BIOSOLIDS TASK GROUP STRATEGIC PLAN July 2013 BACKGROUND In early 2008 a small group of enthusiastic industry representatives, led by Allen Gale as the inaugural Chair, formed the Biosolids Task Group. The Group hit the ground running, taking up and progressing a range of priority issues in the first 12 months of operation. Achievements included establishing a Victorian industry network, producing the first survey of biosolids production and establishing a knowledge hub of related research. Most importantly, the Group influenced the National biosolids agenda and the formation of the Australian Biosolids Partnership; later to become the ANZBP. Towards the end of the first 12 months of operation the Task Group established a “Five Key Issues” priority list and set about addressing them. Many industry representatives will be currently appreciating the benefits of these efforts today, which relate to: Adopting the WERF sustainability template Rationalising regulations and reporting Raising the profile of biosolids management with Government Addressing the risk management aspects of biosolids Developing communications guidelines and toolkits to assist in consistent engagement with stakeholders and the community. In addition to addressing these priorities one of the most important roles of the Task Group is to provide strategic advice and facilitate knowledge sharing throughout the water industry. Just to name a few achievements, the Group has been instrumental in promoting the 2009 community attitudinal survey, assisting to address spontaneous combustion of stockpiles, advocating at National forums and providing a number of useful planning and management resources. More recently the Group has influenced the revision of the Essential Services Commission biosolids management performance measure. Where previously water businesses were required to report both dry biosolids and wet sludge, the performance measure has been rationalised to reporting dried biosolids in stockpile. This is a significant improvement, particularly for businesses with lagoon based systems. Commencing in July 2012, the Biosolids Task Group embarked on a strategic planning exercise to refresh the direction of the Group. This Strategic Plan represents the culmination of those efforts and aims to address the priority biosolids management issues identified by the Victorian water industry over the coming years. VISION AND MISSION As part of the preparation of the Strategy, the Biosolids Task Group reviewed the Vision and Mission, aligning them to the overarching Vicwater Vision and Mission. The following statements have been adopted: Vision: “To support the Victorian Water Industry in becoming the champion of innovative and sustainable biosolids management” Mission: “To support the sustainable and innovative use of biosolids throughout the Victorian Water Industry by providing policy advice and facilitating industry collaboration, information sharing and research” STRATEGIC PLANNING PROCESS In order to collate the priority biosolids management issues for the water industry, all Victorian water corporations were invited to submit their “Top Five” priorities. Fifteen of the seventeen businesses responded with a wide range of issues. Common issues were grouped into 14 common themes and are detailed in Appendix 1. The water corporations were then invited to rank the 14 themes through an on-line voting process. Again 15 of the 17 corporations participated in the voting process and the results are detailed in Appendix 2. The Biosolids Task Group reviewed the voting results and resolved to target the top seven issues for action, having regard to resource availability and competing commitments. The remaining seven issues have been parked for the medium term and will be considered as part of a future strategic plan review. The following detailed scoping plans have been prepared for the seven targeted actions. ACTION PLAN Project One: Project: Person Responsible: Optimising cost of biosolids management Aravind Surapaneni Project Description: Biosolids production is unavoidable. Australia produces approximately 300,000 dry tonnes of biosolids annually Victoria produces around 93,000 dry tonnes annually (AWA Position Paper, July 2012). Costs associated with biosolids management can be separated into two main categories – (i) treatment costs (to produce biosolids), and (ii) beneficial use costs (to use biosolids). Treatment costs can be further broken down into (i) dewatering, (ii) stabilisation, and (iii) storage costs. The most common end use of biosolids in Australia is application to agricultural land, followed by landscaping and soil amendment after biosolids are composted. Costs associated with beneficial use in agriculture can be broken down into (i) transport, (ii) spreading and incorporation, (iii) storage, and (iv) sampling and monitoring. Recently, Darvodelsky (2012) reported (see tables below) the treatment and beneficial use costs of Australian biosolids based on an industry survey conducted in 2010. Treatment step Cost per tonne processed (dry) National annual cost Dewatering $100-300 $50 million Stabilisation $300-1000 $150 million Storage $20-50 $15 million Total treatment costs $400-1500 $215 million Beneficial use Cost per tonne used (dry) National annual cost Transport $100-300 $60 million Spreading and incorporation $40-150 $30 million Storage $20-30 $8 million Sampling and monitoring $10 $3 million Total beneficial use $150-500 $100 million Based on this data, Darvodelsky (2012) noted that the average cost of treatment and beneficial use in Australia is around $700 and $300 per tonne of dry biosolids, respectively. The actual costs of biosolids management across water businesses, however, will depend on the type of sewage treatment process and the type of the end use. Tracking biosolids management costs helps to identify areas of improving efficiencies and maximum cost savings. 1. 2. 3. develop a logical framework for performing a full cost analysis of biosolids management programs across water utilities in Victoria. benchmark the costs associated with managing biosolids across water utilities in Victoria. develop a tool to determine the full costs of biosolids management programs. Proposed Project Deliverables: A web based tool for determining true biosolids management costs in order to provide a logical framework for performing a full cost analysis of biosolids management programs – from point of production. Proposed Roles and Responsibilities (stakeholders involved and associated tasks): TBA Proposed Project Timelines: TBA References: AWA Position Paper (2012) The management of biosolids in Australia, July 2012. Darvodelsky P (2012) Biosolids Snapshot – a report to the Department of Sustainability, Environment, Water, Population and Communities, June 2012. Project Two: The accumulation and beneficial reuse options of alum sludge from water and wastewater plants. Project: Person Responsible: Peter Tolsher Project Description: Alum sludge is a by-product produced from water treatment plants as well as some waste water treatment plants. Some treatment plants direct backwash water straight to the sewer network where the alum sludge is diluted and treated at the waste water plant. In some towns this is not feasible and a stock pile is created at the site, with ultimate disposal being to landfill. As a relatively inert solid, neither option is particularly sustainable. With recently and proposed legislative requirements to have lower limits for NTU the volume of sludge produced has risen drastically in the past two years and has increased the problem. This project is to find options for the beneficial reuse of the Alum sludge and to work with EPA to clarify its classification and, if necessary influence its reclassification to facilitate its sustainable reuse. Proposed Project Deliverables: To produce a reference document/compendium detailing the classification of alum sludge and sustainable options for its reuse. The related deliverables include: Conduct a literature search to identify potential reuse options and environmental risks associated with alum sludge (have any businesses already conducted this work?) Canvas the water industry to identify other options for alum sludge reuse and any related research Working with EPA to ensure alum sludge is appropriately classified to protect environmental values and facilitate highest value and sustainable re-use Identify potential trials and environmental evaluations that could be considered in future to close knowledge gaps (a future project, if warranted) Discussion paper: What is the issue? What has been done to date? - research, projects etc. What are the potential reuse options? Proposed Roles and Responsibilities (stakeholders involved and associated tasks): North East Water in trialling methods/options for reuse. Victorian water industry (and beyond) – literature search of environmental risks, options for reuse and other related science ANZBP – engage to inform of project and seek input, if any EPA – to influence categorisation and endorsement for proposed Proposed Project Timelines: Conduct literature search and canvas industry for research and reports that they can share – Nov 13 Evaluate current waste category and investigate other potential categorisations. Short list preferred options and summarise evidence to support categorisation – Feb 14 Consult EPA and, if appropriate seek to influence re-categorisation – May 14 Develop draft reference compendium – Aug 14 Peer review – Oct 14 Publish final compendium – Dec 14 Project Three: Project: Optimising EIP approvals Person Responsible: Jason McGregor Project Description: Response time for the EPA to approve EIP applications over recent times has been lengthy, with some businesses reporting timeframes of around six months. These delays represent inefficiencies for the wider industry when implementing biosolids reuse opportunities. The influences that are resulting in the lengthy approval timeframes are unclear. It is proposed to work with the EPA to evaluate the related administrative process in detail and produce a consolidated guidance document to streamline the approval process. Proposed activities include: Confirmation of EIP content/requirements and form of application.Working with EPA to establish expectations, internal/external processing and approval steps. Provide simple guidance/clarity to the water industry to facilitate effective and efficient engagement with EPA when seeking EIP approvals. Proposed Project Deliverables: Provision of guidance material suitable for distribution to biosolids managers and practitioners that clearly describes EPA requirements and processes for accepting, assessing and responding to biosolids EIPs submissions, including advice on how to minimise EIP application costs and time. Proposed Roles and Responsibilities (stakeholders involved and associated tasks): Jason McGregor, information gathering and review EPA, clarification of requirements and internal approval timelines & processes BTG for draft document peer review Shauna McDonald, coordination of comms/brochure dissemination. Proposed Project Timelines: Liaison with EPA to resolve agreed process, EIP content and application inclusions and reasonable timelines – Oct 2013 Preparation of draft process flow diagram and guidance document – Dec 2013 Peer review by BTG – Feb 14 EPA endorsement – Apr 14 Publish VicWater website with notification to BTG network – May 14 Project Four: Project: Person Responsible: Review of the EPA Biosolids Management Guidelines TBC Project Description: - - Through the strategic review process, the VicWater Biosolids Network identified updating the EPA biosolids guidelines as the no. 1 key issue for Industry. The EPA has also identified it as a key piece of work that requires progress. Following discussions with the EPA, it is proposed that the work associated with reviewing the guidelines can be worked through by the EPA Water Industry Working Group and the VicWater BTG. Previous discussions on this matter with Industry have also indicated that there was a desire from Industry to move to a national code of practice (discussion paper on this from ANZBP due ~ August 2013). This could be progressed following review of guidelines at the state level – VicWater BTG could lobby AWA to then progress at national level based on Vic’s progress with State guidelines. o Regulators have noted that a National level Guideline would be appropriate, but a State level Regulation would need to be enacted to enforce the use of that Guideline. Issues raised through the BTG included: o o o o o o o o o o o o o o o o o Work with EPA to review EPA guidance to keep pace with the industry Uncertainty as to the direction of regulatory change in the next few years. Will the guidelines change? Will there be a Australian guideline? An International Guideline? The potential for uncertainty regarding future regulatory requirements with respect to land application and transportation from a public health perspective (ie need to ensure that all significant capital investment is forward-thinking) The EPA biosolids guideline for land application does not recognise lagoon based treatment followed by desludging and solar/air stabilisation as a type of treatment Accept air drying as an approved process if test results indicate a T1 product. Biosolids lose nutrient and calorific value over time. Investigating whether the 3 year holding period for stockpiles is conservative and can be reduced would be of value Acceptance of alternative treatment methods by EPA to achieve T1 if validated by extensive testing programs Managing stockpiles & minimising double handling of biosolids (on treatment plant sites) that has to be stored for 3 years to achieve T1. Classification or recognition of lagoon sludge or biosolids that has been in the process for an extended time (10 years plus). When completing application calculations (ie CLAR) some of the contaminant limits outlined in the EPA biosolids guidelines are what trigger your lowest application rate even when results received for that parameter are actually below the limit of detection. Review contaminant limits as they could be too conservative in some instances Update/ amendment of state EPA guidelines to meet Australian standards for biosolids- provide more flexibility for third party application (i.e. conservative CLAR values-etc) Change the guidelines to allow capital applications of P and dilution for heavy metals Simplify management requirements for third party use through use of a risk based approach to management controls (eliminate unnecessary controls) Regulator should only require analysis of biosolids leaving site. Blending of different quality biosolids to produce a better quality product should be an option Develop a best practice guideline for biosolids management Should there be a review of the guidelines in relation to sampling and testing of organic chemicals. Should this be risk based, with a lower number of samples required or should the level of sampling be the same as the level of sampling for metals? The sampling requirements for pesticides and other trace elements needs reviewing. I think there is already some preliminary investigations underway on this issue Proposed Project Deliverables: - - Engage with Industry to identify: o benefits and barriers in current regulations o opportunities to improve Guidelines Engage with EPA to review and, if appropriate, revise the guidelines. - Consider the merits of developing a “how-to manual” of best practice / industry code of practice, possibly inconjunction with the ANZBP - In future work with EPA, ANZBP and other interstate stakeholders to establish National guidelines leveraging from the (revised) Victorian guidelines - Canvas opinions of water industry – what do you like about the guidelines, what do you believe needs to be changed? What is the science that supports proposed changes? Encourage industry to talk to beneficial reuse providers. Proposed Roles and Responsibilities (stakeholders involved and associated tasks): - EPA EPA Water Industry Working Group BTG ANZBP (for information) VicWater Proposed Project Timelines: - EPA has indicated that they would be available to work with the industry on this matter in 2014. - Some initial scoping work with the EPA Industry Working Group and BTG can be completed late2013 Project Five: Project: Combined Biosolids and Organic Waste Management Person Responsible: Muriel Lepesteur-Thompson and Luke Wilson Project Description: There is an increased level of interest from water authorities to receive Industrial Organic Wastes (IOW) to increase biogas production potential at wastewater treatment plants. IOW may include meat processing wastes, brewery wastes, food production wastes, fats, oils and grease, all of which can have a higher biogas yield than sewage sludge. These wastes are generally classified as prescribed wastes which are currently either sent to licensed waste contractors for further treatment or to landfill. The water industry is uniquely placed to play a part in the solution to manage organic wastes as the infrastructure required to appropriately process organic wastes, recover valuable materials and process them into downstream valuable products exists or is familiar to water corporations. Similarly, the required skills to build and operate these types of facilities are already present within the water industry. The term biosolids is defined by the EPA as “organic solids derived from sewage treatment processes”. If prescribed wastes are received directly at wastewater treatment plants, this may change the risk profile of biosolids management. A purpose built resource recovery facility may have a low percentage of solids derived from the sewerage system, when compared to those from other IOW inputs. Management of solids remains one of the greatest risks to the viability of any of these types of facilities. Without a marketable product, stockpiling of the biosolids produced could make the plant unviable (Fawcett, 2013). Other related issues identified through a survey of the Victorian water industry by the BTG include: The challenges associated with liaising with local government and 3rd parties to centralise bio-waste processing How to consider biosolids holistically as part of an overall resource recovery strategy, which considers optimal points in the whole system to recover resources and considers any enhanced benefits of combined waste streams Identifying viable ways to recover costs from biosolids processing (ie through industrial crops or green power). In order to ensure that a competitive market can be established for the reuse of stabilised solids from combined facilities, it should be determined in conjunction with the Victorian EPA: how stabilised solids from co-digestion processes will be classified which regulations will govern its beneficial reuse the role of the water industry in the management of prescribed organic wastes. It is recognised that waste streams and processes will vary for individual treatment and waste management operation. Consequently categorisation of end products may require a case by case approval process. This in turn may drive either revised guidelines or stand alone new guidelines depending on the complexity of the issues. The outcome of this project will either confirm the applicability of the Publication 943 to combined wastes, or will specify the additional governing regulations to be followed to enable the recovery of resources through sustainable beneficial reuse and support the sustainable and innovative use of biosolids throughout the Victorian Water Industry. Drivers Water corporations’ trade waste requirements contribute to the load of organic waste requiring management. When the price of the landfill disposal route escalates due to market forces and regulatory controls, such as the EPA Landfill Levy, generators of trade waste may divert organic wastes to sewer to take advantage of the relatively cheaper trade waste charges. The Victorian Waste and Resource Recovery Policy April 2013, ‘Getting Full Value’, states that strong demand for recovered materials is fundamental to the successful recovery of materials. It states that Victoria’s waste management and resource recovery system will promote forms of waste management and resource recovery which will have the least impact on the natural environment. It is the aim of the Biosolids Task Group to promote biosolids as a resource, provide advice on proposed initiatives and to develop strategic advice on biosolids management for the Victorian Water Industry. The purpose of the BTG is to serve as a steering committee on biosolids related issues, including (but not limited to): Promoting biosolids as a resource and its beneficial uses Working with government on the development and implementation of biosolids related management frameworks Providing advice to industry on current practices and proposed initiatives Coordinating comments from the water industry and being a conduit to represent and progress Victorian biosolids management issues at National forums Proposed Project Deliverables: In order to ensure the water industry can deliver optimal outcomes through combined biosolids and organic waste management it is proposed that the BTG develop a Position Paper to identify: What does it mean for biosolids if we go down this path? If wastes from industries other than Trade Waste sources are treated by water authorities, how will stabilised sludges be regulated? How does acceptance of other wastes change the risk profile of biosolids management? The role of the water industry with regard to organic waste management. To achieve these deliverables the BTG should establish: What is currently happening within water authorities with regard to combined waste management? How do the initiatives of the water authorities align with the objectives of other government departments such as: DEPI, MWMG, DSDB, etc? What is the position of the EPA with regard to the management of combined waste sludges? What are the additional wastes/feedstocks being considered and what legislation applies to these? How do the new feedstocks sit within the biosolids guidelines? Do these feedstocks change the risk profile for biosolids including but not limited to pathogen vectors and odour production? Are there any shortcomings of 943 with regard to combined sludges? The outcome of this project will either confirm the applicability of Publication 943 to combined wastes, or will specify the additional governing regulations to be followed to ensure the long term beneficial reuse of stabilised sludges from combined facilities. Proposed Roles and Responsibilities (stakeholders involved and associated tasks): BTG Project leader – Jeremy Guneratne Broader Victorian industry – determine activities within the field EPA – to consider policy position and beneficial reuse opportunities and controls as part of an overall evaluation of the applicability of Publication 943 DEPI?? Proposed Project Timelines: Literature search & consultation with industry to evaluate activities in the field – Dec 13 Work with EPA – initially could canvas policy position independently of biosolids guidelines review and ultimately tie into Project Four - Review of the EPA Biosolids Management Guidelines Disseminate project deliverables via BTG network and publish on Vicwater website - TBA Project Six: Project: Optimising multiple land applications & contaminant loading Person Responsible: Doug Gardner Project Description: 1. Collect existing data on changes in the soil from past applications of biosolids. This will require the cooperation of corporations that have existing data as well as any international material that may be available and appropriate. 2. Examine current soil sampling techniques to ensure they are adequate for the low concentrations involved in this process. 3. Look at the current testing methods and protocols as well as see that they are at a cost effective levels of detection. This should ensure any decision is based on usable and repeatable data. 4. Establish a benchmark peak loading for the major toxic elements found in biosolids. This will be the point at which the land can no longer be used for application but before there is an impact on produce from the land or the MRL (maximum residue limit) of its produce. 5. Establish a degradation /adsorption rate for each major toxic element. This is the point at which it may change to a point where it is unavailable to plants. i.e. As and Cr. This is important as some elements may be measured in a soil without impeding production or product in their current from. Proposed Project Deliverables: 1. A table of toxic elements common in biosolids in Victoria. I would be inclined to exclude micro nutrients from this list as they are less emotive and still essential for plant growth. i.e. Cu, Zn, Mg. 2. Supply a researched or best guess safe total soil limit for each element/soil type combination. 3. A maximum annual loading limit for each element/soil combination. This should account for any binding effect in soil that locks it up in either the clay matrix or in the organic carbon. 4. Leave the macro nutrients that include N,P,K,Ca,S etc. to be assessed as they are currently under NLAR (nutrient limiting application rates) in the guidelines with the proviso that as long as the application meet plant requirements or capital application and any buffering capacity that may reduce their availability in the soil or be required for latter use. This can be the case of the P buffer effect on limiting available P from the biosolids and also the delayed N response seen from total N to available N. Proposed Roles and Responsibilities (stakeholders involved and associated tasks): Coordination: Biosolids Task Group Desktop Research: ANZPB Gap analysis: Vic Water may indicate a research project on a specific element soil type relationship that has limited or no current data. An example could be Mo in duplex basalt clays. Publication: EPA Vic as part of or an addendum to the guidelines for reuse. Proposed Project Timelines: Research: TBA Project Work: TBA References: 1. Phosphorus Sorption, Desorption, and Buffering Capacity in a Biosolids-Amended Mollisol Yaobing Sui and Michael L. Thompson 2. Toxicity of heavy metals to microorganisms and microbial processes in agricultural soils Ken E Giller, Ernst Witter, Steve P Mcgrath 3. The Real Dirt on Sewage Sludge - Wendy Priesnitz, editor Natural Life Magazine 4. Effect of long-term irrigation with untreated sewage effluents on soil properties and heavy metal adsorption of leptosols and vertisols in Central Mexico - Christina Siebe, Walter R. Fischer 5. Possible chemical forms of cadmium and varietal differences in cadmium concentrations in the phloem sap of rice plants (Oryza sativa L.) - Mariyo Kato et al 6. Australia New Zealand Food Standards Code - Standard 1.4.2 - Maximum Residue Limits (Australia Only) Project Seven: Project: Person Responsible: Community Engagement for Wider Acceptance of Biosolids as a Beneficial Resource Carly Robertson Project Description: When faced with community concern re the use of biosolids in farming, Victorian water authorities have often pointed to the high degree of EPA regulation in Victoria (i.e. the Guidelines) to support their argument that any potential risks are being appropriately managed. However I don’t think the cause and effect link has been appropriately explained to the community. For example what aspects of the regulation control what risks? Are some risks controlled outside of EPA regulation? This all needs to be explained in a clear and direct way, which is easy for community members to understand despite not having previous involvement with biosolids. Proposed Project Deliverables: Discussion paper: Identify specific community concerns (risks) applicable to the Victorian industry – through literature or anecdotal evidence. Show how these risks are mitigated through the application of the EPA Guidelines, or by other controls outside of the Guidelines. If the above process highlights community concerns that are currently being managed outside of the Guidelines, develop best practice methodologies which can be used by Industry to specifically control those risks. These methodologies can then be pointed to when members are defending or attempting to further the use of their biosolids product in agriculture. Potentially provide case-studies that highlight how risks are controlled – would require BTG members to put forward examples. Background work: what has been done in the past re community engagement/surveys. Proposed Roles and Responsibilities (stakeholders involved and associated tasks): Proposed Project Timelines: Appendix 1 Issues Raised by Victorian Water Industry 1 Issue Community Engagement for Wider Acceptance of Biosolids as a Beneficial Resource engagement of the farming community as a means of increasing wider community acceptance of biosolids use Work to increase community acceptance/support for land application of biosolids Lack of engagement with the potential end users in the agricultural community Work to increase community acceptance/support for land application of biosolids Breaking barriers - The stigma attached to the use of biosolids in food production in horticulture industry continue to be the main barrier to the beneficial use of biosolids. Many consumers are still likely to reject direct edible produce Knowledge around reliable, robust markets for products Risks posed by media misrepresentation and community backlash which may be detrimental to a Reuse Scheme operated by the Water Authority Public perceptions issues around the safety of using biosolids Change public perception for third party use of biosolids- shift from opinion of Water Corp’s needing to “get rid of biosolids” to providing a product with commercial value Suitable information to sell the organic benefits of biosolids beyond the NPKS story Transport and application service for third party use for farmers with limited knowledge of product and the correct application procedures. How much assistance should a Corp provide and at what cost to ensure biosolids are applied and stored correctly? 2 Optimising multiple land applications & contaminant loading Future land availability (when taking into account required resting periods) for ongoing spreading and storage of processed biosolids What is the potential for build-up of chemicals from biosolids in the long term. The long term effects of using biosolids in land application needs to be investigated with respect to the accumulation of products in biosolids building up in agricultural use Is C1 achievable with Zinc and Copper coming from domestic sources? If not, what can we do to create a driver to improve biosolids quality in relation to other parameters, given that the biosolids will be classed as C2? Produce quality – e.g. Feed test (forage quality) on biosolids application sites. What is the effect of using biosolids on land and plants? Will biosolids application lead to contaminated produce? There may be a need for an ongoing monitoring project 3 Optimising cost of biosolids management High capital & operating costs of biosolids production – continuous lagoon desludging, third party desludging providers & in-house operations Cost effective options for insitu desludging of lagoons Demonstrating value for money to a produce a high quality product Managing maintenance cost of dewatering equipment 4 Working to maintain a competitive market place Reliance on a single service provider for biosolids collection and treatment Promote biosolids opportunities to increase the number and diversity of service providers 5 Synergies of combined biosolids and organic waste management The challenges associated with liaising with local government and 3 rd parties to centralise bio-waste processing How to consider biosolids holistically as part of an overall resource recovery strategy, which considers optimal points in the whole system to recover resources and considers any enhanced benefits of combined waste streams Identifying viable ways to recover costs from biosolids processing (ie through industrial crops or green power). 6 Issue Identify funding opportunities to develop new initiatives 7 Improved measures for KPI reporting KPI’s to reflect periodic bulk desludging and biosolids applications 8 Optimising EIP approvals The response time for submitting an Environment Improvement plan (EIP) for EPA approval for our last 2 applications took 6 months. This process needs speeding up The time frame for the approval process through the regulator should be quicker 9 Carbon sequestration opportunities Carbon sequestration and the role of biosolids is not well understood. Land application of biosolids may provide an opportunity to sequester carbon but there is a need to understand the value and establish the influence of biosolids on carbon uptake in plants. 10 Control of odour in raw sludge 11 Review of the EPA Biosolids Management Guidelines Work with EPA to review EPA guidance to keep pace with the industry Uncertainty as to the direction of regulatory change in the next few years. Will the guidelines change? Will there be a Australian guideline? An International Guideline? The potential for uncertainty regarding future regulatory requirements with respect to land application and transportation from a public health perspective (ie need to ensure that all significant capital investment is forward-thinking) The EPA biosolids guideline for land application does not recognise lagoon based treatment followed by desludging and solar/air stabilisation as a type of treatment Accept air drying as an approved process if test results indicate a T1 product. Biosolids lose nutrient and calorific value over time. Investigating whether the 3 year holding period for stockpiles is conservative and can be reduced would be of value Acceptance of alternative treatment methods by EPA to achieve T1 if validated by extensive testing programs Managing stockpiles & minimising double handling of biosolids (on treatment plant sites) that has to be stored for 3 years to achieve T1. Classification or recognition of lagoon sludge or biosolids that has been in the process for an extended time (10 years plus). When completing application calculations (ie CLAR) some of the contaminant limits outlined in the EPA biosolids guidelines are what trigger your lowest application rate even when results received for that parameter are actually below the limit of detection. Review contaminant limits as they could be too conservative in some instances Update/ amendment of state EPA guidelines to meet Australian standards for biosolidsprovide more flexibility for third party application (i.e. conservative CLAR values-etc) Change the guidelines to allow capital applications of P and dilution for heavy metals Simplify management requirements for third party use through use of a risk based approach to management controls (eliminate unnecessary controls) Regulator should only require analysis of biosolids leaving site. Blending of different quality biosolids to produce a better quality product should be an option Develop a best practice guideline for biosolids management Should there be a review of the guidelines in relation to sampling and testing of organic chemicals. Should this be risk based, with a lower number of samples required or should the level of sampling be the same as the level of sampling for metals? The sampling requirements for pesticides and other trace elements needs reviewing. I think there is already some preliminary investigations underway on this issue 12 Improved Source Control Develop an appropriate risk matrix for industrial contaminants Challenges in encouraging upstream source control 13 The accumulation and beneficial reuse options of alum sludge from water and wastewater plants 14 Contamination of biosolids stockpiles Appendix 2 Prioritised Issues Item 11 1 2 3 8 13 5 12 6 10 4 9 7 14 Issue/Strategy Action Option BW CHW CWW CW EGW Review of the EPA Biosolids Management Guidelines Community Engagement for Wider Acceptance of Biosolids as a Beneficial Resource Optimising multiple land applications & contaminant loading Optimising cost of biosolids management Optimising EIP approvals The accumulation and beneficial reuse options of alum sludge from water and wastewater plants Synergies of combined biosolids and organic waste management Improved Source Control Identify funding opportunities to develop new initiatives Control of odour in raw sludge Working to maintain a competitive market place Carbon sequestration opportunities Improved measures for KPI reporting Contamination of biosolids stockpiles TOTAL VOTES Total possible votes 1 1 1 1 1 1 1 1 1 1 1 1 1 GW GVW GWMW 1 1 1 1 1 1 1 1 1 MW 1 1 1 LMW 1 1 1 1 NEW SEW SGW WW WPW 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Shortlisted/targeted actions 9 47 9 47 1 6 6 31 31 1 5 26 4 3 21 16 3 2 15 11 2 10 2 10 0 0 1 1 1 1 5 5 52 1 1 5 5 10 1 1 1 74 1 1 1 1 5 5 1 1 1 Total Votes 14 1 1 1 YVW 1 1 1 Wannon Water 1 5 5 5 5 0 5 5 5 1 0 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 5 75 85 % Appendix 3 Task Group Leader for Action Scoping Task Group Member Assigned Issue Aravind Surapaneni, South East Water Optimising cost of biosolids management (42%) – this is BAU for SE Water, continuously looking for operational savings Carly Robertson, Barwon Water Community Engagement for Wider Acceptance of Biosolids as a Beneficial Resource Doug Gardner, Wannon Water Optimising multiple land applications & contaminant loading Shauna McDonald, VicWater Review of the EPA Biosolids Management Guidelines Jason McGregor, Central Highlands Water Optimising EIP approvals Jeremy Guneratne, City West Water Synergies of combined biosolids and organic waste management Peter Tolsher, North East Water The accumulation and beneficial reuse options of alum sludge from water and wastewater plants
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