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.

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About Diane Garvey

Diane Garvey has over 20 years experience as an environmental engineer in the areas of wastewater engineering services and biosolids management. She is proficient in environmental planning, processing, quality control, permitting, marketing, public relations, and recycling. In addition to helping Water Quality Managers comply with State and Federal regulations, Garvey Resources, Inc. offers an array of services including biosolids management planning, permitting assistance, and public outreach and environmental education programs. We are also certified in nutrient and odor management planning.
This entry was posted in Agriculture, agronomic rates, beneficial use, benefits to farmers, biosolids as fertilizer, biosolids management, compliance issues, EQ biosolids, Exceptional Quality Class A biosolids, indicator organisms, land application, Nutrient management, Phosphorus and tagged , , , , , , , , , , , , . Bookmark the permalink.

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