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