Requirements for Biosolid Applications on Cropland in Mississippi

Most growers know the soil benefits from applying animal manures to their land. Some farmers have used municipal sludge (biosolids) as a fertilizer to provide nutrients and organic matter that improves soil properties. The biosolids have been treated to stabilize organic matter and reduce pathogens, they are not raw sewage. Often other solid wastes become available to growers and may be land applied. The rules and regulations may differ from state to state, this is the Mississippi situation.

Land application of animal wastes are addressed by MDEQ water quality permits that follow Nutrient Management Plans usually developed in Mississippi by the Natural Resource Conservation Service (NRCS) for submission to MDEQ administration. Those plans follow Best Management Practices as described by the NRCS Conservation Practice Standards.

Who and what:

The permitting agency for land application of other solid waste in Mississippi is the Department of Environmental Quality. The pathways to permitting as a soil amendment for either fertility or soil conditioning depending on the properties of the material.

Regulations define biosolids, as treated municipal sewage sludge, with potential land application uses as either Class A or Class B. Class A, or ‘exceptional quality’ biosolids have low metal contents, low or nonexistant pathogen levels, and there is little risk of odor issues or attracting pests. Class B biosolids may have a higher pathogen content, but they meet minimum regulation requirements, and can be used to fertilize crops or as soil conditioners.

Materials not prone to creating odors or other nuisances potentially may be applied under a BUD that can be requested by the material generator, an entity distributing it, or the end-user. This route has been used for some paper mill by-products, wood-fired boiler ashes, and other materials.

If a material is malodorous, or has other potential issues, such as elevated concentrations of potentially toxic elements or other contaminants, a site-specific solid waste permit will be required as do Class B biosolids.

These materials usually require a site-specific solid waste management permit. However, if it is categorized as a Class A/exceptional quality sludge, the entity generating or distributing it may request a non-site specific Beneficial Use Determination (BUD) prior to land applications. BUD material may then be spread for agricultural use under recommended application guidelines without a site-specific permit.

Class B biosolid applications may proceed if requested under the statewide general permit, or through an individual permit for a specific site. The individual, site-specific permitting is suitable if the proposed location has conditions or needs that need to be addressed with an individual permit.

Permitting requirements may vary for other nonhazardous materials, but there must a benefit to the receiving soils. This is an important point for producers and landowners, your land becomes a landfill if there is no positive agricultural benefit.

Mississippi Biosolid Permit Requirement Details:

General permits pertain except where individual, other general permit, or BUD are more appropriate. Applications under general permits are limited to Class B biosolids and must comply with the monitoring and analysis requirements.

They are to be applied on the site on the delivery date and soil incorporated or subsurface injected, unless otherwise approved. Applications is to be safely above the water table nor the floodway or within a 100-year flood plain (Nov – April).

Applications are to be setback 300 feet from inhabited residences, 200 feet from the property line, and 250 feet from the edge of surface waters, unless specifically approved. They are not to be applied on delineated wetland areas unless approved by the Army Corps of Engineers and/or NRCS.

Unless otherwise negotiated, the frequency of sludge analysis depends on the quantity applied at a site each year. Maximum application rates depend on the crop to be grown, and are based on the maximum plant available nitrogen applied (pounds/acre/year). Deviation of rates due to double cropping require MDEQ preapproval. The concentration limits and lifetime loading rates of various potential pollutants are listed in Table 1.

Soil is to be monitored each year that sludge is applied, after the final application of the year, or on otherwise previously approved schedule. Required analyses are pH, nitrate, total arsenic, total cadmium, total copper, total lead, total mercury, total nickel, total selenium, total zinc, and fecal coliform. In the absence of specific authorization otherwise, soil pH is to be maintained at 6.5 or greater.

The permit holder is to maintain records of sampling information including who took them, when the analyses were performed, the laboratory used, analytical methods, and results. Records are to be kept of the date and field areas where applied, the quantity and source of the biosolid, and crops grown. Any contracts between permittee and contracted operators should be provided to MDEQ upon request. Annual reports are due to the agency on or before February 28 of each year.

To reiterate, this information is for biosolid applications in Mississippi. For more information, contact the Permits Branch of the Mississippi Department of Environmental Quality.