EPA Electronic Reporting Training for Biosolids Generators

EPA, National (11/26/18) - This information comes from our West Coast colleague at Orange County. At our MABA meeting, we learned that the EPA has seen many mistakes with public agency electronic submissions of Part 503 Annual Reports. What is more, the system is still under development. The EPA has organized trainings to assist biosolid users to electronically report their annual Biosolids data. The 2018 Biosolids Electronic Annual Program Report Training will provide participants with an overview of Biosolids Annual Report and background information to the eRule and how it affected the development of the Electronic Biosolids Form.  The training will explain access request process as well as provide a demo of how to complete the Electronic Biosolids Form.

Two things:

  1. EPA database training is coming up for their new online form (updated 2018). See dates below. I haven’t seen anyone communicating this info, but I may have missed it, so I just wanted to make you aware.

  2. Training sessions are important, especially this year because EPA has added an additional reporting requirement for POTWs to put in third-party handling data:

This is my biggest concern with the new EPA report form. We pulled some text from the new Biosolids User’s Guide and pasted it below. I read it to mean a BIG change from previous electronic reporting year’s where POTWs entered ONLY our own biosolids analytical data, and now they want us to enter the land app / composter’s data also! We have mentioned this to Lauren Fondahl when I noticed this new section in the EPA beta test form. We were hoping it would become optional, but it doesn’t seem optional based on the info below. This will add a LOT of work to completing the forms, no mind the duplicative work since many POTWs will be entering the Same data plus the composters are also entering their data.

Facilities that use a third-party handler, preparer, or applier will need to obtain the reporting data to successfully complete the Annual Biosolids report. For example, if a POTW selects “Land Application / Agricultural Land Application / Bulk / Third-Party” it will be required to enter data for the compliance monitoring events. The POTW may need to contact the third-party handler, preparer, or applier to complete the report.

It is important to note that you should select “Off-Site Third-Party Handler or Applier” or “Off-Site Third-Party Preparer” in scenarios where you generate sewage sludge, but another separate entity provides a service to handle or prepare your sewage sludge. This is often done by commercial enterprises offering services for sewage sludge handling and preparing (e.g., composting) and/or management (e.g., land application, surface disposal, incineration, or other management practice such as disposal in municipal solid waste landfill). A key distinction used in the form is that the third-party handler or preparer is an entity that takes full possession of the sewage sludge from the POTW and makes decisions independent of the POTW regarding the handling, preparing, and ultimate management of the sewage sludge received from the POTW.