IDEM Land Application Reporting Requirement Changes

From Jeff Harmon, IDEM Land Application Program, 9/15/2017 and 12/8/2017:

Biosolids Land Appliers:

Beginning with your January 2018 land application monthly report (due date March 2, 2018), we will be requiring submittal of documentation of pathogen and vector attraction reduction with all reports that indicate land application activity took place.  Currently you are required to retain this information on file as part of your record keeping requirements.  Only facilities with marketing and distribution permits are currently required to submit this information.  To better comply with EPA expectations and ensure compliance with pathogen and vector attraction restrictions, we are expanding the requirement to submit documentation to land appliers as well.   

For most of you, this change will simply mean submitting the preparer certification statement for pathogen reduction along with a copy of your fecal coliform lab results, and the applier certification statement indicating either injection or incorporation for vector attraction reduction.  Many of you already submit these documents with your reports, and for those of you that do, nothing will change.  The documentation needed varies with the pathogen reduction alternative and vector attraction reduction option you use.  Please refer to the Monitoring and Analysis section of your permit for more information about the data you should be collecting.

The linked documents below provide information about the documentation needed for the pathogen reduction alternatives and vector attraction reduction options identified in your current permit.  Each document includes: 1) a description of what we will be looking for in your report, 2) applicable portions of the Indiana land application regulation, and 3) applicable sections from EPA/625/R-92/013, available in full at: https://www.epa.gov/biosolids/control-pathogens-and-vector-attraction-sewage-sludge

• Class B - Alt 1 Monitoring of Indicator Organisms
• VAR - Option 9 Injection
• VAR - Option 10 Incorporation
• Certification Statements

Beginning with reports that show land application activity during January 2018, which are due by March 2, 2018, please include the information identified in the linked documents.  No additional documentation is needed when you submit “No Activity” reports.

Although this information is currently required to be kept on file at your facility, we understand that there may be confusion about the documentation that is to be submitted.  Please feel free to contact staff of the Land Application Program for further clarification.

Jeff Harmon, Senior Environmental Manager

Indiana Department of Environmental Management

Land Application Program

IGCN 1101, 100 North Senate Avenue

Indianapolis, Indiana 46204-2251