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, composting, disposal of biosolids, EQ biosolids, Exceptional Quality Class A biosolids, land application, recycling | 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 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 | 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

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


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

Posted in Agriculture, agronomic rates, beneficial use, biosolids as fertilizer, biosolids management, compliance issues, disposal of biosolids, Exceptional Quality Class A biosolids, land application, Nutrient management, recycling, resource recovery facility, service offered by Garvey Resources | Tagged , , , , , , , , , , | Leave a comment

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.


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

–          Richard Cushing, novelist


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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.

Posted in Agriculture, agronomic rates, beneficial use, biosolids as fertilizer, biosolids management, compliance issues, Nutrient management, Uncategorized | Tagged , , , , , , , , , | 1 Comment

WEF Residuals and Biosolids Conference 2012

Look for Diane Garvey at WEF’s 26th Annual Residuals and Biosolids Conference in Raleigh, North Carolina from March 25 to 28.  In particular, Diane will be attending Workshop C on Sunday, March 25th.  This workshop is entitled, “Why Develop a Nutrient Management Plan – Emerging Issues in Nutrient Management Programs for Class A and Class B Biosolids.”  Garvey Resources feels that this is an important topic because the US Natural Resource Conservation Service is proposing new regulations that would include a nationwide Phosphorus Index.  It is our opinion that, if the new regulations are more stringent than the existing P Index currently implemented on a state level, it could render biosolids land application unfeasible in certain areas.  For example, if phosphorus loading was limited to plant uptake rates in special protection watersheds, such as the Chesapeake Bay, the biosolids loading rate would be so low that more acreage would be needed to apply the same amount of biosolids, most likely increasing hauling distances and, therefore, costs.  There would also be a challenge with the spreading equipment – how low can one calibrate a manure spreader?  These, and other considerations are important when developing a long term plan for biosolids management.

Diane will also be moderating Session 10 of the WEF Conference on Tuesday, March 27th, entitled, “Sustainability, Climate Change and Greenhouse Gas Issues.”

Nutrient Management Planning is only one of the services offered to our clients by Garvey Resources.  Therefore, we strive to stay abreast of trends, proposed regulations, and best management practices in the biosolids sector.

You can reach Diane at the conference by cell or text at 215-872-8701, or by email at

Posted in biosolids management, Diane Garvey, disposal of biosolids, Garvey Resources, service offered by Garvey Resources, Uncategorized | Tagged , , , , | Leave a comment

Cinderella Fuel

President Obama has set an energy goal for the United States.  In his recent State of the Union Address, he declared that, by 2035, 80% of America’s electricity is to come from clean energy sources.  As part of his “Win the Future” plan, he mentioned a number of possible energy sources including wind, solar, nuclear, clean coal, and natural gas.  As far as we’re concerned, he missed a major source of renewable energy fuel – BIOSOLIDS.  They’re not glamorous or “sexy” like wind or solar energy devices, but they are a valuable, constant, renewable energy source.

The United States Department of Agriculture supports the use of biosolids as fuel.  On January 24, 2012, they released a modified version of their “Biorefinery Assistance Program,” part of their Rural Development Energy Programs.  In the program guidelines, the USDA recognized biosolids as an “eligible feedstock” for projects that may be financed through this program.  Agriculture Secretary Tom Vilsack notes on the USDA website that “a future where America runs on cleaner, homegrown fuels is a priority” for the USDA.  In a press release on January 27, 2012, the Secretary in an address at Kansas City, MO, supported the President’s vision of American-made renewable energy sources by pledging to work with scientists, farmers and entrepreneurs to help create a nationwide biofuels economy – one which includes biosolids.

CNN quoted President Obama’s energy comments on January 26, 2012 from his visit to a UPS facility in Las Vegas, Nevada.  He called his energy plan as “all-out, all-in, all-of-the-above strategy that develops every available source of American energy.”  We see this as more evidence that NOW is the perfect time to refine the development of biosolids as a fuel source.  This is one of the best kept secrets in our arsenal of renewable fuels and that needs to change.  The economic and environmental opportunities are huge.  The biosolids sector has only just begun to tap the potential of this ubiquitous and never-ending resource as a source of fuel.  One of the challenges will be educating the public about a new way to recycle this omnipresent commodity, and gaining their acceptance.  Another is getting potential customers to take note of biosolids as fuel.  However, this will be easier once energy assistance money is forthcoming to help in the development of this “new” energy source.

It’s not really a new idea, but it is a good idea.  Dried, pelletized, Class A biosolids from wastewater treatment plants have been used as a renewable fuel source in the cement industry for (over 5 years) and companies such as Synagro are now promoting the use of biosolids pellets as fuel to other industries as well.  Synagro’s fuel product contains about 6,000 to 7,000 BTU of heat energy per pound which is equivalent to low-to-medium BTU coal.  Each ton of dried pellets contains the energy equivalent of 100 gallons of fuel oil.  If the price of foreign oil continues to rise, the cost of using biosolids will become more competitive.  Biosolids also have the potential to be a source of carbon credits for power generating facilities when used as an alternative to fossil fuels nationwide.

In Pennsylvania, the Alternative Energy Portfolio Standards (AEPS) Act of 2004 requires electric distribution companies (EDCs) and electric generation suppliers (EGSs) to supply 18 percent of electricity using alternative energy resources by 2021.  The electric power generators and distributors have already met the goals for 2021 for Tier II sources of alternative energy (which, by definition, includes biosolids) showing that it is relatively easy and economical for power generating facilities to utilize waste materials as a fuel.  The proven economic feasibility of using waste materials as a resource leaves the door open for the increased use of biosolids as an alternative fuel source.

The biosolids sector is firmly behind this move.  In December, 2011, the Water Environment Federation’s (WEF) Board of Trustees approved and released a revised position statement that calls for innovative and beneficial uses of biosolids. The statement encourages “a comprehensive approach to wastewater treatment and solids management that ensures the recycling and recovery of all associated resources including water, nutrients, organic matter and energy.”  WEF Executive Director Jeff Eger stated that, “As a natural byproduct of wastewater treatment, WEF recognizes that biosolids is a renewable resource that is too valuable to waste given our growing needs for renewable energy and sustainability.”  WEF believes that a “cultural move toward sustainability … is creating unprecedented opportunities for the wastewater and biosolids community to position biosolids as a valuable commodity.”

The use of biosolids as a renewable fuel source is not without its challenges.  But what new energy process or idea is not?  With motivation – both environmental and financial – we can meet these challenges, just as is being done today with wind and solar energy sources.

Biosolids are not something that most people think about in their day to day lives and they tend to get a bad rap in the press.  And, like Cinderella, they may not be pretty or popular yet — but they may just be our next, best source of renewable energy.  Let’s invite them to the Ball!

Posted in beneficial use, biosolids as fuel, biosolids management, biosolids treatment, disposal of biosolids, economic benefit, public support, recycling, renewable energy, resource recovery facility, Uncategorized, wastewater treatment plants | Tagged , , , , , , , , , , , , , , , , | 1 Comment

Make a List and Check It Twice!

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SEWAGE SLUDGE INCINERATION – Regulatory Changes on the Horizon

At WEFTEC 2011 there was a meeting of the residuals and biosolids committee.  One topic of discussion was the new Sewage Sludge Incineration (SSI) regulations that are pending at EPA. WEF and the National Association of Clean Water Agencies (NACWA) have been communicating with EPA to reconsider use of the proposed Most Achievable Control Technology (MACT) based air emissions standards. The proposed SSI regulations would move sludge incinerators out from the 503 regulations and apply technology based standards. NACWA says if implemented, the SSI regulations would impose the most stringent regulations in the world.  For some parameters the new regulations would be 100 times more stringent than current standards. Depending on how “Sludge Incineration” is defined, the proposed MACT Standards could also apply to sludge that is burned as fuel and gasification facilities.  Chris Hornbeck, NACWA, noted that the proposed SSI regulation is based on inappropriate assumptions and a utility will have to spend $60,000 to $100,000 to determine if their SSI can meet the proposed standards.  There are currently 3 lawsuits filed against EPA associated with the proposed rule.

Posted in beneficial use, biosolids as fuel, biosolids management, compliance issues, disposal of biosolids, economic benefit, Garvey Resources, regulations, renewable energy, resource recovery facility, wastewater treatment plants | Tagged , , , , , , , , , , , | Leave a comment