Green House Gas Calculator is Now Available for Biosolids

The Biosolids Emissions Assessment Model (BEAM *2022 model) may be accessed at www.biosolidsGHGs.org. When you go to the website, hosted by North East Biosolids and Residual Association (NEBRA), they ask that you make a contribution that will be used to enable them to maintain the website.  The model may be downloaded and used to compare greenhouse gas generation between various biosolids management alternatives.

New Documentary about Biosolids Recycling- It is expected to be released by PBS in November 2022. It’s part of the Viewpoint Project series and stars Dennis Quaid. It is expected to be very positive.

WEF is working on a PFAS roadmap. The roadmap will help WRRFs determine what steps to take regarding monitoring, tracking down sources, and reducing PFAS in the collections system, effluent and biosolids. 

What you need to know before monitoring for PFAS in biosolids and soils.

At this writing, EPA Method 1633 is going through multilab validation. It is expected to be finalized by the end of 2022. Dr. Ian Pepper at Arizona University has been using the method successfully to conduct his research on biosolids amended soils and their impact on crops and groundwater.  He is looking for more WRRFs to offer to be a part of the study. This would involve sampling of biosolids at the plant and soils at farms receiving biosolids. There is an instructional video on how to sample biosolids and soils when testing for PFAS. This is a good way to get your biosolids tested anonymously.

EPA Plans to include PFAS monitoring in NPDES Permits.

Sewage Sludge Incinerators in PA have already been asked to monitor for PFAS in their stack emissions. This will be difficult if not impossible because there are no standard methods for collecting stack samples or test methods for analyzing off gasses for PFAS.

The EPA proposes to include PFAS as a hazardous substance under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

Multiple organizations have written to EPA and Congress including the Water Environment Federation, National Association of Clean Water Agencies, Association of Metropolitan Water Agencies, American Water Works Association, National Association of Counties, National League of Cities, US Conference of Mayors and other organizations.  The letter dated July 11, 2022, states that “the designation of per- and poly-fluoroalkyl substances as hazardous substances will have significant financial implications for local governments.” The letter asks prior to completing its review, the proposal is accompanied by and consistent with a robust economic analysis.

At this writing, PWEA Government Affairs Committee and EPWPCOA Biosolids Committee proposes to submit comments on behalf of its members.

When will the EPA evaluate the additional 296 substances of concern typically found in biosolids?

EPA Is creating a tool to assist in the Risk Assessment Screening Process. This computer model would evaluate the potential pathways the substances could travel and the potential impact to human health and the environment. EPA will ask the Science Advisory Board to review the initial screening model hopefully by the end of 2022. The Science Advisory Board will have 6 months to review and comment. EPA will then address the comments, make any necessary changes and then release the Model for public comment. The final results of the risk assessment will be available no sooner than late in 2024.

Biosolids Advocacy

The Mid Atlantic Biosolids Association (MABA) has teamed with the PA News Media Association to create a webinar; "What your community needs to know and will never want to forget".  This is an effort to create a healthy relationship with the press. The webinar may be viewed by MABA members on their website.

Potential Emergency Situation in the Availability of PADEP Accredited Labs for Biosolids Biological Testing

As of October 5, 2022, Hawk Mountain Labs in Hazel Township notified their customers that they would no longer be accredited for biosolids testing of fecal coliform using method SM 9221E. This is one of the few commercial labs in the northeast part of the state that provide fecal coliform testing of Class A Biosolids. The reason Hawk Mountain Labs had to give up their accreditation was that the staff person who was trained and accredited to run this test would no longer be working there. Throughout PA, employers are finding it impossible to hire qualified employees and the laboratory and waste water treatment operations are no exception.

All the biosolids recyclers that relied on Hawk Mountain Labs will now have to go to either MJ Reider, Suburban, (both in Reading) or Pace in Williamsport. For some, this is significantly farther away and it will be a challenge to meet the 8 hour holding time. In addition, MJ Reider and Suburban have limited capacity to process additional samples.

In addition, some Class A Biosolids processors are required to test for Helminth Ova and Enteric Virus. There is only one laboratory in the world accredited to provide this analysis. 

If these biosolids recyclers cannot obtain testing at the required frequency, they will have to discontinue distribution, marketing, and beneficial use of their Exceptional Quality products or risk being out of compliance. Since people flush and biosolids are produced every day, recyclers would have to find alternative processing or disposal methods. PA Merchant facilities are few and far between. The facilities that provide further processing may also be unable to obtain analytical services and do not have much, if any, available capacity to accept additional biosolids.

Similarly, landfills in eastern and central PA either do not accept biosolids or are already overcommitted to the quantity of biosolids they can accept.

As a result, biosolids recyclers could be heading into an emergency situation.

The PADEP Bureau of Labs should consider enacting emergency policies and procedures to avoid this situation. Alternatives worthy of evaluation include:

1. Practice reciprocity with accredited labs in other states. Many states have accreditation programs that are equally effective as PA.  New Jersey, for example, set the reference standards for accreditation and was one of the first states to provide and require accreditation. New York also has a very reputable and well established lab accreditation program through their Department of Health.

2. Provide an interim accreditation status for those labs who meet NELAP standards.

3. Have the PADEP Laboratory accreditation program evaluated by a third party to determine if it is unnecessarily rigorous. Some labs who were accredited in PA to test for metals and PCBs in biosolids were urged to seek accreditation for fecal coliform in biosolids. They refused on the grounds that the accreditation process was over the top in terms of requirements and ridiculously picayune. Their customers even offered to pay them for the expense but the lab refused on the grounds of principle.