to Farm Act, citing a December 2015 Supreme Court decision to regard the use of biosolid fertilizer as “normal agricultural practice”. The report also mentions the public’s primary concern about biosolid land application in this manner to be the offensive odors they produce.

The report continues with information on how technologies are still developing to use and process biosolids more effectively, including the potential for biosolids to be used to produce methane fuel. Another noted technology cited in the report is the OmniProcessor, demonstrated at a Seattle test facility, which could use some biosolids to produce “…drinkable water, electricity, and a pathogen-free ash”. Another alternative is the use of dried biosolids in coal fired power plants and cement plants. The report also mentions advances in digestion and thermal hydrolysis.

Finally, the report makes its recommendation regarding its findings, stating that the “DEP should modify its General Operating Permit requirements to require biosolids generators to develop odor management plans”. This strategy is designed to address the odor problem of land-applications for biosolids, which the report cites as “…the biggest threat to the beneficial use of biosolids”. It finishes by saying that, should DEP inspectors be made aware of a valid odor complaints, then they should “…take appropriate enforcement actions if the odor management plan is not being properly implemented”.

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New Fact Sheet on Dried Biosolids Distribution and Marketing

The Water Environment Federation, Residuals and Biosolids Committee, Bioenergy Technology Subcommittee, Thermal Drying Taskforce created a new fact sheet, based on a survey, regarding dried product marketing. Some observations follow;

Most of the dryers are in the eastern US and the highest density is in the mid Atlantic region.

Most dried biosolids are sold in bulk for agricultural use.  Only one respondent mentioned the product is sold as a specialty fertilizer.  PA Department of Agriculture definition; A specialty fertilizer is a fertilizer distributed for non-farm use and fertilizer material primarily intended to supply plant nutrients other than nitrogen, phosphate, and soluble potash. A commercial fertilizer distributed primarily for non-farm use, such as, but not limited to, use on home gardens, lawns, shrubbery, flowers, golf courses, municipal parks, cemeteries, greenhouses, and nurseries.

According to the PA Department of Agriculture regulations, you would not be allowed to register dried biosolids as a fertilizer because it is below the minimum concentrations of nitrogen, phosphorus and potassium.  It is surprising that only one product is a Specialty Fertilizer.  Maybe only one respondent thought to mention this.

Most respondents claimed to sell the product for between $1 and $20 per ton, 30% claimed more than $20 per ton and 15% paid for disposal.  Most generators have a backup plan for disposal when they can’t sell it all.

In addition to the lab analysis required for regulatory compliance, respondents monitored; additional pathogens and nutrients, odor, organic compounds and product temperature.  23% had to suspend distribution one or more times due to product quality.

In order to get new customers, generators rely mostly on staff to identify users, word of mouth and their website.

Most marketing programs required 2 years to become established but 33% required longer.

Most utilities rely on customers to handle transportation of the product and 23% provide delivery.

The complete 7 page fact sheet may be found on the WEF website.

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Another Look at Triclosan

In July, 2016, our article entitled, “Triclosan?  Just Wash Your Hands!” appeared in Keystone Water Quality Manager Magazine.  At that time, we reported that indicators and research pointed to a minimal risk to humans of the trace amounts of triclosan found in land-applied biosolids.  We also noted that, since such anti-microbial compounds provided no additional benefit to the consumer over washing with plain soap and water, these active ingredients could be removed from products such as antibacterial wash products without putting the safety of the general public at risk.

A couple months later, the FDA reached a similar conclusion when they released their findings that companies could not prove that the inclusion of such ingredients in consumer wash products provided better protection against spreading certain infections and preventing illness than diligent hand washing alone.  In September, 2016, the FDA issued a final ruling that over-the-counter (OTC), anti-bacterial wash products that contain one or more of 19 specific active ingredients, including triclosan, will no longer be able to be marketed.  This only applies to those products that are intended to be used with water and rinsed off.  It does not affect consumer hand “sanitizers” or wipes, or antibacterial products used in hospital and food service settings.  Manufacturers will have one year to comply by either reformulating or removing the products from the market.

This ruling by the FDA is a follow-up to their proposed rule in 2013 when data showed that long-term exposure to these active ingredients could pose minimal health risks, including bacterial resistance and hormonal effects.  The new ruling concludes that, since there is no benefit to including the ingredients – and, in fact, there is a slight negative health risk – there is no need to use them at all.  The Centers for Disease Control recommends that, if soap and water are not available, consumers should use an alcohol-based hand sanitizer instead.  Other ingredients that have shown anti-bacterial properties in alternative products include hydrogen peroxide, thyme oil, and citric acid.

The FDA has deferred ruling on three other ingredients used in consumer antiseptic wash products until more safety and effectiveness data is submitted.  The three ingredients are: benzalkonium chloride, benzethonium chloride and chloroxyleno (PCMX).

All of this is good news for the biosolids sector.  Eliminating potentially harmful ingredients in the manufacturing of consumer products will subsequently reduce their presence in biosolids and thus reduce the risk and public anxiety over the presence of these microconstituent contaminants in the future.

The 19 banned ingredients are:

  • Cloflucarban
  • Fluorosalan
  • Hexachlorophene
  • Hexylresorcinol
  • Iodophors, which are iodine-containing ingredients
  • Iodine complex, which is ammonium ether sulfate and polyoxyethylene sorbitan monolaurate
  • Iodine complex of phosphate ester of alkylaryloxy polyethylene glycol
  • Nonylphenoxypoly, or ethyleneoxy, ethanoliodine
  • Poloxamer, an iodine complex of Povidone-iodine 5 percent to 10 percent
  • Undecoylium chloride iodine complex
  • Methylbenzethonium chloride
  • Phenol greater than 1.5 percent
  • Phenol less than 1.5 percent
  • Secondary amyltricresols
  • Sodium oxychlorosene
  • Tribromsalan
  • Triclocarban
  • Triclosan
  • Triple dye
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Draft Supplement to Nutrient Management Technical Manual

The State Conservation Commission (SCC) is in the process of writing draft guidance for the next edition of the Nutrient Management Technical Manual dealing with Act 38 participants who utilize Food Processing Residuals (FPRs) and/or Biosolids (Exceptional Quality or Class B) as a nutrient source or soil amendment for agronomic purposes.   On October 24, 2016 the SCC distributed a draft supplement for comment to Nutrient Management Planners.

If you would like Garvey Resources to draft comments on behalf of your organization, please call or email.

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Paper Presented at WEFTEC 2016

Abstract: The Issue: With the growing interest in Resource Recovery, many biosolids producers are keen to continue to recover the nutrients and organics in their biosolids through land application to agricultural lands. The traditional land application of dewatered biosolids, however, often raises concerns from regulators and the public about odors, dust and nutrient run-off. In addition, newly implemented or soon to be implemented Nutrient Management Regulations in each state will limit how much and where biosolids may be used in agriculture.
The Solution: Over the last 8 years a number of biosolids producers in Canada have made use of a biosolids hydrolysis process to overcome stakeholder concerns. This process produces a high solids EQ biosolids liquid that can be land applied in a way that offers a number of benefits to the ratepayer, the public, environmental regulators, and the farmer.
Meeting Regulatory Requirements: In the United States, farmers are facing challenges due to the Natural Resource Conservation Service (NRCS) Code 590 that requires each state to develop nutrient management standards for agriculture that meet the federal requirements. Code 590 states that: “Nutrients must be applied with the right placement, in the right amount, at the right time, and from the right source to minimize nutrient losses to surface and groundwater.” Nutrient management standards will force farmers to closely manage their tillage practices and choose fertilizers and soil amendments that are less likely to migrate to water bodies. As more farmers favor “no-till” methods of planting crops to help reduce soil compaction issues and improve long term soil health, they are less inclined to participate in dewatered biosolids programs at all. The biosolids hydrolysis process and product may help farmers address these challenges. The process produces a Class A Exceptional Quality (EQ) Canadian Food Inspection Agency registered fertilizer which reduces setbacks and the need for regulatory reporting. This high solids, liquid fertilizer product also meets the requirements for US regulations.
The Process: There have been many papers written about the benefits of biosolids hydrolysis technologies used to create a low odor, EQ product when installed in a pre-digestion configuration. The hydrolysis process can also provide some of the same advantages when installed after digestion and dewatering. This post-digestion, post-dewatering configuration has a very unique benefit over pre-digestion hydrolysis. It produces a high solids (15%) liquid that significantly reduces land application costs over dewatered programs, especially when agricultural lands are within a 40 mile radius.
Benefits: From a ratepayer/cost perspective, many of the wastewater agencies in Canada that are using this hydrolysis process report over a 50% reduction in third party costs to haul and land apply high solids liquid biosolids compared to their dewatered programs.

There are a couple of reasons for this. Liquid land application programs can load a truck much faster and more accurately than dewatered programs and, since a liquid tanker truck is usually lighter than a dump trailer, it can take on a heavier payload. Also, liquid land application programs only require one operator and one piece of equipment in the field, while dewatered programs usually require 2-3 operators and three pieces of equipment. In terms of the process, most wastewater agencies are very comfortable operating and maintaining pumps and piping systems, so it is easy for them to manage a liquid program. A dewatered program, on the other hand, requires conveyors and storage hoppers that often require greater attention of operators and maintenance staff.
Canadian agencies have reported that many farmers are more receptive to biosolids management programs that minimize soil compaction and disturbance and do not require the biosolids to be stockpiled in their fields. The use of a high solids liquid biosolids product is a good solution to these concerns. During land application, the product is immediately injected into the soil in one pass, creating minimal soil disturbance and eliminating any issues with offsite odors, dust or nutrient run-off. There is no need to stockpile the biosolids in the field so this eliminates odors and nutrient run-off concerns. The injection process also minimizes nitrogen volatilization.
From the public’s and regulator’s perspective, the high solids liquid biosolids are fully contained in an enclosed tanker during transportation so there is a never an issue with odors at this time. Full containment also eliminates the risk of a biosolids spill during a sudden braking event.
Since the product is a liquid, it is very easy to add additional nutrients, such as potassium, that will make the product more marketable to the farm community as an alternative to a custom blended chemical fertilizer. New or proposed Nutrient Management Regulations for agriculture strictly limit the amount of N-P-K that may be applied to farm fields. This can be problematic with biosolids products since they usually have more phosphorus than needed when the crop nitrogen demand is met. The high solids liquid product can be custom blended to meet the crop’s proper N-P-K demand.

Additionally, the liquid form allows the material to be applied with precision and at a consistent rate, facilitating better nutrient management. The high solids liquid may be kept in storage and injected at an optimal time when the crops will utilize the nutrients assuring farmers that the nutrients applied to crops are readily available in the root zone when needed. Since the nitrogen is primarily in organic form, it is released gradually to meet the crop demand. Subsurface injection of liquid EQ biosolids also minimizes the nutrient losses due to runoff and volatilization.
When fertilizer is injected, there is a reduced loss of P compared to surface application and conventionally tilled fields. In addition, similar to Enhanced Efficiency Fertilizers, the slow release nature of the N and P reduce the risk of nutrient transport to surface and groundwater and increase availability to the crops. Product marketability is also enhanced when storage and minimum disturbance injection is provided. Given these potential benefits, the NRCS will be paying land owners to use certain Enhanced Efficiency Fertilizers as part of the Conservation Stewardship Program, up to $47/acre. At present, farmers are paying for injection of liquid manure and fertilizers and paying a premium for Enhanced Efficiency Fertilizers. The NRCS-approved nutrient risk assessment for phosphorus (P-Index) must be completed when:“phosphorus application rate exceeds land-grant university fertility rate guidelines for the planned crop(s),”
Proposition: This paper will present data showing how the biosolids hydrolysis process can help farmers comply with nutrient management regulations while reducing land application costs.

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Biosolids Presentation Updates

Diane will be presenting at three upcoming events in September.  Two of the presentations at EPWPCOA will deal with permitting for land application of biosolids and the WEFTEC presentation will cover a paper addressing biosolids hydrolysis and high solids liquid fertilizer .

EPWPCOA Meeting and Trade Show in Leesport, PA

Friday, September 16, 2016

The title of the presentation is: “The Phosphorus Index and the Impact on Land Application of Exceptional Quality and Class B Biosolids.”

The conditions of the General Permits for Land Application will be revised and reissued in April 2017 to include an evaluation of each field for the Phosphorus Index.   This presentation will evaluate the impacts of this change and provide recommendations to prepare for these new regulatory requirements.

WEFTEC 2016 – Technical Exhibition and Conference in New Orleans

Technical Session #410, “Sludge Hydrolysis,” Tuesday, September 27, 2016 at 2 PM

This will be a presentation of a paper written by Diane Garvey et. al. entitled, “Hydrolysis Process and High Solids Liquid Fertilizer Reduce Land Application Costs & Complies with Nutrient Management Regulations”

The Issue: With the growing interest in Resource Recovery, many biosolids producers are keen to continue to recover the nutrients and organics in their biosolids through land application to agricultural lands. The traditional land application of dewatered biosolids, however, often raises concerns from regulators and the public about odors, dust and nutrient run-off. In addition, newly implemented or soon to be implemented Nutrient Management Regulations in each state will limit how much and where biosolids may be used in agriculture.
The Solution: Over the last 8 years a number of biosolids producers in Canada have made use of a biosolids hydrolysis process to overcome stakeholder concerns. This process produces a high solids EQ biosolids liquid that can be land applied in a way that offers a number of benefits to the ratepayer, the public, environmental regulators, and the farmer.


EPWPCOA Event “Beneficial Use of Biosolids in Mine Reclamation” in St. Clair, PA

Session entitled “General Permitting for Beneficial Use” on Friday, September 30, 2016 at 10:45 AM

This presentation will cover the process of General Permitting for the Beneficial Use of Biosolids, including the requirements for biosolids quality, preparation of sampling plans for biosolids permitting, and the preparation of Biosolids Quality Enhancement Plans for use in the Land Application and Beneficial Use of Biosolids.

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