Sewage Sludge & Domestic Septage Use or Disposal Regulations and Permitting Requirements in Louisiana – Present & Future Trends
The state of Louisiana does not have a defined and separate Sewage Sludge or Biosolids Program. The regulating and permitting of sewage sludge use or disposal in Louisiana is handled under the Solid Waste regulations. Present regulations for beneficial use or land application were promulgated in 1993 and basically follow the 40 CFR 257 concept with added soil and site restrictions specific to Louisiana. The state of Louisiana should not be less stringent than EPA; therefore, the state also makes use of the 40 CFR 503 regulations. Disposal of sewage sludge in a Municipal Solid Waste Landfill (MSWL) is regulated under the Solid Waste Permit issued to the MSWL. Processing/treatment of the sewage sludge is regulated under a Solid Waste Permit for the processing of solid waste. Disposal/treatment in a pond system is also regulated under a Solid Waste Permit as a solid waste impoundment. The same holds for a landfarm or a monofill. Land application of sewage sludge is regulated under a Solid Waste permit for beneficial use of a solid waste. The only sewage sludge incinerator in the state is regulated under both the solid waste regulations as a solid waste processor and under the air quality regulations as a municipal solid waste incinerator. Because a permit is required under the solid waste regulations, the owners of a sanitary wastewater treatment facility must obtain both a water discharge permit under the water quality regulations and a separate permit for the use or disposal of their sewage sludge under the solid waste regulations. In the case of the sole incinerator, the owner/operator of the POTW must obtain a solid waste permit, an air quality permit, and a water discharge permit.
Presently, there exist only one full time employee involved in the permitting of sewage sludge in Louisiana. Assistance is afforded for facility inspections from the Department's Regional Field Surveillance staff on a limited basis. Assistance is also received on a limited basis from the LSU AgCenter on some issues related to the land application of treated sewage sludge.
Additionally, the Department does not have assumption of the Sewage Sludge Management Program from EPA. Therefore, Class I Sludge Management facilities in the state must also obtain coverage under the EPA Region VI General Permit for the Use or Disposal of Sewage Sludge in Louisiana. There does not exist one standardized permit application that would cover all of the sewage sludge use or disposal practices in the state; and the data base that would be needed for adequate tracking of the sewage sludge quality and uses (including management practices and treatment) is very limited in nature.
There are presently twelve (12) land application of sewage sludge projects for beneficial use in Louisiana. In addition, there exist or are being proposed, seven (7) treatment facilities whose final product will be an Exceptional Quality material.
A new set of regulations was promulgated in April of 2002 and placed as a part of the Water Quality regulations. However, the regulations were promulgated in such a fashion so as to only become effective when the state assumes the Sewage Sludge Management Program from EPA. Assumption of the program from EPA is an option that has been considered and may continue to be considered in the future. Assumption of the Program is a goal that was once set by the Department and may be a continued part of a near future goal of the Department.
Additionally, an increase in the number of staff members devoted to the regulating and permitting of sewage sludge use or disposal is a future option. Generation of a data base and more on-site inspections is also a future consideration. A closer working relationship with the Pretreatment Program Unit in order to assure that proper pretreatment is being performed especially at POTW's who are treating their sludge to Exceptional Quality (EQ) level is a present and future goal of the Department.
Regarding EQ Biosolids, it is hoped, and is presently being worked upon, that there will be a move by more facilities from use of a Class B product to that of treatment of their sludge to meet EQ levels. Another task for the very near future will be to revisit the regulations and make revisions that will make them more protective of human health and the environment. Another goal is to devise a standard permit application that would cover all sewage sludge use or disposal practices in Louisiana. The Department plans to work more with universities, facilities, and the LSU AgCenter regarding Biosolids research, training for sewage sludge generators and land appliers, and public education programs. Additionally, the creation of a sewage sludge/Biosolids page in the Department Internet site is being considered.
Document Type: Research Article
Publication date: 2004-01-01
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