Septage Management Based on the Federal EPA 503 Regulations and the State Solid Waste Management Requirements

A.R. Rubin, Penny Mascaro, Ted Lyon, and Joe Zublena

Septage Defined

The EPA 503 regulation (40 CFRPT 503) was printed in the Federal Register on February 19, 1993. The regulation addresses the management of septage and sludge produced from municipal and domestic sources. Septage is specifically defined as material from domestic sources only. If any commercial or industrial wastes are combined with domestic septage, then the 503 regulation does not apply. In the 503 regulation, septage is defined as liquid, solid, or semi-solid material removed from a septic tank, portable toilet, cesspool, type III marine sanitation or similar facility that receives only non-commercial septage. Some material such as grease trap residues are often referred to as septage but are not included in this definition. The Part 503 regulation offers a simple and manageable regulatory scheme for the land application of septage. This management scheme is applicable only if the septage is applied to “non- public contact sites.” These non-public contact sites are defined as those where the potential for public exposure is minimal. An agricultural field, forest land, or a disturbed site in need of reclamation is considered a non-public contact site.

Land Application to Non-Public Sites

The Part 503 regulation mandates that domestic septage appliers are required to:

1. Meet and certify pathogen reduction and vector attraction reduction requirements prior to land application.
2. follow a prescribed Best Management Practice for septage management.
3. utilize septage application rates based upon the nitrogen requirement of the crop.
4. Ensure that septage is from domestic sources only.
5. Develop and maintain a record-keeping system germane to their land application activities.

Each of the requirements of the 503 regulation are discussed in this document. Septic tank pumpers who land apply septage are not required to obtain a Federal permit for these activities. However, North Carolina law requires that septic tank pumpers who land apply septage obtain two permits; one to transport and haul septage, and a second to land apply it. The land application permit is specific to a defined land receiver site.

Pathogen Reduction

The pathogen reduction requirement on the receiver site in the EPA 503 regulation can be achieved through either defined management practices, requirements for soil incorporation, or through alkaline stabilization of the septage. The management practices are primarily restrictions on harvesting and requirements for restricting public access to the site. The lime or alkaline stabilization process requires septage haulers to add sufficient lime (Ca (OH)2) to the septage to achieve a pH of 12 for at least 30 minutes without the addition of more alkaline material.

On those sites which rely on management practices only, certain crop restrictions must apply. The crop restrictions are:

1. Food crops with harvested parts that touch the soil surface, but are totally above ground, cannot be harvested for 14 months after application. Examples include melons and cucumbers.
2. Root crops cannot be harvested for 20 months after application if the septage is not dished in and remains on the soil surface for 4 months or longer. Examples include carrots and turnips.
3. Root crops cannot be harvested for 38 months after application if the septage remains on the soil surface for less than 4 months.
4. No crop can be harvested for at least 30 days following application of septage. Animals cannot be grazed on a septage receiver site for 30 days following land application.
5. Turf cannot be harvested for one year following application of septage if the turf is to be placed on any sites with high potential for public exposure.

In addition, public access must be restricted for at least 30 days. These restrictions include fencing and posting of signs. Any remotely situated site is considered to have a restricted access by virtue of the location.

When septage is lime stabilized prior to application, the first four restrictions (no food crop harvesting for 14 months, no root crop harvesting for either 20 or 38 months, and no harvesting for 30 days for all crop provisions) still apply. There are, however, no restrictions on animal grazing or use as turf for sites on which lime stabilized septage is applied and there are no public access restrictions to the site.

Vector Attraction and Reduction

There are three vector attraction and reduction alternatives listed in the Part 503 regulation. One of the following of the vector attraction reduction requirements must be employed whenever septage is applied to land.

1. Septage can be injected into the soil surface at the time of application and no significant amount of septage can remain present on the soil surface one hour after application. The regulation does not define a significant amount of septage.
2. Septage must be incorporated into the surface soil within six hours of application.
3. The pH of septage must be elevated to and maintained at a pH of at least 12 for a minimum of 30 minutes without the addition of more alkaline material.

Application Rate Based of Nitrogen Requirements

the maximum volume of domestic septage which can be applied to any receiver site mill depend upon the amount of nitrogen required by the crop grown on that site and the anticipated crop yield. The equation below is used in the regulation to calculate the annual application rate for septage: The annual application rate yielded will be expressed as gallons per acre per year when using a crop nitrogen uptake expressed as pounds of nitrogen per acre per year.

annual application rate (gallon/yr) = crop nitrogen requirement (lb/ac/~!r).0026

In addition to the requirements of the EPA 503 rules, the NC Div. of Solid Waste Management is proposing that no more than 50,000 gallons/acre/year be land applied. When designing application systems for NC, Agronomic N rates would be based on either the EPA formula or the NC 50,000 gal/ac/yr limit which ever is lowest.

Record Keeping

there are no formal reporting requirements listed in the EPA 503 regulation. The regulation does specify that records must be maintained by individuals who land apply septage. The following information must be recorded and retained by the septage applier for five years following any application event:

1. Site location.
2. Number of acres involved in the land application program.
3. Date and time of each application event.
4. The nitrogen requirement of the crop grown on the land receiver site.
5. The gallons of septage applied in each application event, certification that the material is domestic septage only, and that pathogen reduction and vector attraction reduction requirements have been meet.
6. A description of the pathogen reduction and vector attraction reduction methods.

North Carolina Requirements

Any individual or firm which collects, transports, or handles septage in any manner must obtain at least one, and perhaps two permits. The septage management firm must obtain a permit to transport septage over state roads. In order to obtain a permit to operate, the owner must submit the following information to the State Solid Waste Management Branch:

1. The owner’s name and the business name, address, and phone number.
2. The number and capacity of pump trucks.
3. The type of pumping equipment used on the trucks.
4. License and serial numbers of vehicles.
5. A hazardous waste permit number, if appropriate.
6. The county or counties in which the firm operates.
7. The method for ultimate disposal of septage.
8. The location of all septage disposal sites.
9. The method for managing washings and cleanings generated from the interior of the septage hauling containers and the location of the disposal site for those washings.

In addition, if the septage is applied to agricultural lands, the permittee must also submit information concerning the operation of that site. The information which must be submitted to the State Solid Waste Management Branch include:

1. Site location.
2. Name, address, and telephone number of the owner of the site.
3. The number of acres induced in the receiver area on the site.
4. The estimated application rate onto that site.
5. The crop to be grown on that site.
6. Method for managing septage during adverse weather.
7. Method for incorporation and pretreatment methods used for septage management.
8. The equipment to be utilized at that site.

The operator of that site must present to the State Solid Waste Management Branch an estimate of the nutrient and metal assimilative capacity of the site, evidence that the hydraulic components contained in septage will be assimilated on that site, and must document the nutrient requirements of the crop growing or to be grown on that site. In all cases, the state and federal regulatory agencies must consider the impact of the septage management program on rare and endangered species.

The state also limits septage application onto sites based on both a hydraulic and a nutrient load. The federal regulations list setback requirements from surface water which are less stringent that those utilized by the state. In all cases where state rules are more stringent than federal rules, then owners and operators of septage disposal sites must comply with state regulations. The state septage management rules are listed in Section .0900 of the State Solid Waste Management Rules (15ANCAC13BJ). Copies of these rules can be obtained from the Department of Environment, Health, and Natural Resources, Solid Waste Management Section, or from local health departments.

Compliance

Any individual who land applies septage must maintain records of their activities after July 19, 1993. If septage hauling is required to construct any major facility to comply with the 503 provisions, ten a one year compliance period is allowed. Full compliance with the provisions of the 503 regulation will be required by February 19, 1995.l These EPA rules are self implementing. That is, anyone who handles, transports or land applies septage is expected to comply with all provisions of the EPA 503 rule.

Vertical buffer requirements for septage receiver sites