The Draft Guide to Land…

ERO number

019-0739

Comment ID

35194

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Individual

Comment status

Comment approved More about comment statuses

Comment

The Draft Guide to Land Application of Treated Domestic Septage represents a profound change in the management of septage. A typical hydraulic loading rate in a current CofA of 15L/m2/week over 10-20 weeks of application is 1500-3000 m3/ha/year, whereas the proposed regulations limit application to 300 m3/ha/year on corn and forage crops. This means potentially a five to ten fold increase in the required crop land. The additional costs of managing the land application of septage could approach the costs of biosolids management incurred by municipalities. This would result in significant increases in pumpout costs. Many haulers will find it more convenient to haul to a municipal treatment plant (where possible) than either purchase additional farm land or coordinate spreading permits with several farms. The requirements for metals concentrations are not clear. From Column 4 in Table 1, is application to a field limited to a one in 5 year cycle or an annual rate of 1/5 of the metal loading rates presented in the table? Have soil samples been collected from existing septage spreading locations and will a significant number of haulers have to abandon their current spreading sites due to high metals concentrations from past spreading practices?

[Original Comment ID: 115732]