Top Soil Blending with Exceptional Quality Biosolids

Recent enforcement action by PADEP against a biosolids processor and topsoil blender using Exceptional Quality (EQ)1 biosolids warrants review of State and Federal regulations, as well as interpretation of the regulations and permit conditions.                                                                                                                                          

Little known regulatory interpretation – An EPA publication; “Control of Pathogens and Vector Attraction in Sewage Sludge”[2] 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.”[3]

If the EQ product has left the control of the processor, for example, the WWTP or privately owned composting facility sells the EQ biosolids, 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.

In Pennsylvania, there are more specific requirements in the PADEP General Permit for Beneficial Use of Exceptional Quality Biosolids (PAG-07).  These permit conditions are summarized below.

The permittee (preparer of EQ biosolids) must provide the following information in writing to the person(s) responsible for the blending operations.

a. Storage of the EQ biosolids intended for blending and the final product cannot be stored for longer than 1 year.

b. 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.


c. 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.


d. Storage must be designed to prevent discharges into surface or groundwater.


e. Measures must be taken to minimize and control odors and dust emissions.


f. Best management practices must be implemented to minimize run-on and runoff.


g. Trucks must be tarped to prevent the potential for dust or spillage.


h. Trucks/trailers used to transport EQ biosolids or topsoil cannot be used to transport food or feed without proper cleaning.


i. 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.


j. 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 and Septage Beneficial Use General Permits Reach Expiration Date

At this writing, the general permits: PAG-07, PAG-08 and PAG-09 are set to expire on April 2, 2014.  These permits cover land application of septage, Class B biosolids and Exceptional Quality biosolids.  PADEP planned to publish proposed changes to the Conditions of the General Permit in the Pennsylvania Bulletin.  A 30 day comment period will follow and public hearings will be held if requested.  At this writing, changes to the permits are not expected to be significant. 

The WEF Annual Residuals and Biosolids Conference will be held in Austin Convention Center, Austin, Texas   Conference: May 18 – 21, 2014, Exhibition: May 19 - 20, 2014...The theme this year is; Sustainability Made Simple: Facilitating Resource Recovery.  This conference will highlight beneficial reuse options, science, and technologies currently available to leverage biosolids as a valuable resource. 

One preconference workshop has an especially timely topic: “You Just Can’t Hide a Biosolids Program! (But you can Communicate It…)”   This workshop will provide an understanding of the critical importance of proactive communications regarding your biosolids management program, and an introduction to and new ideas for communicating biosolids messages, including working with the media. 

Biosolids Committee Meeting

The next PWEA Biosolids Committee Meeting will tentatively be held at PennTec, mid-day on Tuesday, June 3rd at the Penn Stater Conference Center, State College PA.  Check to confirm final arrangements for the meeting time and room.

[1] Exceptional Quality (EQ) refers to biosolids products that meet Class A with respect to pathogens, meet Vector Attraction Reduction options 1-8 and meet the most stringent metals concentrations (Table 3) and, in PA, < 4 ppm PCBs, and is not liquid.

[2] Also known as the White House document because the picture on the front cover shows compost being spread on the White House lawn in Washington D.C.

[3] USEPA “Control of Pathogens and Vector Attraction in Sewage Sludge” 2003 pg 87


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


This award was established in honor of Dr. David A. Long in recognition of his lifelong service and dedication toward the education and training of wastewater and water treatment plant operators and environmental professionals.


This award is presented to individuals who distinguish themselves through their efforts and contributions to the education of water quality professionals.

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