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.
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 withoin 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 Individaul 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 Mannagement 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 Septembert, 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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Diane Garvey was recently awarded the David A. Long Memorial Educational Service Award by the Pennsylvania Water Environment Association!
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