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.

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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

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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!

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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.

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Where wastewater and rainwater are used to nourish wetlands and irrigate a perennial landscape garden at Rodale Institute.

 Garvey Resources is proud to have been a partner on the team that developed the concept and design of Rodale Institute’s innovative Water Purification ECO-Center (WPEC), a wastewater/stormwater reuse and constructed wetlands facility, at their new Visitor’s Center.  Dedicated on June 16, 2011, this revolutionary on-site wastewater treatment and reuse system, developed by Rodale’s team and funded by the EPA, PADEP and Rodale Institute, utilizes septic waste as a resource.

Rodale Institute Visitor’s Center

The WPEC design uses constructed wetlands as a natural and efficient way to provide sewage treatment.

The technologies used here, along with the outstanding educational facilities at Rodale, give this project the potential to effectively demonstrate, to a broad audience, ways to treat and recycle stormwater and wastewater in a manner that will improve land use practices.

Since the Rodale Institute is a not-for-profit agricultural education center, educating the public about water stewardship is an important part of their mission.  The basis for any water lesson lies in understanding the workings of the hydrologic cycle.  Rainwater which falls on crops, for example, soaks into the ground where it eventually reaches the water table.  It moves through this to streams or rivers where it evaporates to form rain clouds.  But with the WPEC system, rainwater takes a slight detour in this cycle.

Building and wetland

When rain falls on the Visitor’s Center, it is collected in cisterns under the building and is used to flush the toilets.  After flushing, the wastewater flows into a storage tank where the liquid and solid elements are separated.  The solids decompose while the liquid is sent through the constructed wetland area adjacent to the building.  Here, the natural processes of wetlands plants and microbes clean the water twice as well as that of a traditional septic system.  From the wetland, the clean water then flows to a subsurface drip irrigation system in the perennial beds, watering and fertilizing the plants.  As the water seeps through the ground, it is cleaned even more so that, by the time it reaches groundwater level, it has been purified.  In fact, it has been shown that most organic contaminants and pathogens are removed within the first two feet of soil.

Sampling equipment is included in this design to enable Rodale to collect data on the performance of the system.  Unlike conventional septic tanks and sand mounds used for on-lot treatment, this system does not need deep and well-drained soils (which tend to be prime agricultural soils) so it could be used on building sites that do not pass the “percolation test” for conventional treatment.  If this technology becomes more widely used it could contribute to the preservation of farmland.

The simplicity and passive design of this system has great appeal.  There are no moving parts, except for pumps, so there is very little to maintain.  Constructed wetlands, although little-known by the public, have proven to be an incredibly cost effective, energy efficient, and reliable method of treating wastewater.  Part of Rodale’s educational component will be using the WPEC as a learning tool to help visitors rethink their current views about water use and treatment.  Rodale’s reputation for sound scientific study adds credibility to this lesson.

We are pleased and proud to have been a part of a project that has the potential to significantly impact the way the general public views wastewater and its reuse.  Congratulations to the Rodale Institute for leading the way.

Garvey Resources paver

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