ILlililllljlljlllllfljllllljflIlllllllllfll , LIBRAR Y Michigan State ‘ University This is to certify that the thesis entitled AN ANALYSIS OF THE UTILIZATION OF MUNICIPAL SEWAGE SLUDGE ON MICHIGAN PRIVATE FARMLANDS presented by Gerald D. Toland, Jr. has been accepted towards fulfillment of the requirements for Masger's deg-gem Agricultural Economics l/%W/fi .[ifvvn I? ajor professor Date Feb. 18; 1980 0-7 639 4 4 fill-M» .‘ i “I." - .~ «vii? v1,“ -.. OVERDUE FINES: 25¢ per day per item RETURNING LIBRARY MATERIALS : Place in book return to remove charge from circulation records AN ANALYSIS OF THE UTILIZATION OF MUNICIPAL SEWAGE SLUDGE ON MICHIGAN PRIVATE FARMLANDS By Gerald D. Toland, Jr. A THESIS Submitted to Michigan State University in partial fulfillment of the requirements for the degree of MASTER OF SCIENCE Department of Agricultural Economics ABSTRACT AN ANALYSIS OF THE UTILIZATION OF MUNICIPAL SEWAGE SLUDGE ON MICHIGAN PRIVATE FARMLANDS By Gerald D. Toland, Jr. Federal water pollution control laws have required municipalities to upgrade sewage treatment facilities. As a result, increasing quantities of sludge are being pro- duced and communities must implement sludge management plans. The utilization of stabilized sewage sludge on private farmlands is analyzed as one alternative. Economic, institutional and technical aspects of sludge utilization are examined using a multidisciplinary approach. An analysis is presented on surveys conducted with farmers and sewage treatment plant operators who participated in utilization agreements. Representative case studies using synthetic data are used to estimate utilization costs under different contractual arrangements. The results of this research indicated that utilization is a desirable alternative for rural municipalities with neighboring farmlands. The nutrient content of sludges was found to provide incentives for farmers to enter utili- zation agreements. The primary implication of this study is that the success of utilization programs is highly de- pendent on the implementation of certain technical and institutional arrangements. ACKNOWLEDGEMENTS I would like to thank Dr. Larry Connor for the counsel he gave as major professor and thesis advisor. His per— sonal encouragement and professional guidance were ab- solutely necessary to my completion of this research. I am also grateful to Drs. Larry Libby, Garland Wood, Lee Jacobs and Ted Loudon for their thoughtful reading and helpful comments for improving this thesis. I am also indebted to Richard Sprague, who readily provided me with important information whenever it was needed. I would like to express special thanks to my fellow graduate students, who were a constant source of moral support throughout this endeavor. Finally, I thank my mother, father and sisters, whose loving concern means everything. It is to my family that this thesis is dedicated. ii TABLE OF CONTENTS LIST OF TABLES LIST OF FIGURES. . Chapter I. II. INTRODUCTION . Origins of the Wastewater Sludge Problem . Enactment of Public Law 92—500-—The Water Pollution Control Act Amendments of 1972 . . . Farmland Utilization of Municipal Sewage Sludge . . . . . . . Sources of Controversy over Farmland Application. Farmland Utilization as an Increasingly Desirable Sludge- Handling Technique. Purpose of this Study. . . . . Thesis Plan. . . . Endnotes . . . . . A FRAMEWORK FOR EXAMINING SLUDGE FARMLAND APPLICATION PROGRAMS An Outline of the Important Aspects of Sludge Utilization . Goals of Sludge Application Programs Institutional Arrangements and Economic Aspects. Contractual Arrangements for Sludge Utilization. . Conceptual Economic Issues of Sludge Utilization. Interested Parties Technical Characteristics of Sludges Categorizing the Significant Factors in Farmland Sludge Application. Endnotes . . . . . . . . iii Page vii xiii [\3 (DOWN Lb #3 N H»4 l4 14 15 15 17 24 26 29 33 Chapter III. IV. LEGAL, INSTITUTIONAL AND ECONOMIC ASPECTS OF SLUDGE UTILIZATION . . . . . . . . . . Dealing with the New Problem: Sludge Management. . . The Legal Characteristics of Sludge Management. Legislative and Regulatory Responses. to the Sludge Problem. . . Federal Legislation Pertaining to Sludge Use . . . . Public Law 92- SOO--The Federal Water Pollution Control Act Admendments of 1972.. . . Public Law 95- 217-—The Clean Water. Act of 1977 . . Public Law 94- 580--The Resource Conser- vation and Recovery Act of 1976 . . Public Law 94- 469--The Toxic Substances and Control Act of 1976 . . . Public Law 93- 523--The Safe Drinking Water Act of 1974 . . . . Public Law 95-192--The Soil and Water Resources Conservation Act of 1977. Public Law 95-153--The Marine Protection, Research and Sanctuaries Act of 1972. Summary of the Federal Regulations on Sludge Management . . Sludge Disposal Policy in Michigan State Public Acts and Administrative Agencies Which Are Concerned with Sludge Manage- ment. . . . Regulation of Sludge Utilization at the County and Municipal Level of Govern- ment in Michigan. Regulations at the Municipal Level- Local Ordinances and Sludge Utilization Agreements. The Contractual Agreement as an Institutional Arrangement . Sludge Utilization and its Controversial Issues: The Need for an Acceptable Sludge Disposal Solution . Economic Aspects of Sludge Utilization. Some Characteristics of a We11-Managed Sludge Utilization Program for Private Farmlands Endnotes. . . TECHNICAL ASPECTS OF SLUDGE UTILIZATION Introduction to the Agronomic Value of Sludge Use. iv Page 34 34 34 34 36 36 39 42 46 47 48 48 49 50 54 55 56 61 63 72 78 80 8O Chapter IV. VI. Continued Anaerobic Digestion and Other Sludge Stabilization Processes. Sludge Thickening, Dewatering and Drying Processes . . . Storage, Transport and Application of Sludges. . . . . . . Farmland Application of Sludges. . . Agronomic Values, Application Rates and Constraints. . . . Suitability of Sludge Use for Selected Crops. . . . . Measuring and Monitoring Sludges and Sludge Amended Soils . . Summarizing the Technical Aspects of Sludge Utilization . . Endnotes . . . . . . . . . SUMMARY AND INTERPRETATION OF SLUDGE UTILIZATION SURVEY RESULTS . Farmland Application of Sludges in Rural Michigan . . . . . . Characteristics of Sludge Utilization Programs . . . . . Population Size, Program CoSts and the Related Costs of Land Application. Further Influences on Equipment Choice and Program Arrangements Contracting Arrangements for Sludge Utilization in Michigan . Third Party Participants in Sludge Utilization Programs . Parties Consulted for Advice on Utilization. . . Parties with Regulatory Powers over Sludge Programs . Parties in Opposition to Sludge Utilization Programs . . Sludge Utilization, Crop Yields and. Fertilizer Reductions. Future Prospects for Sludge Utilization. ESTIMATING THE COSTS OF SLUDGE UTILIZATION ON FARMLANDS . . . . . . . . . . . Introduction to the Representative Case Studies. General Overview of the Case by Case Approach . Page 86 87 88 91 91 95 98 100 102 104 104 106 106 114 120 126 128 130 133 137 144 147 147 150 Chapter Page VI. Continued Applying the Budgeting Approach . . . . . . . 152 Case Studies of Farmland Utilization Costs . . . . . . . . . . . . . . 152 Sources of Cost Data. . . . . . . . . . . . . 154 Case Analyses . . . . . . . . . . . . 155 Background Information on Case 155 1. Background Information on Case 2.. . . . . 160 Background Information on Case 3.. . . . . 168 Background Information on Case 4.. 174 Evaluating the Usefulness of the Cost Estimates . . . . . . . . . . . . . . . . . 178 Endnotes. . . . . . . . . . . . . . . . . . . 184 VII. SUMMARY AND CONCLUSIONS . . . . . . . . . . . . 188 A Reexamination of Farmland Utilization as an Alternative for Sewage Sludge Management. . . . . . . . . . . . . . . . . 188 Research Objectives . . . . . . . . . . . . . . 189 Methodology . . . . . . . . . . . . . . 189 Results and Implications. . . . . . . . . . . . 191 Areas of Future Research. . . . . . . . . . . . 195 APPENDICES. . . . . . . . . . . . . . . . . . . 196 BIBLIOGRAPHY. . . . . . . . . . . . . . . . . . 217 vi Table 2-1 5-3 5-4 LIST OF TABLES Categorizing the Controlled and Uncon- trolled Variables of a Sludge Utilization Program from the Perspectives of the Participating Farmer and Municipal Sewage Treatment Plant Operator List of Federal Laws which Contain Pro— visions on Sludge Management Solids Content of Sludges. Range and Median of N, P and K Contents of Digested Sewage Sludge . . . Trace Element Concentrations in Digested Sewage Sludge Typical Quantities of Sludge Produced in Wastewater Treatment Processes Sludge Masses. Trends in Production of Municipal Waste— water Sludge Comparison of Treatment Plant's Sludge Production with the Percent of Sludge Output Applied to Private Farmland Comparison of the Treatment Plant's Sludge Production with Population Size Comparison of Treatment Plant Sludge Production with the Design of the Wastewater Flow of the Plant Comparison of Population Size with Distance that Sludge is Transported. Comparison of Population Size with Costs and Arrangements for Sludge Handling Equipment Vii Page - 30 - 37 - 81 . 82 . 82 . 83 . 84 . 84 .107 .109 .110 .110 .113 Table Page 5-6 Comparison of Treatment Plant Sludge Production with Methods of Stabilization . . . 116 5-7 Comparison of the Moisture Content of Sludge with the Farmer’s Use of His Own Equipment to Spread Sludge . . . . . . . . 117 5-8 Comparison of DifferenceS“ in Sludge Application and Transport Equipment with the Farmer's Use of His Own Equipment to Spread Sludge . . . . . . . . . . 117 5-9 Comparison of Differences in Sludge Applicastion and Transport Equipment with Municipal Ownership of the Transport Equipment. . . . . . . . . . . . . . 118 5-10 Comparison of Municipal Ownership of the Transport Equipment with the Farmer‘s Use of His Own Equipment to Spread Sludge. . . 118 5-11 The Frequency of Conducting Testing and Monitoring by Muncipalities. . . . . . . . . . 122 5-12 Comparison of the Frequency of Ground- water and Surface Water Testing with the Frequency of Sludge Sample Analysis by Municipalities . . . . . . . . 123 5-13 The Frequency of Following Management Practices and Testing Procedures by Farmers. . . . . . . . . . . . . . . . . . . . 123 5-14 Comparison of the Number of Years Participation in the Sludge Program with the Frequency of Testing Procedures by Farmers . . . . . . . . . . . . . . . . . . 124a 5-15 Comparison of the Number of Years Parti- cipation in the Sludge Program with the Future Plans to Utilize Sludge by Farmers. . . . . . . . . . . . . . . 124a 5—16 Comparison of the Frequency of County Extension Involvement with the Frequency of County Health Department Participation in a Sludge Utilization Program. . . . . . . . 129 viii Table Page 5-17 Comparison of the Frequency of County Health Department Participation with the Frequency of Following Testing Procedures by Municipalities . . . . . . . . .129 5—18 Comparison of the Frequency of County Extension Involvement with the Frequency of Following Testing Procedures by Municipalities . . . . . . . . . . . . . . . . 130 5-19 Comparison of the Frequency of Local Opposition to Utilization Programs with the Frequency of the Need for Clearances to Approve Landspreading . . . . . . . . . . . 131 5-20 Comparison of the Frequency of County Health Department Participation with Frequency of Local Opposition to the Utilization Program. . . . . . . . . . . . . . 132 5-21 Comparison of the Frequency of County Extension Involvement with the Frequency of Local Opposition to the Utilization Program. . . . . . . . . . . . . . . . . . . .134 5—22 Comparison of the Frequency of Following Testing Procedures with the Frequency of Local Opposition to the Utilization Program. . . . . . . . . . . . . . . . . . . . 135 5-23 Comparison of the Frequency of Local Opposition to the Utilization Program with the Plane of Farmers for Land- spreading Sludges in the Future. . . . . . . . 136 5-24 Comparison of the Frequency of Local Opposition to the Utilization Program with the Years of Participation in Landspreading by Farmers . . . . . . . . . . . 136 5-25 Comparison of Reported Crop Yield Effects of Sludge Use with the Years of Partici- pation in Landspreading by Farmer. . . . . . . 138 5-26 Comparison of the Frequency of Fertilizer Use Reductions with the Years of Partici- pation in Landspreading by the Farmer. . . . . 141 ix Table 5-27 5-28 5—29 5-30 6-1b Page Comparison of the Frequency of Ferti— lizer Use Reductions with the Frequency of Observed Changes in Crop Yields . . . . . . 141 Comparison of the Frequency of Fertilizer Use Reductions with the Frequency of Using a Sludge Analysis on which to Base the Fertilizer Requirement . . . . . . . . . . 142 Comparison of the Frequency of Ferti- lizer Use Reductions with the Frequency of Farmer Knowing the Sludge Application Rate . . . . . . . . . . . . . . . . . . . . . 143 Compariosn of Frequency of Increased Crop Yields with Future Plans of Farmers to Participate in Utilization Programs . . . . 146 Enterprise Budget of Utilization Costs to the Municipality. The One Way Transport Distance from Treatment Plant to Farm Site is 5 Miles. Liquid Sludges with a 5% Solids Content Are Hauled. . . . . . 157 Partial Budget of Utilization Costs to the Municipality. The One Way Transport Distance Is Increased to 15 Miles. Liquid Sludges with a 5% Solids Content Are Hauled . . . . . . . . . . . . . . . . . . . . 158 Enterprise Budget of Utilization Costs to the Farmer for the Incorporation Activity. Liquid Sludges (5% Solids) Are Applied . . . . 158 Enterprise Budget of Utilization Costs to the Farmer for Incorporation and Transport. One-Way Trip is 5 Miles. Liquid Sludges (5% Solids) Are Applied. . . . . . . . 158 Partial Budget of Utilization Costs to the Farmer for Incorporation and Trans- port. One-Way Trip Is Increased to 15 Miles. Liquid Sludges (5% Solids) Are Applied. . . . . . . . . . . . . . . 159 Enterprise Budget of Utilization Costs to the Municipality. The One-Way Trans— port Distance from Treatment Plant to Farm Site is 5 Miles. Filter Cake Table Page 6-5a Sludges with a 40% Solids Content Are Obtained from Open Air Drying Beds and Hauled . . . . . . . . . . 162 6-5b Partial Budget of Utilization Costs to the Municipality. The One-Way Trans— port Distance Is Increased to 15 Miles. Filter Cake Sludges with a 40% Solids Content Are Obtained from Open Air Drying Beds and Hauled . . . . . . . . . . . .163 6-5c Enterprise Budget of Utilization Costs to the Municipality. The One-Way Trans— port Distance from Treatment Plant to Farm Site Is 5 Miles. Filter Cake Sludges with a 40% Solids Content Are Obtained from a Vacuum Filter and Hauled . . . 164 6-5d Partial Budget of Utilization Costs to Municipality. The One-Way Transport Distance from Treatment Plant to Farm Site Is Increased to 15 Miles. Sludges with a 40% Solids Content Are Obtained from a Vacuum Filter and Hauled. . . . . . . . 165 6-6 Enterprise Budget of Utilization Costs to the Farmer for Application and Incorporation. Fitler Cake Sludges with a 40% Solids Content Are Utilized . . . . 167 6-7a Enterprise Budget of Utilization Costs to the Municipality. The Treatment Plant Pays the Farmer at $2 per Thousand Gallon Fee for Hauling Liquid Sludge (5% Solids). . . . . . . . . . 169 6-7b Enterprise Budget of Utlization Costs to the Farmer. The Treatment Plant Pays the Farmer a $2 per Thousand Gallon Fee for Hauling Liquid Sludge (5% Solids). One Way Transport Distance is 5 Miles. . . . . 170 6-7c Partial Budget of Utilization Costs to the Farmer. The Treatment Plant Pays the Farmer a $2 per Thousand Gallon Fee for Hauling Liquid Sludge (5% Solids). One—Way Transport Distance Is Increased to 15 Miles . . . . . . . . . . . . . . . . . . . 171 6-8a Enterprise Budget of Utilization Costs xi Table Page 6—8a to the Municipality. The Treatment Plant Pays the Farmer a $13 per Thousand Gallon Fee for Hauling Liquid Sludge (5% Solids). . . . . . . . . . . . 171 6—8b Enterprise Budget of Utilization Costs to the Farmer. The Treatment Plant Pays the Farmer a $13 per Thousand Gallon Fee for Hauling Liquid Sludge (5% Solids). One—Way Transport Distance is 5 Miles . . . . . . . . . . . . . . . . . . 172 6-8c Partial Budget of Utilization Costs to the Farmer. The Treatment Plant Pays the Farmer a $13 per Thousand Gallon Fee for Hauling Liquid Sludge (5% Solids). One-Way Transport Distance Is Increased to 15 Miles . . . . . . . . . . . 173 6-9a Enterprise Budget of Utilization Costs to the Municipality. The Treatment Plant Pays $40 per 20 Cubic Yards of Filter Cake Sludge to a Private Hauler. Sludge has 40% Solids. . . . . . . . . . . . . 176 6-9b Enterprise Budget of Utilization Costs to the Municipality. The Treatment Plant Pays $16.5 per Thousand Gallons of Sludge Hauled to a Private Firm. Sludge Has 5% Solids . . . . . . . . . . . . . 177 6-10 Enterprise Budget of Utilization Costs to the Farmer. A Private Hauler Trans- ports Sludge (5% Solids). Farmer Applies and Incorporates the Sludges . . . . . . . . . 177 6-11 Enterprise Budget of Utilization Costs to the Farmer. A Private Hauler Transports Filter Cake Sludges (40% Solids). Farmer Applies and Incorporates the Sludges . . . . . 178 6-12 Summary Table of Utilization Costs Under Alternative Contractual Arrangements . . . . . 179 xii LIST OF FIGURES Figure Page 2-1 Diagram of a Wastewater Treatment System and Sources of Sludge Generation . . . . . . . . . . . . . . . . . . 27 5-1 Location of Surveyed Communities . . . . . . . 108 xiii CHAPTER I INTRODUCTION The environmental quality issue began as a popular topic for public debate in the late 1960's, and has become a focus for public policy in the 1970's. In the United States, the "awakening of the ecological conscience" has created an impetus for pollution abatement and resource con- servation. In response to the demands for reform, the political process has enacted voluminous legislation and established new enforcement agencies. These governmental laws and organizations, combined with citizen action groups, have changed the rules for dealing with environmental protection. The birth of these institutions,1 or set of rules, has had a distinct impact on the behavior in the economy. The private and public sectors of the economy have been given incentives to control pollution. Various measures such as taxes, fines, grants and outright reg- ulation have been used to encourage waste management. But pollution abatement has also been recognized as a cost- ly business. The benefits of eliminating all wastes would be far below the associated economic and social costs. The current approach to the problem has been to achieve a desired quality of life at a cost which is acceptable to society. The institutions chosen to deal with pollution exter— nalitiesz have not always performed as intended. In fact, the efforts to abate one form of pollution have caused problems in other areas of waste management. One of these undesired consequences has been the intensification of the sewage sludge disposal problem as a result of the federal water pollution control program. The sludge management issue has been receiving in— creasing attention at national and local levels. This greater recognition stems from the generation of much larger volumes of sludge by municipal wastewater treat- ment plants throughout the country. The growing sludge disposal problem is a direct consequence of water pollution control laws for municipalities who must upgrade their sewage systems. Many communities are trying to identify disposal alternatives which are both economically feasible and socially acceptable. These municipalities are in need of additional knowledge on the available options for handling sludge. In relation to these informational needs, the aim of this thesis is to describe and analyze the farmland sludge utilization alternative. Origins of the Wastewater Sludge Problem Enactment of Public Law 92-500--The Water Pollution Control Act Admendments of 1972 The ninety-second Congress of the United States set a national goal of eliminating pollutant discharges to navigable waters by 1985 when it passed Public Law 92—500. One portion of these Amendments, which are abbreviated as the WPCA of 1972, specifically directs municipalities to upgrade their sewage treatment facilities.3 The 1972 Law requires the use of advanced waste removal techniques to reduce the biochemical oxygen demand, or BOD,4 of municipal wastewaters discharged into local rivers and streams. The organic matter (BOD) and nutrients removed by treatment processes are concentrated into a semi-liquid slurry known generically as sludge. The more advanced techniqhes have raised BOD reduction rates, and have therefore generated larger volumes of sludge. As a result, the abatement of pollution from wastewater out- flows has been gained at the expense of increasing the difficulties of sludge disposal. Since waterways are no longer acceptable as sludge dumping sites, municipalities are trying to develop other options for sludge management. Some of the alternatives which are presently being employed for sludge handling include: 1. The transport of sludges to sanitary landfills. 2. The lagooning of sludges on public lands. 3. The incineration of sludges with the resultant ashes to be lagooned or landfilled. 4. The landspreading of sludges on publicly- owned farms and/or forests. 5. The land application of sludges for the reclamation of strip-mine and other organically deficient soils. 6. The ocean dumping of sludges. 7. The landspreading of sludges on private farm- land and/or forestland by agreement of land— owner and municipality. The private farmland application strategy is the focus of this thesis. All of the above-mentioned alternatives, except ocean dumping, are legally accepted means of sludge disposal. Ocean dumping has been an interim practice of large coastal metropolitan areas, but this type of sludge disposal will be in violation of federal statute in 1981.6 A prime example of a municipality that has been using the ocean dumping option is Philadelphia, Pennsylvania. Under political pressure to meet the federal deadline, Philadelphia, officials have announced that a recycling center will be built to begin composting sludge for use as a fertilizer.7 Farmland Utilization of Municipal Sewage Sludge Sources of Controversy over Farmland Application The potential of sludge to act as a fertilizer and soil admendment has been recognized by agronomists for some time. However, the agricultural utilization alter- native has not been readily adopted. In the past, a num— ber of objections have been raised with respect to the risks associated with sludge use. Some of these problems can be listed as follows:8 1. The costs of sludge utilization can be very high if the municipality must acquire land by con- demnation, in addition to the transport and handling costs. 2. Excessive application rates can cause contamination of groundwaters with toxic levels of nitrates. Other problems include runoff from sludge- amended soils and the direct ingestion of sludge by domestic farm animals 3. The hygienic hazards of the human pathogens which can exist in sludge. 4. The claims that sludges are capable of improving crop yields at a lower cost have been exaggerated. 5. The odor which emanates from incompletely digested sludges is less socially acceptable than manure odor. 6. The research that has been conducted so far is thought by some to be not objective in orientation; studies have tried to justify the land utilization option. 7. Continual application of sludges on a yearly (or annual) basis could result in the buildup of heavy metals and other trace elements. Toxic levels of these sludge components can inhibit plant growth or move further up the food chain. 8. The benefits of sludge use are not readily separated from the associated hazards. The above criticisms deserve attention, and current studies are being geared towards answering the tough questions and finding ways to improve sludge utilization programs. The technical and social problems must be over— come if land application is to be a successful endeavor. An improperly managed sludge disposal plan can pro- duce adverse environmental effects. Untreated sludge has an obnoxious odor and may contain dangerous pathogens. To safely implement a farmland sludge utilization plan, appropriate technical practices must be employed. Processes such as sludge stabilization, soil incorporation and groundwater monitoring are some of the techniques which should be instituted in a sludge program. In addition to preventing the occurrence of mishaps, proper landspreading methods promote the dual utilization goals: the disposal of sludge in an acceptable manner and the enhancement of crop production potentials. Currently, all waste disposal practices are receiving more public scrutiny. In the aftermath of Michigan's PBB incident, citizens throughout the state have been sensitized to issues such as public health and environmental hazards. When this atmosphere of social awareness develops into one of public distrust, risk-related activity may encounter opposition. A strong social reaction can markedly influence a public program. The disposal of sewage sludges is an issue capable of eliciting a vigorous response from a local community. Potential impacts such as odors, runoff and health threats quickly gain the attention of citizen action groups. Interested parties may exercise their rights under nuisance laws to block the implementation of a sludge plan or set restrictions on application practices. Such opposition becomes highly probable when local people are not consulted before a plan is implemented. Citizen participation may be a vital step in getting any program approved. The people in the community should be informed of the nature of the sludge disposal problem, what alter- natives are available, and what decisions need to be made. The choice of a specific option and its accompanying economic and technical impacts, such as private farmland utilization, should receive local consent before action is taken. But even with early citizen participation, there is no assurance of public acceptance of the program. One of the purposes of this study is to examine the technical and social problems presented by sludge disposal. In particular, there are a number of difficulties specific to the choice of private farmland application as a disposal alternative. Also, zinumber of distinct advantages exist for utilizing agricultural lands. This investigation is being conducted because the private farmland option has a potential for dealing with sludge disposal in an accept- able manner. Farmland Utilization as an Increasingly Desirable Sludge - Handling Technique In an effort to promote the landspreading of sludges and wastewaters, the WPCA of 1972 set goals for "the en- couragement of recycling of sewage pollutants through the production of agriculture, silviculture and aqua- culture products."9 The admendments also contained a statement such that "the ultimate disposal of sludges should be carried out in a manner that will not result in en- vironmental hazards."10 In addition to sludge utilization becoming a federally endorsed concept, land application haS'recently been per- ceived as a more economically attractive mode of sludge management. Rural communities with populations of 10,000 or less seem to have the best opportunities for setting up sludge utilization programs. In these smaller munic- ipalities, the wastewater treatment plants are located closer to available farmlands. Transportation is a major activity in a utilization plan, and shorter distances mean lower travel costs and easier access. Also, rural areas with less densepopulations have fewer public exposures to odors and other disposal problems. Another consideration is that sludges which are generated by down—sized sewage plants do not usually contain high concentrations of heavy metals. The problem of metals or trace elements arises when the treatment plant has industrial waste inflows. One of the provisos of any utilization program is that the sludge must be properly stabilized. The agri- cultural use of raw, untreated sludge is simply prohibited in most municipalities of the U.S. Most treatment plants now employ some stabilization process, regardless of whether the sludge is to be placed on farmlands. Sludge treatment is required largely for reasons of hygienic and odor nuisance control. Therefore the costs of stabilizatio; are not solely due to landspreading programs. Purpose of this Study The aim of this thesis is to analyze the social, economic and technical aspects of farmland utilization as a sludge management alternative. To develop a systematic View of the disposal problem, this study has the following objectives: 1. Analyze the contractual arrangements, economic aspects and social problems of sludge utilization programs in Michigan. 2. Outline and explain the significance of the federal, state and local regulations as a legal framework within which local decisions on wastewater and sludge treatment are made. 3. Explain some of the technical aspects of utilizing sludge by examining: a) The physical-chemical-biological character- istics of municipal sludges b) the methods of stabilization and transport c) the potential agronomic effects of sludge utilization d) the environmental hazards associated with im— proper sludge management. 4. Describe and interpret the results of surveys conducted with farmers and wastewater treatment plant Operators who have jointly participated in sludge programs. The implications of the surveys for implementing utilization programs are presented. 5. Perform some representative case studies which approximate the costs of utilization. 6. Summarize the private farmland alternative as a potential solution to the sludge disposal problem in rural Michigan. The necessity for conducting this study stems from the rising interest of rural Michigan communities for sludge utilization. These small municipalities are demand- ing evidence on how well different disposal practices are able to fulfill social, economic and technical standards of performance. Until this study, the state of Michigan has had no complete documentation of the performance of sludge utilization as a disposal alternative. Research papers already completed in states such as Ohio, Illinois, 10 Oregon and Massachusetts have demonstrated the beneficial potential of sludge utilization. This study employs a multi-disciplinary approach to gain a broader perspective on utilization in Michigan. Previous research conducted at Michigan State University has investigated the more varied aspects of the land disposal of municipal waste- water.11 The results of this study of sewage sludge utilization are important to municipalities and farmers who are con- sidering farmland application as an alternative. This research proposes that municipalities can increase their ability to solve the sludge problem by developing a more organized approach. Consideration of the legal, technical, economic and social aspects of a utilization program is necessary if a municipality is to decide whether land app- lication is a feasible and desirable option. Thesis Plan The desired accomplishment of this study is to analyze the feasibility of private farmland sludge utilization as a management alternative. The content is arranged into seven chapters. This first section is an introduction to sludge disposal and the farmland application option. Chapter One has also stated the purposes and justification for the study. Chapter Two sets up an outline for examining the sludge problem in an analytical manner. Chapter Two is primarily designed to give a systematic View of ll sludge utilization. Chapter Three examines the legal structure and institutional arrangements which have shaped the structure of sludge utilization programs. The issues of sludge management are examined at federal, state and local levels of government. The actual im— plementation of utilization plans is viewed from the per- spective of the contractual agreements which occur between the municipality and the farmer for the landspreading of sludges. Chapter Four is an overview of the technical aspects of sludge utilization. This fourth chapter includes a brief description of stabilization and drying techniques, transportation and application equipment and the evidence on sludge's ability to yield agronomic benefits. Chapter Four also discusses the problems of pathogens, heavy metals and nitrogen overloads which are associated with sludge use and misuse. In Chapter Five, the results and implications of surveys conducted with both farmers and sewage treatment plant operators are described. This fifth section uses tables to illustrate important relation- ships which characterize utilization programs. Chapter Six sets up a number of case studies on the costs of farm— land application of sludges. Partial budgets are used to estimate costs under various assumptions about util- ization arrangements. The concluding Chapter Seven summarizes the findings of the study on the farmland app- lication alternative in Michigan. This final chapter em- phasizes the need for more informational and communicational 12 efforts to improve existing programs. It also reviews the various aspects of beginning a sludge utilization pro- gram in a municipality. Finally, the areas in need of further research are outlined and the future aspects for land application as a disposal option are evaluated. ENDNOTES 1An institution is "a set of ordered relationships among people which determine their rights, exposure to the rights of others, and their responsibilities," as defined by A. Allan Schmid, Property, Power and the Public Choice: An Inquiry into Law and Economics (New York: Praeger Publishers, 1978), p. 5. 2An externality is ”an unintended consequence of an economic action for which no compensation is required," as defined by Brian Harvey and John D. Hallett, Environment and Society: An Introductory Analysis (Cambridge: The MIT Press, 1977), p. 97. . 3Title II, Secion 202b of public Law 92-500, The Federal Water Pollution Control Act Admendments of 1972, 33 U.S.C. 1251. 4Biochemical oxygen demand (BOD) is defined as "the quantity of oxygen used by micro-organisms in the decom- position of organic matter in wastewater," in Mark J. Hammer, Water and Waste-Water Technology (New York: John Wiley and Sons, Inc., 1975), p. 80. 5 Hammer, pp. 433-35. 6Title I, Section 101 (a) of Public Law 95-153, Amend- ment to the Marine Protection Research and Sanctuaries Act of 1972, 33 U.S.C. 1420. 7Bob Frump, ”City to Build Plant for Sludge" The Philadelphia Inquirer, 30 August 1978, p. 1B. 8D.R. Egeland, ”Land Disposal: A Giant Step Back- ward," Journal of the Water Pollution Control Federation, 45 (July 1973), 1465-75. 9 Title II, Section 201 (d) (1) of Public Law 92-500. 10Title II, Section 201 (d) (4) of public Law 92—500. 11Jeffery Williams, Case Histories and Comparative Cost Analysis of Land Treatment of Wastewater by Small Municipalities in Michigan, Master's Thesis, Michigan State University, 1977. 13 CHAPTER II A FRAMEWORK FOR EXAMINING FARMLAND SLUDGE APPLICATION PROGRAMS An Outline of the Important Aspects of Sludge Utilizationl In order to state the sludge problem in a concise and comprehensive manner, it is useful to develop an approach for analyzing the various aspects of a landspreading pro- gram. This chapter begins by specifying the primary goals of farmland sludge application. Then the analysis proceeds to View some of the institutional and economic characteristics of sludge utilization. Next, an examination of the interested parties is conducted to highlight the potential impact of these people on the planning and operation of a sludge program. The ”state of the art” technology for the treatment, transport and beneficial use of sludges is then briefly reviewed. Finally, the important dependent and independent variables of sludge management systems are broken down into identifiable categories. Goals of Sludge Application Programs A systematic approach to the analysis of sludge utilization begins with a description of program goals. Sludge landspreading on private farmlands are designed primarily to meet two objectives: l4 15 l. The ultimate disposal of sludges in an environ- mentally-safe and an economically-efficient manner. 2. The application of sludges to enhance the agricul- tural production goals of the participating farmer. The municipal sludge disposal aim, the first one listed above, derives from the public policy for stricter environ- mental standards and the desire to find the cost-effective solution which complies with these standards. The second goal of the sludge program is just as important if utilization is to become a cooperative success. The farmer's crop production goals should be aided by the benefits of sludge as a soil admendment. Recently, an additional incentive for obtaining alternative nutrient sources such as sludge has been the rapidly rising price of petroleum-based fertilizers. The agricultural production goal and the municipal disposal goal are potentially conflicting. To resolve the differences which may exist between the farmer and the treatment plant operator, a contract of mutual agreement is necessary for starting a sludge program. Institutional Arrangements and Economic Aspects Contractual Agreements for Sludge Utilization In general, sludge utilization plans for private farmlands in Michigan involve contractual (oral or written) agreements between a municipality and a landowner.2 In such contracts, joint arrangements are made for the transportation and application of treated sewage sludge onto the farmer's land. The farmer usually agrees to take l6 sludges onto specified sections of his property for a certain period of time. In exchange for the use of the farmer's land, the municipality assumes responsibility for the transport, handling and monitoring costs to ensure safe disposal of all the sludge. In fulfilling the standards for proper sludge management, for example, the municipality is generally expected to perform sludge and soil sample analyses, and slope and runoff evaluation. Groundwater and surface~water tests are also done on a selective basis. The technical, administrative, labor, transport and liability costs can be collectively thought of as the transactions costs for a municipality that institutes a sludge utilization program. The farmer and the municipality may also jointly share the costs of transport and application, since the handling equip— ment serves a dual purpose of wast disposal and agronomic improvement. Using the concepts of theoretical microeconomics, the rational farmer would use a marginal analysis for including sludges as a priced input in his production process. Under the simplifying assumption that the farmer was producing only one output, he would use extra amounts of sludge until the marginal cost of application just equalled the marginal revenue generated by the last unit of sludge input. In most cases the marginality condition can not be applied to sludge use decisions. To correctly balance benefits and costs for maximizing net returns, the farmer would have to determine the independent technical effect of sludge from his production function. He also would 17 need to overcome the "user cost" measurement problems of estimating the value of sludge—handling equipment. In addition, future price trends in the input and output markets would have to be known with certainty. When the municipality takes responsibility for the transport and application costs, the farmer simply agrees on the time schedules and land parcels for the sludge program. The surveys conducted for this study indicate that the municipality often bears most of the utilization costs. If the farmer does not have to share in the costs of the app— lication program, he can maximize the net returns from sludge use, subject only to the institutional and technical constraints on the landspreading operation. Conceptual Economic Issues of Sludge Utilization The advantages of land application of sludges can be arranged into two basic categories. The capacity of sludges to upgrade soil and crop conditions comprises the first class of benefits. Secondly, an improvement in water quality of the environment is expected to result from reducing the discharge of nutrient-laden effluents into natural waterways. The soil admendments anticipated from sludge application are primarily the plant nutrient contributions (N-P-K) and the soil-building capabilities of the sludge organics. If the utilization programs are to be valuable to farmers, the sludge input should generate improved crop production and higher returns from the cropping activity. Alternatively, 18 utilization could also result in a fertilizer cost savings, by decreasing the requirement for commercial fertilizer while maintaining crop yields. Due to the difficulty in measuring the independent effect of sludge on the plant growth process, only rough estimates of the input value of sludge are available. To improve these estimates, further research is necessary to establish the crop yield responses to sludge applications. In conjunction with these technical investigations, economic analysis should demonstrate whether sludge is competitive with alternative nutrient sources. One method of approximating the separable costs and benefits of a sludge program is the use of partial budgets. The results of such budgeting techniques provide estimates of the net value of sludge, which can then be compared with the profitability of other fertilizer inputs. For instance, if the partial budgets demonstrate animal manure to be more cheaply employed than sludge, then the municipality has to offer additional in- centives to encourage the farmer to take sludges onto his land. Such incentives may include the municipality purchasing application equipment, assuming damage lia- bility or generally operating the entire program at no expense to the farmer. The second type of sludge management benefit, improved water quality, also presents measurement difficulties.3 The value of controlling sewage disposal is often measured in purely physical terms, using water pollution indicators such as BOD levels, nitrogen concentrations and bacterial counts. 19 As mentioned previously, secondary sewage treatments eliminate about ninety-five percent of the BOD causing organics in wastewater. But this gain in removal efficiency has expanded sludge production, because the extracted BOD is just concentrated into additional sludge. So the key to the success of a wastewater pollution control program lies in the effective disposal of increasing sludge volumes. A closer examination of the water pollution issues can reveal some insights into the economic value of lowering BOD in natural waterways. A crucial assumption of the entire process of upgrading pollutant removal efficiency is that gains will eventially be obtained in the form of clean- er waters. Higher water quality is often referred to as a "public good" or a "joint impact good."4 A joint impact good is one which, once produced, can be utilized by more than one person.5 Such "public good" qualities can sometimes be more easily handled by a public sector action. Some of these aspects have been categorized as follows:6 1. Negative Externalities or Spillovers Pollution is a classic example of a negative externality. Externalities occur when an economic agent causes a cost (or benefit) to be generated, but that agent does not have to account for that cost (or benefit). 2. High Exclusion Cost and Free Riders The problems of exclusion and free riders occur with common property resources. The difficulty is that, once the good is produced, it can be consumed by more than one person without a decrease in its usefulness. When the costs of excluding a person from using the product become high the incentive is to consume without paying for the good (free rider). 20 3. Resolution of conflicts of interestover public goods use—rights The decision is to distribute the costs and benefits of using a public good among different groups. The public sector politically and legally decides whose interests count. For instance, the Water Pollution Laws have transferred "water quality rights” to target groups concerned with aesthetics, ecological balance, recreational use, and cleaner water supplies. At the same time, "polluters" have been forced to internalize effluent costs through various abatement procedures. When Congress passed Public Law 92-500, it proclaimed a goal of eliminating all water pollutants by 1985. Therefore, the political process has already made an evaluation judgement: the benefits of improved water quality exceed the costs of effluent treatment and alternative disposal. It is in this view that sludge management is an activity that is publicly recognized as having a net benefical value. But what can be implied about the institutional changes that this political decision has caused? To understand the significance of the Congressional decision, the legislative process needs to be more closely examined. The lobbies in Congress represent a whole variety of interests, and the passage of the 1972 water law indicates that the groups concerned with higher water quality prevailed in asserting their position. The target groups who most benefit from the improvements which may result from the new law can be categorized as follows:7 1. Present and Future "Clean-Water" Users A list of the goods and services which can be jointly consumed with improved water quality might include: (a) (b) (C) (d) (e) 21 Aesthetic values attached to unpolluted or pristine waters promoted Recreational opportunities enhanced Ecological balances are allowed to be restored by natural processes Water supplies less threatened by effluents By passing national standards, it was the intent of Congress that all users would eventually realize ”downstream benefits" of pollution abatement. 2. Option Demanders Those people (groups) who may not be presently con- suming the products but effectively demand that action be taken to preserve those opportunities, should they be desired at a later time. 3. Beneficiaries who experience real economic gains (a) (b) Downstream water users have decreased treatment costs, which means that less resources are used to produce the same output. Increased valuation of a "unit of improved water quality" expressed as a higher effective demand. For example, the value attached to recreational and aesthetic qualities may increase as society places a higher significance on amenities. The enactment of Public Law 92-500 has transferred power (rights) to groups primarily interested in water quality. To assure that these interests are converted into effective action, the Congress has played a role of central coordinator to control pollution externalities. In this case the public sector approach has been to administratively employ a number 8 of "solutions": 1. Regulation - For example, a requirement that at least secondary treatment be installed at all municipal wastewater facilities. 22 2. Payments - Construction grant program of federal funding for municipalities upgrading their wastewater plants. 3. Prohibition - Setting of deadlines for implementing effluent controls. 4. Directives - Establishing nationwide water quality standards based on technical infor- mation (for example, the desired levels of Biochemical Oxygen Demand in water- ways). Those who bear the costs of Congress's initiatives can be identified according to sources of funds. For instance, federal grant monies ultimately originate from federal tax- payers, whereas projects designed to upgrade municipal facilities are also financially supported by local plant users. In a sludge application program, if a farmer pays for sludge as a productive input, he is indirectly bearing some of the treatment costs of effluent controls. The costs of clean water are also being internalized by private industry, since the pollution laws apply to almost all sources of effluent. Another aspect of abatement is classified into a category known as pecuniary effects, which are neither costs nor benefits in an analytic sense. Pecuniary effects occur when improved water quality causes an increase in effective demand for water activities, which in turn produces a resultant rise in relative prices. If a supplier of water— related services receives higher prices and profits, due to the increased demand of water-users who now have new opportunities, then income is redistributed from buyer to seller. 23 The cost side of the equation also includes the problems encountered in the enforcement and implementation of en- vironmental legislation. Bureaucratic, informational, and institutional obstacleS‘ add to the job of making abatement a workable concept. Sludge disposal costs are merely one facet of the expenditures for effluent control. Single sludge management is a direct result of Public Law 92-500 and other legislation, it is politically recognized as having a net beneficial value. When the Congress says that the benefits of a project exceed the costs, the work of the economic analyst is reduced to finding the cost— effective (or cheapest) solutions. Techniques such as sen; sitivity analysis and opportunity cost evaluation can be used to establish a framework for economic decisionmaking between sludge disposal alternatives. In connection with these cost-minimizing criteria, the Congress has also demonstrated its support for alternative disposal tech- nologies such as recycling sewage. The Clean Water Act has given these innovative projects an additional 15% advan- tage in cost-effectiveness calculations and has also ab- solutely required municipalities to consider alternative disposal techniques to be eligible for construction grant funds. The water quality of a lake or stream is a primary fac- tor in determining the type and degree of jointness in use. Unpolluted conditions along a certain section of a river would be conducive for simultaneously supplying domestic, 24 aesthetic and recreational water uses. Polluted water may not be useful to any of these groups, or only at a high treatment cost. In addition, water pollution may upset del- icate ecological balances that would directly or indirectly affect economic agents in terms of higher costs of main- 9 O Certaln users taining a desired quality of life. can tolerate a lower water quality at a lower cost than others, so that the desirable characteristics of water for one activity may be incompatible with those for another activity (for example, wastewater treatment versus recreational use). Domestic consumption, industrial use, recreational oppor- tunities and the ecological balance are each affected differently both in degree and in kind by the impacts of a specific level of water quality. Improvements in water conditions may benefit some users a great deal and others none at all (or even negatively). As implied in P.L. 92-500, the target groups of water users who should most benefit from water pollution abatement are those concerned with the consumptive, recreational, ecological and aesthetic goods to be obtained from having a ”cleaner” waterway. Interested Parties Besides the jointly participating farmer and wastewater treatment plant operator, there are a number of other interested parties who can influence a sludge utilization 'program. The presence (or absence) of these groups can markedly affect the final structure and performance of the 25 sludge management scheme. The motivations for these inter- ested groups vary from a federal agenCy's formally designated responsibilities to a citizen's concern for the program's impact on his personal activities. A list of all the interested parties would include:10 1. wastewater treatment plant operator 2. participating farmer(s) 3. neighbors of the participating farmer, concerned local citizens, and the general public 4. local municipal government (such as the local Health Department) 5. state agencies (such as Michigan's Department of Natural Resources) 6. state land-grant university; for example, at Michigan State University the involvement of: a) Agricultural Experiment Station b) Agricultural Extension Directors c) Departments of Crop and Soil Sciences, Agricultural Engineering, and Agricultural Economics 7. Federal agencies, guidelines, and funding a) Environmental Protection Agency b) U.S. Department of Agriculture c) Food and Drug Administration 8. Private Consulting Firms and Hauling Firms Due to their diverse backgrounds and intentions, the input of any (or all) of these above-mentioned parties can influence the development and operation of a sludge utilization pro- gram. The interactions among the various groups produce working relationships which define the rights and respon- sibilities of the primary participants, namely the farmer and the plant operator (who represents the municipality). Another factor which affects the institutional relationships. 26 is the available state-of-the-art technology for implementing a feasible sludge project. Technical Characteristics of Sludges11 The technical considerations for the spreading of sludges onto agricultural lands involve the evaluation of the physical, chemical and biological characteristics of sludge. Sludge is a generic term for the setteable solids which are coagulated in the wastewater treatment processes to form a semi-liquid mix- ture (0.25% or > 0.25% solids) of organic matter and mic- robes. Sludge is categorized by the treatment process from which it originates. Raw (untreated) sludge is composed of the solids directly settled (clarified) from the incoming wastewaters. Activated, chemical and filter sludges are produced from the solids which collect in the secondary treat- ment processes in the wastewater plant. The raw sludge is often mixed with the other treatment sludges, and this mixture is then circulated to the site of stabilization, as depicted in the flow diagram below. Figure 2-1. Raw ;_ Grlt Sewage Diagram of a Wastewater Treatment System and Sources of Sludge Generation. __..<"..__. _. _____ 1.329291993113952“ Secondary Aeration Tanks or Trickling Filter _____—__—-_)_—________ Final Treatment Clarifier Primary Removal Clarifier Raw Sludge Sludge . . . Secondary Stablllzatlon Sludge W Stabilized Sludge \ Drying Sludge Processes >: Storage Secondary Effluent Chlorination Treatment for Disinfection River or Waterway of Sludges Ultimate Disposal 28 Anaerobic digestion (noted in the above diagram) is the most commonly employed stabilization process for treating . raw and secondary sludges. The stabilizing effect of anaerobic digestion is the result of a bacterial fermentation process that breaks down the odorous organic compounds into relatively more inert substances. After digestion, the stabilized sludge is a dark gray to black semi-liquid substance with a granular consistency, a tar-like odor, and a 3 to 5% organic solids content. The physical char- acteristics of digested sludge are compatible with de- watering processes which decrease the volume and mass of sludges for on-site storage processes at the treatment plant. Dewatering reduces the moisture content of stab- ilized sludge, and this "drying“ process can be accomplished with open-air drying beds, centrifuges or vacuum-filter devices. Dewatering produces a 60% moisture, pastelike material which is known as "dry filter cake sludge," as distinguished from ”liquid sludge" which is directly gen- erated by stabilization processes. The importance of the distinction made between liquid and dry sludges becomes more apparent when selecting the proper transportation and application equipment. Hauling and spreading of liquid sludge usually involves the use of modified tank- wagons, while dry sludges may require the use of a manure spreader. Before consideration of sludge handling equipment becomes a matter of decision, the initial evidence for sludge as a 29 valuable crop input should be established. Sludge app- lications provide plant nutrients and can improve the properties of the soil. But sludge also possesses path- ogenic threats. The severity of the disease vector problem is modified by a number of factors: the kind and degree of stabilization, the types of microbes in the sludge and the survival time of pathogens in the soil environment. Other important constraints on sludge application are the build-up of heavy metals in the soil and the prevention of nitrogen excesses and nitrate groundwater contamination. Proper control of the potential damages caused by faulty application methods is also essential if programs are to be successful and begin to receive public acceptance (another constraint). Categorizing the Significant Factors in Farmland Sludge Application13 An understanding of the influences affecting the per- formance of sludge utilization can be found through an identification of the independent and dependent variables in a sludge management system. As a specific strategy, private farmland sludge application programs are jointly implemented by a municipality and a participating farmer. From the point of View of these primary participants, the controllable and uncontrollable variables can be outlined as follows in Table 2-1. The distinctions made in Table 2-1 are useful for Table 2-1. 30 Categorizing the Controlled and Uncontrolled Variables of a Sludge Utilization Program from the Perspectives of the Participating Farmer and Municipal Sewage Plant Operator. Uncontrolled (or Independent) Controlled (or Dependent) Variables Variables Population density and 1. Choice of the approp- growth riate treatment and a) partial determinant of wastewater inflow to the treatment plant and influences the volume of sludge to be disposed 2. Distance between treat- ment plant and avail- able farmland a) influences port costs trans- Environmental con- ditions for land- spreading a) climate, weather 3. b) type of soil 0) topography d) hydrogeology Nutrient content and soil benefits of stabilized sludge a) technical charac- teristics of sludge Pathogenic disease vectors and heavy metals content of sludges a) type and number of pathogens b) estimated survival time of pathogens in the soil c) concentration of heavy metals application technology a) economic aspects b) technical aspects c) institutional aspects Institutional arrange- ments a) terms of the land- spreading agreement b) ability to influence restrictions, e.g., obtain a variance from local zoning ordinance for sludge application. Economic considerations a) decision among the disposal alter- natives b) benefits: and to whom C) costs: how much and who bears them how much 31 Table 2-1 (cont'd.). Social factors a) influence of inter- ested parties on the program b) public attitudes Available technology for sludge util- ization a) transport and application equip- b) C) d) ment stabilization tech- niques sludge and soil analyses estimation of crop yield responses to sludge use Control of potential risks and the ability to promote sludge utilization benefits a) b) 0) use of proper man- agement practices to ensure environ- mental and health protection proper management or application procedures to en- hance the sludge nutrient values for crop production safeguards against longer-term risks through monitoring and testing proce- dures. 32 describing the static situation faced by the farmer and treatment operator. The designations 'controlled' and 'uncontrolled' are intended to be very general. In cer- tain cases, variables such as 'social factors' may in fact be dynamically influenced, or controlled, by the munic- ipality and the farmer. Or, the use of a certain tech- nology may be locked-in (no control), at least in the short run. The municipality and farmer can manipulate the control variables in an attempt to achieve the goals of the sludge program. But changes in either type of variable can effect performance. A complicating factor is that the alter- ing of program conditions causes a number of interrelated consequences. This variety of impacts on the technical, legal and economic aspects of sludge use are difficult to identify and evaluate. A broader approach is necessary to better assess the outcomes which flow from decisions and changes. One of the objectives of this thesis is to widen the scope of analysis to improve the process of solving the multi-faceted problems of sludge utilization. This chapter has briefly outlined the major components of a sludge management program. In the following Chapter Three, a more detailed description of the legal and economic issues is presented. ENDNOTES 1The idea for employing the analysis in Chapter Two is taken from R.H. Pantell, Techniques of Environmental Systems Analysis (New York: John Wiley and Sons, 1976), pp. 1-45. 2The information on farmer-municipality arrangements if obtained largely from private conversations and survey answers provided by actual program participants. 3This discussion takes ideas from A. Allan Schmid, AEC 811, Spring, 1978. 4A. Allan Schmid, Property Power and Public Choice: An Inquiry into Law and Economics (New York: Praeger Publishers, 1978), p. 70. 51bid., p. 79. 6A. Allan Schmid, pp. 37—57, 70-87. 7These concepts of beneficiaries are taken from dis- cussions with Robert S. Manthy, R.D. 809, Winter 1978. 8Otto A. Davis and Morton I. Kamien, "Externalities, Information and Alternative Collective Action,." Public Expenditure and Policy Analysis (Chicago: Rand McNally Pub. Co., 1977), pp. 94-104. 9Roger Blabaum, Larry C. Holcomb, Sarah Fast and Larry Swanson, "An Assessment of the Potential for Applying Urban Wastes to Agricultural Lands," Urban Wastes Project (Omaha: National Science Foundation Program, 1978), p. 47. 10The information on the interested parties is obtained primarily from the surveys conducted with farmers and sewage treatment plant operators. 11Clarence G. Golueke, Biological Reclamation of Solid Wastes (Emmaus: Rodale Press, 1977), pp. 117-150. 12Mark J. Hammer, Water and Waste-Water Technology, (New York: John Wiley and Sons), p. 346. 13 R.H. Pantell, pp. 16-17. 33 CHAPTER III LEGAL, INSTITUTIONAL AND ECONOMIC ASPECTS OF SLUDGE UTILIZATION Dealing with the New Problem: Sludge Management The language of the legislation and policy statements on sludge has increasingly reflected the concern for conservation and recycling efforts, rather than just 1 Alternative technologies have been simple disposal. endorsed, and funding has been provided to do technical research on sludge utilization methods. The phrase ”sludge management" is used to emphasize the role of proper decision-making in successfully confronting the sludge problem. Proper sludge management involves acquiring and organizing the knowledge of the legal, institutional, economic and technical information into a workable pro- gram. This study now proceeds to examine the legal structure that provides a foundation for sludge utilization projects. The Legal Characteristics of Sludge Management Legislative and Regulatory Responses to the Sludge Problem The U.S. Congress designated the Environmental Protection Agency (EPA) as the primary enforcement 34 35 organization for administering the pollution control directives of Public Law 92-500. Authority was to be trans- ferred to individual state environmental agencies, under the condition that the state would enforce requirements at least as strict as the federal regulations. In Michigan, the DepartmentcfliNatural Resources (DNR) serves in the role of enforcer, in addition to numerous other environmental services. The FWPCA of 1972 also called for the construction of improved sewage treatment facilities for municipalities, and financing of these projects were to be up to 75 percent federally funded. Sludge management systems also had to be upgraded and their costs can vary between 30 to 50 percent of total plant expenditures.2 However, the construction grant system was structured so that sludge treatment investments were primarily made in capital intensive equipment. Municipalities also had to rely upon consulting firms for wastewater treatment design expertise, and these firms were composed largely of sanitary and civil engineers who endorsed the use of more sophisticated equipment for sludge management. This sit- uation occurred despite the clauses in Title II of Public Law 92-500 which designated recycling and land application as options to be seriously examined. In 1976, the EPA's Office of Water Program Operations (the OWPO administers the construction grant funding) altered the application procedure to increase the possibilities of receiving 36 federal aid to be used in the purchase of land for sludge and wastewater applications purposes.3 Also, as the Congress became aware of the increasing magnitude of sludge management problems, it enacted new environmental legislation which contained provisions designed to deal with sludge disposal. The following list comprises federal statutes which have sections on sludge management practices. Some of the impacts of new requirements are explained below, following the list of federal laws in Table 3-1 on the next page. Federal Legislation Pertaining to Sludge Use4 Public Law 92-500--The Federal Water Pollution Control Act Admendments of 1972 In order to provide adequate funding of the com- prehensive aims of P.L. 92-500, the U.S. Congress initially authorized the expenditure of 24.7 billion dollars. Such an outlay was unprecedented in the field of pollution abatement. Out of this sizable federal bud- get, some 18 billion dollars were allotted for the con- struction of treatment plants and secondary facilities. As mentioned previously, the approval of grant applications was supposed to be partially dependent upon the mun- icipality's consideration of recycling and recovery alternatives for waste disposal. Regretfully, the ultimate disposal of sludges was a question which was left largely unanswered by P.L. 92-500. Municipalities proceeded to 37 Table 3-1. List of Federal Laws Which Contain Provisions on Sludge Management. Public Public Public Public Public Public Public Law Law Law Law Law Law Law 92-500 95-217 93-523 94-469 94-580 95-153 95-192 Federal Water Pollution Control Act of 1972 (FWPCA of 1972) Clean Water Act of 1977 (Amends WPCA of 1972) Safe Drinking Water Act of 1974 Toxic Substances Control Act of 1976 Resource Conservation and Recovery Act of 1976 Marine Protection, Research and Sanctuaries Act of 1977 (Amends P.L. 92-532 of 1972 on Marine Pro- tection) ' Soil and Water Resources Conservation Act of 1977 38 individually define the strategies which would fulfill the minimum requirements for "disposing of sludges in an environmentally safe manner." The information upon which to make such disposal decisions was for the most part incomplete, and cost-effective alternatives of land application were absent from consideration in numerous cases. Another difficulty involved the lack of coop- eration beetween adjacent counties and townships for land application alternatives. The movement of sludges across political boundaries was interpreted as one area "dumping” at the expense of another, even if the program was designed to enhance the organic content of soils and recycle nutrients back into the ecosystem. Preconceived notions about the undesirability of human wastes often dominated over any efforts to introduce the concept of utilizing treated wastes in a beneficial manner. Such episodes highlighted the need for educational workshops on the magnitude of the wastewater sludge disposal problem and the options available for communities. The implications of P.L. 92-500 were not clearly understood by local officials and the general public, which resulted in an atmosphere of distrust of any landspreading activities proposed by wastewater authorities. The 1972 Admendments faced some additional difficulties in their implementation, among which were the impound- ment of construction grant funds by President Nixon and the. reluctance of municipalities to begin any projects during 39 the inflationary recession of 1974. However, a recent survey of water quality conducted by the EPA revealed that pollution indicators had significantly improved since 1972. Such findings were encouraging news for the proponents of effluent controls, although the results were not conclusive evidence of the success fo the program. By 1977 the funding allotments for construction grants were exhausted, and when the Congress confronted this new fiscal spending decision, much debate began to center on the relative merits of the entire 1972 law. The new legislation which emerged from this debate became known as the Clean Water Act of 1977. This law was labelled in the media as a ”compromise between environmental and industrial interests, with neither side gaining an overall advantage as a result of the new legislation." Public Law 95-217--The Clean Water Act of 1977* The passage of the Clean Water Act of 1977 was gen- erally a renewed commitment by the Congress for eventually eliminating water pollution. But the measure also ex- tended the deadlines for attaining desired treatment levels to give the regulated industries the necessary additional time to comply. The Clean Water Act (hereafter referred to as "the Act") authorized 24.5 billion dollars more to continue the construction grant program for the next five *Public Law 95-217 further amended the 1972 admendments in P.L. 92-500. 40 years. With specific reference to this report, the Act contained a number of new provisions on sludge management and the use of innovative and alternative** technologies for waste treatment. In emphasizing the recycling option, the Act prohibited the financing of grant programs unless the municipal applicant demonstrated why alternative treatment was not suitable. Other financial incentives in the Act for recycling included giving an edge of 15 per- cent in cost effectiveness to warranted innovations and a federal grant that would cover 85 percent (rather than the standard 75%) of the alternative's construction costs. As a result of the congressional efforts to promote recovery concepts for waste treatment in the Act, the issue of sludge management was accorded greater attention. Spe- cifically, the Act contained clauses on the following aspects of sludge disposal: Sludge Disposal Provisions Clean Water Act, P.L. 95-217 (Amends P.L. 92-500 of 1972) 1. Maintained the section of P.L. 92-500 that en- courages facilities provide for... "the ultimate disposal of sludge in a manner that will not result in environmental hazards.” (under section 201 (d) (4).) 2. Placed sludge disposal practices under the National Pollutant Discharge Elimination System (known as the NPDES permit program). In states which have approved NPDES programs, the appropriate ** I O O O The terms "Innovatlve and alternative" are defined as processes which provide for the reclaiming and reuse of water,..., and utilize recycling techniques, land treat- ment,..., for municipal waste..." Title II, Section 201 (g) (5) of P.L. 95-217. 41 state water pollution control agency was delegated primary enforcement responsibilities. Michigan's NPDES program is approved and the Department of Natural Resources (DNR) has the regulatory re- sponsibility. (Sludge placed on NPDES by section 405 (b) of P.L. 95-217.) Required the EPA to set toxic and pretreatment effluent standards for industries which utilize the services of publicly-owned treatment works (or POTW). The EPA regional administrator or the appropriate state agency can require the POTW operator to design a pretreatment program to control pollutants which may contaminate sewage sludge. (under sections 307 (b) (1) and 402 (b) (8)-) Required the EPA to set guidelines and criteria for sludge for various purposes. The regulations were to "... 1. identify uses:fixrsludge, including disposal; 2. specify factors to be taken into account in determining the measure and practices applicable to each such use or disposal (in- cluding publication of information on costs); 3. identify concentrations of pollutants which interfere with each use or disposal. The EPA Administration is authorized to revise any regulation issued under this subsection (under section 405 (d)). The sludge disposal option is to be locally determined, but the locality must comply with any guidelines which the EPA sets for the disposal strategy. Compliance is the responsibility of the owner or operator of the wastewater facility. (under Section 405 (e).) Construction grant funding would be provided for alternative and innovative processes of waste treatment which meet set criteria. Sludge land- spreading projects would be eligible for such support. (under Section 201 (j) and Section 201 (g) (5).) The EPA was required to submit a report to the Congress on the status of the "use of municipal secondary effluent and sludge for agricultural and other purposes that utilize the nutrient value of treated wastewater effluent." (under Section 516 (d).) On February 6, 1978, the EPA released a proposal on the sludge criteria requested by Section 405 (d) of the Clean Water Act.6 These guidelines were narrowed down to five basic areas of concern: 1. analyze the sludge for cadmium and other toxic substances; 2. assure that the sludge has been appropriately stabilized; 3. determine the appropriate application rates and assure that these rates are compiled with; 4. determine what monitoring is required and assure that it is performed; 5. develop any necessary contingency plans and assure that they are followed. The EPA proposal also restated that the responsibility for adherance to the above criteria under Section 405 (e) lies with the owner or operator of the publicly owned treatment works. The above sludge guidelines were also designed to jointly satisfy requirements of the Clean Water Act and the Resource Conservation and Recovery Act of 1976, also known as the RCRA of 1976. The RCRA will be examined next for the relevant clauses on sludge management. Resource Conservation and Recovery Act of 1976 (RCRA) Public Law 94-580 II: In amending the Solid Waste Disposal Act of 1965, the RCRA of 1976 expanded the authority of the federal and state governments to cope with the troublesome problems of garbage and sludge. Recognizing solid waste generation *The RCRA of 1976 amended the 1965 Solid Waste Disposal Act (P.L. 89-272), which had been strengthened by the Resource Recovery Act of 1970 (P.L. 91-512). 43 as an undesirable by-product of technological and economic growth, the Congress drafted the RCRA with the intent of providing technical and financial assistance in developing long-range plans for solid waste management. The RCRA also acknowledged that sludge and other pollution res- idues were occurring in greater quantities as a result of Water Pollution Control Act, Clean Air Act and accompanying environmental legislation (section 1002 (b) (3)). The sludge related provisions of RCRA included a formal classification of sludge as solid waste. Also sludge was defined in P.L. 94-580 as "any solid, semi- solid or liquid waste generated from a municipal, commercial, or industrial wastewater treatment plant,..." (Section 1004, Subsections 26A and 27). The RCRA established an Office of Solid Waste in the EPA and directed this office to develop criteria to ensure that solid waste disposal facilities" pose no reasonable probability of adverse effects on health or the environment..." (Section 4004 (a)). The EPA interpreted the term "disposal facility" to include land application of sludges for use as a soil conditioner and fertilizer. In response to the RCRA directive for establishing criteria, and in coordination with the requirements fo the Clean Water Act, the EPA proposed guidelines for the application of solid waste to land for the production of food chain crops. In the proposal of February 6, 1978, these criteria centered on the following aspects:8 (Part 257.3) 44 1. Set Cadmium levels allowable in solid wastes such as sludge, taking account of site soil conditions such as Cation Exchange Capacity and pH. 2. Concern over Pathogens in solid waste requires that the sludge be stabilized and food crops normally eaten raw should be delayed until at 18 months after application. 3. Application of solid wastes (such as sludge) contianing residues in excess of the tolerances established by the Federal Food, Drug, and Cos- metic Act. 4. Solid wastes (such as sludge) which are of concern due to their pathogen, toxic organic or heavy metal content must not be applied to a site where the waste may be directly ingested by animals raised for milk or by humans. The EPA proposal also contained more generalized criteria for protecting surface waters, groundwaters, public safety and environmentally sensitive areas. An important feature of these above criteria is that responsibility for compliance lies with the "solid waste disposal facility." Such a provision can be interpreted to mean that the private landowner in a landspreading program can be held accountable for proper adherance to solid waste disposal criteria. Recalling that the Clean Water Law of 1977 designated that the owner or operator of a wastewater plant be responsible for fulfilling regulatory requirements, one can theorize a legally- indicated joint obligation for compliance. However, the degree of joint "liability" between the two parties is not clear within the language of the federal laws. De- ciding the relative responsibilities is an institutional issue that is likely to be determined in the framework of 45 state and local administrative processes. The RCRA also set up a grant program of federal fun- ding, but limited the eligible projects to those which were part of a state plan for area-wide solid waste disposal. In addition, the project must promise to ad- vance the state of knowledge in waste management by either reducing environmental impacts achieving recovery of energy or resources, or recycling of useful materials. A specific provision of RCRA also instructed the EPA to undertake a comprehensive study and publish a report on sludge. The report was to cover at least the following topics:9 (Section 8002 (g)) 1. what type of solid waste is to be classified as sludge; 2. the effects of air and water pollution legis- lation on the creation of large volumes of sludge; 3. the amounts of sludge originating in each State and each industry producing sludge; 4. methods of disposal of sludge, including the cost, efficiency and effectiveness of such methods; 5. alternative methods for the use of sludge, in- cluding agricultural applications of sludge and energy recovery of sludge; and 6. methods to reclaim areas which have been used for the disposal of sludge or which have been damaged by sludge. To avoid any duplication in the completion of requested projects and regulations as listed above, the Congress required that the RCRA be properly integrated with related Acts such as the Water Pollution Control Act. RCRA also 46 added another institutional dimension to the attack on solid wastes by authorizing private citizens to sue violators of the solid waste law or to sue the EPA for failure to enforce it. Provisions on sludge recovery also brought on the involvement of two additional federal agencies, the Food and Drug Administration (FDA) and the Department of Agriculture (USDA). Government concerns over Cadmium and pesticide concentrations and their transferral up the food chain have traditionally been the administrative responsibilities of FDA and USDA. Extra authority on potentially harmful chemicals was also granted to by the EPA by the Toxic Substances Control Act of 1976, which is the next topic of discussion. Toxic Substances and Control Act of 1976 (TSCA) Public Law 94-469 The TSCA is a legislative action primarily aimed at preventing public exposure to any hazardous chemicals which could adversely affect health or the environment. The language of P.L. 94-469 is broad enough to be inter- preted in a manner that could place more restrictions on sludge utilization. Part of the TSCA is a testing program to be conducted on " ..... processing, use or disposal of a chemical substance or mixture or that any combination of such activities, may present an unreasonable risk of injury to health or the environment." (Section 4 (a) (1.A.) The results of such tests must indicate the absence of such risks. However, the toxic substances law is 47 tempered by a provision which states that:10 "If the Administrator of the EPA determines that a risk to health or the environment could be elim- inated or reduced by actions taken under the auth- orities contained in other Federal laws, the Admin- istrator shall use such authorities,... unless... it is in the public interest to protect against such risk by actions taken under this Act." (Section 9 (b)) As a result of the above subsection, the EPA released a statement in the solid waste disposal criteria of February 6, 1978, which reads as follows:11 "The EPA will continue to explore and reevaluate its authority under the Solid Waste Disposal Act, the Safe Drinking Water Act, the Toxic Substances Control Act in order to determine the best regulatory approach...to assure the adequate control of the disposal of wastes....” The effect on sludge management of the broad powers of the TSCA can be contrasted with the specific require- ments of the last three federal laws examined in this report. The Safe Drinking Water Act of 1974 Public Law 93-523 The main purpose of the SDWA of 1974 was to ensure that procedures were being followed to guarantee the safety of public water systems. The particular section of this water law that relates to sludge disposal is a request for information on storage practices such as pits, ponds and sewage lagoons. The EPA was instructed to begin a study on the impacts of surface storage im- poundments on underground water recharge areas. One pur- pose of the study was to analyze for any potential hazards 48 to public water supplies caused by sludge treatment tech- niques. The EPA was to coordinate the study to satisfy the requirements of other laws such as the Resource Conservation Act of 1977. Soil and Water Resources Conservation Act of 1977 Public Law 95-192 During 1977 the Congress was alerted to ”land quality issues" as being important in an environmental im- provement policy which had already focused on air and water quality. The main thrust of P.L. 95-192 was to create a continuing plan for improving and protecting soil-related resources for sustained use. This soil and water law contained a clause which authorized the Soil Conservation Service of the Department of Agriculture to conduct an investigation of sludge utilization as'a method "to improve soil tilth and fertility." (Section 6 (a) (5))12 Other investigations were also required, and the input of other agencies (such as EPA) was encouraged to promote coordination of information and projects. The Marine Protection, Research and Sanctuaries Act of 1972 P.L. 92-532, (MPRSA),Amended in 1977 By Public Law 95-153 In 1972, the interest in upgrading water quality generated by the Water Pollution Control Act gave impetus to the congressional attack on marine pollution problems. The Marine Protection Act was designed to set federal guidelines for dumping of materials into the oceans. The law also called for the development of alternative 49 technologies which would eventually supersede the need for ocean dumping. The 1977 admendment to MPRSA set a deadline of December 31, 1981 after which ocean dumping 'of municipal sludges would be prohibited. The largest cities affected by the ban were New York, Philadelphia and Camden. The wastewater authorities of these ocean dumping municipalities have now been literally forced to examine alternatives, such as large sludge composting facilities. Such a facility would produce significant quantities of a sludge soil-conditioner and fertilizer substitute. SUMMARY OF THE FEDERAL REGULATIONS ON SLUDGE MANAGEMENT The federal acts examined in this report indicate a rising national interest in controlling the hazards of sludge as well as attempting to exploit the "recycling benefits." Although the directives and authorities were created With good intentions by the Congress, the job of coordinating a sludge management policy is complicated by the regulations set by six different laws. The Environmental ' Protection Agency has been delegated most of the respon- sibility for decisionmaking and analysis on sludge prob- lems. The EPA needs to organize the required studies and reports on sludge use to prevent any unplanned over- laps. In like manner, the influence of the USDA, FDA, and other agencies must be properly integrated to develop an acceptable policy. The input of a State agency, such as Michigan's Department of Natural Resources is also 50 extremely important for properly implementing the desired sludge practices. Sludge Disposal Policy in Michigan State Public Acts and Administrative Agencies Which Are Concerned with Sludge Management At the state government level, there are also a variety of legal structures which pertain to sludge and wastewaters. State regulations have been steadily changing in recent years due to the flood of federal laws which have requested states to meet new guidelines. In Michigan, the administrative duties of wastewater control have primarily been the responsibility of the Wastewater Section of the State's Department of Natural Resources (hereafter referred .toas DNR). The DNR acts under the authority granted by both state and federal statutes. In most cases, the DNR performs in the role which would otherwise be occupied by the Federal Environmental Protection Agency. Whereas the DNR acts in an administrative capacity, the policy formulation function is the work of the Water Resourc-s Commission (WRC) of Michigan. The WHO was established in Public Act 245 of 1929 (as amended up to 1973), and was to consist of seven permanent members.13 The commission is empowered to initiate state permit programs and prom- ulgate regulations to fulfill its broad purpose of "pro- tecting and conserving the water resources of the state, and to have control over the pollution of any waters of the state, and the Great Lakes.” The formal interrelationships 51 among government agencies at the state, county and municipal levels in wastewater matters are designated by a number of state laws in Michigan. A brief listing of these relevant laws follows: 14 PUBLIC ACTS OF MICHIGAN 1) 2) 3) 4) 5) Public Act 98 of 1913, as amended - Established role of Michigan Department of Public Health in sewage disposal. - Administrative powers originally delegated to Public Health Commissioner, then trans- ferred responsibility to the Wastewater division of DNR in 1973. Public Act 245 of 1929, as amended - Created Water Resources Commission and designated the conservation and pollution control duties of that Commission - Directed the Commission to establish a state permit system for Water Pollutant Discharges. - Gave the Commission the right to act in a court of law in the name of the people of Michigan for violations of water-protection laws. Public Act 342 of 1939 - Known as a County Public Improvement Act - Authorizes counties "to establish and provide connecting water, sewer and/or sewage disposal improvements within or between cities, villages and townships...or any other duly authorized combinations thereof." Public Act 185 of 1957 - Authorized the establishment of a Department and Board of Public Works in counties - Granted special powers and duties to county public works, such as special assessments and condemnation; and contracting rights. Public Act 233 of 1955 - Gave municipalities the official right to acquire, own and operate sewage disposal and water supply systems - Authorized municipalities to contract with other governmental units for the system's operation 52 - Allowed municipalities to issue bonds to finance activities - An area water authority can be established by two or more municipalities. 6) Public Act 329 of 1966, as amended - The purpose of this Act was to prevent the discharge of untreated or inadequately treated sewage or other liquid wastes into state waters. - Established a fund for state grants to assist in the financing of projects designed to accomplish reduced waste discharge. 7) Public Act 641 of 1978 - Known as the Solid Waste Management Act - Defined municipal sewage sludge as a solid waste - Required that transport equipment for sludges be watertight and maintained properly - Placed sludges under county-wide solid waste management plans. 8) Public Act 64 of 1979 - Known as the Hazardous Waste Management Act - Hazardous waste does not include solid or dissolved material in domestic sewage discharge - Some sludges might be classified as hazardous, depending upon criteria established under the Act. The DNR participates in the execution of various disposal-related laws, and in the process of completing its tasks, the DNR issues its own regulations and policies. With reference to the uses of wastewater sludge, the state laws have been interpreted by the Wastewater Section of DNR in the following manner:15 1) The DNR is to encourage sludge utilization prac- tices wherever they are practicable. Landspreading operations are recognized as having the potential to yield benefits of amending the soil, while lowering environmental, public health and energy costs. 53 2) The DNR administers sludge disposal permits under the National Pollutant Discharge Elimination System of Public Law 92-500, as amended in 1977 by the Clean Water Act. There is also a separate state permit system, which is designed to protect groundwaters. Sludge utilization and other agricultural management practices are employed. 3) The DNR obligates itself to providing informational, educational, and coordinational services to en- sure the understanding and compliance with reg- ulatory standards. In addition, DNR is to act as an agency for monitoring wastewater disposal throughout the state. 4) The DNR has issued a policy stance on the partici- pating parties' responsibilities in sludge use programs. The contention of DNR is that the municipality bears primary responsibility in meeting guidelines and ensuring the successful operation of a sludge disposal system, and that the responsibility for any failures cannot be delegated to another private party. (Such as a participating farmer or a sludge hauler.) In the last opinion issued above, the DNR has adopted a policy similar to the one established in the Clean Water Act of 1977, by placing the responsibility of regulatory compliance with the treatment plant operator. Many of the standards that DNR establishes, as well as the pro- gram guideance services that it provides, are of a technical nature. Knowledge of proper application rates and equipment, sludge nutrient content and heavy metals tolerance is important to the success of the sludge oper- ation, and DNR has been working to provide such information. The DNR employs soil scientists and civil engineers who use their expertise in confronting the municipal sludge problem at the state level. One of the jobs of Basin Engineers employed by the State is to monitor the sewage disposal practices, and to act as an information source for officials in the county and municipal subdivisions of government. Regulation of Sludge Utilization Practices at the County and Municipal Level of Government in Michigan Public Act 342 of 1939 (as amended in 1959), authorizes counties to provide for sewage disposal systems. Although many wastewater treatment plants are operated by smaller townships, there are also some county-wide operations. In Michigan, the Muskegon County Wastewater System and the Monroe County Drain Commission are examples of county- 1evel involvement. The Muskegon Project has attracted much attention to the recycling concept and the system operates on publicly-owned farm and forest land. The Monroe County Drain Commission (MCDC) has been dealing with the sewage disposal problem on a less grand scale, but has been directly involved in the encouragement of utilizing sludge on private farmlands.16 In recognizing the cost-savings and potential soil benefits of sludge util— ization as compared to other disposal options, the MCDC has been an early initiator of practicing the recovery concept. Under the contracting rights granted by Public Act 342, the MCDC has entered into a number of written agreements with farmers, specifying the conditions under which sludges would be spread onto farmer's cropland. The content of such written contracts is characterized by a variety of stipulations, among which are guidelines issued by the wastewater authorities at the federal, state 55 and local level. The actual form in which these legal requirements appear on a sludge landspreading contract is not only determined by the participating farmer and plant operator, but also by other interested parties. A coor- dinated sludge program might include a number of inter- relationships. For instance, the County Cooperative Extension Office may make initial contacts with potentially interested farmers. Extension agents also aid in organ- izing workshops for explaining the relative benefits and costs of landspreading sludges. Others who may be involved include soil science and agronomy scientists at Michigan State University, who recommend practices and conduct biochemical sludge analyses. Consulting engineering services may also be called upon to give advice and perform technical tests. Furthermore, if the program is to meet state approval, the participants should confer with DNR and its representatives (such as Basin Engineers). Regulations at the Municipal Level-Local Ordinances and Sludge Utilization Agreements A written contract for sludge application is generally recognized as a formal commitment between the farmer and the municipality. However, in real world circumstances, there is some reluctance by both parties to formalize a landspreading agreement, especially at the beginning of a new program. The reluctance stems from uncertainty about the interpretation of local laws, the reaction of area citizens, and the actual benefits to be obtained. The 56 participating farmer does not desire to become partially liable under a written contract, if he believes the sludge program may be subject to complaints which eventually lead to court action under nuisance and/or zoning ordinances. Adverse opinions on landspreading can originate with neighbors' concern over odors, pathogens, runoff and ground- water contamination which might result from use of improper practices. So until the viability of a sludge project can be demonstrated, the participants often choose to proceed with caution. Early efforts to use private farmlands are on a tentative basis, under verbal or handshake agreements, and are designed to maintain a ”low profile." In the surveys conducted for this research, participating farmers and operators commented on the need for "some shake down time" before entering any formal commitments. Such a loose agreement allows for maximum flexibility to meet changing conditions, but also involves a greater chance for slack compliance with technical standards and could lead to more undesirable consequences. The Contractual Agreement as an Institutional Arrangement As referred to in this research, a contract is a written or oral agreement which can be thought of as mutually desirable exchange of use-rights between two parties. In general, it can be assumed that both participants expect to benefit from the freely entered-upon transaction. In addition, the two parties agree to respect the con- ditions (or restrictions) placed upon each other within the 57 contract. But the essence of the agreement is not perceived as coercive by either party, but rather as an activity which furthers each party's individual interests. An oral agreement which is clearly understood and respected by both parties can be successful in promoting the desired transaction, and has the advantage of a high degree of flexibility. The disadvantages of oral con- tracts include the absence of a legally-binding document and the misinterpretation of contract conditions. In this study, the majority of the surveyed Michigan mun- icipalities engaged in private farmland application were operating on verbal contracts. Such a preference for the loosely-structured "handshake” agreements may be indicative of the degree of confidence that municipalities currently have for utilization as a viable and long-run sludge disposal option. Participants may desire a temporary arrangement which has low exit costs, as opposed to a more permanent written commitment which may carry a high costs of legal liability under circumstances of a program failure. Despite the trend towards loose verbal agreements, some Michigan communities have approached sludge utilization in a formal manner. Written contracts have a slightly different set of characteristics which may be preferred by municipalities who are convinced a well-planned sludge application program is workable and desirable. The written agreement contains the legally-binding rules under 58 which the program will operate. Formulation of the specific provisions to be placed on the document also forces the participants to carefully consider the implications of the contract, and thereby eliminates ambiguities. Examples of written sludge application agreements from Monroe County, Michigan and Bad Axe, Michigan both have similar structures and content, but some clauses are naturally site specific. The social dynamics which occur between the partici- pants and the ”third parties” have an impact on the division of responsibilities that appear on the written contract.17 For instance, it is particularly interesting to trace the development of the landspreading arrangements of Mon- roe and Bad Axe. In Monroe County, the officials of the Drain Commission have been the primary initiators of the program and have made special efforts to attract potential farmers. A typical Monroe County contract stipulates that the Drain Commission is responsible for a variety of technical and administrative services and also carries an insurance policy as evidence of the county's liability in case of damages. But the manner in which the Bad Axe sludge application project has evolved differs, and the resulting contract conditions reflect that difference. In Bad Axe, an informed farmer has been the primary in- stigator in starting sludge use on his land. A number of extra arrangements had to be made before the program could proceed, because the farmer lived in Colfax township, an 59 adjacent but politically-separate entity from the city of Bad Axe. In cooperation with the farmer, the wastewater treatment operator convinced the City of Bad Axe to employ an engineering consulting service to investigate the feasibility of using the farmer's land for sludge application. The report of this firm was then submitted to Colfax Township, which in turn passed a resolution to allow the transport and application of sludges within its boundaries. The actual contract between the city of Bad Axe and the farmer contained many of the same technical provisions which appeared in the Monroe agreements. But an important difference was that the farmer was "to assume liability if damage or crop loss occurred." Such a stipulation seems "unfair" to the farmer, but the City still must perform sludge testing and inform the farmer as to the potential hazards of the material. Also, in this specific case, the farmer owns the transport equipment, is being paid transport costs by the city, and is a knowledgeable person. It can be speculated that since the farmer "forced the issue, and expressed a fairly high interest in obtaining the sludge, that he was willing to take some extra risks. An example of a sample contract for sludge application is in Appendix A. The basic characteristics of sludge utilization con- tracts can be summarized in seven general areas of agreement: 6O 1) Provision and responsibility for technical services a) Testing and monitoring of soils, sludges, groundwaters, and surface waters b) setting of sludge application rates and runoff protection requirements c) deciding on the proper transportation and application equipment d) biochemical and metals analysis of plant leaf and fruit samples to monitor uptake of crops on sludge amended soils. 2) Liabilities of each party established in case of damages to crops and/or surrounding environment as a result of faulty sludge practices. 3) Financial arrangements and source of funds a) Agreement of parties on who purchases transportation/application equipment and or the operating expenses (labor, gasoline, maintenance, etc.) b) agreement on who purchases liability insurance 0) farmer receives any increased revenues which might result from sludge amended soils. 4) Agreement on third party influences a) Involvement of the following organizations and agencies: 1) Michgian's Department of Natural Resources 2) Private Consulting Firms 3) Future landowners through tenant leasing and conditions for sale of land which has been utilized for sludge application. 5) Administrative Responsibilities of the Municipality a) Record keeping of amounts and frequency of application b) Agreeing upon mutually acceptable times for application 6) Sets the time of duration of the sludge program a) the number of years that contract is binding. 7) Establishes the conditions for exiting or term- inating the contract. The major advantage of having a written document as opposed to an oral agreement appears to be in the clarity 61 of the contract stipulations. An explicit statement of each party's responsibilities can aid in creating a greater incentive to fulfill the articles of agreement. If each party is more certain of the other's realized intent to meet a specified set of obligations, then each recognizes the development of a mutually-beneficial trans- action. Formalized contracts are also usually more acceptable at a public-opinion level, since the document's legally binding nature is believed to motivate the participants to take actions to reduce the probability of damages by negligence. Favorable impressions by the public are an important aspect of sludge management. The reaction of neighbors and local citizens is often modified by their perception of the sludge program's organization and legit- amacy. Because the written contract is enforceable, it is an accepted institution which guides the behavior of the participants. Sludge Utilization and its Controversial Issues: The Need for an Acceptable Sludge Disposal Solution If the media are a reflection of public opinion, then there has recently been a rising distrust of waste disposal practices of both private and public facilities. Especially in Michigan, in the aftermath of the PBB incident, the political setting for developing sludge utilization programs is particularly sensitive. It is important to recognize that an improperly 62 controlled sludge project has the potential for producing some adverse environmental and health effects. Specifically, sludge may contain dangerous pathogens and cumulatively harmful concentrations of metals. If the soil conditions are not sufficient to absorb and filter the sludge, there may be a potential for runoff problems or groundwater contamination with nitrates. Difficulties and accidents can also occur in the movement of sludges from the treatment plant onto the farmer's land. Odors of inadequately treated sludges can be particularly offensive, and cause a citizen reaction which questions the safety of the sludge program (and perhaps rightfully so). To answer these concerns, the participants need to demonstrate that sludge recycling is a workable concept and that the proper precautions are taken to ensure a successful and damage-free program. In addition, the local people need to be informed of the constraints under which the municipal treatment plant must work. By con- straints are meant the government regulations, the technical requirements, the feasible disposal options and the financial budget allocated for this purpose. The most important elements of a sludge disposal strategy need to be identified, and the tradeoffs between the various options should be clear enough to make a relative value judgement. Evaluative criteria and rules for decision are necessary if a specific sludge management program is to be chosen. If farmland application is taken to be the optimal 63 choice under these criteria and decision rule, then additional action is necessary to implement the utilization option. For instance, when establishing a private farmland sludge program, the municipality needs to coordinate both the technical and institutional arrangements. Under such situations when constraints, alternatives, value-tradeoffs and decision-making are being considered, a role develops for an economic analysis to specify the distributive and efficiency impacts of the available options. Economic Aspects of Sludge Utilization To begin an economic evaluation of sludge utilization, it is useful to identify the involved participants, the inputs to the project and the desired outputs. For the purposes of analysis, the private farmland application of sludges can be modelled as a contractual arrangement between two primary parties (farmer and treatment plant operator). But it can also be viewed as an activity which both impacts on and is influenced by third parties. The various economic interdependencies between these agents are categorized under the headings of costs and benefits. The costs of sludge utilization are more readily measured and are classified as follows: 1) Implementation Costs. a) Transportation and Application Activities 1) Equipment Purchase and Maintenance 2) Labor Time 3) Energy Requirements 2) 3) 4) b) 64 4) Licensing and Liability 5) Additional treatment costs 6) Management 7) Costs of Contingency Arrangements Administrative 1) Personnel management 2) Public Relations 3) Monitoring, testing and record keeping Opportunity Costs a) b) The concept of opportunity cost applies to both the farmer and the municipality. For the farmer, there may be better nutrient sources in the farm of animal manure or commercial fertilizer. The treatment plant must consider other disposal options such as landfills, incineration or use of public lands. If sludge utilization is not the least cost alternative, then an effective demand for recycling would have to be established to economically justify its choice. Institutional and Social Costs a) b) C) d) Legislation and regulation restrict the number of disposal alternatives that are available. Such constraints can be thought of as an18 institutionally chosen opportunity cost. Local citizen reaction can prevent the imple- mentation of sludge programs. Uncertainty over potential risks and the lack of information can significantly alter public opinion. The possibility of the primary participants having to bear court costs of liability suits and nuisance claims. The costs of obtaining and organizing in- formation. COsts of Potential Environmental or Health Risks a) The extra costs of safeguarding sludge use to prevent pathogenic threats, heavy metal buildups or nutrient overloads. b) 65 Costs of management and administration. This includes program supervision, public relations and contracting. In a similar manner, the potential benefits of utilizing sludges can be categorized: 1) 2) 3) Economic Benefits of Sludge Use Assoicated with Improved Crop Production a) Increased crop yields can result from the technical capacity of sludge as a soil amendment and fertilizer. The economic bene- fit is theoretically the value of the extra amount of crop output produced by the last unit of sludge applied that is, the marginal value product. The Value of Sludge Management as Pollution Avoided: Joint Impacts of Improved Water Quality Resource Recovery a) b) o) The political process has declared that the benefits of avoiding water pollution exceed the costs. The public sector has also encouraged land utilization of sludges whenever it is feasible and acceptable. "Clean" Water is a joint-impact good since once it is produced it can be used by more than one person without appreciably decreasing its value. An example would be any joint recreational, ecological and aesthetic opportunties made available by removing pollution from a stream. The real benefits of improved water quality, which may differ from the politically- intended benefits, need to be adequately measured. To determine whether a pollution control program makes a difference, tests should be designed to eliminate the doubts of causality between the law's intent and the actual abatement that occurs. Cost Savings a) Under the economic conditons of full em- ployment and effective demand, the extra costs avoided by not pursuing another more expensive alternative may be recognized as a cost-savings or benefit. 66 Three basic groups of people are impacted by the costs and benefits listed above. These are the farmer, the municipality and the ”general public." The latter group is included in terms of the downstream effects attributable to improved waste treatment. The distribution of the incomes and outflows which result from implementation of new waste controls and sludge programs is a subject for analysis. The farmer may receive net benefits from utilizing sludges, but the program's profitability depends largely on the crop and soil conditions and also the con- tractual arrangements. In addition, the farmer must evaluate the opportunity costs of using other nutrient sources such as animal manure that might be more economically desirable. Sludge use can increase crop yields for the farmer, but these gains might be offset by expenses for equipment, fuel and labor time. The second affected group, the municipality, may bear a greater part of the cost burden in a sludge utilization plan. From an economic point of View, it is advantageous for the municipality to select the least expensive mode of disposal. Farmland application is not necessarily the lowest cost choice, and a municipality might be better off placing sludge in a sanitary landfill. But again, the contractual arrange- ments may be a deciding factor in determining cost bearing. Another consideration is that certain utilization plans may be eligible for federal funding, and the municipality may be able to minimize its own costs by apportioning some of the expenses to the "general public.” 67 This third group is supposed to benefit from better water quality which results from decreasing wastewater pollution (and increasing sludge production). The "general public" includes people who are option demanders, clean water user, etc. who derive utility (or avoid costs) associated with less pollution. Some of the costs and benefits accruing to the above groups are difficult, if not impossible to measure. But the more readily identified costs usually are paid by the municipality. In a utilization plan, a measureable and important expense is for the transport of sludges. The distance between the treatment plant and the farm accepting sludge has a dominant impact on labor fuel and equipment needs. For instance, a longer transport distance may require a higher capital investment in vehicles and machinery. Application and hauling equipment must generally meet the following technical standards: 1) travel the required distances 2) carry the types of sludges being produced (either liquid or filter cake) and apply sludges at con- trolled rates 3) prevent spillage and/or other accidents 4) prevent soil compaction on farmer's land* The experience in Michigan communities with transport and application costs for sludge utilization varies *The Soil Compaciton Problem - This refers to when the wheels of a heavy vehicle can compress the soil structure. Newer tires have been designed to distribute the vehicle's' weight over a greater surface area. 68 considerably. In some cases municipalities have invested in new sophisticated vehicles, while others have reconvertted dump trucks and oil tankers to suit their specific pur- poses. Capital expenditures on equipment ranged from as low as $1,000 and up to $37,000. But insome instances, the farmers have purchased the necessary vehicles themselves, and the municipal treatment plant has then paid a transport price to the farmer, usually measured in dollars per thousand gallons of sludge hauled. In contrast, one community owns and operates a transporter/applicator known as ”Big Wheels," and the wastewater facility charges the farmer a per mile moving and spreading cost. Finally, some municipalities own the necessary equipment and spread sludges onto the farmer's land at no pecuniary charge to the farmer. In a non-payment situation, the farmer simply must agree to the application site, and may be asked to disk in (incorporate) the sludges into the soil after the sludges have been spread. Another municipal cost of farmland application programs is the provision of storage capacity or "contingency arrangements." The treatment plant may need a "sludge holding capability” when scheduling of spreading times becomes a cumbersome problem. Opportunities for sludge spreading are reduced by adverse weather conditions and the seasonal availability of uncultivated crop sites. For instance, the winter and crop-growing seasons can limit sludge application to the early Spring and late Fall in northern 69 areas similar to Michigan. But sludges are being continuously produced at the treatment plant throughout the year. When open lands are only available at certain times, the municipality may have to confront storage problems and higher costs. Liquid sludges are troublesome to store since their volume usually requires the construction of retention ponds, storage basins, lagoons or large holding tanks. If the treatment plant is equipped with a vacuum filter, or centrifuge devices or drying beds, the volume of sludges can be considerably reduced. When drying pro- cesses are employed, storage problems can be diminished, but sometimes at higher energy costs. In addition to the above considerations are the lia- bility insurance costs to protect the participants in case a mishap does occur. There are also outlays for labor time (e.g., vehicle operators), management time and skills, testing and monitoring of sludges and soils, and groundwater and surface water analyses. In this perspective, sludge utilization appears to be an expensive option. But despite these problems, more municipalities are instituting "back to the land” programs because they are less costly than other alternatives. lAlthough some of the costs of utilization are readily identifiable, the benefit measures have been vague or difficult to validate. The agronomic value of sludges to farmers might be recognized as a resultant increase in net farm income. But the problem of analyzing the separate 70 contribution of sludge in producing higher crop yields (and hopefully higher income) is the establishment of any cause and effect relationship over repeated trials. The surveys conducted for this report indicated that little or no quantitative evidence was available in Michigan, although farmers did perceive visual differences in crop quality and crop yields on sludge amended soils. The surveyed farmers who generally noticed the most positive plant growth effects were those who applied sludges to organically deficient soils. One surveyed Michigan farmer performed a rough "with and without” experiment on adjacent fields of corn, and recorded an average increase of thirty bushels per acre on the sludge amended plot. Other inter- viewed farmers noted little or no change in crop response, but these farmers remained in sludge programs because of soil tests and personal judgements of sludge as an input which promotes favorable soil conditions for crop growth. Such data can not be generalized, but when coupled with the results of soil science research on sludge agronomic benefits, there is sufficient evidence to encourage further investigation and trials. More information will become available as programs continue to progress and as incentives develop to maintain better records. Troublesome problems are also encountered in measuring the value of improved water quality and in establishing cause and effect between effluent treatment and receiving waterway improvement. Current indicators of the benefits 71 of water pollution control include technical characteristics such as dissolved oxygen content, newly created recreational opportunities and revived aesthetic appeal. However, it is beyond the scope of this thesis to appropriately address these measurement and causality issues in a thorough manner. Although evidence of a water quality trend was not solicited in the surveys, interviewed waste treatment operators said that the local waters appeared to have improved over the last five years. The operators referred to the better visual appearance of the rivers as well as to the renewed community interest in beginning stocking programs for game-fish. The beneficial value of a sludge utilization program to a municipality might also be measured as its cost efficiency. The economic welfare of treatment plant users is enhanced if their sewage fees are minimized or reduced by a farmland application solution to the sludge problem. (Such a criterion would be a relative one, measured against all other available and acceptable alternatives). When agricultural lands are within a fifteen mile radius of a treatment plant, the transport costs are relatively low, and sludge utilization should be an option that receives consideration. The results of the survey conducted for this thesis were not intended to provide comparative cost information. But the questionaires do have data that is useful for designing an outline of the essential components that would. comprise a well managed "back to the land" program. Some Characteristics of a Well-Managed Sludge Utilization Program for Private Farmlands Recalling the analytical framework from the second chapter, it is possible to design a guide for examining the feasibility of a sludge application project. A mun- icipality considering sludge utilization might examine this option in the manner outlined below. An Outline for Evaluating a Private Farmland Application Program as an Option for Managing Municipal Sludges A. Specify the Objectives of the Program 1) Goals for the municipality a) b) 0) Minimize the budgetary costs of disposal of sludges Avoid environmental risks in accordance with legal requirements and local citizen expectations and health protection Establish a long term strategy that will assure proper disposal in the future, as well as the present 2) Goals for the Participating Farmer a) b) Enhance the potential for increased crop production and higher net farm income by utilizing the soil admendment and nutrient qual- ities of sludges Decrease fertilizer costs by using less costly sludges as a partial substitute input, and also have a positive effect on income Investigate the Technical Feasibility of Sludge Utilization 1) Determine the type of stabilization procedures necessary to apply sludges to land a) b) Conventional stabilization facilities at treatment plants include: 1) Aerobic Digestion 2) Anaerobic Digestion 3) Chemical Treatment 4) Heat Stabilization 5) Heat Drying Determine whether additional treatment may be required 1) Contact Michigan DNR or MSU's Department of Soil Science 2) 3) 4) 73 Analyze the nutrient value of sludges and the potential hazardous content of sludges a) b) C) Employ testing services of private consulting firm, MSU Department of Crop and Soil Sciences or local chemcial laboratory to analyze sludge samples Use test results to estimate the nitrogen- phosphorus-potassium value of the sludges and to set constraints for heavy metal content and pathogen threats. Determine compatibility of sludges with local soils, consult with the appropriate scientists when necessary Evaluate the type of farmlands which are within a fairly clsoe proximity of the treatment plant a) b) C) d) Gain knowledge of the soil characteristics and cropping practices; set sludge application rates accordingly Determine runoff and infiltration problems which may be peculiar to the application sites- Investigate transportation routes and application sites for distance from higher-density pop- ulation areas Evaluate available lands in a long-term View Determine the necessity for contingency or standby plans a) b) Examine the seasonal nature of open farmlands for application 1) Weather conditions 2) Cultivation and crop growing seasons 3) The frequency and timeliness of application may be a limiting factor Estimate the storage capacity for sludges available at the treatment plant 1) Need to answer question, "Is the sludge holding capability sufficient to contain the sludge accumulation in between applica- tions?” 2) Design and capacity of sludge stoarge facilities should control against environ- mental damages (such as seepage to groundwaters) 3) Examples of storage include: a) Lagoons b) Retention Ponds c) Holding Tanks d) Compost Piles e) Sludge Drying Beds 4) 5) 74 Need to gain a contractual agreement with participating farmers a) b) Verbal or ”handshake" contracts have greatest flexibility and seem to be advantageous for the initial short-term trial period of starting a sludge utilization program Written contracts are preferable for a number of reasons 1) Still have considerable flexibility but also indicate both parties willingness to meet Specific obligations of an agreement 2) Clarity of a written contract tends to eliminate ambiguities over the distribution of responsibilities between parties 3) Public acceptance is usually greater for a formalized program Management of a Sludge Utilization Program a) b) Monitoring technical aspects by regularly performing: 1) Tests of soil samples, sludge samples, groundwaters and surface water runoff 2) Leaf and seed, grain fruit analyses of plants grown on sludge amended soils 3) Maintenance of transport and application equipment to ensure safety and proper spreading rates. Administration 1) Make sure that contract stipulations are fulfilled on past and current agreements with farmers 2) Set up new agreements with other farmers as contracts with current landowners expire 3) Decisionmaking on all other aspects of the program, such as third party influences, legal constraints, labor time, etc. 4) Public relations - education and information D. Categorize the Financial Costs of a Sludge Program Transportation and Applications Costs 1) 2) a) b) o) d) e) f) g) h) Equipment capital costs Labor time (for example, vehicle operators) Energy expenditures Licensing permits Costs of any additional treatment processes Any financial costs of contracting with farmers Repairs and maintenance Management Contingency costs a) b) Storage facility investments Liability insurance 75 5) Obtain or utilize transport and application equip- ment necessary to move sludges from treatment plant a) Vehicles should be designed to: 1) Travel the required distance 2) Carry the type of sludges being produced (either liquid or filter cake) and apply sludges at controlled rates 3) Prevent spillage and/or other accidents 4) Prevent soil compaction on the farmer's land b) Examples of liquid sludge transport and app- lication equipment include 1) Converted oil tankers with applicator attachments 2) Liquid manure spreaders 3) Big wheels transport/applicator 4) Soil injection vehicles 5) Pipeline irrigations (highly capital and intensive; costly) c) Examples of filter cake spreaders l) Converted dump trucks 2) "Dry" manure spreader or compost Spreader C. What Arrangements are Necessary to Make A Sludge Utilization Program Workable? 1) Contact farmers who would be responsive to sludge use idea a) Employ services of county extension agent for initial contacts and also educational/informational workshops 2) Investigate legal constraints a) Federal legislation and enforcement policies b) State regulations 0) Local zoning laws and nuisance ordiances d) Licensing and liability requirements e) Contact state DNR and local officials for interpretations of laws 3) Communication with any or all of the following people may be necessary a) Wastewater authorities at county-level b) Participating farmers c) Neighbors and local citizens in participating farmers' area d) Local governments e) State agencies (DNR in Michigan) f) State Land-Grant University g) Federal agencies h) Private consulting firms and sludge hauling firms 76 3) Costs of technical guidelines a) Testing and monitoring costs b) Records keeping c) Management costs of preventing damages due to technical negligence E. Investigate Financial Sources for Funding the Costs of Sludge Utilization 1) For municipalities in the process of upgrading treatment facilities, up to seventy-five percent of capital costs may be covered by the federal construction grant funding program of the Water Pollution Control Act of 1972 (P.L. 92-500) and its successor, the Clean Water Act of 1977 (P.L. 95-217). a) Federal financing of up to 85% of construction costs is available to municipalities who dem- onstrate the use of innovative technologies, which have been interpreted to include sludge recycling schemes b) The construction grant program is administered by the Federal Environmental Protection Agency's office of water program operations c) Facility costs of sludge stabilization and storage necessary for land treatment programs have been funded (up to 75%) by construction grants 2) Municipal bond issues may be another debt financing alternative 3) Costs of sludge disposal are also reflected in treatment plant user fees (that is the amount of local citizen cost bearing). 4) Contract arrangements with local farmers may in- clude opportunities for joint cost sharing of transport and application costs a) Farmer can have an incentive to employ or modify his own equipment for moving and spreading sludges, due to the value of a potential productive input to cropping activities b) Joint cost sharing occurs since utilization satisfies the dual objectives of safe disposal and enhanced crop production. Private farmland application of municipal sludges is a program that can be summarized in terms of three basic characteristics: technical feasibility, institutional arrangements and economic desirability. First, research and experience have established a technology for implementing 77 the utilization concept. But sludge recycling is a suff- iciently complex activity that it requires the management skills of a well-informed decision-maker. (Usually the greatest weight of responsibility falls upon the waste- water treatment plant operator). Secondly, the institutional arrangements are comprised of interactions among the primary participants and the interested third parties. All of the involved groups play a role, either collectively or individually, in determining the legal, social and con- tractual constraints on a sludge program. Lastly, the costs of sludge utilization on private farmlands need to be compared to the expenses of alternative disposal options, while the questions of cost sharing and budget allocations are simultaneously resolved. The measure of the potential success of sludge utilization lies in the ability of the participants to meet the dis- posal and agronomic goals. The three basic program char- acteristics just mentioned above constitute the general structure within which a farmland sludge operation develops, and therefore influence whether a "real difference" is made in pollution control, resource recovery and crop producition. This thesis has examined some of the institu- tional and financial aspects of sludge utilization. The focus now proceeds to a more in depth discussion of the technical characteristics of a "back to the land" program. ENDNOTES 1"Solid Waste Bill," Congressional Quarterly Almanac, XXXII (Washington: Congressional Quarterly Inc., 1976), p. 199. 2"In Search of A National Sludge Management Policy,” Sludge Magazine, 1, (Jan-Feb. 1978), p. 13. 3 Ibid., p. 13. 4The information on federal laws pertaining to sludge disposal is from the Environment Reporter (Washington: Bureau of National Affairs, Inc., 1979), p. 71:5101-5301. 5These sections of P.L. 95-217 were obtained from Environment Reporter, (Washington: Bureau of National Affairs, Inc., 1979), pp. 71:5114, 5160, 5168. 6"Solid Waste Disposal Facilities - Proposed Criteria," The Federal Register, 43, (Feb. 6, 1978), pp. 4941-4955. 7 Ibid., p. 4943. 8Ibid., p. 4943. 9Resource Conservation and Recovery Act of 1976, Environment Reporter (Washington: Bureau of National Affairs, Inc., 1979), pp. 71:3113-14. 10Toxic Substances Control Act, Environment Reporter (Washington: Bureau of National Affairs, Inc., 1979), p. 71:8510. 11”Solid Waste Disposal Facilities - Proposed Criteria,” p. 4945. 12Soil and Water Resources Conservation Act of 1977, Environment Reporter (Washington: Bureau of National Affairs, Inc., 1979), p. 71:8402. 13Members shall consist of: Director of DNR, Director of the Department of Public Health, Director of the Depart- ment of State Highways, Director of the Department of Ag- riculture, one representative of industrial management, one representative of municipalities, and one representative of conservation interests. This information is from Public Act 245 of 1929, as amended,Environment Reporter (Washington: Bureau of National Affairs, Inc., 1979), p. 811:0101. 78 79 14Lee A. Christensen, Douglas G. Lewis, Larry W. Libby and Larry J. Connor, Land Treatment of Municipal Wastewater (East Lansing: Center for Rural Manpower and Public Affairs, 1976), No. 41, pp. 18-27. 15Richard T. Sprague, "Municipal Wastewater Sludge Application to Land: Pertinent Legislation and Regulations," (Lansing: Wastewater Division of Department of Natural Resources, 1978). 16Paul J. Fleming, "A Program for Land Disposal of Stabilized Wastewater Treatment Sludges," The Monroe County Drain Commission, 1975, pp. 1-4. 17Most of the information on these written contracts is obtained from personal communication, documents and the surveys. 18 1978. Discussion notes from A. Allan Schmid, AEC 811, Spring 80 CHAPTER IV TECHNICAL ASPECTS OF SLUDGE UTILIZATION Introduction to the Agronomic Value of Sludge Use The benefits of utilizing sewage wastes as a soil addition have been recognized since the early stages of civilization. Even from a more current perspective, soil scientists have been able to identify the potential of sludge as a soil admendment. An important reason for the resurgence of interest in the agronomic value of sewage (and of sludge in particular) is the renewed concern for recycling and conservation practices. But when the situation of most municipal wastewater treatment plants is examined, the primary reason for considering farmland application of sewage residuals stems from the need for acceptable dis- posal techniques. The organic and inorganic contents of municipal wastewaters can be removed by various treatments at a sewage facility. The water pollutants removed from sewage inflows are further concentrated to form the sludge material. The composition of sludges is variable, even for separate samples obtained from the same treatment plant. However, some general charaCteristics can still be identified, and the actual proportions of various constituents are related to:1 81 1) the sources of waste inflows 2) the types of treatment processes from which sludges are generated 3) the sludge stabilization technique employed 4) the variety of the thickening, dewatering and drying methods used. The value of sludge as an agronomic aid is dependent on its nutrient content and organic matter. Sludges are variable in their make-up, but information does exist on the range of measured constituents contained in sludge. The following three tables provide some data on the physical and chemical contents of typical wastewater sludges. Table 4-1. Solid Content of Sludges2 ' *Tons ofWater/ Treatment Percent Solids Ton of Sludge Solids Primary Sedimentation 5 19 Chemical Precipitation 7 13 Trickling Filters Humus-low rate 7 l3 Humus-high rate 3 32 Activated Sludge 1-2 ”66 Well-Digested Sludge Primary treatment 10-15 ~7 Activated sludge . 6-10 ~12 82 Table 4-2. Range and Median of N,3P and K Contents of Digested Sewage Sludge * Range Median Component % % lbs/ton Total Nitrogen 2.0-5.0 3.3 66 Organic Nitrogen 1.6-3.0 2.0 40 P (Phosphorus) . 0.5-4.0 2.3 46 P205 (Phosphate) 1.1-9.2 5.3 106 K (Potassium) 0.1-2.0 0.3 6 0.12-2.40 0.4 7 K2) (Potash) * The median is that value for which 50% of the obser- vations, on each side. when arranged in the order of magnitude, lie Table 4-3. Trace Element Concentrations in Digested Sewage Sludge Range Element (ppm*, dry wt.) Median Boron 6-1000 50 Cadmium 3-3000 15 Chromium 20-30,000 1000 Cobalt 2-20 10 Copper 50-1l,000 1000 Nickel 10-5000 100 Manganese 60-7000 300 Mercury 0.5-10,000 5 Molybdenus 20-30 30 Lead 50-20,000 500 Zinc loo-28,000 2000 *Parts per million. Ref: Unpublished data, North Central Regional Committee 118, report entitled "Utilization and Disposal of Municipal, Industrial and Agricultural Processing Wastes." 83 The quantities of sludge produced at a sewage plant generally increase with the amount of treatment that wastewaters receive at the plant. As more facilities come into compliance with water quality standards, larger volumes of sludge are produced. Farmland application of these sludges has led to some speculation on the potential of substituting sludge for petroleum-based fertilizer. But even at the projected increase in sludge production rates, the fertilizer value of all municipal sludges combined would comprise one to two percent of the crop nutrients used for agricultural purposes each year in the U.S.5 A quantitative approximation of the total municipal sludge production rate is about 4.8 million tons per year, compared to the expected rate of 6.7 million tons per year by 1985. The following tables illustrate the average amounts of sludge produced by processes at wastewater plants. Table 4-4. Typical Quantities of Sludge Pgoduced in Wastewater Treatment Processes Imhoff & Treatment Keefer Fair Babbitt M & E Plain Sedimentation 2,950 3,530 2,440 3,000 Trickling Filter Humus 745 530 750 700 Chemical Precipitation 5,120 5,100 5,250 5,100 Activated Sludge 19,400 14,600 18,700 19,400 (Given as gallons/million gallons sewage treated) 84 Sludge Masses7 Table 4-5. % % of Specific Suspended Volatile Gravity Solids lb/day/mg Materials Suspended Treatment Removal Removed Removed Solids Plain Sed- imentation 60 1,020 65 1.33 Trickling Filter . Humus 30 510 45 1.52 Activated Sludge 92- 1,563 65 1.33 (excess) Imhoff Tank 60 1,020 50 1.47 Dig. Table 4-6. Trends in Production of Municipal Wastewater Sludge Population Dry tons** Population. Dry tons Served per year Served per vear Sludge Type (millions) x 106 (millions) s 106 Primary * (0.12 lb/cap-da) 145 3.2 170 3.7 Secondary (0.08 lb/cap-da) 101 1.5 170 2.5 Chemical (0.05 lb/cap-da) 10 0.1 50 0.5 TOTALS 4.8 6.7 2.: lb X 0.454 = kg. ** ton X 0.908 = metric ton. 85 Sludge is a semi-liquid (or semi-solid) mixture of organic and inorganic matter and microbial organisms. During wastewater treatment at a sewage plant, settleable and suspended solids are concentrated (clarified) into a sludge slurry. The sludges are collected from the primary and secondary treatment processes and then circulated to sites of stabilization thickening and storage. The entire system can be depicted as in the diagram on page:?7 of chapter two. Sludge is categorized according to the treatment process from which it originates. Raw sludge (also known as primary or untreated sludge) is composed of solids directly clarified from incoming wastewaters. Activated, filter and chemical sludges are the byproducts of their respective treatment processes. Stabilized sludge is the substance which results from the techniques designed to reduce the odors and volume of raw and secondary sludges. At a stabilization site, various sludges are usually mixed and then processed. Other sludges which require further processing may also be produced by tertiary effluent treatments at a sewage facility.91 Most land application programs require that the sludges receive stabilization before landspreading. This extra treatment of sludges serves a variety of purposes, among which are:10 l) converting the bulky and odorous sludges which result from primary and secondary treatments, to substances which possess qualities better suited to disposal and storage needs. 86 2) decomposing the odor-causing organics into more inert compounds. 3) decrease the potential of sludges for disease transmission by destroying most pathogens during stabilization. 4) reduce the water content (and the mass and volume) of sludge. Anaerobic Digestion and other Sludge Stabilization Processes Anaerobic digestion is the most commonly used stab- ilization process for treating raw and secondary sludges. This digestion process primarily involves the breakdown of volatile organic materials to more inert substances by a bacterial fermentation process. This biological digestion occurs in the absence of oxygen and at heated temperatures of 850 - 950 F over a period of about thirty days. Following digestion, the stabilized sludge is a dark gray to black, semi-liquid (10 percent solids - 90 percent water), with a granular, batter-like consistency. In addition, digested sludge has a tar-like odor and a 3 percent to 5 percent organic solids content. The physical qualities of this type of stabilized sludge are suitable for further thickening and dewatering as well as for direct farmland application as a liquid sludge.11 There are some other accepted methods of stabilization. The processes for sludge treatment include:12 1) aerobic stabilization 2) pond stabilization and lagoons 3) chemical and lime treatments 4) heat stabilization 87 Aerobic stabilization and lagoons also rely upon biological decomposition to stabilize sludge, but the last two options listed above are classified as physical-chemical methods of sludge treatment. These latter techniques are designed to separate the suspended solids from the water content and reduce the volatility of the solids. This separation produces a sludge with less mass, decreased volume and increased handleability. Sludge Thickening, Dewatering and Drying Processes The available techniques for reducing the amount of water in sludge vary considerably in the degree of sophis- tication employed. Small-scale sewage treatment plants can use relatively simple open-air drying beds to separate the water from the solids in digested sludge. After open- air drying, the sludge is a paste-like substance of 40 to 60 percent solids content. This "dried" sludge can be handled with auger and conveyor systems and sub- sequently applied to land with conventional manure spreading equipment.13 Other techniques for concentrating and dewatering sludge may be necessary for larger scale treatment plants. Sludge thickening processes include chemical conditioning, air flotation and gravity-baffle processes. Dewatering can be accomplished by techniques known as centrifugation, vacuum filtration and filter presses. If large volumes of sludge must be reduced in a short period of time due 88 to storage constraints, then one or more of these water- 1 removal processes may be necessary. 4 Storage, Transport and Application of Sludges Farmland utilization programs for sludge disposal may require additional facilities for the storage of sludge. Application can be prohibited when weather, soil or crop conditions are not suited for landspreading. A storage capability is necessary to hold sludges during these some- times extended interim periods between applications. A sludge holding capacity can consist of stabilization tanks, drying beds, stockpiles and lagoons. But storage time can create problems for a plant operator because of the tendencies for natural destabilizing of the sludge, overloading the holding capacity and diminishing the nutrient content of sludge by leaching and volatilizing processes.15 Because of these troubles, plant operators desire to minimize storage time and costs. From the view- point of sewage plant efficiency, the use of farmlands for sludge disposal is a valuable practice only if the availability for spreading coincides with the need to periodically rid the plant of sludge. The focus of most concern for a sludge manager is the proper balance among sludge production rates, sludge holding capacity and the costs of implementing a specific disposal strategy. When farmland utilization becomes a desirable sludge disposal choice, the treatment plant must be capable of 89 properly transporting and spreading the sludges. The movement of sludge from a sewage plant to an application site can be accomplished with a variety of equipment. Pipelines and vehicles are both technically feasible options, but the latter is most commonly (and cheaply) employed. Tankers, dump trucks and soil-injectors are a few of the various machines used for sludge handling. All such vehicles possess some similar characteristics, but the techniques for moving liquid sludge (< 5 to 10 percent solids) differ from those for drier sludge (> 30 percent solids).16 The transport and application of liquid sludge can be completed with the use of a single vehicle. Often a tank truck can be modified with various attachments to spread liquid sludge on the soil at controlled rates. Water-tight tanks can be fitted with gravity flow equip- ment, mechanical pumps, or below-surface soil injection instruments. Except when soil injection methods are used, surface application of sludge often requires a follow- up discing or tilling activity to incorporate the sludge into the soil. The incorporation serves to facilitate the entrance of sludge components into the soil structure, and also to prevent any nutrient loss by runoff, leaching or volatilization.17 Dried and filter-cake sludges have been handled with dump trucks, portable storage bins and manure spreaders. The higher percentage solids content calls for equipment 90 which can mechanically apply dried sludge at acceptable rates. The common type box-spreader, which is used to apply animal manure, can be mounted on a dump truck for spreading solid and semi-solid sludge. Other adaptive equipment has been developed for direct incorporation of dried sludges by employing a disc plow or moldboard. There are a number of tradeoffs between the use of dried and liquid sludges. The advantages of using semi-solid dry sludges are simply the result of the de- creased water content. Dried sludges can be stored more easily for prolonged periods of time and with smaller storage capacity requirements. The transport problems are also somewhat alleviated since more sludge (in dry weight) is carried per truckload. The threats of liquid ponding on the soil surface caused by slow in- filtration of the sludge's water content into the ground, are also greatly reduced. But the costs of drying constitute the major disadvantage of utilizing the semi- solid sludge. These costs are largely the energy and equip- ment necessary for obtaining a dried sludge. Also, the correct hauling and application equipment needs to be available in order to spread the dried sludge. But the equipment requirements for the liquid slurry-form sludge also constitute a considerable investment, since some type of water-tight tank must be used for transport. The main advantages of applying liquid sludge are the avoidance ‘ of costly dewatering procedures and the relative ease 91 of spreading liquid sludges using gravity flow or mechanical pumping methods. The disadvantages of tank trucks are the maintenance needs as well as soil compaction difficulties with wet soils. These compaction problems are being somewhat remedied by the use of trucks with tractor- like tires known as "big wheels tank-trucks."18 The oper- ation of sludge spreading vehicles must be conducted so as to avoid uneven applications and undesired dumping. Proper maintenance of equipment and the training of vehicle drivers lends to greater assurances that the appli- cation occurs at desired rates and with beneficial results. Farmland Application of Sludges Agronomic Values, Application Rates and Constraints The agronomic benefits of sludge application have been identified in three roughly equivalent manners. The most important measures of the sludge value, from the farm- firm point of view, are the contribution to higher crop yields or the reduction of fertilizer cost. The most commonly cited values of sludge utilization practices are:'19 l) The nitrogen and phosphorus additions to soil which are attributed to sludge use. The nutrient content of sludge is generally known as its fert- ilizer valued. Sludges also contain small amounts of potassium and sparse quantities of micro- nutrients, such as boron. 2) Sludge applications can improve soil tilth or soil humus. Sludge is composed of carbon and nitrogen based organic compounds which tend to be - incorporated into the soil structure. The potential soil improvements have been noted as better soil 92 aggregation, water holding capacity, cation ex- change capacity, gas exchange and water infiltration rates. Heavy soils with high clay content can become more friable and loose, while sandy soils achieve improved soil structure, with sludge additions. 3) As a result of the two agronomic values mentioned above, farm crops may react favorably by bringing forth higher yields. New information on the benefits of sludge use is originating from the records of programs currently in operation as well as from data on test plots of soil science experiments. The determination of crop yield response as a function of sludge application rates is still an area of much research. Application rates (sludge loading rates) to the soil are calculated on a technical basis, and actual rates may be an issue for contractual agreement between the farmer and plant operator. Typically, loading rates are determined by considering the following factorszzo 1) Nutrient content of the sludge. 2) The fertilizer recommendations obtained from soil tests. 3) The heavy metals content of the sludge and the soil. When application rates are being computed, usually the limiting nutrient is nitrogen. The reasons for the nitrogen (N) limit include: The high N content of sludge, the rate at which organic N is converted to inorganic forms that are conducive to plant growth, and the problems ass- ociated with excess nitrogen in the soil. (Please note that the heavy metals' constraints on loading rates are to 93 be discussed after the aspects of nitrogen loadings are more fully explained.) Although the specific amounts of nutrients in sludge are variable, the N-P-K* contents have been statistically observed to have values which range over relatively small intervals for samples taken at smaller wastewater treat- ment plants. If nitrogen is determined to be the limiting nutrient, some simple calculations of N loading rates can be made. A hypothetical example would be the application of a sludge with a 3 percent nitrogen content at a rate of 3 dry tons per acre of sludge. The total loading would be 180 poinds per acre of nitrogen. But of this 1,500 pounds of N, only 54 pounds would be in the readily plant-available forms of ammonia (NH3) and nitrate (N03). The remaining 126 pounds of N would consist of organic compounds and not be immediately usable for plant growth. This organic N becomes a type of resevoir of nitrogen which is slowly converted to NH -N and NO -N for plant use. 3 3 The decomposition of the organic N occurs due to a bacterial process known as nitrification. Another series of reactions known as denitrification, acts to slightly deplete the organic N "resevoir" by converting N compounds to nit- rogen gas (N2), which is released to the atmosphere. Ni- trogen additions to the soil by sludge application should therefore be calculated by estimating the available N, —— a: N-P-K = (Nitrogen-Phosphorus-Potassium) 94 as well as the release rates from the organic N in the sludge. In general, both mineral N and the portion of the organic N that breaks down is the ”available N." In relation to these considerations on the nitrogen in sludge, the uptake rate of the crop and the natural soil N con- tent should be used in determining the proper sludge application rate. Excess availability of nitrogen can have a number of adverse effects. When too much nitrogen is available to plants, the maturation of flowering and fruiting growth may be delayed or overwhelmed by stem and leaf growth. Also, when the soil is overloaded with nitrogen, the nitrates may leach to grounwaters, and cause contamination of water supplies. With regard to groun- waters, the depth to the water table is an important factor in choosing sites of application and loading rates.21 The limits placed on sludge spreading rates due to heavy metals content can be more restrictive in some cases. There are a number of significant considerations with reference to the heavy metals in sludge. First, high levels of heavy metals in sludge are mostly due to in- dustrial inflows of waste to the municipal sewage plant. When sewage facilities treat only domestic (human) wastes, then the problem of heavy metals diminishes. But even with industrial flows eliminated, a wastewater plant still must monitor for metals such as zinc, copper and cadmium that generally exist in sludge at concentrations too high to ignore for crop production. Another aspect is that much research is currently in progress to obtain 95 information on:22 1) the uptake rate of metals by plants 2) the concentration levels which should be considered as harmful 3) the effects of animals further down the food chain 4) metals reaction with the soil under various con- ditions. Some general experimental results indicate that the plant uptake of heavy metals is proportional to the metals concentration in the soil. Also, plants tend to collect greater proportions of metals in the leafy and vegetative parts of the plants, rather than in the grain, seeds or fruits. Soil conditions are a major factor in uptake of metals by plants, and the relationship between soil pH and metal contamination has been strongly researched. An acidic level of pH 5.5 or less does permit higher uptakes by causing metals to be more soluble in the soil solution. But under neutral or slightly alkaline conditions (pH 6.5 to 7.5) metals tend to be less soluble and available in soil solution for plants. Other factors which tend to retard uptake and availability of these trace metals are a high cation exchange capacity and a high organic content. Overall, different crops do not have the same uptake rates and also differ in their tolerance for concentrations of metals.23 Suitability of Sludge Use for Selected Crops To avoid the adverse effects of excess heavy metals and nitrogen loadings, sludge applications need to be 96 coordinated with the choice of the cultivated crop. Sludge utilization programs are modified by the different require- ments of each crop. For example, sludge can be applied to sites for annual crops such as corn, grain or soybeans, either before planting in the spring or after harvest in the fall. But incorporation procedures must be followed more closely when cultivating soybeans, because the seed germination of soybeans is more sensitive to changing soil conditions. Perennial crOps used for forage or sod production can utilize sludge, but there are difficulties due to soil clogging from surface applications, plants damaged by equipment traffic and the costs of any sub- surface injection techniques. Small grain crops such as wheat, oats, barley and rye can benefit, although these grains tend to have lower nutrient uptake rates and pro- duce excessive vegetative (stalk) growth in the presence of high nitrogen availability. But the small grains (and forages) also tend to minimize erosion and are tolerant of salts which may exist in s1udge.24 A listing of the desirable and undesirable crop characteristics for sludge applications can be shown as follows:25 Desirable Crop Conditions for Sludge Spreading 1) Greater number of time periods available for application. 2) Higher tolerance of salts and heavy metals. 3) High nutrient uptake rates and low metals uptake rates. 4) Extensive acreage opportunities for spreading. 97 5) High infiltration rates, erosion control, and minimal soil clogging. Undesirable Crop Conditions 1) Reverse characteristics to those listed above. For example, low nutrient uptake rates and high metals uptake. 2) Vegetable crops for human consumption are not allowed to be grown on sludge-amended soils due to potential for health hazards. 3) Animal grazing on sludge-amended soils should be prevented for at least one month, provided the sludge has been stabilized by an acceptable process. 4) Nitrogen excesses can have adverse effects on germination and plant growht of crops, especially the sensitive varieties. Releases of available nitrogen from sludges (nitrification) may delay fruiting or otherwise adversely alter the growth of some crops. 5) Marketing of animal feed products grown on sludge- amended soils may be prohibited or very difficult. When the benefits of sludge use are measured only in terms of yield responses, the record exhibits mostly favorable results. CrOps such as corn and soybeans have been tested with varying application rates, and the results have shown significant yield increases when sludges are spread and incorporated on formerly marginal soils. Although there is a limit to which the sludge application will encourage productivity, soils with lower potentials are generally improved by higher spreading rates. The incorporation of sludge in the soil tends to raise its natural productive capacity by strengthening the soil structure, and restoring nutrient content. 98 Measuring and Monitoring Sludges and Sludge-Amended Soils To apply sludges at a desired loading rate, a knowledge of the N-P-K contents, heavy metals and other constituents is necessary. Approximating the average content of these elements in sludge is usually accomplished by subjecting a collection of sludge samples to chemical analyses. The equipment and expertise required to perform such tests may not be available at the treatment plant. Municipalities can employ the services of privately-owned laboratories or the facilities of large universities. (Michigan State University's Department of Crop and Soil Science provides a complete sludge analysis service.) Although the results of sludge tests are helpful in determining the fertilizer values and in setting spreading rates, these analyses should be complemented by soil tests. If soil samples are taken both prior to and after sludge applications, a more accurate measure of the contribution of sludge to soil fertility can be obtained. When they are performed on an annual (or semi-annual) basis, soil tests can give useful information on the release and buildup of plant-available nitrogen. A soil analysis may also measure Cation Exchange Capacity and soil pH, both of which influence nutrient (and metals) availability to plants. Soil tests also reveal any nutrient deficiencies or excesses, and can be used to predict fertilizer requirements for various crops which might be cultivated. 99 Finally, there is also considerable concern for the infiltration and runoff rates of sludge-amended soils. A well conceived utilization plan includes periodic testing of groundwaters and surface-waters which might be contaminated by sludge residuals. The question of monitoring sludge application also raises the issues of health hazards, odor problems and public acceptance. The primary health concern with sludge is the pathogenci population of micro-organisms which exist in wastewater sludges. The pathogen problem is characterized by two main concerns:26 1) the type and number of micro-organisms a) In sludge, the four dominant pathogens are: l) bacteria 2) protozoa 3) helminth parasites 4) viruses 2) the length of survival time of various pathogens a) stabilization techniques and environmental conditions influence survival. Anaerobic digestion greatly diminishes the pathogen populations, so that a stabilized sludge is generally less hazardous. Another important factor which tends to alleviate the potential for disease is that most sludge pathogens cannot successfully compete with soil micro-flora, so that pathogens usually perish in the soil environment. There are some remaining questions on the survival rates of some viruses and parasitic worm ova. Some studies indicate that these particular organisms (viruses and worm ova) are highly resistant to most adverse environmental conditions. 100 The uncertainties over pathogens have been reason enough to institute a policy of using sludge on food crops not intended for humans. But the record with spreading of treated sludges (stabilized) has had little or no evidence of adverse health effects. The obnoxious odors which emanate from untreated sludge are the source of much public opposition to land application programs. Undesirable smells can be con— siderably eliminated from sludge by stabilization processes. An anaerobically digested sludge has a bearable tar-like odor. But the isolation of sludge application sites is generally a good rule to follow when possible. Destabilizing processes can cause putrescent odors even from digested sludges when they are applied to land but not immediately incorporated in the soil. The manager of a sludge program should not only isolate sludge applications from more densely populated areas, but also conduct workshops to instruct local people as to the alternative sludge dis- posal options available, and to the reasons for choosing a specific strategy (for example, landspreading on farms). Summarizing the Technical Aspects of Sludge Utilization The general perspective on farmland application of sludges is favorable, despite some reservations over the potential hazards. Digestion or other forms of stabilization are a requirement for any landspreading schemes. Stabilization is capable of reducing odor, minimizing pathogen threats 101 and increasing the handleability. Equipment is available for the application of either liquid or dry sludges, and the choice of vehicles is often a decision which is specific to the situation of each treatment plant. The application rates must be determined by estimating the nutrients in the sludge and soils, the nutrient demands of the crops, and the environmental conditions which influence the interrelationships of sludge, soil and plants. Testing and monitoring become an integral part of a well-planned program designed to spread sludges to enhance crop growth and simultaneously dispose of sludge in a safe manner. Actual operations are primarily concerned with meeting these twin goals of disposal and agricultural enhancement. The next chapter examines the results of surveys conducted on Michigan rural communities which have participated in landspreading programs. These surveys provide some factual information on the benefits and problems of sludge utilization. ENDNOTES 1J.R. Peterson, Cecil Lue-Hing and D.R. Zenz, "Chemical and Biological Quality of Municipal Sludge, ” Recycling Treated Municipal Wastewater and Sludge through Forest and Cropland, ed. William E. Sopper and Louis T. Kardos (University Park: The Pennsylvania State University Press, 1973), pp. 27-32. 2B. Vincent Salotto, Gerald Stern and G. Kenneth Dotson, ”Characteristics of Municipal Wastewater Sludges," Utilization of Wastewater Treatment Products Land, (East Lansing: North Central Regional Conference Workshop, 1974), sec. 3, table 1. 3"Ohio Guide for Land Application of Sewage Sludge," (Columbus: Ohio Cooperative Extension Service, 1976), no. 598, p. 4. 4"Ohio Guide for Land Application of Sewage Sludge," (Columbus: Ohio Cooperative Extension Service, 1976), no. 598, p. 4. 5Harry G. Geyer, "An Overview of Municipal Wastewater Systems," Utilization of Wastewater Treatment Products on Land, 1974, sec. 1, pp. 7-8. 6 B. Vincent Sallotto, Gerald Stern and G. Kenneth Dotson, table 3. 7Ibid.,table 4. 81bid., table 2. 9 Harry M. Galloway and Lee W. Jacobs, "Sewage Sludges- Characteristics and Management, " Utilizing Municipal Sewage and Sludges on Land for Agricultural Production, ed. Lee W JaCObS (East Lansing: North Central Re ional Publi ' No. 52, 1977), pp. 3_4. g cation 10Mark J. Hammer, p. 416. l . Clarence G. Golueke, Biological Reclamation of Solid Wastes (Emmaus: Rodale Press, 1977), pp. 119, 150. 102 103 12R.H. Dowdy, R.E. Larson and E. Epstein, "Sewage Sludge and Effluent Use in Agriculture,” Land Application of Waste Materials (Ankeny: Soil Conservation Service of America, 1976), pp. 139-40. 13John M. Walker, "Sewage Sludge—Management Aspects for Land Application," Utilization of Wastewater Treatment Products on Land, 1974, sec. 4, p. 6. 14James E. Etzel and Alfred J. Steffen, "Wastewater Treatment Processes and Products," Utilization of Wastewater Treatment Products on Land, 1974, sec. 3, p. 5. 15 John M. Walker, p. 5. 16Information obtained from a conversation with Lee W. Jacobs, Department of Soil Science, Michigan State University. 17R.H. Dowdy, R.E. Larson and E. Epstein, pp. 144-46. 18Personal conversation with municipal wastewater operator while conducting surveys. 19P.F. Pratt, M.D. Thorne and Frank Wiersma, "Future Direction of Waste Utilization," Soils for Management of Organic Wastes and Wastewaters (Madison: Soil Science Society of America, 1977), pp. 622-23. ZQnarence G. Golueke, pp. 124-129. 21C.M. Gilmore, F.E. Broadbent and S.M. Beck, "Recycling of Carbon and Nitrogen through the Land Disposal of Various Wastes," Soils for Management of Organic Wastes and Waste- waters, pp. 181-192. 22G.W. Leeper, Managing the Heavy Metals on the Land, (New York: Marcel Dekker, Inc., 1978), pp. ll-12. 23Harry M. Galloway and Lee W. Jacobs, pp. 10-12. 24Chris J. Johannsen, "Site Selection and Land-Use Considerations," Utilizing Municipal Sewage Wastewaters and Sludges on Land for Agricultural Production, pp. 37-39. 251bid., pp. 38-39. 26Harry G. Geyer, "Health Aspects," Utilizing Municipal Sewage Wastewaters and Sludges on Land for Agricultural Production, pp. 48-51. CHAPTER V SUMMARY AND INTERPRETATION OF SLUDGE UTILIZATION SURVEY RESULTS Farmland Application of Sludges in Rural Michigan The operation of a sewage treatment plant is often provided as a public service by local government. At the present time, municipal authorities are being required by federal and state laws to upgrade existing sewage disposal systems. Many wastewater facilities are being redesigned to incorporate advanced treatment processes to meet the new water quality standards. The improved waste removal techniques are capable of controlling sewage outflows and preventing water pollution. But these ad— vanced methods are also more costly and generate larger volumes of sludge, which is a solid waste pollution problem. As discussed earlier, the growing difficulties of sludge management are being confronted by all munici- palities. But the purpose of the present chapter is to examine sludge programs only as they pertain to selected communities in Michigan. In general, the responsibility for developing sludge disposal plans has been delegated to state and local levels of government. Federal directives are carried out by agencies such as Michigan's Department of Natural Resources. As a result, sludge programs are not 104 105 uniform. The surveys conducted for this analysis focus on just one of the available disposal alternatives: the application of stabilized sewage sludges to privately-owned farmland in Michigan. Those communities which employ public lands for utilization purposes are not included in this study. Due to the difficulty in addressing all the issues of sludge disposal, the survey objectives are limited. The questionaires are primarily designed to obtain information on utilization agreements in Michigan. Upon examining the sludge disposal practices throughout the state, it was found that private farmland programs tend to be located in rural settings. Less populated areas have utilization programs which are facilitated by the close proximity of the treat- ment plants to cropland. The primary agents involved in implementing a private farmland application plan are the farmer and the sewage treatment plant operator. To analyze sludge programs from the perspectives of both participants, separate surveys were conducted with the farmers and operators involved in landspreading operations. The Michigan Department of Natural Resources (DNR) provided the necessary information on the wastewater facilities which currently spread sludges on private cropland. When the surveys were conducted, twenty Michigan municipalities were actively pursuing utilization programs with local farmers. A total of 37 farmers were interviewed about their participation in sludge programs. 106 The time of the survey was June 1978, and since then a number of additional communities and farmers have initiated utilization agreements. The survey communities are generally located in the southern half of the lower peninsula of Michigan, as indicated by the map on page 108. Most landspreading programs in these municipalities have only been operating for one to three years, but a few locations have been re- cycling sludge on croplands for about eight years. The farmland option has been adopted by about seventy percent of the studied communities as the sole method of ultimate sludge disposal. The relationship between the physical quantity of sludge produced at the treatment plant and the percentage of this total production applied to farmland is illustrated in Table 5-1 on pagelO7. Characteristics of Sludge Utilization Programs Population Size, Program Goals and the Related Costs of Land Application As Table 5-1 indicates, a majority of the current utilization programs meet the disposal needs of the surveyed municipalities. Land application programs seem to have the potential for solving the sludge problems of rural areas. To gain a better idea of the quality of sludge being managed by communities using landspreading programs, Tables 5—2 and 5-3 present the association between sludge production, population size and the sewage treatment plant design size. As might be expected, the larger the population or 107 Table 5-1. Comparison of the Treatment Plant's Sludge Production with the Percent of Sludge Output Applied to Private Farmlanda Quantity of Percentage of Total Sludge Production Sludge Produced Applied To Land in Drbeons Per Day 100% 80-90% 50-60% Row Total 0 - 0.15 5 1 1 7 0.16 - 1.10 4 2 l 7 1.11 - 6.00 2 0 0 2 Column Total 11 3 2 16 aSurvey of Municipal Sewage Treatment Plant Operators bDry Tons Per Day are Calculated Using one of the Following Equivalent Formulas: _ Gallons a 8.34 Lbs. Ton Dry Tons Per Day — ——fiE§—— X m Solids X Gallon X 2000 Lbs. Dry Tons Per Day = Wet Tons Per Day X % DrXOSOIIdS sewage plant size, the greater the amount of sludge that is generated. The population size ranged from 750 to 25,000 people, and sixty-five percent of the surveyed municipalities lie within the 2,000 to 12,000 population interval. The communities having larger and more densely settled areas also tended to be further away from cropland. Table 5-4 shows the influence of population size on the distance between spreading sites and the treatment plant. Transport and application of sludges constitute the major portion of utilization costs. Land application may not be a feasible alternative when the costs rise above °®mfmmtw-oPasaaaeer MICHIGAN EEZ Bad Axe Bedford Berlin Petersburg Big Rapids BriShton Howell Constantine Deerfield Tecumseh Chelsea Flushing Grand Haven Zeeland Holland Grand Ledge Grandville Sparta Hastings West Branch Figure 5-1. 108 ' J ,Jlf‘*fifiwr_5 f;£:7;k QWLL F ! {J IV"! “I”? K j L-L._,! ,fl /-__J:.=r i .\ L... no» -! . . 1%i .“~A Ffifian I _I" 'fifiauvlw a. L ‘ \‘V'N.4 INTI-“r. I I :--— .. i I i !11 .. . ' AfigJay-Iazfiahairfitfiflmfiéfirjzgarff ' 8' ! I, . 4—'--'-——--—.__.:39_f_4 Location of Surveyed Communities. i j A" £1} . U. j? ' ..;;\ ’2 ' 1" . In: “x ‘U A34f§E?Ufififiafifig 3, 109 Table 5-2. Comparison of the Treatment Plant's Sludge Production with Population Sizea Dry TODS Population Size Intervalsc Per Day of Sludge Producedb 0-2000 2001-6000 6001-12,000 12,000 Row Total 0 - 0.15 4 2 1 0 7 0.16 - 1.10 0 1 4 0 5 1.11 - 6.00 0 1 2 2 5 Column Total 4 4 7 2 l7 aSurvey of municipal sewage treatment plant operators. From this point forward, referred to as "Survey of sewage plant Operators." bDry tons per day are calculated using the formulas given for Table 5-1. cData on Population Size obtained from "The Superlist" which is a listing of information on all Michigan Municipal Wastewater Treatment Facilities. Compiled by the Wastewater Division of the Department of Natural Resources- 110 Table 5—3. Comparison of Treatment Plant Sludge Production with the Design Wastewater Flow of the Planta Dry Tons/Day Design Flow of Sewage PlantC _ of Sludge 0 -0.60 0.61-1.20 1.21—5.00 Row Total Producedb MGD MGD MGD 0.00-0.15 DT/D 5 2 0 7 0.16-1.10 DT/D 0 3 3 6 1.11-6.00 DT/D 0 1 3 4 Column Total 5 6 6 17 3'Survey of municipal sewage treatment plant operator. bDry tons per day are calculated using the formulas given for Table 5-1. cDesign flow data obtained from ”The Superlist." Table 5.4. Comparison of Population Size with Distance that Sludge is Transported. Average Distance Sludge Transpogteda Size of l-5 6-10 ll-15 Row Total Populationb Miles Miles Miles 0-2000 4 o o 4 2001-6000 5 2 o 7 6001-12,000 3 4 o 7 12,000 0 o 2 2 Column Total 12 6 2 20 aSurvey of municipal sewage treatment plant operators. bData from "The Superlist.” 111 budgeted amounts or when another alternative can achieve disposal less expensively. More densely populated areas tend to have longer transport distances and, therefore, higher labor and energy costs to move sludges to application sites. In addition, the costs of finding transport routes and controlling contingencies are higher when the treat- ment plant is not conveniently located close to farmlands. But utilization may still be desirable if higher costs can be spread over a greater number of treatment plant users. The survey data on transport and application costs exhibit variability, especially with the expenditures for equip- ment and vehicles. The range in outlays for machinery to move sludges is influenced by a number of factors: 1. The source of funds for purchasing equipment (or use of that equipment) may either be local, federal or both. (a) Federal aid can defray the cost borne by the municipality for purchasing equipment. If federal funds are plentiful, more expensive (and hopefully better) equipment can be obtained. 2. The ownership of the transport and/or the application equipment can lie with: (a) The treatment plant (b) The farmer (s) (c) A private hauler. 112 3. The existence or non-existence of differences between the transport and application vehicles. (a) In the case of liquid sludges, one tank- truck can accomplish both the transport and application procedures. Dried sludges may require the use of a hauling truck as well as a manure spreader. 4. The management objectives and the technical require- ments for a sludge utilization program (a) The desire to use improved technology (equip- ment) to enhance the agricultural usefulness, rather than accomplish just simple disposal, may require higher investment costs. 5. Cost sharing arrangements with farmers and/or haulers for moving the sludges onto the land. (a) The farmer or hauler may own the transport and application equipment, and the munici- pality pay for hauling services (b) The municipality may perform both application and transport activities in exchange for a payment from the farmer (for example, a per mile charge). Only twelve of the municipalities reported cost figures for the sludge—moving equipment. But the cost data still provide some useful information on the arrangements made for procuring the necessary equipment (See Table 5-5). The results from Table 5-5 contain some interesting 113 HmUHo mum. noaUmHHMOb Om pocchnHos sts oomem man >Hdm=mmam=am mow chammlmmsaHHam wnchBmsnm poocwmnHoa mxvmanstHm o: masle mocaoo 0H wcaam zcsHoprHHw< acaHoHumHHdw Menace mHNm Bonn HHD esocmmsamv wow mnchsmun osam pmwm wwnamu pmwm mmmeaosn ow mmchH zcsHoHl mow zo