[USCC] Vol 29, #9--Regulation by various agencies

[frank]

Hi David,

>
>Frank,
>By requiring yard waste and manure composting facilities to use biosolids,
>you would be forcing the facilities to obtain permits to compost biosolids.
>I think this is an unlikely alternative considering that some states do not
>require the composting process to be permitted for agricultural or green
>wastes.  
>  
>
I try to stay away from the cost and regulations and just stick what is 
best for the science. Thinking the regulations will follow and the cost 
will find its own level.

>The temperature monitoring system currently in place is clearly not
>acceptable, but, as I see it, neither is the regulatory framework.  States
>can require temperatures to be taken from specific locations in the
>composting materials and often do specify this in the permitting process.
>Whether the actual temperatures are taken from the center of piles or not is
>clearly up to the facility at this point.  As a compost producer, and having
>taken many temperature readings at different locations in windrows, I can
>honestly tell you from experience that the centers of windrows are often the
>coolest locations.  So, the chances of achieving PFRP temperatures would be
>reduced.  And, given the cross section of a typical windrow, how would I
>locate the center?  
>  
>
I have never taken the temperature of a windrow so I appreciate this 
info. I am surprised the center is the coolest! It is not the outside? 
The center, as I think about it, is if a pile is 10 feet high one would 
go in from the top center and go down 5 feet. But others, like you would 
know the best place to take the readings.


>I suggest a more reasonable method would be to average the temperature taken
>at stratified depths in the material, from the outer most edge of the
>biosolids mix to the approximate center.  For instance, if I have a windrow
>approximately six feet high and 12 ft. wide at the base, I would take a
>reading at one, two, three and four ft. from the outermost biosolids layer
>into the center of the windrow, at a three ft. level from the ground.
>Assume the temperature stratification was as follows; 136, 141, 131, and
>128 degrees F.  The average temperature would be 134 degrees F.
>Redistribution by turning, coupled with longer composting periods, would
>reduce the likelihood of the survival of pathogens.  We need to stop
>worrying about specific temperatures.  If anything, allow lower temperatures
>for extended periods.    
>
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Not sure I agree with this. That is a LOT of readings!  And my thinking 
is that heating compost so one part is very hot and the outside cool - 
then turning it - and repeating the process is like pasteurizing milk. 
Get the vegetative forms to show themselves -then cook them.

>The problem with the theory that biosolids are free of soluble components is
>not strictly true because not all biosolids undergo anaerobic digestion
>processing.  Most treatment facilities aerate biosolids rather than treat
>them anaerobically. 
>
I realize biosolids have solubles but I think if we find a high toxic 
level of something in biosolids there is a good chance that there was a 
LOT of it released to waste and most ended up polluting our waters. Not 
our problem as composters but is our problem as ones sharing this earth.

> Aeration decreases the odorous components while
>decreasing the pathogen concentrations as well.  Some biosolids are
>anaerobically digested and treated with lime to stabilize the digest.  In
>the aerobically digested material, the water is separated from the solids,
>and the solids, typically Class B biosolids, can be directly land applied.
>The main problem with using these biosolids in composting is that they
>contain a significantly smaller fraction of organic matter, and that they
>are very wet, not that the nutrient content is inadequate.  
>  
>
If we were to use biosolids in composting (all compost) the amount in 
the compost would be very small. Not sure how much yard waste is 
produced vs biosolids but I would think it would be a lot. Mabey someone 
has these numbers? Like a zin wine needs to be greater than 51% to call 
it zin,  I suggest we would not have any compost called 'biosolids' 
compost but would be yardwaste or cow manure compost.

>Even though the chemicals I mentioned are organic, the half lives of many
>organic chemicals, even if composted, can be greater than the period of
>composting.  We recently found residuals of a herbicide in one of our
>composts that had gone through six months of composting, and I seem to
>remember a herbicide called cropyralid causing some problems in the past.
>These are also organic chemicals, as are acrylic, latex and enamel paint
>residuals, biphenyls, and a wide range of petroleum products that are not
>easily degraded during the composting process. Composting greatly decreases
>the residuals, usually to very low concentrations, but it some are more
>recalcitrant than others.
>  
>
This is the main problem I have with many of the post on this list. We 
all know biosolids are a soup of toxic microbes, that there are all 
types of things that can happen between all these biological processes 
and that chemicals are being dumpen down the drain all the times. We 
will not stop this from happening! And our job is NOT to find the best 
way to handle biosolids. Others have other solutions to the problem like 
dumping it into the ocean, ashing, making fuel, burying it or dumping it 
in the desert - we offer composting. It is our job to develope 
composting to do the best job it can to kill pathogens and destroy 
organic chemicals. That is all we can do. If its not good enough to 
reduce the risk of toxins to an acceptable level 'they' need to decide 
on another method or find and eliminate the source of the toxin. But 
that is not up to us. Lets go easy on ourselves.

>We do test for Salmonella spp., E. Coli, Clostridium spp., and other
>pathogenic forms routinely in biosolids and composts.  As I recall, there
>are TMECCs for pathogen testing.  Fecal coliform analyses test for the
>presence of the indicator species E. Coli because 95% or more of the fecal
>coliforms present in biosolids are E. Coli.  I have no argument that we need
>to reduce the pathogen levels to specified levels.  My argument is that the
>current time/temperature method may have to be modified so that there is
>less risk of materials in compost piles not achieving the prescribed
>time/temperature objectives, yet assuring that pathogen kill is still
>sufficient.  If this means composting for longer periods at lower
>temperatures, so be it.  Which would be worse; removing and recomposting
>none-compliant materials for 15 more days, or allowing a little more (30
>days) processing time to achieve the same goal? 
>  
>
If based on new studies the temperature is found to need a longer time 
to kill some pathogens than we need a longer time. I assume the 503 
people based the temperature reading needed on their studies. But this 
type of research is never ending and better methods are always in the 
future.


>Unfortunately, if we want to make changes to the biosolids composting rule
>that will be applicable to all states, the rule has to be altered on a
>Federal level, because every state can be more strict, but at least as
>strict as required in the 503 regulations.
>  
>
We (at least I) will try my best to stick with the science and let the 
regulators do as they will. But if industry wants to regulation itself 
and do a stricter job I suggest the USCC would be the ones to do that.  
That is what I would like to see.


>Dave Schellinger   
>Alternatives, L.L.C.
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-- 
Frank Shields
Soil Control Lab
42 Hangar way
Watsonville, CA  95076
(831) 724-5422 tel
(831) 724-3188 fax
frank at compostlab.com
www.compostlab.com