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HomeMy WebLinkAboutAgenda - 10-13-2009 - 1ORANGE COUNTY BOARD OF COMMISSIONERS WORKSESSION AGENDA ITEM ABSTRACT Meeting Date: October 13, 2009 Action Agenda Item No. 1 SUBJECT: Land Application of Wastewater Biosolids DEPARTMENT: Manager, ERCD, Health, PUBLIC HEARING: (Y/N) No Cooperative Extension ATTACHMENT(S): INFORMATION CONTACT: Timeline of Activities to Date Frank Clifton, 245-2300 Map - Biosolid Application Sites, 2008 Dr. Rosemary Summers, 245-2411 Health Department Memo -March 2008 David Stancil, 245-2590 CFE Memo -April 2008 Tom Konsler, 245-2365 May 2008 Correspondence Between Dr. Carl Matyac, 245-2062 Orange County and NCDWQ CFE Memorandum -April 2009 Health Department Proposed Regional Forum -August 2009 Materials CFE Memorandum -August 2009 PURPOSE: To review activities to date and consider a proposal to address issues related to the land application of wastewater biosolids, and provide direction to management and staff concerning desired next steps. BACKGROUND: Local issues regarding the land application of public wastewater biosolids (in previous years informally known as "sludge") date back to the late 1980's. In 1990, prompted by months of review by the Bingham Township Advisory Council (TAC), the Planning Board conveyed information to the Board of Commissioners about OWASA sludge application. This issue continued to be a regular topic of discussion in Bingham TAC meetings for the next few years. The Board of Health adopted rules that included the monitoring of biosolids application activities. The permitting process and regulation, however, remains with the state Division of Water Quality (NCDWQ). During the intervening years, land application of wastewater biosolids in the County increased in scope and number of sites. As of October 2009, six wastewater generators (Burlington, Cary, Durham, Hillsborough, Mebane and OWASA) apply biosolids to over 3,000 acres of farmland in Orange County. OWASA applies biosolids to land it owns as well as land in private ownership. The other five systems apply biosolids to primarily private lands. On March 6, 2008, the executive director of the Blue Ridge Environmental Defense League (BREDL) addressed the Board of Commissioners and asked that the issue of wastewater biosolids and an upcoming renewal of the City of Burlington's biosolids permit be investigated. The Board asked the Commission for the Environment (CFE) to explore this topic and after 2 hearing from OWASA, Health and BREDL representatives, amemorandum (attached) was conveyed in May 2008. Over the subsequent year, a number of memoranda, letters and proposals were developed or conveyed by the Board, CFE, Health Department and NCDWQ on the Burlington permit and larger biosolids application issues. A chronological timeline of this correspondence and related discussion is provided in the attached timeline. In the fall of 2008, the Commission for the Environment continued its exploration of the topic, gathering information on biosolids application from studies, a report from a CFE member with experience in biosolids research, and other sources. As a result of this review, in April 2009 the CFE sent a second memorandum to the Board (attached) suggesting a joint task force be formed with representatives from the CFE, Board of Health and other groups as decided by the Board. The memo also identifies several topics and potential issues for potential review. In December of 2006, the BOCC approved funds from the Health Department budget to be used for a contract with UNC School of Public Health to conduct a pilot study of biosolids applications and methods of measuring potential effects on the environment and on health. After encountering difficulties in identifying a suitable site for such a study, the Health Director met with UNC faculty members in 2009 about the future of the planned research pilot study. Although there was agreement from two landowners to participate in the study, the research team from UNC and NCSU felt that there were insufficient funds to result in a meaningful study. The Health Department recognized the continued need to address community concerns and proposed to re-direct a portion of the funds to hold a regional knowledge and science-based forum with land application of biosolids as the topic. A planning committee with Cooperative Extension, UNC, NCSU and several other agencies developed an agenda for the forum that would provide the public with information on the biosolids process, the state of current regulations, past, ongoing and future research efforts, and the management of health risks. Redirection of the funds was not approved. Additionally, the Board has previously received information from the County Attorney indicating the legality of county regulation of biosolids application. On October 7, management and staff met to discuss possible scenarios for furthering awareness and identifying potential action. The issue of biosolids application is one that transcends many boundaries. tt is simultaneously an agricultural, environmental, public health and land use issue, with financial and economic ramifications for wastewater providers and farmers. Any response to this topic will require a multi-disciplinary effort drawing from multiple resources within and outside of County government. One option that was identified melds the essence of both the CFE and Health Department proposals and engages the agricultural community. This proposal would feature a facilitated public education forum designed to provide for an unbiased perspective on the scientific research to date on biosolids application, while still allowing for diversity of review and discussion. Fortunately, this topic is one that has been of great interest in many localities across the nation and a wide range of research and data exists 3 on the topic. The Health Director, ERCD Director and Extension Director would be asked to explore within their fields of expertise the potential fora "neutral party" to attend and, as keynote speaker, summarize the research to date and present in unbiased fashion what is currently known and unknown about this issue. Such a forum would invite representatives from all stakeholder groups to be present and participate including the wastewater utilities, environmental groups, agricultural operations, public health interests, and others as identified. The end result of the forum would be the identification of a "core list" of key issues, prioritized research needs, "questions that need answers," and potential County actions to this end. As noted by the County Attorney, some activities regarding regulation of biosolids application are clearly the domain of the State. However, there may be avenues or opportunities for joint activities in the public interest. Some of these potential future actions (which are not recommended at this time, but listed below as fodder for future discussions) include: • Engaging the State and utility providers in an enhanced monitoring and maintenance program, • Memoranda of Agreement with the State or with utility providers for provide for more communication and monitoring, • Exploration of activities by other counties around the nation in addressing biosolids issues, and • Other potential joint or partnership activities that furthers needed knowledge or information regarding biosolids application. It should be noted that the creation and planning for the educational forum concept above will require the expenditure of staff resources, and that this event -and more importantly, any subsequent follow-up activity or further research -will compete with existing Board goals and priorities and may impact the ability to accomplish other activities. FINANCIAL IMPACT: There is no financial impact associated with discussion of this topic. Pursuing a forum or subsequent task force would require the expenditure of funds and allocation of staff resources from multiple departments, which may impact other priorities and activities. RECOMMENDATION(S): The Manager recommends that the Board review the activities to date, discuss the proposed educational forum as an initial step to address this issue, and if agreeable, direct the Heath Director, ERCD Director and Extension Director to 1) collectively identify an unbiased expert to be invited to address the forum, and 2) develop a draft program for the event with defined outcomes. The Board may also wish to provide direction to the County Attorney regarding options identified in his previous correspondence. Wastewater Biosolids -Timeline of Activities to Date 1988-1990 Bingham Township residents concerned about OWASA sludge application, presentations to Bingham Township Advisory Council TAC and Plannin Board. 1995 Orange County Board of Health adopts rules that require monitoring of DWQ systems including biosolids application sites. Health De artment staff im lement monitorin ro ram. November Occupation and Environmental Epidemiology Branch issues 2005 recommendations to the Division of Water Quality in the document Human Health Risk Evaluation of Land Application of Sewa a Slud a/Biosolids Dec 2006 Board of Commissioners approves Health Department funds for a contract with UNC to conduct a pilot study focusing on biosolids. Over the next two years, Health Department works with UNC to develo rotocol and attem t to identi a stud site. 2006 City of Burlington applies for renewal of biosolids application ermit. April 2009 Board of Health and OCHD staff begin discussion with DWQ for and ongoing establishing a memorandum of agreement for the monitoring of several system types including biosolids application activities. Staff resources limit the expansion of the current WIMP ro ram. March 2008 Blue Ridge Environmental Defense League (BREDL) makes request at Board of Commissioners meeting to investigate issue of biosolids and Burlington's permit renewal. Matter referred to the Commission for the Environment (CFE). Health Director res onds to Coun Mana er with memo and fact sheet. May 2008 CFE completes and conveys memorandum to BOCC suggesting several areas of investigation, including sites in watershed critical areas, support for planned Board of Health /UNC pilot study, and suggests a second public hearing in Orange County be held on Burlin ton a lication. May 2008 BOCC letter to NCDWQ sent, noting unanswered questions about potential health issues, and proposing a second public hearing in Orange County (due to amount of land in Orange subject to Burlington application), that sites within critical watershed areas not be re-permitted, and that the Health De artment be informed in advance on future re- ermittin . May 2008 Public hearing held on Burlington permit renewal in Graham. BOCC letter conveyed. Many Orange County residents attend ands eak. May 28, NCDWQ letter to Board denying request for second public 2008 hearing and noting discussions between NCDWQ and Health De artment re ardin a ossible MOA. YQ October DWQ renews Burlington permit for land application valid through 2008 October 2013 Fall 2008- CFE continued gathering of information on biosolids and heard Winter 2009 from speakers from OWASA and BREDL and research erformed b members with biosolids knowled e.. April 2009 CFE memo to Board conveyed suggested a joint multi- disciplinary task force to examine several topics and issues. Topic is held until fall due to ressin bud et matters Spring- Several media stories on biosolids application and resident Summer concerns in area newspapers. 2009 April 2009 Health Department meets with DWQ, BREDL, OCPD to discuss chan es to coun notification rocess and ermittin issues. Summer Health Department meets with UNC and learns funds inadequate 2009 for stud , be ins tannin for re Tonal forum. August 2009 Proposed regional forum funding concept placed on BOCC agenda, CFE memorandum asking that joint task force concept be considered. ~ Biosol~d Appl~,cation Sites, 2Q~8 ~~~~,• ,, ~ ~ + ~ ! ; ~~.:.».,,,, e~''~~ ~`~ i ~ •~•~3':• . . ~ l ~1. .,. ~ . .. J~~.` ~i' ,1~ ~ ... ~• ~~ a. . S r .. ~ ~ a< : ' ~ ~'~~ ~ ~ ~,. ~ f ~t ~, . ~ f .. ~ ~ . ,w ^' • + :' . r.. . ~ ~ ` . ~ , . ~ ~~ ~ .. hE « • . `'e~ '~ . K ~~Xr~~"~: ..... 'I ~ ~, ~~I' ~~ ~~"i . ! J t' r~. + 1 Ty ~ ~ : _ / . ~ ;~~ n , '. ~~` •' ~ 1 2 4 Miles f J i ~ i , Y ~ ~ II 9 N , i 4 ~ I~W .~~4~ ;,~ •~ ~~ ~_ ~;,,,••~,,,v:~ ti,!`~`~:~ ~.,,$ l I J, ,1,~ l 1 1 ~ ' ~ t i ..~ 4 f. d . . , +~ ~ . , . 1~ . ~~., t, '.+. ~ i ~, . . . . ~ . . ~, ~ r . . ..i . .r ~:. ^':~+e; :.. .~~. f' ~~ . # ;.~`''••.~ " "~" BIC}SOLII7 FIELDS ~ ~. . ~. ~ Burlington ackive - 404.8 acres '~ . ""' ` Burlington inactive ~-. '~ ;~ , *t; { •.' x . , .' . r ~ . .. .. ` _ . : Caty irtaCtive 115 i 1 3 ~, ~ :. : arres . ve - , ~ Dnrhazn act t, ...,._ ci, ; . ~'; ~ [~ Qarham inactive ~ ... , ,M..~.., ~-` `""``'"'~+^~•~.1~~' F: Hillsbvraugh active- 377.1 aeres ti~ ~~, ~iitls8ara~ugh inaCtive , " ," ~"~ ~ '~ r'-'~ ~ ~ tlrtebane actirre - 248.Q acres ~ Y . .; . [~ Mebane inactive ,• ~~; ~ • ~r .~ - ' •~ ~ > _ ~ ~ ~ ' ~ C3WASA active - 563.45 acres :%'.. - ~ % = ••~ ~`~Y-~~ ~....._~..._.i t?WASA inac#ive '~ ti .4i ,rt ~'~' WATER5HED ~ 4 ...: ~ ~ Critical j , ~~ "' ProE~eted ~ ~ 4. r t'' '°` ~ ~ `M .., _, ' ``- ; ., ~ ~.,, ` [~ Unprc~Eected / ~4 n 8 ~~ `..~ ;'` ~ ~ tr.. . . ~ ~,: s '~ V F ~rwf~, : . ( s~i " . _ Major streams arroads Ma . ~ " ..~.s ~;.. .~ ' -:' j ~ ~ , ~ ,..~-, : r•' `' ~ i, ~ Reservoirs & lakes D ~ ,~ ~ . '~~` ! •~ ~~", ' ` { ~ Active fields ~~ ,,,,~ , < t u~ ~ ~ ~ j._ ,• Fields are on the current DWQ permit T? ~ ~ 4 ~M . ~~ ~ ~ ~~ . : r ~ and are available fvr bios~iids agpiicatioi ~ ~.. ~ r t \~; 1 ~~..A~ '••, ~ " InarHve fields f.4...•• ti y ..~~~ t ~ ~ f f S,ti. r~ . .s '` •.,:. Fietds are no longer ott the current DWQ { ~~ ""s ~ '`•--~,..,,,., +~: -~ ..;,,3~,,,~ . ; ` ~ permit bnt have had biasolids applied tv :;'~y~,~'.+ ` . the field in the past. ''~ ~~`" ~•..~ •'` ~~r; _f ~.. ..' t , `~~ ~. ~ ~.. ~ j . ,' . ~ . _•. ~ ~ .. ; ~ _ ~ ' . ~ ;:. } , "_ , _ . '_ .~ <'.s ." ( , f~ ` ;; ~ ', ,., , ~ _ Orange Couaty ERCF7 „ 5/28J~,009 ~~re MEMORANDUM ~~~ ORANGE COUNTY HEALTH DEPARTMENT Rosemary L Summers, MPH, DrPH Healli~ Director Richard E. Whiffed Human Services Center 300 West't'ryan Street Post Office Box 8181 Hillsborough, NC 2727$ Phone: (919) 245-2411 Fax: .(919) 644-3007 w w t v. c o. o re n o e. n c. us/h e a It h Central Administrative Services Dental Health Sen~ices EnvironmentaE Health Services Health Promotion and Education Services Personal Health Services 306-C Revere Road P O Box 8181 Hillsborough, NC 27278 Phone: (919) 245-2360 FAX: (919) 644-3006 ~_ `a$ >" a E c I? .~ u1 To: Laura Blackmon, County Manager From: Rosemary Summers, Health Director Date: March 10, 2008 Re: Biosolids Program in Orange County CC: David Stanch, Environment & Resource Conservation Director Gwen Harvey, Assistant County Manager Willie Best, Assistant County Manager Tom Konsler, Environmental Health Services Director Board of Health In response to questions that may arise from some of the public comment at the BOCC meeting last night, I thought it might be helpful to outline the level of county involvement in the application of biosolids in Orange County. Biosolids are the digested and treated solids that result from the wastewater sewage treatment plant process. This byproduct contains a significant amount of nutrients that are beneficial to plants ,and are commonly land-applied to agricultural fields as a useable resource. There are regulations and a permitting process that -govern this practice due to the potential for adverse environmental or public health effects if it were otherwise unregulated. There are two classes of biosolids, Class "A" and Class "B". All of the utilities in this area produce Class B biosolids. Some, such as OWASA are considering a higher Ievel of treatment to meet Class A standards. This would reduce some of the regulatory requirements, pose a Iower risk to the environment, and may improve public acceptance of the practice. The state Division of Water Quality (DWQ) in the Department of Environment and Natural Resources has regulatory and permitting authority for: • wastewater systems that apply treated waste to the ground surface, • treatment plants {both public and private) that discharge to surface waters, and • biasolid sites. The rules that govern biosolids are adopted by the North Carolina Environmental Management Commission. Orange County is one of only a handful of counties that have any local involvement in the oversight of biosolids activities. In the early 1990's the Orange County Board of Health adopted an expansion of the wastewater system regulations to include local monitoring and reporting of several system types permitted through DWQ. This Waste Treatment Management Program (WTMP) administered by the Environmental Health Services staff of the Health C:\I?ocuments and Settingsltkonster\L.ocat Settings\Temporary Internet 3iosolids Summary 031tX18.doc "-~. .~ Page 2 biosolids Memorandum March 10, 2008 Department includes monitorine tracking and oversight of biosolids activities within the county. Specific responsib~lrties include -" • a requirement for notification from biosolids appliers, • on-site inspection of the fields and the activities during application of biosolids to assure compliance with the regulations and guidelines, • notification of the applier, the permitee, and DWQ in the event compliance issues are discovered, and • response to complaints or emergency spills. The state permitting.process requires the applicant of new sites to notify the county manager of their intent to apply for a permit. Environmental Health is notified after the sites are permitted by the state. It is my understanding the OC Planning Department has some land use restrictions in certain areas of the county that may preclude an application from going forward. Environmental Health's involvement in the biosolids monitoring has brought about many changes in these practices. Inspections in the early years of the program revealed regular non-compliance with the permit requirements.. For the most part, those issues have been addressed with education and the applier's knowledge that these activities are subject to inspection and reporting. Sites that are permitted to receive biosolids from OWASA, Burlington, and Mebane are well managed and operated. We continue to get resistance from Hillsborough and from Durham to report any activities, so their compliance remains unknown. In December of 2006, the BOCC approved funds for the OCHD to enter into a contract with LJNC School of Public Health to conduct a pilot study of biosolids applications and methods of measuring potential effects on the environment and health. The health department and UNC have encountered difficulties in identifying an acceptable site to study. While Burlington and Mebane have been approached and have agreed to cooperate in such a study, same apprehension by landowners, as well as the drought conditions, have hampered the initiation of the study. Regarding the future of this program, health department staff along with the Board of Health will begin discussions later this year with DWQ to consider entering into a Memorandum of Agreement with DENR to~formalize some of our existing activities and possibly to expand our plan review, monitoring and reporting activities. Any direction that the Board of Commissioners would like to provide regarding this expanded role would be welcome. Please feel free to contact either Tom Konsler or me with further questions C:\Documents and Settingsltkonsler\Local Settings\Temporary Internet FileslOLKC\Biosolzds Summary 031~8.doc Memorandum To: Board of County Commissioners From: Commission for the Environment Date: April 21, 2008 Re: City of Burlington Biosolids Permit Renewal Public Hearing In response to a citizen petition at the March 6 Board of Commissioners meeting, the Commission for the Environment (CFE) has discussed the upcoming Division of Water Quality public hearing for the City of Burlington's biosolids application permit renewal. This hearing appears to now be scheduled for May 13 in Graham. In so doing, the CFE reviewed Health Director Dr. Rosemary Summers March 10 memorandum, and research performed by a CFE member. The CFE feels that a considerable amount of additional information and data is needed to speak knowledgeably about the permit application -and about the ecological and human health issues related to biosolids. However, the Commission would like to forward the following points and ideas for consideration: 1. According to our GIS maps of active biosolids application sites, there appear to be a few sites within the critical areas of Orange County's protected watersheds. These include the Burlington application sites within the Cane Creek watershed and active OWASA application sites within the Upper Eno critical watershed. Under the County's watershed zoning standards, biosolids application is not permitted within the critical area. We do not know if these particular sites are among those proposed for renewal, or if they are "grandfathered" in, but would suggest any re- permitting by the State exclude these properties now and in the future. 2. Based on the publicly available research, the potential environmental and health risks have not been adequately quantified, particularly with regard to organic toxic compounds (such as dioxins, furans and PCB's) and pharmaceutical residues, as these compounds are not subject to regulation. In addition, there appears to be a paucity of current local data both characterizing the compounds present in Burlington's sewage sludge and content of toxic compounds in amended soils -making evaluation of the safety of biosolids application impossible. The CFE proposes that the Health Department and UNC School of Public Health study that is referenced in Dr. Summers' letter be expedited if possible, possibly using County-owned lands, to help address some of these questions. 3. As mapped, biosolids application is widespread in the County, with almost 3,000 acres of permitted sites receiving biosolids application from six different municipal wastewater treatment facilities including: Durham, Cary, OWASA, Burlington, Mebane, and Hillsborough. 0 9 4. The CFE is supportive of further research and discussion about biosolids application, including consideration of possible additional measures in water supply watersheds, and the planned Health Department discussions with NCDWQ about expanding the County's capabilities for review and monitoring. The CFE would appreciate allowing Commission representatives to be part of these discussions if they are pursued. 5. The CFE recommends the County Commissioners request data on the chemical composition of any biosolids being proposed for land-spreading from each wastewater treatment authority. In addition, perhaps State legislation could be considered that requires chemical analysis of wastewater biosolids (pre-application) and soil testing (post-application), for metals and key organics, to learn more about the chemical nature of what is being applied to the land in Orange County. 6. As a large amount of land in Orange County would be affected by this application, a second public hearing held in Orange County would allow for fuller public discussion. In summary, thousands of acres in Orange County are affected by a land application process that does not appear to be widely understood. Greater research into the subject appears warranted, and the CFE would volunteer to work with the Board of Health and other groups in such an effort, if pursued. Thank you for the opportunity to comment on this question, and we look forward to continued dialogue about this complex topic. Copies: Laura Blackmon, County Manager Willie Best, Assistant County Manager Dr. Rosemary Summers, Health Director Tom Konsler, Environmental Health Services Director Craig Benedict, Planning Director _. ~ - - .. ~ ~.Lo BaRRYJACOes, GHrvR ORANGE COUI~ITY BOARD Off' COIvINIISSIOI~IERS 1/ALERIE P. FOUS{iE~ V/CE•4`HA1R Moss ; ~R POST OFFICE Box 81$ ~ AucEM. GO14Dd^' 200 SOUTH CAMERON STREET MIKE NELSON HILLSBOROUGH, I~IORTH CAROLINA 27278 May 8, 2008 Dianne Reid Hearing Office Basinwide Planning Unit Supervisor, Planning Section N.C. Division of Water Quality \°rt Re: May 13, 2008 City of Burlington Residuals Land Application Public Hearing For several years, the Orange County Board of Commissioners' State and Federal legislative agendas have included requests for increased local oversight of biosolid application: We consider this a public health issue of considerable importance. ~aa ~~r~% Then, on March 6, 2008, a representative of the Blue Ridge Environmental Defense League addressed our board regarding an upcorn.ing public hearing for renewal of a wastewater biosolids application permit for the City of Burlington, including•lamd application within Orange County. The matter was subsequently reviewed by the Orange County Board of Health and the Orange County Commission for •the Environment. As part of this review, we learned that more than 3,000 acres withuz Orange County are shown as approved biosolids application sites. Of that amount, approximately 404 acres are subject to this permit renewal. Based on our review, the Orange County Board of Commissioners would like to make the following points for the public hearing: 1. Many questions have been raised about the potential health risks associated with biosolids application, and these questions appear to remain unanswered. There are several national and local studies underway; including a pilot study jointly funded by the UNC School of Public Health and the Orange County Health Department on a site in Orange County yet to be determined. bVWW. CO.Orange.nC, US Profecting and preserving -People, Resources, Qualify of Life Orange Gounfy, North Carolina -You Gounf.- {919) 245-293 a F~UC {919) 644-024fi ~~ ri 2. With better than 400 acres land in Orange County affected by this application, the Orange County Board of Commissioners respectfully requests a second public hearing be held in Orange County on the City of Burlington's application request. This would allow for fuller discussion and comment by Orange County residents who tray not be aware of the May 13 hearing in Graham.. 3. Orange County's Zoning Ordinance prohibits the land application of biosolids within water supply watershed critical areas. It appears that some of the Burlington biosolids application sites lie within the critical area of the Cane Creek Reservoir watershed, which provides drinking water to Chapel Hill and Carrboro area residents. While the County is aware that the State has the power to permit biosolid applications notwithstanding County watershed protection regulations, we do not think it should do so, particularly in watershed critical. areas_ The Orange County Board of Commissioners expressly and respectfully requests that yqu not permit oz repermit any City of Burlington application site Located on land within a water supply watershed critical area, as designated on the laud use planning documents adopted by Orange County. Membexs of Orange County's staff will attend this public heating and provide maps necessary for your consideration of this request_ 4. 1?urther, we respectfizlly request that prior to approving a modification of an existing permit for a new land application site, the Orange County Environmental Health Services Division of the Orange County Health Department be informed of the proposed new application site, in order for it to better monitor'the potential for harm to the public health. Thank you for receiving our comments, and for respecting our concerns. We look forward to your reply. Sincerely, Barry Jacobs, att~ Orange Co Board ~pF WATFR4 ~~ • ... }_ f3 • _ ~ MIchael P. Easley, Goveraot YVili~m O. Ross h'., Secretary ~ ~~ North Carolina Department of ESnvironmen! and NaturaE Rzsouzces Coleen T-L Sollins, Tkrector Division ~ Water Quality May 28, 2008 Barry Jacobs, Chair Orange County Board of Commissioners Post Office Box 8181 Hillsborough, NC 27278 Subject: Public Hearing on City of Burlington's Application Permit WQ0000520 Dear Mr. Jacobs: After reviewing the points submitted in the Board's letter presented by David Stencil, Director of Bnvironmental Resources Department in Orange County at the public hearing on Burlington's permit renewal; the Division does not find that a second public hearing is. needed in Orange County. Your points will be considered in the formulation of final determinations with regards to'this permit. Please note that the written comment period vVas extended and ends May 30, 2008. You may email additional comments to Ed..HardeeC~ncmail.net. Regarding the concerns related to Gounry input into permitting and compliance, there have been Borne discussions between Jay Zimmerman of our Raleigh Regional Office and Tom Konsler with the Orange County Environmental Health Department on entering into a Memorandum of Agreement. This would provide the County with additional input into permitting and compliance. The Board of Commissioners may want to carisider this option. The Division has worked with the County Environmental Health Department in the past and looks forward to doing so in the future. Thank you for your comments and information provided at the public hearing. sincerely Dianne M. Reid cc: Coleen H. Sullins Ed Hardee Norfh Carolina Divisioa of Water Qaallty i 6I7 Mail Service Ceatet Ralagk, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: www.ocwatergnali .orE I.acation: 512 N. Salisbary St. Raleigh, NC 27604 Pex (919) 733-2A9b F-877-623-6748 M Equal Opportunlty/ARtrmfltNe Adiat EmployAr - b096 Aecydedll096 Past Consumer Pepar 13 W- F GUl1~~V1~~-S~C7N f~"C~~THE.~IVVI~?C~~M~1~1"T' ,: , ^ {~ {'~ :: t. MEMORANDUM To: Board of County Commissioners From: Commission for the Environment Date: April 20, 2009 Subject: Land Application of Biosolids in Orange County The Commission for the Environment (CFE) has been discussing the issue of biosolids application in Orange County and has identified areas of concern that pertain to the CFE's charge of advising the Board of County Commissioners (BOCC) on matters related to the protection of the county's natural environment. The CFE recommends that the BOCC receive this information and consider appointing amulti-disciplinary task force to examine environmental and public health issues and develop recommendations for the County to include in the proposed Memorandum of Agreement with the NC Division of Water Quality. The CFE is interested in having representation on this proposed task force. This recommendation follows our April 2008 memorandum to the BOCC regarding issues related to biosolids application, and the renewal of the City of Burlington's biosolids application permit. A copy of that memo and the Board's subsequent response to the NC Division of Water Quality (DWQ) are attached for your reference. As a point of further reference, a May 28 letter from DWQ notes that a memorandum of agreement between DWQ and Orange County is being considered at this time. Biosolids application continues to be widespread in the County, with over 3,000 acres of permitted sites receiving biosolids from five municipal wastewater treatment facilities: Durham, OWASA, Burlington, Mebane, and Hillsborough (a map of the site receiving biosolids in Orange County is attached). Preliminary data compiled by the UNC School of Health indicate that permitted land in the County is receiving upwards of 17 million gallons of biosolids per year, which equals an average rate of 5,000 gallons per acre per year. At least one site is located within the critical area of the Cane Creek protected watershed. The CFE believes that additional information and data is needed to better understand the potential affects of biosolids on the environment and on human health. The following are some of the issues that are of particular interest to the CFE and may be relevant for further consideration: - The application of biosolids on farmland in critical watershed areas. ~4 - The unknowns surrounding the composition of biosolids which are being applied to land in Orange County - The potential affects of biosolids on air and water resources (groundwater and surface water) - The ability of soils to assimilate compounds and metals - The apparent lack of public information and awareness of some of the sites where biosolids are being applied - The question of whether NC counties have authority to control or manage the application of biosolids - A 2005 report from the NC Deptartment of Health and Human Services that discussed risks to human health including concerns with: • nitrate contaminated groundwater in areas of biosolids application; • agronomic application rates governing the application of biosolids; • the criteria used in siting biosolids application sites; • monitoring of biosolids application sites, and • odors at biosolids application sites - The 2009 Targeted National Sewage Sludge Survey Report from the US Environmental Protection Agency, which documents some of the compounds present in treated sewage sludge from selected water treatment facilities across the United States. Quoting from the overview of the report, `The information will help the Agency (EPA) in assessing if exposures may be occurring and whether those levels in sewage sludge may be of concern." - The recent inclusion of Collins Creek on the State's draft 303d list of impaired waters, given that Collins Creek is located outside of the Chapel Hill/Carrboro urban area (where all the other impaired streams in Orange County are located), and is in a basin that contains a number of fields that are subject to the application of biosolids' The CFE would like to acknowledge the information on this subject it has received from Tom Konsler (Orange County Environmental Health Services Director), Sue Dayton (Blue Ridge Environmental Defense League), Ed Holland (Orange Water and Sewer Authority), and a number of Orange County and area residents that have attended recent meetings, and thank them for their assistance. Thank you for the opportunity to comment on this question, and we look forward to continued dialogue about this complex topic. Attachments Copies: Laura Blackmon, County Manager Willie Best, Assistant County Manager David Stancil, Environment and Resource Conservation Director Dr. Rosemary Summers, Health Director Tom Konsler, Environmental Health Services Director While this may or may not imply that biosolids is a partial factor in this rating, we think it worthy of further review. ~~ ORANGE COUNTY ``/~~Y 1 BOARD OF COMMISSIONERS ACTION AGENDA ITEM ABSTRACT Meeting Date: August 18, 2009 Action Agenda Item No. L{- - q SUBJECT: Land Application of Biosolids Re ionat Forum 2009 ~~ DEPARTMENT: Health PUBLIC HEARING: (Y/N) No ATTACHMENT(S): INFORMATION CONTACT: Planning Summary: Biosolids Forum Rosemary Summers, 245-2411 PURPOSE: To authorize redirection of funds from conducting a biosolids research project to an educational forum on land application of biosolids. BACKGROUND: In 2006, because of community concerns about the effects of biosolids on health, the Health Department reserved $10,000 from its operating budget for a research study to get more information about air and water quality in an area surrounding a biosolid application site. The Department developed a service agreement with Dr. Mark Sobsey, an Environmental Sciences and Engineering professor at the UNC Gillings School of Global Public Health for this study. The agreement was to conduct a pilot study in Orange County to determine air and surface water characteristics before and after the land application of Class B biosolids. There were a number of barriers encountered along the way to designing and conducting this study. These barriers included: • Small amount of funding limited the study to graduate student availability on an academic schedule. • Denial of a grant submittal that would have been used to leverage the available funding from Orange County. • Alternate faculty member that was interested in supervising the student changed academic institutions. • Securing permission from two suitable sites' landowners for voluntary participation in the study. • Identifying an alternative permitted application site with suitable geographical considerations (nearby stream). Two sites had landowner permission but were not suitable geographically. • Drought conditions during 2007 and 2008 were not conducive to commencing the study. In the summer of 2009, Health Department staff met with several UNC faculty members in Environmental Sciences and Engineering to determine whether this study would be able to COPY ~b move forward. The faculty members believe the amount of the funding is not adequate to carry out the study and to ensure the quality of the study. Community interest and concern regarding the topic of biosolid application to land remains high in certain areas of the County. Community activist groups have sponsored various listening sessions and distributed materials that advocate for specific policy changes at the state and local level based on the materials and information they have acquired. The Health Department is requesting permission to redirect the research study funds ($10,000) to support costs for holding amulti-county conference/forum on land application of biosolids. The forum would educate participants about various aspects of the current practice of land- applied biosolids from wastewater treatment plants. Both state and nationally recognized experts will present sessions on technology, research, health and environmental risk management of current practices. Afield tour of a local biosolids processing facility and an application site will be offered on a second day. The attached sheet outlines preliminary thoughts from the planning committee. The Planning Committee includes: • Tom Konsler/Greg Grimes, Orange County Health Department, Environmental Health Services • Dr. Fletcher Barber, Orange County Cooperative Extension Director • Dr. Jeff White, North Carolina State University Soil Science • Dr. David Lindbo, North Carolina State University Soil Science • Dr. Chip Simmons, North Carolina State University Bio-Ag Engineering • Gail Hughes/Kenny Ray, Orange County Soil and Water • Jon Risgaard, Department of Environment and Natural Resources, Division of Water Quality • Carl Carroll, Alamance County Health Department, Environmental Health • Andy Seignor/ Terri Ritter, Chatham County Health Department, Environmental Health Tom Konsler and Greg Grimes, Orange County Health Department -Environmental Health Services, are providing staff support for the Planning Committee. County Enviromnment & Resource Conservation Director Dave Stancil and Planning Director Craig Benedict have also been briefed on the upcoming forum so that their boards .can be appropriately advised and encouraged to attend. Re-direction of these funds would be used to defray the costs of the forum to keep registration fees low and encourage widespread attendance. Funds will support travel or honorarium costs for speakers, lunch, breaks, transportation to field sites, marketing, materials preparation, sound system. A specific budget will be developed as the planning committee finalizes the agenda. FINANCIAL IMPACT: The funds were encumbered in 2006. Redirecting their use would not affect the 2009-2010 Fiscal Year budget. It is likely that the entire amount will not be needed for this forum. Any unexpended portion of the $10,000 would return to the general fund (approximately $4,000). RECOMMENDATION(S): The Interim Manager recommends that the Board approve the re- direction of funds for the biosolids research study to support acommunity-wide biosolids forum in an amount up to $6,000 with the remaining portion returning to the general fund. ~:QPY ~''g Conference Planning Summary through July 30 Land Application of Biosolids Regional Forum 2009 Objective: To provide accurate information on land application of biosolids from wastewater treatment plants that includes current best practices based on research and current scientific knowledge. Co-sponsors • OC Health Department • OC Cooperative Extension • NCSU • UNC SPH • Chatham & Alamance County Health Departments • DENR • OC Soil & Water Target Audience: • Interested community members and residents • Industry -biosolids appliers and producers • Regulatory -local and state agency • Policy -planners, commissioners, boazd members • Owners of land being used for biosolids applications Target audience size is 75 -100. Meeting room has capacity for 185. Limitations on field tour numbers will need to be discussed (Field Tour limited to 50?) Conference location: Orange County Southern Human Services Center 2501 Homestead Rd. Chapel Hill http://www.co.oranae.nc.us/gis/locations/index asp~ServiceID=97 (reserved) Date(s): • October 7~' ,2009 from 8:00 - 4:30 • October 8th , 2009 from 8:00 -12:30 -Optional Field Tour Field Tour • OWASA WW Treatment Plant -Could run two groups of 20 ppl each concurrently • OWASA Biosolids Application site -subject to schedule, equipment location, weather • Hillsborough & Burlington also asback-ups • In. case~of inclement weather, OWASA has a prepared presentation demonstrating their WWTP and Biosolids treatment/application program Funding Source • . Possible funds from area health departments • Registration fee - $10 per person to cover lunch and breaks ~tL*'~"~ '$~ Draft Agenda Land Application of Biosolids Forum 2009 October 7 -8, 2009 • Welcome and introduction of the Iocal issues 8 - 8:15 • Treatment PIant Process and Management 8:15 - 9:45 • Description of WWTP Technology focusing on Biosolids treatment • Understanding the process • Options available for Biosolids management • Alternatives to land application • Testing requirements and performance standards • Class A vs. Class B • Regulation of Biosolids in NC 9:45 -10:45 • History • Current practice • Future • Statistics for NC • Science behind the regulations • Break 10:45 -11:00 • Report from US EPA 11:00 -12:00 • How EPA recommendations are established and revised • Future of Biosolids • Emerging contaminants -metals • Lunch - On-site 12:00 -12:45 • Research Summary 12:45 -1:45 • A summary of research that has been published or is planned for Biosolids handling to address the following aspects:agronomic, environmental ,soil, water, air, health • Health and Risk Management 1:45 - 2:45 • agronomic, environmental ,soil, water, air, health • Break 2:45 - 3:00 • Panel Discussion ~ 3:00 - 4:15 • Conclusion 4:15 - 4:30 October 8~, 2009 (Optional Second Day) Meet at Southern Human Services Center 5:00 Session 8:15 -12:45 Bus 1 to Cane Creek /Headwaters Biosolids storage and application site Bus 2 to OWASA WWTP (Buses flip locations for 2nd half of the morning and end at SHSC). 19 ol~n~~~ ~c~ul~. ~:_~~ . Ct~MMrSSIC31y _F`Ca-R'T'IHE EY~,IV~RC)1411~1~~1'T' ;-.. ~,_ MEMORANDUM To: Board of County Commissioners From: Commission for the Environment Date: August 18, 2009 Subject: Biosolids Forum Proposal At the August 17 Commission for the Environment meeting, the Commission added an agenda item to discuss the recently-received August 18 Board of Commissioners agenda item entitled "Land Application of Biosolids Regional Forum 2009." With regard to this proposed agenda item, the Commission unanimously adopted the following statement: 1. The Commission for the Environment recommends that the Board of Commissioners reserve the funding for the proposed biosolids research study, .pending further discussion of the topic. 2. The Commission asks that the Board also consider the creation of a joint multi-disciplinary task force to examine the topic of biosolids application in further detail, as recommended by the Commission in its April 20, 2009 memorandum (attached). Thank you for your consideration. Attachments Copies: Frank Clifton, Interim County Manager Willie Best, Assistant County Manager Dr. Rosemary Summers, Health Director Tom Konsler, Environmental Health Services Director