CLASS A & B Sludge/biosolids Requirements
           It is a little EPA joke on farmers and the public.

Since EPA and State regulators want a cheap method of sludge disposal, farmers and the public are not
informed of the potential danger to human and animal health and the lack of enforcement. The real danger
they don't tell you about is that fecal coliform are heat inhibited E. coli bacteria. Only less than 1% of E. coli
ferment lactose at 44.5deg C. The rest are viable but nonculturable by standard culture methods. Most
bacteria including E. coli 0157 are eliminated by the test because they do not ferment lactose. All other
pathogens such as viruses, parasitic worms and protozoa and fungus are ignored.

EPA admits it  did not do a human carcinogen health risk assessment for chemicals, heavy metals or pathogens in sludge biosolids.
http://www.deadlydeceit.com/503-Riskassessment.html

Carcinogenic Hexavalent chromium is produced by three methods, high-lime, low-lime, and lime-free processes. Chromium
compounds are very sensitive to pH balance and the oxidization process would appear to become extremely effective in
transforming natural occurring chromium-III from the soil into Chromium-VI when the pH is raised to 11 or 12.

Prior to
1973, USDA had made tests to determine the fate of disease organisms overtime with limed treated soil and limed treated
sludges at pH's of 8 to 11 1/2. --  after about a month, the pH dropped in the limed soil and salmonella was found. Similarly, when
limed sludge was mixed with soil, the pH dropped and salmonella was found even at the highest limed rates.

The 1985 Ohio study also noted that the World Health Organization  (WHO, 1981) reported a positive association and a cycle of
infections of Salmonella from humans to sludge, to animals, and back to humans where cattle grazed on sludge treated pastures.
(
Municipal Sewage Sludge Application on Ohio Farms: Health Effects. Dorn, R.C., et al, Environmental Research 38, 332- 335).

"Other workers found that the proportion of antibiotic resistant coliforms increased from those in fecal material (0.1 to 1% of total
coliforms being resistant) through urban wastewater (10% resistant) to river water (50%) and finally to potable water, where 80% of
any coliforms present were antibiotic resistant."

In
2002, the EPA OIG said, "the Office of Water provides the majority of the Headquarters FTEs managing the biosolids program (4),
while the Office of Enforcement and Compliance Assurance (OECA) provides none, even though it has program responsibilities. As
we explained in our prior report, that office has disinvested from the biosolids program."

http://deadlydeceit.com/503-13.html

The pollutant limits section of 503 does not mention Class A sludge/biosolids
Only the Pathogens and Vector Attraction Reduction section 503.32 mentions Class A & Class B Sludge.

Class A sludge/biosolids

§ 503.32   Pathogens.

(8) Class A—Alternative 6. (i) Either the density of fecal coliform in the sewage sludge shall be less than 1000 Most
Probable Number per gram of total solids (dry weight basis), or the density of Salmonella, sp. bacteria in the sewage
sludge shall be less than three Most Probable Number per four grams of total solids (dry weight basis) at the time the
sewage sludge is used or disposed; at the time the sewage sludge is prepared for sale or given away in a bag or other
container for application to the land; or at the time the sewage sludge or material derived from sewage sludge is
prepared to meet the requirements in §503.10(b), (c), (e), or (f).

1 ounce = 28.349523125 gram X 1000 fecal coliform = 28,349 fecal coliform per ounce of sludge biosolids.

Bacteria double every 20 minute.
Fecal coliform EPA only test for is a thermotolerant strain of E. coli that grows at
112.1 degrees. Your body is dead at 108 degrees. Salmonella only grows well at 98 degrees in test..

"The significance of fecal coliforms is that, because they normally inhabit warmer areas than most other
microorganisms, as stated earlier, they incubate at a temperature that is virtually exclusive to itself (44.5C). So, it is
possible to test for only fecal coliforms in any sample. This is important because if these specific bacteria are present
then other harmful microorganisms may also be present, such as Salmonella, Cryptosporidium and Shigella. Lactose is
necessary for growth of the fecal coliforms."
http://www.uhl.uiowa.edu/publications/archive/hotline/1997/1997_08/fecal2.
xml


Table 3 of § 503.13_Pollutant Concentrations  
(EPA Claims this is Exceptional Quality Class A or B
biosolids which require no record keeping.)
------------------------------------------------------------------------
                                       Monthly
                                       average
                                    concentration
 Pollutant                           (milligrams
                                    per kilogram) (ppm)
                                         \1\
------------------------------------------------------------------------
Arsenic..................................................               41
Cadmium..................................................            39
Copper...................................................          1500
Lead.....................................................              300
Mercury..................................................              17
Nickel...................................................               420
Selenium.................................................           100
Zinc.....................................................              2800
------------------------------------------------------------------------
\1\
Dry weight basis.
100,000 ppm LIMIT ON Chromium



Class B sludge/biosolids

Table 1 of § 503.13_Ceiling Concentrations
503 cancer causing agents
------------------------------------------------------------------------
                                       Ceiling
                                    concentration
 Pollutant                           (milligrams
                                   per kilogram) (ppm)
                                         \1\
------------------------------------------------------------------------
Arsenic..................................................            75
Cadmium..................................................          85
Copper...................................................         4300
Lead.....................................................             840
Mercury..................................................            57
Molybdenum...............................................          75
Nickel...................................................             420
Selenium.................................................          100
Zinc.....................................................             7500
------------------------------------------------------------------------
(In original  503 Chromium was limited to................. 3000ppm)
(Chromium in Commercial fertilizer derived from hazardous waste limited to 21.3ppm)
Chromium limit is now 100,000 ppm
\1\ Dry weight basis.

EPA allows two million E. coli bacterial colonies per gram of Class B sludge. That is 56 million most probable number of
E. coli per ounce of sludge biosolids when the test began. That would hardly qualify as sterile biosolids where the
pathogens have been destroyed.
http://thewatchers.us/Fecal_coliform.html

503.9(t) Pollutant is an organic substance, an inorganic substance, a combination of organic and inorganic substances,
or a pathogenic organism that, after discharge  and upon exposure, ingestion, inhalation, or
assimilation into an organism either directly from the environment or indirectly by ingestion through the food chain,
could, on the basis of information available to the Administrator of EPA, cause death, disease, behavioral
abnormalities, cancer, genetic mutations, physiological malfunctions (including malfunction in reproduction), or
physical deformations in either organisms (humans) or offspring (children) of the organisms

§ 503.33 Vector attraction reduction.
(a)(1) One of the vector attraction reduction requirements in §503.33 (b)(1) through (b)(10) shall be met when bulk
sewage sludge is applied to agricultural land, forest, a public contact site, or a reclamation site.

(b)(1) The mass of volatile solids in the sewage sludge shall be reduced by a minimum of 38 percent (see calculation
procedures in “Environmental Regulations and Technology—Control of Pathogens and Vector Attraction in Sewage
Sludge”, EPA–625/R–92/013, 1992, U.S. Environmental Protection Agency, Cincinnati, Ohio 45268).
(2)
When the 38 percent volatile solids reduction requirement in §503.33(b)(1) cannot be met for an anaerobically
digested sewage sludge, vector attraction reduction can be demonstrated by digesting a portion of the previously
digested sewage sludge anaerobically in the laboratory in a bench-scale unit for 40 additional days at a temperature
between 30 and 37 degrees Celsius. When at the end of the 40 days, the volatile solids in the sewage sludge at the
beginning of that period is reduced by less than 17 percent, vector attraction reduction is achieved.
(3)
When the 38 percent volatile solids reduction requirement in §503.33(b)(1) cannot be met for an
aerobically digested sewage sludge, vector attraction reduction can be demonstrated by digesting a portion of
the previously digested sewage sludge that has a percent solids of two percent or less aerobically in the
laboratory in a bench-scale unit for 30 additional days at 20 degrees Celsius. When at the end of the 30 days,
the volatile solids in the sewage sludge at the beginning of that period is reduced by less than 15 percent,
vector attraction reduction is achieved.
(4)
The specific oxygen uptake rate (SOUR) for sewage sludge treated in an aerobic process shall be equal to
or less than 1.5 milligrams of oxygen per hour per gram of total solids (dry weight basis) at a temperature of
20 degrees Celsius.
(5)
Sewage sludge shall be treated in an aerobic process for 14 days or longer. During that time, the
temperature of the sewage sludge shall be higher than 40 degrees Celsius and the average temperature of
the sewage sludge shall be higher than 45 degrees Celsius.
(6)
The pH of sewage sludge shall be raised to 12 or higher by alkali addition and, without the addition of
more alkali, shall remain at 12 or higher for two hours and then at 11.5 or higher for an additional 22 hours.
[this changes Chromium 3 to the carcinogenic Chromium 6 which is readily taken up by crops]
(7)
The percent solids of sewage sludge that does not contain unstabilized solids generated in a primary
wastewater treatment process shall be equal to or greater than 75 percent based on the moisture content and
total solids prior to mixing with other materials.
(8)
The percent solids of sewage sludge that contains unstabilized solids generated in a primary wastewater
treatment process shall be equal to or greater than 90 percent based on the moisture content and total solids
prior to mixing with other materials.
(9)(i)
Sewage sludge shall be injected below the surface of the land.
(ii)
No significant amount of the sewage sludge shall be present on the land surface within one hour after the
sewage sludge is injected.
(iii) When the sewage sludge that is injected below the surface of the land is Class A with respect to
pathogens, the sewage sludge shall be injected below the land surface within eight hours after being
discharged from the pathogen treatment process.
(10)(i) Sewage sludge applied to the land surface or placed on an active sewage sludge unit shall be
incorporated into the soil within six hours after application to or placement on the land, unless otherwise
specified by the permitting authority.
(ii)
When sewage sludge that is incorporated into the soil is Class A with respect to pathogens, the sewage
sludge shall be applied to or placed on the land within eight hours after being discharged from the
pathogen treatment process.
Class A or B sludge biosolids Surface disposal
Table 1 of § 503.23_Pollutant Concentrations_Active
Sewage Sludge  Unit Without a Liner and Leachate
Collection
-------------------------------------------------------------------
                                      Concentration
                                       (milligrams
   Pollutant                       per kilograms (1)
-------------------------------------------------------------------
Arsenic.................................................              73   
(75 allowed as fertilizer)          
Chromium................................................          600  
(100,000 ppm limit as fertilizer. )
Nickel..................................................               420
-------------------------------------------------------------------
(no limit of Cadmium and other pollutants)
1
Dry weight basis.
Class A or B Sludge biosolids Surface disposal
Table 2 of § 503.23_Pollutant Concentrations_Active
Sewage Sludge Unit Without a Liner and Leachate
Collection System That Has a Unit
Boundary to Property Line Distance Less Than 150 Meters
------------------------------------------------------------------------
Unit boundary to property line         Pollutant concentration 1
------------------------------------------------------------------------
                                         Arsenic   Chromium   Nickel
Distance (meters)                     (mg/kg)   (mg/kg)    (mg/kg)
------------------------------------------------------------------------
0 to less than 25........................        30        200       210
25 to less than 50.......................        34        220       240
50 to less than 75.......................        39        260       270
75 to less than 100......................       46        300       320
100 to less than 125.....................       53        360       390
125 to less than 150.....................       62        450       420
------------------------------------------------------------------------
1 Dry weight basis.