[USCC] Compost made with biosolids vs biosolids

Wed May 21 00:10:02 CDT 2008

Rufus, Bill, and Maureen:

I think we need to hear from one of the regulators, i.e. Brobst or Bastien,
or even Al Rubin on this.  My reading on the 503.10(c)(1) and 503.10(f)
sections I quoted seem to be quite different from your opinions.  I think
that if you have done the appropriate reductions in pathogens and vector
attraction, and have done the testing for metals [503.13(b)(3) list] and
pathogens, the label requirement and land application restrictions go away.
Some States may have different requirements, however.

Maureen.........We are talking here ONLY about material that has been
treated and tested to meet all of the Class A requirements for pathogens and
vector attraction, and meets the metals requirements.  The land application
of Class B, or material that does not meet the strict metals requirements in
503(b)(3), both of which some facilities do produce, is more regulated under
503.  It is true that some composters are better than others, but most are
VERY picky to make sure they are delivering quality product.  I know my
clients are.  It is either the best or it does not go out the gate.

Pat Crowley
Crowley Consultants LLC
1935 Lucky Strike Road
Helena, MT 59602
(406) 458-1935 phone and fax
(406) 439-9231 cell
pat at crowleyconsultants.com

-----Original Message-----
From: compost-bounces at mailman.cloudnet.com
[mailto:compost-bounces at mailman.cloudnet.com] On Behalf Of Chaney, Rufus
Sent: Friday, May 16, 2008 5:44 AM
To: Compost Discussion List
Subject: Re: [USCC] Compost made with biosolids vs biosolids

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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_______________________________________
Join us at the US Composting Council's 17th Annual Conference & Trade Show
January 26-29th, 2009 at the Westin Galleria in Houston, TX.
The National forum for those involved in the development and expansion of
the composting and organics recycling industry.
Conference Highlights, Registration forms, Exhibitor information and
Sponsorship Opportunities available at the USCC website:
www.compostingcouncil.org or call the USCC at 631.737.4931 
____________________________________________________________________________
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Compost maillist - compost at mailman.cloudnet.com
http://mailman.cloudnet.com/mailman/listinfo/compost
_______________________________________
This list is a service provided by the US Composting Council (USCC).
(c) Copyright 2004 United States Composting Council - All rights reserved

Opinions expressed do not necessarily represent the USCC, the Foundation, or
the Board of Directors.

Non-members of USCC are encouraged to join the Council through its website
at: http://www.compostingcouncil.org/membership.cfm

Members posting CC copies to the list and other addresses may have their
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