Virginia Regulatory Town Hall
Agency
Virginia Department of Health
 
Board
State Board of Health
 
chapter
Biosolids Use Regulations See Virginia Pollution Abatement (VPA) Permit Regulation at 9 VAC 25 - 32 [12 VAC 5 ‑ 585]
Action Enforcement and Site Management
Stage Proposed
Comment Period Ended on 12/15/2006
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12/8/06  12:00 am
Commenter: Kevin Martin

Storage and Application of Class B Biosolids
 

Looking at specifics of the proposed regulation changes show things like

  • Section 3.c.(1).(a), which states "Biosolids are surface applied...beneath a living crop..., or timely planted small grain cover."  So what is "timely planting" to a farmer whose time is already stretched thin?  Maybe a day, maybe a week, maybe a month, maybe spring comes and it doesn't really matter any more because the sludge has already washed into the creek.
  • Section 3.(d).2, discussing buffer zones, states the "commissioner may impose standards that are more stringent...prevent nuisance conditions from developing...."  Most people would agree that an odor that precludes them from enjoying their yard, and which dramatically reduces the sale-ability of their home would, at a minimum, qualify as a nuisance.  But the commissioner may (or may not) choose to do anything to mitigate this impact on residents surrounding the application/storage site.
  • Section 3.e. states that "Groundwater and surface water and soils monitoring and testing may be required...for any frequent application sites...."  The statement makes it clear that sites reaching agronomic rates more than once in three years have an increased potential for environment or public health concerns. But monitoring and testing to ensure that the public health is not being harmed "may" be required.

The list could go on and on.  But one thing is completely clear, these regulations are aimed at facilitating the disposal of Class B waste, not protecting the welfare of Virginia's people and natural resources.

CommentID: 346