Lagoon Requirements/Best Management Practices for Use/Disposal of Sewage Sludge: U.S. Environmental Protection Agency Issues Guidance Document

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The United States Environmental Protection Agency (“EPA”) issued a February 2024 guidance document (“Guidance”) titled:

Understanding Lagoon Requirements Under 40 C.F.R. Part 503: Best Management Practice for Use or Disposal of Sewage Sludge

See 822R24002.

The Guidance specifically addresses land application of sewage sludge removed from lagoons.

Section 405(d) of the Clean Water Act requires the EPA to:

  • Establish numeric limits and management practices that protect public health and the environment from the reasonably anticipated adverse effects of chemical and microbial pollutants during the use or disposal of sewage sludge
  • Review sewage sludge (biosolids) regulations every two years to identify any additional pollutants that may occur in biosolids, and then set regulations for those pollutants as sufficient scientific evidence shows they may harm human health or the environment.

Such regulations are found at 40 C.F.R. Part 503.

This set of regulations regulate sewage sludge that is applied to land, fired in a sewage sludge incinerator, or placed on a surface disposal site. They include:

  • Pollutant limits
  • Requirements for pathogen and vector attraction reduction
  • Management practices
  • Monitoring
  • Record keeping
  • Reporting

40 C.F.R. Part 503 applies to any person or treatment works that prepares sewage sludge, applies sewage sludge to the land, fires sewage sludge in an incinerator, and the owners and operators of surface disposal sites.

EPA states in the introductory portion of the Guidance that:

… While Part 503 contains requirements when land applying sewage sludge, questions may arise in some cases as how to best meet those requirements for sewage sludge removed from lagoons. The purpose of this document… is to explain the management of sewage sludge removal from wastewater treatment lagoons for land application. This document provides a summary of Part 503 requirements and provides best management practices (BMPs) for the land application of sewage sludge from lagoons.

Besides the introduction, the components of the Guidance include:

  • Planning
  • Assessment and analysis
  • Land application

A copy of the Guidance can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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