Evaluation of Comments on the Proposed Standards for Management of Sewage Sludge Non-Agricultural Land Application

摘要

The report is part of the National Network for Environmental Management Studies under the auspices of the Office of Cooperative Environmental Management of the U.S. Environmental Protection Agency. On February 6, 1989 EPA proposed 40 CFR Parts 257 and 503 Standards for the disposal of Sewage Sludge. Comments on the Proposal Rule were received from 524 different entities. The paper presents those specific to non-agricultural land application. There were four major types of commenters on the Proposed Rule: (1) the sludge generators, (2) the regulators, (3) scientists, and (4) environmental groups. The greatest number of commenters (and thus comments) came from sludge generators. Regulators provided the next most numerous comments. The majority of the comments received from these two groups were that the Proposed Rule was overly restrictive. The scientific community (primarily the W-170 Peer Review) suggested that the regulations as developed were overly restrictive, not scientifically justified and needed major changes. The majority of the comments from the environmental groups were that the Proposed rule should be more restrictive in some areas. However, even they strongly support beneficial use practices over disposal. Many of the comments were about the use of the 98th-percentile concentrations derived from the '40 City Survey.' The other major issue was the restriction on nitrogen loading, which simply is contrary to the philosophies behind practices. There was also considerable support for an exposure risk assessment based approach. This, it was felt, would make the non-agricultural practices more technically based and comparable in concept to agricultural sludge use.