Presentation on theme: "Jeff Hutton Permit Section, Division Of Water Pollution Control"— Presentation transcript:
1Jeff Hutton Permit Section, Division Of Water Pollution Control Changes in State Regulations and Future Issues In Land Application of SludgeJeff HuttonPermit Section,Division Of Water Pollution Control
2Contact People Jeff Hutton/IEPA 217-782-0610 State Land Application PermitsJohn Colletti/USEPAFederal Land Application Permits
3Why Do We Land Apply Sludge The Agency’s position is that material which can be recycled should be recycled in order to save landfill capacity for non-recyclable items.Illinois Generates approximately 380,000 dry tons of sludge per year380,000 dry tons is approximately 845,000 cubic yards
4Who is Generating & Land Applying Sludge 449 Facilities in Illinois generate sludge on an annual basis332 Facilities have permits to land apply sludge in Illinois.Facility size ranges from small towns to the Water Reclamation District of Chicago10 Private Companies have permits to land apply sludge
5Immediate Changes to State Sludge Regulations Changes in Winter Application ProceduresChanges due to regulation of Technologically enhanced naturally occurring radioactive material (TENORM).Radium Requirements
6Changes in Winter Application Requirements Off-site storage will be reduced to 30 days by act of the State LegislatureOff-site storage after November 15 must be on sites approved for winter applicationIf stockpiled material is on unapproved fields after November 15 it must be returned to the generating facility or moved to an approved site..
7Radium IssuesLand application of sludge containing radium is now regulated by the Illinois Emergency Management Agency.The regulatory citation is 32 Ill. Adm. Code (d).IEMA will notify effected facilities
10Existing State Regulations Land application of sludge is governed by 35 Ill. Adm. Code Part 391, Design Criteria For Sludge Application on Land.Became effective January 1, 1984Based on a very conservative approach with regard to public safety.Explain that regs were issued 23 years ago and are being revised to reflect new information.
11Proposed Changes To State Regulations-Soils Required Soil pH is reduced to 6.0Site restriction will be based on permeability rates. No application at rates in excess of 20 in/hr. ½ application rate at >6 in/hr but <20 in/hr.Site restriction based on depth to bedrock. Bedrock at 18 inches or less no application. Bedrock at 18 to 36 inches depth application at ½ rate.
12Proposed Changes To State Regulations-Setbacks Setback from surface waters will be reduced to 100 feet.Setback of 200 feet from operating sand and gravel pitsSetback of 200 feet from homes in all casesSetback of 200 feet from potable wells will remain in regulations
13Proposed Changes To State Regulations Application will be allowed in floodplains if protected from flooding but not closer than 30 feet from the waterbodySludge monitoring and reporting will be based on sludge production as required by 40 CFR Part 503Parameters to be monitored will match 40 CFR Part 50340 CFR Part 503 Ceiling Limits will be adopted
14Changes In Metal Loading (lbs/acre) Metal Existing Proposed Arsenic Cadmium Copper Lead Mercury 7 15 Nickel Manganese 900 Not Included Selenium 8 89 Zinc
15Proposed Changes To State Regulations-Dedicated Sites Surface Disposal under 40 CFR Part 503 will be incorporated into the State Regulations.Land Reclamation projects applying at greater than agronomic rates will be treated as surface disposal units.Regulations will retain surface water monitoring, groundwater monitoring and runoff controls.
16Future Issues Phosphorous vs. Nitrogen Application Rates Urban Sprawl Updating of State RegulationsPublic Demand for Exceptional Quality Sludge TreatmentState Delegation of Part 503 regulationsMisinformation on the Internet
17Phosphorous ConcernsConfined Animal Feeding Operations (CAFOs) are limited to applying manure at the Phosphorous rate.Municipal Sludge is usually applied at nitrogen rates.Some groups have asked why manure is applied at P rates and sludge is applied at N rates.Existing State regulations allow the application of up to 800 pounds of plant available P per acre (400 pounds on sandy soils) based on the Bray 1 soil test.
18Application of sludge based on nitrogen vs phosphorous rates: Assume:50,000 mg/kg Total Kjeldahl nitrogen5000 mg/kg Ammonia20,000 mg/kg Phosphorous1,000 tons of sludge generated (4 MGD plant)
19Application of sludge based on nitrogen vs. phosphorous rates: Corn for grain at 150 bushels/acre20% of organic nitrogen available80% of ammonia nitrogen available1.3 pound plant available nitrogen/bushel0.55 pound plant available phosphorous/bushel
20Application of sludge based on nitrogen vs. phosphorous rates: N application rate = 7.5 dt/acre Acreage required 133 acres P application rate = 3.75 dt/acre Acreage required = 267 acres
21Application of sludge based on nitrogen vs. phosphorous rates: Statewide this means: Present acreage applied: ~21,000 acres (based on N) Acreage at P Rate : ~41,500 acres The extra acreage required would have significant impact in NE Illinois
22PHOSPHOROUS CONCERNSWhat this means to the farmer: Excess phosphorous applied-no big deal Additional nitrogen needed-big deal
23Kane County Land Use Plan Gray is Urban Corridor Yellow is Critical Growth Brown is Towns/Villages Green is Agricultural
24Updating State Regulations Revised regulations will be open to public commentVarious interest groups will be attempting to insert their agendas into the revised sludge regulationsRegulated community needs to be involved in the rulemaking process.
25Public Demand For Exceptional Quality Sludge Most land applied sludge in Illinois is Class B sludge with regard to pathogen reduction.Anti-land application groups in California and Virginia have demanded Class A sludge as a requirement for land application.Class B is safe but this may not make any difference if decisions on sludge application on land become political.
26Delegation of Part 503 to the State of Illinois Presently there are 2 sludge permitting systems in IllinoisState Permits under 35 Ill. Adm. Code Part 391Federal Permits under 40 CFR Part 503Delegation means Illinois EPA would assume responsibility for administering the Federal sludge program.
27Delegation of Part 503 to the State of Illinois The revised State regulations will be more closely aligned with 40 CFR Part 503Illinois has the equivalent of 2 full time employees administering the sludge program. No one is assigned solely to the sludge program.Illinois does not have the resources to accept delegation at this time and in the foreseeable future.
28Misinformation on the Internet If claims are made regarding the land application of sludge contact myself or refer concerned individuals to:Jeff Hutton/ Illinois EPA
29General Public Concerns Odor IssuesDrinking water protectionDiseaseStream contaminationWinter application
30Contact People Jeff Hutton/IEPA 217-782-0610 State Land Application PermitsJohn Colletti/USEPAFederal Land Application Permits