Residential Sewage
Domestic Sewage exclusion for
hazardous waste. "Domestic
sewage is waste and waste water
from humans or household
operations that is discharged to or
otherwise enters a treatment
works." (40 CFR 503.9(g)).
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In a letter dated Feb. 7, 1986, from, The
(EPA) Administrator, to the Honorable
Thomas P. O'Neil, Jr., Speaker. U.S.
House of Representatives, stated: "The
purpose of the Domestic Sewage Study
was to evaluate the impacts of waste
discharged to public owned treatment
works (POTW's) as a result of the
Domestic Sewage Exclusion.
The Domestic Sewage Exclusion,
(specified in Section 1004(27) of RCRA)
provides that a hazardous waste, when
mixed with domestic sewage is no
longer considered hazardous.
Therefore, POTW's receiving hazardous
waste in this manner are not subject to
the RCRA treatment, storage and
disposal facility requirements. The
premise behind the Domestic Sewage
Exclusion is that RCRA management of
wastes within a POTW is unnecessary
and redundant since this wastes are
regulated under the Clean Water Act's
regulatory programs."
Rubin claims, "This is a key
definition, because the standards in
the part 503 regulation apply to
sewage sludge generated during the
treatment of domestic sewage in a
treatment works.
When domestic sewage is in the
influent to a treatment works, even
if the influent also contains
industrial wastewater, sewage
sludge is generated during the
treatment of the domestic sewage."
(FR. 58, p. 9326 - 40 CFR 257 et al.
(503))
503.9(t) Pollutant is an organic
substance, an inorganic substance, a
combination of organic and
inorganicsubstances, 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 or offspring of the
organisms.
RCRA (27) The term ``solid waste'' means any
garbage, refuse, sludge from a waste treatment
plant, water supply treatment plant, or air pollution
control facility
(5) The term ``hazardous waste'' means a solid
waste, or combination of solid wastes, which because
of its quantity, concentration, or physical, chemical,
or infectious characteristics may--
(A) cause, or significantly contribute to an increase
in mortality or an increase in serious irreversible, or
incapacitating
reversible, illness; or
(B) pose a substantial present or potential hazard to
human health or the environment when improperly
treated,
stored, transported, or disposed of, or otherwise
managed.
CWA (6) The term ``pollutant'' means dredged spoil,
solid waste, incinerator residue, sewage, garbage,
sewage sludge, munitions, chemical wastes, biological
materials, radioactive materials, heat, wrecked or
discarded equipment, rock, sand, cellar dirt and
industrial, municipal, and agricultural waste
discharged into water.
13) The term ``toxic pollutant'' means those
pollutants, or combinations of pollutants, including
disease-causing agents, which after discharge and
upon exposure, ingestion, inhalation or assimilation
into any organism, either directly from the
environment or indirectly by ingestion through food
chains, will, on the basis of information
available to the Administrator, cause death, disease,
behavioral abnormalities, cancer, genetic mutations,
physiological malfunctions (including malfunctions in
reproduction) or physical deformations, in such
organisms or their offspring
Sewage sludge
Sewage effluent
Non-hazardous
Permitted sludge
land placement.
62 chemicals for
detection.
220 hazardous
chemicals of
concern
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503 Permitted
surface
disposal site
Arsenic
Chromium
Nickel
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PPM
75
85
N?A
4300
840
57
75
420
100
7500
PPM
73
600
420
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
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Class A Sludge - biosolids
Testing - 1000 MPN thermotolerant E. coli per gram.
Approximately 1 million of these bacteria per kilogram
(fecal coliform)
EPA substituted non-disease causing bacteria in the
Public Health Department Standard for Coliform
No consideration for disease causing organisms
No consideration for viable, but nonculturable bacteria
No consideration for deadly fungus
EPA claims it is:
Excluded from RCRA due to Domestic sewage
exclusion.
Excluded from point source pollution controls due to
agricultural stormwater runoff exclusion in CWA.
Excluded from Superfund law due to normal
application of fertilizer exclusion.
Safe for direct human contact in potting soil, soil
amendment and compost.
Safe for use on garden food crops, lawns, parks, school
yards etc.
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Class B Sludge - biosolids
Testing - 2 million thermotolerant E. coli per gram
Approximately 2 billion of these bacteria per
kilogram (fecal coliform)
EPA substituted non-disease causing bacteria in the
Public Health Department Standard for Coliform
No consideration for disease causing organisms
No consideration for viable, but nonculturable
bacteria No consideration for deadly fungus
EPA claims it is: Excluded from RCRA due to
Domestic sewage exclusion. Excluded from point
source pollution controls due to agricultural
stormwater runoff exclusion in CWA. Excluded
from Superfund law due to normal application of
fertilizer exclusion. Safe for disposal on food crops,
feed crops and fiber crops with 30 day harvest
restriction. Safe for disposal on grazing land and
forest land
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arsenic; beryllium; cadmium;
chromium; lead; mercury
All are toxic to kidneys. Decreased
mental ability, weakness, headache,
abdominal cramps, diarrhea, and
anemia. Also affects blood-forming
mechanisms and the peripheral nervous
system.
Long-term exposure to lead can cause
permanent kidney and brain damage.
Cadmium can cause kidney and lung
disease.
Chromium, beryllium, arsenic, and
cadmium have been implicated as
human carcinogens.
http://www.epa.gov/oerrpage/superfund/p
rograms/er/hazsubs/sources.htm
Solid waste means any garbage or refuse; sludge from a wastewater
treatment plant, water supply treatment plant, or air pollution control
facility; and other discarded material, including solid, liquid, semisolid, or
contained gaseous material resulting from industrial, commercial,
mining, and agricultural operations, and from community activities. Solid
wastes include both hazardous and nonhazardous waste.
http://www.epa.gov/agriculture/lrca.html#Solid%20Wastes
Disposal of hazardous waste on an agricultural establishment could
subject the agricultural producer to significant responsibility, including
closure and post-closure care. Off-site disposal of hazardous waste could
subject agricultural producers to hazardous waste generator
requirements.
http://www.epa.gov/agriculture/twas.html#biological
S. 3681. Status of Manure as a Hazardous Substance
Jul. 19, 2006
A bill to amend the Comprehensive Environmental Response
Compensation and Liability Act of 1980 to provide that manure shall not
be considered to be a hazardous substance, pollutant, or contaminant; to
the Committee on Environment and Public Works (Congressional
Record: July 18, 2006 [Senate], Page S7752).
It is somewhat amazing that EPA would publish totally misleading information on its website. Lying to the public and
politicians is not unusual, but putting it in writing is unusual. Click on highlighted areas for facts.
503.9(t)(aa) Treatment works is either a federally owned, publicly owned, or privately owned device or system
used to treat (including recycle and reclaim) either domestic sewage or a combination of domestic sewage
and industrial waste of a liquid nature.
Fertilizers Made From Domestic Septage and Sewage Sludge (Biosolids)
Biosolids are the treated residuals from wastewater treatment that can be used beneficially. Wastewater residuals
(formerly sewage sludge) would not be known as biosolids unless they have been treated so that they can be beneficially
used.
Years of research and practice have repeatedly demonstrated that biosolids recycling is safe and the food crops grown on
land fertilized with biosolids are safe to eat. The long-term practice of recycling biosolids has been subjected to more than
30 years of intensive careful study. As a result of research and practice showing the safety of biosolids recycling, the U.S.
Department of Agriculture, the Food and Drug Administration, and EPA issued a joint policy statement in 1981 that
endorsed the use of biosolids on land for producing fruits and vegetables. Then, in 1984, EPA issued a policy statement in
the Federal Register that encouraged and endorsed the recycling of biosolids. And again in 1991, EPA was a co-endorser
of an Interagency Policy placed in the Federal Register regarding the benefits of using biosolids.
The Federal rule that governs the use of biosolids today is based on comprehensive science-based risk assessments and
many rounds of extensive review. Additional confirmation of the validity of the Federal biosolids rule and the Federal
policy that promotes the beneficial recycling of biosolids is the careful 3-year review by the prestigious National Research
Council (NRC) of the National Academy of Sciences which took place after the promulgation of the rule. The NRC
concluded in their 1996 report that the use of biosolids in accordance with existing Federal guidelines and regulations
presents negligible risk to the consumer, to crop production, and to the environment.
EPA offers guidance and technical assistance for the beneficial recycling of biosolids as soil amendments and fertilizer.
The use of these valuable materials can enhance water quality, pollution prevention, and sustainable agriculture.
Sewage sludge that is used in agriculture is regulated under the Clean Water Act, and is currently subject to
concentration limits for the metals arsenic, cadmium, copper, lead, mercury, molybdenum, nickel, selenium, and zinc.
http://www.epa.gov/agriculture/tfer.html#Fertilizers%20Made%20from%20Domestic%20Septage%20and%20Sewage%2
0Sludge%20(Biosolids)
Hazardous waste can not
be dumped directly into a
sewage treatment plant,
However, EPA policy allows
hazardous waste to be mixed with
Domestic waste in the pipeline
SEWAGE EFFLUENT AND SEWAGE SLUDGE - BIOSOLIDS
Hazardous Waste Flow chart
Updated 2/28/2012