[USCC] Compost made with biosolids vs biosolids

[Chaney, Rufus]

Dear Bob et al.:

503 is clear that once biosolids, always biosolids. Composting is a treatment process. Yes, a wonderful process that reduces many of the management problems with biosolids, and removes the infectious risk of Class B materials.

The other key is the "Exceptional Quality" which is the combination of Class A and containing lower than the "alternative pollutant limit, APL" levels of metals. If a biosolids meets the APL, and the biosolids mixture with other composting feedstocks achieves Class A treatment, then it can be marketed as a product rather than being applied under a permit. A permit is needed for the process and label on the product which must still say it was derived partially from biosolids.

So, no matter how much the material is changed/improved by composting, it technically remains a biosolids product which requires labeling and compliance with 503. Easy compliance at that point, but still compliance.

Knowing what we know about composting, it is not unreasonable to feel that a material that has been composted properly is so changed that it should not be considered in the same thought as the smelly, germy feedstocks. The biochemical transformations are many and valuable. And the slow release fertilizer part of the compost is quite valuable. And the ability to remediate infertile soils. But the law is clear, once a biosolids, always a biosolids (biosolids is a plural noun)

Regards,

Rufus Chaney
Beltsville, MD

-----Original Message-----
From: compost-bounces at mailman.cloudnet.com [mailto:compost-bounces at mailman.cloudnet.com] On Behalf Of Bob Engel
Sent: Thursday, May 15, 2008 12:29 PM
To: compost at mailman.cloudnet.com
Subject: [USCC] Compost made with biosolids vs biosolids

I have a question that I have not been able to find in the EPA 503  regulations.
At least not stated real clearly!
Once biosolids are composted at a approved facility and have undergone treatment are the land application guidlines for biosolids still applied?
It is my feeling that once composted they are not biosolids anymore but a complete new product bearing no resemblance to the feedstock used to make the compost.
Look forward to any answer and if you can refer to the regulation it would be great.
Bob Engel
Bob at gotcompost.com    


      
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